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BeginnerBrazilian REITs · Lesson B2.2 · Module B2

Administrator: the owner on paper

Module B2: Who runs the fund

10 slides~4 minquiz at the end

In this lesson

  • Who can be an FII administrator
  • The fiduciary owner's duties
  • Resigning: how long it stays liable
See the slides
Keys in the lock of a white door

FIIs · Lesson B2.2

The administrator: owner on paper

The properties are in its name. So is the responsibility.

Who can do it

Only licensed institutions run an FII

  • Bankscommercial, investment and multiple banks with an investment or real estate lending arm
  • Brokers and distributorsof securities
  • Real estate lendersreal estate credit companies and mortgage companies
  • Savings bankssuch as Caixa

Always with a statutory officer in charge. CVM Resolution 175, Annex III, art. 25.

The job

Four duties that are its own

  • Record it on the deedthat the property doesn't answer for its debts
  • Check the appraisaland answer for it if the value is false
  • Reportfilings and audited financial statements
  • Call the meetingwhen unitholders must decide

CVM Resolution 175, Annex III, arts. 9, 30 and 36.

The rule as of 09/2026

Who answers for the properties

Managing the properties falls to the administrator, because it is the fiduciary owner.

CVM Resolution 175, Annex III, art. 26 § 2. The CVM proposed splitting duties differently with the manager (Public Consultation SDM 06/2025); no new rule yet.

Resigning is not running away

It leaves only when the successor is on record

  1. Mar 1Resignsannounces it will leave the fund
  2. May 20Meeting elects a successorunitholders pick another one
  3. Jul 15Recorded on all 12 deedsonly now do its duties end

Illustrative example. CVM Resolution 175, Annex III, art. 34.

The common mistake

It's not a paper pusher

The myth

  • Just stamps paperwork
  • Answers for nothing

The rule

  • Fiduciary owner of the properties
  • Answers for the appraisal
  • Breaching a duty is a serious offense

CVM Resolution 175, Annex III, art. 46.

Keep this

Three takeaways

  1. A licensed institutionOnly banks, brokers, distributors and similar, with an officer in charge.
  2. Fiduciary ownerRecords, checks appraisals, reports and answers for the properties.
  3. No quick exitA resigning administrator stays until the successor is recorded on the deeds.

Quick quiz · 1 of 2

Can a payments fintech that isn't a distributor administer an FII?

See answer

No. Annex III, art. 25 lists who can: banks, brokers, distributors, real estate lenders and savings banks.

Quick quiz · 2 of 2

Resigned in March; successor recorded in July. Until when is it liable?

See answer

Until July. The resignation is only complete once the minutes electing the successor are recorded on the property deeds.

Lesson complete

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B2.3Beginner · Lesson B2.3Manager: who decides what to buySame warehouse, two managers, a 22% gap in income.Continue
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Image credits
  • Alena Darmel · Pexels · Pexels License — Pexels
  • Aaaatu · Wikimedia Commons · CC BY-SA 4.0 — Wikimedia Commons

Educational content, written for learners. Not investment advice.