Portfolio Valuation

Fair value of fund assets

Brazilian FIDCs, FIPs and FIIs under CVM Resolution 175.

FIPs (private equity funds) and FIIs (real estate funds) measure their equity interests and properties at fair value, and in FIDCs (receivables funds) credit rights follow the classification set by the fund's accounting rule, which may bring them to fair value. When an asset has no observable price, its fair value depends on a valuation model. This is the case for privately held equity interests, illiquid credit rights, and real estate and SPV interests.

What CVM Resolution 175 changed

CVM Resolution 175, in force since October 2023, reorganised Brazilian funds into classes and subclasses of quotas, separated the responsibilities of the fund administrator and the manager more clearly, and introduced dedicated annexes for FIDCs, FIIs and FIPs.

Each fund category follows its own CVM accounting instruction (489 for FIDCs, 516 for FIIs and 579 for FIPs), fair value measurement follows CPC 46, the Brazilian equivalent of IFRS 13, and asset pricing follows the manual adopted by the fund.

CVM Resolution 175 · CVM Instructions 489, 516 and 579 · IFRS 13

Equity interests in privately held companies

In FIPs and other funds investing in companies, valuation combines discounted cash flow, market multiples and calibration to the price of the latest transaction, with the marketability and control adjustments the case justifies.

For early-stage investees, the weight of each method depends on the investee's stage and on whether auditable cash flows can be built, and calibration to the latest round and allocation models across share classes usually play a central role.

IFRS 13 · IVS 200 · IPEV Guidelines, December 2025 edition

Illiquid credit rights

In FIDCs, the fair value of portfolios with no active market comes from expected collections, already net of estimated losses, discounted at a rate that reflects the premium a market participant would require for the remaining risk and the recovery period, without counting credit risk twice.

Litigation claims, court-ordered government payments (precatórios), non-performing portfolios and trade receivables call for different assumptions, and the waterfall across senior, mezzanine and subordinated quotas determines how much value belongs to each subclass.

IFRS 13 · IFRS 9 · CPC 48

Real estate and SPVs in FIIs

FII properties are appraised under ABNT NBR 14653 by a licensed engineer or architect, using the direct comparison, income capitalisation, residual or cost method depending on the asset.

When the property sits in an SPV with debt and other assets, the value of the interest also requires a valuation of the vehicle. CBG delivers both within a single engagement, with its Real Estate Appraisal and Business Valuation teams.

ABNT NBR 14653 · IAS 40 · RICS Red Book

How CBG conducts the work

Frequency follows the fund's regulations and pricing manual, monthly, quarterly, semi-annual or annual, plus events such as in-kind subscriptions, amortisations, spin-offs or asset sales.

Each report carries the trail from raw data to conclusion, so that administrator, manager and auditor can rebuild the calculation from the same documents.

Frequently asked questions

Who is responsible for the fair value of a fund's assets?

Pricing follows the manual adopted by the fund and generally rests with the fund administrator. The independent report supports the value of assets without observable prices and is reviewed by the fund's auditor.

How often must assets be revalued?

It depends on the fund's regulations, the pricing manual and the nature of the asset. Real estate and equity interests are usually revalued once or twice a year, and credit portfolios more often, in addition to events that change the portfolio.

Are a valuation report and a broker's opinion equivalent for an FII?

An appraisal report (laudo) under NBR 14653 is signed by an engineer or architect registered with CREA or CAU. A market valuation opinion (PTAM) is signed by a real estate broker registered with CNAI and follows its own rules. In the fund's financial statements and for in-kind contributions of property, the NBR 14653 report is the usual document.

Does CBG also value the SPV that holds the property?

When the property sits in an SPV, CBG values the property and the interest in the vehicle, taking into account debt, cash and other assets and liabilities, within a single engagement.

How is the valuer's independence ensured?

CBG does not manage, distribute or structure the assets it values, and fees do not depend on the value concluded. These restrictions are set out in the engagement letter for each piece of work.

Related publications

Fair value of illiquid credit rights in FIDCs Read →
Subordination in FIDCs: the waterfall as central input Read →
Fair value of venture capital investments and the last round Read →

Contact

Carlos Bernardo Gonçalves

Managing Partner

carlos.bernardo@cbgvaluation.com