🇧🇷Brazil

Gargalo Operacional: Múltiplos Sistemas de Registro de Garantias (Multi-Registry Bottleneck)

Updated: Feb 20261 verified sources

Definition

Receivable assignment requires: (1) Notary-authenticated assignment agreement; (2) C3 registration with Central Bank accreditation; (3) Obligor notification; (4) If collateral is real estate: real estate registry filing; If financial assets: custodian/depository filing. Sequential process with manual handoffs creates backlogs. C3 system has limited integration with origination platforms.

Key Findings

Financial Impact: Manual processing time: 15-40 hours per transaction (legal review, notary coordination, registry filing, compliance verification). For bank originating R$ 10B annual collateralized credit = ~3,000-5,000 transactions; 15-40 hrs × R$ 200-400/hour blended cost = R$ 45-80M annual manual labor cost. Delays in C3 registration create interest rate risk exposure on repo/securitization funding.
Frequency: Every collateral origination and assignment; affects 100% of credit portfolio growth
Root Cause: Fragmented registry architecture (no single electronic system for all collateral types); mandatory notary involvement; Central Bank C3 system lacks real-time integration with bank origination systems; paper-based processes in some regional registries

Why This Matters

The Pitch: Banks and NBFCs waste 15-40 hours per collateral origination managing manual registry filings across fragmented systems. Digital integration platforms enabling batch C3 submissions, real estate registry API connections, and notary automation eliminate 60-80% of manual touchpoints, recovering R$ 30-80M annually in avoided delays and rework for mid-sized credit platforms (R$ 5-20B AUM).

Affected Stakeholders

Credit operations/back-office, Legal documentation teams, Loan servicing, Compliance/audit, Notaries (external)

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Financial Impact

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Current Workarounds

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Methodology & Sources

Data collected via OSINT from regulatory filings, industry audits, and verified case studies.

Evidence Sources:

https://www.levysalomao.com.br/publicacoes/artigo/structured-finance-and-securitisation-in-brazil-overview

Related Business Risks

Custo Brasil em Garantias: Over-Collateralização Obrigatória Pós-Reforma (Post-Reform Mandatory Over-Collateralization)

Incremental collateralization rate increase: 10-30% of loan amount for affected borrower cohorts. For Brazilian SME credit market (R$ 250B+), estimated 15-25% of borrowers affected = R$ 37.5-62.5B at-risk; average excess collateral cost (opportunity cost on pledged assets + financing to meet collateral requirement) = 2-4% per annum = R$ 750M-2.5B annual cost drag.

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