Policy · in force from 1 October 2026

The investment policy.

The rules the portfolios are managed under from the inception date, as decided on 14 September 2026. They are the policy in words: nothing on this site is a live check of the book against them.

Before 1 October 2026

The written investment policy takes effect on 1 October 2026. Every figure on this page is from before it: the portfolios' history, shown so that nothing is left out, and not yet a record kept under the policy.

Objective for the two personal plans: 110% of the CDI a year, before tax, counted from the inception date. Each company treasury follows a policy of its own.
Each personal plan follows a written plan with its own drawdown limit: 10% for one and 20% for the other. A breach of a drawdown limit brings a written review; it never forces a sale.
Rebalancing: each sleeve may drift from its target by a quarter of the target, never by less than 2 points and never by more than 5. A sleeve outside its band is brought back within a month. The portfolios are reviewed quarterly and read monthly.
Concentration: at most 10% in any one share, fund or coin, and at most 15% with any one banking group. Government bonds are not capped. The five largest holdings are at most 60%, counting credit and equity only. Credit issued by the custodian's own bank is at most 15% of each portfolio.
Deposit insurance: bank deposits and bank paper stay within the Brazilian deposit guarantee (FGC) per holder and financial conglomerate.
Cash: a reserve held inside a plan is outside its return goal; money earmarked for transfer is held outside the portfolios.
Target weights for each sleeve are set per plan and are published with the first figures after inception.