CDA — Composition and Diversification of Investments

What it is

Normative Annex I to CVM Resolution 175 bundles the FIF's monthly filing into a single deadline: the trial balance, the portfolio composition and diversification statement (CDA, from the Portuguese "Composição e Diversificação das Aplicações") and the monthly profile are all due within 10 (ten) business days after the end of the month they refer to (art. 24, II). The CDA details every asset in the portfolio on the last day of the month — position, valuation, asset class, maturity, index reference and counterparties — and is the basis for the CVM's monitoring of portfolio compliance, concentration and risk. Filing the key information sheet (lâmina, art. 24, II, "d") has been waived since the October 2024 reference month (Ofício-Circular nº 5/2024/CVM/SIN, question 2.1). Positions the manager considers sensitive may have their identification and quantity omitted from the statement, and must be disclosed within 30 days, non-extendable, for Short-Term, Referenced or Simple fixed income classes, or within 90 days after month-end in all other cases — a period that may be extended once, with CVM approval, up to 180 days (art. 22, §§ 3 and 4). Mind the fund type: the business-day deadline applies to FIF. FIDC and FII file their monthly reports within 15 calendar days, under Normative Annexes II and III. FIPs have no monthly filing — they report through the four-monthly report. FIAGRO has its own regime under Normative Annex VI: a monthly report following Supplement O within 15 days and a quarterly portfolio composition statement within 45 days (art. 33, I and II).