Brazil: Relevant Aspects On The Indebtedness By Brazilian Companies Of The Public Sector

Last Updated: 8 July 2001
Article by José Paulo Bueno

Co-written by Camila Ferreira de Oliveira Gomes and Tamy Fujiwara

I. Introduction

Credit transactions carried out by public companies in general, either in the Brazilian or international market, are subject to certain special conditions set forth by the Brazilian Federal Constitution. The main purpose of such constitutional provisions is to ensure that the Federal Union controls the foreign indebtedness of the federation, the budget balance and the responsibility for the fiscal management of the public indebtedness.

In this respect, according to the Federal Constitution, the Federal Senate 1 is privately empowered to (i) decide on the total limits and conditions for the internal and external credit transactions of the Federal Union, States and Municipalities, as well as for its governmental agencies and other entities controlled by the Federal Public Power, and (ii) establish the total limits for the amount of the restated debt 2 of the Federal Union, States and Municipalities, as per proposal of the President (Federal Constitution, Art. 52, VI and VII).

In addition, the Federal Constitution establishes that a complementary law shall be enacted in order to set forth the general provisions concerning the public finances and the applicable parameters for the indebtedness of the public entities and the granting of guarantees thereby (Federal Constitution, Art. 163).

In this sense, on May 4, 2000, Complementary Law 3 no. 101 was enacted within the Fiscal Stability Program presented by the President on 1998, which aims the reduction of the public deficit and the stability of the public debt in relation to the Gross Internal Product.

The purpose of such Complementary Law is the restructuring of the debts of States and Municipalities, the reorganization of the state banking system and the implementation of the measures of fiscal adjustment by the state and municipal governments, with the intention of establishing the responsible fiscal management regime, upon the adoption of the legal mechanisms that shall guide the public administration.

In this context, credit transactions carried out by public companies are also subject to certain rules of the Complementary Law, as they impact on the public indebtedness.

Therefore, an overview of the regime of credit transactions of public companies in Brazil cannot omit the general conditions to which the public indebtedness is subject, indicating the basic guidelines arising out of three main sources:

  • the rules of the Federal Senate which establish the limits and conditions for the indebtedness of the Federal Union, States, Federal District and Municipalities;
  • the rules of the Fiscal Responsibility Law which directly or indirectly limit the power of the public entities when performing credit transactions; and
  • the rules for private financial institutions which restrict the credit availability of the public entities.

This paper intends to present an overview on these three aspects in which the subject may be divided, in order to provide for an overview of the legal regime in force and applicable as to internal and external credit transactions carried out by entities of the public administration.

II. Resolutions Of The Federal Senate

1. Direct And Indirect Federal Public Administration

Resolution no. 96/89 4 of the Federal Senate refers to (i) total limits for internal and external credit transactions of the Federal Union and its governmental agencies and other entities controlled by the Federal Public Power, and (ii) limits and conditions for the granting of guarantees by the Federal Union in relation to internal and external credit transactions.

Resolution 96 refers not only to the Federal Union, but to all its direct and indirect federal administration. However, it does not refer to the States, Federal District and Municipalities credit transactions - which shall observe the provisions of Resolution 78 of the Federal Senate (see item 2 below) - and does not exclude the independent public companies - which are referred to in Resolution 78 and Complementary Law no. 101.

As per Resolution 96, credit transaction is a transaction which represents obligations with creditors in the country or abroad, such as:

  • any and all obligation arising out of financing or loan (contracts, issuance and acceptance of notes/bonds);
  • lease transactions; and
  • granting of any guaranty.

The States, Federal District and Municipalities and its respective governmental agencies are not allowed to enter into agreements directly with suppliers, services' providers or contractors, upon issuance or guaranty (aval) of notes, acceptance of bills or other similar transactions.

1.1. Limits

The amount of credit transactions in each fiscal year cannot exceed the amount of the capital expenditures (investments, financial inversions, capital transfers, as defined by law), exception made only to the authorized transactions upon supplementary or special credits with specific purpose (credits which are not foreseen in the correspondent fiscal budget), duly approved by the Legislative Power by an absolute majority of votes.

The internal and external credit transactions with financial nature of the Federal Union and its governmental agencies and the issuance of guarantees by the Federal Union shall observe the following limits: (i) the total amount of the transactions for a given fiscal year cannot exceed the amount of the expenditures with charges and amortization of the due and enforceable debt, duly updated and increased by 10% of the actual net income 5; and (ii) the maximum annual expenditure, considering principal and accessories of all transactions, cannot exceed the margin of the actual savings 6

The Federative Units may request to the Federal Senate that the guarantees to be granted to a certain company, foundation or governmental agency are not included for the purpose of the limits mentioned above, provided that the Federative Unit proves that: (i) the credit transaction is contracted for project financing of investment or extension of the debt; and (ii) the guaranteed entity is able to fulfill the contracted obligations.

The request for authorization shall be presented to the Federal Senate with the following documentation:

  • documents attesting the payment ability of the company, foundation or governmental agency;
  • law authorizing the issuance of the guarantee not considered within the limits referred to above;
  • prove of the inclusion of the project in the investment budget of the companies under control of the Federative Unit, as well as in the multi-annual plan law and in the budget guidelines law.

Exceptionally and if duly justified, States, Federal District and Municipalities may request the temporary increase of the limits mentioned above, by presenting to the Federal Senate a requirement including:

  • authorizing law;
  • characteristics of the transaction: term, interest rate, charges, financial schedule; and
  • information of the financial situation of the requiring company.

1.2. Conditions To Contract The Transaction

The credit transaction or the issuance of the guarantee shall only be contracted after the manifestation of the Central Bank, to be issued within ten business days as of the receipt of each request.

Should the Central Bank of Brazil (the "Central Bank") not present its manifestation within such period, the borrower shall be responsible for the contracting of the transaction, observing the applicable limits and conditions.

2. States, Federal District, Municipalities And Its Respective Governmental Agencies And Foundations

Resolution 78/98 of the Federal Senate refers to internal and external credit transactions of States, Federal District, Municipalities and its respective governmental agencies and foundations, including the issuance of guarantees, and the limits and conditions for the authorization.

The definition of credit transaction of Resolution 96/89 (see item 1.1) applies to Resolution 78/98.

The assumption of debts by States, Federal District, Municipalities and its respective governmental agencies and foundations are equivalent to credit transactions.

The States, Federal District, Municipalities and its respective governmental agencies and foundations that have requested authorization to contract credit transactions are not allowed to:

  • obtain funds upon transfers arising out of entities controlled thereby, including companies in which they hold the majority of the voting capital, either directly or indirectly, not even in case of anticipation of payment or retention of taxes;
  • contract obligations directly with suppliers, renders of services or contractors, upon issuance or guaranty (aval) of notes, acceptance of bills or other similar transactions; and
  • carry out any credit transaction that represent a breach of agreements for refinancing contracted with the Federal Union.

Resolution 78 applies to the entities controlled by States, Federal District and Municipalities that do not perform productive activities or that have their own incomes. On the other hand, the State and Municipal public companies and private and public joint stock companies 7 that perform productive activities or have their own incomes, shall not be subject to Resolution 78.

The control of the public investment in such entities is indirectly exercised through the budget targets in the respective States and Municipalities, on the terms of the Fiscal Responsibility Law.

In fact, Complementary Law no. 101 applies only to dependent public company. Dependent public company are companies in which the majority of the voting capital is directly or indirectly held by the Federal Union, States, Federal District or Municipalities and which receives funds from its controlling shareholder for the payment of expenses with its staff or payments in general or capital payments, not including, in such case, funds arising out of increase of shareholding participation.

2.1. Issuance Of Public Debt Notes/Bonds

Public debt notes/bonds of States, Federal District and Municipalities shall only be issued, publicly offered or placed in the market after the prior authorization of the Federal Senate, with the opinion of the Central Bank, which is responsible for the relevant registration within ten business days as of receipt of the request.

The notes/bonds shall be equivalent to the federal notes/bonds and its respective redemption periods shall not be less than six months as of the issuance date.

The issuance of notes/bonds for the redemption of those in the market with due date of less than twelve months or for the purpose of anticipation of budget income in the permitted conditions is not subject to the provision of the paragraph above.

Laws authorizing States, Federal District or Municipalities to issue notes/bonds of the public debt shall contain provisions assuring that:

  • the debt resulting from the outstanding notes/bonds which were not object of redemption shall be updated by the same criteria of adjustment and compensation of the notes/bonds which have originated them; and
  • the notes/bonds shall be equivalent to the federal notes/bond, shall have power of decision for the purpose of payment of taxes; and its redemption periods shall not be less than six months as of the issuance date.

The technical opinion of the Central Bank referring to the issuance of the notes/bonds of the public debt shall include:

  • the amount of the notes/bonds to be issued and the amount of already existing notes/bonds of the same issuer, indicating the date of reference of such amounts;
  • analysis of the impact of the credit transaction in the security market and of the performance of the notes/bonds already issued in such market;
  • in case of refinancing of notes/bonds still to be paid, historical of the evolution of such notes/bonds as of its issuance, including its appreciation in value.

The sale of notes/bonds of the public debt by its issuers shall occur through public electronic auctions of the Central Bank or by an entity authorized by the Brazilian Securities and Exchange Commission (Comissão de Valores Mobiliários - CVM).

After each electronic auction, the Central Bank shall present the main information on the auction to financial institutions, the Federal Senate and Legislative Power and to the Audit Courts to which the entity is subordinated.

States, Federal District and Municipalities cannot issue public debt notes/bonds before December 31, 2010, except in the amount necessary for the refinancing of the principal duly updated of its obligations, represented by such type of notes/bonds.

III. Limitations Of The Fiscal Responsibility Law

Below is a summary of the main provisions of the Complementary Law N. 10, of May 4, 2000 (Lei de Responsabilidade Fiscal - LRF), in connection with the general concept of indebtedness by entities of the public administration:

1. Prohibition Of Operation Between Entities Of Different Levels

LRF prohibits credit transactions between an entity of the Federation, directly or through a fund, autarky, foundation or dependent public entity, and another, including their entities of the indirect administration, even through novation, refinancing or postponement of previous debt.

This prohibition does not include operations between state financial institution and another federal entity (including entities of the indirect administration), which purpose is not:

  • to finance, directly or indirectly, current expenses;
  • to refinance debts that were not contracted with the same institution.

The prohibition contained in the LRF does not prevent States and Municipalities from acquiring Federal government bonds as investment of their funds.

2. Prohibition Of Operation With Controlled Entity

The LRF expressly prohibits credit transactions between a public financial institution and a Federal entity which controls the first one, in the capacity of beneficiary of the loan, except that the controlled financial institution may purchase government bonds in the market in order to comply with clients investment needs, or Federal government bonds to invest its own funds.

3. Other Vetoed Operations

According to the LRF, the following situations are equivalent to credit transactions and, therefore, are not allowed:

  • to receive funds as anticipation of tax or contribution revenue which taxable event has not yet occurred;
  • the receive anticipated amounts of a company in which the Public Power holds, direct or indirectly, the majority of the corporate capital with voting rights, except for profits and dividends, in accordance with applicable law;
  • direct undertaking of commitment, debt confession or similar operation with supplier of goods or services, upon issuance, acceptance or guaranty of bill of exchange (not applicable to dependent public companies);
  • undertaking of liability with without the proper budgetary approval, for future payment of goods and services.

4. Control By The Treasury Department

The Treasury Department shall verify the compliance with limits and conditions relating to the credit transactions of each entity of the Federation, including companies controlled thereby, direct or indirectly.

Without prejudice to the attributions of the Senate and the Central Bank, the Treasury Department shall provide a centralized and updated electronic registration of internal and external public debts, to be accessed by the public, and which shall include:

  • Charges and hiring conditions;
  • Updated outstanding balance and limits referring to consolidated and security debts, credit transactions and guaranties.

The agreements relating to foreign credit transactions may not provide for the automatic off-set of debts and credits.

The financial institution which contracts a credit transaction with a federal entity (except when it relates to security debt - represented by bonds issued by the Union, States or Municipalities - or external debt), shall request appropriate evidence that the operation meets the conditions and limits requirements. An operation that is not in compliance with the provisions of the LRF shall be deemed null and shall be cancelled, upon return of the principal amount.

IV. Limitation Of Indebtedness By The Public Sector

By resolution of the National Monetary Council - CMN, since March 30, 2001, the amount of credit transactions carried out by each financial institution with public bodies and entities is limited to 45% (forty-five per cent) of the net assets8.

This limitation encompasses all bodies an entities of the direct and indirect public administration of the Union, the States, the Federal District and the Municipalities (except for financial private and public joint stock company).

For this purpose, credit transactions are:

  • loans and financing;
  • lease transactions;
  • acquisition, either definitive or through compromised operations for the resale of notes and securities issued by the States, the Federal District or Municipalities, as well as bodies and entities of the relevant direct or indirect administration, excluding definitive acquisition of stock of private and public joint stock companies;
  • issuance of guaranties of any nature whatsoever;
  • any and all operation that results, direct or indirectly, in the release of credit or receipt of funds of any nature whatsoever, including financial derivatives.

Credit transactions for which the National Treasury is liable or which is formally guaranteed (totally and jointly) by the National Treasury are not subject to the referred-to limit.

New credit transactions may be contracted with the States, the Federal District and the Municipalities, as well as with their autarkies, foundations and dependent public companies, provided that the limits and conditions established by the Central Bank are fulfilled.

However, new credit operations may only be contracted with public companies and non-financial and non-dependent public and private joint stock companies, controlled direct or indirectly by the States, the Federal District and the Municipalities, in case the controlling shareholder complies with the limits and conditions established by the Central Bank, except for:

  • financing of projects in respect of international bids, if the financing is provided for in the bid notice;
  • operations with notes and securities, provided that the original issuance was made in compliance with CVM's applicable rules.

In order to carry out said credit transactions, the financial institutions must comply with the operational limits established by applicable legislation, except for credit operations for which the National Treasury is liable or which are formally guaranteed (jointly and totally) by the National Treasury and which receipt and investment structure are linked and identical in respect of term and interest rate.

Furthermore, financial institutions are not allowed to:

  1. carry out credit transactions with governmental bodies or entities of the public sector which are in default with any financial institution and other institutions authorized by the Central Bank to operate;
  2. contract new operations with governmental bodies or entities of the public sector in case they have any pending registration with the System of Registration of Operations with the Public Sector (Sistema de Registro de Operações com o Setor Público - CADIP);
  3. receive, under any modality of credit transaction, as guaranty, principal or collateral, promissory notes, trade bills, bills of exchange, or any other kind of notes, as well as letters of credit, personal or other guaranties for which bodies or entities of the public sector are direct or indirectly liable, relating to obligations with suppliers, contractors or service providers;
  4. carry out any kind of operation that may result in the transfer of the direct or indirect payment obligation under any note for bodies or entities of the public sector.

The prohibition provided in item (c) above does not apply to transactions contracted by public companies or public and private joint stock companies controlled directly or indirectly by the Union, the States, the Federal District and the Municipalities, nor to operations guaranteed formally and exclusively by trade bills owed by public companies or non-financial public and private joint stock companies, their subsidiaries and any other companies controlled, direct or indirectly, by the Union, the States, the Federal District and the Municipalities, including sole purpose companies.

The total amount of new credit transactions shall not exceed R$ 1,000,000,000.00 (one billion reais), except for the following operations:

  1. contracted with public companies or non-financial public and private joint stock companies, their subsidiaries and any other companies controlled, direct or indirectly, by the Union, the States, the Federal District and the Municipalities, including sole purpose companies:
    • guaranteed exclusively by trade bills against the beneficiary of the credit;
    • export financing; and
    • project financing in connection with international bids, if the financing is provided for in the bid notice.
  2. secured formally and exclusively by trade bills against the entities referred-to hereinabove, although they must be calculated for the purposes of operations' limit;
  3. contracted with municipalities with funds from BNDES/PMAT, and destined, exclusively, for the creation of investment programs on tax modernization;
  4. acquisition, either definitive or through compromised operations for the resale of notes and securities issued by the States, the Federal District and the Municipalities, as well as public bodies and entities of the relevant direct or indirect administration, excluding definitive acquisition of stock of private and public joint stock companies.

According to Resolution 2827, new operations may only be contracted upon the prior authorization of the Central Bank, which shall inform the application criteria.

Footnotes

1 The Brazilian Federal Senate is composed by representatives of States of the Federation (one per State) and elected by the majority principle

2 Restated debt, as defined on art. 29, I, of Complementary Law no. 101, dated May 4, 2000, is the total amount of the financial obligations of each of the entities of the federation (the Federal Union, each of States, the Federal District and each of the Municipalities) contracted by virtue of law, contracts, agreements or treats, as well as by the credit transactions for the amortization in a period higher than twelve months.

3 Law approved by absolute majority of the National Congress.

4 Resolution no. 17/92 of the Federal Senate has established an indefinite period of enforceability of Resolution 96/89.

5 Actual net income is the income of the past twelve months in relation the relevant month, excluding the incomes arising out of credit transactions and alienation of assets

6 Margin of the actual savings is the net income amount excluding the usual expenses paid and including the charges and amortization of the funded debts paid

7 Sociedades de economia mista

8 Resolution 2.827 of the Central Bank

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