Filing Behaviour

When funds file, how late, how often they re-file, and which funds stopped filing. The documents come from B3's Fundos.NET (FNET) register as SILO holds it, and the silence test reads CVM's own monthly and daily datasets.

These are signals, not findings. A late delivery is a timestamp compared with a rule. A restatement can be a typo fix. A silent fund can be a merger CVM has not recorded yet. Each section says what else produces the same row. The register is SILO's crawl of FNET, not all of FNET: history before SILO's first crawl is partial, and a document is known as a fund's only through its CNPJ link, which the per-fund sweep adds every two weeks.

The window is 2026-09-16 to

2026-10-15 . Today is left out because the build runs in the morning, while documents are still arriving.

Filings Delivered per Day

Documents in the register by FNET delivery day over the last 90 complete days, first filings (versao 1) apart from re-filings (versao above 1). The day is FNET's own delivery stamp in São Paulo local time. The count covers the FII, FIDC and ETF documents SILO crawls. It is not every document FNET holds, and a dip can be a crawl gap as easily as a quiet day: check the fnet row on Pipeline Ops before reading one.

Late Filers: Monthly Informe Past the CVM 175 Deadline

FIIs and FIDCs whose monthly informe first reached FNET at least 5 days after the deadline in at least 2 of the last 12 reference months. The deadline is cited, not assumed: Resolução CVM 175 gives 15 days after the end of the reference month (FIDC: Anexo Normativo II, art. 27, III; FII: Anexo Normativo III, art. 36, I).

What this screen does not support. SILO applies no holiday calendar, so a deadline on a weekend or holiday may roll forward; the 5-day margin absorbs that. Months before 2024-12 (FIDC) and 2025-07 (FII) are not measured, because funds had until then to adapt to the resolution. A month with no informe in the register is not counted at all; absence is the silent-filer question below. An extension CVM granted, or a filing made by other means and uploaded later, produces the same row. A fund with several classes is measured on its earliest filing.

Silent Filers: Active in the Registry, No Informe

Funds that CVM's registry still lists as active whose last periodic informe in CVM's own dataset is 3 to 24 complete months behind the family's latest complete month. FI is read from the informe diário, FIDC, FII and FIAGRO from the monthly informe. Silence is counted against the newest month CVM has published in full, never today, so an unpublished month does not read as silence. Largest registry net assets first.

What this screen does not support. FIP files once a year and is not screened. The same row comes from a fund merged, incorporated or liquidated whose registry status CVM has not updated, from a CVM 175 adaptation that moved reporting to a class CNPJ, from CVM's dataset lagging the filing itself, or from a SILO ingest gap. If a whole family goes silent at once, check Pipeline Ops first. Registry net assets carry the registry's own date. A blank FNET column means no FNET document is linked to the CNPJ, not that the fund files nowhere.

Frequent Restaters

Funds with at least 3 re-filings (versao above 1) in the last 12 months of FNET deliveries that are also at least 20% of the fund's documents in that window. FNET publishes the kind: RE is voluntary (Reapresentação Espontânea), RC is required by CVM (Reapresentação por Exigência).

What this screen does not support. Only documents linked to the fund's CNPJ count, so a recent re-filing the fortnightly sweep has not linked yet is missing, as is history before SILO's first crawl. The same row comes from routine typo fixes, an administrator or custodian migration that re-submits a whole book, the CVM 175 adaptation, a FNET template change, or a CVM sweep across one administrator's funds. An RC says CVM asked, not what was wrong. Top 50 by re-filings.

Latest Restatements

Re-filings delivered in the last 30 complete days, by FNET document type. Linked is how many carry a fund CNPJ link yet. Diffed is how many SILO has compared field by field with the version they replaced, which today covers the FIDC informe mensal only.

The 50 newest re-filings already linked to a fund CNPJ, each with FNET's download link. The per-fund sweep runs every two weeks, so the newest re-filings are mostly not linked yet. They are counted in the table above and left out here; a fund is never inferred from its name. Diff status is the diff job's verdict on the pair: compared, or why not. Blank means the document was not considered for a diff, which is every type but the FIDC informe mensal.

What a FIDC Restatement Changed

Field by field, for the 10 newest FIDC informe re-filings SILO compared that changed at least one field, at most 20 fields each. Old and new values are the text as filed, comma decimals included. Change is a value changed, added or removed. Delta is set only on numeric fields.

What this does not support. Only the FIDC informe mensal is diffed, and only restatements delivered from 2026 on. Tab VIII (debtors) is not in the XML FNET serves, so its changes are invisible here. The comparison is between FNET's versions, not CVM's CSVs, which CVM republishes in place. A row matched by position rather than key or path is approximate by construction. The full diff for one fund is api.fund_restatement_diff.

An empty table means no fund matched the threshold, not that the screen failed to run. If several sections are empty at once, check whether the FNET and CVM slices landed on Pipeline Ops before concluding that every fund filed on time.