CNSP RESOLUTION NO. 471, OF 25 SEPTEMBER 2024 (*)
Provides for the own risk and solvency assessment (ORSA) and capital management within the scope of insurance companies, open supplementary pension entities (EAPCs), capitalisation companies and local reinsurers.
THE PRIVATE INSURANCE SUPERINTENDENCY - SUSEP, in the use of the powers conferred on it by art. 34, item XI, of Decree no. 60.459, of 13 March 1967, hereby announces that the NATIONAL PRIVATE INSURANCE COUNCIL - CNSP, in an ordinary session held on 24 September 2024, and based on the provisions of art. 32, item II, of Decree-Law no. 73, of 21 November 1966, in arts. 3, item II, 37 and 74 of Supplementary Law no. 109, of 29 May 2001, in art. 3, par. 1, of Decree-Law no. 261, of 28 February 1967, and in art. 5 of Supplementary Law no. 126, of 15 January 2007, and considering what is contained in Susep File no. 15414.607653/2023-24, resolves:
CHAPTER I
OBJECT AND SCOPE
Art. 1 This Resolution provides for the own risk and solvency assessment (ORSA) and capital management within the scope of insurance companies, open supplementary pension entities (EAPCs), savings bonds companies and local reinsurers.
Sole Paragraph. The provisions of this Resolution do not apply to companies and entities included in segments S3 or S4 and to Special Purpose Insurance Companies (SSPE).
CHAPTER II
DEFINITIONS
Art. 2 For the purposes of this Resolution, the following are considered:
I - supervised: the companies and entities mentioned in art. 1;
II - own risk and solvency assessment - ORSA: a process carried out periodically by the supervised company to assess the adequacy of its capital and liquidity, both under normal and stressed conditions, taking into account the risks of its current and planned operations;
III - capital management: a set of processes and routines used by the supervised company, taking into account the results of the ORSA and its risk appetite, to establish and continuously assess the levels of control for its capital, monitor the achievement of these levels and, if they are breached, take the relevant actions;
IV - stress test: an exercise carried out in order to assess the potential impacts of adverse events or circumstances on the operations of the supervised company, encompassing the following methodologies:
a) sensitivity analysis: a stress test methodology that makes it possible to assess the impact of variations in a single relevant input parameter;
b) scenario analysis: a stress test methodology that makes it possible to assess the impact resulting from simultaneous and coherent variations in a defined set of relevant input parameters; and
c) reverse stress test: a stress test methodology that allows the identification of adverse input events or circumstances associated with predefined levels of impact, including those that configure the unviability of the supervised company;
V - strategy risk: the possibility of losses arising from adverse changes in the business environment or the use of inappropriate assumptions in decision-making;
VI - reputational risk: the possibility of losses arising from a negative perception of the supervised company on the part of its clients, counterparties, shareholders, investors, government bodies and other interested parties;
VII - risk of contagion: the possibility of losses for the supervised company as a result of its relationship, whether contractual, corporate or of any other nature, with other companies in the same group to which it belongs;
VIII - concentration risk: the possibility of losses resulting from the concentration of risks in certain investments, insured items, insurance coverages, geographical region of operation, among others;
IX - management bodies: Board of Directors and Executive Board;
X - highest management body: the Board of Directors or, if it does not exist, the Executive Board; and
XI - employees: managers, employees, outsourced services providers and other relevant partners of the supervised company.
Sole Paragraph. Where applicable, the definitions established in the regulations of the National Private Insurance Council (CNSP) dealing with capital requirements and the Risk Management Structure (EGR) shall apply.
CHAPTER III
THE ORSA
Section I
General Provisions of this Chapter
Art. 3 The ORSA must be:
I - compatible with the nature, size, complexity, risk profile and business model of the supervised company;
II - aligned with the supervised company's strategic planning and with the implemented EGR;
III - prospective in its approach, considering, from a continuity of operations perspective, the most relevant material risks to which the supervised company is or may be exposed as a result of its business strategy and changes in the internal and external environments, considering, at a minimum:
a) underwriting, credit, market and operational risks, in accordance with the definitions established in the CNSP regulations on capital requirements;
b) liquidity, cyber, sustainability and other risks defined in regulations dealing with specific risk management; and
c) in the case of supervised companies in the S1 segment, the risks of strategy, reputation, contagion and concentration, in accordance with the definitions established in art. 2, items V to VIII; and
IV - based on consistent processes, methodologies and assumptions that are well documented and replicable over time.
Sole Paragraph. The supervised company may stop including the risks listed in item III in its ORSA if they do not reach the risk level mentioned in art. 5, item III, subitem "e".
Art. 4 The results of the ORSA, as well as the information obtained during its execution, must be used by the supervised company, at least, for the purposes of:
I - strategic planning;
II - improvement of the EGR, especially with regard to the definition of risk appetite, operational exposure limits and risk treatment mechanisms; and
III - capital management, as provided for in Chapter IV.
Section II
ORSA Policy
Art. 5 The supervised company must have an ORSA policy that includes, at least:
I - the commitment of the management bodies to the adequacy of the ORSA, in all its aspects, taking into account the regulations in force and the characteristics and needs of the supervised company;
II - the roles and responsibilities related to the ORSA at the various levels of the supervised company, especially with regard to its execution and validation; and
III - the guidelines for the design, implementation, execution, validation, monitoring and continuous improvement of the ORSA, including at least:
a) planning the execution and validation of the ORSA, as well as defining the specific circumstances that give rise to the extraordinary realisation of these activities, under the terms of arts. 6, par. 1, and 13, par. 2;
b) guaranteeing the quality of the data and information used in ORSA;
c) preparation of the projections and analysis provided for in art. 7;
d) monitoring of the ORSA and reporting on its results, including the preparation and use of the ORSA report; and
e) minimum risk level for the risks to be considered in the ORSA, based on the classification adopted in the supervised company's risk inventory.
Paragraph 1 The guidelines referred to in item III must be broken down into specific internal regulations that establish, in detail, the processes, methodologies and assumptions to be considered in the ORSA.
Paragraph 2 Any changes made to the ORSA policy must be reflected in the internal regulations referred to in par. 1.
Paragraph 3 The ORSA policy should be considered a complementary policy to the risk management policy, and the requirements defined for such complementary policies should apply to it.
Section III
Execution of the ORSA
Art. 6 The supervised company must carry out the ORSA at least annually, when drawing up or updating its business plan.
Paragraph 1 In the event of a significant update to the business plan outside the annual planning cycle, or a substantial change in the risk profile of the supervised company, a new ORSA must be carried out.
Paragraph 2 The provisions of par. 1 do not apply to:
I - business plans drawn up for the purpose of applying for prior authorisation which do not result from significant changes to strategic planning; and
II - adjustments to the business plan arising from the execution of the ORSA itself, under the terms of art. 4, item I, provided that they are made within the period established in art. 12 par. 1.
Paragraph 3 For the purposes of the ORSA referred to in par. 1, only the parts of the last annual ORSA impacted by the change may be updated.
Art. 7 The implementation of the ORSA shall comprise at least:
I - preparation of an economic and financial projection of the supervised company's operations for at least the following three years, reflecting the expected development of its business plan;
II - based on the projection referred to in item I:
a) the projection of the supervised company's capital needs, considering at least:
1. the Minimum Capital Requirement - CMR, in accordance with current regulations; and
2. the results of the quantitative risk measurement methodologies referred to in art. 15, par. 2, of CNSP Resolution no. 416, of 20 July 2021;
b) a projection of the supervised company's Adjusted Net Equity (PLA), as well as its sufficiency in view of the capital requirements mentioned in subitem "a"; and
c) projection of the supervised company's liquidity needs; and
III - analysis of the behaviour of the projections mentioned in items I and II in situations where risks materialise, through the application of stress tests.
Paragraph 1 The projections and analysis listed in the head of this article must be:
I - consistent with the strategic planning of the supervised company and with the EGR implemented, especially with regard to the defined risk appetite and the existing mechanisms for identifying, evaluating, measuring, treating, monitoring and reporting risks; and
II - adhering to the prudential regulations and accounting criteria in force, including in the event that risks are assumed outside the country.
Paragraph 2 For the purposes of the projections referred to in item II of the head of this article, other factors, including those not related to risk coverage, which may influence the supervised company's capital allocation, such as the mandatory distribution of dividends or the need to maintain a certain level of rating with a risk rating agency, should be taken into account when applicable.
Paragraph 3 For the purposes of the projection referred to in item II, subitem "b" of the head of this article, sources of financing provided for in the supervised company's business plan may be taken into account.
Paragraph 4 In the years in which a new business plan is drawn up, the projections contained therein must be used for the purposes of item I of the head of this article.
Art. 8 The stress tests mentioned in art. 7, item III, must:
I - consider variations in the impact of risks, in order to contemplate adverse situations capable of imposing a significant threat to the viability of the supervised company; and
II - must include:
a) reverse stress tests, in the case of supervised companies in the S1 segment; and
b) scenario analysis.
Art. 9 The quantitative methodologies used for the purposes of projecting the capital requirement referred to in art. 7, item II, subitem "a", item 2:
I - will not be subject to prior approval by Susep;
II - may use tools, techniques, databases, distributions, risk measures, confidence levels and time horizons of the supervised company's free choice, provided they are appropriate and compatible with its risk profile; and
III - should consider the behaviour of dependencies between risks or the effects of diversification in stress situations, whenever such mechanisms are used with the aim of reducing the need for capital.
Art. 10 The execution of the ORSA must be coordinated by a unit subordinate, directly or indirectly, to the director responsible for internal controls.
Paragraph 1 The unit referred to in the head of this article may, in accordance with the roles and responsibilities defined in the ORSA policy, carry out activities directly related to the execution of the ORSA or demand them from other units of the supervised company.
Paragraph 2. With regard to the coordination and execution of the ORSA, the unit referred to in the head of this article, as well as other units directly involved, must be guaranteed, under the terms of par. 1:
I - the necessary material and human resources, whether in-house or outsourced, including experienced, trained personnel in sufficient quantity; and
II - unrestricted and timely access to the necessary information.
Paragraph 3 The risk management unit may be responsible for the assignment provided for in the head of this article.
Section IV
The ORSA Report
Art. 11 At the end of the execution of the ORSA, the unit referred to in art. 10 must document the results and the most relevant aspects of the process in the ORSA report, containing at least:
I - information on the ORSA implementation context, including:
a) description of the supervised company's strategic direction;
b) description of the supervised company's approved risk appetite;
c) a description of the risk levels used in the supervised company's risk inventory, indicating those whose risks should be considered in the ORSA, under the terms of art. 5, item III, subitem "e";
d) description, current level and future trend of the risks considered in the ORSA; and
e) where applicable, other relevant considerations about the supervised company's internal and external environments;
II - for supervised companies in the S1 segment, information on the ORSA execution process, including:
a) identification of the various units involved and a description of their respective roles in implementing the ORSA; and
b) description of how the ORSA integrates with risk management, strategic planning and capital management processes;
III - the results of the projections and analysis provided for in art. 7, expressed at least for the base dates of 31 December of each of the financial years considered;
IV - a description of the methodologies, assumptions and databases used to obtain the results mentioned in item III, including:
a) the parameters, including macroeconomic parameters, considered in the projection referred to in art. 7, item I;
b) the assumptions and approximations used in the projections referred to in art. 7, item II;
c) when there is a significant difference between the projections of capital requirements mentioned in items 1 and 2 of item II subitem "a" of art. 7, details of the quantitative risk measurement methodologies referred to in said item 2, including:
1. the main risks considered, the tools, techniques, risk measures, confidence levels and time horizons used;
2. for supervised companies in the S1 segment, considerations on the treatment of dependencies between risks or diversification effects; and
3. identification of the characteristics that most contribute to the difference mentioned in the head of this subitem.
d) the stress test methodologies used in the analysis referred to in art. 7, item III, as well as the main risks considered, the sensitised input or output parameters and the respective variation ranges;
e) where applicable, a description of the factors not related to the coverage of the risks considered, under the terms of art. 7, par. 2; and
f) where applicable, a description of the relevant changes in methodologies, assumptions and databases made in relation to the previous implementation of the ORSA, with the corresponding justification.
V - assessment of the adequacy and reasonableness of the results mentioned in item III, including:
a) complementary qualitative assessments; and
b) where applicable, a description of limitations or potential inconsistencies inherent in the methodologies, assumptions and databases used;
VI - any other information that the management bodies deem necessary for the proper performance of the duties set out in art. 20.
Art. 12 The ORSA report must be:
I - approved by the director responsible for internal controls and the highest management body of the supervised company; and
II - forwarded at least to:
a) the Board of Directors;
b) the Risk Committee; and
c) the risk management unit.
Paragraph 1 The approval referred to in item I must take place within ninety days of the business plan being drawn up or updated, in the event that the execution of the ORSA is related to such events.
Paragraph 2 The persons, bodies and units mentioned in items I and II of the head of this article must:
I - consider the content of the ORSA report when carrying out their respective duties, especially those relating to risk management, strategic planning and capital management; and
II - when applicable, make available to the units and employees involved in the processes mentioned in item I, the information and conclusions contained in the ORSA report that are necessary for the execution of their activities, using clear, accessible language and at a level of detail compatible with their respective functions.
Section V
ORSA Validation
Art. 13 The supervised company must, at least every four years, validate its entire ORSA process, covering aspects of its design, implementation, execution and use, in order to ensure that it remains appropriate over time.
Paragraph 1 The aspects mentioned in the head of this article must include, at least:
I - adherence of the ORSA policy, as well as the internal regulations that implement it, to the requirements established in this Resolution and the guidelines published by Susep;
II - adherence of the execution of the ORSA to the ORSA policy and the internal regulations that implement it, as well as the effectiveness of the internal controls designed to guarantee such adherence;
III - the adequacy and consistency of the processes, methodologies and assumptions used in the ORSA, especially with regard to the projections and analysis mentioned in art. 7;
IV - the effectiveness of the information systems used in the ORSA, including the comprehensiveness, consistency, integrity and reliability of the data and information they make available;
V - consistency, reliability and adequacy of the ORSA documentation, including the ORSA report; and
VI - how the ORSA results are made available internally and their effective contribution to improving risk management, strategic planning and capital management.
Paragraph 2 The supervised company must prioritise, even before the period established in the head of this article has elapsed, the validation of specific aspects of the ORSA that may have been affected by:
I - material changes in the operations of the supervised company or in its business plan;
II - changes in the structure of the supervised or the group to which it belongs;
III - regulatory changes; or
IV - any other change in the supervised company's internal or external environment capable of substantially altering its risk profile.
Art. 14 The validation of the ORSA must be carried out by persons, units or entities internal or external to the supervised company, who:
I - have the training and experience to do so; and
II - have not actively participated in the design, implementation or execution of the aspect of the ORSA that they have validated.
Art. 15 The validation of the ORSA must be coordinated by a unit that has not actively participated in the design, implementation or execution of any aspect of the ORSA.
Paragraph 1 The unit referred to in the head of this article:
I - will not be able to draw up proposals for corrective action with regard to identified deficiencies;
II - must have direct access to the supervised company's highest management body; and
III - may, in accordance with the roles and responsibilities defined in the ORSA policy, carry out activities directly related to ORSA validation or demand them from other units of the supervised company, subject to the provisions of art. 14.
Paragraph 2. With regard to the coordination and execution of the validation of the ORSA, the unit referred to in the head of this article, as well as other units directly involved, must be guaranteed, under the terms of par. 1, item III:
I - the necessary material and human resources, whether in-house or outsourced, including experienced, trained personnel in sufficient quantity; and
II - unrestricted and timely access to the necessary information.
CHAPTER IV
CAPITAL MANAGEMENT
Art. 16 The supervised company must draw up, based on the results of the ORSA and its risk appetite, a capital contingency plan that defines, for the entire period considered in the ORSA:
I - control levels for the PLA, at least:
a) a level that the supervised company considers adequate to reasonably ensure, even in stress situations, full coverage of its capital needs;
b) a level equivalent to the CMR; and
c) a level between the levels provided for in subitems "a" and "b"; and
II - actions to be taken in the event of a breach of each of the control levels, including, at least for cases in which the ORSA indicates the possibility of a breach of the levels provided for in subitems "b" and "c" of item I, sources of funding or corrective actions that make it possible to restore capital.
Sole Paragraph. The actions referred to in item II of the head of this article should guide, but not limit, the options that may be implemented by the supervised company in the specific case, or proposed by it in a solvency regularisation plan (PRS) or in a process for repairing the note (PRA), if requested by Susep, without prejudice to the authority's prerogative to request clarification of any discrepancies.
Art. 17 The sources of funding and corrective actions mentioned in art. 16, item II:
I - they must have a range and scope compatible with the level of control to which their use corresponds;
II - may provide for capital transfers from other companies in the same group as a source of funding, provided that they are:
a) direct or indirect controlling companies of the supervised company; or
b) belonging to the same unified SCI/EGR as the supervised company;
III - must have their availability and viability assessed by the supervised company, taking into account at least:
a) the circumstances in which they would be used, based on the risk materialisation situations established in accordance with art. 7, item III;
b) any regulatory restrictions on their use; and
c) in the case referred to in item II, any restrictions on the fungibility or transferability of assets.
Sole Paragraph. The provisions of item II are subject to the existence of a formal commitment between the companies involved, ratified by the highest management bodies of both.
Art. 18 The capital contingency plan must be:
I - formally registered in writing;
II - approved by the supervised company's highest management body;
III - disclosed to the supervised company's employees who perform roles and responsibilities related to the execution of the capital contingency plan, using clear, accessible language and at a level of detail compatible with their respective functions; and
IV - reassessed at least once the ORSA has been implemented.
Art. 19 The supervised company must implement and maintain strategies, procedures and controls designed to guarantee the periodic monitoring of its PLA against the established control levels and, in the event of a breach of a control level, the timely adoption of the relevant actions.
Paragraph 1 The provisions of the head of this article shall be periodically reported to the management bodies of the supervised company, and in the event of a breach of the control level:
I - the infringement must be reported in good time;
II - the use of funding sources or corrective actions not provided for in the capital contingency plan must be duly justified and approved by the supervised company's highest management body; and
III - the periodic monitoring referred to in the head of this article should be intensified until the PLA returns to the level of control mentioned in art. 16, item I, subitem "a", and should include information on the status of implementation and effectiveness of the actions taken.
Paragraph 2 The strategies, procedures and controls referred to in the head of this article must be documented and provide for clearly established roles and responsibilities at the various levels of the supervised company, including those relating to the reports referred to in par. 1.
CHAPTER V
GOVERNANCE
Art. 20 The supervised company's management bodies must:
I - ensure that the ORSA is properly executed and validated, as well as capital management, monitoring its design, implementation and operation, the reporting and use of its results and the adoption of any necessary corrective actions;
II - have a general understanding of the results of the ORSA and the capital contingency plan, applying them, where possible, to the risk management, strategic planning and capital management processes; and
III - provide the various organisational units involved in the execution and validation of the ORSA, as well as in capital management, with the resources necessary for the proper performance of their activities, subject to the provisions of arts. 10, par. 2, and 15, par. 2.
Paragraph 1 It is the sole responsibility of the supervised company's directors, within their respective spheres of competence, to guide, supervise and guarantee the implementation of activities related to the execution and validation of the ORSA, as well as capital management, including any necessary corrective actions.
Paragraph 2 It is the sole responsibility of the director responsible for internal controls:
I - guide and supervise the design, implementation and execution of the ORSA, including the activities of the unit referred to in art. 10, promoting its integration with the supervised company's EGR;
II - to inform the management bodies periodically, and whenever it deems it necessary, of any material matters relating to the design, implementation or execution of the ORSA, including any factors that may have an impact on the fulfilment of planned schedules;
III - approve the internal regulations referred to in art. 5, par. 1; and
IV - propose changes to ORSA policy.
CHAPTER VI
THE PRUDENTIAL GROUPS
Art. 21 - In the event of the adoption of a unified SCI/EGR, the ORSA and the capital contingency plan must be the same for all the supervised companies that are part of it, and must also contemplate:
I - for the purposes of art. 3, item III, the risks capable of materially affecting the group of supervised companies;
II - for the purposes of art. 7, individual and consolidated projections and analysis relating to the risks referred to in item I, considering parameters, assumptions and stress tests that are consistent with each other.
III - for the purposes of art. 6, par. 1, relevant revisions to the business plans of individual supervised companies, or substantial changes to their risk profiles or those of the group of supervised companies;
IV - for the purposes of art. 11, the following information:
a) a list of the supervised companies included in the ORSA, indicating any additions or deletions of supervised companies in relation to their previous execution;
b) descriptions of the strategic direction, risk appetite and risks of the group of subsidiaries, explaining their relationship with those of each individual subsidiary; and
c) a description of the shareholdings and main transactions between the supervised companies considered in the ORSA; and
V - for the purposes of the provisions of art. 16, the levels of control relating to the group of supervised companies and the actions to be taken by specific supervised companies in cases where the ORSA indicates the possibility of their infringement;
Sole Paragraph. In the consolidated projections and analysis referred to in item II, any shareholdings or existing or planned transactions between supervised companies that could cause the results of an individual supervised company to be unduly considered as duplicates must be eliminated.
Art. 22 In the event provided for in art. 21, the supervised company leading the prudential group shall be responsible for the roles and responsibilities provided for in this Resolution:
I - to establish, approve and keep updated the ORSA policy, referred to in Chapter III, Section II, as well as the internal regulations that implement it, making these documents available to the other supervised companies that are members of the unified SCI/EGR;
II - set up or designate the units referred to in arts. 10 and 15, which may have the prerogative to demand activities from units belonging to the other supervised entities that are part of the unified SCI/EGR;
III - draw up and approve the ORSA report referred to in Chapter III, Section IV, making it available to the other supervised companies that are members of the unified SCI/EGR;
IV - draw up and approve the capital contingency plan referred to in art. 16, making it available to the other supervised companies that are members of the unified SCI/EGR; and
V - to monitor, at an aggregate level, the PLA of the group of supervised companies in relation to the levels of control referred to in art. 21, item V, as well as to demand actions from individual supervised companies in the event of their infringement, as provided for in the capital contingency plan.
Paragraph 1. It will be up to each individual supervised company, in terms of capital management:
I - monitor its PLA in relation to the control levels established in the capital contingency plan and, in the event of its infringement, take the necessary actions; and
II - in the event of a breach of the control levels referred to in art. 21, item V, adopt the actions demanded by the supervised company leading the prudential group.
Paragraph 2 The lead supervisor that is the direct or indirect parent company of other supervised companies in its prudential group may carry out the activities set out in par. 1 on their behalf.
CHAPTER VII
FINAL AND TRANSITIONAL PROVISIONS
Art. 23 The supervised company must keep the current and previous versions of the following documents, in accordance with the regulations in force:
I - ORSA's policy, referred to in Chapter III, Section II, as well as the internal regulations that implement it;
II - the ORSA report referred to in Chapter III, Section III;
III - capital contingency plan; and
IV - other documents proving compliance with the provisions of this Resolution.
Sole Paragraph. The supervised company must allow Susep prompt access to the documents mentioned in the head of this article, whenever requested by Susep.
Art. 24 Susep is hereby authorised to issue complementary rules and guidelines for the implementation of the provisions of this Resolution, including to determine:
I - a standardised format for drawing up the ORSA report, as well as the new mandatory information it must contain; and
II - compulsory stress tests, for the purposes of the provisions of art. 7, item III.
Paragraph 1 The determination of the provisions of items I and II of the main section may be made by means of specific communication to a nominally identified supervised company, or by issuing a circular letter, disclosures on an electronic site or other mechanisms that clearly specify the type or profile of supervised company to which it is addressed.
Paragraph 2 The communication referred to in par. 1 may, taking into account the circumstances of each specific case, grant additional time for the approval of the OSRO report.
Art. 25 Supervised companies will have the following deadlines to adapt to the provisions of this Resolution:
I - for supervised companies in the S1 segment:
a) until 31 December 2026 for the provisions of art. 8, item II, subitem "a"; and
b) until 31 December 2025 for the other devices; and
II - for supervised companies in the S2 segment, until 31 December 2026.
Sole Paragraph. The deadline for completion of the first ORSA validation cycle, in accordance with Chapter III, Section V, shall be four years from the approval of the first ORSA report, without prejudice to the provisions of art. 13, par. 2.
Art. 26 This Resolution comes into force on the date of its publication.
ALESSANDRO SERAFIN OCTAVIAN LUIS
(Official Gazette DOU of 30 September 2024 - pages 79 to 81 - Section 1; and Official Gazette DOU of 1 October 2024, page 46 - Section 1)
The information provided in this publication is general and may not apply to a specific situation or person. Every effort has been made to ensure that matters of concern to readers are covered. Although the information provided is accurate, be advised that this is a developing area. The information contained herein is not intended to be relied upon or to be a substitute for legal advice in relation to particular circumstances. Specific legal advice should always be sought from experienced local advisers. Accordingly, Editora Roncarati accepts no liability for any loss that may arise from reliance upon this publication or the information it contains.
