IPS has no specific internal protocols to recover principal and interest if a bank receiving pension funds falls into arrears, insolvency or bankruptcy. The absence was identified in an audit by the Comptroller General's Office, which recommended specific mechanisms to prevent, monitor and recover investments.
Asked about the procedures applicable to savings deposit certificates (CDA), the Social Security Institute said it relies exclusively on Law No. 2,334/2003 on Deposit Insurance. The Comptroller General's Office said this legal reference does not replace internal operating protocols capable of guiding the institute's response to a banking crisis.
The gap involves resources from the Common Pension and Retirement Fund (FCJP), which must be managed according to the security, diversification and risk-management criteria established in Laws No. 98/92 and No. 7,235/23. CDA account for 46.62% of IPS's investment portfolio, according to the fund's institutional context.
The audit also identified a change in the distribution of deposits in guaraníes. The share invested in banks with an AAA rating fell from 22.72% in 2023 to 15.36% at the end of 2025—a reduction of 7.36 percentage points. During the same period, the share of institutions rated AA rose from 63.54% to 75.32%, while the A category fell from 13.74% to 9.32%.
The report notes that this change did not result from a deliberate IPS disinvestment policy. The concentration in the AA range occurred mainly because institutions such as ueno bank and Banco Familiar improved their risk ratings, moving from A to AA.
In dollar-denominated investments, the share of AAA-rated banks rose from 9.63% in 2024 to 17.12% in 2025. The AA category accounted for 64.65% of the portfolio, while the A range fell from 40.55% in 2023 to 18.23% in 2025. Banco Río's absorption by Banco Continental influenced part of this movement.
The Comptroller General's Office said the lack of specific procedures leaves the reserves exposed to counterparty risk: if a financial institution fails, IPS would depend on the general process established under deposit-insurance legislation, without a detailed internal plan to protect insured people's funds.