Fintech Law Series: Order Routing Systems

Regulatory Framework

• Fintech Law 21.521: General framework governing technology-based financial services

• General Rule No. 524 (NCG N°524): Regulation specifying the requirements for registration and authorization

Checklist: Are You an Order Routing System?

According to Fintech Law 21.521, your company may be considered an Order Routing System if it engages in the following activities:

1. Order Communication

Does your company…?

• Communicate orders involving publicly offered securities or financial instruments?

• Route buy or sell orders on behalf of third parties?

• Operate without restricting clients in choosing the recipient of the order?

Practical Example:

If you run a platform that connects investor orders to multiple intermediaries or trading systems—without influencing which recipient the client selects—you likely fall under this category.

2. Types of Instruments You Route

Do you handle…?

• Publicly offered securities (stocks, bonds)

• Debt-representing instruments

• Virtual financial assets

• Contracts intended to generate monetary returns

3. Order Destinations

Do you route orders to…?

• Alternative Trading Systems

• Securities intermediaries

• Stockbrokers

• Specialized trading platforms

Key Obligations

If you’ve identified your company as an Order Routing System, you must:

• Maintain detailed records of routed orders

• Implement risk management systems

• Ensure traceability of operations

• Guarantee neutrality in the routing process

Important Note

The CMF has set February 2, 2025 as the final deadline to register in the Financial Service Providers Registry.

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