SFH vs SFI: Brazil's two mortgage regimes

The SFH conditions

Article 13 of Resolução CMN 4.676 lists the specific conditions of SFH operations:

1. A ceiling on the appraised value of the financed property. The 2018 text said R$ 1,500,000; Resolução CMN 5.255, published in the Diário Oficial on 10 October 2025 and effective on publication, raised it to R$ 2,250,000.
2. A maximum effective cost to the borrower of 12% a year, including interest, commissions and other financial charges. The cap rests on Lei 8.692 of 1993, article 25, which says the effective interest rate in SFH financing “será de, no máximo, doze por cento ao ano”.
3. If the contract updates the balance, the update uses the basic remuneration of savings deposits.

The 12% cap does not include the insurance premiums (borrower’s death and disability, property damage, builder’s liability) or the two fees allowed by article 14: a fee for analysing an individual insurance policy and a monthly contract administration fee of up to R$ 25.00. Resolução 5.208 of 2025 later added a sole paragraph to article 14, which Payotte did not use for this guide. The custo efetivo total required by Resolução 4.881 is a different measure and does include insurance and fees (CET).

What “outside the SFH” means

The rules read use the SFH as a defined category and apply some conditions only to it. The general rules of Resolução 4.676 (loan-to-value limit, guarantees, transparency) apply to real-estate loans by authorised lenders whether or not they are SFH. A loan on a property above R$ 2,250,000, or one priced above the 12% cap, cannot be an SFH loan. Payotte did not find a rate ceiling for loans outside the SFH in the texts it read, and does not assert one. Lei 9.514 states the purpose of the Sistema de Financiamento Imobiliário (SFI) in article 1: to promote “o financiamento imobiliário em geral”, under conditions compatible with how the funding is raised. Article 2 lists who may operate in it: savings banks (caixas econômicas), commercial and investment banks, banks with a real-estate credit portfolio, real-estate credit companies, savings and loan associations, mortgage companies and, at the CMN’s discretion, other entities. Article 3 adds the securitization companies that buy real-estate loans and issue securities backed by them. The same law created the alienação fiduciária guarantee over real property, explained in alienação fiduciária.

In short, the SFI is the general framework for real-estate finance and securitization, and the SFH is the subset with its own value ceiling, cost cap and savings-based funding. A borrower does not choose a regime in the abstract: the property’s value, the lender’s funding and the contract decide which one applies. Ask the lender, in writing, whether the loan is an SFH operation, because the answer decides FGTS access.

Why the line matters

• FGTS: article 20 of Lei 8.036 lets a worker use the FGTS balance to pay for a home only if the operation is “financiável nas condições vigentes para o SFH”. A purchase outside the SFH cannot use it. See using the FGTS.
• Insurance: the legal requirement for death, disability and damage cover is written for SFH lenders (MIP and DFI).
• Portability: a loan moved to another lender keeps its SFH status, except for the value ceiling (Resolução 5.057, article 12). See mortgage portability.
• Loan size: the 80% and 90% limits are set for all residential purchase loans, not only SFH (how mortgages work).

A calculation

If a home is appraised at R$ 2,400,000, it is above the SFH ceiling by R$ 150,000. The lender’s appraisal, not the contract price, is the figure that counts, so two properties with the same price can fall on different sides of the line (calculation of Payotte, not an official example).

Still to come

Resolução 5.255 changes the system in stages. Some provisions applied from 1 January 2026; others, including a new list of SFH operations and a change in how savings deposits must be lent, apply from 1 January 2027 and are not in force on 15 October 2026. They are published rules with a future date, not proposals, but their effect on borrowers has not been measured.

Which professional to consult

A mortgage lender can say whether a specific property and loan qualify for the SFH (mortgage lender). A property appraiser prepares the valuation that fixes the ceiling test (property appraiser).