Publications

Category: Environmental

In order to improve the regulation on solid waste management and recycling in the country, two federal decrees published on April 14 established the National Solid Waste Plan (Planares) and the Recycling Credit Certificate (Recicla+) as a mechanism to incentive recycling and reverse logistics.

Federal Decree 11,043/22 instrumentalized Article 15 of Federal Law 12,305/10 (National Solid Waste Policy - PNRS), which sets the minimum content for Planares, to be prepared by the Federal Government, under the coordination of the Ministry of the Environment (MMA).

The decree enacted predicts the ways for creation of Planares, which determines, at national level, the strategy to implement legal provisions, principles, objectives and guidelines of the PNRS in the next 20 years.

Planares was prepared by the MMA by means of a cooperation agreement with the Brazilian Association of Public Cleaning and Special Waste Companies (Abrelpe), after contributions obtained at several public hearings and a public consultation, from July to November 2020.^[1]

To formulate Planares guidelines, the main source of data used was the Diagnosis of Urban Solid Waste Management, from 2010 to 2018, from the National Information System on Sanitation/Solid Waste (SNIS-RS), as well as information obtained from Abrelpe, the National Information System on Solid Waste Management (Sinir) and the Brazilian Institute of Geography and Statistics (IBGE).

Planares presents the diagnosis of the situation of solid waste in Brazil, followed by a proposition of scenarios, including national, international and macroeconomic trends. The plan should be updated every four years.

Among the provisions of Planares, the following targets stand out with respect to Urban Solid Waste (RSU), Civil Construction Waste (CCR) and Health Services Waste (RSS):

• Increase the economic and financial sustainability of waste management by municipalities;
• Increase the management capacity of municipalities;
• Eliminate inappropriate final disposal practices and shut down controlled dumps and landfills by 2024;
• Reduce the amount of waste sent to environmentally appropriate final disposal, through recovery of recyclable materials, biological treatment and energy recovery, with a recovery target of 48.1% of the total mass of RSU by 2040;
• Promote social inclusion and economic emancipation of collectors of reusable and recyclable materials, with the formalization of 95% of contracts executed by and between municipalities and waste collectors and cooperatives by 2040;
• Increase the recovery of the dry fraction of RSUs, from the current 3% to 20% in relation to the total mass, as well as increase to 50% the packaging recycling under the reverse logistics system by 2040;
• Increase recycling of the organic fraction of RSU, with recovery of 13.5% by 2040;
• Increase the recovery and energy use of RSU biogas to more than 60% by 2040;
• Increase recovery and energy utilization through heat treatment of RSU, with installed power capacity of 994 MW by 2040;
• Increase RCC recycling up to 25% by 2040; and
• Increase the environmentally appropriate final destination of RSS, so that all municipalities make adequate destination by 2040.

In addition to the recycling and reverse logistics goals and strategies outlined under Planares, Federal Decree 11,044/22 was enacted, establishing the Recycling Credit Certificate, Recicla+.

Recicla+ has as main objectives to:

• improve the implementation and operationalization of infrastructure and logistics in the sector;
• provide scale gains in recycling;
• promote the use of solid waste and its direction for energy recovery or the appropriate production chain;
• stimulate the development and consumption of recyclable products and inputs with smaller environmental impact; and
• match interests between the economic and social agents involved in the chain.

According to data released,^[2] it is estimated that the certificate can generate a potential investment of about R$ 14 billion per year in the recycling sector, increasing the income of waste collectors and all those involved in the reverse logistics chain, in addition to increasing the recycling rate of dry waste in the country and reducing recycling costs for companies subject to reverse logistics targets, as provided for in Art. 33 of the PNRS.

Recicla+ represents a recycling credit – issued by waste collectors cooperatives, consortium, private companies, civil society organizations, municipalities – corresponding to the verified amount of recyclable material destined for recycling or energy recovery. The certificate may be purchased by manufacturers, importers, distributors and traders for the purpose of proving compliance with their reverse logistics targets.

The issuance and acquisition of Recicla+ is voluntary, individualized and must be accomplished based in the Certificate of Final Destination (CDF), issued on the basis of the Waste Transport Manifest (MTR) and electronic invoices of the products/packaging trading operations that have returned for recycling or energy recovery.

The registration of the interested agents and the issuance of Recicla+ will be fulfilled in Sinir by the management entities authorized to operate the reverse logistics systems in a collective model.

The entire process must undergo prior approval of electronic invoices, carried out by an independent auditor hired by the managing body, to prove the veracity, authenticity, uniqueness and additionality of information related to the recycling of products and packaging.

Companies that do not adhere to the collective model of reverse logistics system through a management entity should set up their own structure to operationalize the system – including hiring an independent auditor for the approval of documents – and report the results to MMA.

With the institution of Planares and creation of Recicla+, the idea was to improve the management of solid waste in a proper, transparent and efficient way in the country, reducing the costs of companies subject to reverse logistics and providing income gain to others involved in the chain in benefit of higher waste recycling and preservation of the environment.

It is worth monitoring how public agents and the private sector will adhere to Planares’s strategies and goals and what incentives will be given to the use of Recicla+.

^[1] MMA website - Public hearings on the National Solid Waste Plan run through the regions of the country. Access on 04.20.2022

^[2] MMA website - Federal Government launches Recycling Credit Certificate - Recicla+. Access on 04.20.2022.

Category: M&A and private equity

Violations of the instruction currently revoked by CVM Resolution 44 were related to the non-disclosure of material fact notices

In April, 2022, the board of the Brazilian Securities and Exchange Commission (CVM) ruled over four proposals^[1] of settlement agreements arising from the non-disclosure of material notices and the negotiation with shares of publicly-held companies pending the disclosure of material fact notices. In all cases, the CVM’s board followed the favorable recommendation of the Committee for Settlement Agreements (CTC) on the proposals’ acceptance, with the consequential assumption, by the proponents, of monetary obligations ranging from R$ 21,132.00 to R$ 597,134.01, according to the case.

In the negotiation of the proposals, the following circumstances were taken into account when assessing the monetary obligation to be assumed by each proponent in its respective proceeding:

The Settlement Agreement is a legal statute provided for in RCVM 45 as an alternative method for the termination of CVM’s administrative proceedings. It can be proposed both in the pre-sanctioning phase and after the presentation of the term of indictment by the CVM.

According to article 81 of RCVM 45, "the execution of the Settlement Agreement does not imply confession as to the matter of fact, nor in recognition of the unlawful conduct examined". For this reason, it is not uncommon for this statute to be used as a defense strategy, since its legal effect is to terminate administrative demands before the CVM without the imposition of any official negative background on the proponents.

Despite the wide use in administrative proceedings, the settlement agreements as a method to close cases before the CVM implies that the proponent takes on obligations, which, in general, are of a monetary nature. Where appropriate, these obligations may also be linked to educational measures related to the capital markets, depending on the infringement investigated. Whatever the case, the proponent must always undertake to cease the practice of acts considered unlawful and correct irregularities, including by means of indemnification.

During the proceedings for the execution of a settlement agreement, the specialized federal prosecutor's office issues an opinion on the existence of legal impediments to the acceptance of the proposed settlement, the CTC negotiates the conditions of the proposal to be submitted to the CVM board and, finally, the CVM directors analyze, on a definitive basis, whether the execution of the settlement meets the objective desired by the applicable legislation, resolving on the acceptance or rejection of the proposal.

As described in the table above, in the presentation of the settlement agreement proposal and, mainly, during its negotiation with the CTC, the circumstances involved in the case are considered as a guidance for the CTC's recommendation to accept, suggest improvement or reject the proposal.

In the analysis of such circumstances, Article 86 of SCVM 45 provides that "the opportunity and convenience in executing the settlement, the nature and seriousness of the offences under the proceedings, the background of the accused or investigated or the good faith collaboration of those defendants, and the effective possibility of punishment in the present case" be considered.

Except for the standard followed by the CTC in previous negotiations in similar cases – an assessment that depends on the conduct under analysis in each case – the circumstances that usually operate in favor of negotiating less serious monetary obligations to proponents are:

• good track record of the proponent evidenced by the absence of other ongoing or completed proceedings or investigations;
• presentation of the proposal in the pre-sanctioning phase, which represents procedural efficiency for the public administration;
• conduct occurred prior to Law 13.506/17 enforceability, which altered the guidelines of CVM sanctioning activities;
• the low harm of the conduct according to Annex 63 to the RCVM 45; and
• the reduced scope of the losses generated by the investigated conduct, among other circumstances.

Also in the context of the negotiation of monetary obligations, in the assessment of the proposals highlighted above, the CTC recommended the improvement of the initial proposals after having considered the circumstances of the case. Thus, it also aimed to establish a monetary obligation that is related to the conduct under analysis, in order to inhibit similar behaviors in the future.

As a matter of fact, it is possible to note that the CTC usually analyzes whether the monetary obligation is equivalent, at least, to the amount of the injury caused and/or advantage taken by the agent. In those cases where the value of injury or advantage is not significant, CTC can also find grounds in:

• the percentage of deviation from the expected parameter;
• in the traded volume of the asset; and/or
• multiples (usually three times) of the injury and/or advantage of the injury.

Some data on the execution of settlement agreements by CVM over the years can be found in the Capital Market Observatory, a data mapping sponsored by a Brazilian association, which found, for example, in the records between 25/01/2000 and 26/03/2019, the existence of 601 cases with settlement agreement proposals, from which 351 were executed even if partially.

Of this total, more than 90% resulted in the assumption of monetary obligations. In addition, non-disclosure conducts generally lead the ranking of proceeding closed via settlement agreement, appearing in more than 70% of cases.^[6]

For the cases highlighted herein, whose conducts were, in summary, related to violations of ICVM 358 (revoked by RCVM 44), the identification of the agent as tipper which obtains inside information from the source – or tippee – that obtains the information by other means, including by exchanging information with the tipper - was considered to negotiate the assumed monetary obligations.

Hence, in order to negotiate a settlement agreement proposal with the CTC, it is necessary to take into account that the CVM will find grounds on specific circumstances of the investigated conduct, such as similar precedents and the elements specific to the alleged infringement, as well as in general circumstances weighted in all cases, regardless of the infringement, such as the agent's background, the procedural phase, the injury of the conduct, magnitude and scope of the advantage and/or injury, among others.

Considering the relevance of the statute and its consequences for the sanctioning proceedings, the detailed strategic analysis of the convenience of submitting the proposal and a careful study of the conditions to be offered are essential to ensure greater legal certainty and better chances of success in its acceptance at the end.

^[1] CVM PAS SEI 19957.0002923/2017-81 (ruled 05 De Abril, 2022), PA CVM SEI 19957.004542/2020-32 (ruled on April 5, 2022), CVM PA SEI 19957.000157/2021-05 (ruled on April 5, 2022) and PA SEI 19957.006367/2021-07 (ruled on April 12, 2022).

^[2] Equivalent to the advantage obtained by the proponent indexed to monetary adjustment.

^[3] Article 86 - In the decision of the proposal, the board must consider, among other elements, the opportunity and convenience of the settlement, the nature and severity of the offenses subject to the process, the track record of the accused or investigated or the good faith collaboration of these, and the effective possibility of punishment, in the specific case.

^[4] Equivalent to three times the value of the advantage taken by the proponent according to the defense.

^[5] See note 3 above.

^[6] For more information, please visit: Capital Market Observatory.

Category: Environmental

With the purpose of advancing the agenda of environmental regularization in all Brazilian biomes and ensure compliance with the Brazilian Forest Code, the Ministry of Agriculture, Livestock and Supply (Ministério da Agricultura, Pecuária e Abastecimento), published on March 29, 2022, the Federal Decree 11015/22, which establishes the National Plan for Environmental Regularization of Rural Properties (RegularizAgro) and its Managing Committee.

RegularizAgro aims to develop a government action plan that includes the Federal Government and the States and develops through:

• proposal of measures to comply with the principles and guidelines of environmental regularization in rural properties and possessions;
• coordination of public and public-private strategies and actions aimed at environmental regularization of rural properties;
• guidance of government action to carry out the regularization of rural properties, in compliance with the obligations provided for in the Forestry Code;
• articulation of efforts, at the federal, state, district and municipal levels, of a political, strategic, normative and technological nature, in order to ensure the necessary institutional and organizational alignment between the public agencies responsible for the implementation of the Environmental Regularization Program (Programa de Regularização Ambiental - PRA) at the state and district levels of rural properties; and
• promotion of actions aimed at the environmental recovery of rural properties, without losing the productive aspects of the areas, in compliance with the legislation and in articulation with all federal entities.

One of the objectives of the plan is "to promote and improve the integration of information systems and databases that enhance the application of the Rural Environmental Registry (Cadastro Ambiental Rural – CAR) in the context of land use planning, territorial management for the sustainable development of Brazilian agriculture and its interface with other public policies". It is also intended to improve the processes of environmental regularization with  inclusion of information in the National System of Rural Environmental Registry (Sistema Nacional de Cadastro Ambiental Rural - Sicar).

RegularizAgro was regulated shortly before the 10th anniversary of the Forestry Code (Law 12651/12), which, among several innovations, created the Rural Environmental Register (CAR).

The CAR is the national and mandatory electronic public register of rural properties. It aims to integrate environmental information of rural properties and possessions, as well as to establish a database for control, monitoring, environmental and economic planning and combating deforestation.

For CAR enrollment, the owner or possessor has to submit information of the rural property, such as:

• identification of the owner or holder of the rural property;
• evidence of ownership or possession; and
• presentation of the plan and descriptive memorial for the area, which shall encompass "the location of the remnants of native vegetation, protected areas, restricted use areas, consolidated areas and the location of the Legal Reserve", if any, according to Art. 29 of the Forestry

Enrollment in CAR must be executed through an electronic system in the applicable state agency in which the rural property is located. After this stage, those responsible for areas with environmental liabilities originated by the suppression of native vegetation carried out until July 22, 2008 in Permanent Preservation Area (Área de Preservação Permanente -"APP”), Restricted Use Areas and Legal Reserve (Áreas de Uso Restrito e Reserva Legal) may opt to adhere the PRA.

Creation of the Managing Committee

Decree 11015/22 also establishes for incorporation of managing committee that, among other assignments, should develop and approve strategies, goals, monitoring indicators and deadlines of RegularizAgro, as well as contribute to the success of public and public-private initiatives aimed at environmental regularization.

The committee shall be composed of:

• two members of the Ministry of Agriculture, Livestock and Supply (one from the Brazilian Forest Service (Serviço Florestal Brasileiro – SFB) and another from the Secretariat of Agricultural Policy);
• a member of the National Institute of Colonization and Agrarian Reform (Instituto Nacional de Colonização e Reforma Agrária - Incra);
• a member of the Ministry of the Environment (Ministério do Meio Ambiente);
• a member of Empresa Brasileira de Pesquisa Agropecuária (Embrapa);
• a member of the National Council of Secretaries of State for Agriculture (Conselho Nacional dos Secretários de Estado de Agricultura - Conseagri); and
• a member of the Brazilian Association of State Environmental Entities (Associação Brasileira de Entidades Estaduais de Meio Ambiente - Abema).

Each entity has up to 30 days from the publication of the decree to indicate its representatives.

The decree allows agreements, cooperation arrangements and adjustments to be signed with administrative entities and with private entities and international organizations.

It will be important to closely monitor the implementation of RegularizAgro, especially to assess the impact of the current diversity of systems adopted for registration in the CAR. The Forestry Code provides that the enrollment of rural property in the CAR should be carried out preferably in the municipal or state environmental agency and, currently, there are several systems in operation.

Information released by the Ministry of Agriculture, Livestock and Supply in January 2021 demonstrate, for example, that five states had their own electronic systems for registration in CAR: Bahia, Espírito Santo, Mato Grosso do Sul, São Paulo and Tocantins. Six states use applications developed within the federal level, but with their own database: Acre, Mato Grosso, Minas Gerais, Pará, Rio Grande do Sul and Rondônia. The other states used Sicar applications and information technology infrastructure provided by the SFB and the Ministry of Environment.

With RegularizAgro, it is expected easier and more efficient interaction between entities of the Public Administration (federal, state and municipal). This could enhance the effectiveness of the regularization of rural lands in the country and contribute to an increase in actions to protect native vegetation and other protected areas.

After the appointment of the members of the managing committee and the technical chambers of specific subjects to fulfill the purposes of RegularizAgro, the Ministry of Agriculture, Livestock and Supply has 180 days to present the results of the project. After this period, complements and new guidelines on the subject may be issued.

Category: Real estate

Between 2020 and 2021, the increase in the dollar rate, tied to the high demand for commodities, triggered a significant rise in the General Market Price Index (IGP-M), usually used as an indexer to correct the values of lease agreements.

The increase in the IGP-M (which closed 2021 with 17.81% and accumulated, in May of the same year, a positive variation of 37.04% in 12 months) established a crisis in lease relations and evidenced a problem: the absence of an index that effectively reflects the variations in agreements.

The IGP-M is an index directly affected by the situation of the foreign market and does not have any relationship with the cost of housing in its calculation. For this reason, with the increased reality of the country recorded in the years 2020 and 2021, lessors and lessees began to renegotiate how to correct the values of the contracts.

One of the widely used solutions has been the replacement of the IGP-M by the  Amplified Consumer Price Index (IPCA), which is based on the "inflation of a set of products and services marketed in retail, referring to the personal consumption of households" and which, therefore, also has no direct relationship with variations in the real estate market.

There is, then, an unstable scenario, since both the IGP-M and the IPCA are indices intended for other purposes and do not reflect the changes in the real estate market.

With the proposal to "fill a gap in national statistics" in the niche of lease agreements, the Getúlio Vargas Foundation (FGV) created, on January 11, 2022, a calculation-based index that specifically considers the rental variations, the Residential Rent Variation Index (Ivar). Reported on a monthly basis, the index is part of the fixed calendar of indexes published and calculated by the institution.

To create Ivar, FGV searched for partnerships with real estate management companies, in order to collect data on the values of new agreements and adjustments of existing ones, as well as information on the characteristics of each property. It is important to note that Ivar was designed primarily with the objective of creating an index based on effective agreements data, and not, for example, on rental offer ads.

In its methodology, Ivar applies the weighted average of the data obtained from about ten thousand residential property leases in force in four Brazilian capitals: São Paulo, Rio de Janeiro, Belo Horizonte and Porto Alegre. The expectation is that more cities will be added to the calculation of the index so that it more accurately reflects the situation of the country.

The index also sought to monitor the advances of these lease agreements in the last three years, including both extraordinary variations and pandemic periods, as well as ordinary variations, which commonly result from leases, such as contractual adjustment. In January 2021, the index recorded an increase of 1.86%, while in February 2021, the accumulated change in 12 months was 2.92%.

It is a revolutionary index, which promises to solve the main point of conflict in lease relations and ensure greater predictability in the agreement relationship. However, we understand that there is a long way to go for Ivar to be incorporated by the real estate market, especially in relation to the expansion of the data used for its calculation.

According to a survey conducted in 2018 by the Brazilian Institute of Geography and Statistics (IBGE), Brazil has approximately 12.9 million properties rented for residential purposes. A base composed of ten thousand contracts, located in four capitals, therefore, is not enough to consolidate an index that aims to solve a problem of leases throughout the Brazilian territory.

In addition, Ivar has also limited  nature of the occupation of the property. The index seeks to analyze only variations in residential leases and does not apply to agreements for commercial purposes. In fact, FGV does not yet have robust information about this rental segment. We emphasize that there are no legal impediments to adopt Ivar also in commercial relations, but, as the index is composed today, it will not reflect the reality of these leases and will not be able to resolve the existing controversy.

The moment, therefore, is for caution. It is important to wait for the index to be consolidated and with sufficient data to more fully reflect the real estate reality of Brazil.

Category: Competition

Pursuant to Ordinance 104/22, issued in March 2022, the Brazilian antitrust agency (Cade), updated the Predatory Pricing Analysis Guidelines, published in 2002. Predatory pricing – often mistaken for dumping – is the conduct to sell goods or provide services unjustifiably below the cost price.

Cade has investigated several cases on predatory pricing without, however, convicting any company since the entry into force of Law No. 8.884/94, which preceded the current Brazilian Antitrust Law (Law No. 12.529/11).

Carrying out a predatory pricing investigation is an extremely complex task because simply selling below cost price does not constitute an antitrust violation. According to Cade's precedents, proof that there was a reduction of cost prices for a certain period is insufficient to conclude that there was unlawful predatory pricing. It is necessary to prove that the company charged prices below the average variable cost, aiming to eliminate its competitors to increase the referred prices at a later stage. Then, the company would be able to recover its initial losses in a much less competitive market and make profits similar to those of a monopolist.

The ordinance aims to guide the economic analysis and reduce Cade’s investigation costs. According to the guidelines, Cade shall observe the following steps, successively:

• definition of the relevant market;
• structure of such market and entry conditions;
• supply conditions of the investigated company and its production capacity;
• that company's financial capability to withstand short-term losses, by its own or through third parties; and
• comparison between price and cost.

In the last stage, the most complex of all, the guidelines suggest that the production costs – total average cost (total cost divided by the number of goods produced) and average variable cost (total variable cost divided by the number of goods produced) – be analyzed.

When the price is equal to or higher than the average total cost of production, the practice shall not be deemed as predatory pricing. If the price is between the total average cost and the average variable cost, it is possible that the company practiced predatory pricing. In this case, Cade analyzes the demand and supply conditions (for example, whether there was a sudden demand contraction in the industry or excess capacity) that could justify the practice. After assessing all the steps, if price is lower than the average variable cost, Cade understands that there was unlawful predatory pricing.

In practice, the guidelines of the new ordinance are not expected to necessarily promote convictions for predatory prices because the average variable cost analysis is difficult to apply. In Brazil and abroad, there are even discussions on the use of other methodologies to identify the existence of this type of antitrust violation. For instance, the analysis of structural preconditions that may suggest a rational predatory conduct and the use of concepts of game theory, with the analysis of asymmetric information as a central factor for the discussion of economic rationality.

Category: Real estate

Published in the Official Gazette on March 9, 2022, Law 14,309/22 amended the Civil Code to allow conversion of condominium meetings into permanent sessions (paragraphs 1, 2, and 3, of article 1,353, Civil Code) and allow the convening, holding, and resolution of any type of meeting by electronic or hybrid form (article 1,354-A).

The legal permission for virtual condominium meetings was already a trend since the enactment of Law 13,777/18, which included in the Civil Code the normative provision (article 1,358-Q, VIII), whereby, when a condominium adopts the multi-ownership system, its bylaws must provide for the "holding of non-presence meetings, including by electronic means."

In the same vein, virtual meetings were exceptionally allowed until October 30, 2020, by Law 14,010/20, which instituted transitional and emergency rules for the regulation of private law legal relations due to the covid-19 pandemic. After the end of the period, however, there was no longer any legal support for this possibility, unless expressly provided for in the condominium agreement.

The legislative innovation changed the scenario and opened the definitive possibility of holding virtual or hybrid meetings, as long as these modalities are not prohibited by the condominium’s agreement and the condominium's owners are guaranteed the right to speak, debate, and vote, maintaining an environment in which all participants can participate, even if virtually.

Once the electronic or hybrid form of holding the meeting is adopted, the condominium must include this information in the call notice, in addition to providing instructions for access, taking the floor, and collecting votes.

For the purpose of conducting the meeting, the documents pertinent to the agenda may be made available to the participants in physical or electronic form. The minutes must also be drawn up electronically, but only after all the votes have been summed up and made public, at which point the meeting shall be adjourned.

Just like in-person meetings, virtual or hybrid meetings must observe the minimum legal and contractual quorums for calls to order and resolutions.

Joint owners may decide to include complementary rules concerning electronic meetings in the bylaws, upon approval by a simple majority in a meeting called for this purpose. On this issue, a source of inspiration is DREI Normative Instruction 79/20which brings in great rules for operation digital meetings, possibly usable by condominiums.

The long-awaited legislative change is the possibility of converting the meeting into a permanent session when the resolution requires a special quorum provided by law or agreement and this quorum is not reached. This is what happens, for example, in the case of resolutions to change the agreements, which require approval of 2/3 of the joint owners' votes, or to change the use of common areas, when unanimous approval by the joint owners is required.

For this to be possible, the following requirements are necessary, cumulatively:

• the majority of those present decide on conversion;
• the date and time of the follow-up session, which may not exceed 60 days, are indicated;
• those present and the absent units are summoned in the manner provided for in the agreement;
• the partial minutes are drawn up and sent to all unit owners, present and absent;
• on the appointed day and time, the deliberations continue, in the same minutes that were partially drafted.

The votes given in the first session will be registered, without the need for the owners to appear again to confirm them. If they are present at the next meeting, the owners can request that their votes be changed.

The permanent session may be extended as many times as necessary, provided that the meeting is completed within 90 days.

Long awaited, these innovations accompany the evolution of society and come at a good time to allow owners and purchasers of autonomous units in condominiums with access to technology and the world wide web to actively participate in the deliberations of the meetings, even if at a distance. In addition, the changes provide condominium building managers with more tools and legal security to conduct their work.