On the morning of Friday, June 12, 2026, Nubank customers opened an email, sent from an official company domain, informing them that the Central Bank had decreed the extrajudicial liquidation of the institution and instructing them to request reimbursement of up to R$ 250 from the Credit Guarantee Fund. The same notification appeared within the app. Within minutes, the news was circulating on social media and in investor groups.
It was a mistake. Nubank acknowledged sending the message in error , attributed the incident to a one-off operational failure, and reaffirmed that it is operating normally, with all licenses active. The problem is that the chosen term is not generic. Extrajudicial liquidation has a precise legal meaning, and just a few weeks earlier it had been seriously applied to Banco Master. The difference between the shock and the reality lies precisely in the legal framework that the expression designates.
What is the extrajudicial liquidation of a financial institution?
Extrajudicial liquidation is the process of closing a financial institution conducted by the Central Bank, governed by Law 6.024/1974 . It is not a judicial process. It is an administrative act of the regulator, which decrees the measure, immediately interrupts the institution's operation, and removes it from the National Financial System.
Once the measure is decreed, the Central Bank appoints a liquidator, responsible for assessing the complete financial situation, realizing the assets, and paying creditors in the legal order. Deposits are blocked, which triggers the Credit Guarantee Fund for the covered amounts. This is the most drastic of the three responses the regulator has for crises in supervised institutions. The other two are intervention and the Temporary Special Administration Regime (RAET), which changes the administration but keeps the institution functioning.
According to the lawyer, the difference between these three regimes defines what happens to ongoing contracts, guarantees, deposits, and lawsuits filed against the institution.
When does the Central Bank decree the liquidation regime?
The liquidation regime presupposes serious indications of insolvency or significant non-compliance with regulations. It is not a matter of convenience. It is a response to a financial situation that the regulator considers unsustainable.
The Master case illustrates the point well. On November 18, 2025, the Central Bank decreed the extrajudicial liquidation of Banco Master SA and Master Corretora, subjected Banco Master Múltiplo to the RAET (Special Regime for Temporary Asset Recovery) and extended the measure to other entities in the group, such as Banco Letsbank and Banco Master de Investimento. Insolvency was a determining factor, but suspicions of fraud in the purchase of assets, investigated in Operation Compliance Zero by the Federal Police, focused on the issuance of false credit instruments in the National Financial System, also weighed heavily.
The measure does not end the discussion. Within sixty days, the liquidator submits a report to the Central Bank, which decides whether to maintain the liquidation or convert the process into bankruptcy. Those who advise creditors, suppliers, or investors of an institution in this situation work against this timeline and need to know the order of payment to creditors to assess the real chance of credit recovery.
Liability of administrators and the FGC limit.
There is a common misconception that lawyers need to dispel with their clients: liquidation does not erase responsibilities. On the contrary. The process also exists to investigate the conduct of controllers and directors, who may be held liable for the institution's liabilities with their personal assets, in addition to being held criminally responsible for crimes such as fraudulent management and reckless management.
In the Master case, controller Daniel Vorcaro and his main partner were arrested, and the Federal Regional Court of the 1st Region upheld the arrest on the grounds of risk to public order and systemic fraud. The freezing of the administrators' assets is part of the logic of the regime, not an accessory.
For account holders or investors, the protection has a name and a limit. The Credit Guarantee Fund covers up to R$ 250 per person and per institution. Above that, the creditor depends on the outcome of the liquidation. It was precisely this mechanism that the erroneous Nubank email invoked when instructing the request for reimbursement from the FGC. The guidance would be correct if the fact were true. It wasn't.
Why does Nubank's mistake matter legally?
Communicating to a client, through an official channel, that their bank has been liquidated is not a neutral event. Nubank is a publicly traded institution, listed on the New York Stock Exchange, and its shares fell in trading immediately after the announcement. False information about extrajudicial liquidation, even if sent in error, touches on at least three aspects of interest to the lawyer: the consumer relationship with the alarmed client, the duty to provide accurate information in the capital market, and the integrity of the institutional communication itself.
Professionals working in this field need to distinguish between fact and faulty communication. A client who has made a hasty financial decision based on the message opens a discussion about damages. And a company that issues a communication of this severity due to an operational failure exposes itself to information governance questions that go beyond a simple apology.
The episode also has an unintentional educational value. It shows that the expression "extrajudicial liquidation" carries enough weight to move the price of a stock and generate panic in minutes. This weight comes from the legal framework behind it, and it is this framework that the lawyer in the financial sector needs to master.
The postgraduate program in banking law and capital markets at IDP
Mastering banking crisis regimes, the operation of the Credit Guarantee Fund, the responsibility of administrators, and the regulatory design of the National Financial System requires more than just keeping up with the news. It demands a systematic reading of Law 6.024/1974, prudential regulation, and sanctioning practices—territory that few lawyers navigate with confidence.
The IDP's Postgraduate Program in Banking Law and Capital Markets is structured for this professional. The program covers the structure, regulation, and stability of the National Financial System, with prudential supervision, banking crisis regimes, and money laundering prevention, and delves into financial operations and the capital market, including banking contracts and operations, investment funds, derivatives, the role of the CVM (Brazilian Securities and Exchange Commission), and sanctioning processes. It also addresses the digitalization of the sector, with open finance, fintechs, and virtual assets.
The faculty includes Guilherme Pupe, lawyer, electoral judge of the TRE/DF (Regional Electoral Court of the Federal District) between 2022 and 2026, post-doctoral fellow at the University of Granada and PhD and Master's degree holder from IDP (Institute of Legal Studies), and Raphael Carvalho, lawyer and academic coordinator of the IDP Law School. Classes are 100% online and live, held every two weeks, and the course begins on August 21, 2026. For those who intend to work with financial institutions, the time to build this technical foundation is before the next banking crisis arrives, not after.
The Master case is real, and the Nubank scare was a mistake, but both point to the same place: banking law has ceased to be a niche and has moved to the center of the economy. Those who understand the extrajudicial liquidation regime before it knocks on a client's door will be ahead of those who only study the topic when the notification arrives.
Manassés Lopes da Silva is a business lawyer and university professor. He holds a specialization in Civil Procedural Law from IDP and an LLM in Appeals and Proceedings in Higher Courts. He is a member of IRTS, the Institute of Appeals in Higher Courts. Email: contato@manasseslopes.com
