At the moment, Brazil's banking system is peculiar: commercial banks lend to the government and supply consumers credit, but do not provide much debt to businesses, which mostly finance themselves from retainedprofits.
It could thus go through a period of making losses and simply offset these losses with later profits that are partly retained rather than handed over to the US Treasury.
In particular, it may be difficult to determine whether principal risk has been retained because (i) the retention of such risk is necessary to provide intermediation and liquidity services for a relevant financial instrument or (ii) the position is part of a speculative trading strategy designed to realize profits from price movements in retained principal risk.