Building on a comparative review of frameworks from nine other countries – France, Germany, Israel, Italy, Portugal, Singapore, Spain, the US and the UK – this OECD report recommends a range of actions to address weaknesses in the frameworks for derivative suits and arbitration in Brazil. Policy alternatives offered for Brazil seek to address procedural barriers that minority shareholders must surpass before filing derivative claims. Likewise, the cost allocation between the winning and losing parties serves as another important disincentive for effective private enforcement through derivative lawsuits. Finally, an arbitration framework designed mainly for commercial disputes with two parties might not work adequately for collective or multiparty corporate arbitrations, where, for example, confidentiality creates a number of challenges.