Circular Letter CVM/SIN 01/26

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL
Rua Sete de Setembro, 111/2-5th and 23-34th Floors – Center – Rio de Janeiro - RJ – ZIP: 20050-901 – Brazil Tel.: (21) 3554-8686 - www.cvm.gov.br Circular Letter No. 1/2026/CVM/SIN Rio de Janeiro, January 19, 2026

To

Managers and Administrators of Investment Funds

Subject: Interpretation of a provision of Normative Annex I of CVM Resolution No. 175 - Investment Funds

Dear Sirs/Madams,

1. This Circular Letter aims to disclose the interpretation of this technical area regarding the correct application and interpretation of the provisions set forth in § 3 of Article 73 of Normative Annex I of CVM Resolution No. 175.

2. We clarify that the disclosure of this Circular Letter is motivated by the presentation, to this technical area, of doubts raised by administrators and managers of Financial Investment Funds (“FIF”) regarding the provision.

3. Initially, we emphasize that the scope of the prohibition in the provision is limited to funds dedicated to the general public; and only for operations that result in "exposure to capital risk," that is, those carried out with the objective of leveraging the fund's portfolio.

4. In this regard, it is worth clarifying that, in the view of this technical area, the use of derivatives as a component of an investment fund's strategy can have three main and mutually exclusive objectives: (1) hedging, (2) directional bets on certain risk factors, or (3) leverage. And, once again, the limitation for "hedging or margin for guarantee in an organized market," as provided in the normative, should only be applied to the third type of operations with these derivatives.

5. For the purposes of applying the rule, therefore, an operation shall be considered as hedging that which aims to nullify or reduce exposures held spot by the fund; a leverage operation, those that have the objective of amplifying the risks of any position held spot by the fund's portfolio; and directional bets, all other modalities of use of derivatives, including those that generate an exposure of a nature different from those already existing in the fund's portfolio.

Sincerely,

Digitally signed by
MARCO ANTONIO VELLOSO DE SOUSA
Superintendent of Institutional Investors Supervision