CIRCULAR LETTER/CVM/SIN/No. 02/2014

Rio de Janeiro, December 26, 2014

To: Representatives of Non-Resident Investors.

Subject: Guidelines on the new version of the Foreign Investors System available on CVMWeb

Dear Sir,

The purpose of this Circular Letter is primarily to clarify doubts and outline general guidelines regarding the use of the new version of the Foreign Investors System ("SIE-WEB"), which will be made available in the restricted access system for Representatives of Non-Resident Investors on CVMWeb starting January 5, 2015.

The new version of this system is based on three pillars of development: (1) granting greater agility and autonomy to the participant in requesting, granting, and maintaining the investor's registration with the CVM, without compromising the security, consistency, and integrity of the investor's information; (2) allowing the representative to consult the database of investors they represent with the CVM; and (3) structuring an environment that allows the CVM itself to perform supervision of this market more effectively.

As part of this greater autonomy in granting and maintaining investor registration, we highlight the new functionality that allows, based on an agreement signed with the Brazilian Federal Revenue Service ("RFB"), the obtaining of a CPF (individual taxpayer registry) number for non-resident investors categorized as natural persons (i.e., classification type "i").

The functionalities to be made available to representatives of non-resident investors in the new version of the system are as follows:

Creation of portfolios (own or collective);
Inclusion of a participant in a collective account;
Registration alteration (name, address, qualification) of the investor;
Cancellation of a participant from a collective account;
Cancellation of a portfolio (own or collective);
Submission of (occasional) information regarding the transfer of funds;
Consultation on the registration status of investors represented by the institution.

Thus, the main general usage guidelines for the system are set out below. More details on the use of the system can be found in the "User Manual," which is attached to this Circular Letter and will also be made available on the CVM website in due course.

It should be noted that the registration of each user of the new version of SIE-WEB will be carried out by the CVM itself. To this end, Representatives of Non-Resident Investors must send, to the electronic address gie-internet@cvm.gov.br, starting from December 29, 2014 and whenever changes are necessary, the full name, CPF, and which functionalities (see list above) should be made available to each of their employees. If you need further clarification, please contact analyst Paulo Bonin at the above electronic address or by phone at (21) 3554-8471.

1. REGISTRATION AND CANCELLATION OF REGISTRATION OF NON-RESIDENT INVESTORS

1.1 INVESTOR REGISTRATION

With the new version of the system, the initial process of registering a non-resident investor, which previously involved manual intervention and analysis by the CVM's technical area, will now be conducted almost entirely by the representative of the non-resident investor themselves.

Thus, the first necessary step will be to register the investor in the "Investors" menu, provided they do not already have a registration with the CVM. It is worth noting in this regard that the initial screen of this menu has a query tool that should be activated whenever there is no certainty regarding the non-existence of a prior registration for the investor, as a way to verify that the request will not unduly duplicate this registration.

The characters admissible for entry into the system when registering the investor in the new version of the system are, in addition to all characters provided for in the Portuguese Language, uppercase or lowercase, also numeric (0 to 9), and the characters listed below:

Designation	Symbol
Slash	“/”
Comma	“,”
Period	“.”
Hyphen	“-“
At sign	“@”
Colon	“:”
Ampersand	“&”
Asterisk	“*”
Plus	“+”
Underline	“_”
Single Quote	“'”
Parentheses	“(“ or “)”
Greater than	“>”
Exclamation mark	“!”
Space	“ ”

In the investor registration process, it is worth observing the availability, by the system, of new fields in the case of information regarding classification “i” for the investor ("foreign resident individual"). The first of these asks whether the investor already has a CPF. If positive, this number should then be entered, and if negative, 3 more fields will appear for completion, with the aim of supporting the generation of the CPF in the Revenue systems. These are: "Sex", "Date of Birth", and "Mother's Name".

We alert, however, that the CPF will only be granted by the CVM and Federal Revenue systems after linking this investor to an account, whether own or collective, which will also be carried out by the investor's representative in the new system, as will be seen below.

Considering the specifics of the CPF granting system maintained by the RFB, the following observations regarding the information to be entered in these and other investor registration fields for natural persons are still necessary:

Any special characters should be avoided when entering the investor's name or the investor's mother's name. When there are characters of this nature, we request that they be replaced by the closest graphic counterparts (for example, “n” instead of “ñ”, “a” instead of “á”, “à” or “ä”, and so on). Similarly, numeric characters are not accepted (thus, names like Henrique 3, for example, should be avoided, using the term “III” for indications of descent in this case).
Similarly, we request avoiding descriptions that do not meet the other size or character type criteria accepted by the RFB systems. The most important admitted criteria for the natural person investor are as follows:
a. Address: alphanumeric field, maximum size of 40 characters. b. Complement: alphanumeric field, maximum size of 19 characters.
c. Mother's Name: alphanumeric field, maximum size of 60 characters (see also item 3 below).
In extremely exceptional cases, it is possible that the investor's mother is not known at the time of registration. In these cases, the information “[Mother] [Mae] Unknown” must be entered in the “Mother's Name” field. It is always worth reinforcing the representative's duty to ensure the consistency and integrity of the information provided, which is why we remind you that the use of this possibility is restricted exclusively to cases where the identification of the investor's mother is indeed impossible.
The system will not generate CPFs for investors under 18 years of age at the time of the request, nor in the cases of investors residing in Brazil or of Brazilian nationality, as these cases involve the need to present documents and information not covered by the agreement signed between the CVM and the Federal Revenue.
Investors residing in Brazil, as usual, should not obtain registration with the CVM under the terms of CMN Resolution No. 2,689/00, as they do not meet the requirement provided for in classification “i” (intended, as is known, for investors residing abroad). However, investors of Brazilian nationality but residing abroad may obtain registration with the CVM, provided they already have a CPF at the time of registration, given the observation contained in item (4).
Finally, in the event of improper granting of a CPF to a given investor (which can be verified immediately after completing registration, by consulting the registrations of this investor), we suggest alerting the CVM via message to the address gieinternet@cvm.gov.br, so that the necessary measures can be taken.

For a period of 90 days after the initial granting of the CPF, the RFB systems will allow the rectification of information entered incorrectly in the initial registration made at the CVM, corrections that will thus impact both our databases and those of the RFB. The information subject to correction in the Federal Revenue database is the investor's name, the mother's name, the date of birth, and the sex.

After this period, for this and any other need for maintenance of the investor's CPF registration, the representative must arrange it directly with the respective competent authority (RFB).

After the completion of the investor's registration, a unique, individual, numeric, and 6-digit code will be generated and informed to the representative, as usual, which will become the identifier of this investor in our databases.

1.2 LINKING THE INVESTOR TO AN ACCOUNT, OWN OR COLLECTIVE

After the investor registration operation, it will be up to the representative themselves to proceed to the second step of the registration, which is linking this investor to an account, whether own or collective. To this end, in the first case, the “Accounts” menu should be accessed, and in the second, the “Participants” menu.

In the case of the own account, which by definition is intended for the single investor who will henceforth be linked to it, a new account must be created, with access to the “Create” option, and the respective completion of all information regarding the account to be created.

As for the collective account, the “Include Participant” option should be accessed, with the subsequent indication of the collective account to which the investor belongs.

In either case, if all necessary information is provided satisfactorily, the system will return with confirmation of the operation and the following information:

I. Process Number: As is known, the numbering of CVM administrative processes follows the following structure: RR-AAAA-NNNNN, where “RR” is the CVM Regional office where the process is opened (in the case of these processes, it will always be “RJ”); “AAAA” is the year in which the process was opened; and “NNNNN” is then the sequential identifier number of the process that will be provided by the SIE-WEB system.

II. Protocol Number: This is the sequential identifier number of the request made. It is the code that should be used as a reference by the user, when contacting the CVM External Support, whenever there is any system problem related to the request.

III. Operational Code: This is the investor's code, already granted by the system, in the structure RRRRR.CCCCCC.IIIIII.N-V, where “RRRRR” refers to the investor representative's code, “CCCCCC” will correspond to the own or collective account to which the investor belongs, “IIIIII” will represent the individual code of the investor (as already obtained during the investor's registration), “N” will refer to the type of account in which the investor was included (“0” if own, and “1” if collective), and “V” will be the check digit, calculated automatically by the system.

It is important to note, as mentioned above, that the investor's operational code will be obtained directly and automatically by the investor's representative whenever they successfully conclude an operation of registering a non-resident investor.

We know, however, that the granting of the investor's operational code represented a crucial step in the old registration regime for non-resident investors, insofar as it indicated a first return, by the CVM, of the regularity of the request made, even if, of course, still subject to definitive validation by this Superintendence, which was embodied by means of a digital letter addressed to the electronic address registered by the investor's representative.

Thus, it is important to highlight that, in the same way as was done in the old registration regime, the CVM's technical area will carry out the necessary analysis of the registration request, although, now, at a later stage of this process.

Considering the circumstances imposed by the new registration regime, we deem it pertinent to alert that:

A) The status of the registration request can and should be monitored, either by the investor's representative or by any interested third party, by consulting the “Process Query” tool, available in the “Quick Access” item on the CVM website, in which the process number provided to the applicant as per item I above should be used as a query filter.

B) This Superintendence, due to the new regime, and considering still the possibility of verifying the status of the request at any time through a public query to be carried out as per item A above, informs that it will no longer issue letters communicating the approval of non-resident investor registration requests, serving the result of the aforementioned query, for all legal purposes, as a suitable means to prove the status of the request.

Finally, we inform that a similar dynamic will also be adopted for cases of requests for cancellation of registration (whether inclusion in a collective account or portfolios, own or collective) of non-resident investors carried out through SIE-WEB.

2. CONSULTATION ON THE REGISTRATION OF NON-RESIDENT INVESTORS

As already mentioned, in the new SIE-WEB it is now possible, for a given representative, to consult the entire registration database of non-resident investors they represent.

As a registration database, one should interpret the entire set of information available in the CVM databases regarding a given investor, such as, for example, their registration data (address and other contacts), their individual and operational codes, the registration number at the RFB (CPF or CNPJ, as the case may be), the account to which they belong, the date of registration, the status of the registration, among others.

The User Manual, which is attached to this Circular Letter, explains how to operate, in SIE-WEB, to perform such queries. Without prejudice to this, it is worth highlighting some important observations resulting from the use of this new tool:

A) Naturally, doubts related to the registration, at the CVM, of non-resident investors can and should now be resolved by the representative themselves through consultation of the database, as available in SIE-WEB.

B) Whenever the representative of an investor changes the denomination (or name) of the represented investor, or their country of constitution (tax domicile), and this investor has an active registration with other representatives as well, all these other representatives will receive an alert email from SIE-WEB regarding the alteration.

C) The status of requests for changes in social denomination can and should be monitored, either by the investor's representative or by any interested third party, by consulting the “Process Query” tool, available in the “Quick Access” item on the CVM website, in which the process number provided to the applicant as indicated in item 1.2.I of this Circular should be used as a query filter.

D) Similarly, due to the new regime, and considering still the possibility of verifying the status of registration changes at any time through a public query to be carried out as per item C above, we inform that letters communicating changes in social denomination (or name) and country of constitution will no longer be issued, serving the result of the aforementioned query, for all legal purposes, as a suitable means to prove the status of the registration alteration request.

Sincerely,

FRANCISCO JOSÉ BASTOS SANTOS
Superintendent of Institutional Investor Relations