Circular Letter CVM/SIN 03/23

SECURITY AND EXCHANGE COMMISSION OF BRAZIL
Sete de Setembro Street, 111/2-5th and 23-34th Floors – Center – Rio de Janeiro - RJ – ZIP Code: 20050-901 – Brazil Tel.: (21) 3554-8686 - www.cvm.gov.br Circular Letter No. 3/2023/CVM/SIN Rio de Janeiro, May 26, 2023

To the administrators and managers of investment funds regulated by CVM Instruction No. 555 Subject: Launch of the SIEM system

Dear Sirs,

1. This Circular Letter aims to announce the launch of the new "Electronic Notification System for Penalty Fines (SIEM)," which aims to improve the process of sending by the CVM and receiving, by fund administrators, of notices imposing penalty fines issued based on article 142 of CVM Instruction No. 555.

2. The new system aims to allow the notification of the imposition of these fines to be made available to the fund administrator immediately after its issuance by the CVM, and that it can be received and processed, within the institution, directly by a person previously indicated to the CVM and registered therein who is directly responsible for handling the fines (whether their payment or the filing of an appeal).

3. Furthermore, with the adoption of the new mechanism, greater security and transparency are also sought for this process, as each administering institution will have access to the history of receipt confirmations of each of the penalty fines sent to it and received by it.

4. Thus, to enable the registration of these people, we request that administering institutions of investment funds regulated by CVM Instruction No. 555 holding registration in the "fiduciary administrator" or "full administrator" category send, by 2/6/2023 and to the electronic address gain-cadastro@cvm.gov.br, a message with the title "Registration of responsible persons - SIEM," with the qualification (with full name, CPF, and email address) of the institution's employees who will access the system.

5. By its nature and scope, the system does not involve the registration of portfolio managers registered with the CVM only in the "manager" category.

6. We will only accept institutional email addresses, and we suggest the registration of at least 2 people per administering institution.

7. It is the responsibility of administering institutions to maintain adequate internal controls to ensure the permanent updating of the registration of persons responsible for accessing SIEM, promoting the appropriate updates whenever necessary.

8. Institutions that have already participated in the pilot project for the implementation of the system are exempt from registering new responsible persons, as they already have people registered with the CVM for this purpose.

SECURITY AND EXCHANGE COMMISSION OF BRAZIL
Sete de Setembro Street, 111/2-5th and 23-34th Floors – Center – Rio de Janeiro - RJ – ZIP Code: 20050-901 – Brazil Tel.: (21) 3554-8686 - www.cvm.gov.br

9. After access to SIEM is granted, whenever any new penalty fine is issued regarding the delay or non-compliance in the delivery of periodic documents provided for in CVM Instruction No. 555, the registered persons will receive automatic electronic notification in their respective registered emails to access the system and view and download the applied fine, in order to provide adequate handling (payment or appeal) to them.

10. Thus, it is advisable that the persons registered on behalf of the institution, in addition to being authorized to receive these notices on behalf of the institution they represent, be those who have the functional attribution of receiving these fines, in order to ensure the greatest possible agility, within the administrator, in this handling.

11. After reading the notification and notices imposing penalty fines, the system will record that the reading occurred and keep this information in a file for later consultation and reference, available to the system user at any time. This date, as usual, will be considered as the starting point for counting the appeal period against the imposition of the penalty fine provided for in article 11, § 12, of Law No. 6.385.

12. The aforementioned notification will contain a declaration, to which the notified party must adhere, that the institution, by receiving the notification, adheres to the provisions of article 3 of Decree No. 9,194/2017, with the system serving as the "electronic system" for the purposes provided for in said regulatory device.

13. We alert that the scope of the system is exclusively to provide a more transparent, agile, and secure mechanism for receiving penalty fines by administering institutions, so that no other operation associated with these fines (such as, for example, payment or filing of an appeal) should be carried out through this system. For cases of payment or filing of appeals against the applied fines, for example, and indeed, the same systems currently available and used by administering institutions remain applicable and applicable, as per the information presented in the fine imposition notice.

14. In case of doubts about the system's operation or the filing of appeals, this superintendence can be contacted via the electronic address sin@cvm.gov.br. For issues associated with technological difficulties, it is necessary to contact the CVM External Support, via the electronic address suporteexterno@cvm.gov.br. Finally, for clarifications regarding fine payments, the responsible area is the Collection Management, which can be consulted via the electronic address gearc@cvm.gov.br.

Sincerely,

Digitally signed by
DANIEL WALTER MAEDA BERNARDO
Superintendent of Institutional Investor Supervision