Circular Letter CVM/SIN 04/26: Inapplicability of CVM Registration Requirement for Non-Resident Investors Operating in Agricultural Derivatives

SECURITY 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. 4/2026/CVM/SIN
Rio de Janeiro, February 11, 2026.

To
Representatives of non-resident investors and Administrators of Organized Markets.

Subject: Inapplicability of the CVM registration requirement for non-resident investors operating in agricultural derivatives

Dear Sir/Madam,

1. This Circular Letter aims to disclose this technical area's interpretation regarding the application of Article 6 of Joint Resolution BCB-CVM No. 13, of December 3, 2024 (“Joint Res. 13”).

2. The market has raised questions regarding the establishment of a representative in the Country and the obtaining of registration with this Securities and Exchange Commission (“CVM”) by the non-resident investor who carries out, exclusively, operations related to forward, futures, and options contracts for agricultural and livestock products and performs receipts, payments, and other financial movements in an account maintained abroad (“INR Agro”).

3. Initially, we emphasize that the obligation contained in Article 6 of Joint Res. 13 is limited to non-resident investors who invest in other products of the financial and securities markets (non-resident investment in portfolio), not covering INR Agro.

4. In conclusion, we clarify that, in the view of this technical area, the systematic and historical reading of Joint Res. 13 allows inferring that the general requirement for registration and establishment of a representative provided therein does not apply to non-resident corporate investors who enter the country with the specific purpose of operating in the segments previously regulated by CMN Resolution No. 2,687.

5. As a basis, since it was not the objective of this CVM to impose additional requirements related to the entry, into the Country, of non-resident investors, for purposes of interpretation and application of the rule, therefore, registration must be considered as an obligation of the non-resident investor who invests in other products of the financial and capital markets, without reaching the INR Agro, which is dispensed from the establishment of a representative in the Country and the obtaining of registration with this CVM.

Sincerely,

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