Circular Letter CVM/SIN/SRE No. 02/2016

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. 02/2016/CVM/SIN/SRE Rio de Janeiro, June 13, 2016

To
Directors responsible for investment fund management institutions

Subject: Clarifications on provisions of CVM Instructions No. 476/09 and 555/14

Dear Sirs/Madams,

1. Article 20 of CVM Instruction No. 555/14 states that “the distribution of closed-end fund shares depends on prior registration with the CVM, except for cases of exemption expressly provided for in regulations.” Article 22 of the same regulation provides that “the registration for the distribution of closed-end fund shares intended exclusively for qualified investors is automatically granted upon submission” of documents and information through the CVMWeb system.

2. Thus, the administrator of an investment fund regulated by CVM Instruction No. 555/14 must inform all its public offers for the distribution of shares through the CVMWeb System, noting that the information regarding the initial distribution is a requirement for the fund's registration status with this Commission to change to “in normal operation.”

3. Furthermore, CVM Instruction No. 476/09 allows, in its Article 1, §1, IV, that the public distribution of closed-end investment fund shares be carried out with restricted efforts.

4. In this context, if the public distribution of closed-end investment fund shares is carried out with restricted efforts, in accordance with CVM Instruction No. 476/09, we advise that the information provided by investment fund administrators, in compliance with the provisions of CVM Instruction No. 555/14 through the CVMWeb system, does not exempt the lead intermediary institution of the offer from providing the information set forth in Articles 7-A and 8 of CVM Instruction No. 476/2009, in the form of its Annexes 7-A and 8, through the system for receiving information on distributions with restricted efforts, available on the CVM portal (as described in Circular Letter No. 02/2015/CVM/SRE, of 12/16/2015). Thus, the information must be forwarded through both systems.

Sincerely,

Signed original by
DOV RAWET
Superintendent of Securities Registration

Signed original by
DANIEL WALTER MAEDA BERNARDO
Superintendent of Institutional Investor Relations