Circular Letter CVM/SSE 01/25: Adaptation of SGF and Fundos.Net Systems to Normative Annex VI of Resolution CVM No. 175

COMISSÃO DE VALORES MOBILIÁRIOS
Rua Sete de Setembro, 111/2-5º e 23-34º Andares, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brasil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2º, 3º e 4º Andares, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brasil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4º Andar, Brasília/DF – CEP: 70712-900 – Brasil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br Circular Letter No. 1/2025/CVM/SSE São Paulo, February 27, 2025. To Administrators and Managers of FIAGRO Subject: Adaptation of SGF and Fundos.Net Systems to Normative Annex VI to Resolution CVM No. 175 (“AN VI”). Dear Sir/Madam,

1. This Circular Letter aims to communicate to the market that, starting from 03/07/2025, the SGF (automatic fund registration system) and Fundos.Net systems will be prepared to receive registrations and current, periodic, and occasional information from Investment Funds of the Agricultural Production Chains (FIAGRO), in observance of the new rules and dynamics of the informational regime established by AN VI to RCVM 175, which was instituted by Resolution CVM No. 214 and will enter into force on 03/03/2025.

I - General Guidelines

2. Article 2 of AN VI to RCVM 175 provides that, if a class of FIAGRO shares has an investment policy that allows for the application of more than 50% of its net asset value in assets that are also the subject of investment by another category of fund, it must observe subsidiarily the rules applicable to the respective category, prevailing, in case of conflict, the rules set forth in Normative Annex VI.

3. Thus, the SGF and Fundos.Net systems will be adapted to receive FIAGRO information, observing that in the SGF System a new tab has been made available, in the “Register Fund” functionality, called “Normative Annexes”, where users must select, in order of priority, which other normative annexes’ rules must be observed by the fund in question, according to other Normative Annexes to Resolution CVM No. 175.

II - Periodic Reports

4. The following documents, prepared according to the form available in the aforementioned system and in accordance with Article 33 of AN VI to RCVM 175, must be sent via the Fundos.Net system:
   Monthly Report (Supplement O);
   Fund Basic Information Sheet (Supplement P); and Annual Report (Supplement Q).

5. In addition to the above documents, the following documents must also be sent via the Fundos.Net System, in an unstructured manner, at minimum:
   Statement of composition and diversification of the asset portfolio; Fund’s accounting statements and, if applicable, of its share classes, accompanied by the respective reports of independent auditors; Report of the shareholders’ representatives; Convening notice, administration or management proposal, and other documents related to shareholders’ meetings; Minutes of the shareholders’ meeting; and Summary of decisions taken at the shareholders’ meeting.

27/02/2025, 10:49 SEI/CVM - 2266784 - Circular Letter https://sei.cvm.gov.br/sei/controlador.php?acao=documento_imprimir_web&acao_origem=arvore_visualizar&id_documento=2398443&infra_siste… 1/2

III - Guidelines on the migration of existing FIAGROs to the new FIAGRO category in SGF and FNET

6. Regarding the SGF System, all existing funds, in the cases of FIAGRO-FII and FIAGRO-FIP, must, first, adapt to RCVM 175 within the system itself, respecting the deadline of 06/30/2025 provided for in Article 134 of Resolution CVM No. 175. Subsequently, they must execute the transformation procedure to the new FIAGRO category, also within the SGF, respecting the deadline of 09/30/2025 for adaptation to AN VI to RCVM 175.

7. Still regarding the SGF System, for existing FIAGRO-FIDC that must be adapted to RCVM 175, it is sufficient to execute the transformation to the new FIAGRO category, within the SGF itself, also respecting the deadline of 09/30/2025.

8. Regarding the Fundos.Net System, existing FIAGROs will continue to be treated as subdivisions of the FII and FIDC categories, that is, maintaining the current categorization, until the funds are migrated to the new FIAGRO category in the SGF System. With the transformation in the SGF completed, FIAGROs will begin to report, in the FNET system and in a new category, their periodic and occasional information provided for in AN VI to RCVM 175.

9. This SSE considers it relevant that all FIAGROs disclose in the FNET system, as the first occasional document of the new category, a communication to the market informing: (a) the date of transformation; (b) the previous name of the fund; and (c) to which category the FIAGRO belonged (FIDC, FIP, or FII). Furthermore, they must inform, in the same communication, the method of access to the occasional and periodic information disclosed before the transformation (link to FNET or CVMWeb).

10. Finally, this Superintendency requests that Administrators send, by email to the Securitization and Agriculture Management Department 3 (gsec-3@cvm.gov.br), the names, respective CNPJs, and transformation dates of existing FIAGROs prior to the effectiveness of AN VI to RCVM 175.

11. In case of doubts about the use of the SGF system, the CVM External Support should be contacted by email supoerteexterno@cvm.gov.br. In case of doubts about the use of the Fundos.Net system, the Superintendency of Support to Issuers of B3 should be contacted by phone (11) 2565-5063 or email emissores.fundos@b3.com.br.

Sincerely,
David Menegon
Securitization and Agriculture Management Manager - GSEC-3 Bruno de Freitas Gomes Superintendent of Securitization and Agriculture - SSE

Document electronically signed by Bruno de Freitas Gomes Condeixa Rodrigues, Superintendent, on 02/27/2025, at 10:39, based on Article 6 of Decree No. 8.539, of October 8, 2015.
Document electronically signed by David Menegon, Manager, on 02/27/2025, at 10:40, based on Article 6 of Decree No. 8.539, of October 8, 2015.
The authenticity of the document can be verified on the site https://sei.cvm.gov.br/conferir_autenticidade, by informing the verification code 2266784 and the CRC Code B64394F0.
This document's authenticity can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Código Verificador" 2266784 and the "Código CRC" B64394F0.
Reference: Process No. 19957.009383/2021-43 SEI Document No. 2266784 27/02/2025, 10:49 SEI/CVM - 2266784 - Circular Letter https://sei.cvm.gov.br/sei/controlador.php?acao=documento_imprimir_web&acao_origem=arvore_visualizar&id_documento=2398443&infra_siste… 2/2