Circular Letter CVM/SSE 03/25: Adaptation of FIAGRO to Normative Annex VI of CVM Resolution 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. 3/2025/CVM/SSE São Paulo, on the date of electronic signature. To Administrators and Managers of FIAGRO. Subject: Adaptation of FIAGRO to Normative Annex VI of CVM Resolution 175. Dear Sir/Madam,

1. This Circular Letter aims to disclose this Superintendence of Securitization and Agribusiness - SSE's understanding regarding the application of the provisions of art. 2 of Normative Annex VI of CVM Resolution 175.

I) General Guidelines

2. Art. 2 of Normative Annex VI of CVM Resolution 175 determines the subsidiary application of other normative annexes when the investment policy of FIAGRO allows for the application of more than 50% of its net assets in assets eligible for other fund categories.

3. Thus, it is understood that the provisions of the other annexes to be applied are those referring to the governance of invested assets for the execution of the investment policy, which includes, among others, the duties and responsibilities of service providers related to the execution of the policy and issues involving the administration and management of invested assets, provided there is no conflict with the provisions of Normative Annex VI.

4. In this context, the SSE considers that the disclosure of the specific informational regime of each Normative Annex, as well as the minimum portfolio classification requirements, are not covered, given that Normative Annex VI provides a complete and appropriate regime for FIAGRO, regardless of portfolio concentration. Furthermore, this technical area considers that the quota holder assembly rules provided in the other annexes are also not applicable, as there are specific provisions in Normative Annex VI on the subject.

5. Specifically for FIAGROs that may also adopt Normative Annex II, this SSE emphasizes the obligation for the administrator to send information to the Central Bank of Brazil's SCR System, as regulated by art. 31, items II and III, of the Annex. Thus, FIAGROs with an investment policy that allows for the application of more than 50% of net assets in credit rights must send information to the Central Bank of Brazil, in the same manner as FIDCs and within the same deadlines.

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II) Investment in Receivables Certificates

6. Based on CVM Resolution 39, FIAGROs that invest in securities or capital market assets of securitization, notably Agricultural or Real Estate Receivables Certificates ("CRA" or "CRI"), were authorized to operate in the Real Estate Investment Fund - FII category, thus applying the provisions of Normative Annex III of CVM Resolution 175.

7. Given this scenario, this technical area understands that FIAGROs with a policy allowing investment of more than 50% in securitization assets, such as CRA and CRI, may continue to use Normative Annex III, in addition to Normative Annex VI. Thus, the use of Normative Annex II, for these cases, is optional.

8. This understanding arises from the fact that Normative Annex III adequately addresses the governance required of the administrator and manager to carry out investments in securitization assets.

9. These assets, in general, are regulated by CVM Resolution 60 and Law 14.430, and thus have distinct characteristics from a traditional credit right, considering the operation of securitization companies and fiduciary agents as service providers who have fiduciary duties towards investors. Thus, this extra layer of governance justifies the non-application of the requirements of Normative Annex II, or even of Normative Annex VI itself, regarding specific credit right requirements.

10. This understanding may be applied in case of eventual concentration of the FIAGRO's investment policy in Agricultural or Real Estate Credit Letters ("LCA" or "LCI"), which are also assets permitted for FIAGRO-FIIs governed by CVM Resolution 39.

11. Finally, in case of doubts, this Superintendence can be consulted via the emails gsec-1@cvm.gov.br and sse@cvm.gov.br.

Sincerely,
Cynthia Barião da Fonseca Braga
Securitization and Agribusiness Manager - GSEC-1 Bruno de Freitas Gomes Superintendent of Securitization and Agribusiness - SSE

Document electronically signed by Cynthia Bariao da Fonseca Braga, Manager, on 12/06/2025, at 14:36, based on art. 6 of Decree 8.539, of October 8, 2015.
Document electronically signed by Bruno de Freitas Gomes Condeixa Rodrigues, Superintendent, on 12/06/2025, at 14:39, based on art. 6 of Decree 8.539, of October 8, 2015.

12/06/2025, 14:39 SEI/CVM - 2307328 - Circular Letter https://sei.cvm.gov.br/sei/controlador.php?acao=documento_imprimir_web&acao_origem=arvore_visualizar&id_documento=2440914&infra_siste… 2/3

The authenticity of the document can be verified on the site https://sei.cvm.gov.br/conferir_autenticidade, informing the verification code 2307328 and the CRC Code F86FB380.
This document's authenticity can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Verification Code" 2307328 and the "CRC Code" F86FB380.
Reference: Process No. 19957.009383/2021-43 SEI Document No. 2307328

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