Circular Letter CVM/SSE 09/25

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 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – ZIP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – ZIP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br Circular Letter No. 9/2025/CVM/SSE São Paulo, on the date of electronic signature. To Administrators of Credit Rights Investment Funds (“FIDC”) Subject: Improvements to the current version of the FIDC Monthly Report available in the Fundos.Net system.

Dear Sir/Madam,

1. This Circular Letter aims to communicate that, starting from 01/02/2026, a new version of the FIDC Monthly Report (version 6.6) will be available in the Fundos.Net System, with the following improvements:

Table X: possibility of including a sub-class without a subordination structure;
Table X: unique identifier for each sub-class;
Tables I and VIII (fields “a.11” and “b.11”): invalid CPF or CNPJ or those with repeated digits will not be accepted.

Table X: possibility of including a sub-class without a subordination structure

2. Art. 5, § 5, of the General Part of CVM Resolution No. 175, combined with the provisions of Art. 3 of Normative Annex II to said Resolution, allows for the creation of FIDCs that contain sub-classes without a subordination or seniority structure among them.

3. In this sense, a new version of the FIDC Monthly Report will be made available for reports with a reference date of December 2025, which will contain, in item “1) Number of Unitholders”, the question “Does the class have a subordination structure?”, such that the completion of all of Table X will depend on the existence or not of a subordination structure. It is emphasized that the information regarding the presence of a subordination structure must reflect the situation of the FIDC on the reference date of the Monthly Report.

4. The class of shares that has only one sub-class on the reference date of the report must be considered “without a subordination structure”, since it is not possible to have subordination without the existence of, at least, one senior sub-class and one subordinate sub-class. For example, the non-existence of a subordination structure must be declared in the case of a fund that has only one sub-class on the report's reference date, even if there is a provision that this sub-class will become subordinate to a new senior sub-class in the future. The future realization will entail the alteration of the situation to be declared in the report.

5. The reverse occurs when a fund with subordinate and senior sub-classes becomes constituted of a single sub-class after, for example, the total amortization or redemption of the other sub-classes, and in this case, in the reference month, the FIDC must report that it does not have a subordination structure.

6. Thus, the monthly report of the same class may not have a subordination structure in a certain month and, from the following month, with the creation of another sub-class, may have a subordination structure.

7. When the answer indicates that there is no subordination structure, Fundos.NET will allow only the inclusion of numbered sub-classes. The data of sub-classes and series of the other items in Table X must be filled in under the same system as item 1, in order to maintain consistency.

Table X: unique identifier for each sub-class

8. Starting from the monthly report referring to the reference date of December 2025, the administrator must inform the unique identifier of each sub-class, generated upon its registration with the CVM and containing 15 alphanumeric characters, in order to enable the correspondence between sub-classes listed in reports with different reference dates.

Tables I and VIII (fields “a.11” and “b.11”): invalid CPF or CNPJ or those with repeated digits will not be accepted

9. Starting from the monthly report referring to December 2025, the Fundos.Net system will begin to validate CPF or CNPJ, rejecting, for example, filling errors with invalid numbers or with repeated digits (e.g., 00000000000 or 99999999999999) in the items related to assignors and debtors (fields “a.11” and “b.11” of Table I and Table VIII).

10. In the case of assignment of precatórios, for example, the data of the debtor must be filled in with the name and CNPJ of the corresponding federation entity.

11. It is emphasized that it is the responsibility of the administrator to disclose the monthly reports with correct and complete information, regardless of the checks and consistencies performed by Fundos.Net, being subject to the applicable sanctions in cases of non-observance of the applicable rules.

12. In case of doubts about the content of this Circular Letter, this SSE can be contacted by email sse@cvm.gov.br. Doubts about the use of the Fundos.Net system should be directed to the Superintendency of Support to Issuers of B3, by phone (11) 2565-5064 or email emissores.fundos@b3.com.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 12/12/2025, at 15:26, based on Art. 6 of Decree No. 8.539, of October 8, 2015.
Document electronically signed by Bruno de Freitas Gomes Condeixa Rodrigues, Superintendent, on 12/12/2025, at 15:33, based on Art. 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 2518075 and the CRC code 586D792F.
This document's authenticity can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Verification Code" 2518075 and the "CRC Code" 586D792F.
Reference: Process No. 19957.009383/2021-43 SEI Document No. 2518075 15/12/2025, 10:05 SEI/CVM - 2518075 - Circular Letter https://sei.cvm.gov.br/sei/controlador.php?acao=procedimento_trabalhar&acao_origem=procedimento_controlar&acao_retorno=procedimento_co… 2/2