Circular Letter No. 1/2025/CVM/SMI

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL
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Circular Letter No. 1/2025/CVM/SMI
Rio de Janeiro, August 26, 2025.

To the Directors of Intermediaries responsible for compliance with CVM Resolution 178 and to the Directors responsible for Investment Advisor Companies

Subject: Compliance with the Continuing Education Program (PEC) by investment advisors.

Gentlemen Directors,

1. The purpose of this Circular Letter is to remind you that in 2026 the first cycle of the Continuing Education Program will conclude, which means that some investment advisors may lose their accreditation if certain requirements related to their technical updating are not met.

2. Pursuant to item II of article 39 of CVM Resolution No. 178/2023 and previous norms, the entities accrediting investment advisors must establish a continuing education program, with the objective that the investment advisors accredited by them periodically update and improve their technical capacity. In compliance with the norm's requirements, the National Association of Brokers and Distributors of Securities, Currency and Commodities (Ancord), an entity accredited by the CVM, established the Continuing Education Program (PEC) in 2021.

3. According to the program's regulations, approved by the CVM, investment advisors must comply with the PEC, either:
   (i) by obtaining points annually, over a five-year period, by participating in courses, lectures, seminars or other educational activities;

Circular Letter 1 (2417826) SEI 19957.010334/2025-87 / pg. 1

or

(ii) by passing the Accreditation Renewal Exam, available from 90 days before the end of the five-year cycle.

4. Non-compliance with the provisions of the PEC, as well as the deadlines defined therein, will result in the loss of accreditation, preventing the investment advisor from exercising their activity. Furthermore, investment advisors who lose their accreditation must take the Certification Exam for new accreditation, and cannot practice until they pass the exam.

5. Since the PEC began in 2021 and provides for a five-year cycle, 2026 will be the first year in which an investment advisor may lose their accreditation for non-observance of the PEC.

6. In this context, the SMI advises intermediaries to closely monitor the status of the advisors they have hired, adopting effective mechanisms to ensure that they comply, in a timely manner, with all PEC requirements or that they are properly prepared to take the accreditation renewal exam. The same recommendation applies to the directors responsible for investment advisory companies.

7. Therefore, the SMI recommends that intermediaries widely disseminate to investment advisors the need for strict observance of the PEC rules, alerting them to the risks arising from non-compliance and guiding them to seek, in a timely manner, compliance with the prescribed requirements.

8. Additionally, the SMI emphasizes the importance of intermediaries adopting internal monitoring and control measures regarding the compliance of their investment advisors with the PEC, in order to mitigate potential risks of service discontinuity and harm to investors. The SMI will monitor the effectiveness of these measures and expects intermediaries to act with the necessary diligence to ensure full compliance with the PEC by all advisors under their responsibility or the prompt removal of professionals who may lose their accreditation due to failure to comply with the program.

Sincerely,

Document electronically signed by Andre Francisco Luiz de Alencar Passaro, Superintendent, on 08/27/2025, at 16:12, based on art. 6 of Decree No. 8.539, of October 8, 2015.

Circular Letter 1 (2417826) SEI 19957.010334/2025-87 / pg. 2

The authenticity of the document can be verified on the site https://sei.cvm.gov.br/conferir_autenticidade, by informing the verification code 2417826 and the CRC code 8FB3C3DE.

This document's authenticity can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Verification Code" 2417826 and the "CRC Code" 8FB3C3DE.

Reference: Process No. 19957.010334/2025-87 SEI Document No. 2417826 Circular Letter 1 (2417826) SEI 19957.010334/2025-87 / pg. 3