Circular Letter No. 3/2026/CVM/SMI: Expansion of Admitted Markets for Foreign Intermediary Partnerships

BRAZILIAN SECURITIES AND EXCHANGE COMMISSION
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To institutions part of the securities distribution system and other market participants.
Subject: Expansion of the list of markets admitted in partnerships with foreign intermediaries Dear Sirs/Madams,

1. The Superintendence of Market and Intermediary Relations – SMI, in the exercise of its duties, deems it opportune to disclose, through this Circular Letter, that, pursuant to the Collegiate Decision of May 29, 2026, the exchanges New York Mercantile Exchange, Inc. (NYMEX), Commodity Exchange, Inc. (COMEX), Chicago Mercantile Exchange, Inc. (CME) and Board of Trade of the City of Chicago, Inc. (CBOT) were exceptionally recognized as markets where foreign intermediaries may operate who intend to offer their services in Brazil through the contracting of national intermediaries - a possibility provided for in CVM Guidance Opinion 33 - provided that the parameters defined in Memorandum No. 112/2020-CVM/SMI/GME and in the Collegiate Decision of 23/02/2021 are fully observed, due to the prior regulatory analysis carried out by the CVM in the context of authorizing their access screens.
2. Such approval was conditioned on the demonstration that the aforementioned entities continued to meet the requirements set forth in CVM Resolution 135, in a manner compatible with the analysis previously carried out by the CVM in the approval of the access screens. The corresponding documentation was subsequently received by the SMI and, after detailed analysis, considered sufficient to substantially demonstrate the current adherence of the NYMEX, COMEX, CME, and CBOT exchanges to the requirements set forth in article 167, items I, II, and III, and in the sole paragraph of article 167 of CVM Resolution No. 135/2022, in accordance with the Collegiate Decision of May 29, 2026.
3. It is emphasized that this decision, by itself, does not replace or alter the criteria defined in Memorandum No. 112/2020-CVM/SMI/GME and in the Collegiate Decision of 23/02/2021, and it is certain that the exceptional solution for the case was taken in strict terms, in order to avoid an expansive interpretation or its use as a basis for an implicit, abstract review of the criterion for the operation of a foreign intermediary in a recognized market approved by the Collegiate on 23/02/2021.
4. Furthermore, in order to ensure equal treatment between Brazilian and foreign institutions and to prevent operations through a foreign intermediary from resulting in more favorable regulatory treatment, national intermediaries must adopt adequate controls to prevent investors residing in Brazil from having access to products, services, or functionalities that, due to guidelines issued by the CVM or restrictions provided for in applicable legislation or regulation, (i) could not be offered by Brazilian institutions to these investors, (ii) or could only be offered upon observance of specific requirements, conditions, or restrictions.
5. This Circular Letter is for guidance purposes and does not replace compliance with applicable normative provisions, and must be interpreted in accordance with current CVM regulations and other relevant norms.
6. Due to the relevance of the topic, the SMI will monitor the evolution of the aforementioned models, submitting its evaluation to the internal instances of the CVM, to assess the need for issuing specific regulation on the matter.
   Sincerely,
   Document electronically signed by Egmon Henrique de Oliveira Costa, Superintendent, on 20/08/2026, at 15:25, based on article 6 of Decree No. 8,539, of October 8, 2015.
   This document's authenticity can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Código Verificador" 2802475 and the "Código CRC" 23F7173A.
   Reference: Process No. 19957.009664/2026-19 SEI Document No. 2802475 Circular Letter 4 (2802475) SEI 19957.009664/2026-19 / pg. 2