CVM Resolution No. 235 of November 21, 2025

CVM RESOLUTION NO. 235, OF NOVEMBER 21, 2025
Amends CVM Resolution No. 45, of August 31, 2021, and CVM Resolution No. 209, of August 26, 2024.

The SUBSTITUTE PRESIDENT OF THE SECURITIES COMMISSION – CVM makes public that the Collegiate Body, in a meeting held on November 5, 2025, based on the provisions of Article 8, item I, of Law No. 6,385, of December 7, 1976, APPROVED the following Resolution:

Art. 1. CVM Resolution No. 45, of August 31, 2021, published in the Official Gazette of the Union (“DOU”) on September 2, 2021, and rectified in the DOU on September 10, 2021, shall enter into force with the following wording:

“Art. 4. .............................................................
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§ 5. In the appeal referred to in § 4, the appellant must expressly demonstrate the lack of justification or the discrepancy with the prevailing position of the Collegiate Body, observing that, under penalty of the appeal not being considered:
I – mere dissatisfaction with the reasons presented by the superintendencies, by itself, does not constitute a lack of justification; and II – in case of an allegation of discrepancy, the appellant must indicate the process that reflects the prevailing position of the Collegiate Body on the matter, with the respective date of the decision. § 5-A. A request for reconsideration of the decision not to consider the appeal by the Collegiate Body is not admissible.
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SECURITIES COMMISSION OF BRAZIL www.cvm.gov.br CVM RESOLUTION NO. 235, OF NOVEMBER 21, 2025

by the CVM and the entity administering the organized market in which the intermediary is authorized to operate; j) grant clients financing and loans for operations in the securities market under conditions different from those provided for in the specific regulation on the intermediation of operations carried out with securities; k) allow the presence of clients, in any case, in the trading room environment; l) apply, in the constitution and operation of its portfolio, client resources; m) fail to disclose policies, rules, procedures and internal controls adopted, as well as their updates, on its website, and observing the provisions of the specific regulation on the activity of investment advisor; n) fail to appoint a responsible director in charge of investment advisors, as well as identify him and provide his contact data on a website, as established in a specific regulation; and o) fail to update, on its own page and on the page of the accrediting entity on the World Wide Web, the list of investment advisors hired by it, as established in a specific regulation;

XXIV – the investment advisor:
a) exercise, cumulatively, conflicting activities, such as portfolio management, consulting and analysis of securities; b) use materials that do not comply with the regulations governing the use of materials in the exercise of the investment advisor activity; c) in the case of affiliation with more than one intermediary, fail to observe the abstention from making references to the products, communication channels and other information of the intermediaries by whom he has been hired in a way that may cause doubts about which intermediary the information refers to; d) in the form of a legal entity, fail to inform the website on which the list of natural person investment advisors authorized to act as partners, employees or contractors can be consulted, as established in a specific regulation; and

SECURITIES COMMISSION OF BRAZIL www.cvm.gov.br CVM RESOLUTION NO. 235, OF NOVEMBER 21, 2025

e) in the form of a legal entity, fail to inform the appointment or replacement of the responsible director, as established in a specific regulation;

XXV – the custodian fails to:
a) disclose, on its website, the documents necessary to carry out the transfer of custody to another custodian, as established in a specific regulation; b) inform the client, of the non-conformity of the documentation delivered for the purpose of carrying out the transfer, as established in a specific regulation; and c) indicate:

1. statutory director responsible for compliance with regulations on the provision of securities custody services and inform his appointment or replacement, as established in a specific regulation; and
2. statutory director responsible for supervising the procedures and internal controls adopted in the provision of custody services and inform his appointment or replacement, as established in a specific regulation;

XXVI – the securities registrar fails to:
a) communicate to the CVM the signing and termination of a securities registration contract, as established in a specific regulation; b) disclose, on its website, the documents necessary to carry out transfers, registrations and endorsements in securities accounts in the central deposit, as established in a specific regulation; and c) indicate:

1. statutory director responsible for compliance with regulations on the provision of securities registration services and the issuance of securities certificates, as established in a specific regulation; and
2. statutory director responsible for supervising the procedures and internal controls adopted in the provision of securities registration services and the issuance of securities certificates, as established in a specific regulation; and

XXVII – participants in the securities market, subject to obligations as established in regulations governing the prevention of money laundering, terrorism financing and financing of the proliferation of weapons of mass destruction – AML/CFT within the securities market and, when applicable, the statutory director responsible for compliance with regulations established for AML/CFT fail to:
a) indicate a statutory director responsible for compliance with regulations established for AML/CFT, in particular, for the implementation and maintenance of the respective AML/CFT policy compatible with the nature, size, complexity, structure, risk profile and business model of the institution, in order to ensure the effective management of ML/CFT risks identified, as established in a specific regulation; b) elaborate the AML/CFT policy, as established in a specific regulation; and c) prepare a report on the internal risk assessment of ML/CFT, as established in a specific regulation.” (NR)

Art. 4th. The following are repealed:
I – art. 21, § 3rd, of CVM Resolution No. 45, of August 31, 2021; and II – art. 5th of CVM Resolution No. 209, of August 26, 2024.

Art. 5th. This Resolution enters into force on December 1, 2025, with the exception of art. 2nd, with regard to the inclusion of item IX in Group IV of Annex A of CVM Resolution No. 45, of August 31, 2021, which enters into force on January 2, 2026.

Sole Paragraph. This Resolution applies immediately to ongoing processes, safeguarding the validity of acts performed before its enforcement.

Signed electronically by
MARINA PALMA COPOLA DE CARVALHO
Acting President