Joint Circular CVM/SIN/SSE 01/25

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 Joint Circular No. 1/2025/CVM/SIN/SSE Rio de Janeiro and São Paulo, December 01, 2025. To Administrators and Managers of Investment Funds Subject: Interpretation of provisions of the General Part and Normative Annexes I, II, III, IV and V of CVM Resolution No. 175. Dear Sirs,

1. This Joint Circular aims to disseminate additional interpretations by the Superintendency of Institutional Investor Supervision (“SIN”) and the Superintendency of Securitization and Agribusiness (“SSE”) regarding provisions of the general part of the Resolution, as well as provisions of Annexes I, II, III, IV and V.

2. On 07/11/2024, SIN published Joint Circular No. 3/2024/CVM/SIN recognizing as regular the maintenance of a global fee in the regulations and the disclosure of a fee summary separately as an alternative to the segregation of fees in the regulations. Furthermore, the circular provides that market participants must fully adopt the guidelines to be disseminated by ANBIMA regarding Fee Information Transparency.

3. Joint Circular No. 6/2024/CVM/SIN of 10/15/2024 brings additional clarifications on the subject, detailing in item 8 the expectation of replacing the summary made available by the manager with a platform to be made available according to premises established between the regulator and the self-regulatory organization, where full transparency of fees will be given to investors, including information about the commercial agreement in which the distributor is involved.

4. On 11/22/2024, SSE, through Circular No. 20/2024/CVM/SSE, clarifies to ANBIMA that the guidelines contained in SIN Circular No. 3/2024 can be applied to FIDCs, FIIs, and FIAGROs.

5. Based on the premise in item 2, SIN and SSE recognize the ANBIMA Tool (Fee Transparency Platform) as a centralized and adequate instrument to be adopted in place of disclosure on each manager's website. Its adoption will contribute to greater clarity in the disclosure of remuneration information for investment funds.

6. In this context, it is understood that all previous references to the “Fee Summary” must be reinterpreted as corresponding to the new ANBIMA Platform, which now becomes the means for compliance with the transparency guideline. The replacement of the summary by the platform consolidates the understanding that structured disclosure through the tool meets regulatory requirements and supervisory expectations of these Superintendencies.

7. It is therefore clarified that, from the adoption of the ANBIMA Platform, the following obligations are waived: (i) making the Fee Summary available on the manager's own channels and (ii) updating and sending via the Fundos.Net system for FIIs, FIDCs, and FIAGROs.

8. Additionally, administrators of FIIs, FIDCs, and FIAGROs must give wide publicity, by sending a communication to the market via the Fundos.Net system, about the disclosure that will now be carried out on the ANBIMA Platform and informing the access link for investors.

9. From the adoption of the ANBIMA Platform as the official means of disclosure, it becomes imperative that remuneration information be fully opened through the aforementioned tool, with due reference to the platform in the regulations and disclosure materials of the funds. This direction ensures compliance with the new transparency standard established, in addition to promoting standardization and accessibility of information to investors and other market agents.

10. Participants must fully observe the guidelines established by ANBIMA, both with regard to the migration between the summary and the Platform and to the rules applicable to its use.

11. Finally, the ANBIMA Platform became operational on 11/03/2025 and, therefore, these Superintendencies consider it adequate that, by 03/31/2026, the adaptation of previously constituted fund classes occurs.

Sincerely,

Marco Antonio Velloso de Sousa
Superintendent of Institutional Investor Supervision - SIN Bruno de Freitas Gomes Superintendent of Securitization and Agribusiness - SSE

Joint Circular 1 (2517795) SEI 19957.016087/2025-22 / pg. 1

Document electronically signed by Bruno de Freitas Gomes Condeixa Rodrigues, Superintendent, on 11/26/2025, at 17:39, with basis in art. 6 of Decree No. 8.539, of October 8, 2015.
Document electronically signed by Marco Antonio Velloso de Sousa, Superintendent, on 11/26/2025, at 17:45, with basis in art.
6 of Decree No. 8.539, of October 8, 2015.
The authenticity of the document can be checked on the site https://sei.cvm.gov.br/conferir_autenticidade, informing the verification code 2517795 and the CRC code 533D5DD6.
This document's authenticity can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Verification Code" 2517795 and the "CRC Code" 533D5DD6.
Reference: Process No. 19957.016087/2025-22 SEI Document No. 2517795 Joint Circular 1 (2517795) SEI 19957.016087/2025-22 / pg. 3