Joint Circular No. 1/2025/CVM/SIN/SMI/SSE: Minimum Investor Registration Content for Organized Market Administrators and Financial Market System Operators

SECURITIES COMMISSION OF BRAZIL
Rua Sete de Setembro, 111/2-5º e 23-34º Andares, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brasil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2º, 3º e 4º Andares, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brasil - Tel.: (11) 2146- 2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4º Andar, Brasília/DF – CEP: 70712-900 – Brasil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br Joint Circular No. 1/2025/CVM/SIN/SMI/SSE Rio de Janeiro, March 10, 2025. To organized market administrator entities and financial market system operating institutions that deal with securities. Subject: Minimum registration content of investors to be maintained by organized market administrator entities (EAMOs) and financial market system operating institutions (IOSMFs).

Dear Sir/Madam,

1. This Joint Circular aims to disseminate the interpretation of the Superintendency of Institutional Investor Supervision (“SIN”), the Superintendency of Market and Intermediary Relations (“SMI”), and the Superintendency of Securitization and Agriculture (“SSE”), in articulation with the Core Team for the Prevention of Money Laundering, Terrorism Financing, and Financing of the Proliferation of Weapons of Mass Destruction of the General Superintendency (SGE), regarding the minimum registration information of investors to be maintained by organized market administrator entities (EAMOs) and financial market system operating institutions (IOSMFs) that deal with securities.

2. The plurality of EAMOs and IOSMFs authorized to operate in the securities market requires the CVM to act in a manner that (i) promotes a fair competitive environment, without practices that represent barriers to the entry of new participants or discrimination in access to services; (ii) guarantees fair and transparent access to the trading, registration, clearing, settlement, and deposit systems of EAMOs and IOSMFs; (iii) enables the implementation of interoperability rules, where applicable; (iv) provides efficient supervision and inspection; and (v) facilitates innovation and greater efficiency in the securities market, preserving the different business models implemented by EAMOs and IOSMFs.

Joint Circular 3 Joint Circular No. 1/2025/CVM/SIN/SMI/SS (2277931) SEI 19957.002373/2025-19 / pg. 1

3. Considering these objectives, it is necessary to observe that:
   a) Article 86 of CVM Resolution No. 135, of June 10, 2022, establishes that EAMOs must maintain an updated registry of investors, based on information provided by their participants (defined in Article 2, item IX of the same regulation), and that this registration information must be transmitted to the IOSMFs that provide them with services, to maintain a single and updated registry; b) Article 16 of CVM Resolution No. 31, of May 19, 2021, requires that central depositories be capable of identifying investors and keeping their registration data updated, based on information provided by their custodians; c) Article 11, main text and §2, of CVM Resolution No. 50, of August 31, 2021, specifies that EAMOs and IOSMFs that maintain a direct relationship with the investor must comply with the registration content related to Annexes B and C of the regulation, in its entirety; in this sense, other EAMOs and IOSMFs (i.e., those that do not maintain a direct relationship with the investor) must obtain from their participants the registration information of investors, necessary for the exercise of their activities and limited to the detail established in their regulations (e.g., Article 15 of CVM Resolution No. 135/2022 and Article 45 of CVM Resolution No. 31/2021), without this necessarily including the totality of the data contained in the aforementioned Annexes of CVM Resolution No. 50/2021; d) CVM Resolution No. 225, of December 27, 2024, opened the possibility of using the Access Registry, as an alternative to the registry of natural person investors, provided for in item I of Article 1 of Annex B of CVM Resolution No. 50/2021, according to the rules and procedures defined by EAMOs in their regulations.

4. Thus, the agency clarifies that the minimum registration content regarding the identification of investors in the systems of EAMOs and IOSMFs must include the following fields:
   a) If a natural person: full name; date of birth; registration number in the Individual Taxpayer Registry – CPF; place of residence (street, complement, neighborhood, city, state, and ZIP code) and telephone number; electronic address for correspondence; professional occupation; financial capacity, including income; and whether the client is considered a politically exposed person (PEP); b) If a legal entity: corporate name or business name; registration number in the National Registry of Legal Entities – CNPJ; complete address (street, complement, neighborhood, city, state, and ZIP code); telephone number; electronic address for correspondence; identification of the main economic activity; indicator of the status of being a non-profit organization; c) If an investment fund registered with the CVM: name; registration number in the National Registry of Legal Entities – CNPJ; indicator that it is an exclusive fund; d) If a non-resident investor (natural person): indicator that it is a non-resident investor; full name; registration number in the Individual Taxpayer Registry – CPF; e) If a non-resident investor (in other cases): indicator that it is a non-resident investor; name; registration number in the National Registry of Legal Entities – CNPJ; name of the representative; registration number of the representative in the National Registry of Legal Entities – CNPJ; indicator that it is (i) a non-profit organization or (ii) a trust or similar vehicle.

Joint Circular 3 Joint Circular No. 1/2025/CVM/SIN/SMI/SS (2277931) SEI 19957.002373/2025-19 / pg. 2

5. The obligation of minimum registration content (referred to in point 4 above) applies both to securities subject to central deposit and to the registration of previously executed operations and to the registration of securities, in accordance with Article 143 of CVM Resolution No. 135/2022, including in cases where they are distributed in the account and order modality.

6. Although they do not integrate the set of minimum information referred to above, whenever necessary and in order to fully comply with the obligations contained in the applicable regulation, EAMOs and IOSMFs must obtain complementary registration data from their participants, for the purpose of complying with their AML/CFT policies (Article 11, §2 of CVM Resolution No. 50/2021).

Sincerely,
Digitally signed by
Marco Antonio Velloso de Sousa
Superintendent of Institutional Investor Supervision Digitally signed by André Francisco Luiz de Alencar Passaro Superintendent of Market and Intermediary Relations Digitally signed by Bruno de Freitas Gomes Superintendent of Securitization and Agriculture

Joint Circular 3 Joint Circular No. 1/2025/CVM/SIN/SMI/SS (2277931) SEI 19957.002373/2025-19 / pg. 3