Joint Circular No. 4/2023/CVM/SIN/SSE

SECURITIES COMMISSION BOARD
Rua Sete de Setembro, 111/2-5th and 23-34th Floors – Center – Rio de Janeiro - RJ – CEP: 20050-901 – Brazil Tel.: (21) 3554-8686 - www.cvm.gov.br Joint Circular No. 4/2023/CVM/SIN/SSE Rio de Janeiro, November 22, 2023

To administrators of investment funds
Subject: BCB Resolution No. 38, of November 11, 2020

Dear Sirs,

This Circular aims to clarify the correct completion of investor information that administrators are obligated to send to the Central Bank of Brazil (“BACEN”) in accordance with BCB Resolution No. 38, as regulated by BCB Normative Instruction No. 94, of April 8, 2021.

In this regard, we have identified that positions held by various investors in funds with shares admitted to trading on the secondary market or subject to deposit are sometimes reported as being owned by the custodian itself or by the regulated market where such shares are admitted to trading.

We reiterate that this information is incorrect and must be corrected by the administrators of funds sending this information to the BACEN, so that the database reflects the identification of the actual holders of these shares. Specifically, the investors who, at the end of each reference month, hold such shares under their title and custody.

In this sense, we remind you that, in accordance with Article 15, § 2 of CVM Resolution No. 33, it is the duty of securities registrars (a category that includes general fund share registrars) “to maintain controls to identify the respective investors based on information provided by central custodians”, whenever such securities are deposited.

Sincerely,

Digitally signed by
DANIEL WALTER MAEDA BERNARDO
Superintendent of Institutional Investor Supervision

Digitally signed by
BRUNO DE FREITAS GOMES
Superintendent of Securitization and Agribusiness