CVM publishes guidance on CRI information in the FII quarterly report

The Brazilian Securities and Exchange Commission (“CVM”) published, on April 30, 2026, Circular Letter No. 2/2026/CVM/SSE (“Circular Letter”), through which it provides guidance to the managers of Real Estate Investment Funds (“FII”) regarding the proper completion of information relating to Real Estate Receivables Certificates (“CRI”) in the FII Quarterly Report, as provided in Supplement J to CVM Resolution No. 175, dated December 23, 2022 (“Quarterly Report”).

The guidance arises from inconsistencies identified by the CVM in the completion of the Quarterly Report fields relating to the CRI held by FII, which impair the proper identification of the assets by investors and by the regulator itself.

The main guidelines are summarized below.

1. Completion Guidelines

1.1.Category and Subcategory

The CRI must be reported exclusively under category 1.2 and subcategory 1.2.2 of the Quarterly Report.

1.2. 1.2. Issuance and Series Numbers

The “Issuance” and “Series” fields must be completed exclusively with numbers, and managers must use the number “1” in the case of single series.

1.3. 1.3. Securitization Company Taxpayer ID (CNPJ)

Managers must verify the correct completion of the CNPJ (Brazilian Taxpayer Identification Number) field of the securitization company that issued the CRI.

1.4. 1.4. IF Code for Financial Assets

Given the absence of a specific field for the IF code of financial assets, such information must be included in the “Company” field, as illustrated in the example below.

2. Completion Example

3. Review and Resubmission of Quarterly Reports

The CVM recommends that FII managers conduct an internal review regarding the need to resubmit the Quarterly Reports relating to the reporting periods of 12/2025 and 03/2026, in light of the guidelines set forth in the Circular Letter.

If any information is found to be missing or incorrect, particularly with respect to the IF code of the CRI, the respective Quarterly Report must be resubmitted to the CVM.

The Capital Markets team at SouzaOkawa Advogados remains available to assist in assessing the impacts of the Circular Letter and in reviewing the reporting procedures applicable to FII.