Brazil Securities Commission (CVM) has opened a public consultation on a draft rule that would make targeted but substantive amendments to Annex III of CVM Resolution 175, which sets the specific rules for real estate investment funds (Fundos de Investimento Imobiliário, FIIs). The package is intended to modernise the FII framework by aligning FII-specific requirements more closely with the general regime for other fund categories and by incorporating interpretations already consolidated in CVM Board and technical staff practice. Key proposals include allowing subordination between subclasses of units, adjusting rules on unit repurchases and public tender offers for the acquisition of units, and setting out how reimbursements should work for dissenting unitholders following meeting resolutions. The draft also seeks to strengthen unitholder representation and revise periodic reporting requirements, with the stated aim of improving governance, transparency and investor protection. The consultation is open for comments until 30 January 2026, following the instructions in Public Consultation Notice SDM 06/25.