The Brazil Securities Commission (CVM) rejected a proposed settlement (Termo de Compromisso) submitted by Thaís Nogueira Alonso, in her capacity as investor relations director of Mitre Realty Empreendimentos e Participações S.A., in an administrative sanctions proceeding concerning alleged issuer disclosure failures. The decision means the matter will proceed to a merits decision by the CVM Board. The Federal Attorney’s Office at the CVM (PFE-CVM) found no legal impediment to an agreement, but the Settlement Committee (CTC) concluded acceptance was not convenient or appropriate given the alleged seriousness of the case and points raised by the technical area. The case concerns alleged (i) failure to disclose a material fact regarding the acquisition of land from the company’s chief executive officer and controlling shareholder (identified as F.M.) approved by the board on 27 September 2023, (ii) publication for two days (5 and 6 October 2023) of incomplete minutes from that board meeting without directors’ statements, and (iii) omissions in the 2023 Reference Form regarding the potential risk of a change in control linked to pledging controlling shareholders’ shares as collateral for a loan, as reported in the media on 30 January 2024. The administrative sanctions proceeding (PAS 19957.017629/2024-01) will now move forward for judgment by the CVM Board.