Legal

Regulatory Notices

Last updated October 2026

The Brazil Affordable Housing Platform is sponsored and managed by Strlex Capital Group Inc. (“Strlex”). The notices below summarize Strlex's regulatory status and compliance policies.

Regulatory status

Strlex Capital Group Inc. is an exempt reporting adviser with the U.S. Securities and Exchange Commission (SEC File No. 802-134790; CRD No. 339210). As an exempt reporting adviser, Strlex files portions of Form ADV with the SEC and is subject to applicable SEC rules, but is not registered as an investment adviser. Its Form ADV is publicly available at adviserinfo.sec.gov. Legal Entity Identifier (LEI): 9845005B81BCD1R1F202.

Anti-money laundering and KYC

Strlex maintains anti-money laundering and know-your-customer procedures for investors in the funds it manages, in line with the U.S. Bank Secrecy Act, the USA PATRIOT Act, OFAC sanctions regulations and FATF standards. These include verification of investor identity and beneficial ownership, review of source of funds and wealth, screening against sanctions lists and politically exposed persons, and ongoing monitoring of unusual activity.

Conflicts of interest

Strlex identifies, discloses and manages conflicts of interest in the best interest of its funds and their investors. Conflicts may arise from the allocation of opportunities among funds, co-investments by Strlex or its personnel, and relationships with affiliated service providers, including fund administration by an affiliated firm. Material conflicts are disclosed in each fund's offering documents.

Code of ethics

Strlex personnel are expected to act with integrity and fair dealing, comply with applicable law, protect confidential information, and never misuse material non-public information. Violations may result in disciplinary action.

Cybersecurity

Strlex protects investor and firm information through access controls, multi-factor authentication, encryption and secure cloud storage, and responds promptly to incidents, notifying affected parties where legally required.

Business continuity

Strlex maintains business continuity arrangements, including cloud-based data redundancy and remote operating capability, so that it can continue to serve its funds and investors during a significant disruption.

Questions

Write to info@strlex.capital.