# Turim 21 Investimentos Ltda

> Turim 21 Investimentos Ltda is an SEC-registered investment advisory firm in Rio de Janeiro, Rj, Brazil, registered since 2017, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated July 27, 2026.

- CRD: 286618
- Filed as: TURIM 21 INVESTIMENTOS LTDA
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Rio de Janeiro, Rj, Brazil
- Filing period: October 2026
- Form ADV filing dated: July 27, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/286618
- AdvisorCensus page: https://advisorcensus.com/firm/turim-21-investimentos-ltda-rio-de-janeiro-rj-286618

## Quick answers

**How is Turim 21 Investimentos Ltda compensated?**
On its Form ADV (Item 5.E, October 2026), Turim 21 Investimentos Ltda reports these compensation arrangements: a percentage of assets under its management; fixed fees (other than subscription fees); performance-based fees. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Turim 21 Investimentos Ltda located?**
Turim 21 Investimentos Ltda's principal office is in Rio de Janeiro, Rj, Brazil, according to its Form ADV.

**Is Turim 21 Investimentos Ltda registered with the SEC or a state?**
Turim 21 Investimentos Ltda is an SEC-registered investment advisory firm, registered since 2017. Status as filed: Approved. CRD 286618.

**How much does Turim 21 Investimentos Ltda manage?**
Turim 21 Investimentos Ltda reports $7,239,335,743 in regulatory assets under management in its Form ADV filing dated July 27, 2026 (100% discretionary).

**How have Turim 21 Investimentos Ltda's assets and staff changed since 2021?**
In the Form ADV data for Turim 21 Investimentos Ltda: Regulatory assets under management: $4,301,007,976 in the October 2021 data and $7,239,335,743 in the October 2026 data, up 68%. Total employees: 80 in October 2021 and 124 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Turim 21 Investimentos Ltda serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (445); pooled investment vehicles (other than investment companies and business development companies) (69); corporations or other businesses not listed above (17).

**Which custodians does Turim 21 Investimentos Ltda use?**
Turim 21 Investimentos Ltda's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Santander as a custodian holding 10% or more of its separately managed account assets.

**Does Turim 21 Investimentos Ltda report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/286618

**What changed in Turim 21 Investimentos Ltda's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 17 to 20. Regulatory assets under management went from $5,233,960,613 to $7,239,335,743 (+38%).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Fixed fees (other than subscription fees)
- Performance-based fees

### Custodians (Schedule D, Section 5.K(3))
- Santander

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $7,239,335,743
- Discretionary: $7,239,335,743
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | Fewer than 5 | $8,682,136 |
| High net worth individuals | 445 | $4,790,781,148 |
| Pooled investment vehicles (other than investment companies and business development companies) | 69 | $1,719,441,150 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | Fewer than 5 | $26,880,119 |
| Charitable organizations | 8 | $49,261,935 |
| Insurance companies | Fewer than 5 | $6,652,472 |
| Corporations or other businesses not listed above | 17 | $637,636,783 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients
- Selection of other advisers (including private fund managers)

### Firm details
- Registered since: 2017 (9 years)
- Employees: 124 total, 20 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- turimbr.com

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $4,301,007,976 | 80 | May 5, 2021 |
| October 2022 | $5,263,897,706 | 87 | March 29, 2022 |
| October 2023 | $5,060,540,809 | 100 | September 13, 2023 |
| October 2024 | $5,364,571,913 | 78 | July 25, 2024 |
| October 2025 | $5,233,960,613 | 96 | March 27, 2025 |
| October 2026 | $7,239,335,743 | 124 | July 27, 2026 |

Regulatory assets under management: $4,301,007,976 in the October 2021 data and $7,239,335,743 in the October 2026 data, up 68%.
Total employees: 80 in October 2021 and 124 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 17 to 20.
- Regulatory assets under management went from $5,233,960,613 to $7,239,335,743 (+38%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Turim 21 Investimentos Ltda (CRD 286618): Form ADV filing data as of October 2026.