XP Advisory US, Inc.

• A percentage of assets under your management
• Performance-based fees
• Other

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

Asset-based fee: 0.05% to 0.25% a year (a range, as the brochure states it)

Account minimum: $500,000

Minimum annual fee: $5,000

As stated in the firm's Form ADV Part 2A brochure dated April 20, 2026. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site

$792,319,508 as of October 2026, filing dated April 20, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Portfolio management for individuals and/or small businesses
• Portfolio management for pooled investment vehicles (other than investment companies)
• Selection of other advisers (including private fund managers)
• Other

Also doing business as

XP ADVISORY INTERNATIONAL, XP ASSET MANAGEMENT (USA)

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2019 (7 years)

Employees

Total: 34. Performing investment advisory functions: 27.

Wrap fee program participation

Yes.

Custodians (Schedule D, Section 5.K(3))

Pershing LLC

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.

Other offices (Schedule D, Section 1.F)

1 other office, as of the May 2026 filing

New York, NY

States registered or notice-filed

3 states or jurisdictions

FLNYWY

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

None Reports no disclosure items on Form ADV Item 11. View on IAPD.

Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $835,875,659 in the October 2021 data and $792,319,508 in the October 2026 data, down 5%.

Total employees: 26 in October 2021 and 34 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. May 2026
   • Added the business name XP Asset Management (USA).
   • Added the business name XP Advisory International.
2. April 2026
   • Employees performing advisory functions went from 26 to 27.
   • Regulatory assets under management went from $1,563,934,974 to $792,319,508 (-49%).
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.

Not reported.