Turim 21 Investimentos Ltda provides portfolio management for individuals and small businesses, portfolio management for pooled vehicles, portfolio management for institutions, and selecting other managers. The firm advises 5 private funds.
Turim 21 Investimentos Ltda reports 539 clients. They include 445 high-net-worth individuals, 69 pooled investment vehicles, and 17 corporations and other businesses. Of its assets, 100.0% ($7.24B across 544 accounts) are managed with discretion. Of its clients, 99% are outside the U.S.
| Client type | Clients | Assets |
|---|---|---|
| Individuals (other than HNW) | Fewer than 5 | <1% |
| High-net-worth individuals | 83% | 66% |
| Pooled investment vehicles | 13% | 24% |
| Pension and profit-sharing plans | Fewer than 5 | <1% |
| Charitable organizations | 1% | <1% |
| Other client typesInsurance companies; Corporations and other businesses | 3% | 9% |
Client shares use reported counts. Client types without a reported count are excluded from that total.
Client breakdown and activity details
| Client type | Clients | Regulatory AUM | AUM share | Avg. per client |
|---|---|---|---|---|
| Individuals (other than HNW) | Fewer than 5 | $8.68M | 0.1% | — |
| High-net-worth individuals | 445 | $4.79B | 66.2% | $10.8M |
| Pooled investment vehicles | 69 | $1.72B | 23.8% | $24.9M |
| Pension and profit-sharing plans | Fewer than 5 | $26.9M | 0.4% | — |
| Charitable organizations | 8 | $49.3M | 0.7% | $6.16M |
| Insurance companies | Fewer than 5 | $6.65M | 0.1% | — |
| Corporations and other businesses | 17 | $638M | 8.8% | $37.5M |
| Total | 539 | $7.24B | 100% | — |
- Clients
- Fewer than 5
- Regulatory AUM
- $8.68M
- AUM share
- 0.1%
- Avg. per client
- —
- Clients
- 445
- Regulatory AUM
- $4.79B
- AUM share
- 66.2%
- Avg. per client
- $10.8M
- Clients
- 69
- Regulatory AUM
- $1.72B
- AUM share
- 23.8%
- Avg. per client
- $24.9M
- Clients
- Fewer than 5
- Regulatory AUM
- $26.9M
- AUM share
- 0.4%
- Avg. per client
- —
- Clients
- 8
- Regulatory AUM
- $49.3M
- AUM share
- 0.7%
- Avg. per client
- $6.16M
- Clients
- Fewer than 5
- Regulatory AUM
- $6.65M
- AUM share
- 0.1%
- Avg. per client
- —
- Clients
- 17
- Regulatory AUM
- $638M
- AUM share
- 8.8%
- Avg. per client
- $37.5M
Total
- Clients
- 539
- Regulatory AUM
- $7.24B
- AUM share
- 100%
- Avg. per client
- —
- Clients outside the U.S.
- 99%
- Clients advised without assets under management last fiscal year
- 0
- Private funds advised
- 5
- Financial planning clients last fiscal year
- 0
Turim 21 Investimentos Ltda charges 0.40%–0.55% for its Management fees. The brochure does not state whether the rate is annual. The fee is billed in arrears and is negotiable.
Fee details and sources
Gustavo Marini owns 25% to 50% of Turim 21 Investimentos Ltda. It has 124 employees, 20 of them in advisory roles.
Leadership
- Eduardo Gomes AlmeidaDirector
- Luisa CarmoChief Legal Officer and CCO
- Ana Carolina CarvalhoCo-CEO
- Gustavo MariniDirector
- Bernardo MascarenhasDirector
- Leonardo MoraesCo-CEO
Staff
- 124 employees
- 20 in advisory functions
- 5 soliciting firms
- Owns 25% to 50% of Turim 21 Investimentos Ltda
Gustavo Marini
Control person · since March 2001
- Owns 10% to 25% of Turim 21 Investimentos Ltda
Eduardo Gomes Almeida
Control person · since January 2004
- Owns 5% to 10% of Turim 21 Investimentos Ltda
Leonardo Moraes
Control person · since March 2008
- Owns 5% to 10% of Turim 21 Investimentos Ltda
Ana Carolina Carvalho
Control person · since March 2010
- Owns 5% to 10% of Turim 21 Investimentos Ltda
Fernando Verboonen
Control person · since April 2019
Turim 21 Investimentos Ltda’s regulatory assets grew 1.7× from $4.3B (May 2021) to $7.24B (July 2026); clients rose from 290 to 539 and employees from 80 to 124.
Figures from each annual filing
| Filed | Regulatory AUM | Clients | Employees | Offices |
|---|---|---|---|---|
| July 2026 | $7.24B | 539 | 124 | 1 |
| March 2025 | $5.23B | 453 | 96 | 1 |
| July 2024 | $5.36B | 423 | 78 | 1 |
| March 2023 | $5.06B | 383 | 100 | 1 |
| March 2022 | $5.26B | 318 | 87 | 1 |
| May 2021 | $4.3B | 290 | 80 | 2 |
Besides its headquarters, Turim 21 Investimentos Ltda has 0 offices, with 1 listed address with no US state reported.
Contact and registration details
- Legal name
- Turim 21 Investimentos Ltda
- Headquarters
- Rua Major Rubens Vaz 236, Rio De Janeiro, RJ, Brazil 22470-070
- Website
- turimbr.com
- Phone
- 552122598015
- SEC file
- 801-111000
- Structure
- corporation organized in Brazil
- Fiscal year end
- December
Turim 21 Investimentos Ltda uses Santander ($698M) as custodian for its separately managed accounts. Turim 21 Investimentos Ltda has custody of client assets.
- SantanderSantander · Sao Paolo · $698M100%
At year end, Turim 21 Investimentos Ltda’s separately managed accounts were largely in bonds (49%) and funds (41%). Its reported 13F holdings for the quarter ended 30 June 2026 total $613M across 121 positions; the largest are SPDR S&P 500 ETF Trust (25.5%), iShares MSCI Brazil Capped ETF (14.6%) and Vanguard S&P 500 ETF (7.4%).
What the accounts hold
- Stocks8%
- Exchange-traded equities7%
- Non-exchange-traded equities1%
- Funds41%
- Pooled vehicles35%
- Registered funds6%
- Bonds49%
- High-yield corporate bonds20%
- Sovereign bonds17%
- U.S. government and agency bonds9%
- Investment grade corporate bonds3%
- Cash2%
Reported 13F holdings
- $613M
- Reported 13F value
- 121
- Positions
- 86.8%
- In the 10 largest
- —
- Value vs. prior quarter
- SPDR S&P 500 ETF Trust · Total Stk Mkt25.5%
- iShares MSCI Brazil Capped ETF · MSCI Brazil ETF14.6%
- Vanguard S&P 500 ETF · Russia ETF7.4%
- SPDR Gold Shares · Vng Rus2000idx7.3%
- Vale Sa-sp ADR · ADR6.2%
- Invesco Qqq Trust Series 1 · Ultrapro Short S6.2%
- iShares Core MSCI Emerging · Core MSCI Emkt5.9%
- iShares 1-3 YR Int Treasury Bond · 3yrtb ETF5.8%
- Amazon.com, Inc.3.9%
- Alphabet Inc.-cl C · Cap Stk CL C3.9%
Together, the ten largest are 86.8% of reported value.
How many clients does Turim 21 Investimentos Ltda have?
Turim 21 Investimentos Ltda has 539 clients and manages $7.24 billion for them, as of July 2026. They include 445 high-net-worth individuals, 69 pooled investment vehicles, and 17 corporations and other businesses.
Source: Form ADV Part 1A, Items 5.D and 5.F, filed 27 July 2026
What services does Turim 21 Investimentos Ltda offer?
Turim 21 Investimentos Ltda provides portfolio management for individuals and small businesses, portfolio management for pooled vehicles, portfolio management for institutions, and selecting other managers.
Source: Form ADV Part 1A, Item 5.G, from the SEC's 2 October 2026 data file
How much does Turim 21 Investimentos Ltda charge?
Turim 21 Investimentos Ltda charges 0.40%–0.55% for its Management fees. The brochure does not state whether the rate is annual. The fee is billed in arrears and is negotiable.
Which custodians does Turim 21 Investimentos Ltda use?
Turim 21 Investimentos Ltda’s separately managed account assets are held at Santander (Sao Paolo), with $698M. Only custodians holding at least a tenth of those assets are named.
Source: Form ADV Part 1A, Schedule D, Section 5.K.(3), filed 27 July 2026
How many financial advisors does Turim 21 Investimentos Ltda have?
Turim 21 Investimentos Ltda has 0 investment adviser representatives registered with state securities authorities, out of 124 employees, and 20 perform investment advisory functions. None are registered representatives of a broker-dealer or licensed insurance agents.
Source: Form ADV Part 1A, Items 5.A and 5.B, from the SEC's 2 October 2026 data file
What does Turim 21 Investimentos Ltda invest in?
At the end of its last fiscal year, Turim 21 Investimentos Ltda’s separately managed accounts held 35% pooled vehicles (private funds and similar), 20% high-yield corporate bonds, 17% sovereign bonds, 9% U.S. government and agency bonds, 7% exchange-traded equities, 6% registered funds (mutual funds, ETFs, BDCs), 3% investment grade corporate bonds, 2% cash and equivalents and 1% non-exchange-traded equities. It advises 5 private funds.
Source: Form ADV Part 1A, Items 5.K.(1) and 7.B, from the SEC's 2 October 2026 data file
Who owns Turim 21 Investimentos Ltda?
Turim 21 Investimentos Ltda’s direct owners are Gustavo Marini, Leonardo Moraes, Ana Carolina Carvalho, Eduardo Gomes Almeida and Fernando Verboonen, each holding 50% or less.
Source: Form ADV Part 1A, Schedules A and B, filed 27 July 2026
How does Turim 21 Investimentos Ltda get paid?
Turim 21 Investimentos Ltda is paid through a percentage of assets under management, fixed fees and performance-based fees. Its Form ADV lists no commissions among how it is paid.
Source: Form ADV Part 1A, Item 5.E, from the SEC's 2 October 2026 data file
How do I contact Turim 21 Investimentos Ltda?
Turim 21 Investimentos Ltda’s main office is at Rua Major Rubens Vaz 236, Rio De Janeiro, RJ, Brazil 22470-070. Its phone number is 552122598015. Its website is turimbr.com.