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Turim 21 Investimentos Ltda

Wealth managementRIA

Rio De Janeiro, RJ, BrazilCRD 286618Updated

Turim 21 Investimentos Ltda is an investment adviser based in Rio De Janeiro, RJ, Brazil, registered with the SEC since 2017. It provides investment management. Its clients include high-net-worth individuals, pooled investment vehicles, and corporations and other businesses. Its regulatory assets under management total $7.24 billion, as filed on 27 July 2026.

539
Clients
Not reported
AUM per individual client
20
Advisory staff
1
Offices

From Form ADV filed 27 July 2026SEC record

Services and clients

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.

Clients and assets by client type
Clients539 clients reported
Assets$7.24B
Share of clients and assets by client type
Client typeClientsAssets
Individuals (other than HNW)Fewer than 5<1%
High-net-worth individuals83%66%
Pooled investment vehicles13%24%
Pension and profit-sharing plansFewer than 5<1%
Charitable organizations1%<1%
Other client typesInsurance companies; Corporations and other businesses3%9%

Client shares use reported counts. Client types without a reported count are excluded from that total.

Client breakdown and activity details
Individuals (other than HNW)
Clients
Fewer than 5
Regulatory AUM
$8.68M
AUM share
0.1%
Avg. per client
—
High-net-worth individuals
Clients
445
Regulatory AUM
$4.79B
AUM share
66.2%
Avg. per client
$10.8M
Pooled investment vehicles
Clients
69
Regulatory AUM
$1.72B
AUM share
23.8%
Avg. per client
$24.9M
Pension and profit-sharing plans
Clients
Fewer than 5
Regulatory AUM
$26.9M
AUM share
0.4%
Avg. per client
—
Charitable organizations
Clients
8
Regulatory AUM
$49.3M
AUM share
0.7%
Avg. per client
$6.16M
Insurance companies
Clients
Fewer than 5
Regulatory AUM
$6.65M
AUM share
0.1%
Avg. per client
—
Corporations and other businesses
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

Fees and minimums

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

Ownership and people

Gustavo Marini owns 25% to 50% of Turim 21 Investimentos Ltda. It has 124 employees, 20 of them in advisory roles.

Leadership

Staff

  • 124 employees
  • 20 in advisory functions
  • 5 soliciting firms
Who owns the firm
Turim 21 Investimentos Ltda· the adviser
  • Gustavo Marini

    Control person · since March 2001

    Owns 25% to 50% of Turim 21 Investimentos Ltda
  • Eduardo Gomes Almeida

    Control person · since January 2004

    Owns 10% to 25% 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

    Owns 5% to 10% of Turim 21 Investimentos Ltda

Growth and acquisitions

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.

By annual filing
Measure
Figures from each annual filing
Turim 21 Investimentos Ltda figures from each annual Form ADV filing
FiledRegulatory AUMClientsEmployeesOffices
July 2026$7.24B5391241
March 2025$5.23B453961
July 2024$5.36B423781
March 2023$5.06B3831001
March 2022$5.26B318871
May 2021$4.3B290802

Offices and registration details

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
SEC file
801-111000
Structure
corporation organized in Brazil
Fiscal year end
December

Custodians

Turim 21 Investimentos Ltda uses Santander ($698M) as custodian for its separately managed accounts. Turim 21 Investimentos Ltda has custody of client assets.

Reported separately managed account assets by custodian
$698M
named custodians
  • SantanderSantander · Sao Paolo · $698M100%

Investments and reported holdings

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

Separately managed account assets by class, year end
  • 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
Ten largest positions, share of reported value
  1. SPDR S&P 500 ETF Trust · Total Stk Mkt25.5%
  2. iShares MSCI Brazil Capped ETF · MSCI Brazil ETF14.6%
  3. Vanguard S&P 500 ETF · Russia ETF7.4%
  4. SPDR Gold Shares · Vng Rus2000idx7.3%
  5. Vale Sa-sp ADR · ADR6.2%
  6. Invesco Qqq Trust Series 1 · Ultrapro Short S6.2%
  7. iShares Core MSCI Emerging · Core MSCI Emkt5.9%
  8. iShares 1-3 YR Int Treasury Bond · 3yrtb ETF5.8%
  9. Amazon.com, Inc.3.9%
  10. Alphabet Inc.-cl C · Cap Stk CL C3.9%

Together, the ten largest are 86.8% of reported value.

The 50 largest positions and quarterly changesQuarter ended 30 June 2026 · filed 10 August 2026

Common questions

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.

Source: TURIM FORM ADV PART 2A, filed 30 March 2026

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.

Source: Form ADV Part 1A, Item 1.F, filed 27 July 2026

Sources and methodology

  1. Form ADV Part 1A, amendment filed 27 July 2026. Items 1, 5, 9, 11 and Schedules A, B and D.
  2. TURIM FORM ADV PART 2A, submitted 30 March 2026.
  3. IAPD firm record, CRD 286618.
  4. SEC registered adviser data, annual Form ADV amendments filed 5 May 2021 to 27 July 2026. Items 1.F and 5.
  5. Form 13F-HR, filed 10 August 2026 for the quarter ended 30 June 2026.

Retrieved 15 October 2026. All are published by the SEC and may have been amended since. Disciplinary history is not yet shown here. The SEC publishes the complete record, including any disciplinary events, and it is the authoritative place to check one.

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