TURIM 21 INVESTIMENTOS LTDA

CRD 286618File 801-111000

APPROVED

Retail clients

Custody

Filing as of Jul 27, 2026

Feed vintage Aug 17, 2026

Regulatory AUM

$7.24B

Top 25% of cohort (national)

Discretionary AUM

$7.24B

Clients

539

544 accounts

Employees

124

Identity & registration

ADV Item 1

Organization form: Corporation
Firm type: Registered
SEC region: HQ
Registration date: Aug 15, 2017
Principal office: RUA MAJOR RUBENS VAZ 236, RIO DE JANEIRO, RJ, 22470-070
Phone: 55 21 2259.8015
Website: HTTP://WWW.TURIMBR.COM

Assets & accounts

ADV Item 5F

Total regulatory AUM: $7.24B
Discretionary AUM: $7.24B
Non-discretionary AUM: $0
Discretionary accounts: 544
Non-discretionary accounts: 0
Total accounts: 544
AUM per client: $13.4M

Clients by type

ADV Item 5D

Client type	Clients	AUM
Other	17	$637.6M
Insurance companies	Fewer than 5	$6.7M
Charitable organizations	8	$49.3M
High net worth individuals	445	$4.79B
Pooled investment vehicles	69	$1.72B
Pension and profit sharing plans	Fewer than 5	$26.9M
Individuals (other than high net worth individuals)	Fewer than 5	$8.7M

Compensation & activities

ADV Items 5E, 5G

Compensation

Fixed fees
Performance-based fees
A percentage of assets under your management

Advisory activities

Selection of other advisers
Portfolio management for businesses
Portfolio management for pooled investment vehicles
Portfolio management for individuals and/or small businesses

Custody

ADV Item 9

Firm Custody Cash: Yes
Firm Custody Assets: Yes
Firm Custody Clients: Yes
Firm Custody Securities: Yes
Related Person Custody Cash: No
Related Person Custody Assets: No
Related Person Custody Clients: No
Related Person Custody Securities: Yes

Disclosure events

ADV Item 11

This firm answered no to every Item 11 disclosure question in this filing.

Filed changes

Date	Field	From	To
Aug 12, 2026	Registration	—	APPROVED

Every value above is reproduced from this firm's Form ADV filing. Fields the firm left blank are shown as “Not reported” rather than filled in from other sources.