XP  Advisory  US,  Inc  (“XP  Advisory”),  formerly  known  as  XP  Private,  Inc,  is  a  Registered  Investment 
Adviser formed in the U.S. Securities and Exchange Commission. XP Advisory US, Inc. (hereinafter “XP 
Advisory”) has been located in Miami, Florida since November 2014. XP Advisory is directly owned by XP 
Inc.   
The following paragraphs describe our services and fees. Please refer to the description of the investment 
advisory services listed below for information on how we tailor our advisory services to your individual 
needs. As used in this brochure, the words “we,” “our” and “us” refer to XP Advisory and the words “you,” 
“your” and “client” refer to you as either a client or prospective client of our firm. Also, you may see the 
term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are 
our firm’s officers, employees, and all individuals providing investment advice on behalf of our firm.  
Investment Management Services 
We offer discretionary and non-discretionary investment management services. Our investment advice 
is  tailored  to  meet  our  clients'  needs  and  investment  objectives.  If  you  retain  our  firm  for  investment 
management services, we will meet with you to determine your investment objectives, risk tolerance, and 
other relevant information (the "suitability information") at the beginning of our advisory relationship. We 
will  use  the  suitability  information  we  gather  to  develop  a  strategy  that  enables  our  firm  to  give  you 
continuous and focused investment advice and/or to make investments on your behalf. As part of our 
investment management services, we may customize an investment portfolio for you in accordance with 
your risk tolerance and investing objectives. We may also invest your assets using a predefined strategy, 
or we may invest your assets according to one or more model portfolios developed by our firm. Once we 
construct  an  investment  portfolio  for  you,  or  select  a  model  portfolio,  we  will  monitor  your  portfolio's 
performance  on  an  ongoing  basis,  and  will  rebalance  the  portfolio  as  required  by  changes  in  market 
conditions and in your financial circumstances.  
If you participate in our discretionary portfolio management services, we require you to grant our  firm 
discretionary authority to manage your account. You may limit our discretionary authority (for example, 
limiting the types of securities that can be purchased for your account) by providing our firm with your 
restrictions and guidelines in writing. If you enter into non-discretionary arrangements with our firm, we 
must obtain your approval prior to executing any transactions on behalf of your account. 
XP Advisory provides investment management services to clients with an extensive array of products 
that allow them to efficiently access the international capital markets. Our full commitment to our clients 
eliminates conflicts of interest and ensures that decisions are geared exclusively to producing the best 
results. 
At  XP  Advisory,  we  are  committed  to  being  a  partner  of  choice  and  curating  an  exceptional  suite  of 
products chosen to fit the needs of clients. We are an open platform but give a full due-diligence review 
to each of the proposed products in a client’s portfolio, ensuring that it fits not only their investment profile 
but also our investment fundamentals and management team screening. 
Investment  accounts  are  subject  to  the  written  investment  guidelines  and  investment  objectives  (the 
"Investment  Guidelines")  as  directed  by  each  client  and  approved  by  XP  Advisory.  The  Investment 
Guidelines may be amended from time to time by written notice from the client. XP Advisory recommends 
purchases and sales of domestic and foreign securities and instruments. 
The majority of our clients are high net worth individuals and corporations. We know how important it is 
to understand the unique needs and perspectives of our clients. Our value-added approach offers the 
following advantages: 
  A personalized boutique approach to navigating risks and opportunities. 
  We structure each client’s investment portfolios according to an asset allocation model that takes 
into account their risk and return objectives. 
  We  emphasize  a  balanced  approach  to  asset  allocation,  seeking  to  diversify  the  holdings  by 
products, sectors, and regions of the investments. 
  Our open-architecture platform allows us to provide a global selection of financial products from a 
wide variety of financial institutions. 
  We  remain  nimble  to  the  changes  in  both  the  financial  markets  as  well  as  to  the  personal 
circumstances of our clients. 
Recommendation of Sub Advisers 
As part of our overall portfolio management strategy, we may also recommend affiliated and/or unaffiliated 
sub advisers to manage all or a portion of your account. All sub advisers recommended by our firm must 
either be registered as investment advisers or exempt from registration requirements. These sub advisers 
may  specialize  in  traditional  or  alternative  investments.  Factors  that  we  take  into  consideration  when 
making our recommendations include, but are not limited to, the following: the sub adviser’s performance, 
methods  of  analysis,  fees,  your  financial  needs,  investment  goals,  risk  tolerance,  and  investment 
objectives. Once  a  sub advisory  account  has  been  established,  we  will  provide  all  administrative  and 
clerical duties that are required to service your account. The sub adviser will have little or no direct contact 
with you. Our responsibility to you will be to: (i) continuously evaluate the performance of your portfolio to 
ensure the sub adviser selected adheres to your asset allocation guidelines; (ii) make recommendations 
regarding the sub adviser as market factors and your personal goals dictate, (iii) assume discretionary 
authority to hire or fire the sub adviser where such action is deemed to be in your best interest. 
Important Information about Affiliated Sub-Advisers. 
The XP Investment Management service makes available to clients investment services that are offered 
by  and  XP  Advisory Gestão  de  Recursos  Ltda, affiliates  of  XP  Advisory.  XP  Advisory  has  a  potential 
conflict of interest to the extent XP Advisory would advise a client to select investment services offered 
by those affiliates of XP Advisory. For more information, see Item 10 - Other Financial Industry Affiliations 
and Activities. 
Non-wrap Investment Management Services 
XP Advisory offers investment management services where clients receive ongoing investment advice, 
but separately pays for securities transactions and brokerage-related fees. At the client’s direction, XP 
Advisory  will  manage  the  account  according  to  a  specific  strategy  on  a  discretionary  basis.  The 
investment management service could include affiliated or unaffiliated third-party investment managers. 
XP Advisory provides additional consulting services to the client in accordance with their particular needs 
or  objectives.  This  service  is  designed  to  accommodate  a  client  who  wishes  to  independently  select 
investment services outside of XP Advisory US Wrap Fee Program in managing the assets in the client’s 
account. 
In some  cases,  a  client may  direct  XP  Advisory to
                                        
                                        
                                              use  a  particular  broker-dealer  for execution  of  the 
client’s trade orders (a “directed brokerage arrangement”). This occurs when a client’s account is held at 
another broker-dealer firm and the client directs XP Advisory execute trades through that firm.  
Clients should be aware that any costs related to this arrangement are not included in the advisory fee 
and that the client will be solely responsible for paying any commissions, markups or markdowns or other 
costs  imposed  by  the  directed  broker-dealer.  Please  see  Item  12  –  Brokerage  Practices  for  further 
information. 
Selection of Third-Party Investment Advisors, Platforms and Programs 
We have entered into agreements with various third-party investment advisers for the provision of certain 
investment advisory services. Factors considered in the selection of a third-party advisor include but may 
not be limited to: i) Our firm’s preference for a particular third-party advisor; ii) the client’s risk tolerance, 
goals and objectives, as well as investment experience; and, iii) the amount of client assets available for 
investment.  In  order  to  assist  clients  in  the  selection  of  a  third-party  advisor,  we  will  typically  gather 
information from you about your financial situation and investment objectives. 
The third-party advisor may customize your portfolio by blending traditional investment strategies with an 
allocation to asset classes. Generally, securities transactions will be decided upon and executed by the 
third-party advisor on a discretionary basis. This means that the manager selected will have the ability to 
buy and sell securities in your account without obtaining your approval. We will not manage or obtain 
discretionary authority over the assets in accounts participating in these programs; however, clients may 
grant us the discretionary authority to hire and fire such third-party managers. Generally, clients may not 
impose restrictions  on  investing  in  certain  securities  or types  of  securities  in  accounts  managed  by  a 
third-party advisor.  
We will periodically review reports provided to you. We will contact you at least annually, or more often 
to  review  your  financial  situation  and  objectives,  communicate  information  to  the  third-party  advisor 
managing  the account as necessary, and, to  assist you  in understanding and evaluating the services 
provided by the third-party advisor. Please notify us of any changes in your financial situation, investment 
objectives, or account restrictions. 
A  complete  description  of  the  services  provided,  the  amount  of  total  fees,  the  payment  structure, 
termination provisions and other aspects of the third-party advisor’s advisory business are detailed and 
disclosed in: i) the third-party advisor’s Form ADV Part 2A; ii) the program wrap brochure (if applicable) 
or  other  applicable  disclosure  documents;  iii)  the  disclosure  documents  of  the  portfolio  manager(s) 
selected; or, iv) the third-party advisor’s account opening documents. A copy of all relevant disclosure 
documents of the third-party advisor and of the individual portfolio manager(s) will be provided to anyone 
interested in these programs/managers. 
Investment Services to Pooled Investment Vehicles 
XP  Advisory  also  provides  investment  advisory  services  to  domestic  and  offshore  pooled  investment 
vehicles  that  are  exempt  from  SEC  registration  (“Institutional  Advisory  Services”).  XP  Advisory’s 
investment advisory related services to pooled investment vehicles are subject to the terms set forth in 
their  Private  Placement  Memorandum  or  Explanatory  Memorandum.  Please  see  further  information 
under Item 10 and 14 of this brochure. 
Types of Investments 
We offer our clients a world of options through an open architecture investment platform. 
Equities and Options 
Another  core  component  to  a  well-diversified  portfolio  is  global  equity  products.  At  XP  Advisory,  we 
provide  market  access  to  a  wide  range  of  financial  instruments,  such  as  listed  U.S.  and  International 
stocks, ETFs, equity and index options and ADRs. 
Fixed Income 
Fixed income products are an important component to a well-diversified portfolio. We develop many of 
our strategies based on bond management techniques that focus on adding value while managing risks. 
We offer a comprehensive range of fixed income products, including treasuries, government notes and 
bonds, corporate bonds, emerging market bonds, international sovereign bonds, and agency bonds. 
Mutual Funds 
Another important option for well-structured portfolios is the addition of mutual funds  and the inherent 
diversification they provide. Through our open-architecture, we work with best-in-class fund managers 
with  long,  successful  track  records  and  a  thorough  grounding  in  risk  management.  We  specialize  in 
working with a comprehensive set of fund managers offering products with a unique set of benefits for 
international investors. 
Wrap Fee Program 
XP  Advisory  is  the  portfolio  manager  and  sponsor  of  the  XP  Advisory  US  Wrap  Fee  Program  (“the 
Program”).  Our  portfolio  management  services  are  offered  through the  Program for  a  single  fee  that 
includes administrative fees, portfolio management fees, and commissions. The overall cost you will incur 
if you  participate in our wrap fee program may be  higher  or lower than you might incur by separately 
purchasing the types of securities available in the program. In order to compare the cost of the Program 
with unbundled services, the client should consider the turnover rate in our investment strategies, trading 
activity in the account and standard advisory fees and brokerage commissions that would be charged at 
other broker-dealers and investment advisors. 
The Program began in 2020. Existing clients of our firm have been offered the option of transitioning to 
a wrap account or maintaining their account under a non-wrap arrangement. Therefore, legacy clients of 
XP Advisory could have non-wrap account arrangements. Under certain situations XP Advisory offers 
other investment management account options as disclosed above. There are no differences in how we 
manage wrap fee accounts and how we manage non-wrap accounts.  
XP Advisory, as portfolio manager is responsible for the research, security selection and implementation 
of transaction orders in the client's account. The transactions in the client's account will be executed by 
XP Investments US, LLC (“XPI”), an affiliated and introducing broker-dealer. Client assets are custodied 
at Pershing, LLC (“Pershing”). XP Advisory receives a portion of the Wrap Fee for portfolio management 
services. XPI will receive a portion of the fee for trade execution expenses and Pershing will receive a 
portion of the fee for its custodial services.   
The terms and conditions under which a client participates in XP Advisory’s wrap fee program will be set 
forth in a written agreement between the client and XP Advisory. For detailed information about the XP 
Advisory US Wrap Fee Program, please see our wrap fee brochure (Part 2A Appendix 1 of Form ADV). 
Regulatory Assets Under Management 
As of December 31, 2023, we managed approximately $890,628,814 in client assets on a discretionary 
basis and approximately $643,471,296  in client assets on a non-discretionary basis.