XP Inc. (XP) Investigation

The investigation is focused on the propriety of XP’s statements about its business model and recent assurances to investors that it has improved its internal control over financial reporting.

XP’s assurances may have come under question on March 12, 2025, when Grizzly Research published “XP’s (Nasdaq: XP) Entire Profits Are Dependent on What Insiders Call a ‘Madoff-Like Ponzi Scheme.” Grizzly alleges, in part, that:

• “Our research uncovers that [XP] is running a massive Ponzi scheme facilitated through certain derivatives sales to retail clients, which are funneled through special funds and misrepresented as proprietary trading profits[;]”
• “At the center of the scheme is a XP fund called GLADIUS FIM CP IE (‘Gladius’) that returned over 2,419% over the last five years with unbelievably low volatility[;]”
• “The returns from Gladius and its affiliated fund COLISEU FIM CP IE (‘Coliseu’) are higher than XP’s earnings[]” and “[w]ithout Gladius and Coliseu, XP would be unprofitable[;]”
• “The secret to Gladius’ profitability is a product called COE which stands for Certificado de Operações Estruturadas[]” which “XP pushes aggressively on its Brazilian retail clients[;]
• “According to XP’s former employees, the scheme only continues to work as long as XP is able to sell more COEs[]” and “[a]s soon as the inflows stop growing the system falls apart and XP could be liable for enormous obligations it cannot meet[;]” and
• “Insiders outright called Gladius a ‘Madoff-like Ponzi scheme.’”  

 In response to the Grizzly report, the price of XP shares significantly declined.

FREQUENTLY ASKED QUESTIONS ABOUT THE CASE

What is the XP investigation about?

We are investigating whether whether XP, as Madoff, may have misrepresented its business model to investors.

WHAT SHOULD I DO?

I worked at XP. What should I do?

If you were an employee of XP, you may have valuable information that could be relevant to the investigation. Hagens Berman is one of the nation’s top whistleblower law firms, and has successfully represented many individuals who come forward with information regarding corporate malfeasance. Under the new SEC Whistleblower program, whistleblowers who provide original information may receive rewards totaling up to 30 percent of any successful recovery made by the SEC. For more information, contact Reed Kathrein at 844-916-0895 or [email protected].

There are multiple law firms participating, do I need to contact all of them?

No, you do not need to contact all participating law firms. Generally, class-action investigations and lawsuits are consolidated into a single case to streamline the legal process, and attorneys from only a few law firms are selected to serve in a leadership role on the consolidated case. Hagens Berman has a proven track record of being appointed to leadership roles in complex, multidistrict litigation regarding investor fraud and other consumer rights issues, and your claim will be handled by attorneys who have helped secure approximately $325 billion in class-action settlements on behalf of individuals who have suffered due to corporate malfeasance and the wrongdoing of other powerful institutions.

AM I ELIGIBLE?

What is the threshold amount to be eligible? What are “substantial” losses?

The threshold amount and the definition of "substantial" losses may vary depending on a number of factors specific to the case, including the size of the company, market cap, shares outstanding and who holds them and the damages alleged by the fraud. In general, to be eligible to participate in a class-action lawsuit, you must be able to demonstrate that you suffered financial losses as a result of the alleged wrongdoing and that your losses meet the criteria set by the court or law firm. Fill out the form and submit your losses.

CAN I PARTICIPATE?

Am I affected? What do I need to do to participate?

If you were an investor in XP, you may be affected and eligible to participate in the case. To determine your eligibility and potential involvement, fill out the form and submit your losses.

Can any XP investor participate?

In most class-action investigations and cases, any investor who meets the eligibility criteria, including purchasing the shares during the relevant period, can participate, regardless of the size of their investment. Fill out the form to find out your rights.

I bought on a non-U.S. Exchange. Can I participate?

No. This investigation only covers shares bought on a U.S. exchange, i.e. NASDAQ or NYSE. Fill out the form to find out your rights.

Am I included if I still hold my shares, or do I need to sell to participate?

Participation is based on purchasing shares during the relevant period, rather than your current holdings. Accordingly, you do not need to sell to participate. Fill out the form to find out your rights.