XP Inc.

“XP is Brazil's undisputed independent investment platform leader trading at 7.6x forward earnings — cheap in absolute terms with a credible 2x upside path by 2031 — but the discount is earned: regulatory risk to its commission-based model is the key permanent impairment scenario, management has a pattern of over-optimism on guidance, dual-class governance limits minority shareholder protection, and Nubank's scale creates a long-term competitive shadow. The business is good but not exceptional, and conviction is moderate rather than high, making this a tranche-build TRACK rather than an outright BUY.”