According to the Complaint, XP Inc. purports to be a leading, technology-driven financial services platform and a trusted provider of low-fee financial products and services in Brazil.

On December 11, 2019, XP filed with the SEC its final prospectus for the IPO on Form 424B1, which forms part of the Registration Statement. The Complaint alleges that the Registration Statement featured false and/or misleading statements and/or failed to disclose that: (1) XP engaged in undisclosed related party transactions; (2) XP failed to disclose its common and large system failures and connected losses; (3) XP’s aggressive Independent Financial Agent strategy was and is tenuous; (4) XP had material weaknesses; (5) XP fired its previous accounting firm due that firm finding and disclosing material weaknesses; and (6) as a result, Defendants’ statements about XP’s business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.