United States securities and exchange commission logo

                               November 3, 2020

       Alessandro Monteiro Morgado Horta
       Chief Executive Officer
       Vinci Partners Investments Ltd.
       Av. Bartolomeu Mitre, 336
       Leblon     Rio de Janeiro
       Brazil 22431-002

                                                        Re: Vinci Partners
Investments Ltd.
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted October
7, 2020
                                                            CIK No. 0001826286

       Dear Mr. Horta:

              We have reviewed your draft registration statement and have the
following comments. In
       some of our comments, we may ask you to provide us with information so
we may better
       understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Draft Registration Statement on Form F-1 submitted October 7, 2020


   1.                                                   Please provide us with
supplemental copies of all written communications, as defined in
                                                        Rule 405 under the
Securities Act, that you, or anyone authorized to do so on your
                                                        behalf, have presented
or expect to present to potential investors in reliance on Section
                                                        5(d) of the Securities
Act, whether or not you retained, or intend to retain, copies of those
                                                        communications. Please
contact the staff member associated with the review of this
                                                        submission to discuss
how to submit the materials, if any, to us for our review.
 Alessandro Monteiro Morgado Horta
FirstName  LastNameAlessandro
Vinci Partners Investments Ltd. Monteiro Morgado Horta
Comapany 3,
November   NameVinci
              2020     Partners Investments Ltd.
Page 2     3, 2020 Page 2
FirstName LastName
Summary, page 1

2.       Please ensure that the information you include in your summary is
balanced. To the
         extent that you cite competitive strengths in your summary, please
revise to provide
         balanced information, rather than merely providing a list of risk
factors at the end of this
         section. Please revise your summary disclosure to provide similar
levels of detail and
         prominence of your competitive strengths, strategies and risk factors.
Summary Financial Information
Non-GAAP Financial Measures, page 21

3.       We note your disclosure of "Dividends to Partners, excluding
performance fee-related
         dividends," "Dividends to Partners related to performance fees,"
"Dividends to Partners,
         excluding unrealized performance fee-related dividends," and
"Dividends to Partners".
         Please reconcile these amounts to dividends as reported within your
financial statements.
4.       We note that footnote 6 on page 23 says that you present Adjusted
Profit to provide
         investors and analysts with information regarding the net results of
your business. Please
         clarify whether this is a measure used by and for internal management
purposes as well.
Risk Factors
We are subject to risks related to conflicts of interest, page 54

5.       We note your disclosures that you have made and expect to continue to
make principal
         investments alongside your investors and that you intend to use a
portion of the proceeds
         in order to increase your investments alongside your investors. Please
describe to us, and
         make revisions to your risk factor section as appropriate, whether on
occasion your
         financial interests may be in conflict with the financial interests of
your clients. Please tell
         us about the internal protocols you have in order to manage any
potential or actual such
         conflicts of interests specific related to investing alongside your
Management's Discussion and Analysis of Financial Condition and Results of
Evolution of AUM by Segment, page 99

6.       We note from your use of proceeds disclosure on page 75 that you
intend to use some net
         proceeds from this offering to fund investments in your own products
         your investors. Please clarify whether your Evolution of AUM by
Segment amounts
         currently include your own investments alongside your investors, and
revise to disclose
         and quantify such impacts to the extent that they are material to an
         understanding of your AUM flows.
7.       Please expand your disclosures here or elsewhere to provide an
evolution of total AUM
         for a holistic roll-forward view in addition to the disaggregated
segment views you
         currently provide.
 Alessandro Monteiro Morgado Horta
FirstName  LastNameAlessandro
Vinci Partners Investments Ltd. Monteiro Morgado Horta
Comapany 3,
November   NameVinci
              2020     Partners Investments Ltd.
Page 3     3, 2020 Page 3
FirstName LastName
Industry Overview, page 119

8.       Please indicate whether you contributed any payment for the creation
of any of the third
         party industry information you utilize in this section. Also indicate
if you have any
         affiliations with the named entities.
Our Founding and Evolution, page 140

9.       We note that based on certain data sources you have extrapolated
certain conclusions
         regarding your impact on Brazil. Please revise your second bullet
point in order to better
         explain how investing in other companies would have made you the ninth
         employer in Brazil. In addition, please provide more detail by
quantifying how many of
         the 65,000 jobs generated by the companies in which you invest were a
result of your
         investment. For example, please disclose the capital investment you
made in those
         companies compared by the capital invested by non-affiliates in order
to quantify your
         direct impact. Also quantify how you determine that you are a "leading
independent asset
         manager," with "leading franchises." In addition, please ensure that
the claims you make
         regarding your impact and standing within your industry are clearly
connected to the data
         sources you cite and utilize.
Competitive Strengths
We have an established and recognized track record of achieving returns . . .,
page 143

10.      We note your disclosure on page 144 of the performance of selected
funds against
         benchmarks. Please enhance your disclosure to give some context of how
these funds
         were selected and how they fit into the broader portfolios of their
respective categories;
         e.g., their proportion of AUM, investment funds, or revenue, or
another metric that helps
         link and quantify these funds within each segment.
Compensation of Directors and Officers, page 174

11.      Please disclose the total amount set aside or accrued by you to
provide pension, retirement
         or other similar benefits for your executive officers and directors
during the most recently
         completed fiscal year. Refer to Item 6.B.2 of Form 20-F.
Explanatory Note to the Financial Statements, page 215

12.      We note your disclosure that the financial statements presented are
those of Vinci Partners
         Brazil, but the entity listed on the financial statements is Vinci
Partners Investimentos
         Ltda. Please clarify and revise to disclose whether these two entities
are the same.
 Alessandro Monteiro Morgado Horta
FirstName  LastNameAlessandro
Vinci Partners Investments Ltd. Monteiro Morgado Horta
Comapany 3,
November   NameVinci
              2020     Partners Investments Ltd.
Page 4     3, 2020 Page 4
FirstName LastName
Notes to the Financial Statements
23 Subsequent Events, page F-75

13.      We note the Entity paid dividends to the quotaholders in the amount of
R$ 71,648 in
         January 2020. Please tell us how you considered SAB Topic 1:B.3 in
determining how to
         present such dividends.
       You may contact Lory Empie at (202) 551-3714 or Cara Lubit at (202)
551-5909 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Eric Envall at (202) 551-3234 or David Lin at (202) 551-3552 with any
other questions.


                                                           Division of
Corporation Finance
                                                           Office of Finance