21Peaks Capital Management, LLC

21Peaks Capital Management provides investment advisory services to high-net-worth and ultra-high-net-worth individuals and families, as well as other advisers and institutions, principally through separately managed accounts with a pronounced focus on digital assets. The firm was formed in 2019 and is newly registering with the SEC after previously operating as an exempt reporting adviser that managed private pooled vehicles.

The firm’s investment approach emphasizes customized Investment Policy Statements, long-term tax-efficient portfolio construction, and tailored use of traditional and digital-asset exposures; it manages most accounts on a discretionary basis but documents client-directed limits on discretion where requested. 21Peaks also leverages third‑party managers and offers a curated model portfolio intended to provide direct and indirect price exposure to Bitcoin and other crypto assets via widely available ETFs and equities.

Compared with many peers, 21Peaks combines a pronounced digital-asset specialization with an uncommon operating footprint—operating from five offices despite modest regulatory assets under management and being in the process of initial SEC registration. The firm’s Platform includes features not typical for managers of its size, including allowance for non‑security holdings that may be self‑custodied or held with non‑traditional custodians and a client-specific “blended” breakpoint fee framework rather than a single flat fee schedule.