21st Financial

21st Financial is an independent, single-advisor registered investment adviser that provides discretionary and non-discretionary portfolio management to a small client base including individuals, high-net-worth individuals, and closely held businesses. The firm manages a modest amount of regulatory assets and customizes portfolios to clients’ objectives and risk tolerance, with no stated account minimum.

The firm combines fundamental and technical analysis with a generally long-term, buy-and-hold orientation and uses diversified allocations across equities, fixed income and cash equivalents. For suitable clients, 21st Financial may recommend a material allocation to Bitcoin or Bitcoin-backed credit instruments (generally described as 10–40%) and uses position sizing and, where available, derivatives and options to tailor volatility; the brochure also discloses the principal’s personal holdings in Bitcoin and related securities and highlights the liquidity, volatility and regulatory risks of such allocations.

What distinguishes the firm from many small independent advisers is its explicit referral arrangements with specialized Bitcoin service providers: a revenue-sharing referral agreement that pays the firm a portion of referred clients’ fees in Bitcoin and a profit-share arrangement for referrals to a Bitcoin mining and tax services provider, both addressed in the brochure and disclosed as conflicts of interest. The firm also discloses the ability to waive or reduce advisory fees (including promotional fee-free periods and a referral fee-waiver program) and maintains public communications on multiple social media and digital platforms for educational and marketing content.