Stock Analysis · Bulls vs Bears

Nu Holdings Ltd. NU

🐂 Bulls vs Bears 🐻Report #19 Oct 2026
★ Willem owns this stock · 2.3% of the portfolioOlder version — see the latest →
44
moderate risk
🐂 8vs8 🐻
Even
35%
▲ Chance of the biggest tailwind the forecasts miss
30%
▼ Chance of the biggest headwind the forecasts miss
The verdict

Nu is the low-cost winner of Brazilian retail banking. It has a real and measurable cost and funding edge, it is still growing earnings 40%+ a year at a 33% return on equity, and Mexico is becoming a second leg. What you own is a leveraged bet on the Brazilian consumer: on whether Nu's underwriting holds through a credit turn, and on whether Brazilian politics and tax policy let it keep its margins.

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Written by Claude (Anthropic’s AI) from public sources · Willem owns NU · AI can make mistakes — numbers in brackets point to the sources · Not financial advice

🐂 Bull arguments 8

  1. 1A structural cost advantage nobody has matched at scaleStrong
  2. 2Long runway to earn more from the customers it already hasStrong
  3. 3Cheap, sticky deposits with room to lend more of themMedium
  4. 4Mexico is becoming a second engineMedium
  5. 5Underwriting and data advantage, now AI-drivenMedium
  6. 6Strong capital generation and returns to shareholdersMedium
  7. 7Founder-led team with a record of delivering, and deep regulatory know-howMedium
  8. 8The US is a cheap call optionWeak

🐻 Bear arguments 8

  1. 1An almost-all-unsecured loan book entering a softer Brazilian credit cycleHigh
  2. 2Concentrated in Brazil: politics, currency and ratesMedium
  3. 3A rising tax and regulatory take on Brazilian fintechsMedium
  4. 4Today's margin is partly flattered: one-offs, high rates and a peakMedium
  5. 5Competition intensifies where Nu wants to grow nextMedium
  6. 6Legal and political pressure on card pricingLow
  7. 7Governance and capital-allocation risk under a controlling founderMedium
  8. 8Brazil's customer pool is close to saturatedLow

Bull arguments show how well they survive the devil’s advocate (strong / medium / weak); bear arguments show the damage they could do after the counter-argument (high / medium / low).

Bull case — all positive points (most important first)

🐂 Bull #1A structural cost advantage nobody has matched at scale

  • The point: Nu runs a 139M-customer bank at a fraction of incumbents' cost, so it can charge less, pay more on deposits, accept thinner-margin customers and still earn a 33% return on equity.
  • Evidence:
    • Monthly cost to serve is $1.0 per active customer, against ARPAC (average monthly revenue per active customer) of $17.1 [2].
    • The efficiency ratio is 19.5% [2]. Nu says incumbent cost per customer is about 85% higher [1].
    • Marketing was 1.9% of 2025 revenue [1]. Headcount is about 10,400 and Vélez does not see it "significantly increasing" [6].
    • AI agents now handle more than 60% of Brazilian support conversations [2].
    • Return on equity was 33% in Q2-2026 [2].
  • Why it matters: low cost means each new product (a payroll loan, an insurance policy, a phone plan) is profitable at prices rivals cannot match. That is why Nu can enter the price-capped private payroll market, which management says "will be won by the lowest-cost provider" [9].
  • 😈 Devil's advocate:
    • Cost per customer is low partly because Nu's customers are low-income and use few services. As Nu moves up-market and into secured lending, compliance and servicing costs rise.
    • Becoming a regulated bank in Brazil, Mexico and the US adds supervision cost.
    • Incumbents are cutting branches and digitising too.
    • Cost to serve already rose from $0.8 to $1.0 a year ago, while ARPAC grew faster [2].
  • Verdict: Strong Ten years of evidence, and the gap to incumbents is still several-fold even if it narrows.

🐂 Bull #2Long runway to earn more from the customers it already has

  • The point: Nu has the customers. The next phase is selling them more: payroll loans, small-business credit, insurance, investments and high-income tiers.
  • Evidence:
    • ARPAC is $17.1, up from $12.5 a year earlier. Incumbents earn $40–45, and Nu's 7–8-year-old customer groups are in the "mid-20s" (Vélez) [2,6].
    • Nu claims about 7% of Brazil's $100B+ retail banking gross-profit pool [5]. In unsecured lending it holds about 8% of the stock but 25–30% of monthly originations (Q1-26 call) [7].
    • Nu is the main bank for more than 62% of active Brazilian customers [1].
    • It serves 6.8M small businesses but reaches only about a third of that market [6].
    • Its share of Brazilian card-portfolio growth is outsized: Nu plus Mercado Livre made up 36% of the 12-month growth (Itaú BBA, March 2026) [37].
  • Why it matters: revenue can keep compounding even after customer growth stalls. Each extra dollar of ARPAC comes in at very low marginal cost.
  • 😈 Devil's advocate:
    • Much of the ARPAC growth so far comes from lending more to the same people, and that is exactly the risk in Bear #1.
    • The next products are lower-margin and more competitive. Payroll loans are priced near caps, insurance commissions were only $35.5M in 2025 [1], and incumbents hold high-income customers' main relationship.
    • Vélez himself says Nu will "not get" to incumbents' $40–45 [6].
  • Verdict: Strong The runway is real, but it is earned partly by taking on more credit risk.

🐂 Bull #3Cheap, sticky deposits with room to lend more of them

  • The point: Nu funds itself with retail deposits at below-market cost and lends out only a fraction of them. Shifting deposits from government bonds into higher-yield loans is a built-in margin lever.
  • Evidence:
    • Deposits are $45.3B (+18% a year), all gathered directly, with no brokers [1,2].
    • Cost of deposits is 88% of the interbank rate, 3 percentage points lower than a year earlier [2].
    • The loan-to-deposit ratio was 58% in Q1-2026 (49% in Q4-25), and Mexico's is 35% [2,5].
    • Vélez describes growth as "reallocating…deposits that…are earning CDI…towards a much higher-yielding asset" [6].
  • Why it matters: it funds about 37% loan growth without wholesale borrowing. In a stress scenario, Nu is not dependent on capital markets.
  • 😈 Devil's advocate:
    • Float is 34% of gross profit [4] and shrinks as the Selic falls. It has been cut five times, from 15% to 13.75%, and the Focus survey sees 12% by end-2027 [31].
    • Deposits are high-yield savings balances that can leave if a rival pays more. The FGC top-up after the 2026 bank failures shows depositor confidence in Brazil's mid-sized institutions can wobble [1].
  • Verdict: Medium Strong. A real funding edge, but part of today's profit is a high-interest-rate gift that will fade.

🐂 Bull #4Mexico is becoming a second engine

  • The point: Mexico is less banked than Brazil, Nu is already its largest digital bank, and the new bank licence unlocks salary deposits.
  • Evidence:
    • 16M customers by July 2026, covering 16.5% of Mexican adults [2].
    • Breakeven in Q1-2026, after 6 years versus 8 in Brazil [5,6].
    • Mexico ARPAC is $12.3, against $5.6 for Brazil at the same stage [2].
    • The bank licence was authorised around 2026-07-09 and the bank began operating 2026-08-06 [12,60]. Management says it can now take salary direct deposits and offer higher deposit insurance [6].
    • Credit-card penetration is only about 11–14% of Mexican adults, against about 43% in Brazil [1].
  • Why it matters: Mexico could add a second profit pool. Management's base case is 60–70% of Brazil's size [6]. Nu says it holds less than 1% of Mexico's $40B+ profit pool [7].
  • 😈 Devil's advocate:
    • Mexico is much more competitive for digital banks than Brazil was in 2014: Mercado Pago, Revolut, Openbank, Klar, Stori, Plata and BBVA's strong app [56].
    • Mexican consumers are cash-heavy and borrow less. Banxico rates stay high at 6.50% [59].
    • Nu does not disclose Mexican late-loan rates. A 2025 Euromoney piece put Mexico NPLs near 7% with average customer income of about $5,200 [55].
    • Deposits fell slightly "by design" in Q2, and the loan-to-deposit ratio of 35% shows lending is still cautious [2].
  • Verdict: Medium The trajectory is good, but profitability is new and credit data is opaque.

🐂 Bull #5Underwriting and data advantage, now AI-driven

  • The point: Nu sees each customer's salary, spending and Pix flows, and uses that data to price credit better than rivals.
  • Evidence:
    • NuFormer is in production in card and personal-loan underwriting [2].
    • Card 90+ late rates improved in every income band since July 2025 while peers worsened (company claim) [2].
    • Primary-bank customers default at about half the average rate [6].
    • Loan-loss reserves are 244% of 90+ day late balances [6]. In Nu's own downside macro scenario, reserves would rise only about 9% from base, from $6.56B to $7.15B [3].
  • Why it matters: better underwriting means Nu can say "yes" to more customers at the same loss rate. That compounds Bulls #1 and #2.
  • 😈 Devil's advocate:
    • Most of this evidence is Nu's own presentation, and the consolidated 90+ ratio is still rising (6.5% to 6.9%) because the mix shifts to riskier products [2,6].
    • The models were trained in a period without a full Brazilian consumer-credit bust after 2016. The 90+ ratio peaked at 7.0% in Q3-2024 [5].
    • Other lenders also use Pix and open-finance data.
  • Verdict: Medium Plausible and partly measurable, but not yet proven through a cycle.

🐂 Bull #6Strong capital generation and returns to shareholders

  • The point: Nu now earns more than $1B a quarter at a 33% return on equity and has more capital than it needs.
  • Evidence:
    • Q2-2026 net income was $1,061M (+67% a year) [2,4].
    • Equity is $13.25B [3].
    • A $1.0B buyback was justified by "significant excess capital", and about half was executed in its first four weeks [3,16].
    • Nu says on its managerial basis that it funds growth internally [4].
  • Why it matters: returns can go back to shareholders while the company still grows 30%+.
  • 😈 Devil's advocate:
    • High return on equity partly reflects an unlevered balance sheet earning 13–15% Brazilian rates.
    • The 28-September Monzo report showed management might deploy capital on large deals instead. The stock fell 8–10% before Nu denied it [17,18].
    • The IFRS tax rate was unusually low (8.7% in Q1, guided 15–20%), which flatters earnings [7].
  • Verdict: Medium The returns are real, but capital allocation needs watching.

🐂 Bull #7Founder-led team with a record of delivering, and deep regulatory know-how

  • The point: the team that built Nu still runs it, has met most targets, and added a former central-bank president and a Capital One/Visa finance chief.
  • Evidence:
    • Promises kept on efficiency, Mexico breakeven, Mexico licence and margin recovery (section 1) [2,5,6,12].
    • Campos Neto heads public policy [1].
    • Livingston brings US card-lending experience [20].
  • Why it matters: in a business where regulation sets the rules, insider regulatory knowledge and a credible finance chief lower execution risk, especially for the US.
  • 😈 Devil's advocate:
    • The CFO change surprised the market; BofA called it a "negative surprise" and downgraded [23].
    • Vélez's 74% voting control means outside investors cannot check him.
    • Campos Neto's links to the previous Bolsonaro-appointed era could cut both ways politically.
  • Verdict: Medium

🐂 Bull #8The US is a cheap call option

  • The point: the US launch costs little and could become large if it works.
  • Evidence:
    • Management caps US spend at less than 100 bp of the group efficiency ratio in 2026 and 2027 [7].
    • The launch went live on 2026-09-10 with a 3.50% savings account, a cashback card and stablecoin accounts [14].
    • A Citi bull case reportedly sized a US business at $21B by 2030 [53]. That comes via Yahoo and the original note was not read.
  • Why it matters: it is upside without much downside, if the cap holds.
  • 😈 Devil's advocate:
    • US digital banking is saturated: Chime, SoFi, Revolut, Cash App, and big banks.
    • Nu has no US credit data and needs 12–30 months to build models [6].
    • Its Latin American advantage (an oligopoly of expensive incumbents) does not exist in the US.
  • Verdict: Weak as a value driver today; mainly matters if the cap is breached.

Bear case — all negative points (most important first)

🐻 Bear #1An almost-all-unsecured loan book entering a softer Brazilian credit cycle

  • The point: Nu's loans are mostly credit cards and personal loans with no collateral, to mass-market Brazilians. If household finances weaken, losses rise fast and the margin gains reverse.
  • Evidence:
    • Cards and unsecured loans make up about 92% of the $39.4B book [2]. Citi puts unsecured at about 96% [21].
    • Cards and unsecured were 98% of new credit exposure in Q1-2026, against 88% a year earlier [7].
    • 90+ day late loans rose to 6.9% in Q2-2026, from 6.5% in both Q1 and a year earlier [2].
    • The CFO said the two-year uptrend is "driven by the mix"; a Safra analyst replied "the problem…is the change in mix" [6].
    • Management added 24 bp of "intentional risk expansion" to the shorter 15–90 day late ratio in Q2 [6].
    • Brazilian household delinquency rose from 4.58% (June) to 5.04% (August). Household debt-to-income is near 50% [31].
    • Private payroll loans hit a record 8.6% default rate in June [35].
    • Citi's June downgrade: private payroll loans are deducted from salary first, so card and personal loans are "effectively subordinated". About 9% of Nu's credit customers already have payroll debt elsewhere. Citi cut its sustainable return on equity from 30% to 25% [21,22].
  • Why it matters:
    • Credit losses ("cost of credit", $1.69B in Q2) are Nu's largest cost [4].
    • A few points of extra losses on a $39B book wipe out a large share of the $4B+ annual profit. In the 2024 cycle, the 90+ ratio reached 7.0% [5].
  • 🛡️ Counter-argument:
    • Nu has over-reserved: reserves are 244% of 90+ balances [6].
    • Its downside scenario adds only about 9% to reserves [3].
    • Card delinquency by income band has improved since July 2025 while peers deteriorated (company data) [2].
    • Primary customers default at half the average rate [6].
    • The Selic is falling, which eases borrowers' burden [31].
    • Nu prices for risk: the 12.4% risk-adjusted margin is after losses.
  • Severity: High Even after the counter-argument, this is the variable that most moves earnings, and the mix is moving the wrong way.

🐻 Bear #2Concentrated in Brazil: politics, currency and rates

  • The point: almost all profit is earned in Brazilian reais and reported in dollars. The stock trades like a leveraged Brazil instrument.
  • Evidence:
    • Brazil is about 91% of the interest and fee lines [1].
    • The 2026-10-04 first round gave Flávio Bolsonaro 47.0% against Lula 45.1%; the runoff is 2026-10-25 [29].
    • On 2026-10-05 NU rose about 12–13% to roughly $15.1–15.3 as Brazilian assets rallied, after a 24% run in the prior five sessions [27,28].
    • Investors reportedly put a Flávio win above 80% [29].
    • The 20-F now names the October 2026 election as a volatility risk [1].
    • The US imposed a 25% Section 301 tariff on most Brazilian imports from 2026-07-22. The 301 probe also targets Pix [51].
  • Why it matters: a weaker real cuts dollar earnings one-for-one. A fiscal scare raises Brazilian rates, which pushes up defaults and Nu's funding cost on the credit side. Policy shifts (rate caps, taxes) arrive with elections.
  • 🛡️ Counter-argument:
    • Mexico and Colombia diversify slowly.
    • Nu has grown through Lula, Bolsonaro and the COVID shock.
    • Its funding is local-currency deposits, so there is no currency mismatch on the balance sheet; the hit is translation only.
    • The market already prices a likely Flávio win.
  • Severity: Medium High. Translation and sentiment swings are unavoidable. The election result, either way, is a near-term swing factor.

🐻 Bear #3A rising tax and regulatory take on Brazilian fintechs

  • The point: Brazil is closing the tax gap between fintechs and banks. Nu's new bank licence and the 2027 consumption-tax reform could raise its tax bill further.
  • Evidence:
    • Revenue-based taxes in Nu's managerial accounts rose to $240.9M in Q2-2026 from $111.4M (+116%), while revenue grew about 56% [4]. The filing gives no explanation [2].
    • Complementary Law 224 raised CSLL (a federal tax on profits) for payment institutions from 9% to 12% from April 2026, and to 15% from 2028. Banks stay at 20%; credit-finance companies (SCFIs) go to about 17.5–20% [33].
    • Vélez has said Nu pays "much more than many of the big financial institutions" and proposed a 17.5% minimum effective rate for everyone [34].
    • The Q2 financial statements say tax reform moves financial services to the new IBS/CBS consumption taxes from 2027-01-01, at about 10.85% initially and rising to 12.5% by 2033. Nu says the impact is "still under assessment" [3].
    • Management guides the managerial tax rate at 30–35%; Q2 was about 35% [4,7].
    • Nu paid the $186.4M FGC top-up in March 2026 [1].
  • Why it matters: each percentage point of extra tax cuts net income directly. Brazil has a pattern of raising financial-sector taxes when it needs revenue (IOF changes in 2025).
  • 🛡️ Counter-argument:
    • Banks already pay more, so the "level playing field" also removes a political target.
    • Nu says the bank licence brings no extra capital needs [10].
    • The Q1 IFRS tax rate of 8.7% reflected "structural changes" to Nu's corporate structure that the CFO called "not a one-off" [7].
    • A Flávio Bolsonaro government campaigns on lower taxes, though no promise specific to fintechs was found [29].
  • Severity: Medium Slow-moving but almost certainly negative, and the 2027 IBS/CBS hit is unquantified.

🐻 Bear #4Today's margin is partly flattered: one-offs, high rates and a peak

  • The point: the jump in risk-adjusted margin from 9.5% to 12.4% in Q2 included temporary help, and consensus already assumes it lasts.
  • Evidence:
    • Desenrola (a government debt-renegotiation program Nu joined in May 2026) explained about one third of the margin beat versus guidance and about 5% of cost of credit. Most of the benefit came in Q2, with some in Q3 [6,48].
    • The CFO says 12% "is not a floor" [6].
    • Consensus EPS of about $0.85 for 2026 and $1.11 for 2027 (about 30% growth) assumes margins roughly hold [53].
    • Itaú BBA downgraded to market perform with an $18 target (date not confirmed, about September 2026). It cut its 2027 profit estimate 8%, to 15% below consensus [24].
    • Float income depends on a 13.75% Selic that is falling [31].
  • Why it matters: if margin drifts back toward about 10–11% as Desenrola fades and rates fall, 2027 growth undershoots consensus.
  • 🛡️ Counter-argument:
    • Management says about two-thirds of the Q2 beat was underlying performance and balance growth [6].
    • Lower rates also cut funding cost on the credit book and lower defaults.
    • A rising loan-to-deposit ratio shifts assets from about 14% government paper into card and loan yields far above that [6].
  • Severity: Medium

🐻 Bear #5Competition intensifies where Nu wants to grow next

  • The point: Nu's next growth areas (payroll loans, high income, small business, Mexico) are crowded, and some rivals have structural advantages there.
  • Evidence:
    • Itaú BBA argues Mercado Livre's credit, which starts at checkout and draws on seller cash-flow data, is "structurally stronger than any Brazilian digital bank" [37].
    • Mercado Livre issued about 3M new cards in Q4-25, though its card book still loses money [37].
    • PicPay (now listed) doubled its loan book to R$31.9B in Q2-26 and has more than 3.6M private-payroll contracts [39].
    • Nu's private-payroll share was only about 1% (Morgan Stanley via Bloomberg Línea) [36]. Management says it will take 18–24 months to lead there [9].
    • TikTok/ByteDance applied for Brazilian payment and lending licences in March 2026 [50].
    • In Mexico, Revolut and Plata have bank licences and Klar is buying Banorte's Bineo [56].
  • Why it matters: Nu's "sell more to existing customers" plan (Bull #2) relies on winning these products.
  • 🛡️ Counter-argument:
    • Nu has the largest base, the lowest cost, and is primary bank for most of its customers.
    • Mercado Pago said a Brazilian bank licence is "not a priority" [38].
    • Rivals' growth comes with worse credit: PicPay's 90+ is 9.8% against Nu's 6.9% [39].
    • In payroll loans, being slow avoided the worst early defaults [6].
  • Severity: Medium

🐻 Bear #6Legal and political pressure on card pricing

  • The point: Brazilian card interest is among the highest in the world, a constant political target, and Nu is the biggest card brand.
  • Evidence:
    • In 2026 the Federal District government filed a public civil action against Nu over revolving-card charges, triggered by a debt that grew about 65-fold. It asks for refunds, recalculation and R$10M in collective damages. In July the court gave Nu 15 days to respond, with no injunction yet [40,41].
    • The government introduced a reference-rate regime for private payroll loans in April 2026 and a 1.99%-a-month cap on FGTS-backed payroll loans [35].
    • Vélez warned on the Q1 call that a pricing cap "is going to hurt more the players that were too fast" [7].
  • Why it matters: a broader cap, or limits on interest-free instalments ("parcelado sem juros", which drive card spending) would hit Nu's largest product. No 2026 rule on either was found.
  • 🛡️ Counter-argument:
    • The 100% cap on revolving charges is already in force since 2024, and Nu has adapted [40].
    • A single state lawsuit with an R$10M damages claim is immaterial unless copied nationally.
    • A right-leaning Congress (276 of 513 seats) lowers the odds of new caps [30].
  • Severity: Low Medium.

🐻 Bear #7Governance and capital-allocation risk under a controlling founder

  • The point: one man controls the votes, and 2026 showed management could surprise investors.
  • Evidence:
    • Vélez holds 74.4% of the votes [1].
    • In 2026 there were three surprises:
      • The CFO change, announced 2026-06-01 [20]. BofA cut the stock to Underperform with a $10 target and Santander removed it from its top picks [23].
      • Nu was reported in talks to buy Monzo for £8–10B, likely in cash and stock. The stock fell 8–10% before Nu said on 2026-09-30 that it was "not pursuing" a deal [17,18].
      • A later FT report (secondary) said talks broke down over price [18].
    • Insiders have made no open-market purchases in 2026:
      • Director Anita Sands sold 21,000 shares at $12.24 in May [45].
      • Junqueira sold about $1.3M under a 10b5-1 plan in August [44].
      • Vélez's July disposals were tax withholding on vesting shares [43].
      • Vélez sold about $404M in 2024 and $435M in 2025 for "estate planning" [47].
      • Berkshire Hathaway exited in Q1-2025 [46].
    • Since 2026-03-18 Nu's insiders file US Form 4s under the new Holding Foreign Insiders Accountable Act, so these trades are now visible [42].
  • Why it matters: an empire-building deal or a US cost overrun could destroy value, and outside shareholders cannot block it.
  • 🛡️ Counter-argument:
    • The Monzo denial came within days, which suggests shareholder pushback works.
    • Insider sales are small relative to holdings.
    • The buyback is a shareholder-friendly signal.
    • Vélez's track record (building a $70B+ company from scratch) earns some trust.
  • Severity: Medium Low.

🐻 Bear #8Brazil's customer pool is close to saturated

  • The point: with 62% of Brazilian adults signed up, customer growth must slow.
  • Evidence:
    • Vélez: "At some point, we're going to run out of Brazilian customers. We have been saying that for about 4 years" [6].
    • Nu still adds about 1M customers a month [6].
  • Why it matters: future growth has to come from ARPAC and new countries, which are both harder.
  • 🛡️ Counter-argument: this is a long-known, priced-in fact. ARPAC growth (+37% in a year) already does the work [2].
  • Severity: Low

Tailwinds NOT in the forecasts

  • Mexico bank licence turns into a salary-account and lending engine — 35% chance within 36 months · Impact if it happens: High

    • What it is: with bank status, Nu Mexico can take salary deposits, which deepens engagement and lets it lend more of its $5.7B in Mexican deposits. The loan-to-deposit ratio is only 35% [2]. A Mexican payroll-portability rule becomes mandatory in June 2027 [1].
    • Why it's not priced in: Mexico broke even only in Q1-2026 and is still less than 10% of revenue [1]. Consensus treats it mainly as customer growth, not as a profit pool.
    • What would trigger it / the sign to watch: Mexico disclosed separately with profits; Mexico loan-to-deposit ratio rising above 50%; salary-account numbers at the 2026-12-08 Investor Day.
    • Why this probability: the licence is in hand and ARPAC is ahead of Brazil's curve, but Mexico's competition and cash culture make a fast credit ramp less than even odds.

  • Leadership in private payroll and secured lending lowers credit risk while raising ARPAC — 30% chance · Impact: Medium

    • What it is: Nu says it will be a leading private-payroll lender within 18–24 months [9]. A larger secured book would offset Citi's subordination argument (Bear #1).
    • Why it's not priced in: analysts focus on Nu's roughly 1% share and its caution [36].
    • What would trigger it / the sign to watch: secured lending rising from about 8% toward 15%+ of the book; Nu disclosing its payroll share.
    • Why this probability: the market is capped and crowded and defaults are at records [35], but Nu's cost edge fits a price-capped product.

  • AI productivity keeps the efficiency ratio well below 20% as revenue grows — 40% chance · Impact: Medium

    • What it is: management talks of "2x–5x" AI productivity gains over several years with flat headcount [6].
    • Why it's not priced in: management guides about 20% for 2026 including US costs, so consensus models a flat ratio.
    • What would trigger it / the sign to watch: headcount flat or falling while revenue grows 30%+; efficiency ratio below 18% in 2027.
    • Why this probability: the core efficiency ratio was already 16.6% in Q1-26 [7], but US, Mexico-bank and tax costs push the other way.

  • Larger capital returns — 45% chance · Impact: Low–Medium

    • What it is: a second, larger buyback or a first dividend once the $1B program ends (June 2027).
    • Why it's not priced in: consensus models earnings, not capital returns; the buyback's per-share effect is about 1–2%.
    • What would trigger it / the sign to watch: Investor Day capital framework (2026-12-08) [19].
    • Why this probability: excess capital is stated [16], but the Monzo episode shows management also considers acquisitions.

  • US success — 10% chance of a meaningful US business (more than 5M accounts or a profitable credit book) · Impact: High

    • What it is: the US charter is approved and the Lead Bank launch takes off.
    • Why it's not priced in: management itself calls it a capped "call option" [7].
    • What would trigger it / the sign to watch: FDIC and Fed approval of Nubank N.A.; US account numbers disclosed.
    • Why this probability: US fintech graveyards are full of foreign entrants. Nu has no data edge there.

Headwinds NOT in the forecasts

  • Brazilian consumer-credit downturn in 2027 — 30% chance · Impact: High

    • What it is: rising household delinquency, record private-payroll defaults and payroll loans ranking ahead of cards push Nu's 90+ ratio above 8% (it was 6.9% in Q2).
    • Why it's not priced in: consensus assumes margin holds near 12% and about 30% EPS growth in 2027 [53].
    • What would trigger it / the sign to watch: BCB household delinquency above 5.5%; Nu's 15–90 ratio rising year on year in Q3/Q4-26; reserve builds above loan growth.
    • Why this probability: delinquency is already rising [31], but falling rates and Nu's reserve cushion make a sharp turn less likely than not.

  • Tax take rises: IBS/CBS from 2027, CSLL step-up in 2028, bank-licence effects — 50% chance that Nu's effective managerial tax burden rises by more than 2 percentage points by 2028 · Impact: Medium

    • What it is: the new consumption tax on financial services and the higher CSLL brackets [3,33].
    • Why it's not priced in: Nu says the impact is "under assessment" and gives no number, so analysts can't model it [3].
    • What would trigger it / the sign to watch: IBS/CBS regulations for financial services; Nu's 2027 tax guidance at Investor Day.
    • Why this probability: the laws are passed, so some hit is near-certain. The size is genuinely uncertain because of structuring and offsets.

  • Margin slips back as Desenrola fades and Selic falls — 35% chance of a risk-adjusted margin below 11% in any quarter of 2027 · Impact: Medium

    • What it is: the reversal of Bear #4.
    • Why it's not priced in: consensus extrapolates Q2-26 [53].
    • What would trigger it / the sign to watch: Q3-26 margin (results ~2026-11-12); Desenrola benefit called out as gone.
    • Why this probability: two-thirds of the beat is underlying, and lower funding costs partly offset lower float income.

  • Large acquisition — 20% chance of a deal above $3B within 36 months · Impact: Medium

    • What it is: a Monzo-style purchase outside Latin America.
    • Why it's not priced in: Nu says its framework is "unchanged" [17].
    • What would trigger it / the sign to watch: press reports; Investor Day comments on M&A.
    • Why this probability: the Monzo talks show appetite, and the denial plus the share-price punishment show restraint.

  • Election-driven or court-driven card pricing limits — 15% chance of a binding new rule on card rates or interest-free instalments · Impact: Medium–High

    • What it is: national rate caps or limits on "parcelado sem juros"; the Federal District lawsuit copied by other states.
    • Why it's not priced in: no draft rule exists in 2026 [40].
    • What would trigger it / the sign to watch: a Lula win plus a populist credit agenda; an injunction in the Federal District case.
    • Why this probability: there is a long political history of threats, but the 2024 cap shows Brazil prefers partial measures, and the new Congress leans right.

Investment Risk Score: 44/100

Risk area Weight Score (0–100) Why
Business & competition 25% 38 Clear cost leader with a decade-long moat in Brazil. Mercado Pago, PicPay and incumbents are pushing into Nu's next growth products, and Mexico is far more contested.
Financial health & dilution 20% 32 Unlevered, deposit-funded, 33% ROE, buying back stock. The only drag is an unsecured book with a rising 90+ ratio.
Execution (delivering the plan) 20% 45 Many moving parts at once: a new CFO, the Brazil bank licence, the Mexico bank launch, the US launch, payroll lending and AI rebuilds. Track record so far is good.
Dependency & concentration (customers, suppliers, commodities, key people) 15% 55 About 91% of revenue from one country and currency, a founder with 74% of the votes, dependence on Pix and BCB rules. No customer concentration.
Regulation, policy & geopolitics 10% 60 Tax rises already legislated (CSLL, IBS/CBS), card-rate politics, the bank-name rule, the election runoff and US–Brazil trade tension.
Sentiment & expectations (how much good news the market already expects) 10% 45 About 12.6x forward earnings is undemanding for 40% growth, but consensus assumes Q2's peak margin holds. The rating mix is strongly Buy, and Itaú BBA warns of "limited upside".

Overall = 0.25×38 + 0.20×32 + 0.20×45 + 0.15×55 + 0.10×60 + 0.10×45 = 43.7 → 44 (moderate).

  • Why moderate: Nu is financially strong and has a durable cost edge, which keeps it out of "high" risk.
  • What pulls it up: concentration in one emerging-market country, a mostly unsecured loan book late in a credit up-cycle, and a rising tax and political take.
  • First dive: there is no prior score to compare against.

Conclusion

  • What kind of company this is: a high-return, fast-growing consumer lender and deposit gatherer, wrapped in a technology company's cost structure. It sells mainly to Brazil's mass market.
    • What you are really betting on: Nu's cost and data edge keeps losses manageable while it sells more products per customer and repeats the playbook in Mexico.
    • You are also betting that Brazilian politics, rates and the real do not take away the returns.
  • The 2–3 things that will decide the outcome:
    1. Credit losses through 2027. Does the 90+ ratio stabilise below about 7% as the book shifts toward unsecured cards and loans?
    2. Mexico's second act. Does the new bank win salary accounts and lending at Brazil-like returns?
    3. Brazil's policy environment. That means the runoff result, the tax burden from 2027, and any card-pricing rules.
  • Signposts:
    • Confirm the bull case:
      • 90+ late ratio flat or falling year on year in Q3/Q4-26 while the book still grows above 30%.
      • Risk-adjusted margin holding at or above about 12% after Desenrola fades.
      • Mexico shown with its own profit and a rising loan-to-deposit ratio at the Investor Day (2026-12-08).
      • Secured lending's share of the book rising.
    • Break the bull case:
      • BCB household delinquency above 5.5% and Nu's 90+ ratio above 7.5%.
      • A quantified 2027 tax hit of more than 3 points on the managerial tax rate.
      • US spend breaching the 100 bp cap, or a large acquisition announced.
      • A new national cap on card rates or instalments.
  • Balanced verdict:
    • Bull side: the strongest bull view is that Nu has built Latin America's lowest-cost bank. It is the main account for most of its 118M Brazilian customers, earns a third of its equity each year, and still has a long ARPAC runway and a second country turning profitable. At about 12–13x forward earnings, the market is not paying much for that.
    • Bear side: the strongest bear view is that those returns rest on unsecured lending to Brazil's mass market at Brazilian interest rates. Management is deliberately taking more risk, payroll loans now rank ahead of cards, rates are falling (which shrinks float income), and the state is raising taxes.
    • Where the evidence leans: the business quality is clearly high. The Q2-2026 numbers were helped by one-offs. The 90+ ratio is the number to watch. The evidence leans toward the business edge being durable, and the near-term earnings path being more exposed to Brazil's credit cycle and politics than consensus implies.

Open questions & data gaps

  • Revenue-based taxes: what explains the jump from $111.4M to $240.9M (+116%) in Q2-26? This is not explained in filings [4]. It matters for the tax-trajectory headwind.
  • Credit split: NPLs by country (especially Mexico) and by product (personal loans versus cards versus payroll) are not disclosed in the releases. The consolidated series changed definition in Q4-25. This matters a lot for Bear #1.
  • Payroll lending: the private-payroll balance and Nu's market share are not disclosed (Morgan Stanley's "about 1%" is second-hand) [36].
  • Brazil bank licence:
    • The Banco Porto Real price and BCB approval timing are not found.
    • Which CSLL bracket each Nu entity falls into after the licence is not found.
  • Q4-25 and Q3-25 calls: only AI-generated summaries were read [8].
  • Price snapshots: current price is only approximate, about $15.1–15.3 after 2026-10-05 [27,52]. Some aggregator price data conflict.
  • Unconfirmed or dated sources:
    • The Itaú BBA downgrade date is unconfirmed (about September 2026) [24].
    • The Goldman $23 target and the Citi $21B US sizing come from single secondary sources and were not used as evidence.
  • Macro data: the BCB series labels for card delinquency were not verified, and only household-level delinquency was used. The Focus survey predates the first round.
  • Vélez–OpenAI board seat: not confirmed by a filing.
Sources
  1. Nu Holdings Form 20-F for FY2025 — SEC EDGAR — 2026-04-08 — https://www.sec.gov/Archives/edgar/data/1691493/000129281426002166/nuform20f_2025.htm
  2. Nu Holdings Ltd. Reports Second Quarter 2026 Financial Results (Form 6-K) — Nu Holdings / SEC — 2026-08-13 — https://www.sec.gov/Archives/edgar/data/0001691493/000129281426004222/nupr2q26_6k.htm
  3. Nu Holdings Q2 2026 interim financial statements (Form 6-K) — Nu Holdings / SEC — 2026-08-13 — https://www.sec.gov/Archives/edgar/data/0001691493/000129281426004225/nufs2q26_6k.htm
  4. Managerial P&L and KPMG limited-assurance report (Form 6-K) — Nu Holdings / SEC — 2026-08-13 — https://www.sec.gov/Archives/edgar/data/1691493/000129281426004228/nu20260813_6k1.htm
  5. Nu Holdings Ltd. Reports First Quarter 2026 Financial Results — Nu Holdings — 2026-05-14 — https://www.businesswire.com/news/home/20260514553909/en/Nu-Holdings-Ltd.-Reports-First-Quarter-2026-Financial-Results
  6. Nu (NU) Q2 2026 Earnings Call Transcript — The Motley Fool — 2026-08-20 (call 2026-08-13) — https://www.fool.com/earnings/call-transcripts/2026/08/20/nu-nu-q2-2026-earnings-call-transcript/
  7. Nu (NU) Q1 2026 Earnings Call Transcript — The Motley Fool — 2026-05-15 — https://www.fool.com/earnings/call-transcripts/2026/05/15/nu-nu-q1-2026-earnings-call-transcript/
  8. Earnings call transcript: Nu Holdings Q4 2025 (AI summary) — Investing.com — 2026-02-26 — https://www.investing.com/news/transcripts/earnings-call-transcript-nu-holdings-q4-2025-revenue-beats-expectations-93CH-4526241
  9. Earnings call transcript: Nubank tops $1 billion in Q2 2026 net income — Investing.com — 2026-08-13 — https://www.investing.com/news/transcripts/earnings-call-transcript-nubank-tops-1-billion-in-q2-2026-net-income-93CH-4859540
  10. Form 6-K: agreement to acquire Banco Porto Real de Investimentos — Nu Holdings / SEC — 2026-07-20 — https://www.sec.gov/Archives/edgar/data/1691493/000129281426003814/nu20260720_6k.htm
  11. Nubank secures new banking licence in Brazil through Banco Porto Real acquisition — FinTech Futures — 2026-07 — https://www.fintechfutures.com/m-a/nubank-to-acquire-banco-porto-real
  12. Form 6-K: Mexico banking operating authorisation — Nu Holdings / SEC — 2026-07-10 — https://www.sec.gov/Archives/edgar/data/1691493/000129281426003723/nu20260710_6k.htm
  13. Nu Receives Full Banking License in Mexico — Finovate — 2026-07-10 — https://finovate.com/nu-receives-full-banking-license-in-mexico/
  14. Form 6-K: US launch and Nu Global — Nu Holdings / SEC — 2026-09-10 — https://www.sec.gov/Archives/edgar/data/1691493/000129281426004518/nu20260909_6k.htm
  15. Nu secures approval to establish US national bank — Nu newsroom — 2026-01-29 — https://www.nu.com/en/newsroom/company/nu-secures-approval-to-establish-us-national-bank
  16. Form 6-K: US$1.0 billion share repurchase program — Nu Holdings / SEC — 2026-06-04 — https://www.sec.gov/Archives/edgar/data/0001691493/000129281426003326/nu20260604_6k.htm
  17. Form 6-K: Statement on media reports (Monzo) — Nu Holdings / SEC — 2026-09-30 — https://www.sec.gov/Archives/edgar/data/1691493/000129281426004752/nu20260930_6k.htm
  18. Nubank diz que não busca compra do britânico Monzo após relatos de negócio de até £10 bi — Bloomberg Línea — 2026-09-30 — https://www.bloomberglinea.com.br/2026/09/30/nubank-diz-que-nao-busca-compra-do-britanico-monzo-apos-relatos-de-negocio-de-ate-10-bi/ ; Nubank says it is not pursuing Monzo takeover after shares plunge — City AM — 2026-09-30 — https://www.cityam.com/?p=2462260
  19. Form 6-K: Investor Day 2026-12-08 — Nu Holdings / SEC — 2026-09-02 — https://www.sec.gov/Archives/edgar/data/1691493/000129281426004456/nu20260831_6k.htm
  20. Nubank Appoints Rob Livingston as Chief Financial Officer — Business Wire — 2026-06-01 — https://www.businesswire.com/news/home/20260601015786/en/Nubank-Appoints-Rob-Livingston-as-Chief-Financial-Officer
  21. O risco que levou o Citi a rebaixar o Nubank — Forbes Brasil — 2026-06 — https://forbes.com.br/forbes-money/2026/06/o-risco-que-levou-o-citi-a-rebaixar-o-nubank/
  22. Após BofA, Citi rebaixa Nubank por risco na carteira de crédito — NeoFeed — 2026-06 — https://neofeed.com.br/negocios/apos-bofa-citi-rebaixa-nubank-por-risco-na-carteira-de-credito/
  23. Nubank (ROXO34): Bank of America rebaixa recomendação para venda — Acionista — 2026-06 — https://acionista.com.br/nubank-roxo34-bank-of-america-rebaixa-recomendacao-para-venda/
  24. Nubank: Itaú BBA rebaixa recomendação e corta preço-alvo — Money Times — ~2026-09 (exact date not confirmed) — https://www.moneytimes.com.br/nubank-roxo34-itau-bba-rebaixa-recomendacao-e-corta-preco-alvo-para-as-acoes-qual-o-motivo-lils/
  25. Nu Holdings stock surges 9.5% after breaking $1 billion quarterly profit barrier — Parameter — 2026-08-14 — https://parameter.io/nu-holdings-nu-stock-surges-9-5-after-breaking-1-billion-quarterly-profit-barrier/
  26. Nubank Stock: Why Analysts Turned Bearish in 2026 — The Rio Times — 2026-06-15 — https://www.riotimesonline.com/nubank-stock-analyst-downgrades-credit-cycle-june-2026/
  27. Nu Holding shares up 13% after Bolsonaro outperformed polls — XTB — 2026-10-05 — https://www.xtb.com/en/market-analysis/nu-holding-shares-up-13-after-bolsonaro-outperformed-polls
  28. Nu Holdings Spikes 12% as Brazil Election Upset Drives Rally — 24/7 Wall St — 2026-10-05 — https://247wallst.com/investing/2026/10/05/nu-holdings-spikes-12-as-brazil-election-upset-drives-rally-in-brazilian-assets-robinhood-edges-higher-sofi-stays-put/
  29. Flávio Bolsonaro edges Lula in the first round, both head to October 25 runoff — MercoPress — 2026-10-05 — https://en.mercopress.com/2026/10/05/flavio-bolsonaro-edges-lula-in-the-first-round-both-head-to-an-october-25-runoff ; investor survey via Bloomberg Línea — 2026-10 — https://www.bloomberglinea.com.br/mercados/do-nubank-a-petrobras-veja-como-as-acoes-brasileiras-reagem-apos-as-eleicoes/
  30. Right-wing wave in Brazil's Congress boosts Bolsonaro camp ahead of presidential runoff — Reuters via The Star — 2026-10-05 — https://www.thestar.com.my/news/world/2026/10/05/right-wing-wave-in-brazil039s-congress-boosts-bolsonaro-camp-ahead-of-presidential-runoff
  31. SGS time series (Selic 432, USD/BRL 1, household debt 29037/29035, household delinquency 21082) and Focus survey — Banco Central do Brasil — data to 2026-10-08 — https://api.bcb.gov.br/dados/serie/bcdata.sgs.432/dados ; https://olinda.bcb.gov.br/olinda/servico/Expectativas/versao/v1/odata/ExpectativasMercadoAnuais
  32. Copom reduz Selic para 13,75% em decisão unânime — Atlas Público — 2026-09-16 — https://atlaspublico.com.br/bcb/noticias/copom-reduz-selic-para-13-75pct-ao-ano-em-decisao-unanime-87748
  33. Novo imposto para fintechs e financeiras passa a valer a partir de abril (LC 224) — Finsiders Brasil — 2026-03-20 — https://finsidersbrasil.com.br/noticias-sobre-fintechs/novo-imposto-para-fintechs-e-financeiras-passa-a-valer-a-partir-de-abril/
  34. CEO do Nubank cogita compra de banco para ter licença bancária — Poder360 — 2026 — https://www.poder360.com.br/poder-economia/ceo-do-nubank-cogita-compra-de-banco-para-ter-licenca-bancaria/
  35. Consignado privado: teto de juros e inadimplência — Let's Money / IstoÉ Dinheiro — 2026-04-27 and later — https://www.letsmoney.com.br/noticias/consignado-privado-recua-teto-juros/ ; https://istoedinheiro.com.br/governo-limites-juros-do-consignado-privado-nova-regra
  36. Mercado subestima potencial do Nubank em crédito consignado, diz Morgan Stanley — Bloomberg Línea — 2026 — https://www.bloomberglinea.com.br/negocios/mercado-subestima-potencial-do-nubank-em-credito-consignado-diz-morgan-stanley/
  37. Nubank domina crédito no Brasil, mas Mercado Livre deve virar o jogo (Itaú BBA) — Finsiders Brasil — 2026-03-17 — https://finsidersbrasil.com.br/credito-digital/nubank-domina-credito-no-brasil-mas-mercado-livre-deve-virar-o-jogo/
  38. Mercado Pago diz que licença bancária no Brasil não é prioridade — Finsiders Brasil — 2026-02 — https://finsidersbrasil.com.br/bancos-digitais/mercado-pago-diz-que-licenca-bancaria-no-brasil-nao-e-prioridade/
  39. PicPay 2T26 results coverage — InvesTalk (BB) — 2026-08 — https://investalk.bb.com.br/noticias/mercado/PICS2T26
  40. Juros do cartão Nubank: Justiça dá 15 dias para banco responder ação do GDF — Cartões e Viagens — 2026-07 — https://cartoeseviagens.com.br/juros-do-cartao-nubank
  41. Juros do cartão fazem dívida do Nubank disparar 65 vezes e expõem brecha do rotativo — Economic News Brasil — 2026-05-27 — https://economicnewsbrasil.com.br/2026/05/27/divida-do-nubank-juros-cartao-rotativo/
  42. US Congress eliminates foreign private issuer exemption for insider reporting obligations (Holding Foreign Insiders Accountable Act) — Cooley — 2026-02-25 — https://www.cooley.com/news/insight/2026/2026-02-25-us-congress-eliminates-foreign-private-issuer-exemption-for-insider-reporting-obligations-under-holding-foreign-insiders-accountable-act
  43. Form 4, David Vélez Osorno (2026-07-23) — SEC EDGAR — 2026-07 — https://www.sec.gov/Archives/edgar/data/0001691493/000095010326011220/ownership.xml
  44. Form 4, Cristina Junqueira (2026-08-24/25, 10b5-1 plan) — SEC EDGAR — 2026-08 — https://www.sec.gov/Archives/edgar/data/0001691493/000095010326012947/ownership.xml
  45. Director Sands, Anita M. sold $257,042 worth of Class A shares — Quantisnow — 2026-05 — https://quantisnow.com/insight/director-sands-anita-m-sold-257042-worth-of-class-a-6564040
  46. Warren Buffett ditches Nu Holdings — Benzinga — 2025-05 — https://www.benzinga.com/news/management/25/05/45455434/warren-buffett-ditches-bitcoin-linked-nu-holdings-adds-to-constellation-brands-dominos-pizza-pool
  47. David Vélez vendió 33 millones de acciones de Nu por US$435 millones — Forbes Colombia — 2025-08-19 — https://forbes.co/2025/08/19/editors-picks/david-velez-vendio-33-millones-de-acciones-de-nu-por-us435-millones
  48. Nubank confirms participation in Novo Desenrola Brasil — Nubank — 2026-05-05 — https://international.nubank.com.br/company/nubank-confirms-participation-in-novo-desenrola-brasil/
  49. Nu Colombia revoluciona Bre-B al permitir pagos con cupo de tarjeta de crédito — Descubre — 2026-07-27 — https://www.descubre.vc/noticia/nu-colombia-revoluciona-bre-b-al-permitir-pagos-con-cupo-de-tarjeta-de-cr-dito-2026-07-27
  50. TikTok quer entrar no mercado financeiro brasileiro — Olhar Digital — 2026-03-31 — https://olhardigital.com.br/2026/03/31/pro/tiktok-quer-entrar-no-mercado-financeiro-brasileiro-diz-agencia-de-noticias/
  51. Como estão as tarifas de Trump contra o Brasil hoje — Exame — 2026-07 — https://exame.com/mundo/como-estao-as-tarifas-de-trump-contra-o-brasil-hoje/
  52. NU weekly returns (close 2026-10-02: $13.43) — Chartrow — 2026-10 — https://chartrow.com/quote/nu/weekly-returns
  53. Is NU Stock a Buy or Hold After US Launch and Nu Global Debut? — Zacks via Yahoo Finance — 2026-09-14 — https://finance.yahoo.com/markets/stocks/articles/nu-stock-buy-hold-us-152200781.html
  54. NU Stock Slips Premarket: BofA Sees Trouble Ahead As Key Executive Hands Over The Reins — Yahoo Finance — 2026-06-02 — https://finance.yahoo.com/markets/stocks/articles/nu-stock-slips-premarket-bofa-081132046.html
  55. Are Mexico's digital disruptors blinking first? — Euromoney — 2025 — https://www.euromoney.com/article/2dmmmc959je0txa9ok1ds/opinion/are-mexicos-digital-disruptors-blinking-first/
  56. Mercado Pago, Konfío, Bunq esperan licencia bancaria tras aprobación de Nu — El CEO — 2025–2026 — https://elceo.com/negocios/mercado-pago-konfio-bunq-esperan-licencia-bancaria-tras-aprobacion-nu/
  57. Nubank cresce o dobro do mercado de cartões (BTG / Card Monitor) — Finsiders Brasil — 2026 — https://finsidersbrasil.com.br/pagamentos/cartoes/nubank-cresce-o-dobro-do-mercado-de-cartoes-e-os-bancoes-assistem-a-festa-pela-janela/
  58. Brazilian household debt hits 82% while delinquency eases — Agência Brasil — 2026-08 — https://agenciabrasil.ebc.com.br/en/economia/noticia/2026-08/brazilian-household-debt-hits-82-while-delinquency-eases
  59. Banxico mantiene tasa de interés en 6.50% — Por Esto — 2026-09-24 — https://www.poresto.com/mexico/2026/9/24/banxico-mantiene-tasa-de-interes-en-650-y-preve-que-inflacion-llegue-a-la-meta-hasta-finales-de-2027.html
  60. Nu Mexico to begin operating as a bank from 6 August — The Paypers — 2026-07/08 — https://thepaypers.com/fintech/news/nu-mexico-to-begin-operating-as-a-bank-from-6-august
  61. Nubank compra Banco CGD Brasil? — Let's Money — 2026-03-26 (updated 2026-09-12) — https://www.letsmoney.com.br/noticias/nubank-compra-banco-cgd-brasil-licenca-bancaria/
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Disclaimer. AI-generated research and podcast (Claude by Anthropic, voices by Google Gemini) for educational purposes — not financial advice and not a recommendation to buy or sell. Willem (MR.INVEST) owns this stock. Check the company’s own filings before making any decision.
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