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Twenty-First Tailored Solutions, Inc.
Client Brochure
This brochure provides information about the qualifications and business practices of Twenty-First Tailored
Solutions, Inc. If you have any questions about the contents of this brochure, please contact us at (914)589-6152
or by email at: rich@twenty-first.com. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission or by any state securities authority.
Additional information about Twenty-First Tailored Solutions, Inc. is also available on the SEC’s website at
www.adviserinfo.sec.gov. Twenty-First Tailored Solutions, Inc.’s CRD number is: 158381
143 Country Ridge Road
Scarsdale, New York, 10583
(914) 589-6152
rich@twenty-first.com
Registration does not imply a certain level of skill or training.
Version Date: 01/28/2026
Item 2: Material Changes
The material changes in this brochure from the last annual updating amendment of Twenty-First
Tailored Solutions, Inc. filed on 01/15/2025 is an update to the firm’s assets under management
(“AUM”). No other material changes have been made to the firm’s policies, practices, or conflicts of
interest.
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes .......................................................................................................................................................................................... 2
Item 3: Table of Contents .......................................................................................................................................................................................... 3
Item 4: Advisory Business ........................................................................................................................................................................................ 4
Item 5: Fees and Compensation ............................................................................................................................................................................... 5
Item 6: Performance-Based Fees and Side-By-Side Management ......................................................................................................................... 6
Item 7: Types of Clients ............................................................................................................................................................................................. 6
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ............................................................................................ 6
Item 9: Disciplinary Information .............................................................................................................................................................................. 7
Item 10: Other Financial Industry Activities and Affiliations ............................................................................................................................... 7
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................................................................... 8
Item 12: Brokerage Practices ..................................................................................................................................................................................... 8
Item 13: Reviews of Accounts................................................................................................................................................................................... 8
Item 14: Client Referrals and Other Compensation ............................................................................................................................................... 9
Item 15: Custody ........................................................................................................................................................................................................ 9
Item 16: Investment Discretion ................................................................................................................................................................................. 9
Item 17: Voting Client Securities (Proxy Voting) .................................................................................................................................................... 9
Item 18: Financial Information ............................................................................................................................................................................... 10
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Item 4: Advisory Business
A. Description of the Advisory Firm
Twenty-First Tailored Solutions, Inc. is a Corporation organized in the state of
New York.
Twenty-First Tailored Solutions, Inc. was formed in June 2011, and the principal
owner is Twenty-First Holdings, Inc. The Principal owners of Twenty-First
Holdings, Inc. are Alexandra Gordon and Evan Gordon.
B. Types of Advisory Services
Twenty-First Tailored Solutions, Inc. (hereinafter “TFTS”) no longer accepts new
clients and offers the following services to existing advisory clients:
Investment Services
TFTS provides ongoing investment strategy services and regular portfolio
monitoring services for its short against the box (SATB) portfolio of accounts.
C. Client Tailored Services and Client Imposed Restrictions
TFTS previously tailored a SATB strategy for each client. TFTS will make
recommendations to clients whether to close part or all of the box positions based on
material market, economic or political events, changes to the tax laws or changes in
client’s financial situation such as retirement, termination of employment, physical
move, death or inheritance. Clients then decide whether to close part or all of the box
positions.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated
fee that includes management fees, transaction costs, fund expenses, and any other
administrative fees. TFTS DOES NOT participate in any wrap fee programs.
E. Amounts Under Management
TFTS has the following assets under management:
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Discretionary Amounts:
Non-discretionary Amounts:
Date Calculated:
$0.00
$ 515,261,234
12/2025
Item 5: Fees and Compensation
A. Fee Schedule
Investment Services Fees
Total Assets Under Management
Annual Fee
All Assets Under Management
3.24 BPS – 47.5 BPS
(0.0324% – 0.475%)
These fees were negotiated with each client on a case by case basis at the time
each client account was established. The final fee schedule is described in the
Investment Advisory Contract.
B. Payment of Fees
Payment of Investment Supervisory Fees
Advisory fees are withdrawn directly from the client’s accounts with client written
authorization. Fees are paid monthly in arrears.
C. Clients Are Responsible For Third Party Fees
Clients are responsible for the payment of all third-party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by TFTS. Please see Item 12 of this
brochure regarding broker/custodian.
D. Prepayment of Fees
TFTS collects its fees in arrears and does not collect fees in advance.
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Item 6: Performance-Based Fees and Side-By-Side Management
TFTS does not accept performance-based fees or other fees based on a share of capital
gains on or capital appreciation of the assets of a client.
Item 7: Types of Clients
TFTS generally provides management supervisory services to the following types of clients:
• High-Net-Worth Individuals
• Corporations or Business Entities
• Advisors of High Net Worth Clients
• Trusts
Minimum Account Size
There is no account minimum.
Item 8: Method of Analysis, Investment Strategy, and Risk of
Investment Loss
A. Methods of Analysis and Investment Strategies
TFTS implemented the Short Against the Box Strategy for each client based upon the
goals of the client.
Investing in securities involves a risk of loss that you, as a client, should be
prepared to bear.
B. Material Risks Involved
The Short Against the Box Strategy involves the use of margin. If a margin call
cannot be met, then a portion of the Box may need to be closed which could result
in a capital gain to the account.
Past performance is not a guarantee of future returns. Investing in securities
involves a risk of loss that you, as a client, should be prepared to bear.
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Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SR) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Richard Ainsberg is a registered representative of Crito Capital LLC.
B. Registration as a Futures Commission Merchant, Commodity Pool
Operator, or a Commodity Trading Advisor
Neither TFTS nor its representatives are registered as or have pending applications
to become either a Futures Commission Merchant, Commodity Pool Operator, or
Commodity Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business and
Possible Conflicts of Interests
Clients should be aware that if they engage Mr. Ainsberg in his separate capacity as
a registered representative of a broker-dealer, then he will receive a commission from
the broker-dealer. This involves a conflict of interest, as commissionable products
can conflict with the fiduciary duties of a registered investment adviser. Clients are
in no way required to engage the separate brokerage services of Mr. Ainsberg in
order to receive advisory services from TFTS.
D. Selection of Other Advisors or Managers and How This Adviser is
Compensated for Those Selections
TFTS does not utilize nor select other advisors or third-party managers. All
assets are managed by TFTS management.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
We have a written Code of Ethics that covers the following areas: Prohibited
Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted
Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment,
Confidentiality, Service on a Board of Directors, Compliance Procedures,
Compliance with Laws and Regulations, Procedures and Reporting, Certification of
Compliance, Reporting Violations, Compliance Officer Duties, Training and
Education, Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is
available free upon request to any client or prospective client.
B. Recommendations Involving Material Financial Interests
TFTS does not recommend that clients buy or sell any security in which TFTS or a
related person to TFTS has a material financial interest.
Item 12: Brokerage Practices
The custodian, UBS Financial Services Inc., was chosen based on its relatively low
fees. TFTS will never charge a premium or commission on transactions, beyond the
actual cost imposed by Custodian.
Item 13: Reviews of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those
Reviews
Richard Ainsberg periodically reviews client accounts at intervals set forth in the
agreement with the client. This generally includes daily reviews related to margin
calls, confirmation of funds or securities sent to the custodian; monthly reviews
related to cash credits for short interest rebate, debits for interest expense, corporate
actions; and annual reviews and reports related to 1099 statements.
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B. Factors That Will Trigger a Non-Periodic Review of Client
Accounts
Other than periodic reviews may be triggered by material market, economic or
political events, or by changes in client's financial situations (such as retirement,
termination of employment, physical move, death, or inheritance).
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered
to Clients (Includes Sales Awards or Other Prizes)
TFTS does not receive any economic benefit, directly or indirectly from any third
party for advice rendered to TFTS clients.
B. Compensation to Non – Advisory Personnel for Client Referrals
TFTS does not directly or indirectly compensate any person who is not
advisory personnel for client referrals.
Item 15: Custody
TFTS, with client written authority, has limited custody of client’s assets because it directs
the custodian to deduct its advisory fee from the client’s account. Custody of all client assets
and holdings is maintained at UBS Financial Services Inc. Clients will receive statements
from UBS and they should carefully review those statements for accuracy. TFTS does not
provide account statements to clients in addition to those provided by UBS.
Item 16: Investment Discretion
TFTS does not accept discretionary authority to manage client accounts. TFTS solely provides
non-discretionary SATB investment advisory services to clients.
Item 17: Voting Client Securities (Proxy Voting)
TFTS will not ask for, nor accept voting authority for client securities. Clients will
receive proxies directly from the issuer of the security or the custodian. Clients should
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direct all proxy questions to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
TFTS does not require nor solicit prepayment of more than $1,200 in fees per client,
six months or more in advance and therefore does not need to include a balance
sheet with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet
Contractual Commitments to Clients
Neither TFTS nor its management have any financial conditions that are likely to
reasonably impair our ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
TFTS has not been the subject of a bankruptcy petition in the last ten years.
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