United States securities and exchange commission logo

                             October 28, 2020

       Alexandre Teixeira de Assump    o Saigh
       Chief Executive Officer
       Patria Investments Limited
       18 Forum Lane, 3rd floor,
       Camana Bay, PO Box 757, KY1-9006
       Grand Cayman, Cayman Islands

                                                        Re: Patria Investments
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted October
1, 2020
                                                            CIK No. 0001825570

       Dear Mr. Saigh:

              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

       Registration Statement on Form F-1 filed October 1, 2020

       Summary, page 3

   1.                                                   We note your references
to CAGR in several sections of the prospectus. Because CAGR
                                                        only represents two
discrete snapshots in time, but does not show trends or events during
                                                        the period presented,
please balance your disclosure by including the annual rate for each
                                                        of the periods
presented, or include a reference to where in the prospectus that
                                                        presentation can be
found. Also, please revise the disclosure regarding CAGR to include
                                                        balancing language
stating that there is no guarantee that you will achieve comparable
                                                        CAGR metrics in the
 Alexandre Teixeira de Assump    o Saigh
FirstName  LastNameAlexandre  Teixeira de Assump    o Saigh
Patria Investments Limited
October  28,NamePatria
             2020      Investments Limited
Page  2 28, 2020 Page 2
FirstName LastName
2.       We note references to third-party information and industry research
throughout the
         prospectus, beginning with your reference to the Brazilian Financial
and Capital Markets
         Association on page 5. Please advise us as to whether any of these
reports were
         commissioned or prepared for this filing. If any of these reports were
         specifically for this filing, please file a consent acknowledging the
use of the information
         in the prospectus.
3.       We note references in the Summary and throughout the filing to the
company as an
         industry leader. Please explain the basis for the assertion that the
company is an industry
Market Opportunity, page 5

4.       Please revise to update to a more recent practicable date some of the
data and reports
         discussed in this section, or advise. For instance we note a 2017
report discussed, data
         from 2018 and the growth of global AUM of secondary products from 2015
- 2018.
5.       Please revise the discussion of private versus capital investments at
the top of page 6 to
         provide context for the information and to explain how it pertains to
the company's
Risk Factors, page 21

6.       Please expand the risk factor on page 29 that addresses expansion into
additional Latin
         American geographical regions to explain whether any portion of the
proceeds will be
         used to fund this expansion. If so, please discuss the risks
associated with not being able
         to fund these goals and amend the Use of Proceeds section accordingly.
7.       Refer to the second risk factor on page 39. Please explain your
statement that "we will be
         subject to a number of actual and potential conflicts of interest and
subject to greater
         regulatory oversight and more legal and contractual restrictions than
that to which we
         would otherwise be subject if we had just one line of business." It is
unclear why
         additional lines of asset management business would result in
conflicts of interest. Please
         clarify this for investors.
If we were deemed an "investment company", page 51

8.       Please provide us with an analysis as to why you are not an investment
company as
         defined in the Investment Company Act of 1940 and any exemption you
rely upon.
         Please also expand your risk factor disclosure to explain why you do
not think you are
         Investment Company so that investors can assess the risk.
Special Note Regarding Non-GAAP Financial Measures
Fee Related Earnings , page 69

9.       You disclose that fee related earnings (FRE) is useful to investors
because it provides
         additional insight into the operating profitability of your business
and your ability to cover
 Alexandre Teixeira de Assump    o Saigh
Patria Investments Limited
October 28, 2020
Page 3
         direct base compensation and operating expenses from total fee
revenues. Please tell us,
         and disclose the following, related to FRE:
             which compensation components are revenue based, and the related
revenue; and
             why incentive fees are included in FRE when you disclose on page
89 that these fees
             were exceptionally high in 2019, you had no incentive fees in
2018, and these fees
             will fluctuate in future periods

         Please also enhance the compensation and cost of services rendered
disclosures to specify
         fixed and variable compensation costs.
Use of Proceeds, page 75

10.      We note your disclosure that you intend to use the proceeds to fund
capital commitments,
         expansion through acquisitions, opening new offices, and for general
corporate purposes.
         Please revise to indicate the anticipated amount of proceeds for each
of these uses. Please
         also disclose any known acquisitions, or advise.
Key Business Metrics, page 82

11.      Please disaggregate assets under management (AUM), fee-earning AUM,
         revenue eligible AUM or PREAUM by product (i.e. private equity,
infrastructure) in your
         next amendment, consistent with your disaggregated product portfolio
disclosures on
         pages 135.
12.      You disclose that performance and incentive fees are primarily
generated when the return
         of the funds surpass the performance hurdle set out in the related
charters. You also
         disclose that performance revenue eligible AUM or PREAUM represents
the total capital
         at fair value, on which performance revenues could be earned if
certain hurdles are met.
          Disclose and clarify if PREAUM represents the total capital at fair
value on which
         incentive fees can be earned if certain hurdles are met.
13.      We note your disclosure on page 42 that, "your investment funds
generally invest their
         assets in the equity, debt, loans or other securities of issuers
located in Latin America,
         including...Argentina." Given the current hyperinflationary economy in
Argentina, please
         tell us and revise your disclosures in your next amendment to disclose
your investments in
         Argentina, as well as any material losses, defaults or collection
issues associated with
         these investments.
Management's Discussion and Analysis of Financial Condition and Results of
Operations , page

14.    Please revise to disclose whether there is any specific length of time
that client funds have
FirstName LastNameAlexandre Teixeira de Assump    o Saigh
       to be invested or whether they can manage their investments on an
ongoing basis, making
Comapany    NamePatria
       investment        Investments
                   changes,          Limited
                             withdrawals, or deposits at any point in time.
October 28, 2020 Page 3
FirstName LastName
 Alexandre Teixeira de Assump    o Saigh
FirstName  LastNameAlexandre  Teixeira de Assump    o Saigh
Patria Investments Limited
October  28,NamePatria
             2020      Investments Limited
Page  4 28, 2020 Page 4
FirstName LastName
Our ability to successfully deploy capital, page 85

15.      We note your disclosure that you have overseen the deployment of
capital raised by your
         products, IPOs, and debt raised by underlying companies, for instance.
Please revise to
         briefly explain how these categories relate to your assets under
Management's Discussion and Analysis of Financial Condition and Results of
Results of Operations
Year Ended December 31, 2019, Compared to the Year Ended December 31, 2018
Net Revenues from services, page 88

16.      Please disaggregate net revenue from services by product (i.e. Private
         Infrastructure, and Emerging Products).
Industry, page 96

17.      Please revise the disclosure surrounding the circle graph on page 97
to clarify what
         portion of your investors are outside of Latin America, and to explain
the relevance of the
         market for other parts of the world to your business and to investors.
Competition , page 152

18.      Please revise this section to include a brief description of the
various markets in which
         you compete, the types of competition that you face, and the basis on
which the company
Principal and Selling Stockholder, page 160

19.      Please disclose in a footnote the natural person or persons that have
voting and dispositive
         control of Patria Holdings Ltd. and Blackstone PAT Holdings IV LLC.
20.      Please briefly describe the transactions from which the selling
shareholders initially
         received their shares and the exemption relied upon from registration.
Note 26. Financial Instruments
(d) Risk Management
(i) Credit Risk, page F-34

21.      You disclose that you have a low exposure to credit risk and that as
of December 31,
         2019, most of your accounts receivable are expected to be received in
the first semester of
         2020. Based on the aging disclosed, it appears that $15,110 million of
total accounts
         receivable of $27,117 million is overdue 360 days. Additionally, we
note that your
         deferred taxes related to management fee write-offs increased from
$954 at December 31,
         2018 to $1,442 at December 31, 2019. Please tell us and disclose the
following related to
         accounts receivable:
             clarify how you determined exposure to credit risk is low;
 Alexandre Teixeira de Assump    o Saigh
Patria Investments Limited
October 28, 2020
Page 5
                clarify why the majority of your accounts receivable appear
past due;
                provide a rollforward of accounts receivable in the periods
presented; and
                provide a rollforward of any allowance for accounts receivable
in the periods
22.      Please reconcile the following disclosures related to accounts
receivable which appear to
         be inconsistent: disclosure on page F-36 that, "the amounts receivable
as at December 31,
         2019 are expected to be received mostly in the first semester of
2020," with the disclosure
         on page F-20 that, "non-current balances are related to management
fees receivable in
         annual equal installments between 2020 and 2022."

23.      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 Julia Griffith at 202-551-3267 to
discuss how to submit
         the materials, if any, to us for our review.
24.      Please provide us mockups of any pages that include any additional
pictures or graphics to
         be presented, including any accompanying captions. Please keep in
mind, in scheduling
         your printing and distribution of the preliminary prospectus, that we
may have comments
         after our review of these materials.
       You may contact Michelle Miller at 202-551-3368 or David Irving at
202-551-3321 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Julia Griffith at 202-551-3267 or Susan Block at 202-551-3210 with any
other questions.

FirstName LastNameAlexandre Teixeira de Assump    o Saigh
Comapany NamePatria Investments Limited
                                                     Division of Corporation
October 28, 2020 Page 5                              Office of Finance
FirstName LastName