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Wellington Management Company LLP Institution

Boston, MA

AUM $1.43T
Clients 52
Advisors 1
Locations 1
Owners 6
Private funds 240
Filing snapshot

From the firm’s latest Form ADV. Clients are Item 5C advisory clients.

Regulatory AUM
$1.43T
Clients
52
Fiscal-year advisory clients
Investors
1
Across 1 office
Clients per advisor
52
Typical
Uses the rounded Item 5C count
Avg AUM per client
$27.5B
Regulatory AUM ÷ clients
Client mix
Banks / thrifts 34 $14.7B AUM Investment companies 209 $636B AUM Pooled vehicles 408 $327B AUM Pension / profit-sharing plans 172 $65.7B AUM Charitable organizations 74 $18.6B AUM Corporations / businesses 95 $69.8B AUM State or municipal entities 27 $86.4B AUM Other investment advisers 452 $145B AUM Insurance companies 48 $51.6B AUM Other 40 $12.7B AUM
At a Glance
Firm type
Registered
Registered
Oct 30, 1979
CRD #
106595
Regulatory AUM
$1,428,048,671,402
Advisors
1
Locations
1
Locations 1
Location Advisors City State
1 BOSTON MA
BOSTON, MA • 1 advisor
Disclosures

This firm answered Yes to 2 Form ADV Item 11 disclosure questions. Each line is from the firm’s SEC filing on this profile.

Full Item 11 checklist is in the ADV form below. How to read Item 11

Owners & Control Persons 6
Name Title Ownership Schedule
WELLINGTON INVESTMENT ADVISORS MANAGING PARTNER HOLDINGS LLP E A
HYNES, JEAN, MARIE CHIEF EXECUTIVE OFFICER PRESIDENT NA A
Murphy, Erin, Kimberly CHIEF FINANCIAL OFFICER NA A
SPEEDE, IHSAN, K. CHIEF COMPLIANCE OFFICER NA A
Coyne, Laura, Ann HEAD OF LEGAL AMERICAS NA A
Kramer, Amy, Beth CHIEF OPERATING OFFICER NA A
WELLINGTON INVESTMENT ADVISORS
MANAGING PARTNER HOLDINGS LLP • Ownership E • Schedule A
HYNES, JEAN, MARIE
CHIEF EXECUTIVE OFFICER PRESIDENT • Ownership NA • Schedule A
Murphy, Erin, Kimberly
CHIEF FINANCIAL OFFICER • Ownership NA • Schedule A
SPEEDE, IHSAN, K.
CHIEF COMPLIANCE OFFICER • Ownership NA • Schedule A
Coyne, Laura, Ann
HEAD OF LEGAL AMERICAS • Ownership NA • Schedule A
Kramer, Amy, Beth
CHIEF OPERATING OFFICER • Ownership NA • Schedule A
Private Funds 240
Fund Type Gross assets
PAGOSA STRATEGIES (CAYMAN) SPC 2049000
WELLINGTON CLO PARTNERS FUND (CAYMAN) II L.P.
WELLINGTON CLO PARTNERS FUND I, L.P. 202487000
WELLINGTON CLO PARTNERS FUND II, L.P.
WELLINGTON GLOBAL EQUITY LONG/SHORT STRATEGIES (CAYMAN) SPC 157814000
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST BLENDED OPPORTUNISTIC EMERGING MARKETS DEBT PORTFOLIO 1287976864
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, ASIAN OPPORTUNITIES Liquidity Fund 631765081
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CHILDREN'S MEDICAL CENTER LIQUIDITY PORTFOLIO Liquidity Fund 935412267
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CLIMATE STRATEGY PORTFOLIO Liquidity Fund 32344432
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, COMMODITIES PORTFOLIO 324732501
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CONTRARIAN VALUE INFLATION OPPORTUNITIES PORTFOLIO Liquidity Fund 29922
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CORE BOND PLUS PORTFOLIO 1036142081
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CORE BOND PLUS/MORTGAGE-BACKED SECURITIES PORTFOLIO 1969108624
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CORE BOND PORTFOLIO 1651714428
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CORE HIGH YIELD BOND PORTFOLIO 29642583
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, DIVERSIFIED INFLATION HEDGES II PORTFOLIO 64664831
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, DIVERSIFIED INFLATION HEDGES PORTFOLIO 839972152
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, DURABLE COMPANIES PORTFOLIO 383638075
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, DYNAMIC GROWTH PORTFOLIO Liquidity Fund 202250199
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING COMPANIES PORTFOLIO 368783367
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING LOCAL DEBT PORTFOLIO 590059849
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS DEBT II PORTFOLIO
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS DEBT PORTFOLIO 208258914
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS LOCAL EQUITY PORTFOLIO Liquidity Fund 303463100
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS OPPORTUNITIES PORTFOLIO Liquidity Fund 528948564
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS PORTFOLIO 140652212
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS RESEARCH EQUITY PORTFOLIO Liquidity Fund 589577478
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS SMALL CAP SYSTEMATIC EQUITY PORTFOLIO Liquidity Fund 12999
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, ENDURING ASSETS PORTFOLIO 302673319
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL FUNDAMENTAL GROWTH PORTFOLIO Liquidity Fund 28464
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL IMPACT PORTFOLIO Liquidity Fund 205498443
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL OPPORTUNITIES PORTFOLIO Liquidity Fund 414425765
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL PERSPECTIVES PORTFOLIO Liquidity Fund 348956557
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL PROPERTY PORTFOLIO Liquidity Fund 19633
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL QUALITY GROWTH PORTFOLIO Liquidity Fund 457369922
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL RESEARCH EQUITY CATHOLIC VALUES PORTFOLIO Liquidity Fund 82264809
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL SELECT CAPITAL APPRECIATION PORTFOLIO 269251421
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL TOTAL RETURN II PORTFOLIO 3215000129
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL TOTAL RETURN PORTFOLIO 107702
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, INTERMEDIATE BOND PORTFOLIO 100584869
PAGOSA STRATEGIES (CAYMAN) SPC
• 2049000
WELLINGTON CLO PARTNERS FUND (CAYMAN) II L.P.
WELLINGTON CLO PARTNERS FUND I, L.P.
• 202487000
WELLINGTON CLO PARTNERS FUND II, L.P.
WELLINGTON GLOBAL EQUITY LONG/SHORT STRATEGIES (CAYMAN) SPC
• 157814000
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST BLENDED OPPORTUNISTIC EMERGING MARKETS DEBT PORTFOLIO
• 1287976864
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, ASIAN OPPORTUNITIES
Liquidity Fund • 631765081
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CHILDREN'S MEDICAL CENTER LIQUIDITY PORTFOLIO
Liquidity Fund • 935412267
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CLIMATE STRATEGY PORTFOLIO
Liquidity Fund • 32344432
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, COMMODITIES PORTFOLIO
• 324732501
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CONTRARIAN VALUE INFLATION OPPORTUNITIES PORTFOLIO
Liquidity Fund • 29922
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CORE BOND PLUS PORTFOLIO
• 1036142081
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CORE BOND PLUS/MORTGAGE-BACKED SECURITIES PORTFOLIO
• 1969108624
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CORE BOND PORTFOLIO
• 1651714428
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, CORE HIGH YIELD BOND PORTFOLIO
• 29642583
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, DIVERSIFIED INFLATION HEDGES II PORTFOLIO
• 64664831
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, DIVERSIFIED INFLATION HEDGES PORTFOLIO
• 839972152
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, DURABLE COMPANIES PORTFOLIO
• 383638075
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, DYNAMIC GROWTH PORTFOLIO
Liquidity Fund • 202250199
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING COMPANIES PORTFOLIO
• 368783367
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING LOCAL DEBT PORTFOLIO
• 590059849
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS DEBT II PORTFOLIO
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS DEBT PORTFOLIO
• 208258914
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS LOCAL EQUITY PORTFOLIO
Liquidity Fund • 303463100
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS OPPORTUNITIES PORTFOLIO
Liquidity Fund • 528948564
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS PORTFOLIO
• 140652212
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS RESEARCH EQUITY PORTFOLIO
Liquidity Fund • 589577478
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, EMERGING MARKETS SMALL CAP SYSTEMATIC EQUITY PORTFOLIO
Liquidity Fund • 12999
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, ENDURING ASSETS PORTFOLIO
• 302673319
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL FUNDAMENTAL GROWTH PORTFOLIO
Liquidity Fund • 28464
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL IMPACT PORTFOLIO
Liquidity Fund • 205498443
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL OPPORTUNITIES PORTFOLIO
Liquidity Fund • 414425765
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL PERSPECTIVES PORTFOLIO
Liquidity Fund • 348956557
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL PROPERTY PORTFOLIO
Liquidity Fund • 19633
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL QUALITY GROWTH PORTFOLIO
Liquidity Fund • 457369922
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL RESEARCH EQUITY CATHOLIC VALUES PORTFOLIO
Liquidity Fund • 82264809
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL SELECT CAPITAL APPRECIATION PORTFOLIO
• 269251421
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL TOTAL RETURN II PORTFOLIO
• 3215000129
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, GLOBAL TOTAL RETURN PORTFOLIO
• 107702
WELLINGTON TRUST COMPANY, NA MULTIPLE COMMON TRUST FUNDS TRUST, INTERMEDIATE BOND PORTFOLIO
• 100584869

Showing 40 of 240 private funds.

Notice Filed 32
StateStatusDate
AZ FILED 2021-03-31
CA FILED 1980-08-28
CO FILED 2019-03-29
DE FILED 2006-04-18
DC FILED 2006-04-07
GA FILED 2001-03-23
IL FILED 1984-04-16
IN FILED 2002-04-01
IA FILED 2018-03-29
LA FILED 2012-03-16
MD FILED 1990-10-09
MA FILED 2002-04-01
MI FILED 1999-04-13
MN FILED 1961-10-10
NE FILED 2002-04-01
NJ FILED 1961-01-01
NY FILED 1984-01-01
NC FILED 2000-12-14
OH FILED 2006-04-07
OR FILED 2025-03-31
PA FILED 1997-02-07
SC FILED 2020-03-30
TN FILED 1998-01-05
VA FILED 1988-01-28
WI FILED 1980-03-06
MO FILED 1987-01-23
WA FILED 2008-03-28
TX FILED 1998-03-03
CT FILED 1997-06-23
HI FILED 2012-03-16
FL FILED 1961-04-25
NH FILED 2011-03-31
AZ
2021-03-31
FILED
CA
1980-08-28
FILED
CO
2019-03-29
FILED
DE
2006-04-18
FILED
DC
2006-04-07
FILED
GA
2001-03-23
FILED
IL
1984-04-16
FILED
IN
2002-04-01
FILED
IA
2018-03-29
FILED
LA
2012-03-16
FILED
MD
1990-10-09
FILED
MA
2002-04-01
FILED
MI
1999-04-13
FILED
MN
1961-10-10
FILED
NE
2002-04-01
FILED
NJ
1961-01-01
FILED
NY
1984-01-01
FILED
NC
2000-12-14
FILED
OH
2006-04-07
FILED
OR
2025-03-31
FILED
PA
1997-02-07
FILED
SC
2020-03-30
FILED
TN
1998-01-05
FILED
VA
1988-01-28
FILED
WI
1980-03-06
FILED
MO
1987-01-23
FILED
WA
2008-03-28
FILED
TX
1998-03-03
FILED
CT
1997-06-23
FILED
HI
2012-03-16
FILED
FL
1961-04-25
FILED
NH
2011-03-31
FILED
Registration
Firm Type
Registered
Status
APPROVED
Registered
Oct 30, 1979
SEC #
801-15908
CRD #
106595
SEC Region
BRO
Umbrella
N

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Filed: 2026-07-09 Form Version: 10/2021
1Identifying Information
1F(5) Total number of offices, other than your Principal Office and place of business 6
1I Do you have one or more websites Yes
1M Are you registered with a foreign financial regulatory authority Yes
1N Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934 No
1O Did you have $1 billion or more in assets on the last day of your most recent fiscal year Yes
1O If yes, approx. amount of assets $1 billion - $10 billion
1P Legal Entity Identifier 549300YHP12TEZNLCX41
2SEC Registration / Reporting

SEC Registration Basis (Item 2A)

2A(1) Are a large advisory firm that either: (a) has regulatory assets under management of $100 million (in U.S. dollars) or more, or (b) is SEC-registered and is submitting an annual updating amendment and has regulatory assets under management of $90 million (in U.S. dollars) or more Yes
2A(2) Are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and you are either: (a) not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business, or (b) not subject to examination by the state securities authority of the state where you maintain your principal office and place of business No
2A(4) Have your principal office and place of business outside the United States No
2A(5) Are an investment adviser (or sub-adviser) to an investment company registered under the Investment Company Act of 1940 Yes
2A(6) Are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940 and has not withdrawn the election, and you have at least $25 million of regulatory assets under management No
2A(7) Are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2 No
2A(8) Are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, and your principal office and place of business is the same as the registered adviser No
2A(9) Are a newly formed adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days No
2A(10) Are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d) No
2A(11) Are an Internet adviser relying on rule 203A-2(e) No
2A(12) Have received an SEC order exempting you from the prohibition against registration with the SEC No
2A(13) Are no longer eligible to remain registered with the SEC No
3Form of Organization

Organization Type

Limited Liability Partnership

Fiscal Year End

DECEMBER

Organized Under Laws Of

DE, United States

5AEmployees
Total Employees: 1,868
5B(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research) 497
5B(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer 63
5B(3) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives 1
5B(4) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for an investment adviser other than you 0
5B(5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency 0
5B(6) Approximately how many firms or other persons solicit advisory clients on your behalf 4
5CClients
5C(1) To approximately how many clients did you provide investment advisory services during your most recently completed fiscal year 52
5C(2) Approximately what percentage of your clients are non-United States persons 32
5DClient Types & Assets Under Management
Client Type # Clients Regulatory AUM
(a) Individuals (other than high net worth) 0
(b) High net worth individuals 0
(c) Banking or thrift institutions 34 $14,697,862,809.00
(d) Investment companies 209 $636,360,217,263.00
(e) Business development companies 0
(f) Pooled investment vehicles 408 $327,273,116,754.00
(g) Pension and profit sharing plans 172 $65,670,946,450.00
(h) Charitable organizations 74 $18,614,534,784.00
(i) State or municipal government entities 95 $69,810,295,296.00
(j) Other investment advisers 27 $86,404,158,650.00
(k) Insurance companies 452 $144,986,900,503.00
(l) Sovereign wealth funds 48 $51,567,484,945.00
(m) Corporations or other businesses 40 $12,663,153,948.00
5ECompensation Arrangements
5E(1) A percentage of assets under your management Yes
5E(2) Hourly charges No
5E(3) Subscription fees (for a newsletter or periodical) No
5E(4) Fixed fees (other than subscription fees) Yes
5E(5) Commissions No
5E(6) Performance-based fees Yes
5E(7) Other No
5FRegulatory Assets Under Management
5F(1) Do you provide continuous and regular supervisory or management services to securities portfolios Yes
U.S. Dollar Amount Total Accounts
Discretionary $1,325,852,873,516.00 1,502
Non-Discretionary $102,195,797,886.00 57
Total 5F(2)(c) $1,428,048,671,402.00 1,559

AUM attributable to non-U.S. persons: $384,872,653,301.00

5GAdvisory Services Provided
5G(1) Financial planning services No
5G(2) Portfolio management for individuals and/or small businesses Yes
5G(3) Portfolio management for investment companies Yes
5G(4) Portfolio management for pooled investment vehicles (other than investment companies) Yes
5G(5) Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles and) Yes
5G(6) Pension consulting services No
5G(7) Selection of other advisers No
5G(8) Publication of periodicals or newsletters No
5G(9) Security ratings or pricing services No
5G(10) Market timing services No
5G(11) Educational seminars/workshops No
5G(12) Other No
5IWrap Fee Programs
5I(1) Sponsor the wrap fee program Yes
5I(2a)AUM as sponsor
5I(2b)AUM as portfolio manager $55,476,341.00
5I(2c)AUM as sponsor and portfolio manager
5J-KInvestment Types & Separately Managed Accounts
5J In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments No
5J(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets under management? No
5K(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients) Yes
5K(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise Yes
5K(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise Yes
5K(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of this remaining amount of regulatory assets under management Yes
5LMarketing & Advertising
5L(1)(a) Do any of your advertisements include performance results Yes
5L(1)(b) Do any of your advertisements include a reference to specific investment advice provided by you (as that phrase is used in rule 206(4)-1(a)(5)) Yes
5L(1)(c) Do any of your advertisements include testimonials (other than those that satisfy rule 206(4)-1(b)(4)(ii)) Yes
5L(1)(d) Do any of your advertisements include endorsements (other than those that satisfy rule 206(4)-1(b)(4)(ii)) Yes
5L(1)(e) Do any of your advertisements include third-party ratings Yes
5L(2) Do you pay or otherwise provide cash or non-cash compensation, directly or indirectly, in connection with the use of testimonials, endorsements, or third-party ratings Yes
5L(3) Do any of your advertisements include hypothetical performance Yes
5L(4) Do any of your advertisements include predecessor performance No
6Other Business Activities

You or any related person are registered as or qualified as any of the following (Item 6A)

6A(1) Broker-dealer (registered or unregistered) No
6A(2) Registered representative of a broker-dealer No
6A(3) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) Yes
6A(4) Futures commission merchant No
6A(5) Real estate broker, dealer, or agent No
6A(6) Insurance broker or agent No
6A(7) Bank (including a separately identifiable department or division of a bank) No
6A(8) Trust company No
6A(9) Registered municipal advisor No
6A(10) Registered security-based swap dealer No
6A(11) Major security-based swap participant No
6A(12) Accountant or accounting firm No
6A(13) Lawyer or law firm No
6A(14) Other financial product salesperson No
6B(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice) No
6B(3) Do you sell products or provide services other than investment advice to your advisory clients No
7Financial Industry Affiliations

Related persons that are (Item 7A)

7A(1) Broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered) Yes
7A(2) Other investment adviser (including financial planners) Yes
7A(3) Registered municipal advisor No
7A(4) Registered security-based swap dealer No
7A(5) Major security-based swap participant No
7A(6) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) Yes
7A(7) Futures commission merchant No
7A(8) Banking or thrift institution No
7A(9) Trust company Yes
7A(10) Accountant or accounting firm No
7A(11) Lawyer or law firm No
7A(12) Insurance company or agency No
7A(13) Pension consultant No
7A(14) Real estate broker or dealer No
7A(15) Sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles No
7A(16) Sponsor, general partner, managing member (or equivalent) of pooled investment vehicles Yes
7B Are you an adviser to any private fund Yes
8Participation or Interest in Client Transactions
8A(1) Buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions) No
8A(2) Buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients Yes
8A(3) Recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (other than those mentioned in Items 8.A(1) or (2)) Yes
8B(1) As a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold to or bought from the brokerage customer (agency cross transactions) No
8B(2) Recommend purchase of securities to advisory clients for which you or any related person serves as underwriter, general or managing partner, or purchaser representative Yes
8B(3) Recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of sales commissions as a broker or registered representative of a broker-dealer) No
8C(1) Securities to be bought or sold for a client's account Yes
8C(2) Amount of securities to be bought or sold for a client's account Yes
8C(3) Broker or dealer to be used for a purchase or sale of securities for a client's account Yes
8C(4) Commission rates to be paid to a broker or dealer for a client's securities transactions Yes
8D If you answer "yes" to 8C.(3), are any of the brokers or dealers related persons No
8E Do you or any related person recommend brokers or dealers to clients Yes
8F If you answer "yes" to 8E, are any of the brokers or dealers related persons No
8G(1) Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") in connection with client securities transactions Yes
8G(2) If "yes" to G.(1), are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of the Securities Exchange Act of 1934 Yes
8H(1) Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals Yes
8H(2) Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients Yes
8I Do you or any related person, directly or indirectly, receive compensation from any person for client referrals No
9Custody
9A(1)(a) Cash or bank accounts Yes
9A(1)(b) Securities Yes
9A(2a) Dollar amount in custody
9A(2b) Number of clients 0
9B(1)(a) Cash or bank accounts Yes
9B(1)(b) Securities Yes
9C(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage Yes
9C(2) An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to the investors in the pools Yes
9C(3) An independent public accountant conducts an annual surprise examination of client funds and securities Yes
9C(4) An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodians for client funds and securities Yes
9D(1) You act as a qualified custodian No
9D(2) Do you or your related persons act as qualified custodians for your clients in connection with advisory services you provide to clients your related persons act as qualified custodians Yes
9E Surprise examination date 2026-03
9F If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act as qualified custodians for your clients in connection with advisory services you provide to clients 67
10Control Persons
10A Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies Yes
11Disclosure Information
This firm has one or more disciplinary disclosures on record.
11 Do any of the events below involve you or any of your supervised persons Yes
11A(1) Been convicted of or plead guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony No
11A(2) Been charged with any felony No
11B(1) Been convicted of or plead guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses No
11B(2) Been charged with a misdemeanor listed in 11.B(1) No
11C(1) Found you or any advisory affiliate to have made a false statement or omission No
11C(2) Found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes No
11C(3) Found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted No
11C(4) Entered an order against you or any advisory affiliate in connection with investment-related activity No
11C(5) Imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity No
11D(1) Ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical No
11D(2) Ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes Yes
11D(3) Ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted No
11D(4) In the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity No
11D(5) Ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity No
11E(1) Found you or any advisory affiliate to have made a false statement or omission No
11E(2) Found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC) No
11E(3) Found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted No
11E(4) Disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities No
11F Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended No
11G Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E No
11H(1)(a) The past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity No
11H(1)(b) Ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations No
11H(1)(c) Ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority No
11H(2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H(1) No

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