# 3650 Reit Investment Management LLC

> 3650 Reit Investment Management LLC is an SEC-registered investment advisory firm in Miami, FL, registered since 2017, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 286013
- Filed as: 3650 REIT INVESTMENT MANAGEMENT LLC
- Also doing business as: 3650 CAPITAL, 3650 REIT
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Miami, FL
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/286013
- AdvisorCensus page: https://advisorcensus.com/firm/3650-reit-investment-management-llc-miami-fl-286013

## Quick answers

**How is 3650 Reit Investment Management LLC compensated?**
On its Form ADV (Item 5.E, October 2026), 3650 Reit Investment Management LLC reports these compensation arrangements: a percentage of assets under its management; performance-based fees. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is 3650 Reit Investment Management LLC located?**
3650 Reit Investment Management LLC's principal office is in Miami, FL, according to its Form ADV; the April 2026 filing also lists 2 other offices (Schedule D, Section 1.F).

**Is 3650 Reit Investment Management LLC registered with the SEC or a state?**
3650 Reit Investment Management LLC is an SEC-registered investment advisory firm, registered since 2017. Status as filed: Approved. CRD 286013.

**How much does 3650 Reit Investment Management LLC manage?**
3650 Reit Investment Management LLC reports $2,432,617,368 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (62% discretionary).

**How have 3650 Reit Investment Management LLC's assets and staff changed since 2021?**
In the Form ADV data for 3650 Reit Investment Management LLC: Regulatory assets under management: $1,494,676,841 in the October 2021 data and $2,432,617,368 in the October 2026 data, up 63%. Total employees: 8 in October 2021 and 16 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does 3650 Reit Investment Management LLC serve?**
By number of clients on Form ADV Item 5.D: sovereign wealth funds and foreign official institutions (5); pooled investment vehicles (other than investment companies and business development companies) (4); corporations or other businesses not listed above (3).

**Which custodians does 3650 Reit Investment Management LLC use?**
3650 Reit Investment Management LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists City National Bank, City National Bank of Florida, Computershare Limited and Wells Fargo Bank, N.A. as custodians holding 10% or more of its separately managed account assets.

**Does 3650 Reit Investment Management LLC report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/286013

**What changed in 3650 Reit Investment Management LLC's recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $2,782,900,671 to $2,432,617,368 (-13%).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Performance-based fees

### Custodians (Schedule D, Section 5.K(3))
- City National Bank
- City National Bank of Florida
- Computershare Limited
- Wells Fargo Bank, N.A.

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $2,432,617,368
- Discretionary: $1,503,002,625
- Non-discretionary: $929,614,743

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 4 | $356,901,808 |
| Sovereign wealth funds and foreign official institutions | 5 | $627,123,171 |
| Corporations or other businesses not listed above | 3 | $1,448,592,389 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Other

### Firm details
- Registered since: 2017 (9 years)
- Employees: 16 total, 8 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the April 2026 filing
- Beverly Hills, CA
- New York, NY

### Websites listed on Form ADV (Item 1.I)
- [3650reitinvestmentmanagement.com](https://3650reitinvestmentmanagement.com)

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $1,494,676,841 | 8 | March 31, 2021 |
| October 2022 | $2,322,911,622 | 13 | March 31, 2022 |
| October 2023 | $2,797,453,915 | 14 | March 30, 2023 |
| October 2024 | $2,726,645,343 | 14 | March 30, 2024 |
| October 2025 | $2,782,900,671 | 16 | March 31, 2025 |
| October 2026 | $2,432,617,368 | 16 | March 31, 2026 |

Regulatory assets under management: $1,494,676,841 in the October 2021 data and $2,432,617,368 in the October 2026 data, up 63%.
Total employees: 8 in October 2021 and 16 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $2,782,900,671 to $2,432,617,368 (-13%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. 3650 Reit Investment Management LLC (CRD 286013): Form ADV filing data as of October 2026.
