# Apex Investments Management, S.A.

> Apex Investments Management, S.A. is an SEC-registered investment advisory firm in Guatemala City, Guatemala, registered since 2022, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated September 11, 2026.

- CRD: 323044
- Filed as: APEX INVESTMENTS MANAGEMENT, S.A.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Guatemala City, Guatemala
- Filing period: October 2026
- Form ADV filing dated: September 11, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/323044
- AdvisorCensus page: https://advisorcensus.com/firm/apex-investments-management-s-a-guatemala-city-323044

## Quick answers

**How is Apex Investments Management, S.A. compensated?**
On its Form ADV (Item 5.E, October 2026), Apex Investments Management, S.A. 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 Apex Investments Management, S.A. located?**
Apex Investments Management, S.A.'s principal office is in Guatemala City, Guatemala, according to its Form ADV; the October 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Apex Investments Management, S.A. registered with the SEC or a state?**
Apex Investments Management, S.A. is an SEC-registered investment advisory firm, registered since 2022. Status as filed: Approved. CRD 323044.

**How much does Apex Investments Management, S.A. manage?**
Apex Investments Management, S.A. reports $392,490,285 in regulatory assets under management in its Form ADV filing dated September 11, 2026 (100% discretionary).

**How have Apex Investments Management, S.A.'s assets and staff changed since 2023?**
In the Form ADV data for Apex Investments Management, S.A.: Regulatory assets under management: $127,820,000 in the October 2023 data and $392,490,285 in the October 2026 data, up 207%. Total employees: 8 in October 2023 and 8 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Apex Investments Management, S.A. serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (1).

**Does Apex Investments Management, S.A. 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/323044

**What changed in Apex Investments Management, S.A.'s recent Form ADV filings?**
In the October 2026 filing data: Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

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

### Regulatory assets under management (Item 5.F)
- Total: $392,490,285
- Discretionary: $392,490,285
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 1 | $392,490,285 |

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

### Firm details
- Registered since: 2022 (3 years)
- Employees: 8 total, 7 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 October 2026 filing
- Coconut Grove, FL

### Websites listed on Form ADV (Item 1.I)
- [apexcapitalpe.com](https://apexcapitalpe.com)
- LinkedIn @apex-capital-transforming-businesses

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2023 | $127,820,000 | 8 | March 30, 2023 |
| October 2024 | $134,320,000 | 8 | March 28, 2024 |
| October 2025 | $279,483,839 | 8 | May 3, 2025 |
| October 2026 | $392,490,285 | 8 | September 11, 2026 |

Regulatory assets under management: $127,820,000 in the October 2023 data and $392,490,285 in the October 2026 data, up 207%.
Total employees: 8 in October 2023 and 8 in October 2026.

## Changes in the filing (last 12 months)

### October 2026
- Updated its list of owners and control persons (Schedule A).

### April 2026
- Regulatory assets under management went from $279,483,839 to $392,490,285 (+40%).
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Apex Investments Management, S.A. (CRD 323044): Form ADV filing data as of October 2026.