# Bay Hills Capital Management, LLC

> Bay Hills Capital Management, LLC is an SEC-registered investment advisory firm in San Francisco, CA, registered since 2012, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 158603
- Filed as: BAY HILLS CAPITAL MANAGEMENT, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: San Francisco, CA
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/158603
- AdvisorCensus page: https://advisorcensus.com/firm/bay-hills-capital-management-llc-san-francisco-ca-158603

## Quick answers

**How is Bay Hills Capital Management, LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Bay Hills Capital Management, LLC reports these compensation arrangements: a percentage of assets under its management; performance-based fees.

**Where is Bay Hills Capital Management, LLC located?**
Bay Hills Capital Management, LLC's principal office is in San Francisco, CA, according to its Form ADV.

**Is Bay Hills Capital Management, LLC registered with the SEC or a state?**
Bay Hills Capital Management, LLC is an SEC-registered investment advisory firm, registered since 2012. Status as filed: Approved. CRD 158603.

**How much does Bay Hills Capital Management, LLC manage?**
Bay Hills Capital Management, LLC reports $569,785,000 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (100% discretionary).

**How have Bay Hills Capital Management, LLC's assets and staff changed since 2021?**
In the Form ADV data for Bay Hills Capital Management, LLC: Regulatory assets under management: $617,073,750 in the October 2021 data and $569,785,000 in the October 2026 data, down 8%. Total employees: 8 in October 2021 and 7 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Bay Hills Capital Management, LLC serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (10).

**Does Bay Hills Capital Management, LLC report any disciplinary disclosures?**
Reports 1 disclosure item on Form ADV Item 11: yes answers to 11.H(1)(b) (court finding of a violation). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/158603

**Does Bay Hills Capital Management, LLC state an account minimum?**
Its Form ADV Part 2A brochure dated March 31, 2026 says: "Each BHCP Fund requires an initial minimum investment of $1,000,000, which, on occasion, may be waived in the sole discretion of the general partner."

**What changed in Bay Hills Capital Management, LLC's recent Form ADV filings?**
In the April 2026 filing data: Its Item 11 disclosure answers changed (now yes: 11.H(1)(b); now no: 11.H(2)). Regulatory assets under management went from $873,685,000 to $569,785,000 (-35%). 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

### Fees and minimums (Form ADV Part 2A brochure dated March 31, 2026)

- Account minimum: $1,000,000 (the brochure says it may be waived or negotiated)

> Each BHCP Fund requires an initial minimum investment of $1,000,000, which, on occasion, may be waived in the sole discretion of the general partner.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Regulatory assets under management (Item 5.F)
- Total: $569,785,000
- Discretionary: $569,785,000
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 10 | $569,785,000 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Selection of other advisers (including private fund managers)
- Other

### Firm details
- Registered since: 2012 (14 years)
- Employees: 7 total, 5 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA
- Disclosures (Item 11): Reports 1 disclosure item on Form ADV Item 11.

### Item 11 questions answered yes
- 11.H(1)(b): Has a domestic or foreign court ever found that the firm or an advisory affiliate was involved in a violation of investment-related statutes or regulations?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/158603

### Websites listed on Form ADV (Item 1.I)
- bayhillscapital.com

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $617,073,750 | 8 | March 24, 2021 |
| October 2022 | $780,590,000 | 7 | May 4, 2022 |
| October 2023 | $780,590,000 | 7 | March 28, 2023 |
| October 2024 | $864,385,000 | 7 | March 28, 2024 |
| October 2025 | $873,685,000 | 7 | May 1, 2025 |
| October 2026 | $569,785,000 | 7 | March 31, 2026 |

Regulatory assets under management: $617,073,750 in the October 2021 data and $569,785,000 in the October 2026 data, down 8%.
Total employees: 8 in October 2021 and 7 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Its Item 11 disclosure answers changed (now yes: 11.H(1)(b); now no: 11.H(2)).
- Regulatory assets under management went from $873,685,000 to $569,785,000 (-35%).
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Bay Hills Capital Management, LLC (CRD 158603): Form ADV filing data as of October 2026.