# Birinyi Associates, Inc.

> Birinyi Associates, Inc. is an SEC-registered investment advisory firm in Westport, CT, registered since 1990, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated February 19, 2026.

- CRD: 107169
- Filed as: BIRINYI ASSOCIATES, INC.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Westport, CT
- Filing period: October 2026
- Form ADV filing dated: February 19, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/107169
- AdvisorCensus page: https://advisorcensus.com/firm/birinyi-associates-inc-westport-ct-107169

## Quick answers

**How is Birinyi Associates, Inc. compensated?**
On its Form ADV (Item 5.E, October 2026), Birinyi Associates, Inc. reports these compensation arrangements: a percentage of assets under its management; hourly charges; subscription fees (for a newsletter or periodical); fixed fees (other than subscription fees).

**How much does Birinyi Associates, Inc. charge?**
Its Form ADV Part 2A brochure dated February 19, 2026 states: Subscription: $22.99 a month (newsletter); Subscription: $225 a year (newsletter). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Birinyi Associates, Inc. located?**
Birinyi Associates, Inc.'s principal office is in Westport, CT, according to its Form ADV.

**Is Birinyi Associates, Inc. registered with the SEC or a state?**
Birinyi Associates, Inc. is an SEC-registered investment advisory firm, registered since 1990. Status as filed: Approved. CRD 107169.

**How much does Birinyi Associates, Inc. manage?**
Birinyi Associates, Inc. reports $471,664,259 in regulatory assets under management in its Form ADV filing dated February 19, 2026 (100% discretionary).

**How have Birinyi Associates, Inc.'s assets and staff changed since 2021?**
In the Form ADV data for Birinyi Associates, Inc.: Regulatory assets under management: $327,355,588 in the October 2021 data and $471,664,259 in the October 2026 data, up 44%. Total employees: 5 in October 2021 and 4 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Birinyi Associates, Inc. serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (97); individuals (other than high net worth individuals) (6); corporations or other businesses not listed above (4).

**Which custodians does Birinyi Associates, Inc. use?**
Birinyi Associates, Inc.'s most recent Form ADV filing (Schedule D, Section 5.K(3)) lists RBC Capital Markets, LLC as a custodian holding 10% or more of its separately managed account assets.

**Does Birinyi Associates, Inc. report any disciplinary disclosures?**
Reports 3 disclosure items on Form ADV Item 11: yes answers to 11.C(2) (SEC or CFTC finding of a violation), 11.C(4) (SEC or CFTC order), and 11.C(5) (SEC or CFTC civil money penalty or cease-and-desist order). 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/107169

**Does Birinyi Associates, Inc. state an account minimum?**
Its Form ADV Part 2A brochure dated February 19, 2026 says: "The firm generally requires a prospective client interested in opening and maintaining a separate account to grant the firm discretionary investment advisory authority over at least $2,000,000 of the client’s assets, although exceptions are made in certain circumstances."

**What changed in Birinyi Associates, Inc.'s recent Form ADV filings?**
In the March 2026 filing data: Employees performing advisory functions went from 2 to 3.

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Hourly charges
- Subscription fees (for a newsletter or periodical)
- Fixed fees (other than subscription fees)

### Fees and minimums (Form ADV Part 2A brochure dated February 19, 2026)

- Account minimum: $2,000,000 (the brochure says it may be waived or negotiated)

> The firm generally requires a prospective client interested in opening and maintaining a separate account to grant the firm discretionary investment advisory authority over at least $2,000,000 of the client’s assets, although exceptions are made in certain circumstances.

- Subscription: $22.99 a month (newsletter)

> A subscription to our newsletter costs $22.99 per month or $225 per year.

- Subscription: $225 a year (newsletter)

> A subscription to our newsletter costs $22.99 per month or $225 per year.

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

### Custodians (Schedule D, Section 5.K(3))
- RBC Capital Markets, LLC

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: $471,664,259
- Discretionary: $469,944,195
- Non-discretionary: $1,720,064

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 6 | $1,867,710 |
| High net worth individuals | 97 | $449,854,239 |
| Corporations or other businesses not listed above | 4 | $19,942,310 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses (other than small businesses) or institutional clients
- Publication of periodicals or newsletters

### Firm details
- Registered since: 1990 (36 years)
- Employees: 4 total, 3 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, CT, FL, NY, TX
- Disclosures (Item 11): Reports 3 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.C(2): Has the SEC or the CFTC ever found that the firm or an advisory affiliate was involved in a violation of SEC or CFTC regulations or statutes?
- 11.C(4): Has the SEC or the CFTC ever entered an order against the firm or an advisory affiliate in connection with investment-related activity?
- 11.C(5): Has the SEC or the CFTC ever imposed a civil money penalty on the firm or an advisory affiliate, or ordered the firm or an advisory affiliate to cease and desist from an activity?

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/107169

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

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $327,355,588 | 5 | June 28, 2021 |
| October 2022 | $379,125,959 | 5 | March 24, 2022 |
| October 2023 | $277,140,676 | 5 | March 22, 2023 |
| October 2024 | $348,642,477 | 3 | January 4, 2024 |
| October 2025 | $434,529,012 | 3 | March 5, 2025 |
| October 2026 | $471,664,259 | 4 | February 19, 2026 |

Regulatory assets under management: $327,355,588 in the October 2021 data and $471,664,259 in the October 2026 data, up 44%.
Total employees: 5 in October 2021 and 4 in October 2026.

## Changes in the filing (last 12 months)

### March 2026
- Employees performing advisory functions went from 2 to 3.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Birinyi Associates, Inc. (CRD 107169): Form ADV filing data as of October 2026.