# Bluestone Capital Management, LLC

> Bluestone Capital Management, LLC is an SEC-registered investment advisory firm in Wayne, PA, registered since 2013, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated July 16, 2026.

- CRD: 157841
- Filed as: BLUESTONE CAPITAL MANAGEMENT, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Wayne, PA
- Filing period: October 2026
- Form ADV filing dated: July 16, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/157841
- AdvisorCensus page: https://advisorcensus.com/firm/bluestone-capital-management-llc-wayne-pa-157841

## Quick answers

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

**What does Bluestone Capital Management, LLC's brochure say about its fees?**
Its Form ADV Part 2A brochure dated March 23, 2026 states: Asset-based fee: 1% to 2% a year (a range, as the brochure states it). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Bluestone Capital Management, LLC located?**
Bluestone Capital Management, LLC's principal office is in Wayne, PA, according to its Form ADV; the August 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Bluestone Capital Management, LLC registered with the SEC or a state?**
Bluestone Capital Management, LLC is an SEC-registered investment advisory firm, registered since 2013. Status as filed: Approved. CRD 157841.

**How much does Bluestone Capital Management, LLC manage?**
Bluestone Capital Management, LLC reports $390,099,951 in regulatory assets under management in its Form ADV filing dated July 16, 2026 (100% discretionary).

**How have Bluestone Capital Management, LLC's assets and staff changed since 2021?**
In the Form ADV data for Bluestone Capital Management, LLC: Regulatory assets under management: $2,279,167,406 in the October 2021 data and $390,099,951 in the October 2026 data, down 83%. Total employees: 6 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 Bluestone Capital Management, LLC serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (4); high net worth individuals (1); investment companies (1).

**Which custodians does Bluestone Capital Management, LLC use?**
Bluestone Capital Management, LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. and Interactive Brokers LLC as custodians holding 10% or more of its separately managed account assets.

**Does Bluestone Capital Management, LLC report any disciplinary disclosures?**
Reports 6 disclosure items on Form ADV Item 11: yes answers to 11.C(1) (SEC or CFTC finding of a false statement or omission), 11.C(2) (SEC or CFTC finding of a violation), 11.C(5) (SEC or CFTC civil money penalty or cease-and-desist order), 11.D(2) (another regulator's finding of a violation), 11.D(4) (another regulator's order in the past ten years), and 11.D(5) (another regulator's denial, suspension, or revocation of a registration or license, bar, or restriction). 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/157841

**What changed in Bluestone Capital Management, LLC's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 4 to 2. Regulatory assets under management went from $351,518,705 to $390,099,951 (+11%). 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 23, 2026)

- Asset-based fee: 1% to 2% a year (a range, as the brochure states it)

> Asset-based fees generally range from 1 percent to 2 percent of assets under management.

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

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., Inc.
- Interactive Brokers 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: $390,099,951
- Discretionary: $390,099,951
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 4 | $570,689 |
| High net worth individuals | 1 | $5,035,172 |
| Banking or thrift institutions | 0 | $0 |
| Investment companies | 1 | $352,684,120 |
| Business development companies | 0 | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | 1 | $31,809,970 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 0 | $0 |
| Charitable organizations | 0 | $0 |
| State or municipal government entities (including government pension plans) | 0 | $0 |
| Other investment advisers | 0 | $0 |
| Insurance companies | 0 | $0 |
| Sovereign wealth funds and foreign official institutions | 0 | $0 |
| Corporations or other businesses not listed above | 0 | $0 |
| Other | 0 | $0 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Portfolio management for investment companies (and business development companies)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Selection of other advisers (including private fund managers)
- Other

### Firm details
- Registered since: 2013 (13 years)
- Employees: 4 total, 2 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: PA
- Disclosures (Item 11): Reports 6 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.C(1): Has the SEC or the CFTC ever found that the firm or an advisory affiliate made a false statement or omission?
- 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(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?
- 11.D(2): Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
- 11.D(4): In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?
- 11.D(5): Has another federal regulator, a state regulator, or a foreign financial regulator ever denied, suspended, or revoked the registration or license of the firm or an advisory affiliate, prevented either by order from associating with an investment-related business, or restricted either one's 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/157841

### Other offices (Schedule D, Section 1.F), as of the August 2026 filing
- Humacao, PR

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

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $2,279,167,406 | 6 | March 31, 2021 |
| October 2022 | $217,405,000 | 4 | September 22, 2022 |
| October 2023 | $224,735,701 | 4 | September 25, 2023 |
| October 2024 | $280,985,152 | 4 | March 18, 2024 |
| October 2025 | $351,518,705 | 4 | March 31, 2025 |
| October 2026 | $390,099,951 | 4 | July 16, 2026 |

Regulatory assets under management: $2,279,167,406 in the October 2021 data and $390,099,951 in the October 2026 data, down 83%.
Total employees: 6 in October 2021 and 4 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 4 to 2.
- Regulatory assets under management went from $351,518,705 to $390,099,951 (+11%).
- Updated its list of owners and control persons (Schedule A).

### January 2026
- No longer registered or notice-filed in CA, CO, CT, DC, DE, FL, GA, MA, MD, NC, NH, NJ, NV, NY, OH, OR, SC, TX, UT, VA, WA.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Bluestone Capital Management, LLC (CRD 157841): Form ADV filing data as of October 2026.