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Boulder Asset Management

Englewood, COSEC-registered investment adviserCRD 107636

Filed as BOULDER ASSET MANAGEMENT · Legal name Stark Richard Joseph

Boulder Asset Management is an SEC-registered investment advisory firm in Englewood, CO, registered since 1991, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated March 28, 2025.

35 years
registered since 1991
$426,099,643
assets under management
2 arrangements
Percentage of assets, Fixed fees
None
disclosure items (Item 11)

Quick answers

From the filing

How is Boulder Asset Management compensated?

On its Form ADV (Item 5.E, October 2026), Boulder Asset Management reports these compensation arrangements: a percentage of assets under its management; fixed fees (other than subscription fees).

Where is Boulder Asset Management located?

Boulder Asset Management's principal office is in Englewood, CO, according to its Form ADV.

Is Boulder Asset Management registered with the SEC or a state?

Boulder Asset Management is an SEC-registered investment advisory firm, registered since 1991. Status as filed: Approved. CRD 107636.

How much does Boulder Asset Management manage?

Boulder Asset Management reports $426,099,643 in regulatory assets under management in its Form ADV filing dated March 28, 2025 (100% discretionary).

How have Boulder Asset Management's assets and staff changed since 2021?

In the Form ADV data for Boulder Asset Management: Regulatory assets under management: $582,585,034 in the October 2021 data and $426,099,643 in the October 2026 data, down 27%. Total employees: 4 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 Boulder Asset Management serve?

By number of clients on Form ADV Item 5.D: high net worth individuals (66).

Does Boulder Asset Management 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/107636

What changed in Boulder Asset Management's recent Form ADV filings?

In the January 2026 filing data: No longer registered or notice-filed in FL, OK.

From the Form ADV filing

Every figure below is as the firm filed it with regulators, as of October 2026.

How the firm is compensated

Item 5.E
  • A percentage of assets under your management
  • Fixed fees (other than subscription fees)

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

Fees and minimums

Form ADV Part 2A

Minimum annual fee: $25,000

The brochure's wording
Fees are calculated at 0.5% of client assets under supervision at the beginning of the period. The current minimum fee is $25,000 per year.

As stated in the firm's Form ADV Part 2A brochure dated March 28, 2025. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site

Regulatory assets under management

Item 5.F
$426,099,643

$426,099,643 as of October 2026, filing dated March 28, 2025.

Discretionary: $426,099,643.Non-discretionary: $0.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

Who the firm serves

Item 5.D
Individuals (other than high net worth individuals)
Clients 0 Assets Not reported
High net worth individuals
Clients 66 Assets $426,099,643 (100%)
Banking or thrift institutions
Clients 0 Assets Not reported
Investment companies
Clients 0 Assets Not reported
Business development companies
Clients 0 Assets Not reported
Pooled investment vehicles (other than investment companies and business development companies)
Clients 0 Assets Not reported
Pension and profit sharing plans (but not the plan participants or government pension plans)
Clients 0 Assets Not reported
Charitable organizations
Clients 0 Assets Not reported
State or municipal government entities (including government pension plans)
Clients 0 Assets Not reported
Other investment advisers
Clients 0 Assets Not reported
Insurance companies
Clients 0 Assets Not reported
Sovereign wealth funds and foreign official institutions
Clients 0 Assets Not reported
Corporations or other businesses not listed above
Clients 0 Assets Not reported
Other
Clients 0 Assets Not reported

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

Advisory services

Item 5.G
  • Portfolio management for individuals and/or small businesses

Registration and firm details

Items 1, 2, 5
Legal name
Stark Richard Joseph
Also doing business as
STARK ASSET MANAGEMENT
Registration
SEC-registered investment adviser. Status as filed: Approved.
Registered since
1991 (35 years)
Employees
Total: 4. Performing investment advisory functions: 1.
Wrap fee program participation
No.
States registered or notice-filed
1 state or jurisdiction
CO

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

Disclosures

Item 11

None Reports no disclosure items on Form ADV Item 11. View on IAPD.

Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures

Assets and staff over time

Items 5.A, 5.F
$583M 2021 $487M 2022 $370M 2023 $425M 2024 $426M 2025 $426M 2026
Data periodAssets under managementEmployeesFiling dated
October 2026$426,099,6434March 28, 2025
October 2025$426,099,6434March 28, 2025
October 2024$424,664,1084March 26, 2024
October 2023$370,235,7644March 29, 2023
October 2022$486,925,4334April 1, 2022
October 2021$582,585,0344March 3, 2021

Regulatory assets under management: $582,585,034 in the October 2021 data and $426,099,643 in the October 2026 data, down 27%.

Total employees: 4 in October 2021 and 4 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

Changes in the filing

Last 12 months
  1. January 2026
    • No longer registered or notice-filed in FL, OK.

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.

Websites listed on Form ADV

Item 1.I

Not reported.

Source: Form ADV, as of October 2026. Values appear as filed; a value the firm did not report is shown as "Not reported."

Cite this page

AdvisorCensus. Boulder Asset Management (CRD 107636): Form ADV filing data as of October 2026.
https://advisorcensus.com/firm/boulder-asset-management-englewood-co-107636