# Bristlecone Value Partners, LLC

> Bristlecone Value Partners, LLC is an SEC-registered investment advisory firm in Los Angeles, CA, registered since 2015, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated February 20, 2026.

- CRD: 128117
- Filed as: BRISTLECONE VALUE PARTNERS, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Los Angeles, CA
- Filing period: October 2026
- Form ADV filing dated: February 20, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/128117
- AdvisorCensus page: https://advisorcensus.com/firm/bristlecone-value-partners-llc-los-angeles-ca-128117

## Quick answers

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

**Where is Bristlecone Value Partners, LLC located?**
Bristlecone Value Partners, LLC's principal office is in Los Angeles, CA, according to its Form ADV.

**Is Bristlecone Value Partners, LLC registered with the SEC or a state?**
Bristlecone Value Partners, LLC is an SEC-registered investment advisory firm, registered since 2015. Status as filed: Approved. CRD 128117.

**How much does Bristlecone Value Partners, LLC manage?**
Bristlecone Value Partners, LLC reports $188,400,000 in regulatory assets under management in its Form ADV filing dated February 20, 2026 (99% discretionary).

**How have Bristlecone Value Partners, LLC's assets and staff changed since 2021?**
In the Form ADV data for Bristlecone Value Partners, LLC: Regulatory assets under management: $131,100,000 in the October 2021 data and $188,400,000 in the October 2026 data, up 44%. Total employees: 3 in October 2021 and 3 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Bristlecone Value Partners, LLC serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (62); individuals (other than high net worth individuals) (28); charitable organizations (2).

**Which custodians does Bristlecone Value Partners, LLC use?**
Bristlecone Value Partners, LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. and Fidelity Brokerage Services LLC as custodians holding 10% or more of its separately managed account assets.

**Does Bristlecone Value Partners, LLC 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/128117

**Does Bristlecone Value Partners, LLC state an account minimum?**
Its Form ADV Part 2A brochure dated February 20, 2026 says: "We generally require a minimum of $500,000 to open and maintain an advisory account. At our discretion, we may waive this minimum account size."

**What changed in Bristlecone Value Partners, LLC's recent Form ADV filings?**
In the March 2026 filing data: Regulatory assets under management went from $156,100,000 to $188,400,000 (+21%).

## 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 February 20, 2026)

- Account minimum: $500,000 (the brochure says it may be waived or negotiated)

> We generally require a minimum of $500,000 to open and maintain an advisory account. At our discretion, we may waive this minimum account size.

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.
- Fidelity Brokerage Services 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: $188,400,000
- Discretionary: $186,100,000
- Non-discretionary: $2,300,000

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 28 | $6,100,000 |
| High net worth individuals | 62 | $175,400,000 |
| Pooled investment vehicles (other than investment companies and business development companies) | 1 | $5,200,000 |
| Charitable organizations | 2 | $1,500,000 |
| Corporations or other businesses not listed above | 1 | $200,000 |

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

### Firm details
- Registered since: 2015 (11 years)
- Employees: 3 total, 3 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, NE, NH, OR
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- bristlecone-vp.com
- Facebook @BristleconeVP
- LinkedIn @bristlecone-value-partners-llc

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $131,100,000 | 3 | March 23, 2021 |
| October 2022 | $155,800,000 | 3 | September 20, 2022 |
| October 2023 | $137,500,000 | 3 | August 8, 2023 |
| October 2024 | $155,300,000 | 3 | March 7, 2024 |
| October 2025 | $156,100,000 | 3 | February 25, 2025 |
| October 2026 | $188,400,000 | 3 | February 20, 2026 |

Regulatory assets under management: $131,100,000 in the October 2021 data and $188,400,000 in the October 2026 data, up 44%.
Total employees: 3 in October 2021 and 3 in October 2026.

## Changes in the filing (last 12 months)

### March 2026
- Regulatory assets under management went from $156,100,000 to $188,400,000 (+21%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Bristlecone Value Partners, LLC (CRD 128117): Form ADV filing data as of October 2026.