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City Different Investments

Santa Fe, NMSEC-registered investment adviserCRD 310982

Filed as CITY DIFFERENT INVESTMENTS · Legal name City Different Holdings LP

City Different Investments is an SEC-registered investment advisory firm in Santa Fe, NM, registered since 2021, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated May 31, 2026.

5 years
registered since 2021
$244,435,498
assets under management
3 arrangements
Percentage of assets, Performance-based and more
None
disclosure items (Item 11)

Quick answers

From the filing

How is City Different Investments compensated?

On its Form ADV (Item 5.E, October 2026), City Different Investments reports these compensation arrangements: a percentage of assets under its management; performance-based fees; other. The amounts are in Item 5 of its Form ADV Part 2A brochure.

Where is City Different Investments located?

City Different Investments' principal office is in Santa Fe, NM, according to its Form ADV.

Is City Different Investments registered with the SEC or a state?

City Different Investments is an SEC-registered investment advisory firm, registered since 2021. Status as filed: Approved. CRD 310982.

How much does City Different Investments manage?

City Different Investments reports $244,435,498 in regulatory assets under management in its Form ADV filing dated May 31, 2026 (100% discretionary).

How have City Different Investments' assets and staff changed since 2021?

In the Form ADV data for City Different Investments: Regulatory assets under management: $195,529,706 in the October 2021 data and $244,435,498 in the October 2026 data, up 25%. Total employees: 10 in October 2021 and 16 in October 2026. Assets under management move with markets as well as with clients coming and going.

What types of clients does City Different Investments serve?

By number of clients on Form ADV Item 5.D: high net worth individuals (100); pooled investment vehicles (other than investment companies and business development companies) (4); investment companies (1).

Which custodians does City Different Investments use?

City Different Investments' most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. and National Financial Services LLC as custodians holding 10% or more of its separately managed account assets.

Does City Different Investments 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/310982

What changed in City Different Investments' recent Form ADV filings?

In the June 2026 filing data: Registered or notice-filed in FL, OR.

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
  • Performance-based fees
  • Other

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

The brochure lists different fees for different services or strategies. See the firm's brochure (dated March 6, 2026) for its fees and any account minimum, on the SEC's IAPD site.

Regulatory assets under management

Item 5.F
$244,435,498

$244,435,498 as of October 2026, filing dated May 31, 2026.

Discretionary: $244,435,498.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 $0 (0%)
High net worth individuals
Clients 100 Assets $184,564,218 (76%)
Banking or thrift institutions
Clients 0 Assets $0 (0%)
Investment companies
Clients 1 Assets $32,380,555 (13%)
Business development companies
Clients 0 Assets $0 (0%)
Pooled investment vehicles (other than investment companies and business development companies)
Clients 4 Assets $24,636,501 (10%)
Pension and profit sharing plans (but not the plan participants or government pension plans)
Clients 0 Assets $0 (0%)
Charitable organizations
Clients 0 Assets $0 (0%)
State or municipal government entities (including government pension plans)
Clients 0 Assets $0 (0%)
Insurance companies
Clients 0 Assets $0 (0%)
Sovereign wealth funds and foreign official institutions
Clients 0 Assets $0 (0%)
Corporations or other businesses not listed above
Clients Fewer than 5 Assets $2,854,224 (1%)
Other
Clients 0 Assets $0 (0%)

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
  • Portfolio management for investment companies (and business development companies)
  • Portfolio management for pooled investment vehicles (other than investment companies)
  • Portfolio management for businesses (other than small businesses) or institutional clients
  • Selection of other advisers (including private fund managers)

Registration and firm details

Items 1, 2, 5
Legal name
City Different Holdings LP
Also doing business as
CITY DIFFERENT INVESTMENTS
Registration
SEC-registered investment adviser. Status as filed: Approved.
Registered since
2021 (5 years)
Employees
Total: 16. Performing investment advisory functions: 9.
Wrap fee program participation
No.
Custodians (Schedule D, Section 5.K(3))

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.

States registered or notice-filed
12 states or jurisdictions
CACOFLMAMINJNMNYOHORPATX

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
$196M 2021 $197M 2022 $157M 2023 $115M 2024 $266M 2025 $244M 2026
Data periodAssets under managementEmployeesFiling dated
October 2026$244,435,49816May 31, 2026
October 2025$265,806,16413March 26, 2025
October 2024$114,585,23614July 16, 2024
October 2023$156,966,65113May 11, 2023
October 2022$197,280,22214August 9, 2022
October 2021$195,529,70610July 22, 2021

Regulatory assets under management: $195,529,706 in the October 2021 data and $244,435,498 in the October 2026 data, up 25%.

Total employees: 10 in October 2021 and 16 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. June 2026
    • Registered or notice-filed in FL, OR.
  2. April 2026
    • Employees performing advisory functions went from 8 to 9.
    • Registered or notice-filed in MI.
  3. January 2026
    • No longer registered or notice-filed in KS.
  4. December 2025
    • Registered or notice-filed in OH.

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
citydifferentinvestments.com

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. City Different Investments (CRD 310982): Form ADV filing data as of October 2026.
https://advisorcensus.com/firm/city-different-investments-santa-fe-nm-310982