# City Different Investments

> 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.

- CRD: 310982
- Filed as: CITY DIFFERENT INVESTMENTS
- Legal name: City Different Holdings LP
- Also doing business as: CITY DIFFERENT INVESTMENTS
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Santa Fe, NM
- Filing period: October 2026
- Form ADV filing dated: May 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/310982
- AdvisorCensus page: https://advisorcensus.com/firm/city-different-investments-santa-fe-nm-310982

## Quick answers

**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

### Compensation (Item 5.E)
- A percentage of assets under your management
- Performance-based fees
- Other

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., Inc.
- National Financial 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: $244,435,498
- Discretionary: $244,435,498
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | $0 |
| High net worth individuals | 100 | $184,564,218 |
| Banking or thrift institutions | 0 | $0 |
| Investment companies | 1 | $32,380,555 |
| Business development companies | 0 | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | 4 | $24,636,501 |
| 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 |
| Insurance companies | 0 | $0 |
| Sovereign wealth funds and foreign official institutions | 0 | $0 |
| Corporations or other businesses not listed above | Fewer than 5 | $2,854,224 |
| 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)
- Portfolio management for businesses (other than small businesses) or institutional clients
- Selection of other advisers (including private fund managers)

### Firm details
- Registered since: 2021 (5 years)
- Employees: 16 total, 9 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, CO, FL, MA, MI, NJ, NM, NY, OH, OR, PA, TX
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- citydifferentinvestments.com
- Facebook @citydifferentinvestments
- Instagram @citydifferentinvestments
- LinkedIn @city-different-investments
- YouTube @CityDifferentInvestments

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $195,529,706 | 10 | July 22, 2021 |
| October 2022 | $197,280,222 | 14 | August 9, 2022 |
| October 2023 | $156,966,651 | 13 | May 11, 2023 |
| October 2024 | $114,585,236 | 14 | July 16, 2024 |
| October 2025 | $265,806,164 | 13 | March 26, 2025 |
| October 2026 | $244,435,498 | 16 | May 31, 2026 |

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.

## Changes in the filing (last 12 months)

### June 2026
- Registered or notice-filed in FL, OR.

### April 2026
- Employees performing advisory functions went from 8 to 9.
- Registered or notice-filed in MI.

### January 2026
- No longer registered or notice-filed in KS.

### December 2025
- Registered or notice-filed in OH.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. City Different Investments (CRD 310982): Form ADV filing data as of October 2026.