# Commerce Street Investment Management

> Commerce Street Investment Management is an SEC-registered investment advisory firm in Dallas, TX, registered since 2008, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated September 24, 2026.

- CRD: 144278
- Filed as: COMMERCE STREET INVESTMENT MANAGEMENT
- Legal name: Commerce Street Investment Advisor, LLC
- Also doing business as: COMMERCE STREET INVESTMENT MANAGEMENT, COMMERCE STREET PEAK ADVISORS
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Dallas, TX
- Filing period: October 2026
- Form ADV filing dated: September 24, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/144278
- AdvisorCensus page: https://advisorcensus.com/firm/commerce-street-investment-management-dallas-tx-144278

## Quick answers

**How is Commerce Street Investment Management compensated?**
On its Form ADV (Item 5.E, October 2026), Commerce Street Investment Management reports these compensation arrangements: a percentage of assets under its management; fixed fees (other than subscription fees); performance-based fees; other. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Commerce Street Investment Management located?**
Commerce Street Investment Management's principal office is in Dallas, TX, according to its Form ADV; the October 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Commerce Street Investment Management registered with the SEC or a state?**
Commerce Street Investment Management is an SEC-registered investment advisory firm, registered since 2008. Status as filed: Approved. CRD 144278.

**How much does Commerce Street Investment Management manage?**
Commerce Street Investment Management reports $891,286,277 in regulatory assets under management in its Form ADV filing dated September 24, 2026 (34% discretionary).

**How have Commerce Street Investment Management's assets and staff changed since 2021?**
In the Form ADV data for Commerce Street Investment Management: Regulatory assets under management: $515,887,089 in the October 2021 data and $891,286,277 in the October 2026 data, up 73%. Total employees: 15 in October 2021 and 14 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Commerce Street Investment Management serve?**
By number of clients on Form ADV Item 5.D: pension and profit sharing plans (but not the plan participants or government pension plans) (47); charitable organizations (6); high net worth individuals (5).

**Which custodians does Commerce Street Investment Management use?**
Commerce Street Investment Management's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Empower Trust Company, Fidelity Management Trust Company and Principal Financial Trust as custodians holding 10% or more of its separately managed account assets.

**Does Commerce Street Investment 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/144278

**What changed in Commerce Street Investment Management's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 12 to 10.

## From the Form ADV filing

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

### Custodians (Schedule D, Section 5.K(3))
- Empower Trust Company
- Fidelity Management Trust Company
- Principal Financial Trust

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: $891,286,277
- Discretionary: $300,591,957
- Non-discretionary: $590,694,320

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| High net worth individuals | 5 | $3,100,627 |
| Pooled investment vehicles (other than investment companies and business development companies) | 2 | $85,956,313 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 47 | $590,694,320 |
| Charitable organizations | 6 | $186,185,830 |
| Corporations or other businesses not listed above | 2 | $22,840,669 |
| Other | 2 | $2,508,518 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients
- Pension consulting services

### Firm details
- Registered since: 2008 (18 years)
- Employees: 14 total, 10 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, CO, CT, FL, IL, LA, MA, MS, NC, NE, NH, NJ, NY, OK, TX, WY
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the October 2026 filing
- Raleigh, NC

### Websites listed on Form ADV (Item 1.I)
- commercestreetholdings.com
- LinkedIn @commerce-street-capital-llc

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $515,887,089 | 15 | March 30, 2021 |
| October 2022 | $608,553,183 | 15 | September 27, 2022 |
| October 2023 | $535,442,153 | 13 | March 29, 2023 |
| October 2024 | $745,146,120 | 16 | June 12, 2024 |
| October 2025 | $876,451,597 | 16 | March 26, 2025 |
| October 2026 | $891,286,277 | 14 | September 24, 2026 |

Regulatory assets under management: $515,887,089 in the October 2021 data and $891,286,277 in the October 2026 data, up 73%.
Total employees: 15 in October 2021 and 14 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 12 to 10.

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

### November 2025
- Added an office in Raleigh, NC.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Commerce Street Investment Management (CRD 144278): Form ADV filing data as of October 2026.