# Compass Rose Asset Management

> Compass Rose Asset Management is an SEC-registered investment advisory firm in New York, NY, registered since 2018, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 297010
- Filed as: COMPASS ROSE ASSET MANAGEMENT
- Legal name: Compass Rose Asset Management, LP
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: New York, NY
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/297010
- AdvisorCensus page: https://advisorcensus.com/firm/compass-rose-asset-management-new-york-ny-297010

## Quick answers

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

**Where is Compass Rose Asset Management located?**
Compass Rose Asset Management's principal office is in New York, NY, according to its Form ADV; the April 2026 filing also lists 2 other offices (Schedule D, Section 1.F).

**Is Compass Rose Asset Management registered with the SEC or a state?**
Compass Rose Asset Management is an SEC-registered investment advisory firm, registered since 2018. Status as filed: Approved. CRD 297010.

**How much does Compass Rose Asset Management manage?**
Compass Rose Asset Management reports $16,500,609,281 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (100% discretionary).

**How have Compass Rose Asset Management's assets and staff changed since 2021?**
In the Form ADV data for Compass Rose Asset Management: Regulatory assets under management: $5,772,225,208 in the October 2021 data and $16,500,609,281 in the October 2026 data, up 186%. Total employees: 19 in October 2021 and 37 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Compass Rose Asset Management serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (3).

**Which custodians does Compass Rose Asset Management use?**
Compass Rose Asset Management's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Bank of America, Barclays Bank PLC, BNP Paribas, Carta Capital Markets, LLC, Citibank, Deutsche Bank AG, Goldman Sachs & Co. LLC, J.P. Morgan Clearing Corp., Morgan Stanley & Co. LLC, Royal Bank of Canada and Scotia Bank as custodians holding 10% or more of its separately managed account assets.

**Does Compass Rose 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/297010

**What changed in Compass Rose Asset Management's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 20 to 16. Regulatory assets under management went from $11,859,616,972 to $16,500,609,281 (+39%). No longer lists an office in Charleston, SC. No longer lists an office in Pacific Palisades, CA. Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

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

### Custodians (Schedule D, Section 5.K(3))
- Bank of America
- Barclays Bank PLC
- BNP Paribas
- Carta Capital Markets, LLC
- Citibank
- Deutsche Bank AG
- Goldman Sachs & Co. LLC
- J.P. Morgan Clearing Corp.
- Morgan Stanley & Co. LLC
- Royal Bank of Canada
- Scotia Bank

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: $16,500,609,281
- Discretionary: $16,500,609,281
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | $0 |
| Banking or thrift institutions | 0 | $0 |
| Investment companies | 0 | $0 |
| Business development companies | 0 | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | 3 | $13,742,009,878 |
| 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 |
| Other investment advisers | 0 | $0 |
| Insurance companies | 0 | $0 |
| Sovereign wealth funds and foreign official institutions | 0 | $0 |
| Corporations or other businesses not listed above | 0 | $0 |
| Other | Fewer than 5 | $2,758,599,403 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Other

### Firm details
- Registered since: 2018 (8 years)
- Employees: 37 total, 16 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, CT, FL, NY, SC
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the April 2026 filing
- Vero Beach, FL
- Washington Depot, CT

### Websites listed on Form ADV (Item 1.I)
- compassroseam.com

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $5,772,225,208 | 19 | September 16, 2021 |
| October 2022 | $4,996,744,843 | 20 | March 30, 2022 |
| October 2023 | $8,597,251,978 | 23 | March 31, 2023 |
| October 2024 | $12,351,533,040 | 35 | March 27, 2024 |
| October 2025 | $11,859,616,972 | 35 | March 27, 2025 |
| October 2026 | $16,500,609,281 | 37 | March 31, 2026 |

Regulatory assets under management: $5,772,225,208 in the October 2021 data and $16,500,609,281 in the October 2026 data, up 186%.
Total employees: 19 in October 2021 and 37 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 20 to 16.
- Regulatory assets under management went from $11,859,616,972 to $16,500,609,281 (+39%).
- No longer lists an office in Charleston, SC.
- No longer lists an office in Pacific Palisades, CA.
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Compass Rose Asset Management (CRD 297010): Form ADV filing data as of October 2026.