# Complus Asset Management Limited

> Complus Asset Management Limited is an SEC-registered investment advisory firm in Hong Kong, Hong Kong, registered since 2018, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 173003
- Filed as: COMPLUS ASSET MANAGEMENT LIMITED
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Hong Kong, Hong Kong
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/173003
- AdvisorCensus page: https://advisorcensus.com/firm/complus-asset-management-limited-hong-kong-173003

## Quick answers

**How is Complus Asset Management Limited compensated?**
On its Form ADV (Item 5.E, October 2026), Complus Asset Management Limited 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 Complus Asset Management Limited located?**
Complus Asset Management Limited's principal office is in Hong Kong, Hong Kong, according to its Form ADV.

**Is Complus Asset Management Limited registered with the SEC or a state?**
Complus Asset Management Limited is an SEC-registered investment advisory firm, registered since 2018. Status as filed: Approved. CRD 173003.

**How much does Complus Asset Management Limited manage?**
Complus Asset Management Limited reports $5,866,561,697 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (100% discretionary).

**How have Complus Asset Management Limited's assets and staff changed since 2021?**
In the Form ADV data for Complus Asset Management Limited: Regulatory assets under management: $3,340,000,000 in the October 2021 data and $5,866,561,697 in the October 2026 data, up 76%. Total employees: 26 in October 2021 and 35 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Complus Asset Management Limited serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (6).

**Which custodians does Complus Asset Management Limited use?**
Complus Asset Management Limited's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists J.P. Morgan Securities LLC as a custodian holding 10% or more of its separately managed account assets.

**Does Complus Asset Management Limited 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/173003

**What changed in Complus Asset Management Limited's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 8 to 9.

## 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))
- J.P. Morgan Securities 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: $5,866,561,697
- Discretionary: $5,866,561,697
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 6 | $3,053,697,922 |
| State or municipal government entities (including government pension plans) | Fewer than 5 | $2,812,863,775 |

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

### Firm details
- Registered since: 2018 (8 years)
- Employees: 35 total, 9 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

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

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $3,340,000,000 | 26 | September 6, 2021 |
| October 2022 | $3,121,000,000 | 23 | March 30, 2022 |
| October 2023 | $3,263,000,000 | 27 | May 16, 2023 |
| October 2024 | $4,070,000,000 | 32 | March 25, 2024 |
| October 2025 | $5,353,000,000 | 34 | March 31, 2025 |
| October 2026 | $5,866,561,697 | 35 | March 31, 2026 |

Regulatory assets under management: $3,340,000,000 in the October 2021 data and $5,866,561,697 in the October 2026 data, up 76%.
Total employees: 26 in October 2021 and 35 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 8 to 9.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Complus Asset Management Limited (CRD 173003): Form ADV filing data as of October 2026.