Comvest Credit Managers, LLC

• A percentage of assets under your management
• Performance-based fees

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

See the firm's brochure (dated March 31, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$956,839,000 as of October 2026, filing dated March 31, 2026.

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

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.

• Portfolio management for investment companies (and business development companies)
• Portfolio management for businesses (other than small businesses) or institutional clients

Also doing business as

COMVEST CAPITAL, COMVEST CREDIT OPPORTUNITIES, COMVEST CREDIT PARTNERS, COMVEST GROUP, COMVEST PARTNERS

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2022 (4 years)

Employees

Total: 150. Performing investment advisory functions: 128.

Wrap fee program participation

No.

Other offices (Schedule D, Section 1.F)

2 other offices, as of the April 2026 filing

Chicago, ILNew York, NY

States registered or notice-filed

3 states or jurisdictions

FLILNY

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

4 Reports 4 disclosure items on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.D(1) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?
• 11.D(2) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
• 11.D(4) In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?

Civil court matters Item 11.H

• 11.H(2) Is the firm or an advisory affiliate now the subject of a civil proceeding that could result in a yes answer to any part of 11.H(1)?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $18,333,570 in the October 2024 data and $956,839,000 in the October 2026 data, up 5119%.

Total employees: 97 in October 2022 and 150 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.

1. April 2026
   • Employees performing advisory functions went from 100 to 128.
   • Item 11 disclosure answers changed: 4 yes answers, previously 0 (now yes: 11.D(1), 11.D(2), 11.D(4), 11.H(2)).
   • Added an office in Chicago, IL.
2. January 2026
   • Employees performing advisory functions went from 101 to 100.
   • No longer lists the business name Comvest Investment Partners.
   • No longer lists the business name Comvest Private Equity.
   • Changed its office addresses in Chicago, IL.
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.