# Conifer Investments Ltd

> Conifer Investments Ltd is an SEC-registered investment advisory firm in West Hartford, CT, registered since 1994, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 106159
- Filed as: CONIFER INVESTMENTS LTD
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: West Hartford, CT
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/106159
- AdvisorCensus page: https://advisorcensus.com/firm/conifer-investments-ltd-west-hartford-ct-106159

## Quick answers

**How is Conifer Investments Ltd compensated?**
On its Form ADV (Item 5.E, October 2026), Conifer Investments Ltd reports these compensation arrangements: a percentage of assets under its management; fixed fees (other than subscription fees).

**How much does Conifer Investments Ltd charge?**
Its Form ADV Part 2A brochure dated March 31, 2026 states: Up to $500,000: 1% a year; $500,000 to $2,000,000: 0.8% a year; $2,000,000 to $5,000,000: 0.6% a year; Above $5,000,000: see the brochure. Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Conifer Investments Ltd located?**
Conifer Investments Ltd's principal office is in West Hartford, CT, according to its Form ADV.

**Is Conifer Investments Ltd registered with the SEC or a state?**
Conifer Investments Ltd is an SEC-registered investment advisory firm, registered since 1994. Status as filed: Approved. CRD 106159.

**How much does Conifer Investments Ltd manage?**
Conifer Investments Ltd reports $524,034,271 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (27% discretionary).

**How have Conifer Investments Ltd's assets and staff changed since 2021?**
In the Form ADV data for Conifer Investments Ltd: Regulatory assets under management: $365,711,529 in the October 2021 data and $524,034,271 in the October 2026 data, up 43%. Total employees: 3 in October 2021 and 3 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Conifer Investments Ltd serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (24); individuals (other than high net worth individuals) (17).

**Which custodians does Conifer Investments Ltd use?**
Conifer Investments Ltd's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. as a custodian holding 10% or more of its separately managed account assets.

**Does Conifer Investments Ltd 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/106159

**Does Conifer Investments Ltd state an account minimum?**
Its Form ADV Part 2A brochure dated March 31, 2026 says: "The Firm does not impose a minimum dollar value of assets for establishing or maintaining an investment advisory relationship."

**What changed in Conifer Investments Ltd's recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $465,762,749 to $524,034,271 (+13%).

## From the Form ADV filing

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

### Fees and minimums (Form ADV Part 2A brochure dated March 31, 2026)

- Up to $500,000: 1% a year
- $500,000 to $2,000,000: 0.8% a year
- $2,000,000 to $5,000,000: 0.6% a year
- Above $5,000,000: see the brochure

> Basic Fee Schedule: 1.00% of the first $ 500,000 0.80% of the next $1,500,000 0.60% of the next $3,000,000 Negotiable over $5 million

- Account minimum: None

> The Firm does not impose a minimum dollar value of assets for establishing or maintaining an investment advisory relationship.

- Minimum annual fee: $3,000

> The minimum annual fee for starting and/or maintaining an account is $3,000.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., Inc.

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: $524,034,271
- Discretionary: $141,300,097
- Non-discretionary: $382,734,174

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 17 | $354,112,186 |
| High net worth individuals | 24 | $150,887,051 |
| Charitable organizations | Fewer than 5 | $19,035,034 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Selection of other advisers (including private fund managers)

### Firm details
- Registered since: 1994 (32 years)
- Employees: 3 total, 3 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CT
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $365,711,529 | 3 | April 1, 2021 |
| October 2022 | $416,971,139 | 3 | March 30, 2022 |
| October 2023 | $358,001,490 | 3 | March 31, 2023 |
| October 2024 | $412,870,388 | 3 | March 28, 2024 |
| October 2025 | $465,762,749 | 3 | March 14, 2025 |
| October 2026 | $524,034,271 | 3 | March 31, 2026 |

Regulatory assets under management: $365,711,529 in the October 2021 data and $524,034,271 in the October 2026 data, up 43%.
Total employees: 3 in October 2021 and 3 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $465,762,749 to $524,034,271 (+13%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Conifer Investments Ltd (CRD 106159): Form ADV filing data as of October 2026.