# Cumberland Investment Counsel Inc.

> Cumberland Investment Counsel Inc. is an SEC-registered investment advisory firm in Toronto Ontario, Canada, registered since 1992, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated September 29, 2026.

- CRD: 110887
- Filed as: CUMBERLAND INVESTMENT COUNSEL INC.
- Also doing business as: CONSEILLERS EN PLACEMENT CUMBERLAND, CUMBERLAND, CUMBERLAND INVESTMENT COUNSEL, CUMBERLAND PRIVATE WEALTH, PATRIMOINE PRIVE CUMBERLAND
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Toronto Ontario, Canada
- Filing period: October 2026
- Form ADV filing dated: September 29, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/110887
- AdvisorCensus page: https://advisorcensus.com/firm/cumberland-investment-counsel-inc-toronto-ontario-110887

## Quick answers

**How is Cumberland Investment Counsel Inc. compensated?**
On its Form ADV (Item 5.E, October 2026), Cumberland Investment Counsel Inc. reports these compensation arrangements: a percentage of assets under its management; performance-based fees.

**Where is Cumberland Investment Counsel Inc. located?**
Cumberland Investment Counsel Inc.'s principal office is in Toronto Ontario, Canada, according to its Form ADV; the October 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Cumberland Investment Counsel Inc. registered with the SEC or a state?**
Cumberland Investment Counsel Inc. is an SEC-registered investment advisory firm, registered since 1992. Status as filed: Approved. CRD 110887.

**How much does Cumberland Investment Counsel Inc. manage?**
Cumberland Investment Counsel Inc. reports $1,405,771,456 in regulatory assets under management in its Form ADV filing dated September 29, 2026 (100% discretionary).

**How have Cumberland Investment Counsel Inc.'s assets and staff changed since 2021?**
In the Form ADV data for Cumberland Investment Counsel Inc.: Regulatory assets under management: $930,255,823 in the October 2021 data and $1,405,771,456 in the October 2026 data, up 51%. Total employees: 19 in October 2021 and 19 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Cumberland Investment Counsel Inc. serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (23); high net worth individuals (12); pooled investment vehicles (other than investment companies and business development companies) (10).

**Which custodians does Cumberland Investment Counsel Inc. use?**
Cumberland Investment Counsel Inc.'s most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. and National Bank Financial Inc. as custodians holding 10% or more of its separately managed account assets.

**Does Cumberland Investment Counsel Inc. report any disciplinary disclosures?**
Reports 1 disclosure item on Form ADV Item 11: yes answers to 11.D(2) (another regulator's finding of a violation). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/110887

**Does Cumberland Investment Counsel Inc. state an account minimum?**
Its Form ADV Part 2A brochure dated August 13, 2026 says: "The minimum investment required to establish a client relationship is $1M. Under certain circumstances we may accept a lower minimum investment, subject to management review & approval on a case-by-case basis."

**What changed in Cumberland Investment Counsel Inc.'s recent Form ADV filings?**
In the September 2026 filing data: 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

### Fees and minimums (Form ADV Part 2A brochure dated August 13, 2026)

- Account minimum: $1,000,000

> The minimum investment required to establish a client relationship is $1M. Under certain circumstances we may accept a lower minimum investment, subject to management review & approval on a case-by-case basis.

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.
- National Bank Financial 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: $1,405,771,456
- Discretionary: $1,405,771,456
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 23 | $38,807,020 |
| High net worth individuals | 12 | $31,687,525 |
| Banking or thrift institutions | 0 | Not reported |
| Investment companies | 0 | Not reported |
| Business development companies | 0 | Not reported |
| Pooled investment vehicles (other than investment companies and business development companies) | 10 | $1,328,131,003 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 0 | Not reported |
| Charitable organizations | 1 | $3,294,096 |
| State or municipal government entities (including government pension plans) | 0 | Not reported |
| Other investment advisers | 0 | Not reported |
| Insurance companies | 0 | Not reported |
| Sovereign wealth funds and foreign official institutions | 0 | Not reported |
| Corporations or other businesses not listed above | 2 | $3,851,812 |
| Other | 0 | $0 |

### 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

### Firm details
- Registered since: 1992 (34 years)
- Employees: 19 total, 16 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports 1 disclosure item on Form ADV Item 11.

### Item 11 questions answered yes
- 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?

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. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/110887

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

### Websites listed on Form ADV (Item 1.I)
- [cumberlandcounsel.com](https://cumberlandcounsel.com)

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $930,255,823 | 19 | May 25, 2021 |
| October 2022 | $1,116,641,922 | 23 | July 7, 2022 |
| October 2023 | $880,918,248 | 21 | September 15, 2023 |
| October 2024 | $1,011,784,499 | 21 | December 21, 2023 |
| October 2025 | $1,272,160,433 | 20 | April 11, 2025 |
| October 2026 | $1,405,771,456 | 19 | September 29, 2026 |

Regulatory assets under management: $930,255,823 in the October 2021 data and $1,405,771,456 in the October 2026 data, up 51%.
Total employees: 19 in October 2021 and 19 in October 2026.

## Changes in the filing (last 12 months)

### September 2026
- Updated its list of owners and control persons (Schedule A).

### January 2026
- No longer lists the business name Patrimoine Privé Cumberland.
- Added the business name Patrimoine Prive Cumberland.
- Employees performing advisory functions went from 17 to 16.
- Regulatory assets under management went from $1,272,160,433 to $1,405,771,456 (+11%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Cumberland Investment Counsel Inc. (CRD 110887): Form ADV filing data as of October 2026.
