Denali Advisors, 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

The brochure lists different fees for different services or strategies. See the firm's brochure (dated March 27, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$1,387,865,090 as of October 2026, filing dated March 27, 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 individuals and/or small businesses
• Portfolio management for businesses (other than small businesses) or institutional clients
• Other

Registration

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

Registered since

2001 (25 years)

Employees

Total: 14. Performing investment advisory functions: 9.

Wrap fee program participation

Yes.

Custodians (Schedule D, Section 5.K(3))

BNY Mellon Capital Markets, LLCCharles Schwab & Co., Inc.HSBC Securities (USA) Inc.Northern Trust Securities, Inc.State Street Global Markets, 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.

Other offices (Schedule D, Section 1.F)

2 other offices, as of the April 2026 filing

Anchorage, AKChicago, IL

States registered or notice-filed

52 states or jurisdictions

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

None Reports no disclosure items on Form ADV Item 11. View on IAPD.

Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $729,337,943 in the October 2021 data and $1,387,865,090 in the October 2026 data, up 90%.

Total employees: 14 in October 2021 and 14 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
   • Regulatory assets under management went from $1,198,606,479 to $1,387,865,090 (+16%).
2. December 2025
   • Item 11 disclosure answers changed: 0 yes answers, previously 2 (now no: 11.D(2), 11.D(4)).

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