# Dunham

> Dunham is an SEC-registered investment advisory firm in San Diego, CA, registered since 1985, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated July 15, 2026.

- CRD: 13162
- Filed as: DUNHAM
- Legal name: Dunham & Associates Investment Counsel, Inc.
- Also doing business as: DUNHAM
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: San Diego, CA
- Filing period: October 2026
- Form ADV filing dated: July 15, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/13162
- AdvisorCensus page: https://advisorcensus.com/firm/dunham-san-diego-ca-13162

## Quick answers

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

**Where is Dunham located?**
Dunham's principal office is in San Diego, CA, according to its Form ADV; the August 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Dunham registered with the SEC or a state?**
Dunham is an SEC-registered investment advisory firm, registered since 1985. Status as filed: Approved. CRD 13162.

**How much does Dunham manage?**
Dunham reports $5,627,638,262 in regulatory assets under management in its Form ADV filing dated July 15, 2026 (84% discretionary).

**How have Dunham's assets and staff changed since 2021?**
In the Form ADV data for Dunham: Regulatory assets under management: $2,152,591,097 in the October 2021 data and $5,627,638,262 in the October 2026 data, up 161%. Total employees: 29 in October 2021 and 43 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Dunham serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (10,820); high net worth individuals (1,954); corporations or other businesses not listed above (172).

**Which custodians does Dunham use?**
Dunham's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Fifth Third Bank as a custodian holding 10% or more of its separately managed account assets.

**Does Dunham 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/13162

**What changed in Dunham's recent Form ADV filings?**
In the May 2026 filing data: Changed its office addresses in Reno, NV.

## From the Form ADV filing

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

### Custodians (Schedule D, Section 5.K(3))
- Fifth Third Bank

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: $5,627,638,262
- Discretionary: $4,739,354,000
- Non-discretionary: $888,284,262

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 10,820 | $1,971,840,525 |
| High net worth individuals | 1,954 | $3,155,958,769 |
| Banking or thrift institutions | Fewer than 5 | $0 |
| Investment companies | 15 | $335,678,844 |
| Business development companies | 0 | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | 0 | $0 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 45 | $25,923,959 |
| Charitable organizations | 149 | $38,540,927 |
| State or municipal government entities (including government pension plans) | Fewer than 5 | $0 |
| Other investment advisers | Fewer than 5 | $0 |
| Insurance companies | Fewer than 5 | $0 |
| Sovereign wealth funds and foreign official institutions | Fewer than 5 | $0 |
| Corporations or other businesses not listed above | 172 | $99,695,238 |
| Other | 0 | $0 |

### Advisory services (Item 5.G)
- Financial planning services
- Portfolio management for individuals and/or small businesses
- Portfolio management for investment companies (and business development companies)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients
- Selection of other advisers (including private fund managers)
- Other

### Firm details
- Registered since: 1985 (40 years)
- Employees: 43 total, 9 performing advisory functions
- Wrap fee program participation: Yes
- States registered or notice-filed: AZ, CA, CO, CT, FL, NJ, NV, NY, OR, TX, UT, VA, WA, WY
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the August 2026 filing
- Reno, NV

### Websites listed on Form ADV (Item 1.I)
- dunham.com
- landing.dunham.com/dab2026
- landing.dunham.com/wotgr
- Instagram @dunhaminsights
- LinkedIn @dunham-associates-352864285
- YouTube @dunham745

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $2,152,591,097 | 29 | March 30, 2021 |
| October 2022 | $3,043,067,911 | 29 | September 30, 2022 |
| October 2023 | $2,901,635,752 | 33 | October 1, 2023 |
| October 2024 | $3,763,899,427 | 34 | September 30, 2024 |
| October 2025 | $4,737,607,372 | 39 | April 23, 2025 |
| October 2026 | $5,627,638,262 | 43 | July 15, 2026 |

Regulatory assets under management: $2,152,591,097 in the October 2021 data and $5,627,638,262 in the October 2026 data, up 161%.
Total employees: 29 in October 2021 and 43 in October 2026.

## Changes in the filing (last 12 months)

### May 2026
- Changed its office addresses in Reno, NV.

### April 2026
- Regulatory assets under management went from $4,737,607,372 to $5,627,638,262 (+19%).
- Registered or notice-filed in OR, UT, WA, WY.

### March 2026
- Changed its office addresses in Reno, NV.

### December 2025
- Updated its list of owners and control persons (Schedule A).

### November 2025
- Added the business name Dunham.
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Dunham (CRD 13162): Form ADV filing data as of October 2026.