# Gresham Investment Management LLC

> Gresham Investment Management LLC is an SEC-registered investment advisory firm in New York, NY, registered since 2005, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated June 3, 2026.

- CRD: 134392
- Filed as: GRESHAM INVESTMENT MANAGEMENT LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: New York, NY
- Filing period: October 2026
- Form ADV filing dated: June 3, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/134392
- AdvisorCensus page: https://advisorcensus.com/firm/gresham-investment-management-llc-new-york-ny-134392

## Quick answers

**How is Gresham Investment Management LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Gresham Investment Management LLC reports these compensation arrangements: a percentage of assets under its management; performance-based fees. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Gresham Investment Management LLC located?**
Gresham Investment Management LLC's principal office is in New York, NY, according to its Form ADV.

**Is Gresham Investment Management LLC registered with the SEC or a state?**
Gresham Investment Management LLC is an SEC-registered investment advisory firm, registered since 2005. Status as filed: Approved. CRD 134392.

**How much does Gresham Investment Management LLC manage?**
Gresham Investment Management LLC reports $8,551,134,228 in regulatory assets under management in its Form ADV filing dated June 3, 2026 (100% discretionary).

**How have Gresham Investment Management LLC's assets and staff changed since 2021?**
In the Form ADV data for Gresham Investment Management LLC: Regulatory assets under management: $5,499,174,313 in the October 2021 data and $8,551,134,228 in the October 2026 data, up 55%. Total employees: 40 in October 2021 and 41 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Gresham Investment Management LLC serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (11); state or municipal government entities (including government pension plans) (6); other (4).

**Which custodians does Gresham Investment Management LLC use?**
Gresham Investment Management LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists SG Americas Securities, LLC as a custodian holding 10% or more of its separately managed account assets.

**Does Gresham Investment Management LLC 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/134392

**What changed in Gresham Investment Management LLC's recent Form ADV filings?**
In the July 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

### Custodians (Schedule D, Section 5.K(3))
- SG Americas Securities, 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.

### Regulatory assets under management (Item 5.F)
- Total: $8,551,134,228
- Discretionary: $8,551,134,228
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | Not reported |
| High net worth individuals | 0 | Not reported |
| 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) | 11 | $4,067,382,220 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 0 | Not reported |
| Charitable organizations | 0 | Not reported |
| State or municipal government entities (including government pension plans) | 6 | $3,811,339,488 |
| Other investment advisers | 0 | Not reported |
| Insurance companies | 0 | Not reported |
| Sovereign wealth funds and foreign official institutions | 2 | $524,287,753 |
| Other | 4 | $148,124,767 |

### Advisory services (Item 5.G)
- 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)

### Firm details
- Registered since: 2005 (21 years)
- Employees: 41 total, 18 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: DE
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- [greshamllc.com](https://greshamllc.com)
- LinkedIn @gresham-investment-management

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $5,499,174,313 | 40 | June 22, 2021 |
| October 2022 | $5,966,278,806 | 39 | August 10, 2022 |
| October 2023 | $6,499,285,889 | 40 | March 31, 2023 |
| October 2024 | $6,171,203,123 | 47 | September 18, 2024 |
| October 2025 | $6,768,770,741 | 43 | March 27, 2025 |
| October 2026 | $8,551,134,228 | 41 | June 3, 2026 |

Regulatory assets under management: $5,499,174,313 in the October 2021 data and $8,551,134,228 in the October 2026 data, up 55%.
Total employees: 40 in October 2021 and 41 in October 2026.

## Changes in the filing (last 12 months)

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

### May 2026
- Item 11 disclosure answers changed: 0 yes answers, previously 2 (now no: 11.D(2), 11.D(4)).
- Updated its list of owners and control persons (Schedule A).

### April 2026
- Regulatory assets under management went from $6,900,655,741 to $8,551,134,228 (+24%).
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Gresham Investment Management LLC (CRD 134392): Form ADV filing data as of October 2026.