# Kelley Investments

> Kelley Investments is an SEC-registered investment advisory firm, registered since 2007, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated September 9, 2026.

- CRD: 119099
- Filed as: KELLEY INVESTMENTS
- Legal name: Kelley Investments, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Filing period: October 2026
- Form ADV filing dated: September 9, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/119099
- AdvisorCensus page: https://advisorcensus.com/firm/kelley-investments-119099

## Quick answers

**How is Kelley Investments compensated?**
On its Form ADV (Item 5.E, October 2026), Kelley Investments reports these compensation arrangements: a percentage of assets under its management; hourly charges.

**How much does Kelley Investments charge?**
Its Form ADV Part 2A brochure dated February 12, 2026 states: Asset-based fee: up to 1.75% of assets a year (the maximum the brochure states); Hourly rate: $250 to $500 an hour (financial planning services). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Is Kelley Investments registered with the SEC or a state?**
Kelley Investments is an SEC-registered investment advisory firm, registered since 2007. Status as filed: Approved. CRD 119099.

**How much does Kelley Investments manage?**
Kelley Investments reports $237,956,390 in regulatory assets under management in its Form ADV filing dated September 9, 2026 (91% discretionary).

**How have Kelley Investments' assets and staff changed since 2021?**
In the Form ADV data for Kelley Investments: Regulatory assets under management: $135,154,383 in the October 2021 data and $237,956,390 in the October 2026 data, up 76%. 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 Kelley Investments serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (167); high net worth individuals (49).

**Which custodians does Kelley Investments use?**
Kelley Investments' most recent Form ADV filing (Schedule D, Section 5.K(3)) lists National Financial Services LLC as a custodian holding 10% or more of its separately managed account assets.

**Does Kelley Investments 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/119099

**What changed in Kelley Investments' recent Form ADV filings?**
In the October 2026 filing data: Added an office in Waterloo, IA. Registered or notice-filed in IA.

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Hourly charges

### Fees and minimums (Form ADV Part 2A brochure dated February 12, 2026)

- Asset-based fee: up to 1.75% of assets a year (the maximum the brochure states)

> The annual wealth management fee charged ranges up to a maximum of 1.75% of the assets held in the account (including cash and cash equivalents).

- Hourly rate: $250 to $500 an hour (financial planning services)

> Depending on the level and scope of financial planning services required our fees range from $250 to $500 per hour.

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

### Custodians (Schedule D, Section 5.K(3))
- National Financial Services 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: $237,956,390
- Discretionary: $216,480,191
- Non-discretionary: $21,476,199

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 167 | $76,280,088 |
| High net worth individuals | 49 | $161,676,302 |

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

### Firm details
- Registered since: 2007 (19 years)
- Employees: 3 total, 3 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, IA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

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

### Websites listed on Form ADV (Item 1.I)
- kelleyinvestments.com

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $135,154,383 | 3 | February 23, 2021 |
| October 2022 | $134,992,407 | 3 | July 6, 2022 |
| October 2023 | $143,487,387 | 3 | March 15, 2023 |
| October 2024 | $162,610,189 | 3 | September 5, 2024 |
| October 2025 | $195,574,353 | 3 | April 15, 2025 |
| October 2026 | $237,956,390 | 3 | September 9, 2026 |

Regulatory assets under management: $135,154,383 in the October 2021 data and $237,956,390 in the October 2026 data, up 76%.
Total employees: 3 in October 2021 and 3 in October 2026.

## Changes in the filing (last 12 months)

### October 2026
- Added an office in Waterloo, IA.
- Registered or notice-filed in IA.

### March 2026
- Regulatory assets under management went from $195,574,353 to $237,956,390 (+22%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Kelley Investments (CRD 119099): Form ADV filing data as of October 2026.