Marcellus Investment Managers Private Limited

• A percentage of assets under your management
• Fixed fees (other than subscription fees)
• 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 brochure for them.

Account minimum: $60,000

As stated in the firm's Form ADV Part 2A brochure dated June 17, 2026. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site

$315,209,572 as of October 2026, filing dated June 17, 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 pooled investment vehicles (other than investment companies)
• Portfolio management for businesses (other than small businesses) or institutional clients
• Publication of periodicals or newsletters

Registration

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

Registered since

2022 (4 years)

Employees

Total: 69. Performing investment advisory functions: 23.

Wrap fee program participation

No.

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

HDFC Bank LimitedKotak Mahindra Bank Limited

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)

1 other office, as of the July 2026 filing

Gandhinagar, Gujarat

States registered or notice-filed

16 states or jurisdictions

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

1 Reports 1 disclosure item on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.D(4) In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?

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. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $1,308,083,958 in the October 2022 data and $315,209,572 in the October 2026 data, down 76%.

Total employees: 100 in October 2022 and 69 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. July 2026
   • Employees performing advisory functions went from 32 to 23.
   • Regulatory assets under management went from $603,401,560 to $315,209,572 (-48%).
   • Changed its office addresses in Gandhinagar, Gujarat.
   • No longer lists an office in New York, NY.
2. May 2026
   • Updated its list of owners and control persons (Schedule A).

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