# Nine Ten Capital Management

> Nine Ten Capital Management is an SEC-registered investment advisory firm in Chicago, IL, registered since 2014, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated September 15, 2026.

- CRD: 171420
- Filed as: NINE TEN CAPITAL MANAGEMENT
- Legal name: Nine Ten Capital Management, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Chicago, IL
- Filing period: October 2026
- Form ADV filing dated: September 15, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/171420
- AdvisorCensus page: https://advisorcensus.com/firm/nine-ten-capital-management-chicago-il-171420

## Quick answers

**How is Nine Ten Capital Management compensated?**
On its Form ADV (Item 5.E, October 2026), Nine Ten Capital Management reports these compensation arrangements: a percentage of assets under its management; performance-based fees.

**Where is Nine Ten Capital Management located?**
Nine Ten Capital Management's principal office is in Chicago, IL, according to its Form ADV.

**Is Nine Ten Capital Management registered with the SEC or a state?**
Nine Ten Capital Management is an SEC-registered investment advisory firm, registered since 2014. Status as filed: Approved. CRD 171420.

**How much does Nine Ten Capital Management manage?**
Nine Ten Capital Management reports $480,553,393 in regulatory assets under management in its Form ADV filing dated September 15, 2026 (100% discretionary).

**How have Nine Ten Capital Management's assets and staff changed since 2021?**
In the Form ADV data for Nine Ten Capital Management: Regulatory assets under management: $952,342,377 in the October 2021 data and $480,553,393 in the October 2026 data, down 50%. Total employees: 4 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 Nine Ten Capital Management serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (1).

**Does Nine Ten Capital Management 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/171420

**Does Nine Ten Capital Management state an account minimum?**
Its Form ADV Part 2A brochure dated March 27, 2026 says: "There is a minimum initial investment of $250,000 in to the Fund."

**What changed in Nine Ten Capital Management's recent Form ADV filings?**
In the October 2026 filing data: Employees performing advisory functions went from 3 to 2. 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

### Fees and minimums (Form ADV Part 2A brochure dated March 27, 2026)

- Account minimum: $250,000

> There is a minimum initial investment of $250,000 in to the Fund.

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

### Regulatory assets under management (Item 5.F)
- Total: $480,553,393
- Discretionary: $480,553,393
- 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) | 1 | $480,553,393 |
| 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) | 0 | Not reported |
| Other investment advisers | 0 | Not reported |
| Insurance companies | 0 | Not reported |
| Sovereign wealth funds and foreign official institutions | 0 | Not reported |
| Corporations or other businesses not listed above | 0 | Not reported |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)

### Firm details
- Registered since: 2014 (12 years)
- Employees: 3 total, 2 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: IL, TX
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

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

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $952,342,377 | 4 | April 12, 2021 |
| October 2022 | $1,078,097,922 | 4 | March 9, 2022 |
| October 2023 | $687,438,554 | 5 | October 3, 2023 |
| October 2024 | $471,782,287 | 4 | March 4, 2024 |
| October 2025 | $445,447,429 | 4 | March 20, 2025 |
| October 2026 | $480,553,393 | 3 | September 15, 2026 |

Regulatory assets under management: $952,342,377 in the October 2021 data and $480,553,393 in the October 2026 data, down 50%.
Total employees: 4 in October 2021 and 3 in October 2026.

## Changes in the filing (last 12 months)

### October 2026
- Employees performing advisory functions went from 3 to 2.
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Nine Ten Capital Management (CRD 171420): Form ADV filing data as of October 2026.