# Palestra Capital Management LLC

> Palestra Capital Management LLC is an SEC-registered investment advisory firm in New York, NY, registered since 2012, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 160535
- Filed as: PALESTRA CAPITAL MANAGEMENT LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: New York, NY
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/160535
- AdvisorCensus page: https://advisorcensus.com/firm/palestra-capital-management-llc-new-york-ny-160535

## Quick answers

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

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

**Is Palestra Capital Management LLC registered with the SEC or a state?**
Palestra Capital Management LLC is an SEC-registered investment advisory firm, registered since 2012. Status as filed: Approved. CRD 160535.

**How much does Palestra Capital Management LLC manage?**
Palestra Capital Management LLC reports $5,441,912,932 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (100% discretionary).

**How have Palestra Capital Management LLC's assets and staff changed since 2021?**
In the Form ADV data for Palestra Capital Management LLC: Regulatory assets under management: $6,557,218,456 in the October 2021 data and $5,441,912,932 in the October 2026 data, down 17%. Total employees: 23 in October 2021 and 21 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Palestra Capital Management LLC serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (6).

**Does Palestra Capital Management LLC report any disciplinary disclosures?**
Reports 3 disclosure items on Form ADV Item 11: yes answers to 11.C(2) (SEC or CFTC finding of a violation), 11.C(4) (SEC or CFTC order), and 11.C(5) (SEC or CFTC civil money penalty or cease-and-desist order). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/160535

**Does Palestra Capital Management LLC state an account minimum?**
Its Form ADV Part 2A brochure dated March 31, 2026 says: "Per the private funds ’ Offering Documents, investments in the private funds are subject to a $2 million minimum for initial investments only."

**What changed in Palestra Capital Management LLC's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 11 to 8.

## 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 31, 2026)

- Account minimum: $2,000,000

> Per the private funds ’ Offering Documents, investments in the private funds are subject to a $2 million minimum for initial investments only.

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

### Regulatory assets under management (Item 5.F)
- Total: $5,441,912,932
- Discretionary: $5,441,912,932
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | $0 |
| High net worth individuals | 0 | $0 |
| Banking or thrift institutions | 0 | $0 |
| Investment companies | 0 | $0 |
| Business development companies | 0 | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | 6 | $5,441,912,932 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 0 | $0 |
| Charitable organizations | 0 | $0 |
| State or municipal government entities (including government pension plans) | 0 | $0 |
| Other investment advisers | 0 | $0 |
| Insurance companies | 0 | $0 |
| Sovereign wealth funds and foreign official institutions | 0 | $0 |
| Corporations or other businesses not listed above | 0 | $0 |
| Other | 0 | $0 |

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

### Firm details
- Registered since: 2012 (14 years)
- Employees: 21 total, 8 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports 3 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.C(2): Has the SEC or the CFTC ever found that the firm or an advisory affiliate was involved in a violation of SEC or CFTC regulations or statutes?
- 11.C(4): Has the SEC or the CFTC ever entered an order against the firm or an advisory affiliate in connection with investment-related activity?
- 11.C(5): Has the SEC or the CFTC ever imposed a civil money penalty on the firm or an advisory affiliate, or ordered the firm or an advisory affiliate to cease and desist from an 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. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/160535

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $6,557,218,456 | 23 | June 17, 2021 |
| October 2022 | $5,589,028,727 | 24 | March 31, 2022 |
| October 2023 | $4,099,747,359 | 20 | March 31, 2023 |
| October 2024 | $4,480,219,060 | 22 | August 29, 2024 |
| October 2025 | $5,538,939,464 | 23 | March 31, 2025 |
| October 2026 | $5,441,912,932 | 21 | March 31, 2026 |

Regulatory assets under management: $6,557,218,456 in the October 2021 data and $5,441,912,932 in the October 2026 data, down 17%.
Total employees: 23 in October 2021 and 21 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 11 to 8.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Palestra Capital Management LLC (CRD 160535): Form ADV filing data as of October 2026.