{
  "crd_number": 105335,
  "slug": "paul-comstock-partners-houston-tx-105335",
  "primary_business_name": "PAUL COMSTOCK PARTNERS",
  "legal_name": "FIRST ENDOWMENT DEVELOPMENT CORP",
  "dbas": [],
  "city": "Houston",
  "state": "TX",
  "country": "United States",
  "cbsa_code": "26420",
  "metro": {
    "cbsa_code": "26420",
    "common_name": "Houston",
    "msa_name": "Houston-Pasadena-The Woodlands, TX",
    "path": "/advisors/tx/houston"
  },
  "registration_type": "sec",
  "registration_status": "Approved",
  "registration_date": "1984-11-05",
  "years_registered": 41,
  "period": "2026-10-01",
  "filing_date": "2026-05-22",
  "carried_forward": false,
  "raum_total": 2800211607.0,
  "raum_discretionary": 260017465.0,
  "raum_non_discretionary": 2540194142.0,
  "raum_band": "1b_5b",
  "raum_band_label": "$1 billion to $5 billion",
  "total_employees": 16,
  "advisory_employees": 11,
  "client_count_bucket": null,
  "clients_by_type": {
    "charitable": {
      "raum": 531447523.0,
      "count": 11
    },
    "high_net_worth_individuals": {
      "raum": 2268764084.0,
      "count": 109
    }
  },
  "compensation_types": [
    "fixed",
    "percentage_of_aum"
  ],
  "advisory_activities": [
    "financial_planning",
    "portfolio_management_businesses_institutional",
    "portfolio_management_individuals",
    "selection_of_other_advisers"
  ],
  "wrap_fee_participant": false,
  "disclosure_yes_count": 0,
  "states_registered": [
    "CA",
    "CO",
    "CT",
    "DE",
    "FL",
    "MA",
    "NY",
    "TX",
    "UT"
  ],
  "websites": [
    "https://linkedin.com/company/paulcomstockpartners",
    "https://paulcomstockpartners.com"
  ],
  "iapd_url": "https://adviserinfo.sec.gov/firm/summary/105335",
  "city_as_filed": "HOUSTON",
  "url": "https://advisorcensus.com/firm/paul-comstock-partners-houston-tx-105335",
  "display_name": "Paul Comstock Partners",
  "summary": "Paul Comstock Partners is an SEC-registered investment advisory firm in Houston, TX, registered since 1984, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated May 22, 2026.",
  "citation": "AdvisorCensus. Paul Comstock Partners (CRD 105335): Form ADV filing data as of October 2026.",
  "registration_type_label": "SEC-registered investment adviser",
  "compensation_labels": [
    "A percentage of assets under your management",
    "Fixed fees (other than subscription fees)"
  ],
  "advisory_activity_labels": [
    "Financial planning services",
    "Portfolio management for individuals and/or small businesses",
    "Portfolio management for businesses (other than small businesses) or institutional clients",
    "Selection of other advisers (including private fund managers)"
  ],
  "quick_answers": [
    {
      "q": "How is Paul Comstock Partners compensated?",
      "a": "On its Form ADV (Item 5.E, October 2026), Paul Comstock Partners reports these compensation arrangements: a percentage of assets under its management; fixed fees (other than subscription fees)."
    },
    {
      "q": "How much does Paul Comstock Partners charge?",
      "a": "Its Form ADV Part 2A brochure dated April 15, 2026 states: Asset-based fee: 0.2% to 0.7% a year (a range, as the brochure states it). Fees can differ by service and may be negotiable; the brochure is the complete statement."
    },
    {
      "q": "Where is Paul Comstock Partners located?",
      "a": "Paul Comstock Partners' principal office is in Houston, TX, according to its Form ADV."
    },
    {
      "q": "Is Paul Comstock Partners registered with the SEC or a state?",
      "a": "Paul Comstock Partners is an SEC-registered investment advisory firm, registered since 1984. Status as filed: Approved. CRD 105335."
    },
    {
      "q": "How much does Paul Comstock Partners manage?",
      "a": "Paul Comstock Partners reports $2,800,211,607 in regulatory assets under management in its Form ADV filing dated May 22, 2026 (9% discretionary)."
    },
    {
      "q": "How have Paul Comstock Partners' assets and staff changed since 2021?",
      "a": "In the Form ADV data for Paul Comstock Partners: Regulatory assets under management: $2,789,443,496 in the October 2021 data and $2,800,211,607 in the October 2026 data, unchanged. Total employees: 14 in October 2021 and 16 in October 2026. Assets under management move with markets as well as with clients coming and going."
    },
    {
      "q": "What types of clients does Paul Comstock Partners serve?",
      "a": "By number of clients on Form ADV Item 5.D: high net worth individuals (109); charitable organizations (11)."
    },
    {
      "q": "Which custodians does Paul Comstock Partners use?",
      "a": "Paul Comstock Partners' most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. and Northern Trust as custodians holding 10% or more of its separately managed account assets."
    },
    {
      "q": "Does Paul Comstock Partners report any disciplinary disclosures?",
      "a": "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/105335"
    },
    {
      "q": "Does Paul Comstock Partners state an account minimum?",
      "a": "Its Form ADV Part 2A brochure dated April 15, 2026 says: \"For new clients, Comstock generally requires a minimum of $10,000,000 in assets under management. Exceptions to the minimum are made at the sole discretion of Comstock.\""
    },
    {
      "q": "What changed in Paul Comstock Partners' recent Form ADV filings?",
      "a": "In the June 2026 filing data: Employees performing advisory functions went from 10 to 11."
    }
  ],
  "filing_history": [
    {
      "period": "2021-10-01",
      "regulatory_assets_under_management": 2789443496.0,
      "total_employees": 14,
      "filing_date": "2021-04-09"
    },
    {
      "period": "2022-10-01",
      "regulatory_assets_under_management": 3365393181.0,
      "total_employees": 14,
      "filing_date": "2022-02-28"
    },
    {
      "period": "2023-10-01",
      "regulatory_assets_under_management": 2857791123.0,
      "total_employees": 14,
      "filing_date": "2023-05-11"
    },
    {
      "period": "2024-10-01",
      "regulatory_assets_under_management": 2031373540.0,
      "total_employees": 16,
      "filing_date": "2024-05-31"
    },
    {
      "period": "2025-10-01",
      "regulatory_assets_under_management": 2238868684.0,
      "total_employees": 17,
      "filing_date": "2025-04-16"
    },
    {
      "period": "2026-10-01",
      "regulatory_assets_under_management": 2800211607.0,
      "total_employees": 16,
      "filing_date": "2026-05-22"
    }
  ],
  "recent_changes": [
    {
      "period": "2026-06-01",
      "period_label": "June 2026",
      "notes": [
        "Employees performing advisory functions went from 10 to 11."
      ]
    },
    {
      "period": "2026-04-01",
      "period_label": "April 2026",
      "notes": [
        "Employees performing advisory functions went from 8 to 10.",
        "Regulatory assets under management went from $2,238,868,684 to $2,800,211,607 (+25%)."
      ]
    },
    {
      "period": "2026-02-01",
      "period_label": "February 2026",
      "notes": [
        "Employees performing advisory functions went from 9 to 8."
      ]
    }
  ],
  "fees_from_brochure": {
    "source": "Form ADV Part 2A brochure dated April 15, 2026",
    "provided_by_the_firm": false,
    "tiers": [],
    "flat_rate": null,
    "stated_range": "0.2% to 0.7% a year",
    "stated_maximum": null,
    "account_minimum": "$10,000,000",
    "account_minimum_may_be_waived": true,
    "minimum_annual_fee": null,
    "planning_fees": [],
    "figures": [
      {
        "label": "Asset-based fee",
        "statements": [
          "Asset-based fee: 0.2% to 0.7% a year (a range, as the brochure states it)"
        ],
        "quotes": [
          "Other clients are charged a fee as a percentage of assets. Annual fees range from 0. 20% to 0. 70% per year based on the value of the managed portfolio and scope of services Comstock provides."
        ]
      },
      {
        "label": "Account minimum",
        "statements": [
          "Account minimum: $10,000,000 (the brochure says it may be waived or negotiated)"
        ],
        "quotes": [
          "For new clients, Comstock generally requires a minimum of $10,000,000 in assets under management. Exceptions to the minimum are made at the sole discretion of Comstock."
        ]
      }
    ],
    "values": {
      "tiers": [],
      "range_pct": [
        0.2,
        0.7
      ],
      "max_pct": null,
      "account_minimum": 10000000.0,
      "minimum_annual_fee": null,
      "planning": []
    },
    "quotes": [
      "Other clients are charged a fee as a percentage of assets. Annual fees range from 0. 20% to 0. 70% per year based on the value of the managed portfolio and scope of services Comstock provides.",
      "For new clients, Comstock generally requires a minimum of $10,000,000 in assets under management. Exceptions to the minimum are made at the sole discretion of Comstock."
    ],
    "note": "As stated in the firm's brochure; fees can differ by service and may be negotiable."
  },
  "custodians": [
    {
      "name": "Charles Schwab & Co., Inc.",
      "name_as_filed": "CHARLES SCHWAB & CO., INC.",
      "affiliated": false
    },
    {
      "name": "Northern Trust",
      "name_as_filed": "NORTHERN TRUST",
      "affiliated": false
    }
  ],
  "custodians_note": "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.",
  "markdown_url": "https://advisorcensus.com/firm/paul-comstock-partners-houston-tx-105335.md",
  "clients": [
    {
      "type": "high_net_worth_individuals",
      "label": "High net worth individuals",
      "count": 109,
      "fewer_than_5": false,
      "raum": 2268764084.0
    },
    {
      "type": "charitable",
      "label": "Charitable organizations",
      "count": 11,
      "fewer_than_5": false,
      "raum": 531447523.0
    }
  ],
  "disclosure_line": "Reports no disclosure items on Form ADV Item 11.",
  "disclosure_items": [],
  "indexable": true,
  "suppressed": false,
  "claimed": false,
  "enhanced": false,
  "provided_by_the_firm": null,
  "source": {
    "name": "Form ADV",
    "as_of": "2026-10-01",
    "iapd_url": "https://adviserinfo.sec.gov/firm/summary/105335",
    "operator": "BH Monitor Services, LLC",
    "license": "https://creativecommons.org/licenses/by/4.0/",
    "credit": "AdvisorCensus (advisorcensus.com), from SEC Form ADV data"
  }
}