# Paul Comstock Partners

> 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.

- CRD: 105335
- Filed as: PAUL COMSTOCK PARTNERS
- Legal name: First Endowment Development Corp
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Houston, TX
- Filing period: October 2026
- Form ADV filing dated: May 22, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/105335
- AdvisorCensus page: https://advisorcensus.com/firm/paul-comstock-partners-houston-tx-105335

## Quick answers

**How is Paul Comstock Partners compensated?**
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).

**What does Paul Comstock Partners' brochure say about its fees?**
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.

**Where is Paul Comstock Partners located?**
Paul Comstock Partners' principal office is in Houston, TX, according to its Form ADV.

**Is Paul Comstock Partners registered with the SEC or a state?**
Paul Comstock Partners is an SEC-registered investment advisory firm, registered since 1984. Status as filed: Approved. CRD 105335.

**How much does Paul Comstock Partners manage?**
Paul Comstock Partners reports $2,800,211,607 in regulatory assets under management in its Form ADV filing dated May 22, 2026 (9% discretionary).

**How have Paul Comstock Partners' assets and staff changed since 2021?**
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.

**What types of clients does Paul Comstock Partners serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (109); charitable organizations (11).

**Which custodians does Paul Comstock Partners use?**
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.

**Does Paul Comstock Partners 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/105335

**Does Paul Comstock Partners state an account minimum?**
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."

**What changed in Paul Comstock Partners' recent Form ADV filings?**
In the June 2026 filing data: Employees performing advisory functions went from 10 to 11.

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Fixed fees (other than subscription fees)

### Fees and minimums (Form ADV Part 2A brochure dated April 15, 2026)

- Asset-based fee: 0.2% to 0.7% a year (a range, as the brochure states it)

> 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.

- Account minimum: $10,000,000 (the brochure says it may be waived or negotiated)

> 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.

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

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., Inc.
- Northern Trust

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: $2,800,211,607
- Discretionary: $260,017,465
- Non-discretionary: $2,540,194,142

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| High net worth individuals | 109 | $2,268,764,084 |
| Charitable organizations | 11 | $531,447,523 |

### Advisory services (Item 5.G)
- 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)

### Firm details
- Registered since: 1984 (41 years)
- Employees: 16 total, 11 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, CO, CT, DE, FL, MA, NY, TX, UT
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- paulcomstockpartners.com
- LinkedIn @paulcomstockpartners

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $2,789,443,496 | 14 | April 9, 2021 |
| October 2022 | $3,365,393,181 | 14 | February 28, 2022 |
| October 2023 | $2,857,791,123 | 14 | May 11, 2023 |
| October 2024 | $2,031,373,540 | 16 | May 31, 2024 |
| October 2025 | $2,238,868,684 | 17 | April 16, 2025 |
| October 2026 | $2,800,211,607 | 16 | May 22, 2026 |

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.

## Changes in the filing (last 12 months)

### June 2026
- Employees performing advisory functions went from 10 to 11.

### April 2026
- 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%).

### February 2026
- Employees performing advisory functions went from 9 to 8.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Paul Comstock Partners (CRD 105335): Form ADV filing data as of October 2026.