# Pence Capital Management, LLC

> Pence Capital Management, LLC is an SEC-registered investment advisory firm in Newport Beach, CA, registered since 2023, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated March 30, 2026.

- CRD: 281739
- Filed as: PENCE CAPITAL MANAGEMENT, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Newport Beach, CA
- Filing period: October 2026
- Form ADV filing dated: March 30, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/281739
- AdvisorCensus page: https://advisorcensus.com/firm/pence-capital-management-llc-newport-beach-ca-281739

## Quick answers

**How is Pence Capital Management, LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Pence Capital Management, LLC reports these compensation arrangements: a percentage of assets under its management; hourly charges; other. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Pence Capital Management, LLC located?**
Pence Capital Management, LLC's principal office is in Newport Beach, CA, according to its Form ADV.

**Is Pence Capital Management, LLC registered with the SEC or a state?**
Pence Capital Management, LLC is an SEC-registered investment advisory firm, registered since 2023. Status as filed: Approved. CRD 281739.

**How much does Pence Capital Management, LLC manage?**
Pence Capital Management, LLC reports $1,536,678,991 in regulatory assets under management in its Form ADV filing dated March 30, 2026 (0% discretionary).

**How have Pence Capital Management, LLC's assets and staff changed since 2023?**
In the Form ADV data for Pence Capital Management, LLC: Regulatory assets under management: $1,031,035,699 in the October 2023 data and $1,536,678,991 in the October 2026 data, up 49%. Total employees: 9 in October 2023 and 14 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Pence Capital Management, LLC serve?**
By number of clients on Form ADV Item 5.D: other (6); investment companies (2); other investment advisers (1).

**Which custodians does Pence Capital Management, LLC use?**
Pence Capital Management, LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Advisors Asset Management, Inc. as a custodian holding 10% or more of its separately managed account assets.

**Does Pence Capital Management, LLC 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/281739

**What changed in Pence Capital Management, LLC's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 12 to 8. Regulatory assets under management went from $1,719,621,315 to $1,536,678,991 (-11%).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Hourly charges
- Other

### Custodians (Schedule D, Section 5.K(3))
- Advisors Asset Management, Inc.

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: $1,536,678,991
- Discretionary: $0
- Non-discretionary: $1,536,678,991

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Investment companies | 2 | $67,460,000 |
| Other investment advisers | 1 | $110,901,317 |
| Other | 6 | $1,358,317,674 |

### Advisory services (Item 5.G)
- Portfolio management for businesses (other than small businesses) or institutional clients
- Selection of other advisers (including private fund managers)

### Firm details
- Registered since: 2023 (3 years)
- Employees: 14 total, 8 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AR, CA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- pencecapital.com
- Facebook facebook.com
- LinkedIn @pencecapital
- LinkedIn @dryden-pence
- X @penecapital

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2023 | $1,031,035,699 | 9 | July 12, 2023 |
| October 2024 | $1,082,682,405 | 15 | June 13, 2024 |
| October 2025 | $1,362,823,783 | 17 | March 27, 2025 |
| October 2026 | $1,536,678,991 | 14 | March 30, 2026 |

Regulatory assets under management: $1,031,035,699 in the October 2023 data and $1,536,678,991 in the October 2026 data, up 49%.
Total employees: 9 in October 2023 and 14 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 12 to 8.
- Regulatory assets under management went from $1,719,621,315 to $1,536,678,991 (-11%).

### February 2026
- Regulatory assets under management went from $1,362,823,783 to $1,719,621,315 (+26%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Pence Capital Management, LLC (CRD 281739): Form ADV filing data as of October 2026.