Pender Capital Management, LLC

• A percentage of assets under your management
• Performance-based fees
• Other

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

See the firm's brochure (dated March 23, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$661,353,829 as of October 2026, filing dated March 23, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Portfolio management for investment companies (and business development companies)
• Portfolio management for pooled investment vehicles (other than investment companies)

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2018 (8 years)

Employees

Total: 14. Performing investment advisory functions: 13.

Wrap fee program participation

No.

Other offices (Schedule D, Section 1.F)

1 other office, as of the April 2026 filing

Los Angeles, CA

States registered or notice-filed

2 states or jurisdictions

CATX

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

2 Reports 2 disclosure items on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.D(3) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?
• 11.D(5) Has another federal regulator, a state regulator, or a foreign financial regulator ever denied, suspended, or revoked the registration or license of the firm or an advisory affiliate, prevented either by order from associating with an investment-related business, or restricted either one's 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. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $269,695,072 in the October 2021 data and $661,353,829 in the October 2026 data, up 145%.

Total employees: 12 in October 2021 and 14 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. April 2026
   • Regulatory assets under management went from $505,813,245 to $661,353,829 (+31%).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.