# Polaris Capital Management, LLC

> Polaris Capital Management, LLC is an SEC-registered investment advisory firm in Boston, MA, registered since 1993, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated January 30, 2026.

- CRD: 106278
- Filed as: POLARIS CAPITAL MANAGEMENT, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Boston, MA
- Filing period: October 2026
- Form ADV filing dated: January 30, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/106278
- AdvisorCensus page: https://advisorcensus.com/firm/polaris-capital-management-llc-boston-ma-106278

## Quick answers

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

**How much does Polaris Capital Management, LLC charge?**
Its Form ADV Part 2A brochure dated January 30, 2026 states: Asset-based fee: 0.75% of assets a year. Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Polaris Capital Management, LLC located?**
Polaris Capital Management, LLC's principal office is in Boston, MA, according to its Form ADV; the February 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Polaris Capital Management, LLC registered with the SEC or a state?**
Polaris Capital Management, LLC is an SEC-registered investment advisory firm, registered since 1993. Status as filed: Approved. CRD 106278.

**How much does Polaris Capital Management, LLC manage?**
Polaris Capital Management, LLC reports $5,452,307,694 in regulatory assets under management in its Form ADV filing dated January 30, 2026 (100% discretionary).

**How have Polaris Capital Management, LLC's assets and staff changed since 2021?**
In the Form ADV data for Polaris Capital Management, LLC: Regulatory assets under management: $14,294,560,641 in the October 2021 data and $5,452,307,694 in the October 2026 data, down 62%. Total employees: 18 in October 2021 and 18 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Polaris 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) (7); investment companies (5); pension and profit sharing plans (but not the plan participants or government pension plans) (5).

**Which custodians does Polaris Capital Management, LLC use?**
Polaris Capital Management, LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists BNY Mellon, JP Morgan, Northern Trust and State Street Bank & Trust Company as custodians holding 10% or more of its separately managed account assets.

**Does Polaris 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/106278

**Does Polaris Capital Management, LLC state an account minimum?**
Its Form ADV Part 2A brochure dated January 30, 2026 says: "Separate account minimum $100 million"

**What changed in Polaris Capital Management, LLC's recent Form ADV filings?**
In the February 2026 filing data: Regulatory assets under management went from $8,901,029,329 to $5,452,307,694 (-39%). Added an office in Salem, NH. Registered or notice-filed in NH. Updated its list of owners and control persons (Schedule A).

## 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 January 30, 2026)

- Asset-based fee: 0.75% of assets a year

> Fees are billed monthly or quarterly in arrears, based on the market value of the portfolio. 0.75% on all assets

- Account minimum: $100,000,000

> Separate account minimum $100 million

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

### Custodians (Schedule D, Section 5.K(3))
- BNY Mellon
- JP Morgan
- Northern Trust
- State Street Bank & Trust Company

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: $5,452,307,694
- Discretionary: $5,452,307,694
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | Not reported |
| High net worth individuals | 0 | Not reported |
| Banking or thrift institutions | 0 | Not reported |
| Investment companies | 5 | $2,731,010,928 |
| Business development companies | 0 | Not reported |
| Pooled investment vehicles (other than investment companies and business development companies) | 7 | $943,636,817 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 5 | $938,529,314 |
| Charitable organizations | 1 | $48,960,080 |
| State or municipal government entities (including government pension plans) | 1 | $321,523,607 |
| Other investment advisers | 0 | Not reported |
| Insurance companies | 0 | Not reported |
| Sovereign wealth funds and foreign official institutions | 0 | Not reported |
| Corporations or other businesses not listed above | 0 | Not reported |
| Other | 5 | $468,646,948 |

### Advisory services (Item 5.G)
- Portfolio management for investment companies (and business development companies)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients
- Other

### Firm details
- Registered since: 1993 (33 years)
- Employees: 18 total, 10 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: MA, NH
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the February 2026 filing
- Salem, NH

### Websites listed on Form ADV (Item 1.I)
- bsky.app/PROFILE/POLARISCAPITAL.BSKY.SOCIAL
- polariscapital.com
- polarisfunds.com
- vimeo.com/POLARISCAPITAL
- Facebook @POLARISCAPITALMANAGEMENTLLC
- Instagram @POLARISCAPITALMANAGEMENTLLC
- LinkedIn @POLARIS-CAPITAL-MANAGEMENT
- X @POLARISBOSTON

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $14,294,560,641 | 18 | February 2, 2021 |
| October 2022 | $16,198,252,799 | 19 | February 22, 2022 |
| October 2023 | $12,425,022,064 | 21 | March 27, 2023 |
| October 2024 | $11,775,149,425 | 20 | March 28, 2024 |
| October 2025 | $8,901,029,329 | 18 | March 28, 2025 |
| October 2026 | $5,452,307,694 | 18 | January 30, 2026 |

Regulatory assets under management: $14,294,560,641 in the October 2021 data and $5,452,307,694 in the October 2026 data, down 62%.
Total employees: 18 in October 2021 and 18 in October 2026.

## Changes in the filing (last 12 months)

### February 2026
- Regulatory assets under management went from $8,901,029,329 to $5,452,307,694 (-39%).
- Added an office in Salem, NH.
- Registered or notice-filed in NH.
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Polaris Capital Management, LLC (CRD 106278): Form ADV filing data as of October 2026.