# Polen Capital Management, LLC

> Polen Capital Management, LLC is an SEC-registered investment advisory firm in Boca Raton, FL, registered since 1980, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated September 30, 2026.

- CRD: 106093
- Filed as: POLEN CAPITAL MANAGEMENT, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Boca Raton, FL
- Filing period: October 2026
- Form ADV filing dated: September 30, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/106093
- AdvisorCensus page: https://advisorcensus.com/firm/polen-capital-management-llc-boca-raton-fl-106093

## Quick answers

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

**Where is Polen Capital Management, LLC located?**
Polen Capital Management, LLC's principal office is in Boca Raton, FL, according to its Form ADV; the October 2026 filing also lists 3 other offices (Schedule D, Section 1.F).

**Is Polen Capital Management, LLC registered with the SEC or a state?**
Polen Capital Management, LLC is an SEC-registered investment advisory firm, registered since 1980. Status as filed: Approved. CRD 106093.

**How much does Polen Capital Management, LLC manage?**
Polen Capital Management, LLC reports $24,061,099,864 in regulatory assets under management in its Form ADV filing dated September 30, 2026 (100% discretionary).

**How have Polen Capital Management, LLC's assets and staff changed since 2021?**
In the Form ADV data for Polen Capital Management, LLC: Regulatory assets under management: $46,029,107,670 in the October 2021 data and $24,061,099,864 in the October 2026 data, down 48%. Total employees: 116 in October 2021 and 168 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Polen Capital Management, LLC serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (1,347); other investment advisers (85); corporations or other businesses not listed above (48).

**Which custodians does Polen Capital Management, LLC use?**
Polen Capital Management, LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Morgan Stanley, State Street Bank and UBS Financial Services Inc as custodians holding 10% or more of its separately managed account assets.

**Does Polen 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/106093

**What changed in Polen Capital Management, LLC's recent Form ADV filings?**
In the October 2026 filing data: 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

### Custodians (Schedule D, Section 5.K(3))
- Morgan Stanley
- State Street Bank
- UBS Financial Services 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: $24,061,099,864
- Discretionary: $24,061,099,864
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | $0 |
| High net worth individuals | 1,347 | $1,373,093,151 |
| Banking or thrift institutions | 0 | $0 |
| Investment companies | 14 | $5,227,780,615 |
| Business development companies | 0 | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | 18 | $3,784,953,990 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 22 | $1,690,619,115 |
| Charitable organizations | 42 | $437,177,761 |
| State or municipal government entities (including government pension plans) | 26 | $1,650,002,896 |
| Other investment advisers | 85 | $8,824,606,218 |
| Insurance companies | Fewer than 5 | $13,177,789 |
| Sovereign wealth funds and foreign official institutions | Fewer than 5 | $260,203,583 |
| Corporations or other businesses not listed above | 48 | $799,484,746 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- 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

### Firm details
- Registered since: 1980 (46 years)
- Employees: 168 total, 22 performing advisory functions
- Wrap fee program participation: Yes
- States registered or notice-filed: AK, AL, AR, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VA, VI, VT, WA, WI, WV
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the October 2026 filing
- Boston, MA
- Chicago, IL
- Waltham, MA

### Websites listed on Form ADV (Item 1.I)
- [glassdoor.com/Overview/Working-at-Polen-Capital-EI_IE3242095.11,24.htm](https://glassdoor.com/Overview/Working-at-Polen-Capital-EI_IE3242095.11,24.htm)
- [polencapital.com](https://polencapital.com)
- [vimeo.com/POLENCAPITAL](https://vimeo.com/POLENCAPITAL)
- LinkedIn @polen-capital-management
- YouTube @UCi9uXI1OPFDCXPNeALVJEoA

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $46,029,107,670 | 116 | March 25, 2021 |
| October 2022 | $63,470,965,574 | 142 | March 25, 2022 |
| October 2023 | $36,045,083,867 | 153 | June 6, 2023 |
| October 2024 | $43,238,955,480 | 173 | May 24, 2024 |
| October 2025 | $37,703,918,773 | 229 | May 6, 2025 |
| October 2026 | $24,061,099,864 | 168 | September 30, 2026 |

Regulatory assets under management: $46,029,107,670 in the October 2021 data and $24,061,099,864 in the October 2026 data, down 48%.
Total employees: 116 in October 2021 and 168 in October 2026.

## Changes in the filing (last 12 months)

### October 2026
- Updated its list of owners and control persons (Schedule A).

### April 2026
- Employees performing advisory functions went from 43 to 22.
- Regulatory assets under management went from $37,703,918,773 to $24,061,099,864 (-36%).
- Added an office in Chicago, IL.

### February 2026
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Polen Capital Management, LLC (CRD 106093): Form ADV filing data as of October 2026.