# Polus Capital Management (US) Inc.

> Polus Capital Management (US) Inc. is an SEC-registered investment advisory firm in New York, NY, registered since 2023, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 323283
- Filed as: POLUS CAPITAL MANAGEMENT (US) INC.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: New York, NY
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/323283
- AdvisorCensus page: https://advisorcensus.com/firm/polus-capital-management-us-inc-new-york-ny-323283

## Quick answers

**How is Polus Capital Management (US) Inc. compensated?**
On its Form ADV (Item 5.E, October 2026), Polus Capital Management (US) Inc. 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 Polus Capital Management (US) Inc. located?**
Polus Capital Management (US) Inc.'s principal office is in New York, NY, according to its Form ADV.

**Is Polus Capital Management (US) Inc. registered with the SEC or a state?**
Polus Capital Management (US) Inc. is an SEC-registered investment advisory firm, registered since 2023. Status as filed: Approved. CRD 323283.

**How much does Polus Capital Management (US) Inc. manage?**
Polus Capital Management (US) Inc. reports $1,183,253,410 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (100% discretionary).

**How have Polus Capital Management (US) Inc.'s assets and staff changed since 2024?**
In the Form ADV data for Polus Capital Management (US) Inc.: Regulatory assets under management: $400,000,000 in the October 2024 data and $1,183,253,410 in the October 2026 data, up 196%. Total employees: 13 in October 2024 and 18 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Polus Capital Management (US) Inc. serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (3).

**Does Polus Capital Management (US) Inc. report any disciplinary disclosures?**
Reports 3 disclosure items on Form ADV Item 11: yes answers to 11.D(2) (another regulator's finding of a violation), 11.D(4) (another regulator's order in the past ten years), and 11.H(1)(b) (court finding of a violation). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/323283

**What changed in Polus Capital Management (US) Inc.'s recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 8 to 7. Regulatory assets under management went from $508,382,978 to $1,183,253,410 (+133%). 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

### Regulatory assets under management (Item 5.F)
- Total: $1,183,253,410
- Discretionary: $1,183,253,410
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 3 | $1,183,253,410 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)

### Firm details
- Registered since: 2023 (2 years)
- Employees: 18 total, 7 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: FL
- Disclosures (Item 11): Reports 3 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.D(2): Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
- 11.D(4): In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?
- 11.H(1)(b): Has a domestic or foreign court ever found that the firm or an advisory affiliate was involved in a violation of investment-related statutes or regulations?

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. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/323283

### Websites listed on Form ADV (Item 1.I)
- [poluscapital.com](https://poluscapital.com)
- LinkedIn @polus-capital-management

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2024 | $400,000,000 | 13 | August 15, 2024 |
| October 2025 | $508,382,978 | 18 | June 6, 2025 |
| October 2026 | $1,183,253,410 | 18 | March 31, 2026 |

Regulatory assets under management: $400,000,000 in the October 2024 data and $1,183,253,410 in the October 2026 data, up 196%.
Total employees: 13 in October 2024 and 18 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 8 to 7.
- Regulatory assets under management went from $508,382,978 to $1,183,253,410 (+133%).
- Updated its list of owners and control persons (Schedule A).

### January 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. Polus Capital Management (US) Inc. (CRD 323283): Form ADV filing data as of October 2026.