# Pugh Capital Management, Inc.

> Pugh Capital Management, Inc. is an SEC-registered investment advisory firm in Seattle, WA, registered since 1991, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated March 24, 2026.

- CRD: 111765
- Filed as: PUGH CAPITAL MANAGEMENT, INC.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Seattle, WA
- Filing period: October 2026
- Form ADV filing dated: March 24, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/111765
- AdvisorCensus page: https://advisorcensus.com/firm/pugh-capital-management-inc-seattle-wa-111765

## Quick answers

**How is Pugh Capital Management, Inc. compensated?**
On its Form ADV (Item 5.E, October 2026), Pugh Capital Management, 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 Pugh Capital Management, Inc. located?**
Pugh Capital Management, Inc.'s principal office is in Seattle, WA, according to its Form ADV.

**Is Pugh Capital Management, Inc. registered with the SEC or a state?**
Pugh Capital Management, Inc. is an SEC-registered investment advisory firm, registered since 1991. Status as filed: Approved. CRD 111765.

**How much does Pugh Capital Management, Inc. manage?**
Pugh Capital Management, Inc. reports $12,821,941,180 in regulatory assets under management in its Form ADV filing dated March 24, 2026 (100% discretionary).

**How have Pugh Capital Management, Inc.'s assets and staff changed since 2021?**
In the Form ADV data for Pugh Capital Management, Inc.: Regulatory assets under management: $10,068,152,334 in the October 2021 data and $12,821,941,180 in the October 2026 data, up 27%. Total employees: 24 in October 2021 and 39 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Pugh Capital Management, Inc. serve?**
By number of clients on Form ADV Item 5.D: state or municipal government entities (including government pension plans) (17); pension and profit sharing plans (but not the plan participants or government pension plans) (13); charitable organizations (11).

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

**Does Pugh Capital Management, Inc. 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/111765

## 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))
- State Street Bank and Trust Company
- The Bank of New York Mellon
- The Northern 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: $12,821,941,180
- Discretionary: $12,808,143,615
- Non-discretionary: $13,797,565

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | $0 |
| High net worth individuals | 0 | $0 |
| Banking or thrift institutions | Not reported | $0 |
| Investment companies | 0 | $0 |
| Business development companies | 0 | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | 2 | $277,129,194 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 13 | $2,508,816,889 |
| Charitable organizations | 11 | $900,264,749 |
| State or municipal government entities (including government pension plans) | 17 | $4,776,023,524 |
| Other investment advisers | 2 | $307,407,585 |
| Insurance companies | 2 | $1,890,108,828 |
| Sovereign wealth funds and foreign official institutions | 0 | $0 |
| Corporations or other businesses not listed above | 3 | $696,816,791 |
| Other | 2 | $1,465,373,620 |

### Advisory services (Item 5.G)
- 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: 1991 (35 years)
- Employees: 39 total, 22 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: WA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- pughcapital.com
- LinkedIn @pugh-capital-management-inc

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $10,068,152,334 | 24 | March 26, 2021 |
| October 2022 | $11,661,821,284 | 27 | March 24, 2022 |
| October 2023 | $9,930,016,807 | 26 | September 28, 2023 |
| October 2024 | $10,786,208,521 | 25 | June 6, 2024 |
| October 2025 | $13,139,004,601 | 38 | April 14, 2025 |
| October 2026 | $12,821,941,180 | 39 | March 24, 2026 |

Regulatory assets under management: $10,068,152,334 in the October 2021 data and $12,821,941,180 in the October 2026 data, up 27%.
Total employees: 24 in October 2021 and 39 in October 2026.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Pugh Capital Management, Inc. (CRD 111765): Form ADV filing data as of October 2026.