# Punch Card Management

> Punch Card Management is an SEC-registered investment advisory firm in Winter Park, FL, registered since 2014, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated March 26, 2026.

- CRD: 162939
- Filed as: PUNCH CARD MANAGEMENT
- Legal name: Punch Card Management LP
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Winter Park, FL
- Filing period: October 2026
- Form ADV filing dated: March 26, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/162939
- AdvisorCensus page: https://advisorcensus.com/firm/punch-card-management-winter-park-fl-162939

## Quick answers

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

**Where is Punch Card Management located?**
Punch Card Management's principal office is in Winter Park, FL, according to its Form ADV.

**Is Punch Card Management registered with the SEC or a state?**
Punch Card Management is an SEC-registered investment advisory firm, registered since 2014. Status as filed: Approved. CRD 162939.

**How much does Punch Card Management manage?**
Punch Card Management reports $505,397,719 in regulatory assets under management in its Form ADV filing dated March 26, 2026 (100% discretionary).

**How have Punch Card Management's assets and staff changed since 2021?**
In the Form ADV data for Punch Card Management: Regulatory assets under management: $581,721,769 in the October 2021 data and $505,397,719 in the October 2026 data, down 13%. Total employees: 4 in October 2021 and 4 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Punch Card Management serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (1).

**Does Punch Card Management 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/162939

**Does Punch Card Management state an account minimum?**
Its Form ADV Part 2A brochure dated March 26, 2026 says: "The minimum initial investment in the Fund is $3,000,000, subject to reduction at the sole discretion of Punch Card."

## 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 March 26, 2026)

- Account minimum: $3,000,000 (the brochure says it may be waived or negotiated)

> The minimum initial investment in the Fund is $3,000,000, subject to reduction at the sole discretion of Punch Card.

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

### Regulatory assets under management (Item 5.F)
- Total: $505,397,719
- Discretionary: $505,397,719
- Non-discretionary: $0

### 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 | 0 | $0 |
| Investment companies | 0 | $0 |
| Business development companies | 0 | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | 1 | $505,397,719 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 0 | $0 |
| Charitable organizations | 0 | $0 |
| State or municipal government entities (including government pension plans) | 0 | $0 |
| Other investment advisers | 0 | $0 |
| Insurance companies | 0 | $0 |
| Sovereign wealth funds and foreign official institutions | 0 | $0 |
| Corporations or other businesses not listed above | 0 | $0 |
| Other | 0 | $0 |

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

### Firm details
- Registered since: 2014 (12 years)
- Employees: 4 total, 4 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: FL
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- [punchcardcapital.com](https://punchcardcapital.com)

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $581,721,769 | 4 | March 29, 2021 |
| October 2022 | $710,534,161 | 4 | March 25, 2022 |
| October 2023 | $531,539,843 | 4 | March 30, 2023 |
| October 2024 | $588,346,236 | 4 | March 29, 2024 |
| October 2025 | $530,982,792 | 4 | March 31, 2025 |
| October 2026 | $505,397,719 | 4 | March 26, 2026 |

Regulatory assets under management: $581,721,769 in the October 2021 data and $505,397,719 in the October 2026 data, down 13%.
Total employees: 4 in October 2021 and 4 in October 2026.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Punch Card Management (CRD 162939): Form ADV filing data as of October 2026.