# ROOM40 Capital LLC

> ROOM40 Capital LLC is an SEC-registered investment advisory firm in New York, NY, registered since 2025, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated May 13, 2026.

- CRD: 322436
- Filed as: ROOM40 CAPITAL LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: New York, NY
- Filing period: October 2026
- Form ADV filing dated: May 13, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/322436
- AdvisorCensus page: https://advisorcensus.com/firm/room40-capital-llc-new-york-ny-322436

## Quick answers

**How is ROOM40 Capital LLC compensated?**
On its Form ADV (Item 5.E, October 2026), ROOM40 Capital 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 ROOM40 Capital LLC located?**
ROOM40 Capital LLC's principal office is in New York, NY, according to its Form ADV.

**Is ROOM40 Capital LLC registered with the SEC or a state?**
ROOM40 Capital LLC is an SEC-registered investment advisory firm, registered since 2025. Status as filed: Approved. CRD 322436.

**How much does ROOM40 Capital LLC manage?**
ROOM40 Capital LLC reports $261,736,536 in regulatory assets under management in its Form ADV filing dated May 13, 2026 (100% discretionary).

**How have ROOM40 Capital LLC's assets and staff changed since 2023?**
In the Form ADV data for ROOM40 Capital LLC: Regulatory assets under management: $209,012,497 in the October 2025 data and $261,736,536 in the October 2026 data, up 25%. Total employees: 8 in October 2025 and 11 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does ROOM40 Capital LLC serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (7).

**Does ROOM40 Capital 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/322436

**What changed in ROOM40 Capital LLC's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 5 to 7. Regulatory assets under management went from $209,012,497 to $261,736,536 (+25%). 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: $261,736,536
- Discretionary: $261,736,536
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 7 | $261,736,536 |

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

### Firm details
- Registered since: 2025 (1 year)
- Employees: 11 total, 7 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: NY
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- room40.capital
- room40.xyz
- LinkedIn @room40cap
- X @room40xyz

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2023 | Not reported | Not reported | March 31, 2023 |
| October 2024 | Not reported | Not reported | March 25, 2024 |
| October 2025 | $209,012,497 | 8 | June 26, 2025 |
| October 2026 | $261,736,536 | 11 | May 13, 2026 |

Regulatory assets under management: $209,012,497 in the October 2025 data and $261,736,536 in the October 2026 data, up 25%.
Total employees: 8 in October 2025 and 11 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 5 to 7.
- Regulatory assets under management went from $209,012,497 to $261,736,536 (+25%).
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. ROOM40 Capital LLC (CRD 322436): Form ADV filing data as of October 2026.