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AdvisorCensus / Financial advisors / Arizona / Tucson / Sterling Investment Management, LLC

Sterling Investment Management, LLC

Tucson, AZSEC-registered investment adviserCRD 112923

Filed as STERLING INVESTMENT MANAGEMENT, LLC

Sterling Investment Management, LLC is an SEC-registered investment advisory firm in Tucson, AZ, registered since 1995, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated March 18, 2026.

30 years
registered since 1995
$409,201,752
assets under management
2 arrangements
Percentage of assets, Hourly
None
disclosure items (Item 11)

Quick answers

From the filing

How is Sterling Investment Management, LLC compensated?

On its Form ADV (Item 5.E, October 2026), Sterling Investment Management, LLC reports these compensation arrangements: a percentage of assets under its management; hourly charges.

How much does Sterling Investment Management, LLC charge?

Its Form ADV Part 2A brochure dated March 18, 2026 states: Up to $5,000,000: 1% a year; $5,000,000 to $10,000,000: 0.95% a year; Above $10,000,000: see the brochure; Hourly rate: $500 an hour (other professional advisory services). Fees can differ by service and may be negotiable; the brochure is the complete statement.

Where is Sterling Investment Management, LLC located?

Sterling Investment Management, LLC's principal office is in Tucson, AZ, according to its Form ADV; the April 2026 filing also lists 1 other office (Schedule D, Section 1.F).

Is Sterling Investment Management, LLC registered with the SEC or a state?

Sterling Investment Management, LLC is an SEC-registered investment advisory firm, registered since 1995. Status as filed: Approved. CRD 112923.

How much does Sterling Investment Management, LLC manage?

Sterling Investment Management, LLC reports $409,201,752 in regulatory assets under management in its Form ADV filing dated March 18, 2026 (100% discretionary).

How have Sterling Investment Management, LLC's assets and staff changed since 2021?

In the Form ADV data for Sterling Investment Management, LLC: Regulatory assets under management: $354,004,670 in the October 2021 data and $409,201,752 in the October 2026 data, up 16%. Total employees: 7 in October 2021 and 8 in October 2026. Assets under management move with markets as well as with clients coming and going.

What types of clients does Sterling Investment Management, LLC serve?

By number of clients on Form ADV Item 5.D: high net worth individuals (74); individuals (other than high net worth individuals) (65); charitable organizations (7).

Which custodians does Sterling Investment Management, LLC use?

Sterling Investment Management, LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. as a custodian holding 10% or more of its separately managed account assets.

Does Sterling Investment 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/112923

Does Sterling Investment Management, LLC state an account minimum?

Its Form ADV Part 2A brochure dated March 18, 2026 says: "Sterling requires a minimum investment portfolio(s) of $ 1,000,000 per client household but this minimum may be waived under certain situations."

What changed in Sterling Investment Management, LLC's recent Form ADV filings?

In the April 2026 filing data: Regulatory assets under management went from $360,529,500 to $409,201,752 (+14%).

From the Form ADV filing

Every figure below is as the firm filed it with regulators, as of October 2026.

How the firm is compensated

Item 5.E
  • A percentage of assets under your management
  • Hourly charges

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

Fees and minimums

Form ADV Part 2A
AssetsAnnual rate
Up to $5,000,0001%
$5,000,000 to $10,000,0000.95%
Above $10,000,000See the brochure
The brochure's wording
Effective fee schedule for investment management services based on client’s total assets under management applicable to all clients:
Asset market values up to $ 5,000,000 1.00 %
Market values of $ 5,000,000 to $10,000,000 0.95 %
Market values of greater than $10,000,000 (Negotiated)

Account minimum: $1,000,000 (the brochure says it may be waived or negotiated)

The brochure's wording
Sterling requires a minimum investment portfolio(s) of $ 1,000,000 per client household but this minimum may be waived under certain situations.

Minimum annual fee: $10,000

The brochure's wording
Sterling generally requires an annual minimum fee of $10,000 for investment advisory services.

Hourly rate: $500 an hour (other professional advisory services)

The brochure's wording
For services that fall outside of Sterling’s normal advisory agreements, Sterling may charge an hourly rate fee for other professional advisory services. The hourly rate is $500 per hour

As stated in the firm's Form ADV Part 2A brochure dated March 18, 2026. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site

Regulatory assets under management

Item 5.F
$409,201,752

$409,201,752 as of October 2026, filing dated March 18, 2026.

Discretionary: $409,201,752.Non-discretionary: $0.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

Who the firm serves

Item 5.D
Individuals (other than high net worth individuals)
Clients 65 Assets $32,517,051 (8%)
High net worth individuals
Clients 74 Assets $321,821,484 (79%)
Charitable organizations
Clients 7 Assets $26,176,710 (6%)
State or municipal government entities (including government pension plans)
Clients 1 Assets $4,518,831 (1%)
Corporations or other businesses not listed above
Clients 4 Assets $24,167,676 (6%)

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

Advisory services

Item 5.G
  • Financial planning services
  • Portfolio management for individuals and/or small businesses
  • Portfolio management for businesses (other than small businesses) or institutional clients
  • Publication of periodicals or newsletters

Registration and firm details

Items 1, 2, 5
Registration
SEC-registered investment adviser. Status as filed: Approved.
Registered since
1995 (30 years)
Employees
Total: 8. Performing investment advisory functions: 4.
Wrap fee program participation
No.
Custodians (Schedule D, Section 5.K(3))

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.

Other offices (Schedule D, Section 1.F)
1 other office, as of the April 2026 filing
Scottsdale, AZ
States registered or notice-filed
4 states or jurisdictions
AZCACOOK

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

Disclosures

Item 11

None Reports no disclosure items on Form ADV Item 11. View on IAPD.

Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures

Assets and staff over time

Items 5.A, 5.F
$354M 2021 $338M 2022 $342M 2023 $371M 2024 $361M 2025 $409M 2026
Data periodAssets under managementEmployeesFiling dated
October 2026$409,201,7528March 18, 2026
October 2025$360,529,5008March 27, 2025
October 2024$371,202,0268March 26, 2024
October 2023$341,521,9328March 22, 2023
October 2022$337,723,1977March 31, 2022
October 2021$354,004,6707March 18, 2021

Regulatory assets under management: $354,004,670 in the October 2021 data and $409,201,752 in the October 2026 data, up 16%.

Total employees: 7 in October 2021 and 8 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

Changes in the filing

Last 12 months
  1. April 2026
    • Regulatory assets under management went from $360,529,500 to $409,201,752 (+14%).
  2. January 2026
    • No longer registered or notice-filed in TX.

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.

Websites listed on Form ADV

Item 1.I
sterlinginvestmentmanagement.com

Source: Form ADV, as of October 2026. Values appear as filed; a value the firm did not report is shown as "Not reported."

Cite this page

AdvisorCensus. Sterling Investment Management, LLC (CRD 112923): Form ADV filing data as of October 2026.
https://advisorcensus.com/firm/sterling-investment-management-llc-tucson-az-112923