# 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.

- CRD: 112923
- Filed as: STERLING INVESTMENT MANAGEMENT, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Tucson, AZ
- Filing period: October 2026
- Form ADV filing dated: March 18, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/112923
- AdvisorCensus page: https://advisorcensus.com/firm/sterling-investment-management-llc-tucson-az-112923

## Quick answers

**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

### Compensation (Item 5.E)
- A percentage of assets under your management
- Hourly charges

### Fees and minimums (Form ADV Part 2A brochure dated March 18, 2026)

- 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

> 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)

> 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

> Sterling generally requires an annual minimum fee of $10,000 for investment advisory services.

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

> 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 brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., Inc.

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

### Clients (Item 5.D)

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

### 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

### Firm details
- Registered since: 1995 (30 years)
- Employees: 8 total, 4 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AZ, CA, CO, OK
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the April 2026 filing
- Scottsdale, AZ

### Websites listed on Form ADV (Item 1.I)
- [sterlinginvestmentmanagement.com](https://sterlinginvestmentmanagement.com)
- LinkedIn @sterling-investment-management

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $354,004,670 | 7 | March 18, 2021 |
| October 2022 | $337,723,197 | 7 | March 31, 2022 |
| October 2023 | $341,521,932 | 8 | March 22, 2023 |
| October 2024 | $371,202,026 | 8 | March 26, 2024 |
| October 2025 | $360,529,500 | 8 | March 27, 2025 |
| October 2026 | $409,201,752 | 8 | March 18, 2026 |

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.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $360,529,500 to $409,201,752 (+14%).

### January 2026
- No longer registered or notice-filed in TX.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Sterling Investment Management, LLC (CRD 112923): Form ADV filing data as of October 2026.