# Swarthmore Asset Management Ltd

> Swarthmore Asset Management Ltd is an SEC-registered investment advisory firm in New York, NY, registered since 1992, reporting $25 million to $100 million in regulatory assets under management in its Form ADV filing dated February 25, 2026.

- CRD: 108507
- Filed as: SWARTHMORE ASSET MANAGEMENT LTD
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: New York, NY
- Filing period: October 2026
- Form ADV filing dated: February 25, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/108507
- AdvisorCensus page: https://advisorcensus.com/firm/swarthmore-asset-management-ltd-new-york-ny-108507

## Quick answers

**How is Swarthmore Asset Management Ltd compensated?**
On its Form ADV (Item 5.E, October 2026), Swarthmore Asset Management Ltd reports these compensation arrangements: a percentage of assets under its management; fixed fees (other than subscription fees).

**Where is Swarthmore Asset Management Ltd located?**
Swarthmore Asset Management Ltd's principal office is in New York, NY, according to its Form ADV.

**Is Swarthmore Asset Management Ltd registered with the SEC or a state?**
Swarthmore Asset Management Ltd is an SEC-registered investment advisory firm, registered since 1992. Status as filed: Approved. CRD 108507.

**How much does Swarthmore Asset Management Ltd manage?**
Swarthmore Asset Management Ltd reports $48,586,739 in regulatory assets under management in its Form ADV filing dated February 25, 2026 (100% discretionary).

**How have Swarthmore Asset Management Ltd's assets and staff changed since 2021?**
In the Form ADV data for Swarthmore Asset Management Ltd: Regulatory assets under management: $45,670,828 in the October 2021 data and $48,586,739 in the October 2026 data, up 6%. Total employees: 2 in October 2021 and 2 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Swarthmore Asset Management Ltd serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (9); individuals (other than high net worth individuals) (8); other (5).

**Which custodians does Swarthmore Asset Management Ltd use?**
Swarthmore Asset Management Ltd'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 Swarthmore Asset Management Ltd 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/108507

**What changed in Swarthmore Asset Management Ltd's recent Form ADV filings?**
In the March 2026 filing data: 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
- Fixed fees (other than subscription fees)

### Fees and minimums (Form ADV Part 2A brochure dated February 5, 2026)

- Minimum annual fee: $5,000

> We have a minimum annual fee of $5,000.

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: $48,586,739
- Discretionary: $48,586,739
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 8 | $2,774,099 |
| High net worth individuals | 9 | $23,603,484 |
| Banking or thrift institutions | Fewer than 5 | $0 |
| Investment companies | 0 | $0 |
| Business development companies | 0 | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | 0 | $0 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 1 | $1,924,749 |
| Charitable organizations | 1 | $304,452 |
| State or municipal government entities (including government pension plans) | Fewer than 5 | $0 |
| Other investment advisers | Fewer than 5 | $0 |
| Insurance companies | Fewer than 5 | $0 |
| Sovereign wealth funds and foreign official institutions | Fewer than 5 | $0 |
| Corporations or other businesses not listed above | 1 | $1,372,231 |
| Other | 5 | $18,607,724 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses

### Firm details
- Registered since: 1992 (34 years)
- Employees: 2 total, 1 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $45,670,828 | 2 | February 6, 2021 |
| October 2022 | $45,001,620 | 2 | January 25, 2022 |
| October 2023 | $42,648,697 | 2 | January 24, 2023 |
| October 2024 | $44,688,999 | 2 | January 31, 2024 |
| October 2025 | $48,168,703 | 2 | January 31, 2025 |
| October 2026 | $48,586,739 | 2 | February 25, 2026 |

Regulatory assets under management: $45,670,828 in the October 2021 data and $48,586,739 in the October 2026 data, up 6%.
Total employees: 2 in October 2021 and 2 in October 2026.

## Changes in the filing (last 12 months)

### March 2026
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Swarthmore Asset Management Ltd (CRD 108507): Form ADV filing data as of October 2026.