# The Phoenix Fund Advisor LLC

> The Phoenix Fund Advisor LLC is an SEC-registered investment advisory firm in Guaynabo, PR, registered since 2023, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated October 13, 2025.

- CRD: 316384
- Filed as: THE PHOENIX FUND ADVISOR LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Guaynabo, PR
- Filing period: October 2026
- Form ADV filing dated: October 13, 2025
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/316384
- AdvisorCensus page: https://advisorcensus.com/firm/the-phoenix-fund-advisor-llc-guaynabo-pr-316384

## Quick answers

**How is The Phoenix Fund Advisor LLC compensated?**
On its Form ADV (Item 5.E, October 2026), The Phoenix Fund Advisor LLC reports these compensation arrangements: performance-based fees.

**How much does The Phoenix Fund Advisor LLC charge?**
Its Form ADV Part 2A brochure dated April 1, 2025 states: Asset-based fee: 2% of assets a year. Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is The Phoenix Fund Advisor LLC located?**
The Phoenix Fund Advisor LLC's principal office is in Guaynabo, PR, according to its Form ADV.

**Is The Phoenix Fund Advisor LLC registered with the SEC or a state?**
The Phoenix Fund Advisor LLC is an SEC-registered investment advisory firm, registered since 2023. Status as filed: Approved. CRD 316384.

**How much does The Phoenix Fund Advisor LLC manage?**
The Phoenix Fund Advisor LLC reports $596,381,715 in regulatory assets under management in its Form ADV filing dated October 13, 2025 (100% discretionary).

**How have The Phoenix Fund Advisor LLC's assets and staff changed since 2023?**
In the Form ADV data for The Phoenix Fund Advisor LLC: Regulatory assets under management: $349,620,161 in the October 2023 data and $596,381,715 in the October 2026 data, up 71%. Total employees: 10 in October 2023 and 15 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does The Phoenix Fund Advisor LLC serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (2).

**Does The Phoenix Fund Advisor LLC report any disciplinary disclosures?**
Reports 4 disclosure items on Form ADV Item 11: yes answers to 11.D(2) (another regulator's finding of a violation), 11.D(4) (another regulator's order in the past ten years), 11.E(2) (self-regulatory organization's finding of a rule violation), and 11.E(4) (self-regulatory organization's expulsion, suspension, bar, or restriction). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/316384

**What changed in The Phoenix Fund Advisor LLC's recent Form ADV filings?**
In the November 2025 filing data: Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

### Compensation (Item 5.E)
- Performance-based fees

### Fees and minimums (Form ADV Part 2A brochure dated April 1, 2025)

- Asset-based fee: 2% of assets a year

> The management fee payable by the Fund, will be paid quarterly in arrears on the first day of January, April, July and October of each year, at a rate of 2.00% per annum of the weighted average amount of capital contributed or committed to the Fund

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

### Regulatory assets under management (Item 5.F)
- Total: $596,381,715
- Discretionary: $596,381,715
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 2 | $596,381,715 |

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

### Firm details
- Registered since: 2023 (3 years)
- Employees: 15 total, 1 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports 4 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.D(2): Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
- 11.D(4): In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?
- 11.E(2): Has a self-regulatory organization or a commodities exchange ever found that the firm or an advisory affiliate was involved in a violation of its rules, other than a minor rule violation under a plan the SEC approved?
- 11.E(4): Has a self-regulatory organization or a commodities exchange ever disciplined the firm or an advisory affiliate by expelling or suspending it from membership, barring or suspending it from association with other members, or otherwise restricting its activities?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/316384

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

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2023 | $349,620,161 | 10 | August 17, 2023 |
| October 2024 | $603,957,947 | 15 | March 21, 2024 |
| October 2025 | $596,381,715 | 15 | April 1, 2025 |
| October 2026 | $596,381,715 | 15 | October 13, 2025 |

Regulatory assets under management: $349,620,161 in the October 2023 data and $596,381,715 in the October 2026 data, up 71%.
Total employees: 10 in October 2023 and 15 in October 2026.

## Changes in the filing (last 12 months)

### November 2025
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. The Phoenix Fund Advisor LLC (CRD 316384): Form ADV filing data as of October 2026.