# The Putney Financial Group LLC

> The Putney Financial Group LLC is an SEC-registered investment advisory firm in San Rafael, CA, registered since 2004, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated June 26, 2026.

- CRD: 111639
- Filed as: THE PUTNEY FINANCIAL GROUP LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: San Rafael, CA
- Filing period: October 2026
- Form ADV filing dated: June 26, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/111639
- AdvisorCensus page: https://advisorcensus.com/firm/the-putney-financial-group-llc-san-rafael-ca-111639

## Quick answers

**How is The Putney Financial Group LLC compensated?**
On its Form ADV (Item 5.E, October 2026), The Putney Financial Group LLC reports these compensation arrangements: a percentage of assets under its management; hourly charges; fixed fees (other than subscription fees).

**Where is The Putney Financial Group LLC located?**
The Putney Financial Group LLC's principal office is in San Rafael, CA, according to its Form ADV.

**Is The Putney Financial Group LLC registered with the SEC or a state?**
The Putney Financial Group LLC is an SEC-registered investment advisory firm, registered since 2004. Status as filed: Approved. CRD 111639.

**How much does The Putney Financial Group LLC manage?**
The Putney Financial Group LLC reports $205,409,186 in regulatory assets under management in its Form ADV filing dated June 26, 2026 (98% discretionary).

**How have The Putney Financial Group LLC's assets and staff changed since 2021?**
In the Form ADV data for The Putney Financial Group LLC: Regulatory assets under management: $247,165,862 in the October 2021 data and $205,409,186 in the October 2026 data, down 17%. 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 The Putney Financial Group LLC serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (155); high net worth individuals (57); charitable organizations (3).

**Which custodians does The Putney Financial Group LLC use?**
The Putney Financial Group LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Pacific Select Distributors, LLC and Pershing LLC as custodians holding 10% or more of its separately managed account assets.

**Does The Putney Financial Group LLC report any disciplinary disclosures?**
Reports 4 disclosure items on Form ADV Item 11: yes answers to 11.C(1) (SEC or CFTC finding of a false statement or omission), 11.C(2) (SEC or CFTC finding of a violation), 11.C(4) (SEC or CFTC order), and 11.C(5) (SEC or CFTC civil money penalty or cease-and-desist order). 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/111639

**Does The Putney Financial Group LLC state an account minimum?**
Its Form ADV Part 2A brochure dated June 26, 2026 says: "Generally, a minimum of $ 250,000 of assets under management is required to establish a client relationship with The Putney Financial Group LLC. This account size may be negotiable"

**What changed in The Putney Financial Group LLC's recent Form ADV filings?**
In the April 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
- Hourly charges
- Fixed fees (other than subscription fees)

### Fees and minimums (Form ADV Part 2A brochure dated June 26, 2026)

- Account minimum: $250,000 (the brochure says it may be waived or negotiated)

> Generally, a minimum of $ 250,000 of assets under management is required to establish a client relationship with The Putney Financial Group LLC. This account size may be negotiable

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

### Custodians (Schedule D, Section 5.K(3))
- Pacific Select Distributors, LLC
- Pershing LLC

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: $205,409,186
- Discretionary: $202,054,455
- Non-discretionary: $3,354,731

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 155 | $66,032,909 |
| High net worth individuals | 57 | $139,230,774 |
| Charitable organizations | 3 | $145,503 |

### Advisory services (Item 5.G)
- Financial planning services
- Portfolio management for individuals and/or small businesses
- Publication of periodicals or newsletters
- Educational seminars/workshops

### Firm details
- Registered since: 2004 (22 years)
- Employees: 8 total, 4 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AL, CA, FL, NM, NV, OR, TX, WA
- Disclosures (Item 11): Reports 4 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.C(1): Has the SEC or the CFTC ever found that the firm or an advisory affiliate made a false statement or omission?
- 11.C(2): Has the SEC or the CFTC ever found that the firm or an advisory affiliate was involved in a violation of SEC or CFTC regulations or statutes?
- 11.C(4): Has the SEC or the CFTC ever entered an order against the firm or an advisory affiliate in connection with investment-related activity?
- 11.C(5): Has the SEC or the CFTC ever imposed a civil money penalty on the firm or an advisory affiliate, or ordered the firm or an advisory affiliate to cease and desist from an activity?

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/111639

### Websites listed on Form ADV (Item 1.I)
- putneyfinancial.com
- Facebook @The-Putney-Financial-Group-LLC

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $247,165,862 | 7 | March 29, 2021 |
| October 2022 | $266,858,862 | 7 | March 23, 2022 |
| October 2023 | $166,144,220 | 7 | March 28, 2023 |
| October 2024 | $177,105,756 | 7 | August 23, 2024 |
| October 2025 | $187,290,545 | 7 | May 5, 2025 |
| October 2026 | $205,409,186 | 8 | June 26, 2026 |

Regulatory assets under management: $247,165,862 in the October 2021 data and $205,409,186 in the October 2026 data, down 17%.
Total employees: 7 in October 2021 and 8 in October 2026.

## Changes in the filing (last 12 months)

### April 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. The Putney Financial Group LLC (CRD 111639): Form ADV filing data as of October 2026.