# Theorem

> Theorem is an SEC-registered investment advisory firm in New York, NY, registered since 2016, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated October 1, 2026.

- CRD: 281280
- Filed as: THEOREM
- Legal name: Theorem Partners LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: New York, NY
- Filing period: October 2026
- Form ADV filing dated: October 1, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/281280
- AdvisorCensus page: https://advisorcensus.com/firm/theorem-new-york-ny-281280

## Quick answers

**How is Theorem compensated?**
On its Form ADV (Item 5.E, October 2026), Theorem reports these compensation arrangements: a percentage of assets under its management; performance-based fees. The amounts are in Item 5 of its Form ADV Part 2A brochure.

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

**Is Theorem registered with the SEC or a state?**
Theorem is an SEC-registered investment advisory firm, registered since 2016. Status as filed: Approved. CRD 281280.

**How much does Theorem manage?**
Theorem reports $1,032,394,333 in regulatory assets under management in its Form ADV filing dated October 1, 2026 (100% discretionary).

**How have Theorem's assets and staff changed since 2021?**
In the Form ADV data for Theorem: Regulatory assets under management: $1,511,233,920 in the October 2021 data and $1,032,394,333 in the October 2026 data, down 32%. Total employees: 31 in October 2021 and 121 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Theorem serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (3).

**Which custodians does Theorem use?**
Theorem's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Inspira Financial Trust and Wells Fargo as custodians holding 10% or more of its separately managed account assets.

**Does Theorem report any disciplinary disclosures?**
Reports 2 disclosure items on Form ADV Item 11: yes answers to 11.D(2) (another regulator's finding of a violation) and 11.D(4) (another regulator's order in the past ten years). 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/281280

**What changed in Theorem's recent Form ADV filings?**
In the July 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
- Performance-based fees

### Custodians (Schedule D, Section 5.K(3))
- Inspira Financial Trust
- Wells Fargo

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: $1,032,394,333
- Discretionary: $1,032,394,333
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 3 | $1,025,795,952 |
| Charitable organizations | Fewer than 5 | $6,598,381 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients

### Firm details
- Registered since: 2016 (9 years)
- Employees: 121 total, 3 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports 2 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?

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/281280

### Websites listed on Form ADV (Item 1.I)
- pagaya.com
- Facebook @pagayaltd
- LinkedIn @pagaya
- X @Pagayaltd

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $1,511,233,920 | 31 | September 29, 2021 |
| October 2022 | $2,135,297,937 | 34 | February 25, 2022 |
| October 2023 | $2,751,794,990 | 64 | July 26, 2023 |
| October 2024 | $2,019,603,138 | 62 | September 26, 2024 |
| October 2025 | $1,683,790,473 | 133 | May 14, 2025 |
| October 2026 | $1,032,394,333 | 121 | October 1, 2026 |

Regulatory assets under management: $1,511,233,920 in the October 2021 data and $1,032,394,333 in the October 2026 data, down 32%.
Total employees: 31 in October 2021 and 121 in October 2026.

## Changes in the filing (last 12 months)

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

### April 2026
- Employees performing advisory functions went from 5 to 3.
- Regulatory assets under management went from $1,683,790,473 to $1,032,394,333 (-39%).
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Theorem (CRD 281280): Form ADV filing data as of October 2026.