# TOM Johnson Investment Management, LLC

> TOM Johnson Investment Management, LLC is an SEC-registered investment advisory firm in Oklahoma City, OK, registered since 1992, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated April 28, 2026.

- CRD: 104511
- Filed as: TOM JOHNSON INVESTMENT MANAGEMENT, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Oklahoma City, OK
- Filing period: October 2026
- Form ADV filing dated: April 28, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/104511
- AdvisorCensus page: https://advisorcensus.com/firm/tom-johnson-investment-management-llc-oklahoma-city-ok-104511

## Quick answers

**How is TOM Johnson Investment Management, LLC compensated?**
On its Form ADV (Item 5.E, October 2026), TOM Johnson Investment Management, LLC reports these compensation arrangements: a percentage of assets under its management; hourly charges; fixed fees (other than subscription fees). The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is TOM Johnson Investment Management, LLC located?**
TOM Johnson Investment Management, LLC's principal office is in Oklahoma City, OK, according to its Form ADV.

**Is TOM Johnson Investment Management, LLC registered with the SEC or a state?**
TOM Johnson Investment Management, LLC is an SEC-registered investment advisory firm, registered since 1992. Status as filed: Approved. CRD 104511.

**How much does TOM Johnson Investment Management, LLC manage?**
TOM Johnson Investment Management, LLC reports $1,632,586,982 in regulatory assets under management in its Form ADV filing dated April 28, 2026 (100% discretionary).

**How have TOM Johnson Investment Management, LLC's assets and staff changed since 2021?**
In the Form ADV data for TOM Johnson Investment Management, LLC: Regulatory assets under management: $1,642,967,252 in the October 2021 data and $1,632,586,982 in the October 2026 data, down 1%. Total employees: 12 in October 2021 and 11 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does TOM Johnson Investment Management, LLC serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (4,104); high net worth individuals (1,333); corporations or other businesses not listed above (120).

**Which custodians does TOM Johnson Investment Management, LLC use?**
TOM Johnson Investment Management, LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. and Fidelity Brokerage Services LLC as custodians holding 10% or more of its separately managed account assets.

**Does TOM Johnson 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/104511

**What changed in TOM Johnson Investment Management, LLC's recent Form ADV filings?**
In the May 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)

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., Inc.
- Fidelity Brokerage Services 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: $1,632,586,982
- Discretionary: $1,632,586,982
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 4,104 | $612,779,658 |
| High net worth individuals | 1,333 | $851,965,639 |
| Banking or thrift institutions | 0 | $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) | 27 | $18,026,547 |
| Charitable organizations | 47 | $89,046,912 |
| State or municipal government entities (including government pension plans) | 0 | $0 |
| Other investment advisers | 0 | $0 |
| Insurance companies | 0 | $0 |
| Sovereign wealth funds and foreign official institutions | 0 | $0 |
| Corporations or other businesses not listed above | 120 | $60,768,226 |

### 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
- Pension consulting services
- Selection of other advisers (including private fund managers)

### Firm details
- Registered since: 1992 (33 years)
- Employees: 11 total, 6 performing advisory functions
- Wrap fee program participation: Yes
- States registered or notice-filed: AK, AL, AR, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VA, VT, WA, WI, WV
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

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

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $1,642,967,252 | 12 | March 15, 2021 |
| October 2022 | $1,795,478,023 | 12 | March 29, 2022 |
| October 2023 | $1,519,426,903 | 11 | March 3, 2023 |
| October 2024 | $1,505,567,003 | 11 | March 27, 2024 |
| October 2025 | $1,628,875,708 | 11 | March 24, 2025 |
| October 2026 | $1,632,586,982 | 11 | April 28, 2026 |

Regulatory assets under management: $1,642,967,252 in the October 2021 data and $1,632,586,982 in the October 2026 data, down 1%.
Total employees: 12 in October 2021 and 11 in October 2026.

## Changes in the filing (last 12 months)

### May 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. TOM Johnson Investment Management, LLC (CRD 104511): Form ADV filing data as of October 2026.