# Tomales Bay Capital

> Tomales Bay Capital is an SEC-registered investment advisory firm in Dallas, TX, registered since 2019, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 298932
- Filed as: TOMALES BAY CAPITAL
- Legal name: Tomales Bay Capital, L.P.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Dallas, TX
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/298932
- AdvisorCensus page: https://advisorcensus.com/firm/tomales-bay-capital-dallas-tx-298932

## Quick answers

**How is Tomales Bay Capital compensated?**
On its Form ADV (Item 5.E, October 2026), Tomales Bay Capital 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 Tomales Bay Capital located?**
Tomales Bay Capital's principal office is in Dallas, TX, according to its Form ADV.

**Is Tomales Bay Capital registered with the SEC or a state?**
Tomales Bay Capital is an SEC-registered investment advisory firm, registered since 2019. Status as filed: Approved. CRD 298932.

**How much does Tomales Bay Capital manage?**
Tomales Bay Capital reports $5,112,625,424 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (100% discretionary).

**How have Tomales Bay Capital's assets and staff changed since 2021?**
In the Form ADV data for Tomales Bay Capital: Regulatory assets under management: $682,051,240 in the October 2021 data and $5,112,625,424 in the October 2026 data, up 650%. Total employees: 2 in October 2021 and 3 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Tomales Bay Capital serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (43).

**Does Tomales Bay Capital 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/298932

**What changed in Tomales Bay Capital's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 2 to 1. Regulatory assets under management went from $2,958,967,207 to $5,112,625,424 (+73%). Registered or notice-filed in FL.

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Performance-based fees

### Regulatory assets under management (Item 5.F)
- Total: $5,112,625,424
- Discretionary: $5,112,625,424
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 43 | $5,112,625,424 |

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

### Firm details
- Registered since: 2019 (6 years)
- Employees: 3 total, 1 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: FL, TX
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- tomalesbaycapital.com
- LinkedIn @tomales-bay-capital
- X @tomalesbaycap

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $682,051,240 | 2 | March 31, 2021 |
| October 2022 | $1,847,108,234 | 3 | September 9, 2022 |
| October 2023 | $1,845,109,012 | 4 | August 30, 2023 |
| October 2024 | $2,151,870,552 | 6 | March 28, 2024 |
| October 2025 | $2,958,967,207 | 4 | March 31, 2025 |
| October 2026 | $5,112,625,424 | 3 | March 31, 2026 |

Regulatory assets under management: $682,051,240 in the October 2021 data and $5,112,625,424 in the October 2026 data, up 650%.
Total employees: 2 in October 2021 and 3 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 2 to 1.
- Regulatory assets under management went from $2,958,967,207 to $5,112,625,424 (+73%).
- Registered or notice-filed in FL.

### January 2026
- No longer registered or notice-filed in CA.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Tomales Bay Capital (CRD 298932): Form ADV filing data as of October 2026.