# Tortuga Advisers LLC

> Tortuga Advisers LLC is an SEC-registered investment advisory firm in Simi Valley, CA, registered since 2005, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated April 30, 2026.

- CRD: 137514
- Filed as: TORTUGA ADVISERS LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Simi Valley, CA
- Filing period: October 2026
- Form ADV filing dated: April 30, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/137514
- AdvisorCensus page: https://advisorcensus.com/firm/tortuga-advisers-llc-simi-valley-ca-137514

## Quick answers

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

**How much does Tortuga Advisers LLC charge?**
Its Form ADV Part 2A brochure dated March 31, 2025 states: Asset-based fee: 0.75% of assets a year. Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Tortuga Advisers LLC located?**
Tortuga Advisers LLC's principal office is in Simi Valley, CA, according to its Form ADV.

**Is Tortuga Advisers LLC registered with the SEC or a state?**
Tortuga Advisers LLC is an SEC-registered investment advisory firm, registered since 2005. Status as filed: Approved. CRD 137514.

**How much does Tortuga Advisers LLC manage?**
Tortuga Advisers LLC reports $563,537,021 in regulatory assets under management in its Form ADV filing dated April 30, 2026 (100% discretionary).

**How have Tortuga Advisers LLC's assets and staff changed since 2021?**
In the Form ADV data for Tortuga Advisers LLC: Regulatory assets under management: $401,256,637 in the October 2021 data and $563,537,021 in the October 2026 data, up 40%. Total employees: 1 in October 2021 and 1 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Tortuga Advisers LLC serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (39); charitable organizations (1).

**Does Tortuga Advisers 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/137514

**Does Tortuga Advisers LLC state an account minimum?**
Its Form ADV Part 2A brochure dated March 31, 2025 says: "The minimum account size is $1,000,000 of assets under management, which typically equates to an annual fee of $$7,500. TORTUGA ADVISERS LLC has the discretion to waive the account minimum."

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Fixed fees (other than subscription fees)

### Fees and minimums (Form ADV Part 2A brochure dated March 31, 2025)

- Asset-based fee: 0.75% of assets a year

> In general, annual fees are set a 0.75% of assets under management. In addition to complexity, the amount of assets to be managed influences the fee. Client relationships may exist where the fees are higher or lower than the fee schedule above.

- Account minimum: $1,000,000 (the brochure says it may be waived or negotiated)

> The minimum account size is $1,000,000 of assets under management, which typically equates to an annual fee of $$7,500. TORTUGA ADVISERS LLC has the discretion to waive the account minimum.

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

### Regulatory assets under management (Item 5.F)
- Total: $563,537,021
- Discretionary: $563,537,021
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | $0 |
| High net worth individuals | 39 | $528,173,284 |
| 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) | 0 | $0 |
| Charitable organizations | 1 | $35,363,737 |
| 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 | 0 | $0 |
| Other | 0 | $0 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses

### Firm details
- Registered since: 2005 (20 years)
- Employees: 1 total, 1 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $401,256,637 | 1 | April 23, 2021 |
| October 2022 | $465,397,652 | 1 | March 30, 2022 |
| October 2023 | $468,625,539 | 1 | March 31, 2023 |
| October 2024 | $481,647,547 | 1 | March 29, 2024 |
| October 2025 | $526,954,973 | 1 | March 31, 2025 |
| October 2026 | $563,537,021 | 1 | April 30, 2026 |

Regulatory assets under management: $401,256,637 in the October 2021 data and $563,537,021 in the October 2026 data, up 40%.
Total employees: 1 in October 2021 and 1 in October 2026.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Tortuga Advisers LLC (CRD 137514): Form ADV filing data as of October 2026.