# Trace Capital Management LP

> Trace Capital Management LP is an SEC-registered investment advisory firm in Houston, TX, registered since 2022, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated March 26, 2026.

- CRD: 322094
- Filed as: TRACE CAPITAL MANAGEMENT LP
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Houston, TX
- Filing period: October 2026
- Form ADV filing dated: March 26, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/322094
- AdvisorCensus page: https://advisorcensus.com/firm/trace-capital-management-lp-houston-tx-322094

## Quick answers

**How is Trace Capital Management LP compensated?**
On its Form ADV (Item 5.E, October 2026), Trace Capital Management LP reports these compensation arrangements: a percentage of assets under its management; performance-based fees.

**What does Trace Capital Management LP's brochure say about its fees?**
Its Form ADV Part 2A brochure dated March 26, 2026 states: Asset-based fee: 1% to 2% a year (a range, as the brochure states it). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Trace Capital Management LP located?**
Trace Capital Management LP's principal office is in Houston, TX, according to its Form ADV.

**Is Trace Capital Management LP registered with the SEC or a state?**
Trace Capital Management LP is an SEC-registered investment advisory firm, registered since 2022. Status as filed: Approved. CRD 322094.

**How much does Trace Capital Management LP manage?**
Trace Capital Management LP reports $1,680,044,964 in regulatory assets under management in its Form ADV filing dated March 26, 2026 (100% discretionary).

**How have Trace Capital Management LP's assets and staff changed since 2022?**
In the Form ADV data for Trace Capital Management LP: Regulatory assets under management: $1,471,679,310 in the October 2023 data and $1,680,044,964 in the October 2026 data, up 14%. Total employees: 12 in October 2022 and 16 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Trace Capital Management LP serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (4).

**Does Trace Capital Management LP 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/322094

**What changed in Trace Capital Management LP's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 13 to 15.

## From the Form ADV filing

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

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

- Asset-based fee: 1% to 2% a year (a range, as the brochure states it)

> This management fee generally ranges from 1% to 2% per annum of capital commitments and generally is reduced upon the end of a fund’s commitment period.

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

### Regulatory assets under management (Item 5.F)
- Total: $1,680,044,964
- Discretionary: $1,680,044,964
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | Not reported |
| High net worth individuals | 0 | Not reported |
| Banking or thrift institutions | 0 | Not reported |
| Investment companies | 0 | Not reported |
| Business development companies | 0 | Not reported |
| Pooled investment vehicles (other than investment companies and business development companies) | 4 | $1,680,044,964 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 0 | Not reported |
| Charitable organizations | 0 | Not reported |
| State or municipal government entities (including government pension plans) | 0 | Not reported |
| Other investment advisers | 0 | Not reported |
| Insurance companies | 0 | Not reported |
| Sovereign wealth funds and foreign official institutions | 0 | Not reported |
| Corporations or other businesses not listed above | 0 | Not reported |
| Other | 0 | Not reported |

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

### Firm details
- Registered since: 2022 (4 years)
- Employees: 16 total, 15 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: TX
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- tracecapital.com
- LinkedIn @trace-capital

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2022 | Not reported | 12 | June 7, 2022 |
| October 2023 | $1,471,679,310 | 13 | September 8, 2023 |
| October 2024 | $1,566,474,498 | 15 | March 28, 2024 |
| October 2025 | $1,782,589,922 | 14 | March 28, 2025 |
| October 2026 | $1,680,044,964 | 16 | March 26, 2026 |

Regulatory assets under management: $1,471,679,310 in the October 2023 data and $1,680,044,964 in the October 2026 data, up 14%.
Total employees: 12 in October 2022 and 16 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 13 to 15.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Trace Capital Management LP (CRD 322094): Form ADV filing data as of October 2026.