# Treasure Investment Management, LLC

> Treasure Investment Management, LLC is an SEC-registered investment advisory firm in Scottsdale, AZ, registered since 2020, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated June 16, 2026.

- CRD: 309258
- Filed as: TREASURE INVESTMENT MANAGEMENT, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Scottsdale, AZ
- Filing period: October 2026
- Form ADV filing dated: June 16, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/309258
- AdvisorCensus page: https://advisorcensus.com/firm/treasure-investment-management-llc-scottsdale-az-309258

## Quick answers

**How is Treasure Investment Management, LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Treasure Investment Management, LLC reports these compensation arrangements: a percentage of assets under its management.

**How much does Treasure Investment Management, LLC charge?**
Its Form ADV Part 2A brochure dated June 16, 2026 states: Asset-based fee: 0.2% to 0.35% 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 Treasure Investment Management, LLC located?**
Treasure Investment Management, LLC's principal office is in Scottsdale, AZ, according to its Form ADV.

**Is Treasure Investment Management, LLC registered with the SEC or a state?**
Treasure Investment Management, LLC is an SEC-registered investment advisory firm, registered since 2020. Status as filed: Approved. CRD 309258.

**How much does Treasure Investment Management, LLC manage?**
Treasure Investment Management, LLC reports $252,655,798 in regulatory assets under management in its Form ADV filing dated June 16, 2026 (100% discretionary).

**How have Treasure Investment Management, LLC's assets and staff changed since 2021?**
In the Form ADV data for Treasure Investment Management, LLC: Regulatory assets under management: $25,000,000 in the October 2022 data and $252,655,798 in the October 2026 data, up 911%. Total employees: 3 in October 2021 and 4 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Treasure Investment Management, LLC serve?**
By number of clients on Form ADV Item 5.D: corporations or other businesses not listed above (336).

**Which custodians does Treasure Investment Management, LLC use?**
Treasure Investment Management, LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Apex Clearing Corporation as a custodian holding 10% or more of its separately managed account assets.

**Does Treasure 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/309258

**Does Treasure Investment Management, LLC state an account minimum?**
Its Form ADV Part 2A brochure dated June 16, 2026 says: "There is no minimum account size required to open an account or establish an advisory relationship with Treasure."

**What changed in Treasure Investment Management, LLC's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 1 to 0. Regulatory assets under management went from $108,467,640 to $252,655,798 (+133%). Registered or notice-filed in DE, FL, GA, IL, MA, NC, NV, TX, WY.

## From the Form ADV filing

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

### Fees and minimums (Form ADV Part 2A brochure dated June 16, 2026)

- Asset-based fee: 0.2% to 0.35% a year (a range, as the brochure states it)

> Treasure charges clients asset based fees between 0.20 % and 0.35% ( 20-35 basis points) of the assets under management annually (the “Investment Management Fee”), charged monthly in arrears based on the average daily balance of the investment account in the prior month.

- Account minimum: None

> There is no minimum account size required to open an account or establish an advisory relationship with Treasure.

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

### Custodians (Schedule D, Section 5.K(3))
- Apex Clearing Corporation

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: $252,655,798
- Discretionary: $252,655,798
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Charitable organizations | Fewer than 5 | $418,964 |
| Corporations or other businesses not listed above | 336 | $252,236,834 |

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

### Firm details
- Registered since: 2020 (5 years)
- Employees: 4 total, 0 performing advisory functions
- Wrap fee program participation: Yes
- States registered or notice-filed: AZ, CA, CO, DE, FL, GA, IL, MA, NC, NV, NY, TX, WA, WY
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- [treasure.tech](https://treasure.tech)
- [treasurefi.com](https://treasurefi.com)
- LinkedIn @16272277

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | Not reported | 3 | September 8, 2021 |
| October 2022 | $25,000,000 | 3 | February 3, 2022 |
| October 2023 | $250,000,000 | 3 | February 7, 2023 |
| October 2024 | $222,060,272 | 3 | August 16, 2024 |
| October 2025 | $108,467,640 | 5 | April 22, 2025 |
| October 2026 | $252,655,798 | 4 | June 16, 2026 |

Regulatory assets under management: $25,000,000 in the October 2022 data and $252,655,798 in the October 2026 data, up 911%.
Total employees: 3 in October 2021 and 4 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 1 to 0.
- Regulatory assets under management went from $108,467,640 to $252,655,798 (+133%).
- Registered or notice-filed in DE, FL, GA, IL, MA, NC, NV, TX, WY.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Treasure Investment Management, LLC (CRD 309258): Form ADV filing data as of October 2026.
