AdvisorCensus / Financial advisors / Texas / Dallas / Turtle Creek Trust
Turtle Creek Trust
Filed as TURTLE CREEK TRUST · Legal name Turtle Creek Management, LLC
Turtle Creek Trust is an SEC-registered investment advisory firm in Dallas, TX, registered since 2006, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated March 30, 2026.
Quick answers
From the filingHow is Turtle Creek Trust compensated?
On its Form ADV (Item 5.E, October 2026), Turtle Creek Trust reports these compensation arrangements: a percentage of assets under its management.
Where is Turtle Creek Trust located?
Turtle Creek Trust's principal office is in Dallas, TX, according to its Form ADV.
Is Turtle Creek Trust registered with the SEC or a state?
Turtle Creek Trust is an SEC-registered investment advisory firm, registered since 2006. Status as filed: Approved. CRD 140212.
How much does Turtle Creek Trust manage?
Turtle Creek Trust reports $4,280,497,349 in regulatory assets under management in its Form ADV filing dated March 30, 2026 (36% discretionary).
How have Turtle Creek Trust's assets and staff changed since 2021?
In the Form ADV data for Turtle Creek Trust: Regulatory assets under management: $2,637,428,289 in the October 2021 data and $4,280,497,349 in the October 2026 data, up 62%. Total employees: 9 in October 2021 and 10 in October 2026. Assets under management move with markets as well as with clients coming and going.
What types of clients does Turtle Creek Trust serve?
By number of clients on Form ADV Item 5.D: high net worth individuals (96); individuals (other than high net worth individuals) (5).
Which custodians does Turtle Creek Trust use?
Turtle Creek Trust's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists National Financial Services LLC as a custodian holding 10% or more of its separately managed account assets.
Does Turtle Creek Trust 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/140212
Does Turtle Creek Trust state an account minimum?
Its Form ADV Part 2A brochure dated March 30, 2026 says: "In general, the minimum size for an Account is $1 million, although this may be waived based on considerations such as the Account’s relationship to established clients and other factors."
What changed in Turtle Creek Trust's recent Form ADV filings?
In the April 2026 filing data: Regulatory assets under management went from $3,661,746,284 to $4,280,497,349 (+17%). Registered or notice-filed in NY.
From the Form ADV filing
Every figure below is as the firm filed it with regulators, as of October 2026.
How the firm is compensated
Item 5.E- A percentage of assets under your management
Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ
Fees and minimums
Form ADV Part 2AThe brochure lists different fees for different services or strategies; see the brochure for them.
Account minimum: $1,000,000 (the brochure says it may be waived or negotiated)
The brochure's wording
In general, the minimum size for an Account is $1 million, although this may be waived based on considerations such as the Account’s relationship to established clients and other factors.
As stated in the firm's Form ADV Part 2A brochure dated March 30, 2026. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site
Regulatory assets under management
Item 5.F$4,280,497,349 as of October 2026, filing dated March 30, 2026.
A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means
Who the firm serves
Item 5.DA firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.
Advisory services
Item 5.G- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses (other than small businesses) or institutional clients
Registration and firm details
Items 1, 2, 5- Legal name
- Turtle Creek Management, LLC
- Also doing business as
- TURTLE CREEK TRUST
- Registration
- SEC-registered investment adviser. Status as filed: Approved.
- Registered since
- 2006 (20 years)
- Employees
- Total: 10. Performing investment advisory functions: 6.
- Wrap fee program participation
- No.
- Custodians (Schedule D, Section 5.K(3))
-
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.
- States registered or notice-filed
-
4 states or jurisdictions
SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration
Disclosures
Item 11None Reports no disclosure items on Form ADV Item 11. View on IAPD.
Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures
Assets and staff over time
Items 5.A, 5.F| Data period | Assets under management | Employees | Filing dated |
|---|---|---|---|
| October 2026 | $4,280,497,349 | 10 | March 30, 2026 |
| October 2025 | $3,661,746,284 | 10 | March 31, 2025 |
| October 2024 | $3,541,418,573 | 10 | April 4, 2024 |
| October 2023 | $3,176,442,691 | 8 | March 31, 2023 |
| October 2022 | $3,148,766,830 | 9 | June 30, 2022 |
| October 2021 | $2,637,428,289 | 9 | March 30, 2021 |
Regulatory assets under management: $2,637,428,289 in the October 2021 data and $4,280,497,349 in the October 2026 data, up 62%.
Total employees: 9 in October 2021 and 10 in October 2026.
As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.
Changes in the filing
Last 12 months- April 2026
- Regulatory assets under management went from $3,661,746,284 to $4,280,497,349 (+17%).
- Registered or notice-filed in NY.
Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.
Websites listed on Form ADV
Item 1.ISource: Form ADV, as of October 2026. Values appear as filed; a value the firm did not report is shown as "Not reported."
Cite this page
AdvisorCensus. Turtle Creek Trust (CRD 140212): Form ADV filing data as of October 2026. https://advisorcensus.com/firm/turtle-creek-trust-dallas-tx-140212