# Turtle Creek Trust

> 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.

- CRD: 140212
- Filed as: TURTLE CREEK TRUST
- Legal name: Turtle Creek Management, LLC
- Also doing business as: TURTLE CREEK TRUST
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Dallas, TX
- Filing period: October 2026
- Form ADV filing dated: March 30, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/140212
- AdvisorCensus page: https://advisorcensus.com/firm/turtle-creek-trust-dallas-tx-140212

## Quick answers

**How 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

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

### Fees and minimums (Form ADV Part 2A brochure dated March 30, 2026)

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

> 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 brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- National Financial Services LLC

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: $4,280,497,349
- Discretionary: $1,550,328,446
- Non-discretionary: $2,730,168,903

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 5 | $1,743,142 |
| High net worth individuals | 96 | $4,239,169,367 |
| Banking or thrift institutions | Not reported | $0 |
| Investment companies | Not reported | $0 |
| Business development companies | Not reported | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | Not reported | $0 |
| Charitable organizations | Fewer than 5 | $37,998,146 |
| State or municipal government entities (including government pension plans) | Not reported | $0 |
| Other investment advisers | Not reported | $0 |
| Insurance companies | Not reported | $0 |
| Sovereign wealth funds and foreign official institutions | Not reported | $0 |
| Corporations or other businesses not listed above | Fewer than 5 | $1,586,694 |

### 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: 2006 (20 years)
- Employees: 10 total, 6 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, MA, NY, TX
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- turtlecreekdallas.com
- turtlecreektrust.com
- LinkedIn @turtle-creek-management-llc

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $2,637,428,289 | 9 | March 30, 2021 |
| October 2022 | $3,148,766,830 | 9 | June 30, 2022 |
| October 2023 | $3,176,442,691 | 8 | March 31, 2023 |
| October 2024 | $3,541,418,573 | 10 | April 4, 2024 |
| October 2025 | $3,661,746,284 | 10 | March 31, 2025 |
| October 2026 | $4,280,497,349 | 10 | March 30, 2026 |

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.

## 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.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Turtle Creek Trust (CRD 140212): Form ADV filing data as of October 2026.