# Twele Capital Management, Inc.

> Twele Capital Management, Inc. is an SEC-registered investment advisory firm in Minnetonka, MN, registered since 2007, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated January 6, 2026.

- CRD: 130239
- Filed as: TWELE CAPITAL MANAGEMENT, INC.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Minnetonka, MN
- Filing period: October 2026
- Form ADV filing dated: January 6, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/130239
- AdvisorCensus page: https://advisorcensus.com/firm/twele-capital-management-inc-minnetonka-mn-130239

## Quick answers

**How is Twele Capital Management, Inc. compensated?**
On its Form ADV (Item 5.E, October 2026), Twele Capital Management, Inc. reports these compensation arrangements: a percentage of assets under its management; hourly charges.

**Where is Twele Capital Management, Inc. located?**
Twele Capital Management, Inc.'s principal office is in Minnetonka, MN, according to its Form ADV.

**Is Twele Capital Management, Inc. registered with the SEC or a state?**
Twele Capital Management, Inc. is an SEC-registered investment advisory firm, registered since 2007. Status as filed: Approved. CRD 130239.

**How much does Twele Capital Management, Inc. manage?**
Twele Capital Management, Inc. reports $578,455,059 in regulatory assets under management in its Form ADV filing dated January 6, 2026 (100% discretionary).

**How have Twele Capital Management, Inc.'s assets and staff changed since 2021?**
In the Form ADV data for Twele Capital Management, Inc.: Regulatory assets under management: $580,954,883 in the October 2021 data and $578,455,059 in the October 2026 data, unchanged. Total employees: 6 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 Twele Capital Management, Inc. serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (37); individuals (other than high net worth individuals) (30).

**Which custodians does Twele Capital Management, Inc. use?**
Twele Capital Management, Inc.'s most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. as a custodian holding 10% or more of its separately managed account assets.

**Does Twele Capital Management, Inc. 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/130239

**Does Twele Capital Management, Inc. state an account minimum?**
Its Form ADV Part 2A brochure dated January 6, 2026 says: "Generally, a minimum of $500,000 of assets under management is required for this service. This account size is negotiable."

**What changed in Twele Capital Management, Inc.'s recent Form ADV filings?**
In the February 2026 filing data: Regulatory assets under management went from $484,354,195 to $578,455,059 (+19%).

## From the Form ADV filing

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

### Fees and minimums (Form ADV Part 2A brochure dated January 6, 2026)

- Account minimum: $500,000 (the brochure says it may be waived or negotiated)

> Generally, a minimum of $500,000 of assets under management is required for this service. This account size is negotiable.

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

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., Inc.

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: $578,455,059
- Discretionary: $578,455,059
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 30 | $16,190,990 |
| High net worth individuals | 37 | $95,570,731 |
| 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) | Fewer than 5 | $456,760,473 |
| Charitable organizations | Fewer than 5 | $2,088,142 |
| 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 | Fewer than 5 | $6,758,894 |
| Other | Fewer than 5 | $1,085,829 |

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

### Firm details
- Registered since: 2007 (19 years)
- Employees: 4 total, 3 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: MN, TX
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- twelecapital.com
- LinkedIn @twele-capital-management-inc

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $580,954,883 | 6 | March 11, 2021 |
| October 2022 | $810,904,079 | 5 | July 25, 2022 |
| October 2023 | $624,711,832 | 5 | February 9, 2023 |
| October 2024 | $636,528,502 | 4 | September 30, 2024 |
| October 2025 | $484,354,195 | 4 | January 24, 2025 |
| October 2026 | $578,455,059 | 4 | January 6, 2026 |

Regulatory assets under management: $580,954,883 in the October 2021 data and $578,455,059 in the October 2026 data, unchanged.
Total employees: 6 in October 2021 and 4 in October 2026.

## Changes in the filing (last 12 months)

### February 2026
- Regulatory assets under management went from $484,354,195 to $578,455,059 (+19%).

### January 2026
- No longer registered or notice-filed in MO.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Twele Capital Management, Inc. (CRD 130239): Form ADV filing data as of October 2026.