# Wincoram Asset Management LLC

> Wincoram Asset Management LLC is an SEC-registered investment advisory firm in Houston, TX, registered since 2021, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 312425
- Filed as: WINCORAM ASSET MANAGEMENT LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Houston, TX
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/312425
- AdvisorCensus page: https://advisorcensus.com/firm/wincoram-asset-management-llc-houston-tx-312425

## Quick answers

**How is Wincoram Asset Management LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Wincoram Asset Management LLC reports these compensation arrangements: a percentage of assets under its management; performance-based fees. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Wincoram Asset Management LLC located?**
Wincoram Asset Management LLC's principal office is in Houston, TX, according to its Form ADV.

**Is Wincoram Asset Management LLC registered with the SEC or a state?**
Wincoram Asset Management LLC is an SEC-registered investment advisory firm, registered since 2021. Status as filed: Approved. CRD 312425.

**How much does Wincoram Asset Management LLC manage?**
Wincoram Asset Management LLC reports $8,186,110,539 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (89% discretionary).

**How have Wincoram Asset Management LLC's assets and staff changed since 2021?**
In the Form ADV data for Wincoram Asset Management LLC: Regulatory assets under management: $414,242,500 in the October 2021 data and $8,186,110,539 in the October 2026 data, up 1876%. Total employees: 10 in October 2021 and 28 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Wincoram Asset Management LLC serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (15).

**Does Wincoram Asset Management LLC report any disciplinary disclosures?**
Reports 1 disclosure item on Form ADV Item 11: yes answers to 11.E(2) (self-regulatory organization's finding of a rule violation). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/312425

**What changed in Wincoram Asset Management LLC's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 13 to 11. Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

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

### Regulatory assets under management (Item 5.F)
- Total: $8,186,110,539
- Discretionary: $7,257,073,958
- Non-discretionary: $929,036,581

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 15 | $7,260,517,763 |
| Insurance companies | Fewer than 5 | $620,010,318 |
| Corporations or other businesses not listed above | Fewer than 5 | $305,582,458 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients

### Firm details
- Registered since: 2021 (5 years)
- Employees: 28 total, 11 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: TX
- Disclosures (Item 11): Reports 1 disclosure item on Form ADV Item 11.

### Item 11 questions answered yes
- 11.E(2): Has a self-regulatory organization or a commodities exchange ever found that the firm or an advisory affiliate was involved in a violation of its rules, other than a minor rule violation under a plan the SEC approved?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/312425

### Websites listed on Form ADV (Item 1.I)
- LinkedIn @wincoram-asset-management

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $414,242,500 | 10 | August 30, 2021 |
| October 2022 | $1,220,920,914 | 10 | March 31, 2022 |
| October 2023 | $2,026,282,215 | 12 | August 31, 2023 |
| October 2024 | $2,385,583,398 | 18 | May 10, 2024 |
| October 2025 | $5,920,735,973 | 26 | March 29, 2025 |
| October 2026 | $8,186,110,539 | 28 | March 31, 2026 |

Regulatory assets under management: $414,242,500 in the October 2021 data and $8,186,110,539 in the October 2026 data, up 1876%.
Total employees: 10 in October 2021 and 28 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 13 to 11.
- Updated its list of owners and control persons (Schedule A).

### December 2025
- Item 11 disclosure answers changed: 1 yes answer, previously 0 (now yes: 11.E(2)).
- Regulatory assets under management went from $5,920,735,973 to $8,091,328,267 (+37%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Wincoram Asset Management LLC (CRD 312425): Form ADV filing data as of October 2026.