Wealth manager, independent · Houston, TX
Paul Comstock Partners
First Endowment Development Corp · SEC-registered investment adviser · CRD 105335 · SEC 801-22496
At a glance
Paul Comstock Partners is an SEC-registered investment adviser based in Houston, Texas, with $2.8B in regulatory assets under management as of its Form ADV filed May 22, 2026. It reports 109 individual clients, 109 of them high-net-worth, holding an average of about $21 million each, and 16 employees. That ranks it 400th among the nation’s 5,657 independent wealth management RIAs and 20th of 367 in Texas. It reports 2 custodians for its clients’ separately managed accounts: Charles Schwab and Northern Trust.
Main office 713-977-2694paulcomstockpartners.comLinkedInAs filed on Form ADV
- Regulatory AUM
- $2.8B
- Rank among independent wealth managers
- #400 of 5,657
- Rank among all SEC RIAs
- #2,957 of 17,210
- Rank in Texas
- #20 of 367
- Individual clients
- 109
- High-net-worth clients
- 109
- Accounts
- 120
- Discretionary
- 9% of AUM
- Employees
- 16
- Advisory staff
- 11
- Offices
- 1
Owners and executives on its Form ADV
- Stephen C. BrowneDirector,cio,cco
- Paul L. ComstockDirector, Relationship Manager
- Alison C. MossChairman/ceo
Custody and brokerage
Broker-dealer
No broker-dealer ties
Paul Comstock Partners reports no employees registered with a broker-dealer and no affiliated broker-dealer.
Who it serves
| Client type | Clients | Regulatory AUM | Share |
|---|---|---|---|
| High-net-worth individuals | 109 | $2.3B | 81% |
| Charitable organizations | 11 | $531M | 19% |
Disciplinary disclosures
Paul Comstock Partners reports no disciplinary disclosures in Item 11 of Form ADV. Read the details on the SEC’s adviser search ↗
Services
- Financial planning
- Portfolio management for individuals and small businesses
- Portfolio management for businesses and institutions
- Selecting other advisers
How it’s paid
- A percentage of assets under management
- Fixed fees
Form ADV and brochures on the SEC’s adviser search ↗paulcomstockpartners.com ↗
AtlasMembers
The full record on Paul Comstock Partners
Ten years of SEC filings, its owners and contacts, and how it stacks up against its peers. Atlas members see all of it.
- Assets, accounts, clients and staff, ten years of filings
- Locked
- Growth over one, three and five years
- Locked
- Rank against 1,434 peers of its type and size
- Locked
- Owners and executives, with titles and stakes
- 3 namedLocked
- Main office, fax and compliance officer
- Locked
- Filing changes this year, with alerts
- 1Locked
Free while Atlas launches: create a free account and confirm your email. Every figure comes from SEC filings.
Similar-size RIAs in Texas
All of Texas →| Firm | Regulatory AUM | Clients |
|---|---|---|
| 1900 WealthSAN Antonio | $3.1B | 454 |
| Sfmg Wealth AdvisorsPlano | $3.0B | 968 |
| Legacy Knight MFO, LLCDallas | $2.8B | 20 |
| Titleist Asset Management, LLCSAN Antonio | $2.8B | 2,103 |
| Icon Wealth PartnersHouston | $2.6B | 617 |
| Warwick PartnersBryan | $2.5B | 253 |
Background
Questions
How much does Paul Comstock Partners manage?
Paul Comstock Partners reports $2.8B in regulatory assets under management across 120 accounts, 9% of it on a discretionary basis, on its Form ADV filed May 22, 2026.
How many clients does Paul Comstock Partners have?
It reports 109 individual clients: 109 high-net-worth individuals and 0 other individuals. Individuals account for about 81% of its regulatory assets.
Where is Paul Comstock Partners headquartered?
Its main office is in Houston, Texas. It reports 1 office in total and 16 employees, 11 of whom perform investment advisory functions.
How does Paul Comstock Partners charge clients?
On Form ADV it lists these forms of compensation: a percentage of assets under management; fixed fees. Fees and minimums are set out in its Form ADV Part 2A brochure, available on the SEC’s adviser search.
What custodian does Paul Comstock Partners use?
It reports 2 custodians for its clients’ separately managed accounts: Charles Schwab and Northern Trust. On Schedule D of its Form ADV filed May 22, 2026, it reports these amounts held: Charles Schwab ($1.9B); Northern Trust ($474M). Form ADV lists only custodians holding 10% or more of separately managed account assets.
Is Paul Comstock Partners a hybrid RIA with a broker-dealer?
Paul Comstock Partners reports no employees registered with a broker-dealer and no affiliated broker-dealer.
Is Paul Comstock Partners a fiduciary?
As an SEC-registered investment adviser, Paul Comstock Partners owes its advisory clients a fiduciary duty under the Investment Advisers Act of 1940, which includes duties of care and loyalty. It reports no employees who are registered representatives of a broker-dealer.
Where these numbers come from
Every figure is Paul Comstock Partners’s own answer on its latest Form ADV, from the SEC’s registered-adviser list as of October 1, 2026: regulatory assets and accounts (Item 5.F), clients by type (5.D), employees (5.A and 5.B), compensation (5.E) and services (5.G). Custodians come from Schedule D 5.K(3) of its latest filing (2026-05-22), which lists those holding 10% or more of separately managed account assets and the amount at each. “Hybrid” means some employees are also registered representatives of a broker-dealer (Item 5.B(2)); affiliated broker-dealers are the related persons it lists in Item 7.A and Schedule D. Firm type comes from its own answers: broker-dealer firms are registered broker-dealers themselves (Item 6.A); private fund advisers manage mostly private funds (Item 7.B, 5.D); wealth managers manage at least half their assets for individuals (5.D). Its national rank compares it with every US-based independent wealth management RIA, the same field as The Largest RIAs. Figures are as of the firm’s last annual update, so they can lag recent deals and market moves. Regulatory AUM counts assets the firm continuously supervises and can differ from what a firm markets.
Not an endorsement or a recommendation. Before hiring any adviser, read its Form ADV Part 2A brochure and check its record on the SEC’s adviser search. How to check a financial advisor →