SEC-registered independent wealth management RIA
Paul Comstock Partners
As of its Form ADV filed May 22, 2026, Paul Comstock Partners, an SEC-registered independent wealth management RIA in Houston, Texas, reported $2.8 billion in regulatory assets under management across 120 accounts, ranking #21 among independent RIAs in Texas by assets.
Registration
- Registration
- SEC-registered, Approved
- CRD number
- 105335
- SEC file number
- 801-22496
- Registered since
- November 5, 1984
- Latest Form ADV filing
- May 22, 2026
- Legal name
- FIRST ENDOWMENT DEVELOPMENT CORP
- Organized as
- Corporation
- Fiscal year ends
- December
- Other offices
- 0
Key figures
- Regulatory assets under management
- $2.8 billion
- Discretionary
- $260.0 million (9.3%)
- Non-discretionary
- $2.5 billion
- Accounts
- 120 (29 discretionary)
- Clients
- 123, approximate as reported
- Employees
- 16
- Advisory staff
- 11 performing investment advisory functions
- Average account
- $23.3 million
- Asset growth, 1 year
- 25.1% (from $2.2 billion a year earlier)
- Asset growth, 3-year annual rate
- -0.7% (from $2.9 billion three years earlier)
- Asset growth, 5-year annual rate
- 0.1% (from $2.8 billion five years earlier)
- Client growth, 1 year
- 1.7% (from 121)
Independent wealth management RIA: individual and high net worth clients hold at least half of its regulatory assets, it offers financial planning or portfolio management for individuals, and it is not a broker-dealer, a bank or part of one by the directory's rules. How firms are classed.
Growth rates come from the SEC's yearly snapshots and are left blank when the years are not comparable.
Rankings
Among independent wealth management RIAs.
| Ranking | Nationally | In Texas | Value |
|---|---|---|---|
| Largest independent RIAs by assets under management | #423 | #21 | $2.8 billion |
| Fastest-growing independent RIAs over one year | #1,495 | #115 | 25.1%from $2.2 billion |
| Fastest-growing independent RIAs over three years | #5,261 | #384 | -0.7%from $2.9 billion |
| Fastest-growing independent RIAs over five years | #4,400 | #312 | 0.1%from $2.8 billion |
| Independent RIAs with the biggest asset gains over one year | #367 | #26 | $561.3 million |
| Independent RIAs with the most clients | #7,800 | #526 | 123 |
| Independent RIAs with the fastest client growth over one year | #3,612 | #259 | 1.7%from 121 |
| Independent RIAs with the most accounts | #10,571 | #754 | 120 |
| Independent RIAs with the most advisory staff | #976 | #79 | 11 |
| Independent RIAs with the most high net worth clients | #2,877 | #195 | 109 |
| Independent RIAs with the most CFP professionals | #3,524 | #266 | 1 |
Assets over time
Data table
| As of | RAUM |
|---|---|
| October 1, 2010 | $131.3 million |
| October 3, 2011 | $1.6 billion |
| October 1, 2012 | $1.6 billion |
| October 1, 2013 | $1.9 billion |
| October 1, 2014 | $2.1 billion |
| October 1, 2015 | $2.5 billion |
| October 3, 2016 | $2.3 billion |
| October 2, 2017 | $2.1 billion |
| October 1, 2018 | $2.2 billion |
| October 1, 2019 | $2.2 billion |
| October 1, 2020 | $2.4 billion |
| October 4, 2021 | $2.8 billion |
| October 3, 2022 | $3.4 billion |
| October 5, 2023 | $2.9 billion |
| October 1, 2024 | $2.0 billion |
| September 2, 2025 | $2.2 billion |
| October 2, 2026 | $2.8 billion |
Clients and services
Client mix
| Measure | Bar | RAUM |
|---|---|---|
| High net worth individuals 109 clients | $2.3 billion | |
| Charitable organizations 11 clients | $531.4 million |
How the firm is paid
- A percentage of assets under management
- Fixed fees
Advisory services
- Financial planning
- Portfolio management for individuals or small businesses
- Portfolio management for businesses or institutional clients
- Selection of other advisers
Financial planning clients (Item 5.H): 51-100.
Wrap fee program sponsor or portfolio manager: no.
Other business, affiliations and custody
Other business activities (Item 6.A)
None reported.
Financial industry affiliations (Item 7.A)
None reported.
Custody (Item 9)
The firm reported custody of client cash or securities, $611.8 million in total.
Investment adviser representatives
- IARs registered with the firm
- 13
- Also registered through a broker-dealer
- 0
- Employees who are IARs (Form ADV 5.B(3))
- 11
Designations held by the firm's IARs: CFA 3, CFP 1, ChFC 1.
0 of the firm's 13 IARs are registered in jurisdictions that require IAR CE. IAR CE requirements by state.
Counts only. AdvisorIQ does not list individual people.
Disclosures
On Form ADV Item 11 the firm answered yes to 0 disclosure questions. See the detail on IAPD.
Succession and acquired firms
On Form ADV Item 4 the firm did not report succeeding to another adviser's business.
Similar-sized firms in Texas
| Firm | City | RAUM |
|---|---|---|
| SFMG Wealth Advisors | Plano | $3.0 billion |
| Legacy Knight Mfo, LLC | Dallas | $2.8 billion |
| Maslow Wealth Advisors | Austin | $2.8 billion |
| Titleist Asset Management, LLC | San Antonio | $2.8 billion |
| Turtle Creek Wealth Advisors, LLC | Dallas | $2.8 billion |
The five independent RIAs nearest in regulatory assets with a main office in the same state.
Elsewhere
- Paul Comstock Partners on IAPD: Form ADV, brochures and disclosure detail.
- Firm website: www.paulcomstockpartners.com
- Independent RIAs in Texas
Firm data as of October 2, 2026, from ia100226.zip. Figures are as the firm reported them; corrections are made on Form ADV and appear after the next monthly reload.
Data as of October 2, 2026, from Form ADV. Sources: SEC registered adviser data (ia100226.zip) and IAPD compilation reports. How the directory is built.