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PAUL COMSTOCK PARTNERS
Legal name: FIRST ENDOWMENT DEVELOPMENT CORP
CRD 105335File 801-22496
APPROVED
Retail clients
Custody
Filing as of May 22, 2026
Feed vintage Oct 1, 2026
Regulatory AUM
$2.80B
Top 25% of cohort (national)
Discretionary AUM
$260.0M
Non-discretionary $2.54B
Clients
120
120 accounts
Employees
16
Top 25% of cohort in TX
Identity & registration
ADV Item 1- Organization form
- Corporation
- Firm type
- Registered
- SEC region
- FWRO
- Registration date
- Nov 5, 1984
- Principal office
- 1177 WEST LOOP SOUTH, SUITE 1500, HOUSTON, TX, 77027
- Phone
- 713-977-2694
Assets & accounts
ADV Item 5F- Total regulatory AUM
- $2.80B
- Discretionary AUM
- $260.0M
- Non-discretionary AUM
- $2.54B
- Discretionary accounts
- 29
- Non-discretionary accounts
- 91
- Total accounts
- 120
- AUM per client
- $23.3M
Clients by type
ADV Item 5D| Client type | Clients | AUM |
|---|---|---|
| Charitable organizations | 11 | $531.4M |
| High net worth individuals | 109 | $2.27B |
Compensation & activities
ADV Items 5E, 5GCompensation
- Fixed fees
- A percentage of assets under your management
Advisory activities
- Financial planning services
- Selection of other advisers
- Portfolio management for businesses
- Portfolio management for individuals and/or small businesses
Custody
ADV Item 9- Firm Custody Cash
- Yes
- Firm Custody Assets
- No
- Firm Custody Clients
- No
- Firm Custody Securities
- Yes
- Related Person Custody Cash
- No
- Related Person Custody Assets
- No
- Related Person Custody Clients
- No
- Related Person Custody Securities
- No
Disclosure events
ADV Item 11This firm answered no to every Item 11 disclosure question in this filing.
Filed changes
| Date | Field | From | To | Change |
|---|---|---|---|---|
| Jun 1, 2026 | Employees | 15 | 16 | increased by1 |
| Apr 1, 2026 | Employees | 16 | 15 | decreased by1 |
| Apr 1, 2026 | Clients | 118 | 120 | increased by2 |
| Apr 1, 2026 | AUM | $2,238,868,684 | $2,800,211,607 | increased by$561,342,923 |
| Apr 1, 2026 | Accounts | 118 | 120 | increased by2 |
| Feb 1, 2026 | Employees | 17 | 16 | decreased by1 |
| May 1, 2025 vs Oct 1, 2022 | Employees | 14 | 17 | increased by3 |
| May 1, 2025 vs Oct 1, 2022 | Clients | 111 | 118 | increased by7 |
| May 1, 2025 vs Oct 1, 2022 | AUM | $3,365,393,181 | $2,238,868,684 | decreased by$1,126,524,497 |
| May 1, 2025 vs Oct 1, 2022 | Accounts | 111 | 118 | increased by7 |
| Mar 1, 2022 | Clients | 112 | 111 | decreased by1 |
| Mar 1, 2022 | AUM | $2,789,443,496 | $3,365,393,181 | increased by$575,949,685 |
| Mar 1, 2022 | Accounts | 112 | 111 | decreased by1 |
| Apr 1, 2021 | Registration | — | APPROVED |
On Form 5500, an adviser usually appears as a plan service provider (Schedule C), not the plan sponsor.
See plans that list “PAUL COMSTOCK” as a service provider on 5500mcp →Matched by name only — Form ADV and Form 5500 share no identifier, and names are searched loosely (“PAUL COMSTOCK” may also match similarly-named firms). Confirm identity against each filing.
Every value above is reproduced from this firm's Form ADV filing. Fields the firm left blank are shown as “Not reported” rather than filled in from other sources.

