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PUGH CAPITAL MANAGEMENT, INC.
CRD 111765File 801-39138
APPROVED
Custody
Filing as of Mar 24, 2026
Feed vintage Oct 1, 2026
Regulatory AUM
$12.82B
Top 10% of cohort (national)
Discretionary AUM
$12.81B
Non-discretionary $13.8M
Clients
50
82 accounts
Employees
39
Top 10% of cohort in WA
Identity & registration
ADV Item 1- Organization form
- Corporation
- Firm type
- Registered
- SEC region
- SFRO
- Registration date
- Jun 27, 1991
- Principal office
- 1700 7TH AVENUE, SUITE 1510, SEATTLE, WA, 98101
- Phone
- 206-322-4985
- Website
- https://www.pughcapital.com
Assets & accounts
ADV Item 5F- Total regulatory AUM
- $12.82B
- Discretionary AUM
- $12.81B
- Non-discretionary AUM
- $13.8M
- Discretionary accounts
- 79
- Non-discretionary accounts
- 3
- Total accounts
- 82
- AUM per client
- $256.4M
Clients by type
ADV Item 5D| Client type | Clients | AUM |
|---|---|---|
| Other | Fewer than 5 | $696.8M |
| Insurance companies | Fewer than 5 | $1.89B |
| Charitable organizations | 11 | $900.3M |
| Other investment advisers | Fewer than 5 | $307.4M |
| Pooled investment vehicles | 2 | $277.1M |
| Pension and profit sharing plans | 13 | $2.51B |
| State or municipal government entities | 17 | $4.78B |
Compensation & activities
ADV Items 5E, 5GCompensation
- Performance-based fees
- A percentage of assets under your management
Advisory activities
- Portfolio management for businesses
- Portfolio management for pooled investment vehicles
Custody
ADV Item 9- Firm Custody Cash
- Yes
- Firm Custody Assets
- No
- Firm Custody Clients
- No
- Firm Custody Securities
- Yes
- Related Person Custody Cash
- Yes
- 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 |
|---|---|---|---|---|
| Aug 17, 2026 | Clients | 52 | 50 | decreased by2 |
| Apr 1, 2026 | Employees | 38 | 39 | increased by1 |
| Apr 1, 2026 | Clients | 44 | 52 | increased by8 |
| Apr 1, 2026 | AUM | $13,139,004,601 | $12,821,941,180 | decreased by$317,063,421 |
| Apr 1, 2026 | Accounts | 86 | 82 | decreased by4 |
| May 1, 2025 vs Oct 1, 2022 | Employees | 27 | 38 | increased by11 |
| May 1, 2025 vs Oct 1, 2022 | Custody | No | Yes | |
| May 1, 2025 vs Oct 1, 2022 | Clients | 41 | 44 | increased by3 |
| May 1, 2025 vs Oct 1, 2022 | AUM | $11,661,821,284 | $13,139,004,601 | increased by$1,477,183,317 |
| May 1, 2025 vs Oct 1, 2022 | Accounts | 62 | 86 | increased by24 |
| Apr 1, 2022 | Employees | 24 | 27 | increased by3 |
| Apr 1, 2022 | Clients | 39 | 41 | increased by2 |
| Apr 1, 2022 | AUM | $10,068,152,334 | $11,661,821,284 | increased by$1,593,668,950 |
| Apr 1, 2022 | Accounts | 60 | 62 | increased by2 |
| 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 “PUGH CAPITAL” as a service provider on 5500mcp →Matched by name only — Form ADV and Form 5500 share no identifier, and names are searched loosely (“PUGH CAPITAL” 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.