TOPTURN CAPITAL, LLC

CRD 151464File 801-70572

APPROVED

Retail clients

Custody

Filing as of Mar 30, 2026

Feed vintage Aug 17, 2026

Regulatory AUM

$187.4M

Bottom 25% of cohort (national)

Discretionary AUM

$167.1M

Non-discretionary $20.2M

Clients

106

318 accounts

Employees

Bottom 25% of cohort in CA

Identity & registration

ADV Item 1

Organization form: Limited Liability Company
Firm type: Registered
SEC region: SFRO
Registration date: Sep 15, 2009
Principal office: 200 CLOCK TOWER PLACE, SUITE B208, CARMEL, CA, 93923
Phone: (831) 324-0481
Website: https://www.facebook.com/topturncapital/

Assets & accounts

ADV Item 5F

Total regulatory AUM: $187.4M
Discretionary AUM: $167.1M
Non-discretionary AUM: $20.2M
Discretionary accounts: 271
Non-discretionary accounts: 47
Total accounts: 318
AUM per client: $1.8M

Clients by type

ADV Item 5D

Client type	Clients	AUM
Other	8	$3.4M
Charitable organizations	9	$36.5M
High net worth individuals	45	$105.4M
Pension and profit sharing plans	6	$21.9M
Individuals (other than high net worth individuals)	38	$20.1M

Compensation & activities

ADV Items 5E, 5G

Compensation

Fixed fees
A percentage of assets under your management

Advisory activities

Financial planning services
Selection of other advisers
Portfolio management for other
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: Yes

Disclosure events

ADV Item 11

This firm answered no to every Item 11 disclosure question in this filing.

Filed changes

Date	Field	From	To
Aug 12, 2026	Registration	—	APPROVED

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.