First Endowment Development provides financial planning, portfolio management for individuals and small businesses, portfolio management for institutions, and selecting other managers. Financial planning was provided to 51–100 clients last fiscal year.
First Endowment Development reports 120 clients. They include 109 high-net-worth individuals and 11 charitable organizations. Of its assets, 9.3% ($260M across 29 accounts) are managed with discretion; $2.54B across 91 accounts are not. It advised 3 clients without assets under management last fiscal year.
| Client type | Clients | Assets |
|---|---|---|
| High-net-worth individuals | 91% | 81% |
| Charitable organizations | 9% | 19% |
Client breakdown and activity details
| Client type | Clients | Regulatory AUM | AUM share | Avg. per client |
|---|---|---|---|---|
| High-net-worth individuals | 109 | $2.27B | 81.0% | $20.8M |
| Charitable organizations | 11 | $531M | 19.0% | $48.3M |
| Total | 120 | $2.8B | 100% | $23.3M |
- Clients
- 109
- Regulatory AUM
- $2.27B
- AUM share
- 81.0%
- Avg. per client
- $20.8M
- Clients
- 11
- Regulatory AUM
- $531M
- AUM share
- 19.0%
- Avg. per client
- $48.3M
Total
- Clients
- 120
- Regulatory AUM
- $2.8B
- AUM share
- 100%
- Avg. per client
- $23.3M
- Clients outside the U.S.
- 0%
- Clients advised without assets under management last fiscal year
- 3
- Private funds advised
- 0
- Financial planning clients last fiscal year
- 51–100
First Endowment Development charges 0.20%–0.70% a year for its Investment Advisory Services. The fee is billed in advance and is negotiable. The brochure also prices one other service, listed under fee details.
Fee details and sources
Other fees
- Present Position Analysis
- A one-time review of portfolio, financial and estate planning, typically $25,000 to $150,000, agreed before engagement.
Alison Comstock Moss Separate Property Trust owns 50% to 75% of First Endowment Development. It has 16 employees, 11 of them in advisory roles.
Leadership
- Stephen BrowneDirector,cio,cco
- Paul ComstockDirector, Relationship Manager
- Alison MossChairman/CEO
Investment adviser representatives
13 representatives listed in the SEC register as of 9 October 2026.
- Jose Abelino Amoles
- Stephen Carpenter Browne
- Julie Anne Choate
- Paul Leon Comstock
- Bryce Kyle Cooper
- James Andrew Crockett
- Anne-Elizabeth Huynh
- Jaqlyn Ann Lullo
- Matthew Kerr Mackey
- Alison Comstock Moss
- Nicholas Allen Price
- Marc Daniel Shmerling
- Winton Floyd Starling
Staff
- 16 employees
- 11 in advisory functions
- 11 state-registered reps
- 1 insurance agent
- 1 soliciting firm
- Owns 50% to 75% of First Endowment Development Corp
Alison Comstock Moss Separate Property Trust
Control person · since March 2018
Alison Moss
Trustee · Control person · since January 2018
- Owns 50% to 75% of First Endowment Development Corp
Alison Comstock Moss Separate
Control person · since March 2018
- Owns 25% to 50% of First Endowment Development Corp
Paul Comstock
Control person · since March 2018
First Endowment Development’s regulatory assets went from $2.79B (April 2021) to $2.8B (May 2026); clients rose from 112 to 120 and employees from 14 to 16.
Figures from each annual filing
| Filed | Regulatory AUM | Clients | Employees | Offices |
|---|---|---|---|---|
| May 2026 | $2.8B | 120 | 16 | 1 |
| April 2025 | $2.24B | 118 | 17 | 1 |
| May 2024 | $2.03B | 114 | 16 | 1 |
| May 2023 | $2.86B | 110 | 14 | 1 |
| February 2022 | $3.37B | 111 | 14 | 1 |
| April 2021 | $2.79B | 112 | 14 | 1 |
Besides its headquarters, First Endowment Development has 0 offices, with 1 listed address in Texas.
Texas · 1 listed address
- 1177 West Loop South, Suite 1500, HoustonHQ
Contact and registration details
- Legal name
- First Endowment Development Corp
- Headquarters
- 1177 West Loop South, Suite 1500, Houston, TX 77027
- Website
- paulcomstockpartners.com
- Phone
- 713-977-2694
- @paulcomstockpartners
- SEC file
- 801-22496
- Structure
- Texas corporation
- Fiscal year end
- December
First Endowment Development uses Charles Schwab ($1.94B, 80%) and Northern Trust ($474M, 20%) as custodians for its separately managed accounts. First Endowment Development has custody of $612M in client assets for 67 clients.
- Charles SchwabCharles Schwab & Co., Inc. · Westlake, TX · $1.94B80%
- Northern TrustNorthern Trust · Chicago, IL · $474M20%
At year end, First Endowment Development’s separately managed accounts were mostly in funds (55%) and stocks (34%).
What the accounts hold
- Stocks34%
- Funds55%
- Registered funds48%
- Pooled vehicles7%
- Bonds6%
- State and local bonds4%
- U.S. government and agency bonds1%
- Investment grade corporate bonds1%
- Cash6%
How many clients does First Endowment Development have?
First Endowment Development has 120 clients and manages $2.8 billion for them, as of May 2026. They include 109 high-net-worth individuals and 11 charitable organizations.
Source: Form ADV Part 1A, Items 5.D and 5.F, filed 22 May 2026
What services does First Endowment Development offer?
First Endowment Development provides financial planning, portfolio management for individuals and small businesses, portfolio management for institutions, and selecting other managers.
Source: Form ADV Part 1A, Item 5.G, from the SEC's 2 October 2026 data file
How much does First Endowment Development charge?
First Endowment Development charges 0.20%–0.70% a year for its Investment Advisory Services. The fee is billed in advance and is negotiable.
Which custodians does First Endowment Development use?
First Endowment Development’s separately managed account assets are held at Charles Schwab & Co., Inc. (Westlake, TX), with $1.94B and Northern Trust (Chicago, IL), with $474M. Only custodians holding at least a tenth of those assets are named.
Source: Form ADV Part 1A, Schedule D, Section 5.K.(3), filed 22 May 2026
How many financial advisors does First Endowment Development have?
First Endowment Development has 11 investment adviser representatives registered with state securities authorities, out of 16 employees, and 11 perform investment advisory functions. 0 employees are registered representatives of a broker-dealer and 1 employee is a licensed insurance agent.
Source: Form ADV Part 1A, Items 5.A and 5.B, from the SEC's 2 October 2026 data file
What does First Endowment Development invest in?
At the end of its last fiscal year, First Endowment Development’s separately managed accounts held 48% registered funds (mutual funds, ETFs, BDCs), 34% exchange-traded equities, 7% pooled vehicles (private funds and similar), 6% cash and equivalents, 4% state and local bonds, 1% U.S. government and agency bonds and 1% investment grade corporate bonds.
Source: Form ADV Part 1A, Items 5.K.(1) and 7.B, from the SEC's 2 October 2026 data file
Who owns First Endowment Development?
First Endowment Development’s direct owners are Paul Comstock (25% to 50%), Alison Comstock Moss Separate Property Trust (50% to 75%) and Alison Comstock Moss Separate (50% to 75%).
Source: Form ADV Part 1A, Schedules A and B, filed 22 May 2026
How does First Endowment Development get paid?
First Endowment Development is paid through a percentage of assets under management and fixed fees. Its Form ADV lists no commissions or performance-based fees among how it is paid.
Source: Form ADV Part 1A, Item 5.E, from the SEC's 2 October 2026 data file
Is First Endowment Development registered with the SEC?
Yes, First Endowment Development has been registered with the SEC as an investment adviser since 5 November 1984. Its CRD number is 105335 and its SEC file number is 801-22496.
Source: Form ADV Part 1A, Item 1, filed 22 May 2026; IAPD firm record
How do I contact First Endowment Development?
First Endowment Development’s main office is at 1177 West Loop South, Suite 1500, Houston, TX 77027. Its phone number is 713-977-2694. Its website is paulcomstockpartners.com.