{"url":"https://nivawealth.com/firms/first-endowment-development-105335","iapdUrl":"https://adviserinfo.sec.gov/firm/summary/105335","regulatoryAum":2800211607,"crd":"105335","adviserRoster":{"asOf":"2026-10-09","items":[{"crd":"7452466","suffix":null,"lastName":"Amoles","firstName":"Jose","middleName":"Abelino"},{"crd":"4522357","suffix":null,"lastName":"BROWNE","firstName":"STEPHEN","middleName":"CARPENTER"},{"crd":"5690133","suffix":null,"lastName":"CHOATE","firstName":"JULIE","middleName":"ANNE"},{"crd":"51804","suffix":null,"lastName":"COMSTOCK","firstName":"PAUL","middleName":"LEON"},{"crd":"6449320","suffix":null,"lastName":"COOPER","firstName":"BRYCE","middleName":"KYLE"},{"crd":"8268980","suffix":null,"lastName":"Crockett","firstName":"James","middleName":"Andrew"},{"crd":"3195490","suffix":null,"lastName":"HUYNH","firstName":"ANNE-ELIZABETH","middleName":null},{"crd":"5931245","suffix":null,"lastName":"Lullo","firstName":"Jaqlyn","middleName":"Ann"},{"crd":"8215099","suffix":null,"lastName":"Mackey","firstName":"Matthew","middleName":"Kerr"},{"crd":"5524696","suffix":null,"lastName":"MOSS","firstName":"ALISON","middleName":"COMSTOCK"},{"crd":"6954518","suffix":null,"lastName":"Price","firstName":"Nicholas","middleName":"Allen"},{"crd":"5680906","suffix":null,"lastName":"SHMERLING","firstName":"MARC","middleName":"DANIEL"},{"crd":"4726822","suffix":null,"lastName":"STARLING","firstName":"WINTON","middleName":"FLOYD"}],"total":13,"loadedAt":"2026-10-10T00:20:19.761928+00:00","sourceUrl":"https://reports.adviserinfo.sec.gov/reports/CompilationReports/IA_INDVL_Feed_10_09_2026.xml.zip"},"history":[{"filedOn":"2021-04-09","regulatoryAum":2789443496,"clients":112,"employees":14,"offices":1},{"filedOn":"2022-02-28","regulatoryAum":3365393181,"clients":111,"employees":14,"offices":1},{"filedOn":"2023-05-11","regulatoryAum":2857791123,"clients":110,"employees":14,"offices":1},{"filedOn":"2024-05-31","regulatoryAum":2031373540,"clients":114,"employees":16,"offices":1},{"filedOn":"2025-04-16","regulatoryAum":2238868684,"clients":118,"employees":17,"offices":1},{"filedOn":"2026-05-22","regulatoryAum":2800211607,"clients":120,"employees":16,"offices":1}],"secFileNumber":"801-22496","legalName":"First Endowment Development Corp","displayName":"First Endowment Development","slug":"first-endowment-development-105335","website":"https://paulcomstockpartners.com/","classification":{"segment":"individuals","segmentLabel":"Wealth management","type":"independent_wealth_manager","typeLabel":"RIA","feeDisclosure":"full"},"linkedinUrl":"https://www.linkedin.com/company/paulcomstockpartners/","founded":null,"organization":"Texas corporation","fiscalYearEnd":"December","headquarters":{"street":"1177 West Loop South, Suite 1500","city":"Houston","state":"TX","stateName":"Texas","country":"United States","postalCode":"77027"},"tradeNames":[],"registration":{"secApproved":"5 November 1984","noticeFilings":null,"latestNoticeFiling":null},"wealthAumPerClient":20814349.394495413,"staff":{"employees":16,"advisory":11,"brokerDealerReps":0,"insuranceAgents":1,"promoters":1},"aum":{"regulatory":2800211607,"discretionary":260017465,"discretionaryAccounts":29,"nonDiscretionary":2540194142,"nonDiscretionaryAccounts":91,"wrapProgram":null,"nonUsClientsPct":0,"nonAumClients":3},"clientTypes":[{"label":"High-net-worth individuals","clients":109,"regulatoryAum":2268764084},{"label":"Charitable organizations","clients":11,"regulatoryAum":531447523}],"feePrograms":[{"role":"main","program":"Investment Advisory Services","feeBasis":"range","fee_tiers":null,"sourceUrl":"https://files.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=1041486","versionId":1041486,"ratePeriod":"annual","fee_billing":"advance","submittedOn":"2026-04-15","documentName":"PART 2A - FIRM BROCHURE","fee_rate_low":0.2,"fee_rate_high":0.7,"fee_negotiable":true,"minimum_account":null,"feeMinimumPeriod":null,"fee_minimum_annual":null},{"role":"other","program":"Present Position Analysis","summary":"A one-time review of portfolio, financial and estate planning, typically $25,000 to $150,000, agreed before engagement.","sourceUrl":"https://files.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=1041486","versionId":1041486,"submittedOn":"2026-04-15","documentName":"PART 2A - FIRM BROCHURE"}],"brochureCoverage":{"scope":"sec_inventory","status":"reviewed","checkedAt":"2026-10-22T03:56:35.1273+00:00","documents":[{"name":"PART 2A - FIRM BROCHURE","status":"read","sourceUrl":"https://files.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=1041486","versionId":1041486,"submittedOn":"2026-04-15"}]},"custodians":[{"name":"Charles Schwab & Co., Inc.","shortName":"Charles Schwab","location":"Westlake, TX","smaAssets":1942928700},{"name":"Northern Trust","shortName":"Northern Trust","location":"Chicago, IL","smaAssets":473651665}],"custodyNote":"First Endowment Development has custody of $612M in client assets for 67 clients.","leadership":[{"name":"Stephen Browne","title":"Director,cio,cco","crd":"4522357"},{"name":"Paul Comstock","title":"Director, Relationship Manager","crd":"51804"},{"name":"Alison Moss","title":"Chairman/CEO","crd":"5524696"}],"ownership":[{"label":"Paul Comstock","detail":"Director, relationship manager in the 25% to 50% ownership band and a control person, since March 2018."},{"label":"Alison Comstock Moss Separate Property Trust","detail":"Owner in the 50% to 75% ownership band and a control person, since March 2018."},{"label":"Alison Comstock Moss Separate","detail":"Owner in the 50% to 75% ownership band and a control person, since March 2018."},{"label":"Alison Moss","detail":"Indirect owner: trustee of Alison Comstock Moss Separate Property Trust and a control person, since January 2018.","parent":"Alison Comstock Moss Separate Property Trust"}],"filedOffices":{"otherThanPrincipal":0,"privateResidences":0},"listedOfficeAddresses":1,"foreignOffices":[],"officesByState":[{"state":"Texas","offices":1,"addresses":[{"street":"1177 West Loop South, Suite 1500","city":"Houston","headquarters":true}]}],"advFacts":{"source":{"file":"ia100226.zip","asOf":"2 October 2026"},"telephone":"713-977-2694","stateRegisteredReps":11,"otherAdviserReps":0,"compensation":["A percentage of assets under management","Fixed fees (other than subscription fees)"],"activities":["Financial planning services","Portfolio management for individuals and/or small businesses","Portfolio management for businesses (other than small businesses) or institutional clients","Selection of other advisers (including private fund managers)"],"financialPlanningClients":"51-100","assetMix":[{"label":"Exchange-traded equity securities","percent":34},{"label":"U.S. government/agency bonds","percent":1},{"label":"U.S. state and local bonds","percent":4},{"label":"Investment grade corporate bonds","percent":1},{"label":"Securities issued by registered investment companies or business development companies","percent":48},{"label":"Securities issued by pooled investment vehicles (other than registered investment companies)","percent":7},{"label":"Cash and cash equivalents","percent":6}],"privateFunds":0},"sources":{"adv1FilingDate":"22 May 2026","adv1Url":"https://reports.adviserinfo.sec.gov/reports/ADV/105335/PDF/105335.pdf","brochureDate":"15 April 2026","brochureUrl":"https://files.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=1041486","iapdCompiledDate":null,"retrievedDate":"15 October 2026","retrievedOn":"2026-10-15","updatedOn":"2026-10-22","holdingsUpdatedOn":"2026-10-21","adv1Pages":{},"brochurePages":{}},"otherBusiness":[],"faq":[{"question":"How many clients does First Endowment Development have?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"What services does First Endowment Development offer?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"How much does First Endowment Development charge?","answer":"First Endowment Development charges 0.20%–0.70% a year for its Investment Advisory Services. The fee is billed in advance and is negotiable.","source":"PART 2A - FIRM BROCHURE, filed 15 April 2026","sourceRef":{"doc":"brochure","section":"fees"}},{"question":"Which custodians does First Endowment Development use?","answer":"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","sourceRef":{"doc":"adv1","section":"custodians"}},{"question":"How many financial advisors does First Endowment Development have?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"What does First Endowment Development invest in?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"Who owns First Endowment Development?","answer":"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","sourceRef":{"doc":"adv1","section":"scheduleA"}},{"question":"How does First Endowment Development get paid?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"Is First Endowment Development registered with the SEC?","answer":"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","sourceRef":{"doc":"adv1","section":"identity"}},{"question":"How do I contact First Endowment Development?","answer":"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.","source":"Form ADV Part 1A, Item 1.F, filed 22 May 2026","sourceRef":{"doc":"adv1","section":"offices"}}],"holdings":null,"notice":"Compiled from public SEC Form ADV filings on the dates in `sources`. Facts as filed; not a rating, ranking, or recommendation. Niva is not affiliated with this firm. Disciplinary history is deliberately not included here or on the page; the SEC publishes the complete record at the `iapdUrl` above."}