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Pendleton Financial

Wealth managementRIA

Raleigh, NCCRD 325303Updated

Pendleton Financial is an investment adviser based in Raleigh, NC, registered with the SEC since 2023. It provides financial planning and investment management. Its clients include pension and profit-sharing plans, high-net-worth individuals, and individual clients. Its regulatory assets under management total $160 million, as filed on 31 March 2026.

143
Clients
$676K
AUM per individual client
1
Advisory staff
1
Offices
0.20–1.25%
Annual fee

From Form ADV filed 31 March 2026SEC record

Services and clients

Pendleton Financial provides financial planning, portfolio management for individuals and small businesses, pension consulting, selecting other managers, publishing newsletters, and educational seminars. Financial planning was provided to 101–250 clients last fiscal year.

Pendleton Financial reports 143 clients. They include 76 individual clients, 52 high-net-worth individuals, and 13 pension and profit-sharing plans. Of its assets, 100.0% ($160M across 365 accounts) are managed with discretion.

Clients and assets by client type
Clients143 clients
Assets$160M
Client typeClientsAssets
Individuals (other than HNW)53%12%
High-net-worth individuals36%42%
Pension and profit-sharing plans9%44%
Corporations and other businesses1%2%
Client breakdown and activity details
Individuals (other than HNW)
Clients
76
Regulatory AUM
$19.1M
AUM share
11.9%
Avg. per client
$251K
High-net-worth individuals
Clients
52
Regulatory AUM
$67.5M
AUM share
42.2%
Avg. per client
$1.3M
Pension and profit-sharing plans
Clients
13
Regulatory AUM
$69.9M
AUM share
43.6%
Avg. per client
$5.37M
Corporations and other businesses
Clients
Fewer than 5
Regulatory AUM
$3.63M
AUM share
2.3%
Avg. per client
$1.82M

Total

Clients
143
Regulatory AUM
$160M
AUM share
100%
Avg. per client
—
Clients outside the U.S.
0%
Clients advised without assets under management last fiscal year
0
Private funds advised
0
Financial planning clients last fiscal year
101–250

Fees and minimums

Pendleton Financial charges 0.20%–1.25% a year for its Investment Management Fees. 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

Pension Consulting & ERISA Retirement Advisory
Annual asset-based fee for ERISA plan consulting: 1.00% on the first $1 million, stepping down to 0.10% above $15 million, with a minimum of $500 a month or $1,500 a quarter.

Ownership and people

Gray Pendleton owns 75% or more of Pendleton Financial. The leadership team of Pendleton Financial includes President Gray Pendleton. It has 4 employees, 1 of them in advisory roles.

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Staff

  • 4 employees
  • 1 in advisory functions
  • 1 state-registered rep
  • 1 insurance agent
Who owns the firm
Pendleton Financial, LLC· the adviser
  • Gray Pendleton

    Control person · since February 2023

    Owns 75% or more of Pendleton Financial, LLC

Growth and acquisitions

Pendleton Financial’s regulatory assets grew Infinity× from $0 (June 2023) to $160M (March 2026); employees rose from 1 to 4.

By annual filing
Measure
Figures from each annual filing
FiledRegulatory AUMClientsStaffEmployeesOffices
Mar 2026March 2026$160M14341
Mar 2025March 2025$142M12641
Mar 2024March 2024$110M11311
Jun 2023June 2023$0011

Offices and registration details

Besides its headquarters, Pendleton Financial has 0 offices, with 1 listed address in 1 state.

Listed office addresses by state

North Carolina · 1 listed address

  • 2607 Oberlin Road, Suite 100, RaleighHQ

Contact and registration details

Legal name
Pendleton Financial, LLC
Headquarters
2607 Oberlin Road, Suite 100, Raleigh, NC 27608
SEC file
801-127988
Structure
North Carolina LLC
Fiscal year end
December

Custodians

Pendleton Financial’s named custodians for separately managed accounts are Charles Schwab ($71.5M, 76%) and Ascensus Trust ($23.2M, 24%). Pendleton Financial does not have custody of client assets.

Reported separately managed account assets by custodian
$94.7M
named custodians
  • Charles SchwabCharles Schwab & Co., Inc. · Westlake, TX · $71.5M76%
  • Ascensus TrustAscensus Trust Company · Fargo, NC · $23.2M24%

Investments and reported holdings

At year end, Pendleton Financial’s separately managed accounts were mostly in funds (81%).

What the accounts hold

Separately managed account assets by class, year end
  • Stocks7%
  • Funds81%
    • Registered funds75%
    • Pooled vehicles6%
  • Bonds3%
  • Cash9%

Common questions

How many clients does Pendleton Financial have?

Pendleton Financial has 143 clients and manages $160 million for them, as of March 2026. They include 76 individual clients, 52 high-net-worth individuals, and 13 pension and profit-sharing plans.

Source: Form ADV Part 1A, Items 5.D and 5.F, filed 31 March 2026

What services does Pendleton Financial offer?

Pendleton Financial provides financial planning, portfolio management for individuals and small businesses, pension consulting, selecting other managers, publishing newsletters, and educational seminars.

Source: Form ADV Part 1A, Item 5.G, from the SEC's 2 October 2026 data file

How much does Pendleton Financial charge?

Pendleton Financial charges 0.20%–1.25% a year for its Investment Management Fees. The fee is billed in advance and is negotiable.

Source: FORM ADV PART 2A - PENDLETON FINANCIAL LLC, filed 31 March 2026

Which custodians does Pendleton Financial use?

Pendleton Financial’s separately managed account assets are held at Charles Schwab & Co., Inc. (Westlake, TX), with $71.5M and Ascensus Trust Company (Fargo, NC), with $23.2M. Only custodians holding at least a tenth of those assets are named.

Source: Form ADV Part 1A, Schedule D, Section 5.K.(3), filed 31 March 2026

How many financial advisors does Pendleton Financial have?

Pendleton Financial has 1 investment adviser representative registered with state securities authorities, out of 4 employees, and 1 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 Pendleton Financial invest in?

At the end of its last fiscal year, Pendleton Financial’s separately managed accounts held 75% registered funds (mutual funds, ETFs, BDCs), 9% cash and equivalents, 7% exchange-traded equities, 6% pooled vehicles (private funds and similar) and 3% U.S. government and agency bonds.

Source: Form ADV Part 1A, Items 5.K.(1) and 7.B, from the SEC's 2 October 2026 data file

Who owns Pendleton Financial?

Pendleton Financial’s direct owner is Gray Pendleton (75% or more).

Source: Form ADV Part 1A, Schedules A and B, filed 31 March 2026

How does Pendleton Financial get paid?

Pendleton Financial 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

How do I contact Pendleton Financial?

Pendleton Financial’s main office is at 2607 Oberlin Road, Suite 100, Raleigh, NC 27608. Its phone number is 919-781-4167. Its website is pendletonfinancial.com.

Source: Form ADV Part 1A, Item 1.F, filed 31 March 2026

Sources and methodology

  1. Form ADV Part 1A, amendment filed 31 March 2026. Items 1, 5, 9, 11 and Schedules A, B and D.
  2. FORM ADV PART 2A - PENDLETON FINANCIAL LLC, submitted 31 March 2026.
  3. IAPD firm record, CRD 325303.
  4. SEC registered adviser data, annual Form ADV amendments filed 15 June 2023 to 31 March 2026. Items 1.F and 5.
  5. SEC investment adviser representative register, as of 9 October 2026; loaded 10 October 2026.

Retrieved 15 October 2026. All are published by the SEC and may have been amended since. Disciplinary history is not yet shown here. The SEC publishes the complete record, including any disciplinary events, and it is the authoritative place to check one.

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