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Sterling Investment Management

Wealth managementRIA

Tucson, AZCRD 112923Updated

Sterling Investment Management is an investment adviser based in Tucson, AZ, registered with the SEC since 1995. It provides financial planning and investment management. Its clients include high-net-worth individuals, individual clients and charitable organizations. Its regulatory assets under management total $409 million, as filed on 18 March 2026.

151
Clients
$2.55M
AUM per individual client
4
Advisory staff
2
Offices
0.95–1.00%
Annual fee

From Form ADV filed 18 March 2026SEC record

Services and clients

Sterling Investment Management provides financial planning, portfolio management for individuals and small businesses, portfolio management for institutions, publishing newsletters, and education planning. Financial planning was provided to 51–100 clients last fiscal year.

Sterling Investment Management reports 151 clients. They include 74 high-net-worth individuals, 65 individual clients and 7 charitable organizations. Of its assets, 100.0% ($409M across 399 accounts) are managed with discretion.

Clients and assets by client type
Clients151 clients
Assets$409M
Share of clients and assets by client type
Client typeClientsAssets
Individuals (other than HNW)43%8%
High-net-worth individuals49%79%
Charitable organizations5%6%
State or municipal government entities<1%1%
Corporations and other businesses3%6%
Client breakdown and activity details
Individuals (other than HNW)
Clients
65
Regulatory AUM
$32.5M
AUM share
7.9%
Avg. per client
$500K
High-net-worth individuals
Clients
74
Regulatory AUM
$322M
AUM share
78.6%
Avg. per client
$4.35M
Charitable organizations
Clients
7
Regulatory AUM
$26.2M
AUM share
6.4%
Avg. per client
$3.74M
State or municipal government entities
Clients
Fewer than 5
Regulatory AUM
$4.52M
AUM share
1.1%
Avg. per client
$4.52M
Corporations and other businesses
Clients
Fewer than 5
Regulatory AUM
$24.2M
AUM share
5.9%
Avg. per client
$6.04M

Total

Clients
151
Regulatory AUM
$409M
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
51–100

Fees and minimums

Sterling Investment Management charges 0.95%–1.00% a year for its Investment Management. The fee is billed in advance, is negotiable and has a $10,000 annual minimum. The brochure also prices one other service, listed under fee details.

Fee details and sources

Other fees

Professional Advisory Services
Services outside the normal advisory agreements are billed at $500 per hour, rounded up to the next full hour.

Ownership and people

John Payne owns 75% or more of Sterling Investment Management. The leadership team of Sterling Investment Management includes Chief Investment Officer John Payne and Chief Compliance Officer Crystal Kelly. It has 8 employees, 4 of them in advisory roles.

Leadership

Investment adviser representatives

4 representatives listed in the SEC register as of 9 October 2026.

Staff

  • 8 employees
  • 4 in advisory functions
  • 3 state-registered reps
Who owns the firm
Sterling Investment Management, LLC· the adviser
  • John Payne

    Control person · since September 1995

    Owns 75% or more of Sterling Investment Management, LLC
  • Crystal Kelly

    since May 2015

    Owns 5% to 10% of Sterling Investment Management, LLC
  • Arumayta Arguello

    since January 2022

    Owns 5% to 10% of Sterling Investment Management, LLC

Growth and acquisitions

Sterling Investment Management’s regulatory assets grew from $354M (March 2021) to $409M (March 2026); clients were 151 in both filings and employees rose from 7 to 8.

By annual filing
Measure
Figures from each annual filing
Sterling Investment Management figures from each annual Form ADV filing
FiledRegulatory AUMClientsEmployeesOffices
March 2026$409M15182
March 2025$361M14882
March 2024$371M15282
March 2023$342M16082
March 2022$338M14972
March 2021$354M15272

Offices and registration details

Besides its headquarters, Sterling Investment Management has 1 office, with 2 listed addresses in Arizona.

Listed office addresses in Arizona
TucsonScottsdale

Arizona · 2 listed addresses

  • 6262 North Swan RD., Suite 210, TucsonHQ
  • 16427 N. Scottsdale Road, Scottsdale

Contact and registration details

Legal name
Sterling Investment Management, LLC
Headquarters
6262 North Swan RD., Suite 210, Tucson, AZ 85718
SEC file
801-50373
Founded
1995
Structure
Arizona LLC
Fiscal year end
December

Custodians

Sterling Investment Management uses Charles Schwab ($409M) as custodian for its separately managed accounts. Sterling Investment Management has custody of client assets.

Reported separately managed account assets by custodian
$409M
named custodians
  • Charles SchwabCharles Schwab & Co., Inc. · San Francisco, CA · $409M100%

Investments and reported holdings

At year end, Sterling Investment Management’s separately managed accounts were largely in stocks (47%) and bonds (36%). Its reported 13F holdings for the quarter ended 30 June 2026 total $182M across 66 positions; the largest are Vanguard Mortgage-backed Securities ETF (8.2%), Berkshire Hathaway Inc. Del CL B New (6.7%) and SPDR Gold Shares (6.5%).

What the accounts hold

Separately managed account assets by class, year end
  • Stocks47%
  • Funds13%
  • Bonds36%
    • Investment grade corporate bonds16%
    • U.S. government and agency bonds15%
    • High-yield corporate bonds5%
  • Cash4%

Reported 13F holdings

$182M
Reported 13F value
66
Positions
51.6%
In the 10 largest
+9.4%
Value vs. prior quarter
Ten largest positions, share of reported value
  1. Vanguard Mortgage-backed Securities ETFETF8.2%
  2. Berkshire Hathaway Inc. Del CL B New6.7%
  3. SPDR Gold SharesETF6.5%
  4. GE Aerospace Com New5.6%
  5. Janus Henderson Aaa Clo ETFETF4.9%
  6. S&P Global Inc.4.4%
  7. Proshares Short S&P500ETF4.2%
  8. Moodys Corp.3.9%
  9. Visa Inc. Com CL A3.9%
  10. State Street Energy Select Sector SPDR ETFETF3.4%

Together, the ten largest are 51.6% of reported value.

The 50 largest positions and quarterly changesQuarter ended 30 June 2026 · filed 22 July 2026

Common questions

How many clients does Sterling Investment Management have?

Sterling Investment Management has 151 clients and manages $409 million for them, as of March 2026. They include 74 high-net-worth individuals, 65 individual clients and 7 charitable organizations.

Source: Form ADV Part 1A, Items 5.D and 5.F, filed 18 March 2026

What services does Sterling Investment Management offer?

Sterling Investment Management provides financial planning, portfolio management for individuals and small businesses, portfolio management for institutions, publishing newsletters, and education planning.

Source: Form ADV Part 1A, Item 5.G, from the SEC's 2 October 2026 data file; Part 2A brochure, Item 4

How much does Sterling Investment Management charge?

Sterling Investment Management charges 0.95%–1.00% a year for its Investment Management. The fee is billed in advance, is negotiable and has a $10,000 annual minimum.

Source: STERLING INVESTMENT MANAGEMENT ADV 2A & 2B, filed 18 March 2026

Which custodians does Sterling Investment Management use?

Sterling Investment Management’s separately managed account assets are held at Charles Schwab & Co., Inc. (San Francisco, CA), with $409M. Only custodians holding at least a tenth of those assets are named.

Source: Form ADV Part 1A, Schedule D, Section 5.K.(3), filed 18 March 2026

How many financial advisors does Sterling Investment Management have?

Sterling Investment Management has 3 investment adviser representatives registered with state securities authorities, out of 8 employees, and 4 perform investment advisory functions. None are registered representatives of a broker-dealer or licensed insurance agents.

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

What does Sterling Investment Management invest in?

At the end of its last fiscal year, Sterling Investment Management’s separately managed accounts held 47% exchange-traded equities, 16% investment grade corporate bonds, 15% U.S. government and agency bonds, 13% registered funds (mutual funds, ETFs, BDCs), 5% high-yield corporate bonds and 4% cash and equivalents.

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

Who owns Sterling Investment Management?

Sterling Investment Management’s direct owners are John Payne (75% or more), Crystal Kelly (5% to 10%) and Arumayta Arguello (5% to 10%).

Source: Form ADV Part 1A, Schedules A and B, filed 18 March 2026

How does Sterling Investment Management get paid?

Sterling Investment Management is paid through a percentage of assets under management and hourly charges. 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 Sterling Investment Management?

Sterling Investment Management’s main office is at 6262 North Swan RD., Suite 210, Tucson, AZ 85718. Its phone number is 520-293-3311. Its website is sterlinginvestmentmanagement.com.

Source: Form ADV Part 1A, Item 1.F, filed 18 March 2026

Sources and methodology

  1. Form ADV Part 1A, amendment filed 18 March 2026. Items 1, 5, 9, 11 and Schedules A, B and D.
  2. STERLING INVESTMENT MANAGEMENT ADV 2A & 2B, submitted 18 March 2026.
  3. IAPD firm record, CRD 112923.
  4. SEC registered adviser data, annual Form ADV amendments filed 18 March 2021 to 18 March 2026. Items 1.F and 5.
  5. SEC investment adviser representative register, as of 9 October 2026; loaded 10 October 2026.
  6. Form 13F-HR, filed 22 July 2026 for the quarter ended 30 June 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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