Turtle Creek Management provides portfolio management for individuals and small businesses and portfolio management for institutions.
Turtle Creek Management reports 101 clients. They include 96 high-net-worth individuals and 5 individual clients. Of its assets, 36.2% ($1.55B across 465 accounts) are managed with discretion; $2.73B across 94 accounts are not.
| Client type | Clients | Assets |
|---|---|---|
| Individuals (other than HNW) | 5% | <1% |
| High-net-worth individuals | 95% | 99% |
| Charitable organizations | Fewer than 5 | <1% |
| Corporations and other businesses | Fewer than 5 | <1% |
Client shares use reported counts. Client types without a reported count are excluded from that total.
Client breakdown and activity details
| Client type | Clients | Regulatory AUM | AUM share | Avg. per client |
|---|---|---|---|---|
| Individuals (other than HNW) | 5 | $1.74M | 0.0% | $349K |
| High-net-worth individuals | 96 | $4.24B | 99.0% | $44.2M |
| Charitable organizations | Fewer than 5 | $38M | 0.9% | — |
| Corporations and other businesses | Fewer than 5 | $1.59M | 0.0% | — |
| Total | 101 | $4.28B | 100% | — |
- Clients
- 5
- Regulatory AUM
- $1.74M
- AUM share
- 0.0%
- Avg. per client
- $349K
- Clients
- 96
- Regulatory AUM
- $4.24B
- AUM share
- 99.0%
- Avg. per client
- $44.2M
- Clients
- Fewer than 5
- Regulatory AUM
- $38M
- AUM share
- 0.9%
- Avg. per client
- —
- Clients
- Fewer than 5
- Regulatory AUM
- $1.59M
- AUM share
- 0.0%
- Avg. per client
- —
Total
- Clients
- 101
- Regulatory AUM
- $4.28B
- 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
Turtle Creek Management charges 0.50%–1.00% for its Separately Managed Accounts. The brochure does not state whether the rate is annual. Each asset band is charged at its own rate. The fee is billed in arrears, is negotiable and requires an account of at least $1,000,000.
| Asset band | Rate (period not stated) |
|---|---|
| $0–$1M | 1.00% |
| $1M–$3M | 0.80% |
| $3M–$5M | 0.70% |
| $5M–$10M | 0.60% |
| $10M and above | 0.50% |
Fee details and sources
TCTC Holdings, LLC owns 75% or more of Turtle Creek Management and is in turn owned by Philip Kistler (50–75%) and Richard Knocke (50–75%). The leadership team of Turtle Creek Management includes Chief Compliance Officer Sarah Wood. It has 10 employees, 6 of them in advisory roles.
Leadership
- Sarah WoodChief Compliance Officer
- Philip KistlerManager
- Richard KnockeManager
Investment adviser representatives
3 representatives listed in the SEC register as of 9 October 2026.
- Philip Corder Witter Kistler
- Richard Craig Knocke
- Mark Edward Lanyon
Staff
- 10 employees
- 6 in advisory functions
- 3 state-registered reps
- 1 soliciting firm
- Owns 75% or more of Turtle Creek Management, LLC
TCTC Holdings, LLC
Control person · since December 2009
- Owns 50% to 75% of TCTC Holdings, LLC
Philip Kistler
Control person · since December 2009
- Owns 50% to 75% of TCTC Holdings, LLC
Richard Knocke
Control person · since December 2009
Turtle Creek Management’s regulatory assets grew 1.6× from $2.64B (March 2021) to $4.28B (March 2026); clients fell from 448 to 101 and employees rose from 9 to 10.
Figures from each annual filing
| Filed | Regulatory AUM | Clients | Employees | Offices |
|---|---|---|---|---|
| March 2026 | $4.28B | 101 | 10 | 1 |
| March 2025 | $3.66B | 105 | 10 | 1 |
| April 2024 | $3.54B | 136 | 10 | 1 |
| March 2023 | $3.18B | 140 | 8 | 1 |
| June 2022 | $3.15B | 107 | 9 | 1 |
| March 2021 | $2.64B | 448 | 9 | 1 |
Besides its headquarters, Turtle Creek Management has 0 offices, with 1 listed address in Texas.
Texas · 1 listed address
- 3838 Oak Lawn Ave, Suite 1650, DallasHQ
Other business names
Turtle Creek Management has reported 1 other business name to the SEC.
- Turtle Creek Trust
Contact and registration details
- Legal name
- Turtle Creek Management, LLC
- Headquarters
- 3838 Oak Lawn Ave, Suite 1650, Dallas, TX 75219
- Website
- turtlecreektrust.com
- Phone
- 214-468-0100
- @turtle-creek-management-llc
- SEC file
- 801-66626
- Structure
- Texas LLC
- Fiscal year end
- December
Turtle Creek Management uses Fidelity ($2.59B) as custodian for its separately managed accounts. Turtle Creek Management has custody of $1.61B in client assets for 104 clients.
- FidelityNational Financial Services LLC · Jersey City, NJ · $2.59B100%
At year end, Turtle Creek Management’s separately managed accounts were mostly in stocks (78%) and cash (12%).
What the accounts hold
- Stocks78%
- Funds5%
- Bonds5%
- U.S. government and agency bonds2%
- Investment grade corporate bonds2%
- High-yield corporate bonds1%
- Cash12%
How many clients does Turtle Creek Management have?
Turtle Creek Management has 101 clients and manages $4.28 billion for them, as of March 2026. They include 96 high-net-worth individuals and 5 individual clients.
Source: Form ADV Part 1A, Items 5.D and 5.F, filed 30 March 2026
What services does Turtle Creek Management offer?
Turtle Creek Management provides portfolio management for individuals and small businesses and portfolio management for institutions.
Source: Form ADV Part 1A, Item 5.G, from the SEC's 2 October 2026 data file
How much does Turtle Creek Management charge?
Turtle Creek Management charges 0.50%–1.00% for its Separately Managed Accounts. The brochure does not state whether the rate is annual. Each asset band is charged at its own rate. The fee is billed in arrears, is negotiable and requires an account of at least $1,000,000.
Which custodians does Turtle Creek Management use?
Turtle Creek Management’s separately managed account assets are held at National Financial Services LLC (Jersey City, NJ), with $2.59B. Only custodians holding at least a tenth of those assets are named.
Source: Form ADV Part 1A, Schedule D, Section 5.K.(3), filed 30 March 2026
How many financial advisors does Turtle Creek Management have?
Turtle Creek Management has 3 investment adviser representatives registered with state securities authorities, out of 10 employees, and 6 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 Turtle Creek Management invest in?
At the end of its last fiscal year, Turtle Creek Management’s separately managed accounts held 78% exchange-traded equities, 12% cash and equivalents, 5% registered funds (mutual funds, ETFs, BDCs), 2% U.S. government and agency bonds, 2% investment grade corporate bonds and 1% high-yield corporate bonds.
Source: Form ADV Part 1A, Items 5.K.(1) and 7.B, from the SEC's 2 October 2026 data file
Does Turtle Creek Management have a minimum investment?
Yes, Turtle Creek Management’s minimum account size for its Separately Managed Accounts is $1M.
Who owns Turtle Creek Management?
Turtle Creek Management is owned through a holding company by Philip Kistler and Richard Knocke. Its direct owner is TCTC Holdings, LLC (75% or more).
Source: Form ADV Part 1A, Schedules A and B, filed 30 March 2026
How does Turtle Creek Management get paid?
Turtle Creek Management is paid through a percentage of assets under management. 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 Turtle Creek Management registered with the SEC?
Yes, Turtle Creek Management has been registered with the SEC as an investment adviser since 17 May 2006. Its CRD number is 140212 and its SEC file number is 801-66626.
Source: Form ADV Part 1A, Item 1, filed 30 March 2026; IAPD firm record
How do I contact Turtle Creek Management?
Turtle Creek Management’s main office is at 3838 Oak Lawn Ave, Suite 1650, Dallas, TX 75219. Its phone number is 214-468-0100. Its website is turtlecreektrust.com.