Twin Lakes Capital Management provides financial planning, portfolio management for individuals and small businesses, portfolio management for institutions, selecting other managers, education planning, and estate planning. Financial planning was provided to 1–10 clients last fiscal year.
Twin Lakes Capital Management reports 89 clients. They include 49 high-net-worth individuals, 34 individual clients, and 6 corporations and other businesses. Of its assets, 100.0% ($315M across 401 accounts) are managed with discretion.
| Client type | Clients | Assets |
|---|---|---|
| Individuals (other than HNW) | 38% | 5% |
| High-net-worth individuals | 55% | 88% |
| Pension and profit-sharing plans | Fewer than 5 | 2% |
| Charitable organizations | Fewer than 5 | <1% |
| Corporations and other businesses | 7% | 4% |
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) | 34 | $15.9M | 5.1% | $468K |
| High-net-worth individuals | 49 | $278M | 88.5% | $5.68M |
| Pension and profit-sharing plans | Fewer than 5 | $7.03M | 2.2% | — |
| Charitable organizations | Fewer than 5 | $50.4K | 0.0% | — |
| Corporations and other businesses | 6 | $13.3M | 4.2% | $2.22M |
| Total | 89 | $315M | 100% | — |
- Clients
- 34
- Regulatory AUM
- $15.9M
- AUM share
- 5.1%
- Avg. per client
- $468K
- Clients
- 49
- Regulatory AUM
- $278M
- AUM share
- 88.5%
- Avg. per client
- $5.68M
- Clients
- Fewer than 5
- Regulatory AUM
- $7.03M
- AUM share
- 2.2%
- Avg. per client
- —
- Clients
- Fewer than 5
- Regulatory AUM
- $50.4K
- AUM share
- 0.0%
- Avg. per client
- —
- Clients
- 6
- Regulatory AUM
- $13.3M
- AUM share
- 4.2%
- Avg. per client
- $2.22M
Total
- Clients
- 89
- Regulatory AUM
- $315M
- 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
- 1–10
Twin Lakes Capital Management is paid through a percentage of assets under management. The reviewed brochures do not disclose an asset-based fee rate. Read the SEC-filed brochure.
Min Kim owns 75% or more of Twin Lakes Capital Management. The leadership team of Twin Lakes Capital Management includes President Frank Yi and Chief Compliance Officer Min Kim. It has 5 employees, 2 of them in advisory roles.
Leadership
- Frank YiSR. Vice President
- Min KimManaging Member/Chief Compliance Officer
Investment adviser representatives
2 representatives listed in the SEC register as of 9 October 2026.
- Min Gyo Kim
- Frank Kwangjae Yi
Staff
- 5 employees
- 2 in advisory functions
- 2 state-registered reps
- Owns 75% or more of Twin Lakes Capital Management, LLC
Min Kim
Control person · since August 2005
- Owns 5% to 10% of Twin Lakes Capital Management, LLC
Frank Yi
since January 2018
Twin Lakes Capital Management’s regulatory assets grew from $273M (March 2021) to $315M (March 2026); clients rose from 78 to 89 and employees fell from 6 to 5.
Figures from each annual filing
| Filed | Regulatory AUM | Clients | Employees | Offices |
|---|---|---|---|---|
| March 2026 | $315M | 89 | 5 | 2 |
| March 2025 | $246M | 90 | 5 | 2 |
| March 2024 | $262M | 99 | 6 | 2 |
| June 2023 | $267M | 102 | 8 | 2 |
| March 2022 | $304M | 88 | 7 | 2 |
| March 2021 | $273M | 78 | 6 | 2 |
Besides its headquarters, Twin Lakes Capital Management has 1 office, with 2 listed addresses in California and Hawaii.
California · 1 listed address
- 3 Lagoon Drive, Suite 150, Redwood ShoresHQ
Hawaii · 1 listed address
- 55 Merchant Street, Honolulu
Contact and registration details
- Legal name
- Twin Lakes Capital Management, LLC
- Headquarters
- 3 Lagoon Drive, Suite 150, Redwood Shores, CA 94065
- Website
- twinlakescapital.com
- Phone
- 650-610-9363
- SEC file
- 801-113264
- Structure
- Delaware LLC
- Fiscal year end
- December
Twin Lakes Capital Management uses Charles Schwab ($226M) as custodian for its separately managed accounts. Twin Lakes Capital Management has custody of $135M in client assets for 73 clients.
- Charles SchwabCharles Schwab & Co., Inc. · Westlake, TX · $226M100%
At year end, Twin Lakes Capital Management’s separately managed accounts were mostly in stocks (54%) and cash (23%). Its reported 13F holdings for the quarter ended 30 June 2026 total $262M across 208 positions; the largest are Seagate Technology Hldngs PL (17.9%), Vanguard Instl Index FD (10.0%) and Apple Inc. (9.0%).
What the accounts hold
- Stocks54%
- Funds17%
- Bonds6%
- Cash23%
Reported 13F holdings
- $262M
- Reported 13F value
- 208
- Positions
- 55.0%
- In the 10 largest
- +18.9%
- Value vs. prior quarter
- Seagate Technology Hldngs PL17.9%
- Vanguard Instl Index FD · 0 3 MO TR BI ETF10.0%
- Apple Inc.9.0%
- Nvidia Corporation2.9%
- Gilead Sciences Inc.2.8%
- Protagonist Therapeutics Inc.2.7%
- Central Pac Finl Corp.2.7%
- Berkshire Hathaway Inc. Del · CL B New2.5%
- Schwab Charles Corp.2.3%
- Fedex Corp.2.2%
Together, the ten largest are 55.0% of reported value.
How many clients does Twin Lakes Capital Management have?
Twin Lakes Capital Management has 89 clients and manages $315 million for them, as of March 2026. They include 49 high-net-worth individuals, 34 individual clients, and 6 corporations and other businesses.
Source: Form ADV Part 1A, Items 5.D and 5.F, filed 25 March 2026
What services does Twin Lakes Capital Management offer?
Twin Lakes Capital Management provides financial planning, portfolio management for individuals and small businesses, portfolio management for institutions, selecting other managers, education planning, and estate planning.
Source: Form ADV Part 1A, Item 5.G, from the SEC's 2 October 2026 data file; Part 2A brochure, Item 4
Which custodians does Twin Lakes Capital Management use?
Twin Lakes Capital Management’s separately managed account assets are held at Charles Schwab & Co., Inc. (Westlake, TX), with $226M. Only custodians holding at least a tenth of those assets are named.
Source: Form ADV Part 1A, Schedule D, Section 5.K.(3), filed 25 March 2026
How many financial advisors does Twin Lakes Capital Management have?
Twin Lakes Capital Management has 2 investment adviser representatives registered with state securities authorities, out of 5 employees, and 2 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 Twin Lakes Capital Management invest in?
At the end of its last fiscal year, Twin Lakes Capital Management’s separately managed accounts held 54% exchange-traded equities, 23% cash and equivalents, 17% pooled vehicles (private funds and similar) and 6% 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 Twin Lakes Capital Management?
Twin Lakes Capital Management’s direct owners are Min Kim (75% or more) and Frank Yi (5% to 10%).
Source: Form ADV Part 1A, Schedules A and B, filed 25 March 2026
How does Twin Lakes Capital Management get paid?
Twin Lakes Capital 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 Twin Lakes Capital Management registered with the SEC?
Yes, Twin Lakes Capital Management has been registered with the SEC as an investment adviser since 18 May 2018. Its CRD number is 137522 and its SEC file number is 801-113264.
Source: Form ADV Part 1A, Item 1, filed 25 March 2026; IAPD firm record
How do I contact Twin Lakes Capital Management?
Twin Lakes Capital Management’s main office is at 3 Lagoon Drive, Suite 150, Redwood Shores, CA 94065. Its phone number is 650-610-9363. Its website is twinlakescapital.com.