Commerce Street Investment Management

Registered investment adviser · Dallas, TX · CRD #144278

Form ADV data as of 2026-09-01

Regulatory assets

$891.3 million

Total accounts

Employees

Disclosure events

Firm details

Website: https://www.linkedin.com/company/commerce-street-capital-llc/
Telephone: 214-545-6800
SEC file number: 801-68792
Most recent Form ADV filing: 2026-03-31
SEC record: View this firm on the SEC's IAPD site

Disciplinary disclosures

This firm answered No to every Item 11 disciplinary question on its most recent Form ADV filing.

Assets and accounts

Provides continuous and regular supervisory or management services	Yes
Discretionary regulatory assets under management	$300.6 million
Non-discretionary regulatory assets under management	$590.7 million
Total regulatory assets under management	$891.3 million
Discretionary accounts	17
Non-discretionary accounts	47
Total accounts	64
Regulatory assets under management attributable to non-U.S. persons	$0

People

Total employees (excluding clerical)	14
Employees performing investment advisory functions (including research)	10
Employees who are registered representatives of a broker-dealer	11
Employees registered as investment adviser representatives with a state	11
Employees registered as IARs for another investment adviser	0
Employees who are licensed insurance agents	0
Firms or persons who solicit advisory clients on the firm's behalf	0

Custody

Has custody of client cash or bank accounts	No
Has custody of client securities	No
A related person has custody of client cash or bank accounts	Yes
A related person has custody of client securities	Yes
Client funds and securities held in a related person's custody	$75.8 million
Clients for whom a related person has custody	2
The firm acts as a qualified custodian	No
A related person acts as a qualified custodian	Yes
Number of persons acting as qualified custodians for the firm's clients	2

How the firm is compensated

A percentage of assets under managementFixed fees (other than subscription fees)Performance-based feesOther

Advisory services offered

Portfolio management for individuals and/or small businessesPortfolio management for pooled investment vehiclesPortfolio management for businesses or institutional clientsPension consulting services

Affiliated related persons

Broker-dealer, municipal securities dealer, or government securities broker or dealerSponsor, general partner, or managing member of pooled investment vehicles

Reported conflicts of interest

Form ADV Items 8 asks advisers to disclose arrangements that may create a conflict with client interests. This firm answered Yes to:

Recommends securities in which it has another proprietary interest
Brokers or dealers selected under 8.C.(3) are related persons
Recommends brokers or dealers to clients
Brokers or dealers recommended under 8.E. are related persons
Compensates a non-employee for client referrals
Provides employee compensation specifically for obtaining clients

Client types

Type of client	Clients	Assets
High net worth individuals	5	$3.1 million
Pooled investment vehicles (other than investment companies and BDCs)	2	$86.0 million
Pension and profit sharing plans (not the participants or government plans)	47	$590.7 million
Charitable organizations	6	$186.2 million
Corporations or other businesses not listed above	2	$22.8 million
Other	2	$2.5 million