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Commonwealth Asset Management LP: investment adviser
Commonwealth Asset Management LP is an investment adviser registered with the SEC (file 801-136890, CRD 306098). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.
- Assets managed
- $295.7M
- Discretionary
- 0%
- Accounts
- 3
- Employees
- 4
- In advisory roles
- 3
- Disclosures
- 0
Company page · SEC adviser record · Full Form ADV (PDF)
The firm reports that it or a related person has custody of client cash and securities.
Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.
Clients and fees
Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.
| Client type | Clients | Assets | Share |
|---|---|---|---|
| Private funds and other pooled vehicles | 3 | $295.7M | 100.0% |
How it is paid
- A percentage of assets under your management
- Fixed fees (other than subscription fees)
- Performance-based fees
Services
- Portfolio management for pooled investment vehicles (other than investment companies)
Who owns it
Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.
Indirect owners (Schedule B)
| Owner | Owns a stake in | Type | Stake | Control | Public company |
|---|---|---|---|---|---|
| Jonathan Ross Gilbert | The Fisher Family | Person | F General partner, trustee or managing member | Yes | |
| JP Morgan Trust Company | The Fisher Family | Company (U.S.) | F General partner, trustee or managing member | ||
| Alta L.P. | Brevan Howard | Company (outside the U.S.) | E 75% or more | Yes | |
| Brevan Howard Capital | Brevan Howard | Company (outside the U.S.) | E 75% or more | Yes | |
| Brevan Howard Partners | Brevan Howard | Company (outside the U.S.) | E 75% or more | Yes | |
| Cwam Fisher Holdco LLC | Commonwealth | Company (U.S.) | D 50% to 75% | Yes | |
| Cwam Fisher LLC | Commonwealth | Company (U.S.) | D 50% to 75% | Yes | |
| Fisher Cwoc (MM) LLC | Cwam Fisher LLC | Company (U.S.) | D 50% to 75% | Yes | |
| Fisher Cwoc (MM) LLC | Cwam Fisher | Company (U.S.) | D 50% to 75% | Yes | |
| Fisher Cwoc LLC | Cwam Fisher LLC | Company (U.S.) | D 50% to 75% | Yes | |
| Fisher Cwoc LLC | Cwam Fisher | Company (U.S.) | D 50% to 75% | Yes | |
| Adam Blaine Fisher | Fisher Cwoc (MM) | Person | D 50% to 75% | Yes | |
| Alan Eldad Howard | Alta L.P. | Person | D 50% to 75% | Yes | |
| The Fisher Family 2013 Delaware Trust | Fisher Cwoc LLC | Company (U.S.) | D 50% to 75% | ||
| Bhus Holdings LLC | Commonwealth | Company (U.S.) | C 25% to 50% | Yes |
Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.
Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.
Disciplinary history
The firm answered No to every disciplinary question on Form ADV (Item 11).
The brochure
Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.
Cwam Form ADV Part 2A, filed Jun 29, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18
Item 4. Advisory business
Advisory Business and Principal Owners Commonwealth Asset Management LP ("CWAM" or the "Firm") is a Delaware limited partnership formed on January 29, 2019. The Firm provides investment management services to a limited number of institutional advisory clients pursuant to written advisory agreements (each a "Client" and, collectively, the "Clients"). Each Client's investment objectives, strategies, guidelines, and restrictions, including any restrictions on investing in certain securities or types of securities, are set forth in the applicable advisory agreement and related governing documents. The Firm provides advisory services to each Client in accordance with the terms of such documents.
Read the rest of Item 4 (109 more words)
Commonwealth Asset Management Holdings LLC, a Delaware limited liability company formed on June 17, 2019, is the general partner and majority owner of CWAM. The Firm is led by its indirect majority principal owner, Mr. Adam B. Fisher. In addition to Mr. Fisher’s indirect majority ownership of the Firm, BHUS Holdings LLC (“BHUS”), a Delaware limited liability company, indirectly owns an interest in the Firm. BHUS is indirectly owned by Brevan Howard Capital Management, LP (“Brevan Howard”). Wrap Fee Programs The Firm does not participate in wrap fee programs. Assets Under Management As of December 31, 2025, the Firm manages $295,683,751 in assets under management on a nondiscretionary basis.
Item 5. Fees and compensation
Fees and Compensation The Firm is compensated for its advisory services through fees set forth in each Client's advisory agreement and related governing documents. Compensation may include asset-based management fees, performance-based or incentive-based compensation. The specific fees, fee structures, calculation methodologies, payment terms, and offsets, if any, applicable to a particular Client are negotiated and set forth in the applicable governing documents. Fees are negotiable.
Read the rest of Item 5 (471 more words)
Fees and compensation may differ among Clients and among investments, and may vary based on the nature, structure, terms, and characteristics of the underlying investment, the type of investment vehicle through which the investment is held, the investment strategy, the duration of the engagement, the services provided, and the liquidity and other terms applicable to the relationship. The Firm, in its discretion, may waive, reduce, or rebate all or any portion of any fee, and the Firm may agree to fee terms with employees, members of their families, affiliates, or other related persons that differ from, and may be more favorable than, the fee terms applicable to other Clients. Differences in fees among Clients do not entitle any Client to any reduction, waiver, or rebate. Clients also bear investment-related expenses and other expenses associated with their advisory relationship and underlying investments, including, as applicable, custodial fees and expenses, professional fees (including legal, accounting, audit, tax, and consulting fees), administration fees, third-party valuation fees, research and data fees, transaction costs, brokerage commissions and other transaction-related charges, financing costs, taxes, regulatory and filing fees, organizational and operating expenses, and similar expenses, in each case as set forth in the applicable governing documents. Clients will incur brokerage and other transaction costs in connection with their advisory relationship. The Firm may, from time to time, enter into side letter or similar arrangements with one or more Clients or investors that supplement or modify the rights, terms, or provisions of the applicable governing documents, including with respect to economic terms, fee structures, information rights, and liquidity rights. The Firm has no obligation to offer the same or similar terms to any other Client or investor. Termination The terms applicable to the termination of an advisory relationship, including any required notice period and the treatment of fees and expenses through the date of termination, vary by Client and are agreed at the time the advisory relationship is established. Where a Client's holdings include investments that are illiquid, long-term in nature, or otherwise not readily or reliably valued, the availability of proceeds attributable to such investments will be subject to the realization or resolution of those investments.
Billing Fees and expenses are paid as agreed at the time the advisory relationship is established. The frequency, timing, and method of payment vary by Client and may include payment in advance or in arrears, deduction from a Client's assets, or direct billing. If fees are paid in advance and the advisory relationship is terminated before the end of a billing period, the Client will receive a prorata refund of any prepaid fees attributable to the unexpired portion of the billing period. Sales-Based Compensation Neither the Firm nor any of its principals or employees receives any transaction-based compensation for the sale of securities or other investment products except as outlined above.
Item 6. Performance-based fees and side-by-side management
The Firm may receive performance-based compensation, including in the form of an incentive allocation based on capital appreciation of, or capital gains on, a Client's assets, as set forth in the applicable advisory agreement and related governing documents. The Firm’s ability to receive performance-based fees may create an incentive to recommend investments or strategies that carry a higher degree of risk than would otherwise be the case. The Firm has adopted and implemented written compliance policies and procedures that are reasonably designed to address such conflicts of interest.
Item 7. Types of clients
The Firm's Clients consist of pooled investment vehicles that are organized as private investment funds and are exempt from registration under the Investment Company Act of 1940. The minimum initial investment commitment for a Client is generally $1,000,000, subject to applicable investor eligibility standards under U.S. federal securities laws. The Firm reserves the right to accept investments below this threshold, or to require a higher minimum, in its sole discretion.
Item 8. Methods of analysis, investment strategies and risk of loss
Methods of Analysis In evaluating potential investments and making investment recommendations, the Firm relies primarily on fundamental and qualitative analysis, supplemented by investment due diligence. For long-term or illiquid investments, this evaluation also takes into account considerations relating to the expected holding period, the absence of an active market for the investment, and the potential paths to realization of value. The Firm may consult with third-party advisors, consultants, and service providers in connection with its analysis of particular investments. Risks of Investments and Strategies Utilized Investments in General: An investment with the Firm involves a high degree of risk, including the risk that the entire amount invested may be lost.
Read the rest of Item 8 (1,167 more words)
There can be no assurance that the Firm's investment activities will be successful, that any Client will achieve its investment objective, or that any Client will be able to avoid losses. Investments may be subject to market, economic, political, regulatory, and other risks, and the value of investments may decline due to factors affecting financial markets generally, factors affecting particular industries or issuers, or factors specific to particular investments. Past performance is not indicative of future results. Long-Term and Illiquid Investments: The Firm's investment activities for its Clients may include investments that are long-term, illiquid, and held to liquidation or realization rather than traded on a regular basis. Clients should expect to bear the economic risk of these investments for an extended and indefinite period of time. There is no active secondary market for many of these investments, and the timing of any liquidity event is uncertain and outside the Firm's control. The realization of value, if any, may depend on factors including the operating performance of underlying portfolio investments, market conditions at the time of any realization event, the actions of third parties (including counterparties, co-investors, and acquirors), legal and regulatory developments, and other factors. The Firm's investment program is opportunistic and is not constrained to a particular asset class, industry, geography, or investment strategy. The risks described in this Item 8 may apply with greater force to long-term, illiquid investments than to investments in more liquid markets. Side-Pocketed Investments: The Firm may classify certain investments as "side-pocketed" investments. Side-pocketed investments are typically illiquid, long-term in nature, or otherwise not readily or reliably valued. Side-pocketed investments are valued at fair value as determined by the Firm in its sole discretion, until such investments are liquidated or "deemed realized." Clients participating in side-pocketed investments will not receive proceeds from those investments until the side-pocketed investments are liquidated or deemed realized, and the timing of any such event is uncertain. The valuation of side-pocketed investments is inherently subjective and may not reflect the value ultimately realized. The Firm has a potential conflict of interest in designating investments as side-pocketed, including because the timing of performance-based compensation, if any, may be affected by such designation.
Key Person Risk: The Firm's investment activities depend on the continued service of a limited number of key personnel. The loss of one or more key personnel, or the unavailability of such personnel for any reason, could materially and adversely affect the Firm's ability to provide advisory services to its Clients. The Firm will provide investors with notice in the event of any material change affecting the availability of its key personnel. Business Continuity and Cybersecurity: The Firm relies on information technology systems, including systems operated by third-party service providers, in connection with its operations and the provision of advisory services. These systems may be subject to security breaches, cyberattacks, system failures, human error, natural disasters, and other events that could disrupt the Firm's operations, compromise sensitive information, or otherwise materially and adversely affect the Firm and its Clients. The Firm has implemented measures intended to address these risks, but there can be no assurance that such measures will be effective. Market Risk: The success of the Firm's investment activities depends, in part, on accurately evaluating future price movements, cash flows, and other characteristics of investments. The Firm may not accurately predict such movements or characteristics, and there can be no assurance that the Firm's investment activities will be successful. Investments may be subject to material declines in value, including as a result of changes in market conditions, economic conditions, interest rates, credit conditions, regulatory changes, or other factors. Reliance on Service Providers: The Firm relies on third-party service providers to perform certain functions in connection with its operations and the provision of advisory services to its Clients. The failure of any service provider to perform its obligations, the termination of a relationship with a service provider, or any delay in appointing a replacement service provider could materially and adversely affect the Firm and its Clients. Counterparty Risk: Clients may be subject to the credit risk of counterparties engaged in connection with their investment activities, including banks, custodians, broker-dealers, and other counterparties. If a counterparty becomes insolvent, becomes subject to a bankruptcy or similar proceeding, or otherwise fails to perform its obligations, a Client may experience delays in recovering, or may be unable to recover, amounts owed to it. Concerns regarding the financial condition of a counterparty or other market participant may also adversely affect liquidity and pricing in markets generally. Illiquidity: Investments may be illiquid and may not be readily marketable or capable of being sold or otherwise disposed of at the time and price desired. There may be no established market for certain investments, and resale may be subject to legal, contractual, or other restrictions. The realization of value from illiquid investments may take an extended period of time, and there can be no assurance as to the timing or amount of any realization. Clients may be required to bear the expenses of holding illiquid investments for an indefinite period.
Concentration of Investments: Clients may hold a limited number of investments and may be concentrated in particular issuers, industries, sectors, or types of investments. Concentration may increase the impact on a Client of adverse developments affecting any particular investment or category of investments and may result in greater volatility in the value of a Client's investments than would be the case in a more diversified portfolio. Valuation: Certain investments may be difficult to value due to the absence of an active market or other factors. Valuations may be based on estimates, assumptions, models, or third-party inputs that may prove to be inaccurate, and the value ultimately realized on the disposition of an investment may differ materially from the value at which the investment is carried. Valuation methodologies applicable to a Client are set forth in the applicable governing documents. Legal and Regulatory Change: The legal, tax, and regulatory environment applicable to the Firm and its Clients may change in ways that are adverse to Client interests. Legal and regulatory changes may affect the availability or terms of investments, the costs of operating the Firm and its Clients, the ability to implement particular investment activities, or the tax treatment of Clients and investors. The Firm cannot predict the timing, scope, or impact of legal and regulatory changes. Tax: An investment with the Firm may have material tax consequences for an investor. Investors should consult their own tax advisors regarding the tax treatment applicable to them. The tax treatment of investments and of an investor's interest may change as a result of changes in applicable law or interpretations thereof, in each case as a result of factors outside the Firm's control. No Assurance of Achieving Investment Objective: There can be no assurance that any Client will achieve its investment objective or that any Client will avoid losses. Past performance, including past performance of the Firm and its personnel, is not indicative of future results.
Item 9. Disciplinary information
There are no legal or disciplinary events that are material to a Client's or prospective Client's evaluation of the Firm's advisory business or the integrity of its management.
Item 10. Other financial industry activities and affiliations
Neither the Firm, nor any of its directors, officers or principals is registered as a broker-dealer or a representative of a broker-dealer or has an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Neither CWAM nor any of its management persons is registered, or has an application pending to register, as a futures commission merchant, commodity pool operator, or commodity trading advisor, or as an associated person of any of the foregoing. As referenced above in Item 4 and disclosed in Schedule B of the Firm’s Form ADV Part 1A, CWAM has a minority owner that is affiliated with Brevan Howard Capital Management LP ("Brevan Howard"), a global alternative investment manager.
Read the rest of Item 10 (109 more words)
Brevan Howard's affiliate holds a passive, non-controlling economic interest in CWAM and does not participate in CWAM's investment decisions, have access to Client investment positions, or otherwise influence the dayto-day operations of CWAM's advisory business. No CWAM personnel hold positions with Brevan Howard or its affiliates, and no Brevan Howard personnel hold positions with CWAM. CWAM does not believe this ownership relationship creates a material conflict of interest with Clients. Other than as described above, CWAM does not have any other relationship or arrangement with any related person that is material to its advisory business or Clients. CWAM does not recommend or select other investment advisers for its Clients.
Item 11. Code of ethics, participation in client transactions and personal trading
Transactions and Personal Trading Code of Ethics The Firm has adopted a Code of Ethics pursuant to Rule 204A-1 under the Investment Advisers Act of 1940. The Code of Ethics establishes standards of conduct applicable to the Firm and its personnel and addresses, among other things, fiduciary duties to Clients, compliance with applicable federal securities laws, personal securities transactions, the handling of material nonpublic information, outside business activities, gifts and entertainment, and political contributions. The Firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request.
Read the rest of Item 11 (150 more words)
Participation or Interest in Client Transactions The Firm and its related persons may, from time to time, have financial interests that intersect with the investment activities of the Firm's Clients. The Firm has adopted policies and procedures, including the Code of Ethics, that are designed to identify, address, and mitigate conflicts of interest that may arise in connection with such activities, and to ensure that the Firm acts in the best interests of its Clients consistent with its fiduciary duties. Personal Trading Subject to the requirements of the Code of Ethics, personnel of the Firm may, for their personal accounts, buy, sell, or hold investments that are the same as, similar to, or different from investments held by the Firm's Clients. The Code of Ethics imposes restrictions and reporting requirements on personal trading by Firm personnel that are designed to address conflicts of interest that may arise from such activities.
Item 12. Brokerage practices
The Firm does not regularly engage broker-dealers to execute purchases or sales of securities on behalf of its Clients, as Client investments are generally acquired and disposed of in privately negotiated transactions. To the extent that CWAM may engage a broker-dealer in connection with a Client transaction, the Firm selects the broker-dealer based on relevant factors specific to the situation, which may include execution capability, financial condition, responsiveness, reputation, and the nature of the proposed transaction. The Firm seeks to obtain best execution for Client transactions in accordance with its fiduciary duties.
Read the rest of Item 12 (143 more words)
CWAM does not receive research or other products or services other than execution from a brokerdealer or a third party in connection with Client securities transactions (“soft dollar benefits”). CWAM does not consider, in selecting or recommending broker-dealers, whether CWAM or a related person receives Client referrals from a broker-dealer or third party. CWAM does not engage in directed brokerage. The nature of the Firm's investment activities is such that the Firm generally does not aggregate or batch securities orders. To the extent that the Firm at any time provides advisory services to more than one Client and aggregation of orders or allocation of investment opportunities is appropriate, the Firm will allocate investment opportunities and aggregate orders in a manner that the Firm believes to be fair and equitable over time and, to the extent required, in accordance with the applicable governing documents.
Item 13. Review of accounts
The Firm has detailed knowledge of the investments in each Client. The Client portfolios are under continuous review by the investment professionals responsible for such accounts and they seek to ensure that transactions are within the parameters of the applicable investment mandate. Clients receive periodic written reports regarding their accounts. Such reports typically include account statements and performance information, which are generally provided on a quarterly basis, and may include such other reports as the Firm determines appropriate or as required by applicable law or regulation.
Read the rest of Item 13 (46 more words)
Clients also receive audited financial statements following the end of each fiscal year, distributed in accordance with the timing requirements of Rule 206(4)-2 under the Investment Advisers Act of 1940 (the "Custody Rule"). Audited financial statements are prepared in accordance with U.S. Generally Accepted Accounting Principles.
Item 14. Client referrals and other compensation
The Firm receives management fees and, where applicable, performance-based compensation from Clients as described in Item 5 (Fees and Compensation). The Firm does not receive any economic benefit from any person other than a Client for providing investment advice or other advisory services to its Clients.
(B)
CWAM has not and does not expect to enter into arrangements whereby it will compensate persons that are not its supervised persons for Client referrals.
Item 15. Custody
Portfolio securities of Clients are held in custodial accounts at unaffiliated qualified custodians where applicable. The Firm is deemed to have custody of assets of its private fund Clients, pursuant to the Custody Rule. Certain assets may be exempt from the requirement to be held by a qualified custodian. The Firm's Clients are subject to an annual financial statement audit by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. The audited financial statements are prepared in accordance with U.S. Generally Accepted Accounting Principles and are distributed in accordance with the Custody Rule. The Firm urges recipients to carefully review these financial statements.
Item 16. Investment discretion
CWAM accepts discretionary and non-discretionary authority over Clients’ portfolios. The scope of the Firm's investment authority, any limitations on that authority, and any investment objectives, guidelines, or restrictions applicable to a Client's portfolio are established in the applicable advisory agreement and related governing documents. With respect to discretionary Client portfolios, this means that CWAM has the authority to determine without obtaining specific Client consent which securities or assets to buy or sell and the amount to buy or sell. With respect to nondiscretionary accounts, CWAM must obtain Client consent as to which securities or assets to buy or sell and the amount of securities or assets to buy or sell.
Item 17. Voting client securities
The Firm's authority to vote proxies on behalf of a Client, if any, is set forth in the applicable advisory agreement and other governing documents. To the extent the Firm has accepted authority to vote proxies on behalf of a Client, the Firm has adopted written proxy voting policies and procedures pursuant to Rule 206(4)-6 under the Investment Advisers Act of 1940. Proxy voting matters may not arise frequently in connection with the Firm's advisory activities. If the Firm exercises voting authority, the Firm will vote in a manner that it believes serves the best interests of the applicable Client, taking into account such factors as the Firm considers relevant.
Read the rest of Item 17 (168 more words)
The Firm will monitor for, and seek to address, material conflicts of interest that may arise in connection with the voting of proxies. Where a material conflict of interest is identified, the Firm will address the conflict in a manner the Firm considers appropriate under the circumstances. The Firm may also determine, in its discretion, not to vote a particular proxy where it believes that voting is not in the Client's best interest or is otherwise not warranted under the circumstances. Where the Firm does not have authority to vote proxies on behalf of a Client, proxies and related materials will be received and handled in accordance with the arrangements established by the Client, which may include receipt directly from the relevant custodian or a third-party proxy voting service. Clients with questions regarding a particular solicitation may contact the Firm. Clients may obtain a copy of the Firm's proxy voting policies and procedures, and information regarding how the Firm voted proxies on behalf of the Client, upon request.
Item 18. Financial information
The Firm does not require or solicit prepayment of fees in advance of services rendered.
B)
The Firm is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to the Client.
C)
The Firm has never been the subject of a bankruptcy petition.
Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.