Five Eleven Partners is a investment adviser based in Garden City, NY, that holds a 95.9/100 Fidelon TransparencyScore (93rd percentile among SEC-registered advisers), with 3 registered advisors. Score based on public SEC and FINRA filings.
Five Eleven Partners
Five Eleven Family Office · CRD #334002
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Five Eleven Partners is an SEC-registered investment adviser in Garden City, NY. It used to be called Five Eleven Family Office LLC. It has 3 registered advisors. It manages $162.7 million across 36 client accounts. It charges a yearly percentage of your account, and it does not report earning commissions. Its services include financial planning, portfolio management, educational seminars and investment newsletters. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
764th of 10,815
SEC-registered advisers
Top 7%
95th of 1,070
SEC-registered advisers in NY
Top 9%
3rd of 16
SEC-registered advisers in Garden city, NY
Top 19%
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Charges fixed fees for specific services
- Does not earn commissions on product sales
What you’d pay
Your balance falls in the All accounts band, charged at 0.00%–2.00% on the full amount. The brochure files a range for this band, so the exact rate is set in your agreement.
This fee is negotiable
“Client fees are negotiated and are set forth in detail in the corresponding Investment Management Agreement.”
From their Form ADV Part 2A. Most investors never ask.
Other arrangements offered
- • A negotiated fee, agreed individually
Not included above
- • Clients generally incur certain charges imposed by the Financial Institutions and other third parties such as fees charged by independent investment managers, custodial fees, charges imposed directly by a mutual fund or ETF, deferred sales charges, odd-lot differentials, trade away fees, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. In addition to all other fees and expenses incurred in the management of advisory accounts, Client accounts that utilize margin strategies will also incur interest charges.
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| All accounts | 0.00%–2.00% |
Billed quarterly in advance of each calendar quarter
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Fee-only compensation — no commission income reported
- Registered as investment adviser with fiduciary obligation
- No broker-dealer registration — advisory services only
- Clean regulatory record — no disclosures, arbitrations, or fines
- Transparent fee structure — charges advisory fees, no commissions
Conflict Audit
Our analysis identified 2 potential conflicts of interest in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
What this firm says about how it gets paid
“The more assets in a client's account, the more the client will pay in fees, thus the Adviser has an incentive to encourage the client to increase the assets in their account.”
Source: the firm’s own Form CRS — quoted directly
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
88/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
73/100
Fair
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Their two-page relationship summary
The SEC requires every SEC-registered investment adviser to hand you this summary, called a Form CRS, and says what it must cover. We checked this firm's against that list. What is a Form CRS?
- Does it include everything the SEC requires?
- Required sections
- 94/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
- 71/100
- Can you tell what you would pay?
- What you pay
- 75/100
- Is it written in plain English?
- Plain language
- 94/100
This firm's Form CRS averages 84 out of 100 and adds 5.88 points to the score above.
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity85/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
The Management Fee ranges from 0% to 2% per annum.p. 4
- Does it say whether the fee can be negotiated?CoveredItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
Client fees are negotiated and are set forth in detail in the corresponding Investment Management Agreement.p. 4
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
Five Eleven’s Agreement and/or the agreement between a client and a Financial Institution typically authorizes Five Eleven or an independent investment manager to debit the Client’s account for the amount of Five Eleven’s fee and to directly remit that management fee to the Firm or the independent investment manager.p. 6
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
The Management Fee will be paid quarterly in advance of each calendar quarter.p. 4
- Does it list the other costs you pay, like fund and custodian fees?CoveredItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
Clients generally incur certain charges imposed by the Financial Institutions and other third parties such as fees charged by independent investment managers, custodial fees, charges imposed directly by a mutual fund or ETF, deferred sales charges, odd-lot differentials, trade away fees, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.p. 5
- Does it say how you get money back if you leave mid-period?Not found in the brochureItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
What to askAsk what happens to fees already paid if you close the account partway through a billing period.
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity70/100
The SEC asks the brochure to name each way the firm gets paid besides your fee, what that tempts the firm to do, and what it can cost you.
The brochure answers every one of these.
The brochure states the firm has no conflicts of this kind, and its Form ADV Part 1 agrees.
- Does the brochure say the firm has no conflicts of this kind?CoveredItems 10/11/12.B/14 + Part 1A
A clear statement that the firm earns nothing from commissions, perks or referrals is the simplest answer there is.
Five Eleven does not have any affiliation with brokerage firms or other product sales firms.p. 11
Do they earn commissions on products, and do they say so?Brochure Sales CompensationNot applicable
Not applicable: the brochure describes no product-sales commissions
Do they get free research or services from brokers, and does it affect you?Brochure Soft Dollars82/100
When brokers give the firm research or services in return for your trades, the SEC asks the brochure to say what the firm gets and what it may cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it list what the firm gets from brokers for free?CoveredItem 12.A.1.e
Research, software and data paid for by your trades are a cost you never see.
In such cases, Soft Dollar credits, generated by the Client’s trading activities, would be used to purchase brokerage and research services or products that would otherwise have been Fund expense.p. 12
- Does it say the firm benefits by not paying for those things?CoveredItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
The provision by a broker of research and other services and property to us creates an incentive for us to select such broker since we would not have to pay for such research and other services and property as opposed to solely seeking the most favorable execution for a client.p. 12
- Does it say those perks can shape which broker it picks for you?CoveredItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
The provision by a broker of research and other services and property to us creates an incentive for us to select such broker since we would not have to pay for such research and other services and property as opposed to solely seeking the most favorable execution for a client.p. 12
- Does it say whether those perks stay within what the law allows?CoveredItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
We intend to keep any such arrangements within the parameters of the safe harbor of Section 28(e) of the Exchange Act.p. 12
- Does it say whether you pay more in trading costs because of those perks?Does not applyItem 12.A.1.c
Paying up for trades to earn the firm a perk comes straight out of your returns.
- Does it say whether every client benefits or only some?Not found in the brochureItem 12.A.1.d
Your trades may be paying for research that helps other clients' accounts, not yours.
What to askAsk whether the research your trades help pay for is used for your account.
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
Next Steps
Advisor Roster
3 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Gilbert Aaron Calderon | 5002608 | — | — |
| Keith J. Feinberg | 7394452 | — | — |
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.15 · CRD #334002