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Fidelon

Theorem is a investment adviser based in New York, NY, that holds a 60.0/100 Fidelon TransparencyScore (th percentile), with 3 registered advisors. Score based on public SEC and FINRA filings.

60.0Transparency Score
Bottom3%

Theorem

A registered investment adviser held to a fiduciary standard.

335 Madison Avenue, 16th Fl, New York, NY, 10017-4611
646-214-8587Website
Investment AdviserFiduciary
Prep Kit

Fidelon Fact Sheet

Theorem is an investment adviser in New York, NY. It manages private funds and holds client money. The firm charges a fee based on the size of each account. It runs educational seminars on private investments. It has a clean record with no complaints or fines.

60.0FairBottom 3% of scored firms
How they're paidPaid more when your account grows — a conflict to weigh.
Performance-based fees
Duty to youLegally required to put your interests first.
Registered adviser · fiduciary
Assets under managementAcross 4 client accounts.
$1B
Firm size
3 advisors
Who holds your moneyThe firm or a related party can hold or access client funds.
Custody disclosed
Regulatory recordFull record in Regulatory Track Record below.
1 disclosure · last action 2020
Based on live filings from SEC Form ADV and FINRA BrokerCheck. Scored using Fidelon's published methodology. Data as of Jun 2026

Peer Context

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Key Findings

Strengths

  • Registered as investment adviser with fiduciary obligation

Things You Should Know

  • 1 regulatory complaint in public regulatory filings
  • $2K in regulatory fines
  • Fee disclosure could be more detailed — regulatory filings describe fee schedules and service terms less clearly than top-scoring peers

Conflict Audit

Conflict AuditCaution

Our analysis identified 2 potential conflicts of interest in regulatory filings.

✓
Not registered as broker-dealer
✓
No commissions on advisory accounts
✓
No outside compensation from related parties
✓
No related-party custodian
⚠
Charges performance-based fees — may incentivize riskier strategies
⚠
Also sells commodity trading — can earn money beyond advisory fees

Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14

Regulatory Events

Next Steps

This firm's score reflects some areas where disclosure could improve. Here's what that means for you.
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Meeting Prep Kit for Theorem

Walk into your next meeting fully prepared. We'll generate a meeting prep kit based on Theorem's actual regulatory filings — not generic advice.

✓Fee structure breakdown
✓Conflict of interest analysis
✓Regulatory track record
✓Fiduciary status check
✓Personalized questions to ask
✓How they compare locally

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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

SEC Form ADV Part 1 — Filed Jun 2026SEC Form ADV Part 2ASEC IAPDFINRA BrokerCheck

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: 3.8 · CRD #281280