Firm profile

Pender Capital Management, LLC

DALLAS, TXCRD 281448Registration Status: ApprovedEffective since June 15, 2018SEC # 801-113467Latest ADV March 23, 2026

Pender Capital Management, LLC is an SEC registered investment adviser organized as a limited liability company with a primary office location in Dallas, TX. Its latest Form ADV filing, dated March 23, 2026, reports $661M in regulatory assets under management, 14 employees, 2 offices, and 2 accounts.

Assets Under Management
$661M
Employees
14
Offices
2 offices
Total Clients
<5

Associated firm names

1 name listed
  • PENDER CAPITAL MANAGEMENT, LLC

Leadership

3 roles identified
CEOCory A. Johnson
CEOZachary W. Murphy
CCOJason B. Aro

Advisory services offered

2 types reported
Portfolio management for investment companies
Portfolio management for pooled investment vehicles

Fee models offered

3 types reported
Asset based fees
Other fee arrangements
Performance-based fees

Offices & Contact

Primary office

DALLAS, Texas, United States

Loading map…

Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Texas

DALLASPrimary office

California

LOS ANGELES

2 office records listed · 2 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$661Mas of March 23, 2026
Discretionary100.0%
$661M
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentInvestment Cos. represent 50.0% of total clients.
Top client categories% of clientsClients
1
Investment Cos.
50.0%
1
2
Pooled Investment Vehicles
50.0%
1

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$661M
Total Accounts2
10Y AUM Change+$585M (+771.5%)

Private Funds

Private funds reported by Pender Capital Management, LLC

Loading private fund disclosures…

Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees14
Clients per Employee0:1
10Y Employee Change+5 (+55.6%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.


Ownership

Reported direct and indirect ownership ranges

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
PENDER CAPITAL, INC.Direct owner · Schedule AInterest in PENDER CAPITAL MANAGEMENT, LLC
50% to < 75%
REM CAPITAL MANAGEMENT INC.Direct owner · Schedule AInterest in PENDER CAPITAL MANAGEMENT, LLC
25% to < 50%
Cory Allen JohnsonIndirect owner · Schedule BInterest in PENDER CAPITAL, INC.
75%+
Zachary Wilkinson MurphyIndirect owner · Schedule BInterest in REM CAPITAL MANAGEMENT INC.
75%+

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Pender Capital Management, LLC.

Reported ownership and control details

Form ADV · Filing date 2026-03-23 · Schedules A and B

6 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1Cory Allen JohnsonMANAGING DIRECTOR; CEOIndividualPENDER CAPITAL MANAGEMENT, LLCLess than 5%Code NAYesMANAGING DIRECTOR; CEO06/2015Schedule APDF page 25
2PENDER CAPITAL, INC.MEMBERDomestic entityPENDER CAPITAL MANAGEMENT, LLC50% to less than 75%Code DYesMEMBER06/2015Schedule APDF page 25
3Jason Bradford AroCHIEF COMPLIANCE OFFICERIndividualPENDER CAPITAL MANAGEMENT, LLCLess than 5%Code NAYesCHIEF COMPLIANCE OFFICER01/2022Schedule APDF page 25
4REM CAPITAL MANAGEMENT INC.MEMBERDomestic entityPENDER CAPITAL MANAGEMENT, LLC25% to less than 50%Code CYesMEMBER06/2023Schedule APDF page 25
5Cory Allen JohnsonCEOIndividualPENDER CAPITAL, INC.75% or moreCode EYesCEO08/2014Schedule BPDF page 26
6Zachary Wilkinson MurphyCEOIndividualREM CAPITAL MANAGEMENT INC.75% or moreCode EYesCEO06/2023Schedule BPDF page 26

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 3/23/2026 3:36:59 PM

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that none of the events below involve the firm or its supervised persons.RIA responseNo
AFelonies2 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?No
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions2 Yes3 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?Yes
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?Yes
ESelf-regulatory organization actions4 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 3 source blocks

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

regulatory · block 1PENDER CAPITAL ASSET BASED LENDING FUND I, LPPDF pages 26–28
Advisory affiliate name — filed text
PENDER CAPITAL ASSET BASED LENDING FUND I, LP
Regulator name — filed text
DEPARTMENT OF BUSINESS OVERSIGHT OF THE STATE OF CALIFORNIA
Monetary/Fine Amount — filed text
$ 4,000.00
How was matter resolved — filed text
Consent

Action status / disposition — filed text

PENDER CAPITAL MANAGEMENT, LLC ("THE FIRM"), SERVES AS GENERAL PARTNER AND INVESTMENT ADVISER OF THE FUND, BY AND THROUGH ITS AFFILIATE. THE FIRM WAS SIGNIFICANTLY IMPACTED BY THE GLOBAL PANDEMIC KNOWN AS COVID-19 CAUSING ILLNESS, REQUIRING ITS CORPORATE OFFICE TO CLOSE, AND EMPLOYEES TO WORK FROM HOME PURSUANT TO STATE ORDERED MANDATE. AS A RESULT, THE FIRM WAS UNABLE TO TIMELY FILE THE FUND'S CFL ANNUAL REPORT. THE CALIFORNIA DEPARTMENT OF BUSINESS OVERSIGHT REVOKED THE FUND'S CFL LICENSE (NO. 60DBO- 43830), AND SHORTLY THEREAFTER, RESCINDED THE REVOCATION PURSUANT TO A CONSENT ORDER, RESULTING IN THE FIRM PAYING AN ADMINISTRATIVE PENALTY OF $4,000.
Other filed details

Description of allegations — filed text

FAILURE TO TIMELY FILE ANNUAL REPORT REQUIRED BY CALIFORNIA FINANCIAL CODE SECTION 22159

Sanction detail — filed text

ON APRIL 03, 2020, THE CALIFORNIA COMMISSIONER OF BUSINESS OVERSIGHT REVOKED PENDER CAPITAL ASSET BASED LENDING FUND I, L.P.'S (THE "FUND") CFL LICENSE (NO. 60DBO-43830), AND SHORTLY THEREAFTER, ON APRIL 27, 2020, RESCINDED THE REVOCATION PURSUANT TO CONSENT ORDER . AS PART OF SUCH ORDER, THE FUND AGREED TO PAY AN ADMINISTRATIVE PENALTY OF $4,000 (WHICH WAS PAID ON APRIL 27, 2020).
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the

same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
PENDER CAPITAL ASSET BASED
LENDING FUND I, LP
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
DEPARTMENT OF BUSINESS OVERSIGHT OF THE STATE OF CALIFORNIA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/03/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
60DBO-43830
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
COMMERCIAL REAL ESTATE LOANS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO TIMELY FILE ANNUAL REPORT REQUIRED BY CALIFORNIA FINANCIAL CODE SECTION 22159

8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
04/27/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 4,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
ON APRIL 03, 2020, THE CALIFORNIA COMMISSIONER OF BUSINESS OVERSIGHT REVOKED PENDER CAPITAL ASSET BASED LENDING FUND I,
L.P.'S (THE "FUND") CFL LICENSE (NO. 60DBO-43830), AND SHORTLY THEREAFTER, ON APRIL 27, 2020, RESCINDED THE REVOCATION PURSUANT
TO CONSENT ORDER . AS PART OF SUCH ORDER, THE FUND AGREED TO PAY AN ADMINISTRATIVE PENALTY OF $4,000 (WHICH WAS PAID ON
APRIL 27, 2020).
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
PENDER CAPITAL MANAGEMENT, LLC ("THE FIRM"), SERVES AS GENERAL PARTNER AND INVESTMENT ADVISER OF THE FUND, BY AND THROUGH ITS
AFFILIATE. THE FIRM WAS SIGNIFICANTLY IMPACTED BY THE GLOBAL PANDEMIC KNOWN AS COVID-19 CAUSING ILLNESS, REQUIRING ITS CORPORATE
OFFICE TO CLOSE, AND EMPLOYEES TO WORK FROM HOME PURSUANT TO STATE ORDERED MANDATE. AS A RESULT, THE FIRM WAS UNABLE TO TIMELY
FILE THE FUND'S CFL ANNUAL REPORT. THE CALIFORNIA DEPARTMENT OF BUSINESS OVERSIGHT REVOKED THE FUND'S CFL LICENSE (NO. 60DBO-
43830), AND SHORTLY THEREAFTER, RESCINDED THE REVOCATION PURSUANT TO A CONSENT ORDER, RESULTING IN THE FIRM PAYING AN
ADMINISTRATIVE PENALTY OF $4,000.
regulatory · block 2PDF pages 28–30
Regulator name — filed text
DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION
Monetary/Fine Amount — filed text
$ 4,000.00
How was matter resolved — filed text
Consent

Action status / disposition — filed text

PENDER CAPITAL MANAGEMENT, LLC ("THE FIRM") WAS REQUIRED TO RESTATE THEIR 2023 FINANCIALS, WHICH DELAYED THE PREPARATION AND FILING OF THE 2024 FINANCIALS. AS A RESULT, THE FIRM WAS UNABLE TO TIMELY FILE THE CFL ANNUAL REPORT. THE CALIFORNIA DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION REVOKED THE FIRM'S CFL LICENSE (NO. 60DBO-188299), AND SHORTLY THEREAFTER, RESCINDED THE REVOCATION PURSUANT TO A CONSENT ORDER, RESULTING IN THE FIRM PAYING AN ADMINISTRATIVE PENALTY OF $4,000.
Other filed details

Description of allegations — filed text

FAILURE TO TIMELY FILE ANNUAL REPORT REQUIRED BY CALIFORNIA FINANCIAL CODE SECTION 22159

Sanction detail — filed text

ON APRIL 24, 2025, THE DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION REVOKED PENDER CAPITAL MANAGEMENT, LLC'S (THE "FIRM") CFL LICENSE (NO. 60DBO-188299), AND SHORTLY THEREAFTER, ON MAY 29, 2025, RESCINDED THE REVOCATION PURSUANT TO CONSENT ORDER. AS PART OF SUCH ORDER, THE FIRM AGREED TO PAY AN ADMINISTRATIVE PENALTY OF $4,000.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/24/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
60DBO-188299
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
COMMERCIAL REAL ESTATE LOANS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO TIMELY FILE ANNUAL REPORT REQUIRED BY CALIFORNIA FINANCIAL CODE SECTION 22159
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):
05/29/2025
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 4,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
ON APRIL 24, 2025, THE DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION REVOKED PENDER CAPITAL MANAGEMENT, LLC'S (THE
"FIRM") CFL LICENSE (NO. 60DBO-188299), AND SHORTLY THEREAFTER, ON MAY 29, 2025, RESCINDED THE REVOCATION PURSUANT TO
CONSENT ORDER. AS PART OF SUCH ORDER, THE FIRM AGREED TO PAY AN ADMINISTRATIVE PENALTY OF $4,000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
PENDER CAPITAL MANAGEMENT, LLC ("THE FIRM") WAS REQUIRED TO RESTATE THEIR 2023 FINANCIALS, WHICH DELAYED THE PREPARATION AND
FILING OF THE 2024 FINANCIALS. AS A RESULT, THE FIRM WAS UNABLE TO TIMELY FILE THE CFL ANNUAL REPORT. THE CALIFORNIA DEPARTMENT OF
FINANCIAL PROTECTION AND INNOVATION REVOKED THE FIRM'S CFL LICENSE (NO. 60DBO-188299), AND SHORTLY THEREAFTER, RESCINDED THE
REVOCATION PURSUANT TO A CONSENT ORDER, RESULTING IN THE FIRM PAYING AN ADMINISTRATIVE PENALTY OF $4,000.
regulatory · block 3PENDER REAL ESTATE CREDIT FUNDPDF pages 30–32
Advisory affiliate name — filed text
PENDER REAL ESTATE CREDIT FUND
Regulator name — filed text
DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION
Monetary/Fine Amount — filed text
$ 4,000.00
How was matter resolved — filed text
Consent

Action status / disposition — filed text

PENDER CAPITAL MANAGEMENT, LLC ("THE FIRM"), SERVES AS GENERAL PARTNER AND INVESTMENT ADVISER OF THE FUND, BY AND THROUGH ITS AFFILIATE. THE FIRM WAS REQUIRED TO RESTATE THEIR 2023 FINANCIALS, WHICH DELAYED THE PREPARATION AND FILING OF THE 2024 FINANCIALS. AS A RESULT, THE FIRM WAS UNABLE TO TIMELY FILE THE FUND'S CFL ANNUAL REPORT. THE CALIFORNIA DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION REVOKED THE FUND'S CFL LICENSE (NO. 60DBO-188297), AND SHORTLY THEREAFTER, RESCINDED THE REVOCATION PURSUANT TO A CONSENT ORDER, RESULTING IN THE FIRM PAYING AN ADMINISTRATIVE PENALTY OF $4,000.
Other filed details

Description of allegations — filed text

FAILURE TO TIMELY FILE ANNUAL REPORT REQUIRED BY CALIFORNIA FINANCIAL CODE SECTION 22159

Sanction detail — filed text

ON APRIL 24, 2025, THE DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION REVOKED PENDER REAL ESTATE CREDIT FUND'S (THE "FUND") CFL LICENSE (NO. 60DBO-188297), AND SHORTLY THEREAFTER, ON MAY 29, 2025, RESCINDED THE REVOCATION PURSUANT TO CONSENT ORDER. AS PART OF SUCH ORDER, THE FUND AGREED TO PAY AN ADMINISTRATIVE PENALTY OF $4,000.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
PENDER REAL ESTATE CREDIT
FUND
(For individuals, Last, First,

Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/24/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
60DBO-188297
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
COMMERCIAL REAL ESTATE LOANS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO TIMELY FILE ANNUAL REPORT REQUIRED BY CALIFORNIA FINANCIAL CODE SECTION 22159
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
05/29/2025
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 4,000.00

 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
ON APRIL 24, 2025, THE DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION REVOKED PENDER REAL ESTATE CREDIT FUND'S (THE
"FUND") CFL LICENSE (NO. 60DBO-188297), AND SHORTLY THEREAFTER, ON MAY 29, 2025, RESCINDED THE REVOCATION PURSUANT TO
CONSENT ORDER. AS PART OF SUCH ORDER, THE FUND AGREED TO PAY AN ADMINISTRATIVE PENALTY OF $4,000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
PENDER CAPITAL MANAGEMENT, LLC ("THE FIRM"), SERVES AS GENERAL PARTNER AND INVESTMENT ADVISER OF THE FUND, BY AND THROUGH ITS
AFFILIATE. THE FIRM WAS REQUIRED TO RESTATE THEIR 2023 FINANCIALS, WHICH DELAYED THE PREPARATION AND FILING OF THE 2024 FINANCIALS.
AS A RESULT, THE FIRM WAS UNABLE TO TIMELY FILE THE FUND'S CFL ANNUAL REPORT. THE CALIFORNIA DEPARTMENT OF FINANCIAL PROTECTION
AND INNOVATION REVOKED THE FUND'S CFL LICENSE (NO. 60DBO-188297), AND SHORTLY THEREAFTER, RESCINDED THE REVOCATION PURSUANT TO A
CONSENT ORDER, RESULTING IN THE FIRM PAYING AN ADMINISTRATIVE PENALTY OF $4,000.

* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.