CIK: 0002007171
Total reported value
$2.0B
Reporting period: 2026-09-30 · Number of holdings: 505
Turtle Creek Wealth Advisors, LLC disclosed 505 holdings in its latest 13F filing for the period ending 2026-09-30, with total reported value of $2.0B and a quarterly turnover rate of 26.4%.
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Turtle Creek Wealth Advisors, LLC's disclosed holdings carry a Herfindahl concentration index of 0.021 — mathematically equivalent to about 49 equally-sized positions, well below its 505 actual disclosed holdings. That gap points to a strategy built around a small core of high-conviction bets rather than broad diversification.
Position sizes vary widely across the portfolio (a coefficient of variation of 3.06), with a handful of outsized bets alongside many smaller positions.
No strong tilt toward either adding to existing winners or initiating outsized new positions was observed in the latest reported quarter.
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New buy 30233Q108
Sold out XOM
Add CVX
+29.7% $39.0M
Add MPC
+92.1% $35.0M
Trim SPY
-25.6% -$21.6M
Add MSFT
+11.7% $23.9M
Showing top 200 holdings (of 505 total)
| # | Ticker | Issuer | Asset Subclass | Weight | Weight Change | Shares Change | 4Q Trend |
|---|---|---|---|---|---|---|---|
| 1 | VOO | Vanguard S&p 500 ETF | ETF-Large Cap & Growth | 6.61% | +0.02% | +2.91% | |
| 2 | CVX | Chevron CORP | Stock-Energy | 5.28% | +1.82% | +29.75% | |
| 3 | AAPL | Apple Inc | Stock-Tech | 4.26% | +0.58% | +5.26% | |
| 4 | NVDA | Nvidia CORP | Stock-Tech | 3.86% | +0.50% | +5.20% | |
| 5 | IEFA | Ishares Core Msci Eafe ETF | ETF-Other | 3.86% | -0.02% | +3.63% | |
| 6 | SPY | Ss Spdr S&p 500 ETF Trust-us | ETF-Large Cap & Growth | 3.48% | -1.30% | -25.64% | |
| 7 | MSFT | Microsoft CORP | Stock-Tech | 3.46% | +1.10% | +11.67% | |
| 8 | ✓ | Stock-Other | 3.20% | +3.20% | NEW | ||
| 9 | MPC | Marathon Petroleum CORP | Stock-Energy | 2.67% | +1.73% | +92.13% | |
| 10 | GOOGL | Alphabet Inc-cl A | Stock-Comm Services | 1.83% | +0.02% | +9.93% | |
| 11 | AMZN | Amazon.com Inc | Stock-Consumer Disc | 1.72% | +0.14% | +9.06% | |
| 12 | LLY | Eli Lilly & Co | Stock-Healthcare | 1.67% | -0.09% | +2.95% | |
| 13 | CAT | Caterpillar Inc | Stock-Industrials | 1.51% | -0.44% | +6.66% | |
| 14 | IJH | Ishares Core S&p Midcap ETF | ETF-Other | 1.45% | -0.23% | -3.15% | |
| 15 | AVGO | Broadcom Inc | Stock-Tech | 1.42% | -0.11% | +4.30% | |
| 16 | LRCX | Lam Research CORP | Stock-Tech | 1.38% | -0.59% | -3.15% | |
| 17 | JPM | Jpmorgan Chase & Co | Stock-Financials | 1.36% | -0.05% | -0.85% | |
| 18 | META | Meta Platforms Inc-class A | Stock-Comm Services | 1.30% | +0.32% | +7.22% | |
| 19 | GOOG | Alphabet Inc-cl C | Stock-Comm Services | 1.26% | -0.08% | +2.25% | |
| 20 | DMLP | Dorchester Minerals LP | Stock-Other | 1.19% | +0.07% | — | |
| 21 | AMAT | Applied Materials Inc | Stock-Tech | 1.13% | -0.53% | +0.04% | |
| 22 | KLAC | Kla CORP | Stock-Tech | 1.11% | -0.70% | -0.68% | |
| 23 | KO | Coca-cola Co/the | Stock-Consumer Staples | 0.99% | +0.05% | +4.12% | |
| 24 | V | Visa Inc-class A Shares | Stock-Financials | 0.98% | -0.01% | -0.67% | |
| 25 | APH | Amphenol Corp-cl A | Stock-Tech | 0.97% | -0.06% | +105.97% | |
| 26 | VEA | Vanguard Ftse Developed ETF | ETF-Other | 0.95% | -0.23% | -14.69% | |
| 27 | PAGP | Plains Gp Holdings Lp-cl A | Stock-Energy | 0.93% | -0.11% | -12.34% | |
| 28 | PG | Procter & Gamble Co/the | Stock-Consumer Staples | 0.85% | -0.04% | +0.57% | |
| 29 | JNJ | Johnson & Johnson | Stock-Healthcare | 0.80% | -0.01% | -0.97% | |
| 30 | COST | Costco Wholesale CORP | Stock-Consumer Staples | 0.79% | -0.03% | +3.74% | |
| 31 | EPD | Enterprise Products Partners | Stock-Energy | 0.79% | -0.04% | +1.95% | |
| 32 | ET | Energy Transfer LP | Stock-Energy | 0.75% | — | +1.05% | |
| 33 | EOG | Eog Resources Inc | Stock-Energy | 0.73% | +0.04% | +5.11% | |
| 34 | PH | Parker Hannifin CORP | Stock-Industrials | 0.69% | -0.02% | +4.89% | |
| 35 | TJX | Tjx Companies Inc | Stock-Consumer Disc | 0.67% | -0.15% | -2.01% | |
| 36 | GRMN | Garmin Ltd. | Stock-Tech | 0.62% | +0.09% | +1.71% | |
| 37 | IWB | Ishares Russell 1000 ETF | ETF-Other | 0.59% | -0.02% | — | |
| 38 | TT | Trane Technologies plc | Stock-Industrials | 0.57% | -0.05% | +5.08% | |
| 39 | PM | Philip Morris International | Stock-Consumer Staples | 0.56% | +0.04% | +7.91% | |
| 40 | BLK | Blackrock Inc | Stock-Financials | 0.56% | -0.39% | -44.59% | |
| 41 | MA | Mastercard Inc - A | Stock-Financials | 0.55% | +0.05% | +7.29% | |
| 42 | ITOT | Ishares Core S&p Total U.s. | ETF-Other | 0.54% | +0.03% | +10.72% | |
| 43 | ETR | Entergy CORP | Stock-Utilities | 0.54% | -0.05% | +10.40% | |
| 44 | AFL | Aflac Inc | Stock-Financials | 0.53% | -0.03% | +3.37% | |
| 45 | PGR | Progressive CORP | Stock-Financials | 0.50% | -0.06% | +0.01% | |
| 46 | HD | Home Depot Inc | Stock-Consumer Disc | 0.49% | -0.18% | -4.01% | |
| 47 | SPGI | S&p Global Inc | Stock-Financials | 0.49% | -0.01% | +5.87% | |
| 48 | MU | Micron Technology Inc | Stock-Tech | 0.48% | -0.02% | +8.64% | |
| 49 | TXN | Texas Instruments Inc | Stock-Tech | 0.48% | -0.13% | -12.74% | |
| 50 | CI | THE Cigna Group | Stock-Healthcare | 0.46% | -0.01% | +5.51% |
Performance for Q4 2026
+2.7%
Performance Last 4 Quarters
+16.5%
Turtle Creek Wealth Advisors, LLC's most significant position changes for 2026-09-30: New buy: ; Sold out: Exxon Mobil CORP (XOM); Sold out: Sm Energy Co (SM); New buy: ; Sold out: Oneok Inc (OKE).
Showing top 200 changes by size (of 552 total)
| # | Ticker | Issuer | Weight Change | Shares Change | Action |
|---|---|---|---|---|---|
| 1 | ✓ | +3.2% | NEW | New buy | |
| 2 | CVX | Chevron CORP | +1.8% | +29.75% | Add |
| 3 | MPC | Marathon Petroleum CORP | +1.7% | +92.13% | Add |
| 4 | MSFT | Microsoft CORP | +1.1% | +11.67% | Add |
| 5 | AAPL | Apple Inc | +0.6% | +5.26% | Add |
| 6 | NVDA | Nvidia CORP | +0.5% | +5.20% | Add |
| 7 | MSI | Motorola Solutions Inc | +0.4% | +3172.61% | Add |
| 8 | NDAQ | Nasdaq Inc | +0.4% | +2057.07% | Add |
| 9 | GWW | Ww Grainger Inc | +0.4% | +3371.72% | Add |
| 10 | META | Meta Platforms Inc-class A | +0.3% | +7.22% | Add |
| 11 | AMZN | Amazon.com Inc | +0.1% | +9.06% | Add |
| 12 | BTI | British American Tob-sp Adr | +0.1% | +1039.92% | Add |
| 13 | COP | Conocophillips | +0.1% | +41.21% | Add |
| 14 | ✓ | +0.1% | NEW | New buy | |
| 15 | PLTR | Palantir Technologies Inc-a | +0.1% | +39.77% | Add |
| 16 | GRMN | Garmin Ltd. | +0.1% | +1.71% | Add |
| 17 | AMD | Advanced Micro Devices | +0.1% | +23.99% | Add |
| 18 | EMR | Emerson Electric Co | +0.1% | +162.29% | Add |
| 19 | DMLP | Dorchester Minerals LP | +0.1% | — | Unchanged |
| 20 | ✓ | +0.1% | NEW | New buy | |
| 21 | KO | Coca-cola Co/the | +0.1% | +4.12% | Add |
| 22 | MA | Mastercard Inc - A | +0.1% | +7.29% | Add |
| 23 | AMGN | Amgen Inc | +0.1% | +14.22% | Add |
| 24 | EOG | Eog Resources Inc | 0% | +5.11% | Add |
| 25 | PM | Philip Morris International | 0% | +7.91% | Add |
| 26 | CRWD | Crowdstrike Holdings Inc - A | 0% | +309.24% | Add |
| 27 | CRM | Salesforce Inc | 0% | +59.23% | Add |
| 28 | TMO | Thermo Fisher Scientific Inc | 0% | +14.35% | Add |
| 29 | NOW | Servicenow Inc | 0% | +15.35% | Add |
| 30 | ITOT | Ishares Core S&p Total U.s. | 0% | +10.72% | Add |
| 31 | MRK | Merck & Co. Inc. | 0% | +7.19% | Add |
| 32 | CME | Cme Group Inc | 0% | -4.68% | Trim |
| 33 | GILD | Gilead Sciences Inc | 0% | +22.12% | Add |
| 34 | PANW | Palo Alto Networks Inc | 0% | +8.72% | Add |
| 35 | MRVL | Marvell Technology Inc | 0% | +237.11% | Add |
| 36 | LNG | Cheniere Energy Inc | 0% | +34.62% | Add |
| 37 | VOO | Vanguard S&p 500 ETF | 0% | +2.91% | Add |
| 38 | GOOGL | Alphabet Inc-cl A | 0% | +9.93% | Add |
| 39 | ADP | Automatic Data Processing | 0% | +2.12% | Add |
| 40 | ANET | Arista Networks Inc | 0% | +18.11% | Add |
| 41 | DE | Deere & Co | 0% | +8.62% | Add |
| 42 | NFLX | Netflix Inc | 0% | +20.93% | Add |
| 43 | ACN | Accenture plc | 0% | +18.94% | Add |
| 44 | HIG | Hartford Insurance Group Inc | 0% | NEW | New buy |
| 45 | NVS | Novartis Ag-sponsored Adr | 0% | NEW | New buy |
| 46 | DHR | Danaher CORP | 0% | +48.79% | Add |
| 47 | SYF | Synchrony Financial | 0% | NEW | New buy |
| 48 | IHI | Ishares U.s. Medical Devices | 0% | NEW | New buy |
| 49 | RJF | Raymond James Financial Inc | 0% | NEW | New buy |
| 50 | LBTYA | Liberty Global Ltd. | 0% | NEW | New buy |
Turtle Creek Wealth Advisors, LLC returned an annualized 16.4% over the trailing 32 months — outperforming the S&P 500 by 0.2 points — based on a reconstructed track record of its disclosed 13F positions, with a beta of 0.89 (less volatile than the market) and a 34% quarterly batting average against the index.
Its portfolio is broadly diversified and moderately active, with 32.5% of the portfolio concentrated in Information Technology.
Its turnover score has fallen from 57 to 26 over the past 4 quarters — a shift toward longer holding periods.
It has added to its CVX position over the past two quarters (+$98.5M, now $104.7M), while trimming INTU over the same stretch (-$7.9M, still holding $813.9K).
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