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Clearwater Advisors, LLC

Boise, IDSEC-registered investment adviserCRD 116865

Filed as CLEARWATER ADVISORS, LLC

Clearwater Advisors, LLC is an SEC-registered investment advisory firm in Boise, ID, registered since 2001, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated May 7, 2026.

24 years
registered since 2001
$4,650,566,101
assets under management
2 arrangements
Percentage of assets, Fixed fees
None
disclosure items (Item 11)

Quick answers

From the filing

How is Clearwater Advisors, LLC compensated?

On its Form ADV (Item 5.E, October 2026), Clearwater Advisors, LLC reports these compensation arrangements: a percentage of assets under its management; fixed fees (other than subscription fees).

How much does Clearwater Advisors, LLC charge?

Its Form ADV Part 2A brochure dated May 7, 2026 states: Asset-based fee: 0.1% to 0.4% a year (a range, as the brochure states it). Fees can differ by service and may be negotiable; the brochure is the complete statement.

Where is Clearwater Advisors, LLC located?

Clearwater Advisors, LLC's principal office is in Boise, ID, according to its Form ADV.

Is Clearwater Advisors, LLC registered with the SEC or a state?

Clearwater Advisors, LLC is an SEC-registered investment advisory firm, registered since 2001. Status as filed: Approved. CRD 116865.

How much does Clearwater Advisors, LLC manage?

Clearwater Advisors, LLC reports $4,650,566,101 in regulatory assets under management in its Form ADV filing dated May 7, 2026 (84% discretionary).

How have Clearwater Advisors, LLC's assets and staff changed since 2021?

In the Form ADV data for Clearwater Advisors, LLC: Regulatory assets under management: $4,001,533,347 in the October 2021 data and $4,650,566,101 in the October 2026 data, up 16%. Total employees: 9 in October 2021 and 9 in October 2026. Assets under management move with markets as well as with clients coming and going.

What types of clients does Clearwater Advisors, LLC serve?

By number of clients on Form ADV Item 5.D: corporations or other businesses not listed above (17); state or municipal government entities (including government pension plans) (10); insurance companies (5).

Which custodians does Clearwater Advisors, LLC use?

Clearwater Advisors, LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists BNY Mellon Capital Markets, LLC and U.S. Bancorp Investments, Inc. as custodians holding 10% or more of its separately managed account assets.

Does Clearwater Advisors, LLC report any disciplinary disclosures?

Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/116865

Does Clearwater Advisors, LLC state an account minimum?

Its Form ADV Part 2A brochure dated May 7, 2026 says: "Clearwater assesses and accepts clients on a case-by-case basis, with no set minimum account size."

From the Form ADV filing

Every figure below is as the firm filed it with regulators, as of October 2026.

How the firm is compensated

Item 5.E
  • A percentage of assets under your management
  • Fixed fees (other than subscription fees)

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

Fees and minimums

Form ADV Part 2A

Asset-based fee: 0.1% to 0.4% a year (a range, as the brochure states it)

The brochure's wording
Management fees typically range between 0.1% and 0.40% of assets under management.

Account minimum: None

The brochure's wording
Clearwater assesses and accepts clients on a case-by-case basis, with no set minimum account size.

As stated in the firm's Form ADV Part 2A brochure dated May 7, 2026. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site

Regulatory assets under management

Item 5.F
$4,650,566,101

$4,650,566,101 as of October 2026, filing dated May 7, 2026.

Discretionary: $3,923,197,241.Non-discretionary: $727,368,860.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

Who the firm serves

Item 5.D
Individuals (other than high net worth individuals)
Clients 0 Assets $0 (0%)
High net worth individuals
Clients Fewer than 5 Assets $78,894,423 (2%)
Banking or thrift institutions
Clients Fewer than 5 Assets $43,097,299 (1%)
Investment companies
Clients 0 Assets $0 (0%)
Business development companies
Clients 0 Assets $0 (0%)
Pooled investment vehicles (other than investment companies and business development companies)
Clients 0 Assets $0 (0%)
Pension and profit sharing plans (but not the plan participants or government pension plans)
Clients Fewer than 5 Assets $861,356,182 (19%)
Charitable organizations
Clients 0 Assets $0 (0%)
State or municipal government entities (including government pension plans)
Clients 10 Assets $740,232,495 (16%)
Other investment advisers
Clients 0 Assets $0 (0%)
Insurance companies
Clients 5 Assets $626,418,908 (13%)
Sovereign wealth funds and foreign official institutions
Clients 0 Assets $0 (0%)
Corporations or other businesses not listed above
Clients 17 Assets $2,300,566,794 (49%)
Other
Clients 0 Assets $0 (0%)

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

Advisory services

Item 5.G
  • Portfolio management for individuals and/or small businesses
  • Portfolio management for businesses (other than small businesses) or institutional clients
  • Other

Registration and firm details

Items 1, 2, 5
Registration
SEC-registered investment adviser. Status as filed: Approved.
Registered since
2001 (24 years)
Employees
Total: 9. Performing investment advisory functions: 5.
Wrap fee program participation
No.
Custodians (Schedule D, Section 5.K(3))

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

States registered or notice-filed
5 states or jurisdictions
CAIDMIORWA

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

Disclosures

Item 11

None Reports no disclosure items on Form ADV Item 11. View on IAPD.

Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures

Assets and staff over time

Items 5.A, 5.F
$4B 2021 $4.01B 2022 $3.63B 2023 $3.8B 2024 $4.53B 2025 $4.65B 2026
Data periodAssets under managementEmployeesFiling dated
October 2026$4,650,566,1019May 7, 2026
October 2025$4,525,460,77310March 6, 2025
October 2024$3,797,719,93110March 7, 2024
October 2023$3,626,745,62410July 17, 2023
October 2022$4,009,666,14610February 15, 2022
October 2021$4,001,533,3479September 21, 2021

Regulatory assets under management: $4,001,533,347 in the October 2021 data and $4,650,566,101 in the October 2026 data, up 16%.

Total employees: 9 in October 2021 and 9 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

Changes in the filing

Last 12 months

No changes to these filed facts in the last 12 months of filing data.

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.

Websites listed on Form ADV

Item 1.I
clearwateradvisors.com

Source: Form ADV, as of October 2026. Values appear as filed; a value the firm did not report is shown as "Not reported."

Cite this page

AdvisorCensus. Clearwater Advisors, LLC (CRD 116865): Form ADV filing data as of October 2026.
https://advisorcensus.com/firm/clearwater-advisors-llc-boise-id-116865