# 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.

- CRD: 116865
- Filed as: CLEARWATER ADVISORS, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Boise, ID
- Filing period: October 2026
- Form ADV filing dated: May 7, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/116865
- AdvisorCensus page: https://advisorcensus.com/firm/clearwater-advisors-llc-boise-id-116865

## Quick answers

**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

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

### Fees and minimums (Form ADV Part 2A brochure dated May 7, 2026)

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

> Management fees typically range between 0.1% and 0.40% of assets under management.

- Account minimum: None

> Clearwater assesses and accepts clients on a case-by-case basis, with no set minimum account size.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- BNY Mellon Capital Markets, LLC
- U.S. Bancorp Investments, Inc.

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.

### Regulatory assets under management (Item 5.F)
- Total: $4,650,566,101
- Discretionary: $3,923,197,241
- Non-discretionary: $727,368,860

### Clients (Item 5.D)

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

### 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

### Firm details
- Registered since: 2001 (24 years)
- Employees: 9 total, 5 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, ID, MI, OR, WA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- clearwateradvisors.com
- LinkedIn @CLEARWATERADVISORS

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $4,001,533,347 | 9 | September 21, 2021 |
| October 2022 | $4,009,666,146 | 10 | February 15, 2022 |
| October 2023 | $3,626,745,624 | 10 | July 17, 2023 |
| October 2024 | $3,797,719,931 | 10 | March 7, 2024 |
| October 2025 | $4,525,460,773 | 10 | March 6, 2025 |
| October 2026 | $4,650,566,101 | 9 | May 7, 2026 |

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.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Clearwater Advisors, LLC (CRD 116865): Form ADV filing data as of October 2026.