# Clearwater Management Co., Inc.

> Clearwater Management Co., Inc. is an SEC-registered investment advisory firm in St Paul, MN, registered since 1987, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated March 17, 2026.

- CRD: 105307
- Filed as: CLEARWATER MANAGEMENT CO., INC.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: St Paul, MN
- Filing period: October 2026
- Form ADV filing dated: March 17, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/105307
- AdvisorCensus page: https://advisorcensus.com/firm/clearwater-management-co-inc-st-paul-mn-105307

## Quick answers

**How is Clearwater Management Co., Inc. compensated?**
On its Form ADV (Item 5.E, October 2026), Clearwater Management Co., Inc. reports these compensation arrangements: a percentage of assets under its management; other. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Clearwater Management Co., Inc. located?**
Clearwater Management Co., Inc.'s principal office is in St Paul, MN, according to its Form ADV; the April 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Clearwater Management Co., Inc. registered with the SEC or a state?**
Clearwater Management Co., Inc. is an SEC-registered investment advisory firm, registered since 1987. Status as filed: Approved. CRD 105307.

**How much does Clearwater Management Co., Inc. manage?**
Clearwater Management Co., Inc. reports $4,681,919,861 in regulatory assets under management in its Form ADV filing dated March 17, 2026 (100% discretionary).

**How have Clearwater Management Co., Inc.'s assets and staff changed since 2021?**
In the Form ADV data for Clearwater Management Co., Inc.: Regulatory assets under management: $3,077,409,131 in the October 2021 data and $4,681,919,861 in the October 2026 data, up 52%. Total employees: 1 in October 2021 and 1 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Clearwater Management Co., Inc. serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (9); investment companies (4).

**Does Clearwater Management Co., Inc. 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/105307

**What changed in Clearwater Management Co., Inc.'s recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $4,119,965,494 to $4,681,919,861 (+14%).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Other

### Regulatory assets under management (Item 5.F)
- Total: $4,681,919,861
- Discretionary: $4,681,919,861
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Investment companies | 4 | $3,900,605,254 |
| Pooled investment vehicles (other than investment companies and business development companies) | 9 | $781,314,607 |

### Advisory services (Item 5.G)
- Portfolio management for investment companies (and business development companies)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Selection of other advisers (including private fund managers)

### Firm details
- Registered since: 1987 (39 years)
- Employees: 1 total, 1 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: MN, WA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the April 2026 filing
- Tacoma, WA

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $3,077,409,131 | 1 | July 1, 2021 |
| October 2022 | $3,916,168,533 | 1 | June 29, 2022 |
| October 2023 | $3,188,836,603 | 1 | March 23, 2023 |
| October 2024 | $3,797,803,633 | 1 | June 27, 2024 |
| October 2025 | $4,119,965,494 | 1 | June 24, 2025 |
| October 2026 | $4,681,919,861 | 1 | March 17, 2026 |

Regulatory assets under management: $3,077,409,131 in the October 2021 data and $4,681,919,861 in the October 2026 data, up 52%.
Total employees: 1 in October 2021 and 1 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $4,119,965,494 to $4,681,919,861 (+14%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Clearwater Management Co., Inc. (CRD 105307): Form ADV filing data as of October 2026.