# Clifford Swan Investment Counselors

> Clifford Swan Investment Counselors is an SEC-registered investment advisory firm in Pasadena, CA, registered since 1999, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated February 10, 2026.

- CRD: 108033
- Filed as: CLIFFORD SWAN INVESTMENT COUNSELORS
- Legal name: Clifford Swan Investment Counsel LLC
- Also doing business as: CLIFFORD SWAN, CLIFFORD SWAN INVESTMENT COUNSEL
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Pasadena, CA
- Filing period: October 2026
- Form ADV filing dated: February 10, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/108033
- AdvisorCensus page: https://advisorcensus.com/firm/clifford-swan-investment-counselors-pasadena-ca-108033

## Quick answers

**How is Clifford Swan Investment Counselors compensated?**
On its Form ADV (Item 5.E, October 2026), Clifford Swan Investment Counselors reports these compensation arrangements: a percentage of assets under its management; hourly charges; fixed fees (other than subscription fees).

**Where is Clifford Swan Investment Counselors located?**
Clifford Swan Investment Counselors' principal office is in Pasadena, CA, according to its Form ADV.

**Is Clifford Swan Investment Counselors registered with the SEC or a state?**
Clifford Swan Investment Counselors is an SEC-registered investment advisory firm, registered since 1999. Status as filed: Approved. CRD 108033.

**How much does Clifford Swan Investment Counselors manage?**
Clifford Swan Investment Counselors reports $4,482,345,088 in regulatory assets under management in its Form ADV filing dated February 10, 2026 (88% discretionary).

**How have Clifford Swan Investment Counselors' assets and staff changed since 2021?**
In the Form ADV data for Clifford Swan Investment Counselors: Regulatory assets under management: $3,533,971,121 in the October 2021 data and $4,482,345,088 in the October 2026 data, up 27%. Total employees: 29 in October 2021 and 40 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Clifford Swan Investment Counselors serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (588); individuals (other than high net worth individuals) (296); charitable organizations (62).

**Which custodians does Clifford Swan Investment Counselors use?**
Clifford Swan Investment Counselors' most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. as a custodian holding 10% or more of its separately managed account assets.

**Does Clifford Swan Investment Counselors 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/108033

**Does Clifford Swan Investment Counselors state an account minimum?**
Its Form ADV Part 2A brochure dated February 10, 2026 says: "In general, our minimum annual fee structure drives a minimum client relationship size of $1 million in liquid, actively managed assets."

**What changed in Clifford Swan Investment Counselors' recent Form ADV filings?**
In the March 2026 filing data: Employees performing advisory functions went from 15 to 17. Registered or notice-filed in PA.

## From the Form ADV filing

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

### Fees and minimums (Form ADV Part 2A brochure dated February 10, 2026)

- Account minimum: $1,000,000

> In general, our minimum annual fee structure drives a minimum client relationship size of $1 million in liquid, actively managed assets.

- Minimum annual fee: $10,000

> The minimum Investment Counseling Fee is $10,000 per annum (which could be modified under extenuating circumstances).

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

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., 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: $4,482,345,088
- Discretionary: $3,925,252,939
- Non-discretionary: $557,092,149

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 296 | $112,918,146 |
| High net worth individuals | 588 | $3,659,325,702 |
| Banking or thrift institutions | 0 | $0 |
| Investment companies | 0 | $0 |
| Business development companies | 0 | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | 0 | $0 |
| Charitable organizations | 62 | $533,124,557 |
| State or municipal government entities (including government pension plans) | 0 | $0 |
| Other investment advisers | 0 | $0 |
| Insurance companies | 0 | $0 |
| Sovereign wealth funds and foreign official institutions | 0 | $0 |
| Corporations or other businesses not listed above | 24 | $176,976,683 |
| Other | 0 | $0 |

### Advisory services (Item 5.G)
- Financial planning services
- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses (other than small businesses) or institutional clients
- Selection of other advisers (including private fund managers)
- Publication of periodicals or newsletters

### Firm details
- Registered since: 1999 (27 years)
- Employees: 40 total, 17 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AZ, CA, CO, FL, HI, ID, LA, MA, NC, NH, NM, NV, NY, OR, PA, TX, UT, WA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- cliffordswan.com
- LinkedIn @CLIFFORD-SWAN-INVESTMENT-COUNSEL

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $3,533,971,121 | 29 | March 22, 2021 |
| October 2022 | $4,186,718,533 | 30 | March 22, 2022 |
| October 2023 | $3,630,129,062 | 31 | April 10, 2023 |
| October 2024 | $3,848,216,402 | 31 | September 26, 2024 |
| October 2025 | $4,143,559,319 | 33 | July 18, 2025 |
| October 2026 | $4,482,345,088 | 40 | February 10, 2026 |

Regulatory assets under management: $3,533,971,121 in the October 2021 data and $4,482,345,088 in the October 2026 data, up 27%.
Total employees: 29 in October 2021 and 40 in October 2026.

## Changes in the filing (last 12 months)

### March 2026
- Employees performing advisory functions went from 15 to 17.
- Registered or notice-filed in PA.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Clifford Swan Investment Counselors (CRD 108033): Form ADV filing data as of October 2026.