# Cloverlay Investment Management, LLC

> Cloverlay Investment Management, LLC is an SEC-registered investment advisory firm in Conshohocken, PA, registered since 2015, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated August 28, 2026.

- CRD: 277170
- Filed as: CLOVERLAY INVESTMENT MANAGEMENT, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Conshohocken, PA
- Filing period: October 2026
- Form ADV filing dated: August 28, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/277170
- AdvisorCensus page: https://advisorcensus.com/firm/cloverlay-investment-management-llc-conshohocken-pa-277170

## Quick answers

**How is Cloverlay Investment Management, LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Cloverlay Investment Management, LLC reports these compensation arrangements: a percentage of assets under its management; performance-based fees.

**What does Cloverlay Investment Management, LLC's brochure say about its fees?**
Its Form ADV Part 2A brochure dated August 28, 2026 states: Asset-based fee: 0.7% to 1.25% 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 Cloverlay Investment Management, LLC located?**
Cloverlay Investment Management, LLC's principal office is in Conshohocken, PA, according to its Form ADV.

**Is Cloverlay Investment Management, LLC registered with the SEC or a state?**
Cloverlay Investment Management, LLC is an SEC-registered investment advisory firm, registered since 2015. Status as filed: Approved. CRD 277170.

**How much does Cloverlay Investment Management, LLC manage?**
Cloverlay Investment Management, LLC reports $1,830,952,939 in regulatory assets under management in its Form ADV filing dated August 28, 2026 (45% discretionary).

**How have Cloverlay Investment Management, LLC's assets and staff changed since 2021?**
In the Form ADV data for Cloverlay Investment Management, LLC: Regulatory assets under management: $720,808,102 in the October 2021 data and $1,830,952,939 in the October 2026 data, up 154%. Total employees: 12 in October 2021 and 18 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Cloverlay Investment Management, LLC serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (13).

**Does Cloverlay Investment Management, 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/277170

**What changed in Cloverlay Investment Management, LLC's recent Form ADV filings?**
In the September 2026 filing data: Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

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

### Fees and minimums (Form ADV Part 2A brochure dated August 28, 2026)

- Asset-based fee: 0.7% to 1.25% a year (a range, as the brochure states it)

> The commitment-based management fee (the “Management Fee”) is paid to Cloverlay periodically in accordance with the terms of the applicable Fund’s Governing Documents and generally ranges from 0.70% to 1. 25% of either a) commitments or b) net invested capital .

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

### Regulatory assets under management (Item 5.F)
- Total: $1,830,952,939
- Discretionary: $818,045,185
- Non-discretionary: $1,012,907,754

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 13 | $1,830,952,939 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)

### Firm details
- Registered since: 2015 (11 years)
- Employees: 18 total, 10 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: PA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

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

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $720,808,102 | 12 | March 26, 2021 |
| October 2022 | $1,035,934,060 | 13 | March 25, 2022 |
| October 2023 | $1,419,912,769 | 15 | July 21, 2023 |
| October 2024 | $1,471,292,466 | 16 | March 25, 2024 |
| October 2025 | $1,572,922,124 | 18 | March 27, 2025 |
| October 2026 | $1,830,952,939 | 18 | August 28, 2026 |

Regulatory assets under management: $720,808,102 in the October 2021 data and $1,830,952,939 in the October 2026 data, up 154%.
Total employees: 12 in October 2021 and 18 in October 2026.

## Changes in the filing (last 12 months)

### September 2026
- Updated its list of owners and control persons (Schedule A).

### April 2026
- Regulatory assets under management went from $1,572,922,124 to $1,830,952,939 (+16%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Cloverlay Investment Management, LLC (CRD 277170): Form ADV filing data as of October 2026.