# Gambit Capital Management, LLC

> Gambit Capital Management, LLC is an SEC-registered investment advisory firm, registered since 2025, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated August 3, 2026.

- CRD: 318313
- Filed as: GAMBIT CAPITAL MANAGEMENT, LLC
- Also doing business as: STILL WATER WEALTH MANAGEMENT
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Filing period: October 2026
- Form ADV filing dated: August 3, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/318313
- AdvisorCensus page: https://advisorcensus.com/firm/gambit-capital-management-llc-318313

## Quick answers

**How is Gambit Capital Management, LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Gambit Capital Management, LLC reports these compensation arrangements: a percentage of assets under its management; fixed fees (other than subscription fees).

**How much does Gambit Capital Management, LLC charge?**
Its Form ADV Part 2A brochure dated August 3, 2026 states: Subscription: $1,000 a month (CIO consulting services); Flat fee: $500 to $2,500 (tax preparation services); Flat fee: $300 (initial consultation for financial coaching services); Subscription: $60 a month (financial coaching services). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Is Gambit Capital Management, LLC registered with the SEC or a state?**
Gambit Capital Management, LLC is an SEC-registered investment advisory firm, registered since 2025. Status as filed: Approved. CRD 318313.

**How much does Gambit Capital Management, LLC manage?**
Gambit Capital Management, LLC reports $167,479,471 in regulatory assets under management in its Form ADV filing dated August 3, 2026 (98% discretionary).

**How have Gambit Capital Management, LLC's assets and staff changed since 2025?**
In the Form ADV data for Gambit Capital Management, LLC: Regulatory assets under management: $101,311,686 in the October 2025 data and $167,479,471 in the October 2026 data, up 65%. Total employees: 4 in October 2025 and 6 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Gambit Capital Management, LLC serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (58); high net worth individuals (49).

**Which custodians does Gambit Capital Management, LLC use?**
Gambit Capital Management, LLC's 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 Gambit Capital Management, LLC report any disciplinary disclosures?**
Reports 2 disclosure items on Form ADV Item 11: yes answers to 11.E(2) (self-regulatory organization's finding of a rule violation) and 11.E(4) (self-regulatory organization's expulsion, suspension, bar, or restriction). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/318313

**What changed in Gambit Capital Management, LLC's recent Form ADV filings?**
In the September 2026 filing data: Added the business name Still Water Wealth Management. Added an office in Stillwater, MN. No longer lists an office in Woodbury, MN.

## 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 August 3, 2026)

- Subscription: $1,000 a month (CIO consulting services)

> Flat Fees for CIO consulting services are set at a fixed annual fee rate of $1,000 per month.

- Flat fee: $500 to $2,500 (tax preparation services)

> GCM will assess a flat fee for this service, which typically ranges between $500-$2,500.

- Flat fee: $300 (initial consultation for financial coaching services)

> The initial consultation fee for financial coaching services are charged in advanced at a fixed rate of $300.

- Subscription: $60 a month (financial coaching services)

> Following the initial consultation, financial coaching services are set at a fixed monthly rate of $60 per month.

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: $167,479,471
- Discretionary: $164,278,826
- Non-discretionary: $3,200,645

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 58 | $16,411,661 |
| High net worth individuals | 49 | $148,961,544 |
| Corporations or other businesses not listed above | Fewer than 5 | $2,106,266 |

### Advisory services (Item 5.G)
- Financial planning services
- Portfolio management for individuals and/or small businesses
- Pension consulting services
- Selection of other advisers (including private fund managers)
- Other

### Firm details
- Registered since: 2025 (1 year)
- Employees: 6 total, 6 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AZ, MN, ND, SD, TN, TX, WI
- Disclosures (Item 11): Reports 2 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.E(2): Has a self-regulatory organization or a commodities exchange ever found that the firm or an advisory affiliate was involved in a violation of its rules, other than a minor rule violation under a plan the SEC approved?
- 11.E(4): Has a self-regulatory organization or a commodities exchange ever disciplined the firm or an advisory affiliate by expelling or suspending it from membership, barring or suspending it from association with other members, or otherwise restricting its activities?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/318313

### Other offices (Schedule D, Section 1.F), as of the September 2026 filing
- Stillwater, MN

### Websites listed on Form ADV (Item 1.I)
- gambitcm.com
- open.spotify.com/show/53TYPbZ9C66tjPP2T4aqin
- podcasts.apple.com/us/podcast/the-smo-show/id1752726544
- LinkedIn @gambitcm

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2025 | $101,311,686 | 4 | July 21, 2025 |
| October 2026 | $167,479,471 | 6 | August 3, 2026 |

Regulatory assets under management: $101,311,686 in the October 2025 data and $167,479,471 in the October 2026 data, up 65%.
Total employees: 4 in October 2025 and 6 in October 2026.

## Changes in the filing (last 12 months)

### September 2026
- Added the business name Still Water Wealth Management.
- Added an office in Stillwater, MN.
- No longer lists an office in Woodbury, MN.

### April 2026
- Its Item 11 disclosure answers changed.
- Employees performing advisory functions went from 4 to 6.
- Regulatory assets under management went from $101,311,686 to $167,479,471 (+65%).
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Gambit Capital Management, LLC (CRD 318313): Form ADV filing data as of October 2026.