# Innealta Capital

> Innealta Capital is an SEC-registered investment advisory firm, registered since 2018, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated April 2, 2026.

- CRD: 292158
- Filed as: INNEALTA CAPITAL
- Legal name: Innealta Capital, LLC
- Also doing business as: ACCLIVITY INVESTMENT RESEARCH
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Filing period: October 2026
- Form ADV filing dated: April 2, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/292158
- AdvisorCensus page: https://advisorcensus.com/firm/innealta-capital-292158

## Quick answers

**How is Innealta Capital compensated?**
On its Form ADV (Item 5.E, October 2026), Innealta Capital reports these compensation arrangements: a percentage of assets under its management.

**How much does Innealta Capital charge?**
Its Form ADV Part 2A brochure dated April 2, 2026 states: Asset-based fee: 0.35% to 1% a year (a range, as the brochure states it). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Is Innealta Capital registered with the SEC or a state?**
Innealta Capital is an SEC-registered investment advisory firm, registered since 2018. Status as filed: Approved. CRD 292158.

**How much does Innealta Capital manage?**
Innealta Capital reports $222,447,705 in regulatory assets under management in its Form ADV filing dated April 2, 2026 (100% discretionary).

**How have Innealta Capital's assets and staff changed since 2021?**
In the Form ADV data for Innealta Capital: Regulatory assets under management: $239,048,939 in the October 2021 data and $222,447,705 in the October 2026 data, down 7%. Total employees: 10 in October 2021 and 4 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Innealta Capital serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (73); corporations or other businesses not listed above (24); high net worth individuals (17).

**Which custodians does Innealta Capital use?**
Innealta Capital's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. and US Bank as custodians holding 10% or more of its separately managed account assets.

**Does Innealta Capital 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/292158

**What changed in Innealta Capital's recent Form ADV filings?**
In the March 2026 filing data: Regulatory assets under management went from $258,841,573 to $222,447,705 (-14%). No longer lists an office in Austin, TX. 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

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

- Asset-based fee: 0.35% to 1% a year (a range, as the brochure states it)

> Innealta receives a management fee (accrued daily) that range from 0.35% to 1.00% annually and payable monthly in arrears from each respective Fund.

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.
- US Bank

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: $222,447,705
- Discretionary: $222,447,705
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 73 | $12,779,563 |
| High net worth individuals | 17 | $9,190,638 |
| Investment companies | 3 | $184,531,605 |
| Corporations or other businesses not listed above | 24 | $15,945,899 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Portfolio management for investment companies (and business development companies)
- Portfolio management for businesses (other than small businesses) or institutional clients

### Firm details
- Registered since: 2018 (8 years)
- Employees: 4 total, 4 performing advisory functions
- Wrap fee program participation: Yes
- States registered or notice-filed: CO, MN, TX
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- acclivityfunds.com
- acclivityresearch.com
- innealtacapital.com
- innealtafunds.com
- LinkedIn @acclivity-investment-research
- LinkedIn @innealta-capital
- YouTube @UCzXua-4Ihp6B08niQNBDwgg

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $239,048,939 | 10 | March 24, 2021 |
| October 2022 | $255,558,240 | 13 | September 9, 2022 |
| October 2023 | $286,210,701 | 17 | March 28, 2023 |
| October 2024 | $305,046,819 | 10 | March 29, 2024 |
| October 2025 | $258,841,573 | 6 | March 25, 2025 |
| October 2026 | $222,447,705 | 4 | April 2, 2026 |

Regulatory assets under management: $239,048,939 in the October 2021 data and $222,447,705 in the October 2026 data, down 7%.
Total employees: 10 in October 2021 and 4 in October 2026.

## Changes in the filing (last 12 months)

### March 2026
- Regulatory assets under management went from $258,841,573 to $222,447,705 (-14%).
- No longer lists an office in Austin, TX.
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Innealta Capital (CRD 292158): Form ADV filing data as of October 2026.