# Polen Capital CLO Management, LLC

> Polen Capital CLO Management, LLC is an SEC-registered investment advisory firm in Waltham, MA, registered since 2024, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated March 26, 2026.

- CRD: 330470
- Filed as: POLEN CAPITAL CLO MANAGEMENT, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Waltham, MA
- Filing period: October 2026
- Form ADV filing dated: March 26, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/330470
- AdvisorCensus page: https://advisorcensus.com/firm/polen-capital-clo-management-llc-waltham-ma-330470

## Quick answers

**How is Polen Capital CLO Management, LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Polen Capital CLO Management, LLC reports these compensation arrangements: a percentage of assets under its management; performance-based fees. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Polen Capital CLO Management, LLC located?**
Polen Capital CLO Management, LLC's principal office is in Waltham, MA, according to its Form ADV; the April 2026 filing also lists 2 other offices (Schedule D, Section 1.F).

**Is Polen Capital CLO Management, LLC registered with the SEC or a state?**
Polen Capital CLO Management, LLC is an SEC-registered investment advisory firm, registered since 2024. Status as filed: Approved. CRD 330470.

**How much does Polen Capital CLO Management, LLC manage?**
Polen Capital CLO Management, LLC reports $808,397,779 in regulatory assets under management in its Form ADV filing dated March 26, 2026 (100% discretionary).

**How have Polen Capital CLO Management, LLC's assets and staff changed since 2024?**
In the Form ADV data for Polen Capital CLO Management, LLC: Regulatory assets under management: $157,236,974 in the October 2025 data and $808,397,779 in the October 2026 data, up 414%. Total employees: 208 in October 2024 and 46 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Polen Capital CLO Management, LLC serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (2).

**Does Polen Capital CLO 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/330470

**What changed in Polen Capital CLO Management, LLC's recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $157,236,974 to $808,397,779 (+414%). Employees performing advisory functions went from 23 to 28. Added an office in London.

## From the Form ADV filing

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

### Regulatory assets under management (Item 5.F)
- Total: $808,397,779
- Discretionary: $808,397,779
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | Not reported |
| High net worth individuals | 0 | Not reported |
| Banking or thrift institutions | 0 | Not reported |
| Investment companies | 0 | Not reported |
| Business development companies | 0 | Not reported |
| Pooled investment vehicles (other than investment companies and business development companies) | 2 | $808,397,779 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 0 | Not reported |
| Charitable organizations | 0 | Not reported |
| State or municipal government entities (including government pension plans) | 0 | Not reported |
| Other investment advisers | 0 | Not reported |
| Insurance companies | 0 | Not reported |
| Sovereign wealth funds and foreign official institutions | 0 | Not reported |
| Corporations or other businesses not listed above | 0 | Not reported |

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

### Firm details
- Registered since: 2024 (2 years)
- Employees: 46 total, 28 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: DE, MA
- 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
- Boca Raton, FL
- London

### Websites listed on Form ADV (Item 1.I)
- glassdoor.com/Overview/Working-at-Polen-Capital-EI_IE3242095.11,24.htm
- polencapital.com
- vimeo.com/POLENCAPITAL
- LinkedIn @polen-capital-management
- YouTube @UCi9uXI1OPFDCXPNeALVJEoA

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2024 | Not reported | 208 | March 14, 2024 |
| October 2025 | $157,236,974 | 48 | March 27, 2025 |
| October 2026 | $808,397,779 | 46 | March 26, 2026 |

Regulatory assets under management: $157,236,974 in the October 2025 data and $808,397,779 in the October 2026 data, up 414%.
Total employees: 208 in October 2024 and 46 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $157,236,974 to $808,397,779 (+414%).
- Employees performing advisory functions went from 23 to 28.
- Added an office in London.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Polen Capital CLO Management, LLC (CRD 330470): Form ADV filing data as of October 2026.