# Shearwater Capital

> Shearwater Capital is an SEC-registered investment advisory firm in Denver, CO, registered since 2013, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated March 17, 2026.

- CRD: 115399
- Filed as: SHEARWATER CAPITAL
- Legal name: Shearwater Capital, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Denver, CO
- Filing period: October 2026
- Form ADV filing dated: March 17, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/115399
- AdvisorCensus page: https://advisorcensus.com/firm/shearwater-capital-denver-co-115399

## Quick answers

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

**How much does Shearwater Capital charge?**
Its Form ADV Part 2A brochure dated March 17, 2026 states: Up to $100,000: 0.85% a year; $100,000 to $250,000: 0.75% a year; $250,000 to $500,000: 0.65% a year; $500,000 to $1,000,000: 0.55% a year; $1,000,000 to $2,500,000: 0.45% a year; $2,500,000 to $5,000,000: 0.35% a year; $5,000,000 to $10,000,000: 0.25% a year; Above $10,000,000: 0.15% a year. Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Shearwater Capital located?**
Shearwater Capital's principal office is in Denver, CO, according to its Form ADV.

**Is Shearwater Capital registered with the SEC or a state?**
Shearwater Capital is an SEC-registered investment advisory firm, registered since 2013. Status as filed: Approved. CRD 115399.

**How much does Shearwater Capital manage?**
Shearwater Capital reports $427,265,198 in regulatory assets under management in its Form ADV filing dated March 17, 2026 (100% discretionary).

**How have Shearwater Capital's assets and staff changed since 2021?**
In the Form ADV data for Shearwater Capital: Regulatory assets under management: $308,633,087 in the October 2021 data and $427,265,198 in the October 2026 data, up 38%. Total employees: 1 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 Shearwater Capital serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (120); individuals (other than high net worth individuals) (60).

**Which custodians does Shearwater Capital use?**
Shearwater Capital'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 Shearwater 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/115399

**Does Shearwater Capital state an account minimum?**
Its Form ADV Part 2A brochure dated March 17, 2026 says: "The minimum account size for a new client is $500,000; however, this requirement can be waived at the discretion of the company Principals."

**What changed in Shearwater Capital's recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $348,161,272 to $427,265,198 (+23%). Registered or notice-filed in PA.

## 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 March 17, 2026)

- Up to $100,000: 0.85% a year
- $100,000 to $250,000: 0.75% a year
- $250,000 to $500,000: 0.65% a year
- $500,000 to $1,000,000: 0.55% a year
- $1,000,000 to $2,500,000: 0.45% a year
- $2,500,000 to $5,000,000: 0.35% a year
- $5,000,000 to $10,000,000: 0.25% a year
- Above $10,000,000: 0.15% a year

> Fees are charged quarterly, in arrears for the prior quarter, based on the following annualized fee schedule: Account Size Annual Fee <$100,000 0.85% $100,000-$250,000 0.75% $250,000-$500,000 0.65% $500,000-$1,000,000 0.55% $1,000,000-$2,500,000 0.45% $2,500,000-$5,000,000 0.35% $5,000,000-$10,000,000 0.25% > $10,000,000 0.15%

- Account minimum: $500,000 (the brochure says it may be waived or negotiated)

> The minimum account size for a new client is $500,000; however, this requirement can be waived at the discretion of the company Principals.

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: $427,265,198
- Discretionary: $426,037,096
- Non-discretionary: $1,228,102

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 60 | $18,831,136 |
| High net worth individuals | 120 | $402,065,120 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | Fewer than 5 | $6,368,942 |

### 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
- Educational seminars/workshops

### Firm details
- Registered since: 2013 (13 years)
- Employees: 4 total, 4 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AZ, CA, CO, FL, IL, MO, NY, PA, TX, WA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- shearcap.com
- shearwatercapital.com
- Facebook @SHEARWATERCAPITAL
- LinkedIn @jeffrey-brown-cfp
- X @ShearwaterCap

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $308,633,087 | 1 | February 18, 2021 |
| October 2022 | $306,023,575 | 5 | February 2, 2022 |
| October 2023 | $279,763,823 | 4 | March 18, 2023 |
| October 2024 | $306,864,566 | 4 | March 22, 2024 |
| October 2025 | $348,161,272 | 4 | February 7, 2025 |
| October 2026 | $427,265,198 | 4 | March 17, 2026 |

Regulatory assets under management: $308,633,087 in the October 2021 data and $427,265,198 in the October 2026 data, up 38%.
Total employees: 1 in October 2021 and 4 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $348,161,272 to $427,265,198 (+23%).
- Registered or notice-filed in PA.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Shearwater Capital (CRD 115399): Form ADV filing data as of October 2026.