# Tailwater Capital

> Tailwater Capital is an SEC-registered investment advisory firm in Dallas, TX, registered since 2013, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated June 12, 2026.

- CRD: 167240
- Filed as: TAILWATER CAPITAL
- Legal name: TW-IM, LLC
- Also doing business as: TAILWATER
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Dallas, TX
- Filing period: October 2026
- Form ADV filing dated: June 12, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/167240
- AdvisorCensus page: https://advisorcensus.com/firm/tailwater-capital-dallas-tx-167240

## Quick answers

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

**Where is Tailwater Capital located?**
Tailwater Capital's principal office is in Dallas, TX, according to its Form ADV; the July 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Tailwater Capital registered with the SEC or a state?**
Tailwater Capital is an SEC-registered investment advisory firm, registered since 2013. Status as filed: Approved. CRD 167240.

**How much does Tailwater Capital manage?**
Tailwater Capital reports $3,974,046,326 in regulatory assets under management in its Form ADV filing dated June 12, 2026 (83% discretionary).

**How have Tailwater Capital's assets and staff changed since 2021?**
In the Form ADV data for Tailwater Capital: Regulatory assets under management: $2,821,492,331 in the October 2021 data and $3,974,046,326 in the October 2026 data, up 41%. Total employees: 26 in October 2021 and 46 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Tailwater Capital serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (21).

**Does Tailwater 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/167240

**Does Tailwater Capital state an account minimum?**
Its Form ADV Part 2A brochure dated June 12, 2026 says: "The Funds generally have no minimum investment amount for third- party investors"

**What changed in Tailwater Capital's recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $3,397,731,345 to $3,974,046,326 (+17%).

## 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 June 12, 2026)

- Account minimum: None

> The Funds generally have no minimum investment amount for third- party investors

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

### Regulatory assets under management (Item 5.F)
- Total: $3,974,046,326
- Discretionary: $3,314,298,688
- Non-discretionary: $659,747,638

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 21 | $3,974,046,326 |

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

### Firm details
- Registered since: 2013 (13 years)
- Employees: 46 total, 27 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: TX
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the July 2026 filing
- The Woodlands, TX

### Websites listed on Form ADV (Item 1.I)
- tailwatercapital.com
- LinkedIn @TAILWATER-CAPITAL-LLC

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $2,821,492,331 | 26 | July 7, 2021 |
| October 2022 | $3,379,624,080 | 43 | March 31, 2022 |
| October 2023 | $3,318,460,315 | 41 | March 31, 2023 |
| October 2024 | $3,125,915,284 | 48 | March 28, 2024 |
| October 2025 | $3,397,731,345 | 46 | March 31, 2025 |
| October 2026 | $3,974,046,326 | 46 | June 12, 2026 |

Regulatory assets under management: $2,821,492,331 in the October 2021 data and $3,974,046,326 in the October 2026 data, up 41%.
Total employees: 26 in October 2021 and 46 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $3,397,731,345 to $3,974,046,326 (+17%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Tailwater Capital (CRD 167240): Form ADV filing data as of October 2026.