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AdvisorCensus / Financial advisors / Utah / Provo / Thistle Creek Capital, LLC

Thistle Creek Capital, LLC

Lehi, UTSEC-registered investment adviserCRD 331449

Filed as THISTLE CREEK CAPITAL, LLC

Thistle Creek Capital, LLC is an SEC-registered investment advisory firm in Lehi, UT, registered since 2025, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated March 26, 2026.

1 year
registered since 2025
$160,988,324
assets under management
2 arrangements
Performance-based, Other
None
disclosure items (Item 11)

Quick answers

From the filing

How is Thistle Creek Capital, LLC compensated?

On its Form ADV (Item 5.E, October 2026), Thistle Creek Capital, LLC reports these compensation arrangements: performance-based fees; other.

Where is Thistle Creek Capital, LLC located?

Thistle Creek Capital, LLC's principal office is in Lehi, UT, according to its Form ADV.

Is Thistle Creek Capital, LLC registered with the SEC or a state?

Thistle Creek Capital, LLC is an SEC-registered investment advisory firm, registered since 2025. Status as filed: Approved. CRD 331449.

How much does Thistle Creek Capital, LLC manage?

Thistle Creek Capital, LLC reports $160,988,324 in regulatory assets under management in its Form ADV filing dated March 26, 2026 (100% discretionary).

How have Thistle Creek Capital, LLC's assets and staff changed since 2024?

In the Form ADV data for Thistle Creek Capital, LLC: Regulatory assets under management: $183,632,754 in the October 2025 data and $160,988,324 in the October 2026 data, down 12%. Total employees: 6 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 Thistle Creek Capital, LLC serve?

By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (1).

Does Thistle Creek Capital, 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/331449

Does Thistle Creek Capital, LLC state an account minimum?

Its Form ADV Part 2A brochure dated March 26, 2026 says: "The minimum initial subscription to the Fund of a Limited Partner must be at least $500,000, subject to the General Partner’s right to waive this minimum in its sole discretion."

What changed in Thistle Creek Capital, LLC's recent Form ADV filings?

In the April 2026 filing data: Regulatory assets under management went from $183,632,754 to $160,988,324 (-12%).

From the Form ADV filing

Every figure below is as the firm filed it with regulators, as of October 2026.

How the firm is compensated

Item 5.E
  • Performance-based fees
  • Other

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

Fees and minimums

Form ADV Part 2A

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

The brochure's wording
The minimum initial subscription to the Fund of a Limited Partner must be at least $500,000, subject to the General Partner’s right to waive this minimum in its sole discretion.

As stated in the firm's Form ADV Part 2A brochure dated March 26, 2026. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site

Regulatory assets under management

Item 5.F
$160,988,324

$160,988,324 as of October 2026, filing dated March 26, 2026.

Discretionary: $160,988,324.Non-discretionary: $0.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

Who the firm serves

Item 5.D
Pooled investment vehicles (other than investment companies and business development companies)
Clients 1 Assets $160,988,324 (100%)

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

Advisory services

Item 5.G
  • Portfolio management for pooled investment vehicles (other than investment companies)

Registration and firm details

Items 1, 2, 5
Registration
SEC-registered investment adviser. Status as filed: Approved.
Registered since
2025 (1 year)
Employees
Total: 6. Performing investment advisory functions: 6.
Wrap fee program participation
No.
States registered or notice-filed
1 state or jurisdiction
UT

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

Disclosures

Item 11

None Reports no disclosure items on Form ADV Item 11. View on IAPD.

Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures

Assets and staff over time

Items 5.A, 5.F
Not reported 2024 $184M 2025 $161M 2026
Data periodAssets under managementEmployeesFiling dated
October 2026$160,988,3246March 26, 2026
October 2025$183,632,7546January 10, 2025
October 2024Not reportedNot reportedJune 26, 2024

Regulatory assets under management: $183,632,754 in the October 2025 data and $160,988,324 in the October 2026 data, down 12%.

Total employees: 6 in October 2025 and 6 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

Changes in the filing

Last 12 months
  1. April 2026
    • Regulatory assets under management went from $183,632,754 to $160,988,324 (-12%).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.

Websites listed on Form ADV

Item 1.I
thistlecreek.com

Source: Form ADV, as of October 2026. Values appear as filed; a value the firm did not report is shown as "Not reported."

Cite this page

AdvisorCensus. Thistle Creek Capital, LLC (CRD 331449): Form ADV filing data as of October 2026.
https://advisorcensus.com/firm/thistle-creek-capital-llc-lehi-ut-331449