# 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.

- CRD: 331449
- Filed as: THISTLE CREEK CAPITAL, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Lehi, UT
- Filing period: October 2026
- Form ADV filing dated: March 26, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/331449
- AdvisorCensus page: https://advisorcensus.com/firm/thistle-creek-capital-llc-lehi-ut-331449

## Quick answers

**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

### Compensation (Item 5.E)
- Performance-based fees
- Other

### Fees and minimums (Form ADV Part 2A brochure dated March 26, 2026)

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

> 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 brochure. Fees can differ by service and may be negotiable.

### Regulatory assets under management (Item 5.F)
- Total: $160,988,324
- Discretionary: $160,988,324
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 1 | $160,988,324 |

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

### Firm details
- Registered since: 2025 (1 year)
- Employees: 6 total, 6 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: UT
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- thistlecreek.com
- LinkedIn @thistle-creek-capital

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2024 | Not reported | Not reported | June 26, 2024 |
| October 2025 | $183,632,754 | 6 | January 10, 2025 |
| October 2026 | $160,988,324 | 6 | March 26, 2026 |

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.

## Changes in the filing (last 12 months)

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

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Thistle Creek Capital, LLC (CRD 331449): Form ADV filing data as of October 2026.