Clearwater Capital Management provides portfolio management for individuals and small businesses.
Clearwater Capital Management reports 18 high-net-worth individuals. Of its assets, 92.5% ($129M across 17 accounts) are managed with discretion; $10.4M across 1 account is not.
| Client type | Clients | Assets |
|---|---|---|
| High-net-worth individuals | 100% | 100% |
Client breakdown and activity details
| Client type | Clients | Regulatory AUM | AUM share | Avg. per client |
|---|---|---|---|---|
| High-net-worth individuals | 18 | $139M | 100.0% | $7.74M |
| Total | 18 | $139M | 100% | $7.74M |
- Clients
- 18
- Regulatory AUM
- $139M
- AUM share
- 100.0%
- Avg. per client
- $7.74M
Total
- Clients
- 18
- Regulatory AUM
- $139M
- AUM share
- 100%
- Avg. per client
- $7.74M
- Clients outside the U.S.
- 0%
- Clients advised without assets under management last fiscal year
- 0
- Private funds advised
- 0
Clearwater Capital Management charges 0.50%–0.75% a year for its Advisory Fee. Each asset band is charged at its own rate. The fee is billed in arrears and requires an account of at least $1,000,000.
| Asset band | Annual rate |
|---|---|
| $0–$3M | 0.75% |
| $3M–$10M | 0.60% |
| $10M and above | 0.50% |
Fee details and sources
Richard Struthers owns 75% or more of Clearwater Capital Management. The leadership team of Clearwater Capital Management includes Chief Compliance Officer Richard Struthers. It has 1 employee.
Staff
- 1 employee
- 1 in advisory functions
- 1 state-registered rep
- Owns 75% or more of Clearwater Capital Management LLC
Richard Struthers
Control person · since February 1998
Besides its headquarters, Clearwater Capital Management has 2 offices (2 private residences, listed without an address), with 1 listed address with no US state reported.
Contact and registration details
- Legal name
- Clearwater Capital Management LLC
- Headquarters
- Not reported
- Website
- Not reported
- Phone
- 612-860-8489
- SEC file
- 801-134477
- Structure
- Delaware LLC
- Fiscal year end
- December
Clearwater Capital Management’s named custodian for separately managed accounts is Charles Schwab ($132M). Clearwater Capital Management does not have custody of client assets.
- Charles SchwabCharles Schwab & Co., Inc. · Phoenix, AZ · $132M100%
At year end, Clearwater Capital Management’s separately managed accounts were mostly in stocks (94%).
What the accounts hold
- Stocks94%
- Bonds3%
- U.S. government and agency bonds1%
- State and local bonds1%
- Investment grade corporate bonds1%
- Cash3%
How many clients does Clearwater Capital Management have?
Clearwater Capital Management has 18 clients and manages $139 million for them, as of March 2026. They include 18 high-net-worth individuals.
Source: Form ADV Part 1A, Items 5.D and 5.F, filed 2 March 2026
What services does Clearwater Capital Management offer?
Clearwater Capital Management provides portfolio management for individuals and small businesses.
Source: Form ADV Part 1A, Item 5.G, from the SEC's 2 October 2026 data file
How much does Clearwater Capital Management charge?
Clearwater Capital Management charges 0.50%–0.75% a year for its Advisory Fee. Each asset band is charged at its own rate. The fee is billed in arrears and requires an account of at least $1,000,000.
Which custodians does Clearwater Capital Management use?
Clearwater Capital Management’s separately managed account assets are held at Charles Schwab & Co., Inc. (Phoenix, AZ), with $132M. Only custodians holding at least a tenth of those assets are named.
Source: Form ADV Part 1A, Schedule D, Section 5.K.(3), filed 2 March 2026
How many financial advisors does Clearwater Capital Management have?
Clearwater Capital Management has 1 investment adviser representative registered with state securities authorities, out of 1 employees, and 1 perform investment advisory functions. None are registered representatives of a broker-dealer or licensed insurance agents.
Source: Form ADV Part 1A, Items 5.A and 5.B, from the SEC's 2 October 2026 data file
What does Clearwater Capital Management invest in?
At the end of its last fiscal year, Clearwater Capital Management’s separately managed accounts held 94% exchange-traded equities, 3% cash and equivalents, 1% U.S. government and agency bonds, 1% state and local bonds and 1% investment grade corporate bonds.
Source: Form ADV Part 1A, Items 5.K.(1) and 7.B, from the SEC's 2 October 2026 data file
Does Clearwater Capital Management have a minimum investment?
Yes, Clearwater Capital Management’s minimum account size for its Advisory Fee is $1M.
Who owns Clearwater Capital Management?
Clearwater Capital Management’s direct owner is Richard Struthers (75% or more).
Source: Form ADV Part 1A, Schedules A and B, filed 2 March 2026
How does Clearwater Capital Management get paid?
Clearwater Capital Management is paid through a percentage of assets under management and fixed fees. Its Form ADV lists no commissions or performance-based fees among how it is paid.
Source: Form ADV Part 1A, Item 5.E, from the SEC's 2 October 2026 data file
How do I contact Clearwater Capital Management?
Its phone number is 612-860-8489.