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Clearwater Capital Management

Wealth managementRIA

CRD 115283Updated

Clearwater Capital Management is an investment adviser, registered with the SEC since 2025. It provides investment management. Its clients include high-net-worth individuals. Its regulatory assets under management total $139 million, as filed on 2 March 2026.

18
Clients
$7.74M
AUM per individual client
1
Advisory staff
3
Offices
0.50–0.75%
Annual fee

From Form ADV filed 2 March 2026SEC record

Services and clients

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.

Clients and assets by client type
Clients18 clients
Assets$139M
Client typeClientsAssets
High-net-worth individuals100%100%
Client breakdown and activity details
High-net-worth individuals
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

Fees and minimums

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.

$0–$3M0.75%
$3M–$10M0.60%
$10M and above0.50%
Fee details and sources

Ownership and people

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.

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Staff

  • 1 employee
  • 1 in advisory functions
  • 1 state-registered rep
Who owns the firm
Clearwater Capital Management LLC· the adviser
  • Richard Struthers

    Control person · since February 1998

    Owns 75% or more of Clearwater Capital Management LLC

Offices and registration details

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
SEC file
801-134477
Structure
Delaware LLC
Fiscal year end
December

Custodians

Clearwater Capital Management’s named custodian for separately managed accounts is Charles Schwab ($132M). Clearwater Capital Management does not have custody of client assets.

Reported separately managed account assets by custodian
$132M
named custodians
  • Charles SchwabCharles Schwab & Co., Inc. · Phoenix, AZ · $132M100%

Investments and reported holdings

At year end, Clearwater Capital Management’s separately managed accounts were mostly in stocks (94%).

What the accounts hold

Separately managed account assets by class, year end
  • Stocks94%
  • Bonds3%
    • U.S. government and agency bonds1%
    • State and local bonds1%
    • Investment grade corporate bonds1%
  • Cash3%

Common questions

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.

Source: FORM ADV PART 2A AND 2B, filed 2 March 2026

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.

Source: FORM ADV PART 2A AND 2B, filed 2 March 2026

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.

Source: Form ADV Part 1A, Item 1.F, filed 2 March 2026

Sources and methodology

  1. Form ADV Part 1A, amendment filed 2 March 2026. Items 1, 5, 9, 11 and Schedules A, B and D.
  2. FORM ADV PART 2A AND 2B, submitted 2 March 2026.
  3. IAPD firm record, CRD 115283.
  4. SEC investment adviser representative register, as of 9 October 2026; loaded 10 October 2026.

Retrieved 15 October 2026. All are published by the SEC and may have been amended since. Disciplinary history is not yet shown here. The SEC publishes the complete record, including any disciplinary events, and it is the authoritative place to check one.

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