{"url":"https://nivawealth.com/firms/clearwater-capital-management-115283","iapdUrl":"https://adviserinfo.sec.gov/firm/summary/115283","regulatoryAum":139300000,"crd":"115283","adviserRoster":{"asOf":"2026-10-09","items":[{"crd":"871078","suffix":null,"lastName":"STRUTHERS","firstName":"RICHARD","middleName":"EDWARD"}],"total":1,"loadedAt":"2026-10-10T00:20:19.761928+00:00","sourceUrl":"https://reports.adviserinfo.sec.gov/reports/CompilationReports/IA_INDVL_Feed_10_09_2026.xml.zip"},"secFileNumber":"801-134477","legalName":"Clearwater Capital Management LLC","displayName":"Clearwater Capital Management","slug":"clearwater-capital-management-115283","website":null,"classification":{"segment":"individuals","segmentLabel":"Wealth management","type":"independent_wealth_manager","typeLabel":"RIA","feeDisclosure":"full"},"founded":null,"organization":"Delaware limited liability company","fiscalYearEnd":"December","headquarters":{"street":"","city":"","state":"","stateName":"","country":"","postalCode":null},"tradeNames":[],"registration":{"secApproved":"13 November 2025","noticeFilings":null,"latestNoticeFiling":null},"wealthAumPerClient":7738888.888888889,"staff":{"employees":1,"advisory":1,"brokerDealerReps":0,"insuranceAgents":0,"promoters":0},"aum":{"regulatory":139300000,"discretionary":128900000,"discretionaryAccounts":17,"nonDiscretionary":10400000,"nonDiscretionaryAccounts":1,"wrapProgram":null,"nonUsClientsPct":0,"nonAumClients":0},"clientTypes":[{"label":"High-net-worth individuals","clients":18,"regulatoryAum":139300000}],"feePrograms":[{"role":"main","program":"Advisory Fee","feeBasis":"marginal","fee_tiers":[{"to":3000000,"pct":0.75,"from":0},{"to":10000000,"pct":0.6,"from":3000000},{"to":null,"pct":0.5,"from":10000000}],"sourceUrl":"https://files.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=1013249","versionId":1013249,"ratePeriod":"annual","fee_billing":"arrears","submittedOn":"2026-03-02","documentName":"FORM ADV PART 2A AND 2B","fee_rate_low":0.5,"fee_rate_high":0.75,"fee_negotiable":null,"minimum_account":1000000,"feeMinimumPeriod":null,"fee_minimum_annual":null}],"brochureCoverage":{"scope":"sec_inventory","status":"reviewed","checkedAt":"2026-10-22T12:20:17.342901+00:00","documents":[{"name":"FORM ADV PART 2A AND 2B","status":"read","sourceUrl":"https://files.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=1013249","versionId":1013249,"submittedOn":"2026-03-02"}]},"custodians":[{"name":"Charles Schwab & Co., Inc.","shortName":"Charles Schwab","location":"Phoenix, AZ","smaAssets":132200000}],"custodyNote":"Clearwater Capital Management does not have custody of client assets.","otherCustodians":[],"leadership":[{"name":"Richard Struthers","title":"Chairman, CEO and Chief Compliance Officer","crd":"871078"}],"ownership":[{"label":"Richard Struthers","detail":"Chairman, ceo and chief compliance officer in the 75% or more ownership band and a control person, since February 1998."}],"branchOffices":null,"filedOffices":{"otherThanPrincipal":2,"privateResidences":2},"listedOfficeAddresses":1,"foreignOffices":[],"officesByState":[],"advFacts":{"source":{"file":"ia100226.zip","asOf":"2 October 2026"},"telephone":"612-860-8489","stateRegisteredReps":1,"otherAdviserReps":0,"compensation":["A percentage of assets under management","Fixed fees (other than subscription fees)"],"activities":["Portfolio management for individuals and/or small businesses"],"financialPlanningClients":null,"assetMix":[{"label":"Exchange-traded equity securities","percent":94},{"label":"U.S. government/agency bonds","percent":1},{"label":"U.S. state and local bonds","percent":1},{"label":"Investment grade corporate bonds","percent":1},{"label":"Cash and cash equivalents","percent":3}],"privateFunds":0},"sources":{"adv1FilingDate":"2 March 2026","adv1Url":"https://reports.adviserinfo.sec.gov/reports/ADV/115283/PDF/115283.pdf","brochureDate":"2 March 2026","brochureUrl":"https://files.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=1013249","iapdCompiledDate":null,"retrievedDate":"15 October 2026","retrievedOn":"2026-10-15","updatedOn":"2026-10-22","holdingsUpdatedOn":"2026-10-21","adv1Pages":{},"brochurePages":{}},"otherBusiness":[],"faq":[{"question":"How many clients does Clearwater Capital Management have?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"What services does Clearwater Capital Management offer?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"How much does Clearwater Capital Management charge?","answer":"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","sourceRef":{"doc":"brochure","section":"fees"}},{"question":"Which custodians does Clearwater Capital Management use?","answer":"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","sourceRef":{"doc":"adv1","section":"custodians"}},{"question":"How many financial advisors does Clearwater Capital Management have?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"What does Clearwater Capital Management invest in?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"Does Clearwater Capital Management have a minimum investment?","answer":"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","sourceRef":{"doc":"brochure","section":"fees"}},{"question":"Who owns Clearwater Capital Management?","answer":"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","sourceRef":{"doc":"adv1","section":"scheduleA"}},{"question":"How does Clearwater Capital Management get paid?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"How do I contact Clearwater Capital Management?","answer":"Its phone number is 612-860-8489.","source":"Form ADV Part 1A, Item 1.F, filed 2 March 2026","sourceRef":{"doc":"adv1","section":"offices"}}],"holdings":null,"notice":"Compiled from public SEC Form ADV filings on the dates in `sources`. Facts as filed; not a rating, ranking, or recommendation. Niva is not affiliated with this firm. Disciplinary history is deliberately not included here or on the page; the SEC publishes the complete record at the `iapdUrl` above."}