Investment adviser · CRD 105307

CLEARWATER MANAGEMENT CO., INC.

Investment adviser filing (IA)

ST PAUL, MN, United States · Form ADV filed Mar 17, 2026

Regulatory AUM: $4.68B
Client accounts: 13
Employees: 1
Advisory professionals: 1

Who they report serving

Form ADV · Item 5.D

Client types and their share of reported regulatory assets.

Client type	Clients	Regulatory assets	Share of AUM
Investment companies	4	$3,900,605,254	83.3%
Pooled investment vehicles	9	$781,314,607	16.7%

Filing source

Form ADV 2043113 · Mar 17, 2026 · Item 5.D

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

Private funds & service providers

10 Private funds

The count excludes feeder funds. Funds in the latest filing appear first, ordered by reported gross assets. Earlier funds retain their last reported values.

CLEARWATER DIVERSIFYING STRATEGIES FUND, LLCHedge Fund · Last reported Mar 17, 2026$181MGross asset value

Form D fundraising filings

Clearwater Diversifying Strategies Fund, LLC

Feeder funds

CLEARWATER DIVERSIFYING STRATEGIES OFFSHORE FUND LTD.

Fund administrator NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Investor statements: No (provided to no investors) Related to adviser: No

Auditor KPMG LLP MINNEAPOLIS, Minnesota, United States

Custodian NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Related to adviser: No

Marketer FIDUCIARY COUNSELLING INC ST. PAUL, Minnesota, United States Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

KPMG LLP
PCAOB 185

FIDUCIARY COUNSELLING INC
CRD 104753 · SEC 801-4158

Fund details & source

Fund ID: 805-4666639533
Reported beneficial owners: 66
Minimum commitment: $300K
Form D file number: 021-391798

Form ADV 2043113 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

CLEARWATER PRIVATE OPPORTUNITY FUND VIII, LLCPrivate Equity Fund · Last reported Mar 17, 2026$122MGross asset value

Form D fundraising filings

Clearwater Private Opportunity Fund VIII, LLC

Fund administrator NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Investor statements: No (provided to no investors) Related to adviser: No

Auditor KPMG LLP MINNEAPOLIS, Minnesota, United States

Custodian NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Related to adviser: No

Marketer FIDUCIARY COUNSELLING INC ST. PAUL, Minnesota, United States Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

KPMG LLP
PCAOB 185

FIDUCIARY COUNSELLING INC
CRD 104753 · SEC 801-4158

Fund details & source

Fund ID: 805-5055087407
Reported beneficial owners: 82
Minimum commitment: $300K
Form D file number: 021-460684

Form ADV 2043113 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

CLEARWATER PRIVATE OPPORTUNITY FUND VI, LLLPPrivate Equity Fund · Last reported Mar 17, 2026$116MGross asset value

Form D fundraising filings

CLEARWATER PRIVATE OPPORTUNITY FUND VI, LLLP

Fund administrator NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Investor statements: No (provided to no investors) Related to adviser: No

Auditor KPMG LLP MINNEAPOLIS, Minnesota, United States

Custodian NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Related to adviser: No

Marketer FIDUCIARY COUNSELLING INC ST. PAUL, Minnesota, United States Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

KPMG LLP
PCAOB 185

FIDUCIARY COUNSELLING INC
CRD 104753 · SEC 801-4158

Fund details & source

Fund ID: 805-6488218823
Reported beneficial owners: 71
Minimum commitment: $150K
Form D file number: 021-296734

Form ADV 2043113 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

CLEARWATER PRIVATE OPPORTUNITY FUND V, LLLPPrivate Equity Fund · Last reported Mar 17, 2026$112MGross asset value

Form D fundraising filings

Clearwater Private Opportunity Fund V, LLLP

Fund administrator U.S. BANK N.A. MILWAUKEE, Wisconsin, United States Investor statements: No (provided to no investors) Related to adviser: No

Auditor KPMG LLP MINNEAPOLIS, Minnesota, United States

Custodian U.S. BANK N.A. MILWAUKEE, Wisconsin, United States Related to adviser: No

Marketer FIDUCIARY COUNSELLING INC ST. PAUL, Minnesota, United States Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

KPMG LLP
PCAOB 185

FIDUCIARY COUNSELLING INC
CRD 104753 · SEC 801-4158

Fund details & source

Fund ID: 805-1929765435
Reported beneficial owners: 71
Minimum commitment: $300K
Form D file number: 021-221739

Form ADV 2043113 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

CLEARWATER PRIVATE OPPORTUNITY FUND VII, LLCPrivate Equity Fund · Last reported Mar 17, 2026$103MGross asset value

Form D fundraising filings

Clearwater Private Opportunity Fund VII, LLC

Fund administrator NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Investor statements: No (provided to no investors) Related to adviser: No

Auditor KPMG LLP MINNEAPOLIS, Minnesota, United States

Custodian NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Related to adviser: No

Marketer FIDUCIARY COUNSELLING INC ST. PAUL, Minnesota, United States Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

KPMG LLP
PCAOB 185

FIDUCIARY COUNSELLING INC
CRD 104753 · SEC 801-4158

Fund details & source

Fund ID: 805-6934680105
Reported beneficial owners: 55
Minimum commitment: $300K
Form D file number: 021-369085

Form ADV 2043113 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

CLEARWATER OPPORTUNITY FUND, LLLPHedge Fund · Last reported Mar 17, 2026$102MGross asset value

Form D fundraising filings

CLEARWATER OPPORTUNITY FUND, LLLP

Fund administrator NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Investor statements: No (provided to no investors) Related to adviser: No

Auditor KPMG LLP MINNEAPOLIS, Minnesota, United States

Custodian NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Related to adviser: No

Marketer FIDUCIARY COUNSELLING INC ST. PAUL, Minnesota, United States Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

KPMG LLP
PCAOB 185

FIDUCIARY COUNSELLING INC
CRD 104753 · SEC 801-4158

Fund details & source

Fund ID: 805-9390014266
Reported beneficial owners: 73
Minimum commitment: $300K
Form D file number: 021-296940

Form ADV 2043113 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

CLEARWATER PRIVATE OPPORTUNITY FUND IV, LLLPPrivate Equity Fund · Last reported Mar 17, 2026$30.7MGross asset value

Form D fundraising filings

Clearwater Private Opportunity Fund IV, LLLP

Fund administrator U.S. BANK N.A. MILWAUKEE, Wisconsin, United States Investor statements: No (provided to no investors) Related to adviser: No

Auditor KPMG LLP MINNEAPOLIS, Minnesota, United States

Custodian U.S. BANK N.A. MILWAUKEE, Wisconsin, United States Related to adviser: No

Marketer FIDUCIARY COUNSELLING INC ST. PAUL, Minnesota, United States Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

KPMG LLP
PCAOB 185

FIDUCIARY COUNSELLING INC
CRD 104753 · SEC 801-4158

Fund details & source

Fund ID: 805-6492841810
Reported beneficial owners: 73
Minimum commitment: $300K
Form D file number: 021-161376

Form ADV 2043113 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

Services & filing details

Most recent filing: Mar 17, 2026. View historical filings

Reported services

Investment company portfolio management · Pooled investment vehicle management · Selection of other advisers

Compensation

Percentage of assets

Principal office

30 EAST 7TH STREET, SUITE 2000
ST PAUL, MN, 55101, United States

CRD 105307

Filing source

Form ADV 2043113 · Mar 17, 2026 · Items 1 & 5

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.