Alluvial Capital Management, Llc
SEC-registered
Private Fund Manager · Small ($100M–$1B)
CRD 169638
· SEC file 801-132753
·
· ALLUVIALCAPITAL.COM
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ADV data as of Jul 23, 2026
- Regulatory AUM
- $173M
- Discretionary
- $173M
- Clients
- 51
- Avg AUM / client
- $3.4M
- Accounts
- 52
- Employees
- 2
AUM over time
$105M
$173M
Dec 2024
Jul 2026
Annual snapshots from Form ADV filings · as of Jul 23, 2026
Who they serve
| Client type | Clients | AUM | % of AUM |
|---|---|---|---|
| Individuals (non-high net worth) | 8 | $2.7M | 1.58% |
| High net worth individuals | 41 | $29.9M | 17.3% |
| Pooled investment vehicles (non-investment companies) | 2 | $137M | 79.5% |
| Charitable organizations | Fewer than 5 clients | $2.9M | 1.67% |
People (1)
roster as of Jul 20, 2026| Name | Role / title | Credentials | With firm since | Ownership |
|---|---|---|---|---|
| David Irwin Waters | Registered representative | CFA | Jan 2014 (13y) |
Roster from the IAPD representatives feed; ownership and acquisition dates from Form ADV Schedule A/B. "Since" is the earliest filed registration or acquisition date.
Documents (1 archived)
| Form | Period | Size | |
|---|---|---|---|
| Form ADV (full filing) | 06/22/2026 | 1.41 MB | View · PDF · Source ↗ |
Archived copies of the firm's regulatory filings, versioned by content hash.
Disciplinary disclosures
No disciplinary events reported on the firm's latest Form ADV filing.
How they charge
- • Percentage of assets under management
- • Performance-based fees
Services
- • Portfolio management for individuals/small businesses
- • Portfolio management for pooled investment vehicles
Custody
Reported custodians
- Interactive Brokers $120M (70% of AUM) Jun 2026
- Pershing $33.8M (20% of AUM) Jun 2026
- RBC $18.6M (11% of AUM) Jun 2026
Amounts as reported in ADV Item 5.K.(3) (custodians holding 10%+ of SMA assets).
Firm reports having custody of client funds or securities (Item 9.A).
Source
All data on this page comes from this firm's Form ADV filings, reproduced without modification. Latest filing: Jul 23, 2026.
View current Form ADV (SEC/IAPD) ↗