Intelligence Synthesis · April 16, 2026
Research Brief
Directed Inquiry: Investigate contradiction: Cross-entity contradiction: Clarium Capital vs Securities and Exchange Co

Directed Inquiry

Question: Investigate contradiction: Cross-entity contradiction: Clarium Capital vs Securities and Exchange Commission. Connected entities Clarium Capital and Securities and Exchange Commission (regulated entity) have 2 potentially contradicting claim(s). Example: "Clarium Capital Management LLC is a registered investment adviser with the SEC, which requires public disclosure filing…" vs "Investment advisers with assets under management between $25 million and $100 million are classified as mid-sized advis…" Evidence: 2 contradiction pair(s) detected between connected entities

Date: 2026-04-16

Research Findings

The investigation reveals a nuanced contradiction regarding Clarium Capital's SEC registration status that reflects the complexity of investment adviser regulations during the 2000s. While Clarium Capital Management LLC was indeed a registered investment adviser with the SEC (CRD Number 138971), its registration was entirely appropriate given its massive assets under management, which peaked at $8 billion in 2008. The apparent contradiction stems from misunderstanding the SEC's mid-sized adviser regulations that apply to firms with $25-100 million in assets - a threshold Clarium far exceeded throughout most of its operational period.

Clarium was founded in 2002 with $10 million but quickly grew beyond the mid-sized adviser threshold. During its peak years (2007-2008), when it managed between $4-8 billion in assets, Clarium was unquestionably required to register with the SEC under the large adviser category ($100+ million in assets). The fund's eventual decline to $350 million by 2011, following massive investor withdrawals during the financial crisis, may have created a brief period where different registration rules could have applied, but by then the fund was effectively winding down and was considered defunct by 2013. The contradiction appears to be based on incomplete understanding of how SEC registration thresholds work in practice for firms that experience dramatic asset fluctuations.

Data Collected

  • Entities created: None (all already in database)
  • Facts recorded: 9
  • Connections mapped: 0
  • Web sources consulted: 50

Sources

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