BREAKWATER INVESTMENT MANAGEMENT

Legal name: BREAKWATER INVESTMENT MANAGEMENT, LLC

CRD 150841File 801-79040

APPROVED

Retail clients

Custody

Filing as of Apr 15, 2026

Feed vintage Oct 1, 2026

Regulatory AUM

$302.7M

Below cohort median (national)

Discretionary AUM

$302.7M

Clients

152

572 accounts

Employees

Below cohort median in WA

Identity & registration

ADV Item 1

Organization form: Limited Liability Company
Firm type: Registered
SEC region: SFRO
Registration date: Jan 9, 2014
Principal office: 2033 SIXTH AVENUE, #1010, SEATTLE, WA, 98121
Phone: 206.621.8832
Website: https://www.breakwater.com/

Assets & accounts

ADV Item 5F

Total regulatory AUM: $302.7M
Discretionary AUM: $302.7M
Non-discretionary AUM: $0
Discretionary accounts: 572
Non-discretionary accounts: 0
Total accounts: 572
AUM per client: $2.0M

Clients by type

ADV Item 5D

Client type	Clients	AUM
Charitable organizations	Fewer than 5	$555K
High net worth individuals	56	$252.4M
Individuals (other than high net worth individuals)	96	$49.8M

Compensation & activities

ADV Items 5E, 5G

Compensation

Fixed fees
Hourly charges
A percentage of assets under your management

Advisory activities

Other advisory activities
Financial planning services
Portfolio management for individuals and/or small businesses

Custody

ADV Item 9

Firm Custody Cash: Yes
Firm Custody Assets: No
Firm Custody Clients: No
Firm Custody Securities: Yes
Related Person Custody Cash: No
Related Person Custody Assets: No
Related Person Custody Clients: No
Related Person Custody Securities: No

Disclosure events

ADV Item 11

This firm answered no to every Item 11 disclosure question in this filing.

Filed changes

Date	Field	From	To	Change
May 1, 2026	Employees	3	4	increased by1
Apr 1, 2026	Clients	157	152	decreased by5
Apr 1, 2026	AUM	$250,791,556	$302,726,806	increased by$51,935,250
Apr 1, 2026	Accounts	557	572	increased by15
May 1, 2025 vs Oct 1, 2022	Employees	2	3	increased by1
May 1, 2025 vs Oct 1, 2022	Clients	159	157	decreased by2
May 1, 2025 vs Oct 1, 2022	AUM	$227,080,444	$250,791,556	increased by$23,711,112
May 1, 2025 vs Oct 1, 2022	Accounts	554	557	increased by3
Mar 1, 2022	Employees	3	2	decreased by1
Mar 1, 2022	AUM	$221,389,698	$227,080,444	increased by$5,690,746
Mar 1, 2022	Accounts	486	554	increased by68
Oct 1, 2021	Clients	258	159	decreased by99
Oct 1, 2021	AUM	$191,208,464	$221,389,698	increased by$30,181,234
Oct 1, 2021	Accounts	259	486	increased by227
Apr 1, 2021	Registration	—	APPROVED

On Form 5500, an adviser usually appears as a plan service provider (Schedule C), not the plan sponsor.

See plans that list “BREAKWATER INVESTMENT” as a service provider on 5500mcp →

Matched by name only — Form ADV and Form 5500 share no identifier, and names are searched loosely (“BREAKWATER INVESTMENT” may also match similarly-named firms). Confirm identity against each filing.

Every value above is reproduced from this firm's Form ADV filing. Fields the firm left blank are shown as “Not reported” rather than filled in from other sources.