Private company

CLEARFIELD CAPITAL MANAGEMENT LP

Last updated Oct 21, 2026.

Overview

Corporate structure

CLEARFIELD CAPITAL MANAGEMENT LP sits at the top of its group. 2 entities, 1 country on record. Switch between the flow chart and the network, and select any entity to see its details.

Major holders of CLEARFIELD CAPITAL MANAGEMENT LP

  • Philip Joseph Hilal Owns control (general partner, trustee or manager) of Hilal Family 2014, since 11/2014 (Form ADV)

Built from stakes of 5% or more it reported on Schedules 13D and 13G (1 companies); owners and owned firms from Form ADV, the registration investment advisers file with the SEC. Each entity in the chart links to its source.

Investment adviser

CLEARFIELD CAPITAL MANAGEMENT LP is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.

  • Assets it manages$240.2M2 3 accounts, all with discretion
  • Employees4 2 in investment advice or research
  • ClientsPooled investment vehicles (other than investment companies and: 3 ($240.2M)
  • How it is paidA percentage of assets under its management; Performance-based fees
  • What it doesPortfolio management for pooled investment vehicles (other than investment companies)
  • Holds client assetsYes: cash and securities
  • RegistrationSEC 801-81056, CRD 174981 IAPD record

Who owns it

Owners of 5% or more as the firm lists them (Schedule A), and the owners of those owners up the chain (Schedule B).

  • CLEARFIELD CAPITAL MANAGEMENTowns 75% or more, since 09/2014
  • Philip Joseph Hilalowns general partner, trustee or manager of HILAL FAMILY 2014, since 11/2014

In its own words: the client brochure

Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/26/2026.3 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.

Item 4: Advisory business Services

Clearfield Capital Management LP is a Delaware limited partnership that was formed on September 22, 2014. Clearfield is controlled by its principal owner, Philip Hilal (the “Principal Owner”), who acts as the managing member of Clearfield's general partner, Clearfield Capital Management GP LLC, a Delaware limited liability company (the “Investment Adviser General Partner”). Clearfield provides investment advisory services to private funds (each a “Fund” and collectively, the “Funds”) and may in the future advise separately managed accounts (the “Managed Accounts”). Unless stated otherwise, the Funds are collectively referred to herein as the “Clients.” The general partner for Clearfield Domestic Fund LP and Clearfield Master Fund LP is Clearfield Capital GP LLC (the “General Partner”), a Delaware Limited Liability Company formed on January 16, 2015. The General Partner has ultimate responsibility for the management, operations and investment decisions of the Funds. Clearfield provides investment management services to its Clients pursuant to investment guidelines within the relevant organizational documents, limited partnership agreement, investment management agreement, offering memorandum and/or subscription agreements, as the case may be (each an “Offering Document”, and collectively, the “Offering Documents”). Clearfield does not tailor its services to the individual Fund investors or provide investors with the right to specify, restrict, or influence the Funds’ investment objectives or any investment or trading decisions. Clearfield seeks to accomplish its Clients' investment objectives through disciplined, researchintensive investment and risk-management processes focusing primarily on public equity (including "new issues") and equity-linked securities (e.g., common and preferred stock, options, warrants and other derivatives), which the Firm believes are priced below their intrinsic value, and debt from time to time. Clearfield does not provide investment advisory services with respect to a limited range of investments. Clearfield and the Funds have entered into, and may in the future enter into agreements, commonly known as “Side Letters,” with certain investors under which Clearfield waives or modifies the application of certain investment terms applicable to such investors, without obtaining the consent of any other investor in the Fund (other than an investor whose rights would be materially and adversely affected by the waiver or modification). Clearfield does not participate in wrap fee programs. As of December 31, 2025, the Firm managed $240,200,778 in regulatory assets under management (“RAUM”), all managed on a discretionary basis.

Item 5: Fees and compensation Fees

Clearfield or its affiliates receive a management fee and performance-based compensation (“Incentive Allocation”) from Clients. Such compensation arrangements are set forth in the relevant Offering Document with each Client. The management fees paid by the Funds are generally equal to an annual rate of 1.25% - 1.75%, based on the respective values of the net assets of each particular share class. These management fees are paid by the Fund quarterly in advance, are amortized monthly over the fiscal quarter, and are prorated for any investment period that is less than a full calendar quarter. The Firm or its affiliates may reduce, waive or calculate differently the management fee for certain investors or Clients, including members, employees and affiliates of the Firm.

The Funds will bear their own expenses including, but not limited to, the management fee; investment expenses, whether or not such investments are consummated (such as brokerage commissions, expenses relating to short sales, clearing and settlement charges, custodial fees, bank service fees and interest expenses); investment-related travel expenses incurred by the Firm related to the purchase or sale of, or due diligence regarding, the Funds’ investments, whether or not such investments are consummated; third-party professional fees (including, without limitation, expenses of consultants, investment bankers, attorneys, accountants and other experts) relating to investments; fees and expenses relating to software tools, programs or other technology utilized in managing the Funds; research and market data (including, without limitation, any computer hardware and connectivity hardware incorporated into the cost of obtaining such research and market data); administrative expenses (including, without limitation, fees and expenses of the administrator); third-party legal expenses; third-party accounting and valuation expenses (including, without limitation, the cost of accounting software packages); audit and tax preparation expenses; premiums for liability insurance (including, without limitation, D&O and/or E&O insurance); costs of printing and mailing reports and notices; entity-level taxes; corporate licensing; regulatory expenses (including expenses related to preparing and making regulatory and compliance filings associated with the Funds and their investment activities, such as filing fees and costs of software and systems relating to such filings); organizational expenses; fees and expenses for directors and officers of the Funds (including any AML officers); expenses incurred in connection with the offering and sale of the interests and other similar expenses related to the Funds (excluding fees payable to any placement agent); indemnification expenses; and extraordinary expenses. To the extent that Clearfield allocates Clients’ capital to money market funds or exchangetraded funds, Clients will indirectly incur similar fees and expenses as these funds in turn pay similar fees and expenses to their investment managers and other service providers.

Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks

Investment Strategy Clearfield seeks to accomplish its Clients’ investment objectives with a concentrated, fundamental, value-oriented long/short and event-driven strategy. Clearfield employs disciplined and research-intensive investment and risk-management processes focusing primarily on corporate securities whose prices diverge materially from Clearfield’s assessment of long-term intrinsic value, often with price-correcting catalysts that can be identified or created. Clearfield believes that intrinsic value is generally determined by the level and use of long-term discretionary free cash flows and realizable asset values. Clearfield believes that long and short investments that meet its Clients' investment criteria are often found in situations involving complexity (which can obscure intrinsic value) and change (which can alter or unlock intrinsic value). Clearfield seeks to develop differentiated investment conclusions in such situations by gathering extensive data and conducting in-depth analysis. Clearfield will cause its Clients to invest primarily in developed markets, but may also opportunistically invest in other geographies. Method of Analysis Fundamental Analysis – Clearfield's investment process utilizes a "bottom-up" stock selection process based on fundamental analysis. The Firm's fundamental analysis is driven by experienced analysts, and investment decisions are based on in-depth fundamental research. Such bottom-up analysis is combined with a thematic or "top-down" view of opportunities across the various sectors and seeks to identify the best long and short opportunities globally. The top-down view also focuses on the overall composition of the portfolio in an attempt to minimize areas where the Clients may have unintended exposure to a particular sector, country or macro-economic variable such as interest rates or foreign exchange rates. Event Driven – Clearfield, on behalf of the Clients, may also invest in loans and securities of companies involved in reorganizations, mergers, acquisitions, bankruptcies, binary biotechnology events or other extraordinary corporate events/transactions with the intention of capturing a spread between the current value of the securities and their value upon consummation of the event within a specified period of time. Clearfield, on behalf of the Clients, may also make special situation or relative value investments, seeking to exploit fundamental valuation discrepancies caused by market dislocations, lack of sell side following, or expected corporate events. Clearfield may (1) position the Clients’ portfolios from both the long and the short side, (2) actively trade such positions and related spreads, and (3) utilize leverage and derivatives to optimize returns. Certain Risk Factors Investing in securities involves risk of loss that Clients and Fund investors should be prepared to bear. The following explanation of certain risks is not exhaustive, but rather highlights some of the more significant risks involved in Clearfield’s investment strategy. For a more complete list of expected risk factors, prospective Fund investors should review each Fund’s offering documents.

Legal and Regulatory Environment for Private Investment Funds and their Managers – The legal, tax and regulatory environment worldwide for private investment funds (such as the Funds) and their managers is evolving. Changes in the regulation of private investment funds, their managers, and their trading and investing activities may have a material adverse effect on the ability of the Funds to pursue their investment programs and the value of investments held by the Funds. There has been an increase in scrutiny of the private investment fund industry by governmental agencies and self-regulatory organizations. New laws and regulations or actions taken by regulators that restrict the ability of the Funds to pursue their investment programs or employ brokers and other counterparties could have a material adverse effect on the Funds and the investors' investments therein. In addition, Clearfield may, in its sole discretion, cause the Funds to be subject to certain laws and regulations if the Firm believes that an investment or business activity is in the Funds’ interest, even if such laws and regulations may have a detrimental effect on one or more investors. Systems and Operational Risks – Clients depend on the Firm to develop and implement appropriate systems for the Clients’ activities. Clients rely heavily on a daily basis on financial, accounting and other data processing systems to execute, clear and settle transactions across numerous and diverse markets and to evaluate certain securities, to monitor its portfolio and capital, and to generate risk management and other reports that are critical to oversight of Clients’ activities. In addition, Clients rely on information systems to store sensitive information about the Clients, Clearfield, their affiliates and the investors. Certain of the Clients’ and the Firm’s activities will be dependent upon systems operated by third parties, including prime brokers, the administrator, market counterparties and other service providers, and the Firm may not be in a position to verify the risks or reliability of such thirdparty systems. Failures in the systems employed by Clearfield, prime brokers, the administrator, counterparties, exchanges and similar clearance and settlement facilities and other parties could result in mistakes made in the confirmation or settlement of transactions, or in transactions not being properly booked, evaluated or accounted for. In addition, despite the security measures established by Clearfield and third parties to safeguard the information in these systems, such systems may be vulnerable to attacks by hackers or breached due to employee error, malfeasance or other disruptions. Any such breach could compromise these systems and result in the theft, loss or public dissemination of the information stored therein. Disruptions in the Clients’ operations or breach of the Clients’ information systems may cause the Clients to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing failures or disruptions could have a material adverse effect on the Clients and the investors’ investments therein. Cybersecurity Risk – As part of its business, the Firm processes, stores and transmits large amounts of electronic information, including information relating to the transactions of the Clients and personally identifiable information of investors. Similarly, service providers of Clearfield and the Funds, especially the administrator, may process, store and transmit such information. Clearfield has procedures and systems in place that it believes are reasonably designed to protect such information and prevent data loss and security breaches. However, such measures cannot provide absolute security. The techniques used to obtain unauthorized access to data, disable or degrade service, or sabotage systems change frequently and may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design or manufacture or other problems that could unexpectedly compromise information security. Network connected services provided by third parties to Clearfield may be susceptible to compromise, leading to a breach of the Firm’s network. Clearfield’s systems or facilities may be susceptible to employee error or malfeasance, government surveillance, or other security threats. On-line services provided by the Firm to the investors may also be susceptible to compromise. Breach of Clearfield’s information systems may cause information relating to the transactions of the Clients and personally

identifiable information of the investors to be lost or improperly accessed, used or disclosed. The service providers of Clearfield and its Clients are subject to the same electronic information security threats as Clearfield. If a service provider fails to adopt or adhere to adequate data security policies, or in the event of a breach of its networks, information relating to the transactions of the Clients and personally identifiable information of the investors may be lost or improperly accessed, used or disclosed. The loss or improper access, use or disclosure of the Firm’s or the Clients’ proprietary information may cause Clearfield and the Clients to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing events could have a material adverse effect on the Clients and the investors’ investments therein. Counterparty Risk – The Firm expects to cause the Clients to establish relationships to obtain financing, derivative intermediation and prime brokerage services that permit the Clients to trade in any variety of markets or asset classes over time. However, there can be no assurance that the Firm will be able to establish or maintain such relationships on behalf of the Clients. An inability to establish or maintain such relationships could limit the Clients’ trading activities, create losses, preclude the Clients from engaging in certain transactions or prevent the Clients from trading at optimal rates and terms. Moreover, a disruption in the financing, derivative intermediation and prime brokerage services provided by such relationships could have a significant impact on the Clients’ business due to the Clients’ reliance on such counterparties. Event-Driven – The success of the Clients’ event-driven investment strategy depends upon Clearfield's ability to make predictions about (i) the likelihood that an event will occur and (ii) the impact such event will have on the value of a company's securities. If the event fails to occur or it does not have the effect foreseen, losses can result. For example, the adoption of new business strategies or completion of asset dispositions or debt reduction programs by a company may not be valued as highly by the market as the Firm had anticipated, resulting in losses. In addition, a company may announce a plan of restructuring which promises to enhance value, but fail to implement it, which can result in losses to investors. In liquidations and other forms of corporate reorganization, the risk exists that the reorganization either will be unsuccessful, will be delayed or will result in a distribution of cash or a new security, the value of which will be less than the purchase price to the Clients of the security in respect of which such distribution was made. The consummation of mergers and tender and exchange offers can be prevented or delayed by a variety of factors, including: (i) opposition of the management or stockholders of the target company, which will often result in litigation to enjoin the proposed transaction; (ii) intervention of a U.S. federal or state regulatory agency; (iii) efforts by the target company to pursue a "defensive" strategy, including a merger with, or a friendly tender offer by, a company other than the offeror; (iv) in the case of a merger, failure to obtain the necessary stockholder approvals; (v) market conditions resulting in material changes in securities prices; (vi) compliance with any applicable U.S. federal or state securities laws; and (vii) inability to obtain adequate financing. Because of the inherently speculative nature of event-driven investing, the results of the Firm's investment activities on behalf of the Clients may be expected to fluctuate from period to period. Accordingly, investors in the Funds should understand that the results of a particular period will not necessarily be indicative of results that may be expected in future periods. Equity Securities Generally – The value of equity securities of public and private, listed and unlisted companies and equity derivatives generally varies with the performance of the issuer and movements in the equity markets. As a result, the Clients may suffer losses if Clearfield causes them to invest in equity instruments of issuers whose performance diverges from Clearfield's expectations or if equity markets generally move in a single direction and Clearfield has not caused the Clients to hedge against such a general move. The Clients also may be exposed to risks that issuers will not fulfill contractual obligations such as, in the case of

Read the rest in the brochure

Item 7: Types of clients

Clearfield provides investment advice to private funds. Each Fund’s Offering Documents provide the eligibility criteria and minimum investment requirements.

In general, each Investor in the Funds must be an “accredited investor” as defined in Regulation D under the Securities Act of 1933, as amended, and a “qualified purchaser” as defined in Section 2(a)(51) of the Investment Company Act of 1940.

Item 6: Performance-based fees and side-by-side management Conflicts of interest

Clearfield or its affiliates receive Incentive Allocation from Clients, generally equal to 10% 20% of the net profits, depending on the net asset value of each particular share class of each Client. Additional information regarding such compensation arrangements are set forth in the relevant Offering Document with each Client. The Firm or its affiliates may reduce, waive or calculate differently the Incentive Allocation for certain investors or Clients, including members, employees and affiliates of the Firm. The terms of the Incentive Allocation may differ among the Clients. This may result in a conflict of interest when allocating opportunities among Clients, as Clearfield may have an incentive to favor Clients that have higher Incentive Allocation. To avoid such a conflict of interest, Clearfield has developed documented procedures for allocating opportunities among Clients in a fair and equitable manner. As management fees and Incentive Allocation are based directly on Clients’ net asset values, Clearfield may have a conflict of interest in valuing the assets held in Client accounts. Clearfield follows documented valuation policies and consults with each Client’s third-party administrator, as applicable, in order to mitigate this risk.

Item 10: Other financial industry activities and affiliations Conflicts of interest

The General Partner, an affiliate of the Firm, serves as the General Partner to certain of the Clients.

Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest

Trading Code of Ethics Clearfield has adopted a Code of Ethics (the “Code of Ethics”), which is designed to ensure that it conducts its business in accordance with all applicable laws and regulations and in an ethical and professional manner. The Code of Ethics applies to all Clearfield employees. In addition, Clearfield recognizes that it has a fiduciary duty to its Clients, and that all of its employees need to conduct their business on Clearfield’s behalf in a manner that enables Clearfield to fulfill this fiduciary duty. In this regard, Clearfield has developed policies and procedures in the Code of Ethics that are premised on the fundamental principles of openness, integrity, honesty and trust. Employees are provided with a copy of the Code of Ethics and are annually required to sign and acknowledge that they will comply with its provisions. Clearfield will provide a copy of the Code of Ethics to any Client or prospective Client upon request. The Code of Ethics sets forth formal policies and procedures with respect to the personal securities trading activities of the Firm’s employees. The Code also addresses outside activities of employees, conflicts of interest, policies and procedures concerning the prevention of insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and the pre-clearance and reporting of political contributions. Personal Trading The Code sets forth formal policies and procedures with respect to the personal securities trading activities of the Firm’s employees. The Code generally prohibits employees from trading reportable securities in covered accounts. Clearfield employees (and members of their immediate households) are not permitted to invest in single name equity securities, options on equities, bonds, futures or commodities. Employees are permitted to trade in ETFs and are permitted to sell reportable securities reported at the start of employment. All trades must receive pre-clearance from Clearfield’s Chief Compliance Officer (the “CCO”). The Code requires employees to report all reportable securities transactions and provide a summary of securities holdings initially upon hire and on an annual basis thereafter via the Firm’s electronic compliance portal. The spirit of the Code of Ethics is to discourage frequent trading in employee personal accounts. All employees are required to link personal trading accounts to the Firm’s electronic compliance portal to monitor personal securities transactions. These records are used to monitor compliance with the foregoing policies. Participation and Interest in Client Transactions Subject to applicable law, Clearfield may effect transactions between Client accounts whereby one Client account will purchase securities from or sell securities to another account. Clearfield does not currently intend to engage in such activity. Nonetheless, if it plans on effecting such transactions in the future, it will develop documented procedures for doing so, including requiring pre-approval from the CCO.

Item 12: Brokerage practices Conflicts of interest

Selection of Brokers

In placing portfolio transactions for Clients, Clearfield seeks to obtain the best execution for Clients’ accounts, which may take into account a number of the following factors, among others: price, timeliness of execution, the availability of financing, the financial stability and reputation of a broker, the value of research, brokerage and other services provided including capital introduction services, the responsiveness of a broker-dealer, a broker-dealer’s financial resources, counterparty credit risk, and access to liquidity for certain less liquid products. Clearfield has established a Brokerage Committee (consisting of the CCO and the Principal Owner), which meets on a quarterly basis to review the execution performance of the brokerdealers Clearfield uses to execute Client transactions. The committee also reviews commissions paid to brokers, soft dollar arrangements and certain conflicts of interest. Research and Other Soft Dollar Benefits Clearfield may enter into soft dollar arrangements with brokers. Soft dollar arrangements arise when an investment adviser obtains products and services, other than securities execution, from a broker in return for directing Client securities transactions to the broker. Soft dollar arrangements may pose a conflict of interest for Clearfield in that such arrangements may allow Clearfield to pay with Client commissions expenses that would otherwise be borne by Clearfield. If Clearfield uses Client brokerage commissions (or markups or markdowns) to obtain research or other products or services, it will receive a benefit because it will not have to produce or pay for the research, products or services. Clearfield may have an incentive to select a broker based on Clearfield’s interest in receiving the research or other products or services offered by such broker, rather than on Clients’ interests in receiving most favorable execution. To the extent that it engages in soft dollar transactions, Clearfield will comply with the safe harbor requirements of Section 28(e) of the Securities Exchange Act of 1934, as amended. Under this provision, in exercising its discretionary authority to select or arrange for the selection of brokers for execution of transactions for Clients, and, subject to its duty to obtain best execution, Clearfield may consider the value of research and brokerage products and services (collectively, “Research”) provided by such brokers. Research may include, among other things, proprietary research from brokers, which may be written or oral, databases and quotation services, research concerning market, economic and financial data, a particular aspect of economics or on the economy in general, statistical information, pricing data and availability of securities, financial publications, electronic market quotations, performance measurement services, analyses concerning specific securities, companies, industries or sectors, market, economic and financial studies and forecasts, appraisal services, and invitations to attend conferences or meetings with management or industry consultants. Accordingly, if Clearfield determines in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the brokerage and products or services provided by such broker, a Client may pay commissions to such broker in an amount greater than the amount another broker might charge. Research provided by such brokers may be used to service all Clients and not exclusively in connection with the management of the Clients that generated the particular soft dollar credits. When a product or service obtained with Client commission dollars provides both research and non-research assistance to Clearfield, Clearfield will make a reasonable allocation of the cost which may be paid for with Client commission dollars.

Clearfield executes securities transactions on behalf of Clients with broker-dealers that provide Clearfield with access to proprietary research reports (such as standard investment research and credit reports). To Clearfield’s knowledge, these services are generally made available to all institutional investors doing business with such broker-dealers. These bundled services are made available to Clearfield on an unsolicited basis and without regard to the rates of commissions charged or paid by Clients or the volume of business that Clearfield directs to such broker-dealers. Capital Introduction From time to time, brokers (including the prime brokers) may assist the Funds in raising additional funds from investors. Additionally, brokers may provide capital introduction and marketing assistance services, and representatives of the Firm may speak at conferences and programs sponsored by the brokers, for investors interested in investing in private investment funds. Through such events, prospective investors in the Funds may encounter representatives of the Firm. Brokers may also provide other services, including, without limitation, consulting services relating to technology and office space. Although neither the Firm nor the Funds compensate brokers for such assistance, events or services, or for any investments ultimately made by prospective investors attending such events, such activities may influence the Firm in deciding whether to use such brokers in connection with brokerage, financing and other activities of the Funds. Subject to its obligation to seek best execution, the Firm may consider referrals of investors to the Funds in determining its selection of brokers. However, the Firm will not commit to an investor or a broker to allocate a particular amount of brokerage in any such situation. Aggregation of Orders Clearfield currently conducts all trades in Clearfield Master Fund LP. However, in the future, if the Firm were to provide advisory services to multiple fund structures or Clients, the policy will be to generally aggregate orders for the same security unless aggregation is not consistent with the Firm’s duty to seek best execution and the terms of the investment guidelines and restrictions of each account for which trades are being aggregated. Aggregation opportunities would generally arise when more than one account is capable of purchasing or selling a particular security based on investment objectives, available cash and other factors. When aggregating trades, no account will be favored over any other account. Any account that participates in an aggregated order will participate at the average price for all of Firm’s transactions in that security on a given business day, with transaction costs shared pro rata, based on each account’s participation in the transaction.

Item 14: Client referrals and other compensation Conflicts of interest

Other than the products and services that Clearfield receives from broker-dealers (described above under Item 12), Clearfield does not currently and does not expect to receive any economic benefits from third parties in connection with the provision of investment advice to Clients. Additionally, other than considerations regarding capital introduction programs (described above under Item 12), Clearfield does not currently and does not plan on directly or indirectly compensating any person for investor referrals.

Item 9: Disciplinary information

There have been no legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of Clearfield’s advisory business or the integrity of Clearfield’s management.

Item 13: Review of accounts

The Principal Owner reviews Client accounts continually for overall adherence to the investment strategy and investment guidelines. The Firm engages in active management of the Client accounts and accordingly reviews transactions, positions and cash balances on a daily basis. Clearfield provides Fund investors with annual audited financial statements and additional periodic reporting (see item 15).

Item 15: Custody

Clearfield will comply with the requirements of the Rule 206(4)-2 of the Advisers Act with regards to Clearfield’s custody of the Funds’ assets. Clearfield is deemed to have custody of Client funds and securities because it has the authority to obtain Client funds or securities, for example, by deducting advisory fees from a Client's account or otherwise withdrawing funds from a Client's account. Clearfield does not expect to be required to comply (or expects to be deemed to have complied) with certain requirements of the Custody Rule with respect to each Fund because it complies with the provisions of the so-called "Pooled Vehicle Annual Audit Exception", which, among other things, requires that (i) each Fund be subject to audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, (ii) each Fund’s audited financial statements are prepared in accordance with U.S. generally accepted accounting principles (GAAP), and (iii) each Fund distributes its audited financial statements to all investors within 120 days of the end of its fiscal year.

Item 16: Investment discretion

Clearfield has discretionary authority to manage securities accounts on behalf of the Clients, which includes the authority to determine, without obtaining specific consent, the securities to be bought or sold, the amount of securities to be bought or sold, the broker-dealer to be used and the commission rates to be paid. The investors in the Funds generally will not have the ability to place any limits on Clearfield’s authority beyond the limitations set forth in the Offering Documents of the applicable Fund.

Item 17: Voting client securities

Clearfield has established proxy voting policies and procedures (the “Proxy Voting Policy”) designed to ensure that proxies are voted in the best interest of the Clients. The Proxy Voting Policy requires Clearfield, when voting proxies, to follow procedures designed to identify and address material conflicts that may arise between its interests and those of its Clients. Accordingly, prior to voting any proxy, the CCO will determine whether a material conflict of interest exists and will either resolve the conflict or refer the proxy vote to an outside service provider for its independent consideration. In the absence of a material conflict, Clearfield will follow the voting guidelines set forth in its Proxy Voting Policy to determine whether and how to vote a proxy. Upon request by a Client, Clearfield will disclose to such Client how it voted securities owned by such Client. Clients may also contact Clearfield via e-mail or telephone to request a copy of its Proxy Voting Policy.

Item 18: Financial information

Clearfield has no financial commitment that impairs the Firm’s ability to meet contractual and fiduciary commitments to Clients, and has not been the subject of a bankruptcy proceeding.

Filings

23 filings to the SEC since October 2021: 23 other. The latest 20:

  1. Aug 27, 2026N-PX EDGAR
  2. Aug 14, 202613F-HR EDGAR
  3. May 15, 202613F-HR EDGAR
  4. Feb 13, 202613F-HR EDGAR
  5. Nov 14, 202513F-HR EDGAR
  6. Aug 29, 2025N-PX EDGAR
  7. Aug 14, 202513F-HR EDGAR
  8. May 15, 202513F-HR EDGAR
  9. Feb 14, 202513F-HR EDGAR
  10. Nov 7, 202413F-HR EDGAR
  11. Sep 19, 2024N-PX EDGAR
  12. Aug 13, 202413F-HR EDGAR
  13. May 14, 202413F-HR EDGAR
  14. Feb 14, 202413F-HR EDGAR
  15. Nov 14, 202313F-HR EDGAR
  16. Aug 14, 202313F-HR EDGAR
  17. May 12, 202313F-HR EDGAR
  18. Feb 14, 202313F-HR EDGAR
  19. Nov 14, 202213F-HR EDGAR
  20. Aug 12, 202213F-HR EDGAR

The 23 filings since October 2021 can be filtered by form type and year here when JavaScript is on.

Every filing from the last five years, summarized. The full record is on SEC EDGAR.

Stakes it holds

CLEARFIELD CAPITAL MANAGEMENT LP has told the SEC it owns more than 5% of 1 company, latest first (Schedules 13D and 13G).