--- title: "Cliffwater Review 2026: CCLFX, Its Sister Funds and What the Repurchase Record Shows" url: https://altstreet.investments/platforms/reviews/cliffwater kind: platform-review updated: 2026-10-29 description: "Cliffwater review 2026: CCLFX and its sister interval funds, their 3.20% expense ratio, manager-set valuations, distributions above net investment income and rising repurchases." publisher: AltStreet (https://altstreet.investments) license: Public factual pages may be read, quoted and cited with attribution and a link. Bulk redistribution is not permitted. --- # Cliffwater Review 2026: CCLFX, Its Sister Funds and What the Repurchase Record Shows Cliffwater, an institutional investment consultant, runs the largest family of interval funds in the US, led by the $30 billion Cliffwater Corporate Lending Fund (CCLFX). The fund has returned 9.17% a year net since 2019 with very few realized losses, but its total annual expenses are 3.20% of net assets, more than half of it borrowing cost, nearly all of its assets are valued with significant judgment from manager marks, with Cliffwater as the valuation designee, in March 2026 it bought back 7% of its shares, the full amount available under that quarter's offer, and in its last fiscal year its distributions exceeded its net investment income. AltStreet score: 64.3 (B+), scored October 29, 2026. Method: https://altstreet.investments/platforms | Field | Value | | --- | --- | | Platform | Cliffwater | | What it is | Interval fund sponsor (registered closed-end funds sold through financial advisers) | | Asset class | Private credit (direct loans, private CLO equity, BDCs, asset-backed finance) and private equity and real assets funds of funds | | Website | cliffwaterfunds.com | | Review first published | October 29, 2026 | | Last updated | October 29, 2026 | | AltStreet relationship | None: no affiliate, sponsorship or partnership | ## The short version Cliffwater LLC is a Marina del Rey investment consultant, founded by Stephen Nesbitt in 2004, that advises pension funds and endowments on private markets and since 2019 has run its own registered interval funds, sold daily at NAV through financial advisers with quarterly or semiannual repurchase offers. The flagship, the Cliffwater Corporate Lending Fund (CCLFX), had $30.4 billion of net assets at June 30, 2026 and holds direct loans made alongside about 30 lending firms, plus stakes in private CLOs, non-traded BDCs and private credit funds. Its record is real: 9.17% a year net since June 2019, a positive return in every calendar year, and realized losses the fund reports at 0.04% of NAV since inception. The prospectus fee table totals 3.20% of net assets a year: a 1.00% management fee and 0.31% of other expenses, 1.68% of borrowing costs, and 0.21% of acquired fund fees, the line for the fees inside the BDCs, CLO equity and funds it holds, which were 42.8% of net assets; the prospectus does not show which of those vehicles the 0.21% covers. The fund's published net returns are after these costs. About 97% of the portfolio is valued from unobservable inputs or the underlying managers' own reported NAVs, with Cliffwater as the board's valuation designee and the daily NAV adjusted by estimated returns between quarter ends. That approach rests on significant judgment and can smooth reported returns, so the 1.66% standard deviation the fund reports is not directly comparable with that of traded credit. Since late 2025 the fund has bought back more than it used to: 5.32% of shares in December 2025, 7.00% in March 2026, the full amount available under that quarter's 5% offer and 2% discretionary extension, and about 5% in May 2026, $6.04 billion in its fiscal year to March 2026 against $2.24 billion the year before. Buying more than 5% shows that requests exceeded the original offer; no filing says how many shares investors asked to sell, so whether any requests went unfilled is not known. Over the same year its distributions exceeded net investment income by $313.5 million, and the October 2026 distribution notice estimates about 10% of that payment as return of capital, an estimate the year-end tax characterization can change. None of this is a finding of wrongdoing; it is the trade a buyer accepts: steady reported income from private credit, in exchange for 3.20% of annual expenses, valuations that rest on significant judgment, and an exit limited to the amount each quarterly offer sets, with requests above it cut back pro rata. - **7.00%** Share of CCLFX shares bought in the March 10, 2026 repurchase, the full amount available under that offer (5% plus a discretionary 2%; the fund's policy allows offers of 5% to 25%). Before late 2025, no offer since May 2020 bought more than 3.70%. - **3.20%** CCLFX's total annual expenses in the July 2026 prospectus: 1.00% management fee, 1.68% borrowing costs, 0.21% acquired fund fees and 0.31% other. The prospectus does not show which of the BDCs, CLO equity and funds held the 0.21% covers. - **97%** Share of CCLFX investments valued with unobservable inputs (Level 3) or at the underlying managers' reported NAV at June 30, 2026, with Cliffwater as the board's valuation designee. Data note: Fund figures from the CCLFX prospectus (July 29, 2026), annual report for the year ended March 31, 2026 (audited) and schedule of investments at June 30, 2026 (unaudited); repurchase results from the funds' shareholder reports and, for May 2026, Form N-PORT. Requested repurchase levels are not in any filing. Percentages are AltStreet's arithmetic. ## Key figures | Figure | What it is | Context | | --- | --- | --- | | 7.00% | Requests exceeded the original 5% offer, so the fund used its discretionary extension; no filing shows whether requests also exceeded the 7% it bought. | Share of CCLFX's shares bought in the March 10, 2026 repurchase offer, the full amount available under that quarter's 5% offer and 2% discretionary extension. Audited annual report; the extra 2% is used only when tenders exceed 5%. Requests are not reported in any filing. | | 3.20% | CCLFX total annual expenses in the July 2026 prospectus, of which 1.68% is borrowing cost and 0.21% acquired fund fees. | Prospectus fee table; FY2026 audited ratio 3.31% including interest, before acquired fund fees. | | $313.5M | Amount by which CCLFX's distributions exceeded its net investment income in the year to March 31, 2026 ($3.07 billion against $2.76 billion). | Audited statements of operations and changes in net assets; AltStreet arithmetic. | ## Verdict Cliffwater built the largest interval fund business in the US on a simple idea: let advisers' clients own a diversified private credit portfolio at a daily price, with a fixed quarterly exit. The record is good on its own terms, 9.17% a year net since 2019 and very few realized losses, and the funds are registered, audited and fully itemized. The trade-offs are in the parts the marketing plays down. Total annual expenses are 3.20% of net assets for CCLFX, more than half of it borrowing cost; nearly all values come from the lenders' and Cliffwater's own marks, a method that can smooth the 1.66% volatility the fund reports; and repurchases have grown, with the flagship buying the full 7% available in its March 2026 offer while its distributions exceeded net investment income for the year. Whether any requests went unfilled is not disclosed. A buyer should treat CCLFX as a long-term holding whose exit depends on each quarter's offer, compare its net return with listed alternatives, and ask the adviser for the tender and proration history before investing. **Best for** - Advised investors who want diversified private credit income, accept manager-set valuations and can hold for years with an exit limited to each quarterly offer. **Look elsewhere if** - You may need the money within a year. - You judge the fund by its distribution rate. - You want independently priced assets. **Strengths** - Registered funds with audited annual reports, an independent board majority and bank custody. - A seven-year net return record of 9.17% a year, with realized losses the fund reports at 0.04% of NAV. - Full position-level schedules each quarter; repurchase results reported by offer. - No incentive fee at fund level; management fee on net assets, not gross. **Limitations** - Total annual expenses of 3.20% of net assets (CCLFX), 1.68% of it borrowing cost. - About 97% of the portfolio valued at Level 3 or manager-reported NAV, with Cliffwater as valuation designee. - The full 7% available bought in March 2026; requests and proration not disclosed. - Distributions above net investment income in the latest fiscal year. - Cliffwater owns the index the fund aims to resemble, and its marketing scale figures are client commitments, not assets managed. ## Who it fits | Investor | Fit | Why | | --- | --- | --- | | Investors with an adviser who want private credit income and can leave the money for years | neutral | | | Investors who may need the money within a few quarters | poor-fit | | ## Questions **Is Cliffwater legit?** Yes. Cliffwater LLC is an SEC-registered adviser founded in 2004, and its funds are registered under the Investment Company Act with audited annual reports, an independent board majority and bank custody. Cliffwater is a defendant in a 2020 civil rights suit over New Jersey pension mandates that does not involve the funds; no SEC action was located in the sources searched. **Can you get your money out of CCLFX?** Through the fund's quarterly repurchase offers only, each for 5% of shares with discretion to buy up to 7%. The fund bought the full 7% available under its March 2026 offer and about 5% in May 2026; when requests exceed the amount bought, they are cut back pro rata. The fund's policy allows offers of 5% to 25% of shares; each offer since 2019 has been for 5%. **What are CCLFX's fees?** The July 2026 prospectus shows total annual expenses of 3.20%: a 1.00% management fee, 1.68% of borrowing costs, 0.21% of acquired fund fees and 0.31% of other expenses. The 0.21% line is the table's measure of the fees inside the funds it holds; the prospectus does not show which of the BDCs, CLO equity and private funds it includes. Published net returns are after these costs. There is no incentive fee at the fund level. **Is the CCLFX distribution rate its yield?** No. The 8.5% distribution rate is projected distributions divided by NAV. In the year to March 2026 distributions exceeded net investment income by $313.5 million, and the October 2026 notice estimated about 10% of that payment as return of capital, an estimate the year-end tax form can change. **How is CCLFX valued?** Cliffwater is the board's valuation designee. Loans are valued mainly from the lending partners' marks and funds at their reported NAV; between quarter ends the loan values are adjusted daily by estimated returns. About 97% of the portfolio is Level 3 or valued at reported NAV. ## Evidence appendix Platform website captured October 28, 2026. 120 pages of cliffwaterfunds.com including every fund's prospectus, statement of additional information, annual and semiannual reports and schedules; the EDGAR records of Cliffwater LLC and eight fund and feeder filers (about 135 filings read); Form ADV; CourtListener, EDGAR full-text and SEC enforcement release legal scan. **Highlights** - CCLFX prospectus: 'The Investment Manager intends for the Fund to closely resemble the CDLI'; home page: 'The CDLI is owned exclusively by Cliffwater'. - CCLFX prospectus: 'the Investment Management Fee is based on the value of the Fund's assets' (valuation conflict). - CCLFX annual report: values of direct loans 'are adjusted daily based on the estimated total return that the asset will generate during the current quarter'. - CCLFX prospectus: payments to intermediaries 'may provide such third parties or their employees with an incentive to favor sales of Shares of the Fund over other investment options'. **Primary source pages** - CCLFX prospectus and SAI, July 29, 2026: fee table, repurchase policy, valuation, conflicts, CDLI. - CCLFX annual report for the year ended March 31, 2026 (Cohen & Company): balance sheet, operations, Note 6 repurchases, fair value hierarchy, board contract review. - CCLFX schedule of investments, June 30, 2026: portfolio mix, Level 3 rollforward, borrowings. - CCLFX distribution notice (19a), October 2026; fact page and 'Ten Things to Know', September 30, 2026. - Form N-PORT, June 30, 2026, and N-23C3A notices 2019 to 2026. - CELFX, CPEFX and CRAFX prospectuses, annual reports and fact pages; Cliffwater Form ADV amendment, October 8, 2026. ## Related - Full review (HTML): https://altstreet.investments/platforms/reviews/cliffwater - Every platform review: https://altstreet.investments/platforms/reviews - Methodology and scoring: https://altstreet.investments/platforms - Category hub: https://altstreet.investments/categories/private-credit-rbf --- Source page: https://altstreet.investments/platforms/reviews/cliffwater Machine index: https://altstreet.investments/llms.txt AltStreet reads what platforms, funds and issuers file with the SEC and what they tell investors, and publishes the difference. Figures are as filed or as captured on the date stated; nothing here is investment advice.