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.
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What the data actually shows - TL;DR
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.
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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.
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%.
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.
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.
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.
Quick Verdict
Is this platform right for you?
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.
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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.
Avoid if
- You may need the money within a year.
- You judge the fund by its distribution rate.
- You want independently priced assets.
Top 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.
Key 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.
Compare Before Deciding
Where Cliffwater fits against alternatives
Use these hooks to pressure-test whether this is the right platform, or whether a nearby alternative matches the job better.
How this compares to The Private Shares Fund Review
The Private Shares Fund Review
Another interval fund whose repurchase offers have been prorated.
How this compares to Percent Review
Percent Review
Private credit sold to individual investors deal by deal.
How this compares to The Private Shares Fund
The Private Shares Fund
Interval fund of late-stage private companies; repurchases prorated since 2025.
Quick Answers
What most investors want to know first
The highest-signal facts first: minimums, liquidity reality, K-1 timing, and whether distributions are actually part of the experience.
Minimum
$10 million (firm level) for CCLFX and CELFX Class I; $25 million for the Cascade funds; $50,000 for CLDFX; no investor qualification.
Liquidity
No secondary market; exit only through the fund's offers, which bought the full 7% available in March 2026.
K-1 Timing
No K-1; Form 1099-DIV.
Distributions
Calendar published by each fund.
Overview
Platform Overview
A concise read on what the platform is, how the structure works, and where the practical friction shows up for real investors.
Cliffwater sells four registered closed-end funds that operate as interval funds: investors buy at the daily NAV through a financial adviser or brokerage platform, and the fund offers at set intervals to buy back a fixed share of its stock at NAV. The Corporate Lending Fund (CCLFX, $30.4 billion of net assets at June 30, 2026) and the Enhanced Lending Fund (CELFX Class I and CLDFX Class D, $7.8 billion) offer quarterly to buy back 5% of shares, with discretion to buy 2% more if more is tendered (CCLFX's fundamental policy allows offers of 5% to 25%); when tenders exceed the amount bought, purchases are cut back pro rata. The Cascade Private Capital Fund (CPEFX, $6.0 billion), a former Barings fund Cliffwater took over in February 2024, and the Cascade Real Assets Fund (CRAFX), launched in 2026, offer semiannually.
The stated minimum is $10 million (CCLFX, CELFX Class I) or $25 million (Cascade funds) at the firm level, and $50,000 for CLDFX, so in practice investors reach the funds through advisers who aggregate accounts; there is no accredited-investor requirement. Cliffwater is paid a management fee on net assets (1.00% CCLFX, 0.95% CELFX, 1.40% Cascade funds) and no incentive fee, and the funds pay the fees of the private funds, BDCs and CLOs they hold.
Its Form ADV (October 8, 2026) reports $48.5 billion of regulatory assets in 25 accounts, $43.9 billion of it in three registered funds, and 213 employees. The Corporate Lending Fund began investing on June 5, 2019, grew to $15.5 billion of net assets by the end of 2023 and $31.5 billion by the end of 2025, and is held mostly through omnibus accounts at Schwab (42.6%), Fidelity's National Financial Services (32.7%) and Pershing (9.4%). Cliffwater calls itself 'the largest interval fund provider'.
What it is
Sponsor of four registered interval funds sold through advisers at daily NAV; Cliffwater LLC is the investment manager (SEC-registered adviser, CRD 132167).
Flagship
Cliffwater Corporate Lending Fund (CCLFX): $30.4 billion of net assets at June 30, 2026; senior loans 76.3%, private CLOs 27.8%, BDCs 7.5% of net assets.
Other funds
Enhanced Lending (CELFX/CLDFX, $7.8 billion), Cascade Private Capital (CPEFX, $6.0 billion), Cascade Real Assets (CRAFX, launched 2026).
Costs
CCLFX 3.20% total (1.00% management fee, 1.68% borrowing, 0.21% acquired fund fees, 0.31% other); CELFX 2.94% / 3.79%; CPEFX 2.80%; no incentive fee at fund level.
Returns
CCLFX 9.17% a year net from June 2019 to September 2026; 6.59% over one year; distribution rate 8.5%.
Liquidity
CCLFX and CELFX: quarterly offers, each for 5% of shares since 2019, up to 7% at the board's discretion (CCLFX policy allows 5% to 25%); Cascade funds: semiannual.
Minimum
$10 million (firm level) for CCLFX and CELFX Class I; $25 million for the Cascade funds; $50,000 for CLDFX; no investor qualification.
Legal record
Cliffwater LLC is a defendant in a 2020 civil rights suit over New Jersey pension mandates, unrelated to the funds; no SEC action located in the sources searched; Form ADV disciplinary items all 'No'.
Visual Summary
CCLFX repurchase offers, fiscal 2025 to 2026
Amount bought and share of outstanding shares bought in each quarterly offer. Each offer was for 5% of shares with discretion to buy 2% more. Sources: N-CSR for the years ended March 31, 2025 and 2026; May 2026 from the June 2026 Form N-PORT (AltStreet derivation). Requests are not disclosed in any filing.
May 15, 2024
Amount bought
$389.4M
% of shares bought
1.99%
NAV per share
$10.62
Aug 14, 2024
Amount bought
$558.3M
% of shares bought
2.58%
NAV per share
$10.68
Nov 13, 2024
Amount bought
$695.3M
% of shares bought
2.92%
NAV per share
$10.66
Feb 19, 2025
Amount bought
$595.1M
% of shares bought
2.24%
NAV per share
$10.66
Jun 9, 2025
Amount bought
$1,025.3M
% of shares bought
3.42%
NAV per share
$10.76
Sep 8, 2025
Amount bought
$917.5M
% of shares bought
2.90%
NAV per share
$10.72
Dec 9, 2025
Amount bought
$1,756.7M
% of shares bought
5.32%
NAV per share
$10.67
Mar 10, 2026
Amount bought
$2,344.0M
% of shares bought
7.00%
NAV per share
$10.52
May 29, 2026
Amount bought
about $1,577.9M
% of shares bought
about 5%
NAV per share
$10.39 (notice)
Investor Operations
The practical questions investors actually care about: when tax documents arrive, how cash distributions work, and whether capital can be exited before the underlying asset is sold.
Tax Documents
K-1 Timing
What to expect
No K-1; Form 1099-DIV.
Cash Flow
Distributions
Frequency
Quarterly (CCLFX, CELFX); annual (CPEFX, CRAFX).
Timing
Calendar published by each fund.
Consistency
CCLFX distributions exceeded net investment income in the year to March 2026.
Liquidity
Exit Reality
Holding period
None contractually; exit only through the repurchase offers.
Exit options
- Tender in the quarterly repurchase offer.
Secondary market
No secondary market; exit only through the fund's offers, which bought the full 7% available in March 2026.
Investment Structures
Cliffwater Corporate Lending Fund (CCLFX)
Class I only; $30.4 billion of net assets at June 30, 2026; quarterly repurchase offers of 5% (up to 7%); 1.00% management fee, 3.20% total expenses.
Cliffwater Enhanced Lending Fund (CELFX Class I, CLDFX Class D)
Fund of private credit funds; $7.8 billion; quarterly offers; 2.94% (I) and 3.79% (D) total expenses; Class D has a load of up to 2.00% and a $50,000 minimum.
Cascade Private Capital Fund (CPEFX)
Private equity funds, secondaries and co-investments; $6.0 billion; semiannual offers; 2.80% total expenses plus underlying carry.
Cascade Real Assets Fund (CRAFX)
Real estate and infrastructure funds and co-investments; effective August 28, 2026; semiannual offers; management fee waived to August 28, 2027.
Risk
Risk Structure
This is where the marketplace pitch gives way to the actual operating reality: delayed exits, limited disclosure, fee drag, and path-dependent outcomes.
Liquidity
CCLFX bought 7% in March 2026, the full amount available under that offer, and about 5% in May 2026; requests exceeded the original 5% offer in December and March, and no filing states whether any went unfilled.
Costs
3.20% of net assets for CCLFX, including 1.68% borrowing and 0.21% acquired fund fees; which underlying vehicles the 0.21% covers is not shown.
Valuation
About 97% Level 3 or manager-reported NAV; Cliffwater is valuation designee; daily NAV moved by estimated returns.
Leverage
Notes and credit facility about 29% of net assets, secured on all fund assets, plus leverage inside CLO equity and levered funds.
Distributions
FY2026 distributions exceeded net investment income by $313.5 million; about 10% of the October 2026 payment estimated as return of capital.
You may not get out when you want
Each quarterly offer sets how much the fund will buy (5% of shares since 2019, up to 7% at the board's discretion), and requests above that are cut back pro rata.
Why it matters
CCLFX bought more than 5% in December 2025 and the full 7% in March 2026, which it does only when requests exceed 5%; whether any requests went unfilled is not disclosed. When requests exceed the amount bought, a holder who needs cash waits for later offers, and the prospectus warns that proration 'may cause some investors to tender more Shares for repurchase than they wish'.
Mitigation / verification
Ask the adviser or platform for the last four quarters' tender and proration figures before buying, and size the position as money you can leave for years.
Costs are higher than the management fee suggests
CCLFX's total annual expenses are 3.20% of net assets: 1.31% of management and operating expenses, 1.68% of borrowing costs and 0.21% of acquired fund fees.
Why it matters
Borrowing is the largest line and moves with rates and the amount borrowed: FY2026 borrowing-related costs were about 1.97% of average net assets, above the 1.68% in the table. The prospectus does not show which underlying vehicles the 0.21% covers. Published net returns are after all of these costs.
Mitigation / verification
Compare the fund's net return, not its yield, with a listed leveraged loan fund or BDC index over the same period.
Values come from the managers and Cliffwater
About 97% of investments are Level 3 or valued at manager-reported NAV, with Cliffwater as the board's valuation designee.
Why it matters
Repurchases and purchases happen at that NAV; if values later prove too high, the prospectus says remaining holders bear it and those who left received 'a windfall'.
Mitigation / verification
Read the quarterly schedules of investments for marked-down loans and non-accruals, and ask whether any independent firm reviews the marks.
Payout above earnings
Distributions exceeded net investment income by $313.5 million in the year to March 2026, and part of the current payout is estimated return of capital.
Why it matters
Return of capital for tax purposes reduces the investor's cost basis, and the 19a figure is an estimate; the final character is on the year-end Form 1099-DIV. Separately, CCLFX's NAV per share fell from $10.83 to $10.52 in that year.
Mitigation / verification
Track the 19a notices and NAV per share, not the distribution rate.
Leverage and layered leverage
CCLFX borrows about 29% of net assets against all its assets and owns CLO equity and levered funds that borrow again.
Why it matters
In a credit downturn, losses in the levered layers reach NAV faster, and the prospectus says the fund 'might also be required to de-leverage, selling securities at a potentially inopportune time'.
Mitigation / verification
Watch the CLO equity share (27.8% of net assets in June 2026) and the asset coverage in each report.
Regulatory & Legal Posture
Security Status
Each fund is a closed-end management investment company registered under the Investment Company Act of 1940 and operated as an interval fund under Rule 23c-3; shares are registered under the Securities Act and sold continuously. Cliffwater LLC is an SEC-registered investment adviser (801-63344). The funds file annual and semiannual reports (N-CSR), monthly portfolio reports (N-PORT) and repurchase notices (N-23C3A).
Registration brings audited annual reports, an independent board majority, custody at a bank and daily NAV, but it does not make the underlying private assets liquid or independently priced.
- Cliffwater LLC is a defendant in Blueprint Capital Advisors, LLC v. State of New Jersey et al. (D.N.J. 2:20-cv-07663, filed June 23, 2020), a civil rights suit under 42 U.S.C. 1981 brought by a New Jersey investment manager against state investment officials, BlackRock, Owl Rock and Cliffwater over the award of state pension mandates. It does not concern the funds or their investors, and AltStreet treats it as background; a renewed motion to dismiss filed August 20, 2026 is pending.
- No SEC litigation release or administrative proceeding naming Cliffwater, its funds or Stephen Nesbitt was located in the sources searched (SEC releases 1995 to October 27, 2026); Form ADV disciplinary disclosures are all 'No'.
- SEC co-investment exemptive order granted August 11, 2026 (Release 36292) for the funds and Cliffwater.
- Cliffwater paid S&P for the rating services behind the 'A' rating it cites for CCLFX ('Cliffwater provided compensation for the ratings services provided') and paid PEI Group in connection with the PDI awards it cites ('Cliffwater LLC has provided compensation to PEI Group'). Paying for rating services is common; neither disclosure says the rating or the awards depended on the payment.
Disclosure Quality
Full position-level schedules of investments, audited annual statements and repurchase results by quarter; requests and proration are not reported, and the acquired fund fees computation is not shown.
Custody Model
Fund assets are held by State Street Bank and Trust (UMB Bank for CRAFX); UMB Fund Services is administrator and transfer agent; private fund interests are recorded in the funds' names.
Regulatory Backing
Investment Company Act protections (board, custody, asset coverage limits) apply; there is no deposit insurance or guarantee.
Tax Treatment
Reporting
Form 1099-DIV; the funds elect to be taxed as regulated investment companies.
CCLFX and CELFX distribute quarterly; the Cascade funds annually.
Income Character
Mostly ordinary income dividends
Interest from private loans is distributed as ordinary income, not qualified dividends; CCLFX's 2025 tax-year distributions were $3.07 billion of ordinary income. Part of a distribution may be return of capital, which is not taxed when paid but reduces the investor's cost basis; the funds' 19a notices give estimates, and the final character is on the year-end 1099-DIV.
Limitation
AltStreet is not a tax adviser; the tax character of distributions is set after year end.
Special Considerations
- Because most income is ordinary, the funds are often held in tax-deferred accounts.
- Return of capital estimates in the 19a notices can differ from the year-end tax character.
Account Suitability
Taxable
Possible; ordinary income taxed at the investor's rate.
Roth IRA
Common through advisory platforms.
Traditional IRA
Common through advisory platforms.
HSA
Depends on the custodian's platform.
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AltStreet Data Layer
What the data actually shows
What the filings show about CCLFX's repurchases, payout and portfolio over the last year.
Repurchases nearly tripled
$6.04 billion bought in the year to March 2026 against $2.24 billion the year before; 7.00% of shares in March 2026, the full amount available under that offer.
What this means
Requests exceeded the original 5% offer in December and March; whether they exceeded the amount bought is not disclosed.
Loan share fell, CLO share rose
Senior loans fell from 85.2% to 76.3% of net assets in the quarter to June 2026, with $6.86 billion of sales and paydowns against $3.56 billion of purchases; private CLOs rose from 24.7% to 27.8%.
What this means
The filings do not say why; the decline combines sales and contractual paydowns.
Distributions above net investment income
Distributions $3.07 billion, net investment income $2.76 billion, NAV per share $10.83 to $10.52 in the year to March 2026.
What this means
The October 2026 notice estimates about 10% of that payment as return of capital, subject to the year-end tax characterization.
Debt is about 29% of net assets
Notes $6.41 billion and facility $2.44 billion at June 30, 2026 ($8.85 billion), per the fund's schedule of investments. The June 2026 Form N-PORT reports $20.75 billion of liabilities, a figure that does not match the fund's own.
What this means
AltStreet uses the fund's figures; the filings do not explain the N-PORT discrepancy.
Data as of 2026-10-29 . AltStreet review evidence layer . Public-source analysis
Full datasetDecision Fit
Investor Fit
Who this works for, who it does not, and what level of patience and complexity tolerance the platform really demands.
Investors with an adviser who want private credit income and can leave the money for years
The return record is steady and losses low, but expenses are 3.20% a year, values rest on significant judgment and the exit is limited to each offer's size.
Investors who may need the money within a few quarters
Exit is only through quarterly offers of a set size, with requests above it cut back pro rata.
Tradeoffs
Key Tradeoffs
The attraction of pre-IPO access is real, but every benefit comes bundled with a corresponding liquidity, transparency, or pricing cost.
Return
Total annual expenses of 3.20% of net assets.
Liquidity
Each offer buys a set amount (5% of shares, up to 7%); the full 7% was bought in March 2026.
Pricing
The NAV rests on manager marks and estimated returns, with Cliffwater as valuation designee.
Avoid
Who This Is Not For
This section should be read as a filter, not an afterthought. If you need income, simplicity, or near-term access to capital, the structure is working against you.
Anyone who may need the money within a year
Exit is only through quarterly offers of a set size, cut back pro rata when requests exceed it.
Investors who read the distribution rate as yield
Distributions exceeded net investment income in the latest fiscal year.
Investors without an adviser
The funds are sold through advisers and platforms with firm-level minimums.
Editorial View
AltStreet Perspective
The compressed version of the review: what matters, what marketing tends to obscure, and how we would frame the platform for a serious allocator.
Verdict
Cliffwater's funds do what they say: they hold real private credit portfolios, report them in detail, and have paid steady income for seven years. The questions are about price and exit. The fund costs about 3% a year, its values are set largely by the managers it invests with and by Cliffwater, and its quarterly repurchases, sold as matching the natural repayment of the loans, have grown since late 2025 while inflows slowed, using the discretionary extension in December and March. The record shows larger repurchases met in an orderly way, not a fund in distress. The fund also bought 7% in May 2020; how today's $30 billion portfolio, with 27.8% in private CLOs, would behave in another downturn is the open question.
Positioning
Against non-traded BDCs such as Blue Owl Credit Income or HPS Corporate Lending, CCLFX offers broader diversification across lenders and no incentive fee, with similar limits on exit and similar reliance on internal marks. Against listed BDCs and leveraged loan funds, it offers smoother reported returns and higher income, in exchange for daily liquidity and market pricing.
The Bottom Line
The largest interval fund family in the US: steady private credit income at about 3% a year in costs, with values set by the managers and an exit limited to each quarterly offer.
Action
Next Steps
If you still want to engage after reading the review, these are the practical next moves that reduce avoidable mistakes.
Ask the adviser or platform for each of the last four repurchase offers: shares tendered, shares bought and the proration factor.
Read the latest 19a distribution notice to see how much of the payout is estimated return of capital.
Compare CCLFX's net return over one and three years with a listed BDC or leveraged loan fund over the same period.
Check the quarterly schedule of investments for the share in private CLOs and BDCs, and for marked-down loans.
Ask whether any independent firm reviews Cliffwater's valuations and the daily return estimates.
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Deal Intelligence →Appendix
Sources, Disclosures, and Supporting Context
The lower section is structured like a report appendix: relationship context first, adjacent reading second, and evidence last.
Report Appendix
Disclosure
Relationship and compensation context
+
Report Appendix
Disclosure
Relationship and compensation context
Report Appendix
Related Resources
Adjacent platform comparisons, frameworks, and category links
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Report Appendix
Related Resources
Adjacent platform comparisons, frameworks, and category links
Further Reading
Related Resources
Adjacent frameworks and reviews that help place the platform in a broader allocation or due-diligence context.
Frameworks
Similar Platform Reviews
- The Private Shares Fund Review
Another interval fund whose repurchase offers have been prorated.
- Percent Review
Private credit sold to individual investors deal by deal.
Report Appendix
Evidence & Methodology
6 cited passages on file; sources, scope, and how the review was assembled
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Report Appendix
Evidence & Methodology
6 cited passages on file; sources, scope, and how the review was assembled
Evidence on file
6 supporting passages on file for Cliffwater and its offerings from 3 source documents, 6 verified by an analyst through 2026-10-29, no discrepancies flagged. Each passage records the metric it supports, the value read from the document, the page, and the verbatim text where the document has it. Terminal subscribers read the passages; open them in the terminal.
- Cited passages
- 6
- Source documents
- 3
- Analyst verified
- 6
- Discrepancies flagged
- 0
Latest analyst verification 2026-10-29; latest extraction 2026-10-29. A discrepancy is a disagreement between two sources, or between a document and a marketing claim, recorded rather than resolved silently.
ASReview Evidence
Methodology
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.
Scope
Cliffwater LLC and its four registered funds, with the Corporate Lending Fund as the main subject, from public sources only.
Key Findings
- *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
Comparable Platforms
- The Private Shares Fund
Interval fund of late-stage private companies; repurchases prorated since 2025.
- Percent
Private credit notes sold deal by deal to accredited investors.
FAQ
Frequently Asked Questions
High-intent search questions answered directly, without making users hunt through the full review.
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.