Bridgewater Associates, LP

All figures below are the values reported in the filings themselves. Item numbers refer to Form ADV Part 1A unless the text says Part 2A. Quotations are the filing’s own wording.

Part 1A — Identity and registration

Part 1A — Regulatory assets under management (Item 5.F)

The non-U.S. share is 69.8% of total regulatory AUM. The firm reports no non-discretionary regulatory AUM, so every one of the 133 accounts is managed on a discretionary basis (Item 5.F(2)).

The Part 2A brochure states a different figure — approximately $102,400,000,000 of client assets as of 31 December 2025 (Part 2A Item 4). The firm answers “Yes” to Item 5.J(2), which asks whether it reports client assets in Part 2A Item 4.E computed using a different method than the method used to compute regulatory AUM.

Part 1A — Clients by type (Item 5.D)

Rows (a), (b), (d), (e), (j), (k) and (m) of Item 5.D are reported as zero: no individuals, no high net worth individuals, no investment companies, no business development companies, no other investment advisers, no insurance companies and no corporations or other businesses. Pooled investment vehicles account for 76.4% of regulatory AUM.

Part 1A — Services, compensation and affiliations

Compensation arrangements (Item 5.E)

• (1) A percentage of assets under management
• (6) Performance-based fees
• (7) Other, specified in the filing as “INVESTMENT ADVISORY SUPPORT SERVICES”

Types of advisory service (Item 5.G)

• (4) Portfolio management for pooled investment vehicles (other than investment companies)
• (5) Portfolio management for businesses (other than small businesses) or institutional clients
• (8) Publication of periodicals or newsletters
• (11) Educational seminars/workshops
• (12) Other, specified as “NON-DISCRETIONARY INVESTMENT ADVISORY SERVICES TO A REGISTERED INVESTMENT COMPANY”

Separately managed accounts (Item 5.K)

The firm answers “Yes” to all four questions: it has regulatory AUM attributable to clients other than separately managed account clients (5.K(1)); it engages in borrowing transactions on behalf of separately managed account clients (5.K(2)); it engages in derivative transactions on behalf of those clients (5.K(3)); and at least one custodian holds ten percent or more of the remaining regulatory AUM (5.K(4)).

Marketing (Item 5.L)

Advertisements include performance results (5.L(1)(a)), references to specific investment advice (5.L(1)(b)), endorsements (5.L(1)(d)), third-party ratings (5.L(1)(e)) and hypothetical performance (5.L(3)). Testimonials are not used (5.L(1)(c)). The firm answers “Yes” to 5.L(2): it pays or otherwise provides cash or non-cash compensation in connection with the use of endorsements or third-party ratings.

Other business and affiliations (Items 6 and 7.A)

• Item 6.A(3): the firm is also a commodity pool operator or commodity trading advisor.
• Item 7.A(2): related person that is another investment adviser.
• Item 7.A(16): related person that is a sponsor, general partner or managing member of pooled investment vehicles.
• Item 10.A: “No” — no person outside Item 1.A and Schedules A, B or C directly or indirectly controls the firm’s management or policies.

Proprietary interest, sales interest and discretion (Item 8)

• 8.A(1) Yes — principal transactions with advisory clients.
• 8.A(2) Yes — buys or sells for itself securities that it also recommends to advisory clients.
• 8.B(2) Yes — recommends to advisory clients the purchase of securities for which the firm or a related person serves as underwriter or general or managing partner.
• 8.C(1)–(4) Yes to all four — discretion over the securities bought or sold, the amount, the broker or dealer used, and the commission rates paid.
• 8.E Yes — the firm or a related person recommends brokers or dealers to clients; 8.F “No”, none of those brokers or dealers is a related person.
• 8.G(1) Yes — receives research or other products or services other than execution from a broker-dealer or third party (soft dollar benefits); 8.G(2) Yes — all such benefits are eligible “research or brokerage services” under section 28(e) of the Securities Exchange Act of 1934.
• 8.H(1) “No”; 8.H(2) Yes — employee compensation is provided that is specifically related to obtaining clients for the firm. 8.I “No”.

Part 1A — Private funds (Item 7.B and Schedule D Section 7.B.(1))

The firm answers “Yes” to Item 7.B (adviser to a private fund) and reports 38 private funds in Schedule D Section 7.B.(1), with combined gross asset value of $126,901,740,157. Of the 38, 37 are reported as hedge funds and 1 as a liquidity fund (Section 7.B.(1) Question 10). Every fund relies on the section 3(c)(7) exclusion; none relies on 3(c)(1) (Question 4). Every fund is subject to an annual audit and prepares financial statements in accordance with U.S. GAAP (Question 23.a). Organisation: 31 Cayman Islands, 5 Delaware, 2 British Virgin Islands (Question 2). Auditors named are KPMG LLP for 37 funds and Deloitte & Touche LLP for Bridgewater Pure Alpha Trading Company IV, LP (Question 23.b).

Ten largest private funds by gross asset value

Minimum investment commitment (Question 12) is $10,000,000 for most funds; four funds report $100,000, two report $0, two report $11,744,500 and two report $13,450,500, and Bridgewater Pure Alpha Fund III, Ltd. reports $6,668,500. Eleven funds report a non-zero percentage owned by the adviser and its related persons (Question 14), including Bridgewater Pure Alpha Trading Company IV, LP, BW CCF-8B Ltd. and Bridgewater Implementation Fund III, Ltd. at 100%, Bridgewater Special Opportunities Fund Trading Company, Ltd. at 92%, Bridgewater Event Risk Fund I, Ltd. at 91% and Bridgewater Short Term Investment Fund II, LLC at 79%.

Part 1A — Owners and control persons (Schedules A and B)

Schedule A — direct owners and executive officers

Schedule B — indirect owners

Codes are as printed on the schedules: DE = domestic entity, FE = foreign entity, I = individual. Schedule A ownership codes run NA (less than 5%) through E (75% or more). On Schedule B, code F is “Other (general partner, trustee, or elected manager)”. Robert Prince and Gregory Jensen are marked as control persons on Schedule B; the other board members are not.

Part 1A — Custody (Item 9)

The custody safeguard the firm relies on is the annual audit route in Item 9.C(2). It reports no surprise examination under Item 9.C(3). The amount subject to firm custody, $121,944,665,903, is 81.2% of total regulatory AUM.

Part 1A — Disciplinary information (Item 11)

Item 11 opens: “In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates.”

The firm answers “No” to every question in Item 11 — the preliminary question and all of 11.A(1)–(2), 11.B(1)–(2), 11.C(1)–(5), 11.D(1)–(5), 11.E(1)–(4), 11.F, 11.G and 11.H(1)–(2). No criminal, SEC, other regulatory, self-regulatory organisation or civil judicial event is disclosed for the firm or any advisory affiliate, and no Disclosure Reporting Pages are triggered.

Part 2A brochure — Advisory business (Item 4)

The brochure is titled “BRIDGEWATER ASSOCIATES, LP, PART 2A, MARCH 2026”, submitted 30 March 2026, 51 pages, Items 1 to 19. Bridgewater provides discretionary investment management to pooled investment vehicles and single investor funds and to managed account clients, and also provides non-discretionary investment advisory services to non-affiliated entities. It began investment operations in 1975 as a consulting business, began managing assets for institutional investors in 1985 and registered with the SEC in 1990. It publishes The Bridgewater Daily Observations, described as its flagship research publication — the activity reported at Part 1A Item 5.G(8).

Item 8 states the same figure differently and adds a client count:

Strategies and process

Item 4 states that Bridgewater structures portfolios “in a manner designed to produce consistent returns”, that risk allocations are more effective than capital allocations, and that investors should consider strategic asset allocation (beta) separately from tactical moves (alpha). Pure Alpha is described as the optimal alpha, seeking high returns with no bias to markets or other managers; All Weather as the optimal beta, seeking to capture risk premiums embedded in assets by balancing exposure to the primary drivers of market volatility. Item 4 also names “new sources of alpha (such as using artificial intelligence and machine learning to generate returns in markets)”.

The Investment Committee is responsible for all aspects of the investment process, including portfolio risk management, performance oversight and the governance and delegation of investment decision-making authority. It is led by Co-CIOs Bob Prince, Greg Jensen and Karen Karniol-Tambour. Bank of New York Mellon and Northern Trust act as primary and secondary providers of fund administration, middle and back office and custodial services under a tri-party model in which the secondary provider independently replicates and verifies certain activities of the primary provider.

Ownership and control

Item 4 adds structural detail that Part 1A Schedule A does not show. It names two direct owners, Bridgewater Associates Intermediate Holdings, LP (general partner and limited partner) and Bridgewater Partner, LLC (limited partner); Intermediate Holdings is the sole member of Bridgewater Partner, LLC and so is “effectively Bridgewater’s sole direct owner”. On the tier above:

Part 2A brochure — Fees and compensation (Item 5)

Fee arrangements vary by strategy and involve management fees (a percentage of assets), a profit participation (a percentage of profits) or a combination. The brochure publishes no fee schedule and no management fee or profit participation percentages. Profit participation is typically based on a percentage of profits for each calendar quarter or year and can be subject to adjustment for previous unrecovered net losses or underperformance against a benchmark. Performance fee arrangements are structured under Section 205(a)(1) and Rule 205-3 of the Advisers Act (Part 2A, Item 6).

Expenses and billing

Clients bear auditor fees, custodian fees, back and middle office fees, regulatory and legal expenses, transaction expenses including brokerage fees, and government filing fees. Funds bear ongoing offering expenses, with initial organisational expenses amortised in some cases over 36 months, and a long list of operating expenses running to investment expenses, research expenses, data, information systems and technology expenses, professional and legal fees, administration, insurance, compliance costs, a portion of the general partner’s operating expenses, and extraordinary expenses including litigation and government investigation costs and any judgment or settlement paid. A fund expense review group chaired by the Chief Financial Officer, with the Chief Compliance Officer and Counsel, the Head of Back Office and Operations, a senior attorney, a senior manager for client service and marketing and the Head of Investment Implementation, reviews and approves the expense types allocated to discretionary funds.

Item 5 discloses a fee-layering point and a vendor-pricing conflict. Where a strategy invests in a third-party managed commingled vehicle, that vehicle may charge additional asset-based or performance-based fees and “Bridgewater’s Management Fees and Profit Participation will not be reduced to the extent any such fees are paid”. On vendor rates, the brochure states there may be instances where service providers “may charge the funds different rates compared to the rates charged to Bridgewater, which may result in Bridgewater being subject to more favorable rates than those payable by the funds”.

Part 2A brochure — Performance-based fees and side-by-side conflicts (Item 6)

Item 6 names two specific conflicts. The first is preferential treatment:

The second is the incentive created by performance fees:

Part 2A brochure — Types of clients (Item 7)

The brochure’s client list is broader than the Part 1A Item 5.D table, which reports clients only in rows (c), (f), (g), (h), (i), (l) and (n) and reports zero investment company clients in row (d). Schedule D Section 7.B.(1) Question 12 shows minimum investment commitments of $10,000,000 for 27 of the 38 funds, with a floor of $0 for two.

Part 2A brochure — Risk disclosures (Item 8)

Item 8 runs from page 11 to page 38 and is organised in two blocks: “Risks of Investing in Certain Instruments” (pages 11 to 27) and “Additional Risks of Investing with Bridgewater” (pages 27 to 37). The overall statements of loss come first.

Instrument and market risks

Leverage and margin

Derivatives

Counterparty failure

Market liquidity

Emerging markets and non-U.S. legal protection

Fraud and government defaults

Additional risks of investing with Bridgewater

This second block covers the firm rather than the instruments. The model, technology and personnel risks are the ones specific to a systematic manager.

Model and strategy risk

Artificial intelligence tools

The brochure states that Bridgewater uses AI tools in managing fund and client portfolios, implemented “to varying degrees based on strategy, in connection with asset allocation decisions, pre-trade and post-trade descriptive, predictive, or prescriptive analysis, as well as throughout the associated research processes”, and that for specific strategies it uses one or more AI tools directly for investment and asset allocation decisions. On the failure mode:

Systems failure and cybersecurity

Reliance on the firm and its people

Capacity, past performance and loss of capital

Side letters

Closing statement of Item 8

Item 8 risk factor inventory

Risks of Investing in Certain Instruments — run-in sub-headings, alphabetical as printed:

Additional Risks of Investing with Bridgewater — run-in sub-headings:

Read down the left column, then the right. Sub-headings are run-in at the start of each paragraph rather than set as separate lines.

Part 2A brochure — Items 9 to 19

Disciplinary information (Item 9)

Other financial industry activities and affiliations (Item 10)

Item 10 also discloses that Northern Trust and Bank of New York Mellon, or their affiliates, manage certain cash management vehicles that Bridgewater recommends or selects for discretionary clients, selected on yield, safety and liquidity and on the operational efficiency of using a cash vehicle managed by the account’s custodian. Two wholly owned foreign affiliates are named: Bridgewater (China) Investment Management Co., Ltd. in Shanghai, granted a Private Fund Manager licence by the Asset Management Association of China in June 2018, which does not provide investment advisory services to Bridgewater; and Bridgewater Associates (Singapore) Management, PTE. LTD., granted a Capital Markets Services licence by the Monetary Authority of Singapore in July 2022 and a foreign private adviser to Bridgewater.

Code of ethics, participation or interest in client transactions and personal trading (Item 11)

The Code of Ethics is adopted under Rule 204A-1 and approved by the board of trustees of the investment company clients. Personal trading controls include duplicate statements or electronic feeds for all full-time employees and subjected consultants rather than only access persons, pre-clearance of most trades, a 60-day holding period for profitable trades, a permitted-instrument list, and a requirement to hold most account types at an approved broker with a direct electronic feed. This is the item behind the “Yes” answers at Part 1A Items 8.A(1) and 8.A(2).

Item 11 also discloses that Bridgewater recommends that clients invest in commingled funds in which it or a related person acts as member manager, manager, investment manager or director, or in which Bridgewater, its affiliates, their officers, directors, partners, members, employees or agents have invested or may invest, stating that the decision to recommend is “based solely on the suitability of the investment for the particular Client”.

Brokerage practices (Item 12)

Counterparties are onboarded after due diligence on competitiveness, risk and operational capability, then compete for business on proprietary execution performance metrics. On soft dollars, the brochure’s wording is narrower than the Part 1A Item 8.G(1) “Yes”:

On allocation, the policy is to aggregate where advantageous, to prohibit any allocation giving proprietary, affiliated or particular client accounts more favourable treatment over time, and to allocate pro rata with randomisation in account selection where purely proportional allocation is insufficient. Bridgewater generally does not engage in cross-trades. The error policy classifies only two things as trade errors — breach of a client’s guideline objectives, and a trade execution error requiring reversal — and states the consequence for a systematic manager:

Review of accounts (Item 13)

The Portfolio Implementation group monitors discretionary portfolio positions daily against guidelines coded into the portfolio construction system, with a separate independent back-end process assessing guideline compliance. Cash, trades and positions are reconciled daily between the middle office book of record and external counterparties and custodians, and monthly between official and shadow books and records. Fund investors receive monthly performance and valuation statements from the fund administrators. Separately managed account clients receive monthly statements from both Bridgewater and their qualified custodians, and clients typically receive a quarterly report with portfolio and market commentary.

Client referrals and other compensation (Item 14)

Compensation is paid as a fixed fee, a performance fee or a percentage of revenue of assets raised, and is disclosed in relevant offering materials. Item 14 also discloses that Bridgewater invites consultants to events or entertainment it hosts and pays registration or other fees to participate in consultant-sponsored forums, and that “Bridgewater relies on each consultant to make appropriate disclosure to its clients of any conflict that the consultant believes to exist due to its relationship with Bridgewater”.

Custody (Item 15)

For separately managed accounts and non-discretionary clients the brochure states Bridgewater does not have custody, and it encourages clients to compare custodian statements against Bridgewater’s appraisal reports.

Investment discretion (Item 16)

Discretion is granted through the investment management agreements and is limited by each client’s investment guidelines, which may include tracking error or volatility targets, position and exposure limits, counterparty requirements and restrictions, prohibited investments and legal or regulatory restrictions. Bridgewater is generally authorised as agent and attorney-in-fact to sign fund subscription agreements and redemption notices, futures clearing agreements, master netting agreements, prime brokerage agreements, repurchase agreements, ISDA agreements and account control agreements. This is the authority reported at Part 1A Item 8.C(1) to (4).

Voting client securities (Item 17)

Glass, Lewis & Co. votes proxies where authority has been delegated to Bridgewater, under Rule 206(4)-6. Bridgewater generally subscribes to Glass Lewis policies, directing the benchmark policy for portfolios with traditional risk and return objectives, and reserves the right to direct a contrary vote. Fund investors cannot direct votes for the funds they are invested in. Bridgewater often declines to vote where expected costs exceed expected benefit or where voting would block a sale for a period. On class actions, it generally refrains from serving as lead plaintiff and will opt out where it expects to bring a direct claim or where the risk of information leakage or the effort of claiming outweighs the expected recovery. It generally does not file class action claims for separately managed account clients.

Financial information (Item 18) and state registration (Item 19)

Source note

Part 1A figures and answers are taken from the Form ADV Part 1A record for CRD 105129 as filed on 18 August 2026, together with Schedule A, Schedule B and Schedule D Section 7.B.(1), retrieved through the sec-api.io Form ADV endpoints. Form ADV item labels quoted in the Part 1A sections are quoted from Form ADV Part 1A as published by the SEC.

Part 2A text is taken from the full brochure PDF (51 pages, 484 KB) downloaded from the IAPD brochure URL for version 1032747, document properties “2026 Annual Amendment Form ADV Part 2A Clean”, created 30 March 2026. Every passage shown in quotation marks was matched character for character against that file. Ellipses mark omitted words inside a quotation; nothing else has been altered.