Diligence report Financial services, cloud-native brokerage, clearing, custody, financing and capital-markets infrastructure Private unicorn / growth-stage regulated financial infrastructure company

Clear Street

Clear Street Startup Diligence Report

The diligence thesis is that Clear Street may be building modern cloud-native brokerage, clearing, financing and workflow infrastructure for sophisticated market participants; to underwrite that thesis, investors must prove revenue quality, regulatory capital strength, customer/balance durability, product reliability, security controls and valuation support beyond company-owned marketing metrics.

Company profile

Clear Street Startup Diligence Report

Clear Street qualifies for continued private-unicorn diligence based on a CB Insights USD 2B valuation row and active company materials showing a large regulated capital-markets infrastructure business. Public evidence supports product breadth, client-scale claims and regulatory surface area, but investment underwriting remains blocked by private financial, cap-table, regulatory, customer, technology, legal and HR records.

Website: www.clearstreet.io
Sector: Financial services, cloud-native brokerage, clearing, custody, financing and capital-markets infrastructure
Geography: United States / New York headquarters with public office footprint across North America, Europe, Asia and Israel
Stage: Private unicorn / growth-stage regulated financial infrastructure company
Known aliases: Clear Street, Clear Street LLC, Clear Street UK Limited, Clear Street Derivatives LLC, Clear Street FCM, Clear Street Canada Inc., Clear Street Europe
Report version: 1.0
Timezone: UTC

Executive summary

Strengths

CB Insights lists Clear Street as a USD 2B Financial Services unicorn in New York.
Clear Street publicly markets a broad cloud-native platform across clearing, financing, execution/trading, investment banking and Studio tooling.
Company regulatory disclosures identify broker-dealer/FCM and UK FCA/LME regulatory surfaces.

Risks

Financial statements, revenue quality, cash/burn, debt and regulatory capital are not public.
Regulated broker-dealer, FCM and international financial-services operations create high compliance and capital-risk diligence needs.
Customer identities, balance concentration, churn, contracts and retention are not public despite aggregate client-scale claims.
Cloud-native trading/clearing/custody infrastructure requires independent security and operational-resilience evidence.

Gaps

Audited financials, management accounts, revenue by product, gross margin, cash, debt, burn, runway and regulatory capital reports.
Fully diluted cap table, financing documents, preference stack, debt/notes, investor rights and current valuation support.
Top-customer revenue/balance concentration, churn/NRR, customer contracts, references and pipeline.
Security/technology artifacts: SOC reports, penetration tests, incidents, BCP/DR, architecture and vendor-risk files.
Regulator extracts, examination letters, enforcement searches, counsel letters, docket searches and material contracts.
HRIS, org chart, attrition, compensation/equity, retention and international employment compliance.

Recommended next steps

Run confirmatory financial, regulatory-capital and cap-table diligence before relying on the public valuation signal.
Prioritize customer/balance concentration, churn, contract and reference-call workstreams.
Conduct regulatory/legal diligence across FINRA/SIPC, CFTC/NFA, FCA/LME and international entities.
Run technical/security diligence on cloud-native platform, Studio, trading systems, incident history and operational resilience.
Review product-level economics, pricing, gross margin and competitive displacement.

Risk register

high high likelihood

R-001: Financial opacity

Audited financials, ARR/revenue, gross margin, cash, burn, debt, regulatory capital and runway are not public despite large operating-scale claims.

Diligence request: Request audited financials, management accounts, revenue bridge, product margins, regulatory capital reports, cash/debt schedule and forecast model.

high high likelihood

R-002: Regulatory and clearing/FCM exposure

Broker-dealer, FCM, UK FCA/LME and international operations create capital, compliance, customer-asset, supervision and enforcement risks.

Diligence request: Obtain regulator extracts, examination correspondence, enforcement searches, capital reports, compliance policies, surveillance records and counsel letters.

high medium likelihood

R-003: Customer and balance concentration opacity

Aggregate client and balance metrics are public, but top-account concentration, customer profitability, churn and contract terms are not.

Diligence request: Request customer/balance concentration schedules, top contracts, churn/NRR, references and balance volatility analysis.

high medium likelihood

R-006: Cybersecurity and operational resilience

Cloud-native trading, clearing, custody, financing and client portals require strong security, availability and disaster-recovery controls; public pages do not disclose independent audits.

Diligence request: Request SOC reports, penetration tests, incident logs, BCP/DR tests, vendor-risk program, access controls and client SLA history.

medium high likelihood

R-004: Valuation and capital-structure uncertainty

CB Insights lists a USD 2B valuation and company materials cite large financing rounds, but current valuation, liquidation preferences, debt and investor rights are private.

Diligence request: Request full cap table, financing documents, preference stack, option pool, debt/notes, secondary transactions and 409A reports.

medium high likelihood

R-005: Product expansion and execution complexity

Rapidly expanding service lines, asset classes, acquisitions and international footprint increase product delivery, integration and operational-risk complexity.

Diligence request: Run product/technology diligence on roadmap, uptime, incidents, integrations, acquisition integration, SLAs and product-level economics.

medium high likelihood

R-007: Competition and pricing pressure

Clear Street competes with incumbent prime brokers, clearing firms and fintech brokers that can pressure pricing, balance-sheet economics and client acquisition.

Diligence request: Benchmark pricing, win/loss records, margin by product, competitor displacement, customer references and sales-cycle metrics.

medium medium likelihood

R-008: International expansion complexity

Offices and regulated entities across multiple jurisdictions raise entity management, labor, tax, licensing, supervision and data-governance complexity.

Diligence request: Request entity chart, local regulatory status, tax/legal memos, HR compliance, cross-border data flows and integration plans.

Chapter 01

01Financial Information

Clear Street has strong public scale and unicorn signals, including a CB Insights USD 2B valuation row and company-owned metrics for capital raised, clients, balances and trading activity. Underwriting remains blocked by missing audited financials, revenue quality, regulatory capital, debt/cash and cap-table records.

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I.A Annual and quarterly financial information for the past three years

not publicly verifiable confidence: high

Public sources disclose scale metrics but not audited financial statements, ARR/revenue, gross margin, cash, burn, debt, regulatory capital or runway.

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Evidence gaps

Audited financials, management accounts, revenue bridge, regulatory capital reports and forecast model were unavailable.

Hidden risks

Audited financials, ARR/revenue, gross margin, cash, burn, debt, regulatory capital and runway are not public despite large operating-scale claims.

Follow-up questions

Provide audited financial statements, monthly management accounts, revenue by product, cash/debt schedule, regulatory capital and forecast support.

Public financial and operating metrics versus private-data needs
metric	public value	source context	verification status	private data needed
Capital raised	USD 1.0B	Company homepage/About page	partially_verified	Cap table, financing ledger, debt/equity classification.
Institutional clients	700+ / about 700	Homepage and About page scale metrics	partially_verified	Customer list, active/inactive definition, segment revenue.
Customer balances	about USD 16B	Homepage and About page scale metrics	partially_verified	Daily/monthly balance history, segregation, concentration and financing balances.
Daily activity	about 550M shares/day and USD 28.4B notional/day	About page scale metrics	partially_verified	Time period, methodology, client mix and product contribution.
Revenue, gross margin, cash, burn, debt, runway	—	No gathered public source disclosed these metrics	not_publicly_verifiable	Audited financials, management accounts, revenue bridge, debt/cash schedule and forecast model.

Public funding and valuation anchors Bar chart of publicly disclosed funding/valuation anchors and gaps.

I.B Capitalization, ownership and financing history

partially verified confidence: medium

CB Insights lists Clear Street as a USD 2B unicorn and company sources list major Series B funding events, but ownership, preferences and current valuation remain private.

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Evidence gaps

Cap table, preference stack, investor rights, secondary transactions, debt/notes and 409A reports were not public.

Hidden risks

CB Insights lists a USD 2B valuation and company materials cite large financing rounds, but current valuation, liquidation preferences, debt and investor rights are private.

Follow-up questions

Provide fully diluted cap table, financing documents, investor rights, liquidation preferences, option pool, debt/notes and current valuation support.

Public funding and valuation timeline
date	event	public amount usd m	public valuation usd b	verification status	diligence request
2018-09	Clear Street founded	—	—	verified	Formation documents, founder equity, initial capitalization.
2022-04/05	CB Insights unicorn row and company Series B event	165	2	partially_verified	Series B purchase agreement, valuation support, investor rights and preference stack.
2023-12	Additional Series B funding increasing round to USD 685M	520	—	verified	Second tranche terms, post-money valuation, new/inside investor participation.
current public site	Company claims USD 1.0B capital raised	1000	—	partially_verified	Reconcile total capital raised to cap table, debt and secondary transactions.

Capital structure and ownership snapshot from public sources
stakeholder	public position	evidence	diligence caveat
Prysm Capital	Selected investor in CB Insights row	CB Insights Clear Street row	Ownership percentage, round participation and rights not public.
NextGen Venture Partners	Selected investor in CB Insights row	CB Insights Clear Street row	Ownership percentage and rights not public.
McLaren Strategic Ventures	Selected investor in CB Insights row	CB Insights Clear Street row	Ownership percentage and rights not public.
Founders, executives and employees	Company founded and led by industry experts; 800+ employees	About/Careers pages	Founder equity, option pool and retention grants not public.

Chapter 02

02Products

Clear Street publicly markets a broad cloud-native platform across clearing, financing, execution/trading, investment banking and Studio workflow tools. Product breadth appears meaningful, but pricing, product P&L, reliability, security and adoption data are not public.

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II.A Products, services and customer-facing capabilities

verified confidence: high

Clear Street publicly describes clearing, financing, execution/trading, investment banking and Studio products for multiple capital-markets customer segments.

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Evidence gaps

Product-level revenue, adoption, SLAs and customer ROI are not public.

Hidden risks

Rapidly expanding service lines, asset classes, acquisitions and international footprint increase product delivery, integration and operational-risk complexity.
Clear Street competes with incumbent prime brokers, clearing firms and fintech brokers that can pressure pricing, balance-sheet economics and client acquisition.

Follow-up questions

Provide product P&L, customer usage, roadmap, implementation backlog, support metrics and client references.

Product and service matrix
product or service	public description	target users	verification status	diligence test
Clearing	Real-time transparency, cross-asset flexibility and modern clearing infrastructure	Sophisticated market participants	verified	Clearing volumes, margin, settlement fails, client assets and regulatory capital.
Financing	Integrated cash and synthetic financing solutions	Funds, family offices and institutions	verified	Financing balances, spreads, collateral policy, counterparty limits and loss history.
Execution and trading	Advanced algorithms, liquidity access and support	Traders, broker-dealers, market makers and funds	verified	Order routing, best execution, algorithm performance and venue economics.
Investment banking	Advisory and capital-markets support for innovators, founders, executives and investors	Corporate issuers and investors	verified	Engagement letters, revenue pipeline, conflicts and licenses.
Clear Street Studio	Portfolio, financing, risk and execution tooling	Asset managers and trading clients	verified	Usage, uptime, roadmap, feature adoption and client ROI.

Clear Street public product architecture map Architecture-style map of public product modules and dependencies.

II.B Product economics, pricing and technical dependencies

not publicly verifiable confidence: high

Public pages list product capabilities but do not disclose standardized pricing, take rates, financing spreads, contribution margin or independent security/reliability evidence.

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Evidence gaps

Pricing, margin, uptime, incidents, SOC reports and cloud/vendor contracts were unavailable.

Hidden risks

Audited financials, ARR/revenue, gross margin, cash, burn, debt, regulatory capital and runway are not public despite large operating-scale claims.
Cloud-native trading, clearing, custody, financing and client portals require strong security, availability and disaster-recovery controls; public pages do not disclose independent audits.
Clear Street competes with incumbent prime brokers, clearing firms and fintech brokers that can pressure pricing, balance-sheet economics and client acquisition.

Follow-up questions

Provide SKU/fee schedule, contracts, invoices, product gross margin, SOC reports, incident logs and architecture review materials.

Asset-class and platform scope
asset class or capability	public status	evidence basis	risk or gap
Equities and options	Listed as supported asset classes	Services page asset-class list	Need volumes, margin and venue routing economics.
Futures	Listed asset class; About journey says futures clearing began in 2024	Services and About pages	Need FCM controls, capital and segregation review.
Fixed income, FX, swaps, commodities and repo	Listed as supported asset classes	Services page asset-class list	Need product maturity, client adoption and risk limits by asset class.
Digital assets	Services page says coming soon; newsroom lists digital asset trading launch/partnership activity	Services and Newsroom pages	Need regulatory, custody, counterparty and compliance controls.

Pricing and monetization diligence matrix
service line	public pricing signal	likely revenue driver	verification status	private data needed
Clearing and custody	No public tariff card located	Clearing fees, custody/servicing and balance-related economics	not_publicly_verifiable	Fee schedules, invoices, contracts and revenue-recognition memo.
Financing	No public rates located	Financing spreads and collateral usage	not_publicly_verifiable	Financing book, spread history, collateral policy and counterparty limits.
Execution/trading	No public fee schedule located	Execution commissions, routing economics and algorithmic services	not_publicly_verifiable	Order-routing economics, best-execution reviews and client fee schedules.
Studio/SaaS-like tooling	Request-a-demo motion; no published pricing	Bundled platform fees or included workflow tooling	not_publicly_verifiable	SKU list, contracts, usage and product P&L.

Chapter 03

03Customer Information

Public evidence supports aggregate client scale and target segments but not customer identities, concentration, balances by customer, churn, renewal terms, NRR or references. This is a core diligence gap for a brokerage/clearing platform.

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III.A Customers, references, concentration and churn

partially verified confidence: medium

Clear Street claims about 700 institutional clients and describes target customer segments, but top-customer revenue, balance concentration, churn and contract terms are not public.

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Evidence gaps

Top-customer schedule, customer revenue, balances, churn/NRR and references were unavailable.

Hidden risks

Aggregate client and balance metrics are public, but top-account concentration, customer profitability, churn and contract terms are not.

Follow-up questions

Provide customer/balance concentration, contract terms, churn/NRR, pipeline, references and customer calls.

Publicly identified customer segments and concentration gaps
segment	public evidence	revenue or balance weight	verification status	follow up
Institutional clients aggregate	Company claims 700+ institutional clients/about 700 institutional clients	Aggregate count only; no revenue share	partially_verified	Active client definition, revenue/balance concentration and churn.
Hedge funds/emerging managers	Clients page describes emerging managers to billion-dollar multi-strats	—	verified	Top hedge-fund contracts, financing balances and churn.
Broker-dealers and market makers	Clients page says broker-dealers rely on Clear Street for flexible clearing, financing and execution infrastructure	—	verified	Omnibus/fully disclosed exposures, credit limits and service-level obligations.
Family offices, ETF issuers and sophisticated traders	Services/Clients pages list these target clients	—	verified	Segment revenue, CAC, support load and retention.

Customer-segment disclosure chart Bar chart showing the only public customer-count anchor and undisclosed segment weights.

III.B Strategic relationships, suppliers and dependencies

partially verified confidence: medium

Company sources list partnerships and acquisitions, while critical infrastructure, venue, vendor and market-utility dependencies are not fully public.

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Evidence gaps

Vendor contracts, partner economics, venue/counterparty concentration and integration records were not public.

Hidden risks

Aggregate client and balance metrics are public, but top-account concentration, customer profitability, churn and contract terms are not.
Cloud-native trading, clearing, custody, financing and client portals require strong security, availability and disaster-recovery controls; public pages do not disclose independent audits.
Offices and regulated entities across multiple jurisdictions raise entity management, labor, tax, licensing, supervision and data-governance complexity.

Follow-up questions

Provide partner contracts, vendor list, cloud agreements, venue/counterparty concentration, acquisition integration plans and support obligations.

Strategic relationships, acquisitions and expansion signals
relationship or event	date or period	public signal	diligence gap
Kalshi partnership	2026-05	Newsroom lists Clear Street and Kalshi partnership for institutional access to prediction market exchange	Partner agreement, economics, regulatory analysis and launch status.
BitGo partnership	2025-11	About journey lists Clear Street & BitGo partnership	Digital-asset custody/counterparty terms and regulatory review.
REACT futures clearing platform acquisition	2023-07	About journey says Clear Street acquired cloud-native futures clearing platform REACT	Purchase agreement, integration costs, liabilities and technology due diligence.
Fox River algorithmic trading business acquisition	2024-10	About journey says Clear Street acquired Fox River algorithmic trading business from Instinet	Acquisition documents, customer migration, IP ownership and integration risk.

Supplier, infrastructure and counterparty dependency map
dependency	public evidence	concentration risk	diligence request
Cloud-native infrastructure	Company describes real-time cloud-native platform	Cloud vendor and architecture not public	Architecture diagrams, vendor contracts, SOC reports, DR tests and outage history.
Regulatory memberships and clearing utilities	FINRA/SIPC, CFTC/NFA, FCA/LME disclosures	Membership/capital compliance critical to operations	Regulator extracts, capital reports and utility/clearing agreements.
Market venues, liquidity providers and custodial counterparties	Execution/trading and multi-asset claims imply venue/counterparty dependencies	Not publicly disclosed	Venue list, routing economics, counterparty limits, credit policies and incidents.

Chapter 04

04Competition

Clear Street competes in a crowded capital-markets infrastructure market against bank prime brokers, clearing/custody platforms, broker infrastructure and workflow vendors. Public materials support differentiation around modern cloud-native infrastructure, but win/loss, pricing and margin evidence are private.

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IV.A Competitive landscape and product overlap

partially verified confidence: medium

Public product scope maps Clear Street into competition with incumbent prime brokers, clearing platforms and trading workflow vendors.

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Evidence gaps

Competitive win/loss, displacement data, customer references and pricing benchmarks were unavailable.

Hidden risks

Clear Street competes with incumbent prime brokers, clearing firms and fintech brokers that can pressure pricing, balance-sheet economics and client acquisition.

Follow-up questions

Provide win/loss reports, competitor displacement examples, pricing benchmarks and customer reference calls.

Competitive landscape comparison
competitor set	examples	overlap with clear street	clear street public differentiator	evidence status
Incumbent prime brokers and investment banks	Goldman Sachs, Morgan Stanley, JPMorgan, UBS and similar institutions	Prime brokerage, financing, execution and investment banking	Modern cloud-native infrastructure and integrated workflow tooling	analyst_estimate
Clearing/custody platforms and broker-dealer infrastructure providers	Pershing, Apex, StoneX, Interactive Brokers and similar providers	Clearing, custody, execution and platform services	Real-time, cross-asset, one-platform positioning	analyst_estimate
Trading workflow and PMS/EMS providers	Order, portfolio, risk and execution-management software vendors	Portfolio analytics, risk and execution tooling	Studio integrated with brokerage/financing infrastructure	analyst_estimate

Competitive positioning map Market map of Clear Street against likely capital-markets infrastructure competitors.

IV.B Basis of competition and defensibility

partially verified confidence: medium

Clear Street publicly emphasizes cloud-native infrastructure, speed, transparency and scale, but defensibility depends on product performance, regulated operating scale, service quality and balance-sheet economics.

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Evidence gaps

Product usage, uptime, customer ROI, price realization and balance-sheet economics were not public.

Hidden risks

Rapidly expanding service lines, asset classes, acquisitions and international footprint increase product delivery, integration and operational-risk complexity.
Clear Street competes with incumbent prime brokers, clearing firms and fintech brokers that can pressure pricing, balance-sheet economics and client acquisition.

Follow-up questions

Run technical diligence, reference calls, pricing analysis, margin benchmarking and competitive displacement review.

Basis-of-competition scoring
axis	clear street public position	competitor pressure	evidence strength	diligence test
Technology modernization	Cloud-native, real-time platform and Studio tooling	Incumbents can invest heavily but may carry legacy infrastructure	medium	Architecture review, uptime, client references and product usage.
Balance sheet and financing capacity	About USD 16B customer balances and financing services	Large banks may have deeper balance sheets	low	Financing book, capital ratios, credit limits, loss history and concentration.
Breadth of asset classes	Multi-asset claims including equities, options, futures, fixed income, FX, swaps, commodities and repo	Large incumbents offer broad global asset coverage	medium	Revenue/volume by asset class and implementation maturity.
Price and service model	Pricing not public; company stresses speed/transparency/scale	Pricing and bundled service pressure likely	low	Win/loss, discounts, gross margin and customer reference calls.

Chapter 05

05Marketing, Sales, and Distribution

Clear Street appears to use direct institutional sales, demo/contact motions, partnerships, acquisitions, product launches and owned content. Public channel activity is visible, but CAC, sales productivity, conversion, pipeline quality and quota attainment are not.

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V.A Sales channels and distribution motions

partially verified confidence: medium

Clear Street publicly signals a direct institutional sales motion, partnerships and acquisition-led expansion, but private pipeline and sales efficiency metrics are missing.

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Evidence gaps

Pipeline, CAC, sales-cycle length, quota attainment and win/loss data were unavailable.

Hidden risks

Clear Street competes with incumbent prime brokers, clearing firms and fintech brokers that can pressure pricing, balance-sheet economics and client acquisition.

Follow-up questions

Provide CRM export, pipeline, sales cycle, quota attainment, CAC/payback, channel attribution and win/loss records.

GTM channels and distribution motions
channel	public signal	likely role	verification status	private data needed
Direct institutional sales	Services and Clients pages call for contact/demo and target institutions, funds, brokers and traders	Primary enterprise acquisition motion	partially_verified	Pipeline, sales cycle, quota attainment and win/loss.
Partnerships and ecosystem relationships	Newsroom/About pages list Kalshi, BitGo and iConnections relationships	Market access, product expansion and lead generation	partially_verified	Partner agreements, economics and shared pipeline.
Acquisitions/product expansion	REACT, Fox River and Boom Securities appear in company journey/news pages	Capability and geography expansion	partially_verified	Integration plans, purchase accounting, customer migration and liabilities.
Owned content and thought leadership	Newsroom lists 87 blogs, 62 press releases and 7 whitepapers	Awareness and credibility among capital-markets buyers	verified	Attribution, MQL/SQL conversion and CAC.

Owned GTM signal counts Bar chart of public owned-channel GTM evidence.

V.B Marketing signals and brand/reputation

verified confidence: medium

Clear Street has an active owned newsroom/content surface and workplace/industry award signals, but marketing conversion and customer satisfaction data are not public.

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Evidence gaps

MQL/SQL conversion, paid spend, NPS, win/loss and customer satisfaction data were not public.

Hidden risks

Clear Street competes with incumbent prime brokers, clearing firms and fintech brokers that can pressure pricing, balance-sheet economics and client acquisition.

Follow-up questions

Provide marketing attribution, conversion funnel, NPS/customer satisfaction, press impact and event ROI.

Public marketing and reputation signals
signal	public evidence	diligence value	gap
News/content cadence	Newsroom lists 87 blogs and 62 press releases	Shows active communications and product announcement cadence	Does not prove pipeline conversion.
Whitepapers	Newsroom lists 7 whitepapers	Supports thought-leadership motion to emerging managers and institutions	Download leads and conversion metrics unavailable.
Workplace and industry awards	Careers page shows Great Place to Work, Hedgeweek and other awards	Supports employer and service reputation screening	Award methodology and customer satisfaction data need validation.
Social/technical footprint links	Footer links to LinkedIn, YouTube and GitHub	Points for follow-up on hiring, brand and technical activity	Follower counts, engagement and open-source activity not validated here.

Chapter 06

06Research and Development

Public product milestones show a broad and fast expansion cadence across securities finance, fixed income, futures, UK, extended-hours trading, digital assets and active trading. The pace supports growth potential but increases roadmap, integration, control and technical-risk diligence needs.

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VI.A Product roadmap and pipeline

partially verified confidence: medium

Company journey/news pages show repeated product launches, acquisitions and geographic expansion from 2018 through 2026.

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Evidence gaps

Roadmap prioritization, engineering capacity, integration burndown and product adoption were not public.

Hidden risks

Rapidly expanding service lines, asset classes, acquisitions and international footprint increase product delivery, integration and operational-risk complexity.
Offices and regulated entities across multiple jurisdictions raise entity management, labor, tax, licensing, supervision and data-governance complexity.

Follow-up questions

Provide roadmap, release metrics, engineering capacity, integration plans, customer adoption and post-launch incident reports.

Public product and R&D pipeline events
date or period	event	product or capability	verification status	diligence follow up
2022-11	Launches ATLAS	Automated Trading Locates Allocation Systems / securities finance stack	verified	Feature usage, revenue contribution, system reliability.
2023-10	Expands asset class capabilities to fixed income	Fixed income securities	verified	Volume, coverage and risk controls.
2024-04	Begins market-maker and futures clearing services	Market maker/futures clearing	verified	FCM operations, capital, margin and segregation.
2025-03/04	Launches 24/6 trading and expands overnight access	Extended-hours trading	verified	Venue, support, incident and best-execution controls.
2026-03/05	Digital asset trading and active trading app/news items	Digital assets and individual trader platform	partially_verified	Regulatory, custody, launch status and customer adoption.

Product and expansion roadmap timeline Timeline of public product, acquisition and expansion milestones.

VI.B Technology, security and operational controls

not publicly verifiable confidence: high

Clear Street describes cloud-native and in-house tooling, but independent technology, security and operational-resilience evidence was not public.

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Evidence gaps

SOC reports, penetration tests, incident logs, BCP/DR tests, vendor-risk files and technical architecture were unavailable.

Hidden risks

Cloud-native trading, clearing, custody, financing and client portals require strong security, availability and disaster-recovery controls; public pages do not disclose independent audits.

Follow-up questions

Provide SOC 1/2, penetration tests, architecture diagrams, incident history, BCP/DR results, vendor-risk program and security policies.

Technology architecture and control diligence matrix
domain	public claim or signal	risk	requested artifact
Cloud-native core platform	Real-time, cloud-native capital-markets infrastructure	Availability, resiliency, data consistency and vendor dependency	Architecture diagrams, cloud contracts, SOC reports, BCP/DR tests, incident logs.
Studio client workflow layer	Financing portal, PMS, risk management and EMS	Data quality, entitlement, accuracy and user adoption	Product usage, uptime, access controls, model/calculation validation, roadmap.
Trading and execution systems	Advanced algorithms and in-house trading system	Best execution, routing conflicts, latency and venue economics	Best-execution reviews, order-routing data, algorithm tests, surveillance logs.
Security and data governance	Security page exists but independent reports were not gathered	Cyber, client-data protection and regulatory reporting	SOC 1/2, penetration tests, vulnerability logs, DPA, retention and access-control policies.

Chapter 07

07Management and Personnel

Clear Street publicly shows a sizeable employee base, 18-office footprint and senior leadership bench. HR diligence must verify org structure, board/governance, attrition, compensation, retention incentives, key-person dependencies and international employment compliance.

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VII.A Senior management and governance

partially verified confidence: medium

The About page publicly identifies senior leaders across commercial, trading, operations, investment banking and people functions, but full board/governance details are not public.

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Evidence gaps

Board list, org chart, employment agreements, succession and retention grants were unavailable.

Hidden risks

The company has 800+ employees and many specialist leaders; public sources do not disclose attrition, succession, retention grants or key-person concentration.

Follow-up questions

Provide board materials, org chart, executive agreements, compensation/equity, succession plan and key-person analysis.

Public senior management roster
name	public role	public source context	diligence follow up
Andy Volz	Chief Commercial Officer	About page leadership card and quote	Employment agreement, responsibilities, sales org metrics and succession.
John DiBacco	Head of Markets Trading	About page leadership card	Trading governance, conflicts, compliance and key-person risk.
Sean Hendelman	Chief Executive Officer, Active & Pro Trading	About page leadership card	Active trader app strategy, licenses, KPIs and risk controls.
Jon Daplyn	Chief Operating Officer / technology-operating leader per About page context	About page quote and image context	Confirm current title, responsibilities, technical org and operational resilience ownership.
Michael Stover	Chief People & Performance Officer	About page leadership card	HR, retention, compensation, culture and attrition metrics.

People-scale public anchors Bar chart of public headcount and office-footprint anchors.

VII.B Headcount, hiring, locations and turnover

partially verified confidence: medium

Company pages disclose 800+ employees and 18 offices, but functional mix, attrition and hiring plan are private.

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Evidence gaps

Monthly headcount by function/location, attrition, contractor counts, open roles and retention data were unavailable.

Hidden risks

Offices and regulated entities across multiple jurisdictions raise entity management, labor, tax, licensing, supervision and data-governance complexity.
The company has 800+ employees and many specialist leaders; public sources do not disclose attrition, succession, retention grants or key-person concentration.

Follow-up questions

Provide HRIS export, attrition and retention analysis, contractor data, open roles, local employment compliance and compensation bands.

Headcount, office footprint and workforce signals
signal	public value	source context	risk or gap	request
Employees	800+	About and Careers pages	Function/location mix, attrition and contractor counts unavailable	HRIS export and monthly headcount by function/location.
Office footprint	18 office locations	Careers page lists US, Canada, UK, Netherlands, Sweden, Singapore, India and Israel locations	Entity, payroll, tax, immigration and supervision complexity	Entity chart, payroll/vendors, leases and local compliance memos.
Workplace awards	Great Place to Work and other awards listed	Careers page awards grid	Awards are positive but do not disclose retention or engagement data	Engagement surveys, attrition, retention grants and DEI metrics.
Departures/turnover	—	Not disclosed in gathered public sources	Turnover and key-person risk not publicly verifiable	Executive changes, regretted attrition, open roles and succession plans.

Chapter 08

08Legal and Related Matters

Clear Street publicly discloses regulated entities and memberships that create high-priority legal/regulatory diligence. Public sources do not provide counsel letters, regulator correspondence, enforcement searches, litigation dockets, insurance, IP assignments or material contracts.

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VIII.A Regulatory status, compliance and agency matters

partially verified confidence: medium

Company disclosures identify broker-dealer, FCM, UK FCA/LME and other entity surfaces, but independent regulator records and correspondence were not gathered.

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Evidence gaps

Regulator extracts, capital reports, exam letters, enforcement searches and compliance policies were unavailable.

Hidden risks

Broker-dealer, FCM, UK FCA/LME and international operations create capital, compliance, customer-asset, supervision and enforcement risks.
Offices and regulated entities across multiple jurisdictions raise entity management, labor, tax, licensing, supervision and data-governance complexity.

Follow-up questions

Provide FINRA/CRD/BrokerCheck, NFA/CFTC, FCA/LME extracts, capital reports, exam correspondence, enforcement searches and compliance policies.

Regulated entities and public memberships
entity or disclosure	public status	jurisdiction or regulator	diligence request
Clear Street LLC	Broker dealer member FINRA/SIPC; FCM registered with CFTC and NFA member	United States / FINRA, SIPC, CFTC, NFA	FINRA BrokerCheck/CRD extracts, FCM records, capital reports, exam letters and enforcement searches.
Clear Street UK Limited	Authorised and regulated by FCA; Category 1 LME member	United Kingdom / FCA, LME	FCA register extract, LME membership status, local capital and compliance correspondence.
Clear Street Canada, Derivatives, FCM, Europe	Listed as registered-entity disclosure pages	Canada, derivatives/FCM, Europe	Entity chart, licenses, local counsel memos and regulatory filings.
Privacy/security legal pages	Privacy Notice and Security links available from footer	Data/privacy and cybersecurity controls	Privacy assessment, DPAs, incident logs, SOC reports and vendor-risk evidence.

Regulatory action and compliance follow-up matrix
agency or area	public record status	priority	next check
FINRA/SIPC broker-dealer	Company discloses membership; independent BrokerCheck fetch was not usable in this workflow	high	Pull BrokerCheck firm summary, disciplinary history, CRD and customer relationship summary.
CFTC/NFA FCM	Company discloses FCM registration and NFA membership	high	Pull NFA BASIC records, capital requirements, segregation and exam correspondence.
FCA/LME UK operations	Company discloses FCA authorization and Category 1 LME membership	high	Pull FCA register, permissions, capital status and LME membership records.
Privacy/security	Legal links exist; no incident or assessment records public	medium	Review privacy notices, DPAs, SOC reports, incidents, vendor risk and data-flow maps.

Diligence risk heatmap Risk heatmap for Clear Street diligence workstreams.

VIII.C Litigation, IP, contracts and related matters

not publicly verifiable confidence: high

Public pages do not disclose comprehensive litigation, IP ownership, FTO, customer/vendor contracts, acquisition liabilities or insurance schedules.

EC-010 EC-014

Evidence gaps

Counsel letters, docket searches, IP assignments/FTO, OSS scans, material contracts and insurance schedules were unavailable.

Hidden risks

Litigation, IP ownership, acquisition liabilities, customer contracts, vendor contracts and insurance were not available publicly.

Follow-up questions

Provide counsel letters, docket searches, IP/trademark/patent and OSS materials, top customer/vendor contracts, acquisition agreements and insurance schedules.

Litigation, IP and material-contract diligence gaps
topic	public evidence	verification status	why it matters	request
Pending lawsuits against Clear Street	No comprehensive docket search available in gathered public sources	not_publicly_verifiable	Potential damages, injunctions, client disputes or regulatory overlap	Counsel letters and docket searches across relevant jurisdictions.
Claims initiated by Clear Street	No comprehensive docket search available in gathered public sources	not_publicly_verifiable	Could reveal IP, contract or customer disputes	Docket searches and litigation schedules.
IP ownership and open-source compliance	Public pages show product/brand assets but not IP assignment or FTO documents	not_publicly_verifiable	Trading, risk and platform software depend on clean ownership and licenses	IP assignments, patent/trademark list, FTO, OSS scan and acquisition IP schedules.
Material customer, vendor and acquisition contracts	Partner/acquisition events are public; contracts are private	not_publicly_verifiable	Contracts govern revenue quality, obligations, liabilities and change-of-control risks	Top MSAs, vendor agreements, partner contracts and acquisition documents.

Evidence

Evidence claims
ID	Claim	Status	Sources
EC-001	CB Insights lists Clear Street as a USD 2B private unicorn in financial services.	verified medium	SRC-001
EC-002	Clear Street publicly claims USD 1.0B capital raised, 700+ institutional clients and about USD 16B customer balances.	partially verified medium	SRC-002
EC-003	Clear Street publicly claims significant trading-volume, headcount and growth scale.	partially verified medium	SRC-003
EC-004	Clear Street markets a broad cloud-native capital-markets infrastructure and services platform.	verified high	SRC-004
EC-005	Clear Street publicly targets sophisticated individual traders, emerging managers, institutions and broker-dealers.	verified high	SRC-005
EC-006	Clear Street Studio is positioned as an integrated portfolio-management, financing, risk and execution tooling layer.	verified high	SRC-006
EC-007	Clear Street discloses multiple regulated entities and memberships.	verified medium	SRC-007
EC-008	Clear Street careers page claims 18 offices and 800+ employees.	verified medium	SRC-008
EC-009	Clear Street About page provides a dated company journey from founding through product and geographic expansion.	verified medium	SRC-003
EC-010	Clear Street newsroom shows continuing product launches, partnerships and expansion activity in 2024-2026.	partially verified medium	SRC-003 SRC-009
EC-011	Clear Street does not publicly disclose audited financial statements, ARR, revenue, gross margin, cash burn or runway in gathered public sources.	not publicly verifiable high	SRC-002 SRC-003 SRC-010
EC-012	Clear Street does not publicly disclose customer concentration, customer names, contract terms, churn, renewal or revenue by segment in gathered public sources.	not publicly verifiable high	SRC-002 SRC-005 SRC-010
EC-013	Clear Street does not publicly disclose standardized pricing or take-rate economics in gathered public sources.	not publicly verifiable high	SRC-004 SRC-006 SRC-010
EC-014	Legal, litigation, IP assignment, regulatory-exam and material-contract diligence requires private or regulator-source records beyond the gathered public pages.	not publicly verifiable high	SRC-007 SRC-010
EC-015	Clear Street publicly identifies a senior leadership bench across commercial, operations, markets, investment banking and people functions.	verified medium	SRC-003
EC-016	Clear Street maintains active owned-channel marketing and thought-leadership surfaces.	verified medium	SRC-009

Sources
ID	Publisher	Title	Accessed
SRC-001	CB Insights	The Complete List Of Unicorn Companies	2026-05-24
SRC-002	Clear Street	Clear Street homepage	2026-05-24
SRC-003	Clear Street	Clear Street About page	2026-05-24
SRC-004	Clear Street	Clear Street Services page	2026-05-24
SRC-005	Clear Street	Clear Street Clients page	2026-05-24
SRC-006	Clear Street	Clear Street Studio page	2026-05-24
SRC-007	Clear Street	Clear Street regulatory disclosures page	2026-05-24
SRC-008	Clear Street	Clear Street careers page	2026-05-24
SRC-009	Clear Street	Clear Street newsroom page	2026-05-24
SRC-010	GitHub Copilot diligence agent	Analyst synthesis from fetched public sources	2026-05-24

Disclaimer

This report is a public-evidence diligence snapshot, not investment advice. Important financial, legal, technical, and contractual facts remain non-public and should be verified directly with management and primary documents before any investment decision.