Overview
A. Description of the Advisory Firm
The Windmill Group, Inc. (hereinafter “TWGI”) is a Corporation organized in the State of
New York. The firm was formed in July 1970, and the principal owners are Gregory
Capozzi and John Maceranka.
B. Types of Advisory Services
Portfolio Management Services
TWGI offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. TWGI creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a
portfolio that matches each client's specific situation. Portfolio management services
include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
TWGI evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. TWGI will request discretionary authority from clients in order
to select securities and execute transactions without permission from the client prior to
each transaction. Risk tolerance levels are documented in the Investment Policy
Statement, which is given to each client.
TWGI seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of TWGI’s economic,
investment or other financial interests. To meet its fiduciary obligations, TWGI attempts
to avoid, among other things, investment or trading practices that systematically
advantage or disadvantage certain client portfolios, and accordingly, TWGI’s policy is to
seek fair and equitable allocation of investment opportunities/transactions among its
clients to avoid favoring one client over another over time. It is TWGI’s policy to allocate
investment opportunities and transactions it identifies as being appropriate and prudent
among its clients on a fair and equitable basis over time.
Services Limited to Specific Types of Investments
TWGI generally limits its investment advice to mutual funds, fixed income securities,
insurance products including annuities, equities, ETFs and treasury inflation
protected/inflation linked bonds. TWGI may use other securities as well to help diversify
a portfolio
when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
TWGI will tailor a program for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that
will be executed by TWGI on behalf of the client. TWGI may use model allocations
together with a specific set of recommendations for each client based on their personal
restrictions, needs, and targets. Clients may impose restrictions in investing in certain
securities or types of securities in accordance with their values or beliefs. However, if the
restrictions prevent TWGI from properly servicing the client account, or if the restrictions
would require TWGI to deviate from its standard suite of services, TWGI reserves the
right to end the relationship. TWGI selects investments in client portfolios only after
applying its internal due diligence process.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. TWGI does not participate in wrap fee
programs.
E. Assets Under Management
TWGI has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 32.101.709 $0 December 2023