TradeWinds, LLC provides financial advisory and investment management services to individual investors to
help them achieve their financial goals and needs. Founded in 2021, the Firm is wholly owned by Timothy
Whitney.
This Disclosure Brochure describes the business of TradeWinds. Certain sections will also describe the activities
of Supervised Persons. Supervised Persons are any of TradeWind’s officers, partners, directors (or other persons
occupying a similar status or performing similar functions), or employees, or any other person who provides
investment advice on TradeWind’s behalf and is subject to TradeWinds’s supervision or control.
Financial Planning Services
TradeWinds may provide its clients with a broad range of comprehensive financial planning services. These
services are only offered to certain ongoing investment management clients. Our Advisors review a client’s
financial situation which includes a review of all assets, liabilities, estate, tax and insurance needs. We will conduct
an analysis of cash flow, risk tolerance, investment objectives and other evaluation tools to develop a proposed
asset allocation. Intergenerational family planning services may be included as part of our financial plans.
Wealth Management Services
Clients can engage TradeWinds to manage all or a portion of their assets on a discretionary basis. In limited
instances, we will manage assets on a non-discretionary basis.
We provide wealth management services specific to the needs of each individual client. Prior to formulating any
investment allocation recommendation, we will work with our clients to ascertain each client’s general financial
situation, investment objectives, liquidity needs, time horizon and risk tolerance, as well as any special
considerations relevant to the formulation of the client’s investment program. It should be noted, however, that
we do not limit our advice to any specific class of securities and that other security types and investment options
are frequently used in the construction of client portfolios.
Client assets are generally allocated among our custom, proprietary strategies. Each client’s custom strategy will
generally include a mix of individual equity securities, mutual funds, and ETF’s in accordance with the client's stated
investment objective and risk/volatility parameters. Where appropriate, clients may also engage TradeWinds to
manage and/or advise on certain investment products that are not maintained at their primary custodian, such as
variable life insurance and annuity contracts (to the extent permissible without an insurance license) and assets
held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations,
TradeWinds will direct or make recommendations on a non-discretionary basis for the allocation of client assets
among the various investment options available with the product. These assets are generally maintained at the
underwriting insurance company or custodian for the plan trustee or administrator and clients retain responsibility
for effecting trades in these accounts.
Clients may also retain TradeWinds to provide advisory services for their retirement plan account. When
providing these services, TradeWinds acts as an ERISA 3(21) or 3(38) fiduciary and is required to act under the
standard of care in ERISA that is generally a higher standard than imposed on our firm under the Investment
Advisers Act of 1940. Advisory services available to plan participants include:
• Non-discretionary investment advice
• Asset allocation models
• Strategic investment allocations
• Investment performance reporting
Clients may, at any time, request restrictions on or customizations to their accounts. However, we reserve the
right not to accept and/or terminate the management of a client account if we feel that the customizations or
restrictions imposed by the client, in our opinion, prevent us from managing the account in a manner that is
consistent with the client’s stated investment objectives.
Clients are advised to promptly notify TradeWinds if there are changes in their financial situation or
investment objectives or if they wish to impose any reasonable restrictions upon TradeWind’s management
services.
Financial Planning Services
TradeWinds starts with an extensive review of a client's financial situation which includes assets and liabilities as
well as estate, tax, and insurance needs. The Firm then employs a risk tolerance and risk capacity-focused
simulation to get a detailed cash flow analysis and proposed asset allocation. Financial planning services are typically
bundled alongside our discretionary investment management services, but they can also be offered independently.
Financial plans and financial planning include, but are not limited to:
• investment planning;
• life insurance and annuities;
• tax concerns;
• retirement planning;
• college planning; and
• debt/credit planning.
TradeWinds may recommend clients engage the firm for additional related services as part of the financial plan,
or we may recommend other professionals to implement recommendations made by TradeWinds. Such additional
services by TradeWinds or another professional will be provided for additional compensation, commensurate
with the nature, extent, complexity, and other characteristics of such services. Clients are advised that a conflict
of interest, or the perception of one, may exist because the firm may have additional incentive to recommend
such additional services based on the compensation to be received, rather than solely based on the client's needs,
and in some cases, based on the prospect of cross-referrals of advisory clients from the other professional or his
or her firm.
Clients are under no obligation to act upon any recommendations made by TradeWinds under a financial planning
engagement or to engage the services of a third-party professional. Clients retain the absolute right to decide
whether or not to act on such recommendations, and if they choose to act on such recommendations, whether
to engage the Firm or such professional for such services or to engage another investment adviser or professional
of their choosing, which may charge less (or more) for such services. Should a client choose to implement the
recommendations contained in the plan, TradeWinds suggests the client work closely with his/her attorney,
accountant and/or insurance agent.
Implementation of financial plan recommendations is entirely at the client's discretion. Financial planning
recommendations are of a generic nature and are not limited to any specific product or service offered by a broker
dealer or insurance company. No Legal, Accounting or Tax Advice. TradeWinds will act solely in its capacity as a
registered investment advisor and does not provide any legal, accounting or tax advice. Client should seek the
counsel of a qualified accountant and/or attorney when necessary. TradeWinds may assist clients with tax
harvesting, and we will work with a client’s tax specialist to answer any questions related to the client’s portfolio
account.
Recommending Rollovers and Transfers
As part of our investment advisory services to you, we may recommend that you withdraw the assets from your
employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage
on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of
interest because persons providing investment advice on our behalf have an incentive to recommend a rollover
to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are
under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the
rollover, you are under no obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also, current
employees can sometimes move assets out of their company plan before they retire or change jobs. In determining
whether to complete the rollover to an IRA, and to the extent the following options are available, you should
consider the costs and benefits of: 1)) Leaving the funds in your employer's (former employer's) plan; 2) moving
the funds to a new employer's retirement plan; 3) cashing out and taking a taxable distribution from the plan;
and/or 4) rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages
and before making a change we encourage you to speak with your CPA and/or tax attorney. Our
recommendations may include any of them, depending on what we feel is in your best interest.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you
regarding your retirement plan account or individual retirement account, we are also 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. As a fiduciary, we are required to document the reason(s) for why the
recommendation we made is in your best interest.
Digital Assets
We offer Digital Asset Management services to our clients where suitable, given the client’s investment objectives
and risk tolerance. The fees associated with Digital Asset are separate and in addition to the contractual disclosed
ongoing financial planning or investment management fees charged and collected by the firm. Clients will be
required to complete a separate addendum for these services. The additional Digital Asset fees and how they are
to be billed are disclosed in Item 5.
Assets Under Management
As of December 31, 2023, the Firm has $292,288,693. in assets under management. All of our assets under
management are discretionary.