Winans International dba Winans Investments is a registered investment adviser based in Novato, California. We are organized as a corporation under the laws of the State of California and we have been providing investment advisory services since 1992. Kenneth Grant Winans is our principal owner. Currently, we offer the following investment advisory services, which are personalized to each individual client:
•Portfolio Management Services
•Advisory Consulting and Research Services Portfolio Management Services We offer discretionary and non-discretionary portfolio management services where our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf.
As part of our portfolio management services, we may customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. We may also invest your assets using a predefined strategy, or we may invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances.
If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm or a limited power of attorney. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. If you enter into non- discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account.
Advisory Consulting and Research Services We offer consulting services designed to provide experienced investors with information and guidance in managing their investments. We initially conduct a preliminary investment analysis of your existing portfolio plus an analysis of the tax implications or mutual fund expenses. We will then provide you with a written report and assist you in formulating an investment strategy. On a quarterly basis, we will provide you with a performance report which will contain a statistical and fundamental analysis of stock and bond ratings. We will also conduct a meeting or conference call to review the information provided and discuss possible changes to your portfolio.
We also provide research services to unaffiliated third party financial databases where we sell several proprietary market indices and indicators developed by our firm. The research may be available for purchase directly from the third party for a fee which

are separate and apart from the advisory fees charged by our firm. 4 IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. 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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Sub-Adviser Relationship Winans Investments may engage in one or more sub-adviser relationships with other registered investment advisers ("Other Firm"). When engaged iin these sub-adviser relationships, Winans Investments will provide "strategies" or "models" to be used by the Other Firm in their management of Other Firm clients' accounts ("Other Firm Accounts").
Winans Investments will design, monitor on a daily basis, and as necessary or desirable, update the models used by the Other Firm. Winans Investments has no relationship with Other Firm Accounts or the account owners and does not determine suitability or best interest for Other Firm Accounts. The Other Firm shall obtain purchase and sale recommendations from Winans Investments in order to manage Other Firm Accounts in accordance with the recommendations of Winans Investments. The Other Firm implements the recommendations in Other Firm Accounts. Winans Investments does not act as custodian nor does it place trades for any Other Firm Accounts.
Winans Investments may use the same or similar models and trade recommendations for its own or its own clients' accounts. Wrap Fee Programs We do not participate in any wrap fee program.
Types of Investments We primarily offer advice on stocks, bonds, real estate, mutual funds, exchange traded funds and derivatives.
5 You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing.
Assets Under Management As of December 31, 2022, we provide continuous management services for $245,180,000 in client assets on a discretionary basis.