Leeward Investments LLC

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Leeward Investments LLC
CRD #312557
SEC #801-122220
CIK #0001923173, 0001603872, 0001508033
AUM 2,869.9 M (2026-03-10)
Employees 14 (36% Investors, 0% Brokers)
Fees
Minimum
Phone617-468-6700
Address10 Winthrop Square
Boston, MA 02110
Source [IAPD] [EDGAR] [Website] [LinkedIn]
Total AUM ($B)
4.03.22.41.60.80.02010201520212027
Fees and Compensation — Form ADV Part 2A (3/10/2026) [Brochure]
Item 5 - Fees and Compensation
We generally set standard fee schedules for our strategies. Fees may be negotiable based upon factors
including services required, size of assets to be managed, product type, the medium for delivering our
advisory services, investment capacity, and size of the overall relationship.

Generally, we are compensated by our clients on the basis of assets under management computed and
payable quarterly. Fees are calculated each quarter and one fourth of the annual amount is billed in
arrears, unless the client and we agree to another arrangement. Clients may elect to be billed directly
for fees or to authorize us to directly debit fees from client accounts.

Fees for Separately Managed Accounts

    Strategy               Standard Fee Range
    US Value Strategies    0.55% - 1.00%

Our investment management fees are exclusive of brokerage commissions, transaction fees, and other
related costs which are incurred by the client. Clients may incur and be responsible for payment of
other charges imposed by custodians, brokers, and other third parties such as fees charged by any
other client-engaged advisors, custodial fees, deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions.

Fees for Mutual Funds
Our fees for services as a mutual fund sub adviser are negotiated with, and compensated by, each
fund or trust. Our fees are charged in a manner similar to separately managed accounts or paid directly

5                                                 Leeward Investments, LLC FORM ADV PART 2A - March 10, 2026

by the financial intermediaries. Mutual funds and ETFs also charge internal management fees, which
are disclosed in a prospectus. Such charges, fees, and commissions are exclusive of and in addition to
our fees, and we do not receive any portion of these commissions, fees, and costs.

Fees for Wrap Fee Programs and Model Portfolio Accounts
Advisory fees earned by us for wrap fee programs are covered under agreements with the Sponsors
and are part of a single inclusive (wrap) fee charged by each Sponsor to clients for investment advisory
services, commissions, custody, and administrative costs. Fees for wrap fee accounts are based on
each client's assets under management. The fee and service arrangements for accounts under any
wrap fee program are negotiated between each client and the Sponsor. The fee paid by a client to the
Sponsor may cover the services of the Sponsor and/or its affiliated entities such as trade execution and
custodial services. We receive a portion of the wrap fee for the advisory services we render to the
client. Sponsors often opt to create their own fee invoices in lieu of ours.

For model portfolio accounts, we are paid at negotiated rates by the Model Clients that receive our
model portfolios.

Additional Fee Details
In certain situations, we may generate more revenue from one client relationship than another
depending on size of assets or fee structure. To ensure fairness to all clients, we have adopted certain
policies and follow certain procedures that are designed to prevent favoring one account over another.
These procedures include side-by-side management controls, trade aggregation, and trade allocation
procedures.

We may charge a flat fee for accounts where the account type, services provided, size of assets, or
similar factors indicate that a flat fee is appropriate. In addition, for accounts under a certain size, a
minimum fee may be charged based on the specific type of account. See Item 7 for additional
information about minimum account sizes.

Fees are charged quarterly in arrears based on the market value of the client's account(s), as
determined by Leeward or by the custodian, on the last business day of the quarter; provided, however,
that for the initial quarter the client engages our Firm, fees are charged on a pro-rated basis in arrears
on the last business day of the initial quarter. For partial quarters, fees are pro-rated. Unless other
arrangements are made, fees are directly debited from a client's account(s), and each client is required
to provide the qualified custodian of the client's account(s) written authorization to deduct the fees
described.

Cash and assets which are invested in exchange-traded funds are included in the calculation of the
value of the client's assets under management with us for purposes of computing our fee. Cash and
money market accounts are also included in the computation.

The client’s custodian sends the client a statement, at least quarterly, indicating the amount of our fees
and all amounts disbursed from the account to us for our fees. The client is responsible for verifying
the accuracy of the fee calculation, as the custodian will not verify the calculation. Payment of fees
may result in the liquidation of client's securities if there is insufficient cash in the client's account(s).

ERISA Account Fees and Compensation
The US Department of Labor regulations under the Employee Retirement Income Security Act ("ERISA")
6                                                   Leeward Investments, LLC FORM ADV PART 2A - March 10, 2026

require that we disclose information about direct and indirect compensation we reasonably expect to
receive in connection with the investment management services we provide to employee benefit plans
subject to ERISA. We provide discretionary investment management services to ERISA plans as
described in each investment management agreement between an ERISA plan and us.

Direct Compensation
We receive an annual investment management fee, which is billed or invoiced to the responsible plan
fiduciary. The fee is paid in arrears from the assets of the account or by the plan sponsor, in its
discretion and in accordance with plan documents. The fee is based on the value of the assets of the
...
Account Minimums and Types of Clients — Form ADV Part 2A (3/10/2026) [Brochure]
Item 7 - Types of Clients

We provide investment advice to taxable, non-taxable, foreign and domestic clients. Such clients
include individuals, high net worth individuals, trusts, corporate pension and profit-sharing plans, ERISA
plans, Taft-Hartley plans, charitable institutions, foundations, endowments, public employee retirement
systems, registered mutual funds, and other U.S. and international institutions. The vast majority of
these arrangements are discretionary in which we select the investments and trade on the client's
behalf without prior consultation with the client. We also participate in a limited number of model
portfolio programs in which we provide a model portfolio to Model Clients but do not exercise
CIK Period
0001923173 0001603872 0001508033
Sector Form 13F Holdings Value ($B)
JDS Uniphase Corp /CA/ 0.0
Silver Run Acquisition Corp 0.0
Regal Beloit Corp 0.0
Clean Harbors Inc 0.0
Healthsouth Corp 0.0
Agree Realty Corp 0.0
Hexcel Corp /DE/ 0.0
Standex International Corp/De/ 0.0
Enpro Industries Inc 0.0
Newmark Group Inc 0.0
Keysight Technologies Inc 0.0
Silicon Laboratories Inc 0.0
Gates Industrial Corp PLC 0.0
Lumentum Holdings Inc 0.0
Columbia Banking System Inc 0.0
Performance Food Group Co 0.0
Wintrust Financial Corp 0.0
Idacorp Inc 0.0
Valmont Industries Inc 0.0
Valley National Bancorp 0.0
Prestige Brands Holdings Inc 0.0
First Horizon National Corp 0.0
Installed Building Products Inc 0.0
CACI International Inc /DE/ 0.0
Huron Consulting Group Inc 0.0
First Interstate Bancsystem Inc 0.0
Valvoline Inc 0.0
Axalta Coating Systems Ltd 0.0
National Bank Holdings Corp 0.0
ITT Corp 0.0
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AUM Breakdown Accounts AUM ($B)
By Client Type
(a) Individuals (other than high net worth individuals) 0 0.0
(b) Individuals (high net worth individuals) 11 0.1
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 8 1.1
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 1 0.1
(g) Pension and profit sharing plans 3 0.3
(h) Charitable organizations 4 0.2
(i) State or municipal government entities 5 0.2
(j) Other investment advisers 2,661 0.7
(k) Insurance companies 6 0.2
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 1 0.0
(n) Other 0 0.0
Total 54 2.9
By Discretionary
Discretionary 39 2.0
Non-Discretionary 15 0.9
Total 54 2.9
By Non-United States Persons
Non-United States Persons 0.0
United States Persons 2.9
Total 54 2.9
EDGAR Form CIK 2011 - 2026
D [0001508033]
D [0001603872]
13F-HR [0001923173]
Firm Profile (Form ADV)
ServesInstitutional, Retail
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