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| Tradewinds Capital Management LLC
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| CRD # | 145934 |
| SEC # | 801-68789 |
| CIK # | 0001616026 |
| AUM | 727.3 M (2026-03-26) |
| Employees | 10 (70% Investors, 0% Brokers) |
| Fees | |
| Minimum | |
| Phone | 360-715-9000 |
| Address | 2211 Rimland Drive Bellingham, WA 98226 |
| Source | [IAPD] [EDGAR] [Website] [LinkedIn] [Facebook] |
| Total AUM ($M) |
|---|
| Fees and Compensation — Form ADV Part 2A (3/23/2026) [Brochure] |
|---|
Item 5 Fees and Compensation
INVESTMENT ADVISORY SERVICES
If a client determines to engage the Registrant to provide discretionary and/or
non- discretionary investment advisory services on a fee-only basis, the
Registrant’s annual investment advisory fee shall be based upon a percentage (%)
of the market value and type of assets placed under the Registrant’s management
(between 0.40% and 0.90%). The following fee schedule applies to all accounts
and all assets in all Tradewinds Capital Management accounts unless the account
qualifies for one of the alternative fee schedules:
STANDARD FEE SCHEDULE
0.90% for the FIRST $250,000
0.85% for the NEXT $250,000 (up to $500,000)
0.80% for the NEXT $250,000 (up to $750,000)
0.75% for the NEXT $250,000 (up to $1,000,000)
0.70% for the NEXT $1,000,000 (up to $2,000,000)
0.60% for the NEXT $1,000,000 (up to $3,000,000)
0.50% for the NEXT $2,000,000 (up to $5,000,000)
0.40% for the VALUES over $5,000,000
ALTERNATIVE FEE SCHEULDES
ANNUITY FEE SCHEDULE: Applies to annuity contracts managed by Tradewinds
Capital Management held at Nationwide in the Monument Advisor Product.
0.75% for ALL VALUES
501(C)(3) CHARITY FEE SCHEDULE: Applies only to accounts held by charitable
organizations with the 501(c)(3) IRA designation.
0.50% for ALL VALUES
HOMEOWNERS’ ASSOCIATION FEE SCHEDULE: Applies only to accounts held by
Tradewinds Capital Management – ADV Part 2A - 2026.03.06 Page | 10
homeowners’ associations.
0.50% for ALL VALUES
EXTENDEND FAMILY MEMBERS FEE SCHEDULE: Applies only to parents,
grandparents, siblings, children of siblings, aunts or uncles, children of aunts or
uncles of a currently employed Tradewinds Capital Management advisor and their
spouses.
0.50% for ALL VALUES
For legacy stock, mutual fund and fixed income positions and all other accounts,
the fee is 0.00% for all values. ANY QUESTIONS: The Registrant’s Chief
Compliance Officer, Donald Bradley Pence, remains available to address any
questions that a client or prospective may have regarding the above fee billing
practice. Additionally, please review the Registrant’s most current Fee and Billing
Policy.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
To the extent specifically requested by a client, the Registrant may determine to
provide financial planning and/or consulting services (including investment and
non- investment related matters, including estate planning, insurance planning,
etc.) on a stand-alone fee basis. Registrant’s planning and consulting fees are
negotiable, but generally range from $1,000 to $2,000 on a fixed fee basis, and
from $150 to $225 on an hourly rate basis, depending upon the level and scope of
the service(s) required and the professional(s) rendering the service(s).
RETIREMENT CONSULTING
The Registrant also provides pension consulting services, pursuant to which it
assists sponsors of self-directed retirement plans with the selection and/or
monitoring of investment alternatives (generally open-end mutual funds) from
which plan participants shall choose in self-directing the investments for their
individual plan retirement accounts. Registrant’s retirement consulting fees are
negotiable, but generally range from 0.60% to 0.80% of the market value of the
plan assets, depending upon the level and scope of the service(s) required.
A. Fee Dispersion: Registrant, in its discretion, may charge a lesser investment
advisory fee, charge a flat fee, waive its fee entirely, or charge fee on a different
interval, based upon certain criteria (i.e. anticipated future earning capacity,
anticipated future additional assets, dollar amount of assets to be managed,
related accounts, account composition, complexity of the engagement, anticipated
services to be rendered, grandfathered fee schedules, employees and family
members, courtesy accounts, competition, competition, negotiations with client,
etc.). As a result of these factors, similarly, situated clients could pay different fees,
the services to be provided by the Registrant to any particular client could be
available from other advisers at lower fees, and certain clients may have fees
different than those specifically set forth above. The Registrant’s Chief
Compliance Officer, Donald Bradley Pence, remains available to address any
questions that a client or prospective client may have regarding the above fee
determination.
Clients may elect to have the Registrant’s advisory fees deducted from their
custodial account. Both Registrant's Investment Advisory Agreement and the
custodial/clearing agreement may authorize the custodian to debit the account for
the amount of the Registrant's investment advisory fee and to directly remit that
management fee to the Registrant in compliance with regulatory procedures. In
the limited event that the Registrant bills the client directly, payment is due upon
receipt of the Registrant’s invoice. The Registrant shall deduct fees and/or bill
clients monthly in arrears, based upon the average daily market value of the
assets during the previous month.
Tradewinds Capital Management – ADV Part 2A - 2026.03.06 Page | 11
... |
| Account Minimums and Types of Clients — Form ADV Part 2A (3/23/2026) [Brochure] |
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Item 7 Types of Clients
The Registrant’s clients shall generally include individuals, pension and profit-
sharing plans, business entities, trusts, estates and charitable organizations.
Registrant, in its discretion, may charge a lesser investment advisory fee, charge a
flat fee, waive its fee entirely, or charge fee on a different interval, based upon
certain criteria (i.e. anticipated future earning capacity, anticipated future
additional assets, dollar amount of assets to be managed, related accounts,
account composition, complexity of the engagement, anticipated services to be
rendered, grandfathered fee schedules, employees and family members, courtesy
accounts, competition, competition, negotiations with client, etc.).
Please Note: As result of the above, similarly situated clients could pay different
fees. In addition, similar advisory services may be available from other investment
advisers for similar or lower fees. Any Questions: Adviser’s Chief Compliance
Officer, Donald Bradley Pence, remains available to address any questions that a
client may have regarding its advisory fee schedule. |
| Sector | Form 13F Holdings | Value ($M) | |
|---|---|---|---|
| World Currency Gold Trust | 38.4 | ||
| ETFS Silver Trust | 36.1 | ||
| Global MOFY Metaverse Ltd | 26.2 | ||
| Microsoft Corp | 9.5 | ||
| Apple Inc | 4.2 | ||
| Amazon Com Inc | 2.9 | ||
| Johnson & Johnson | 2.8 | ||
| Alphabet Inc | 2.0 | ||
| Holdings by Sector ($M) |
|---|
| AUM Breakdown | Accounts | AUM ($M) |
|---|---|---|
| By Client Type | ||
| (a) Individuals (other than high net worth individuals) | 2,028 | 241.6 |
| (b) Individuals (high net worth individuals) | 196 | 483.0 |
| (c) Banking or thrift institutions | 0 | 0.0 |
| (d) Investment companies | 0 | 0.0 |
| (e) Business development companies | 0 | 0.0 |
| (f) Pooled investment vehicles | 0 | 0.0 |
| (g) Pension and profit sharing plans | 0 | 0.0 |
| (h) Charitable organizations | 5 | 1.0 |
| (i) State or municipal government entities | 0 | 0.0 |
| (j) Other investment advisers | 0 | 0.0 |
| (k) Insurance companies | 0 | 0.0 |
| (l) Sovereign wealth funds and foreign official institutions | 0 | 0.0 |
| (m) Corporations or other businesses not listed above | 9 | 1.8 |
| (n) Other | 0 | 0.0 |
| Total | 2,268 | 727.3 |
| By Discretionary | ||
| Discretionary | 2,268 | 727.3 |
| Non-Discretionary | 0 | 0.0 |
| Total | 2,268 | 727.3 |
| By Non-United States Persons | ||
| Non-United States Persons | 0.0 | |
| United States Persons | 727.3 | |
| Total | 2,268 | 727.3 |
| EDGAR Form | CIK | 2011 - 2026 |
|---|---|---|
| 13F-HR | [0001616026] |
| Firm Profile (Form ADV) | |
|---|---|
| Discretionary AUM | $0.3B |
| Serves | Institutional, Retail |
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|---|---|---|
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|
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|
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|
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|
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|
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|
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