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.