Our Firm Windsor Capital Management, LLC, a Minnesota limited liability company established in 2000, is a fee- only registered investment adviser with its primary offices located in Phoenix, Arizona. We also maintain branch offices in Oak Brook, Illinois and Greenwood Village, CO. The firm's principal owners are Darren L. Whitehurst and Donald E. Peppler.
We provide our clients with an extensive range of investment advisory services through various investment management programs, including traditional discretionary and non-discretionary portfolio management services, and advisory consulting services. Our integrated suite of services may be offered to clients on an all-inclusive or individual basis. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to our clients' individual needs.
As used in this firm brochure, the words "we, "our," "firm," and "us" refer to Windsor Capital Management, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Also, you may see the phrase "associated person" throughout this firm brochure. As used in this firm brochure, our associated persons shall include our firm's officers, employees, and all individuals providing investment advice on behalf of the firm.
Portfolio Management Services We typically offer our traditional portfolio management services exclusively on a discretionary basis. The advisory services offered under this program are tailored in accordance with your individual investment needs and objectives and are delivered based upon our consultation(s) with you (in-person, telephonic, and otherwise) regarding your unique financial circumstances and goals. We will analyze the information gathered during our consultation(s), assist you in determining (a) an appropriate set of financial goals, (b) your level of risk tolerance, and (c) your retirement plan time horizon, and create a customized investment portfolio and strategy that is based upon your investment profile. Following the creation and implementation of your initial investment portfolio, we will monitor the performance of your holdings on an ongoing basis and implement adjustments within your account as needed, in view of current economic conditions, our market assumptions, and your investment profile. If you participate in our traditional portfolio management services, we will require you to grant our firm discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. This authorization includes deciding which securities to buy and sell, when to buy and sell, and in what amounts, the broker or dealer to be used and the commission rates to be paid in accordance with your investment program, without obtaining your prior consent or approval for each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, and/or trading authorization forms. You may limit our discretionary authority (for example, limiting the specific securities or types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing.
As part of our traditional portfolio management services, in addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model.
4 We may utilize the custodial services of Altruist LLC ("Altruist") to manage accounts. In addition to traditional custodial services, Altruist also provides proprietary automated investment management trading platform, which will give us the ability to provide you with a customized portfolio of exchange traded funds ("ETFs"), publicly-traded equities, fixed income securities, mutual funds, closed end funds ("CEFs"), and currencies (collectively, "Investments"). In limited circumstances, and solely at our discretion, we may also manage your accounts on a non- discretionary basis. Where we manage your account on a non-discretionary basis, we must obtain your consent prior to each transaction and you will have an unrestricted right to decline to implement any advice or recommendations provided by our firm.
You may make additions to and withdrawals from your account at any time, subject to our right to terminate an account that in our discretion falls below a size which is too small to effectively manage. You may withdraw account assets on notice to our firm, and subject to the usual and customary securities settlement procedures. Our investment models typically rely on long-term investment strategies and asset withdrawals may therefore impair the achievement of your specific investment objectives.
We do not hold ourselves out as a financial planner, but may offer financial planning related services incidental to the portfolio management services disclosed above, or as part of an advisory consulting engagement as disclosed below. Fees and fee paying arrangements for financial planning services are negotiated on a case-by-case basis and will be clearly set forth in the agreement for services. Advisory Consulting Services We offer general consulting services with respect to securities and non-securities related investments and financial matters. These services are provided on a non-continuous basis, to include one-time, monthly, quarterly, semi-annual or annual advice. The frequency of the services provided will be agreed upon in advance of the services to be rendered. The topics we address may include, but are not limited to, a review of the client's existing portfolio with asset allocation recommendations, a review/evaluation of recommendations made by other advisory professionals for suitability, management and/or monitoring of a participant's investments in a 401(k) plan, on-going

portfolio monitoring services or other financial planning related services.
Advisory Services to Retirement Plans As described above, we offer our traditional discretionary portfolio management services to employee benefit plans ("Plan"). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below).
The services we provide to your Plan are described above, and in the service agreement that you have previously signed with our firm. Our compensation for these services is described below, at Item 5 - Fees and Compensation, and also in the service agreement. We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan. If we receive any other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you.
5 In providing services to the Plan, our status is that of an investment adviser registered under the Investment Advisers Act of 1940, and we are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we are acting as a fiduciary of the Plan as a discretionary fiduciary as defined in Section 3(21) and Section 3(38) under ERISA. Advisory Services to Unaffiliated Registered Investment Advisers We also provide investment advisory services to unaffiliated registered investment advisers. In providing these services, our role is limited to providing these unaffiliated firms with access to our portfolio models. In these arrangements, individual clients are clients of the unaffiliated investment adviser, not our firm. The unaffiliated firm will determine the suitability of their client's participation in one or more of our model portfolios. We do not make any recommendations, determine suitability, or provide any advisory services to individual clients of the unaffiliated firm. Sub-Advisory / Co-Advisory Management Services Windsor Capital Management, LLC provides sub-advisory portfolio management services to unaffiliated third-party investment advisers (the "Primary Investment Adviser") and to their clients where we provide discretionary portfolio management services using specific investment strategies developed by our firm. In such cases, the Primary Investment Adviser retains the role of primary advisor to their client, and we act as a Co-Advisor. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold within our investment strategies. As part of these services, the Primary Investment Adviser has the initial and ongoing responsibility to collect and review client suitability information (investment objectives / financial circumstances), and will be solely responsible for selecting the appropriate model investment strategy offered by our firm. Clients will enter into a written agreement with our firm, which will authorize our firm to rely on the Client's Primary Investment Adviser's determination as to the appropriate model investment strategy. Clients will also have a separate engagement directly with the Primary Investment Adviser. Wrap Fee Program(s) We do not participate in any wrap fee program.
Types of Investments We primarily offer advice on individual fixed income and equity securities, exchange traded funds ("ETFs"), and closed ended mutual funds, some which may employ leverage. We will also provide advice on open-ended mutual funds. In addition, we will also offer advice on individual stocks as part of our proprietary model stock portfolios. We do not generally recommend individual stocks as part of our standard advisory services to individual accounts. We may recommend other types of investments since each client has different needs and different tolerances for risk. We may also advise you on any type of investment held in your portfolio at the inception of our advisory relationship, or on specific types of investments at your request.
IRA Rollover Recommendations 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: 6
•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.
Assets Under Management As of December 31, 2022, we provide continuous management services for $587,483,051 in client assets on a discretionary basis.