Tradewinds is a investment adviser based in Raleigh, NC, that holds a 89.5/100 Fidelon TransparencyScore (79th percentile among SEC-registered advisers), with 11 registered advisors. Score based on public SEC and FINRA filings.
Tradewinds
Tradewinds, LLC · CRD #316415
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Tradewinds, LLC is an SEC-registered investment adviser in Raleigh, NC. It has 11 registered advisors. It manages $659.4 million across 1,672 client accounts. It charges a yearly percentage of your account that gets smaller as the account grows, and it does not report earning commissions. Its services include financial planning, portfolio management and educational seminars. It reports that it can hold or access client money, which the SEC requires firms to disclose. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
2,286th of 10,815
SEC-registered advisers
Top 21%
54th of 262
SEC-registered advisers in NC
Top 21%
10th of 47
SEC-registered advisers in Raleigh, NC
Top 21%
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Charges fixed fees for specific services
- Does not earn commissions on product sales
What you’d pay
Blended across 1 tiers, from $50,001 - $3,000,000.
This fee is negotiable
“Our fees will vary on the types of advisory services we offer and may be negotiated at our sole discretion.”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Additional fees and expenses may include securities brokerage commissions, transaction fees, custodial fees, charges imposed by mutual funds or ETFs, 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
- • Digital Asset fees are an annual management fee of 1.00% paid monthly in arrears to TradeWinds, LLC, plus additional fees charged by Eaglebrook Advisors, Inc.
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| $0 - $50,000 | 2.25% |
| $50,001 - $3,000,000 | 1.50% |
| $3,000,001 - $10,000,000 | 1.00% |
Billed monthly in arrears
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Fee-only compensation — no commission income reported
- Registered as investment adviser with fiduciary obligation
- No broker-dealer registration — advisory services only
- Clean regulatory record — no disclosures, arbitrations, or fines
- Transparent fee structure — charges advisory fees, no commissions
Conflict Audit
Zero material conflicts identified in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
What this firm says about how it gets paid
“This means that the more assets you invest in your account, the more you will pay in fees, and therefore we have an incentive to encourage you to increase your advisory account assets.”
“Your broker-dealer and custodian provide us with access to electronic systems that assist us in managing your account, as well as research, software, other technology, and discounts for products and services offered by third-party service providers.”
Source: the firm’s own Form CRS, filed 2025-03-28 — quoted directly
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
88/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
70/100
Fair
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Their two-page relationship summary
The SEC requires every SEC-registered investment adviser to hand you this summary, called a Form CRS, and says what it must cover. We checked this firm's against that list. What is a Form CRS?
- Does it include everything the SEC requires?
- Required sections
- 98/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
- 79/100
- Can you tell what you would pay?
- What you pay
What to askAsk what you would pay in a year, in dollars, including fund and trading costs.
- 42/100
- Is it written in plain English?
- Plain language
- 93/100
This firm's Form CRS averages 78 out of 100. It adds 4.5 points once the firm's filings and record score 90 on their own; they score 89.5 today.
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity100/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
The brochure answers every one of these.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
Our fee schedule for Advisory services is as follows: Assets Under Management Maximum Annual Advisory Fee $0 to $50,000 2.25% $50,001 to $3,000,000 1.75% $3,000,001 to $10,000,000 1.25% More than $10 million Negotiablep. 7
- Does it say whether the fee can be negotiated?CoveredItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
Our fees will vary on the types of advisory services we offer and may be negotiated at our sole discretion.p. 6
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
Clients generally provide TradeWinds with the authority to directly debit their accounts for payment of the Firm’s investment advisory fees.p. 7
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
Fees are generally billed monthly in arrears, based on average daily balance of the account(s) during the period.p. 7
- Does it list the other costs you pay, like fund and custodian fees?CoveredItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
In addition to the advisory fees paid to TradeWinds, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”).p. 7
- Does it say how you get money back if you leave mid-period?CoveredItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
TradeWind’s fees are prorated through the date of termination and any remaining balance is charged or refunded to the client, as appropriate.p. 8
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity70/100
The SEC asks the brochure to name each way the firm gets paid besides your fee, what that tempts the firm to do, and what it can cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
If the firm gets research or services from a custodian or broker, does it explain them?
Research or services received from a custodian or broker (soft dollars)
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
TradeWinds receives compensation from Trade-PMR, Inc., the broker-dealer used for your account, and your account custodian in the form of access to electronic systems that assist us in the management of client accounts, as well as research, software and other technologyp. 20
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
These economic benefits create a conflict of interest in that it gives our firm an incentive to recommend one broker-dealer or custodian over another that does not provide similar electronic systems, support or services.p. 20
- Does it describe what the arrangement actually is?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
TradeWinds receives compensation from Trade-PMR, Inc., the broker-dealer used for your account, and your account custodian in the form of access to electronic systems that assist us in the management of client accounts, as well as research, software and other technologyp. 20
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk what the firm receives from the custodian or broker it uses for you, and whether that costs you anything.
Do they earn commissions on products, and do they say so?Brochure Sales CompensationNot applicable
Not applicable: the brochure describes no product-sales commissions
Do they get free research or services from brokers, and does it affect you?Brochure Soft Dollars71/100
When brokers give the firm research or services in return for your trades, the SEC asks the brochure to say what the firm gets and what it may cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it list what the firm gets from brokers for free?CoveredItem 12.A.1.e
Research, software and data paid for by your trades are a cost you never see.
TradeWinds receives compensation from Trade-PMR, Inc., the broker-dealer used for your account, and your account custodian in the form of access to electronic systems that assist us in the management of client accounts, as well as research, software and other technologyp. 20
- Does it say the firm benefits by not paying for those things?CoveredItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
These economic benefits create a conflict of interest in that it gives our firm an incentive to recommend one broker-dealer or custodian over another that does not provide similar electronic systems, support or services.p. 20
- Does it say those perks can shape which broker it picks for you?CoveredItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
These economic benefits create a conflict of interest in that it gives our firm an incentive to recommend one broker-dealer or custodian over another that does not provide similar electronic systems, support or services.p. 20
- Does it say whether those perks stay within what the law allows?Not found in the brochureItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
What to askAsk whether everything the firm receives from brokers is research the law lets it take in return for your trades.
- Does it say whether you pay more in trading costs because of those perks?Does not applyItem 12.A.1.c
Paying up for trades to earn the firm a perk comes straight out of your returns.
- Does it say whether every client benefits or only some?Not found in the brochureItem 12.A.1.d
Your trades may be paying for research that helps other clients' accounts, not yours.
What to askAsk whether the research your trades help pay for is used for your account.
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
Next Steps
Advisor Roster
11 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Stephanie Ross Williams | 4876561 | — | — |
| Timothy M. Whitney | 4560097 | — | — |
| Tracey Lynn Nobles | 2794755 | — | — |
| Miller Brunson Hoffman | 6810819 | — | — |
| Martin McConnico Boney | 2214276 | — | — |
| Todd William Shand | 3189361 | — | — |
| Austin Bradford Moore | 8107440 | — | — |
| Ralston Turner | 6836931 | — | — |
| James Edward Bowie | 7648744 | — | — |
| Emma Isabelle Schneider | 8061141 | — | — |
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.15 · CRD #316415