# Windrose Advisors LLC

> Windrose Advisors LLC is an SEC-registered investment advisory firm in Waltham, MA, registered since 2009, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated March 31, 2026.

- CRD: 152145
- Filed as: WINDROSE ADVISORS LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Waltham, MA
- Filing period: October 2026
- Form ADV filing dated: March 31, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/152145
- AdvisorCensus page: https://advisorcensus.com/firm/windrose-advisors-llc-waltham-ma-152145

## Quick answers

**How is Windrose Advisors LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Windrose Advisors LLC reports these compensation arrangements: a percentage of assets under its management; performance-based fees.

**How much does Windrose Advisors LLC charge?**
Its Form ADV Part 2A brochure dated March 31, 2026 states: Asset-based fee: up to 1% of assets a year (the maximum the brochure states). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Windrose Advisors LLC located?**
Windrose Advisors LLC's principal office is in Waltham, MA, according to its Form ADV.

**Is Windrose Advisors LLC registered with the SEC or a state?**
Windrose Advisors LLC is an SEC-registered investment advisory firm, registered since 2009. Status as filed: Approved. CRD 152145.

**How much does Windrose Advisors LLC manage?**
Windrose Advisors LLC reports $2,669,012,816 in regulatory assets under management in its Form ADV filing dated March 31, 2026 (37% discretionary).

**How have Windrose Advisors LLC's assets and staff changed since 2021?**
In the Form ADV data for Windrose Advisors LLC: Regulatory assets under management: $2,188,754,450 in the October 2021 data and $2,669,012,816 in the October 2026 data, up 22%. Total employees: 18 in October 2021 and 23 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Windrose Advisors LLC serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (71); high net worth individuals (70); charitable organizations (12).

**Which custodians does Windrose Advisors LLC use?**
Windrose Advisors LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists BNY Mellon Capital Markets, LLC as a custodian holding 10% or more of its separately managed account assets.

**Does Windrose Advisors LLC report any disciplinary disclosures?**
Reports 1 disclosure item on Form ADV Item 11: yes answers to 11.H(2) (pending civil proceeding). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/152145

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Performance-based fees

### Fees and minimums (Form ADV Part 2A brochure dated March 31, 2026)

- Asset-based fee: up to 1% of assets a year (the maximum the brochure states)

> Our annual advisory fee ranges up to 1.00% and covers advisory services provided by Windrose. Additionally, clients pay a 0.02% fee for reporting and data aggregation.

> Fees are negotiable in certain circumstances. In all cases, Windrose discloses the fee charged in the Investment Advisory Agreement and offering documents prior to services being provided.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- BNY Mellon Capital Markets, LLC

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $2,669,012,816
- Discretionary: $982,503,159
- Non-discretionary: $1,686,509,657

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | $0 |
| High net worth individuals | 70 | $1,457,156,455 |
| Banking or thrift institutions | 0 | $0 |
| Investment companies | 0 | $0 |
| Business development companies | 0 | Not reported |
| Pooled investment vehicles (other than investment companies and business development companies) | 71 | $982,503,159 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 0 | $0 |
| Charitable organizations | 12 | $229,353,202 |
| State or municipal government entities (including government pension plans) | 0 | $0 |
| Other investment advisers | 0 | $0 |
| Insurance companies | 0 | $0 |
| Sovereign wealth funds and foreign official institutions | 0 | $0 |
| Corporations or other businesses not listed above | 0 | $0 |
| Other | 0 | $0 |

### Advisory services (Item 5.G)
- Financial planning services
- Portfolio management for individuals and/or small businesses
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients
- Selection of other advisers (including private fund managers)

### Firm details
- Registered since: 2009 (16 years)
- Employees: 23 total, 8 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, FL, IL, MA, NY, TX
- Disclosures (Item 11): Reports 1 disclosure item on Form ADV Item 11.

### Item 11 questions answered yes
- 11.H(2): Is the firm or an advisory affiliate now the subject of a civil proceeding that could result in a yes answer to any part of 11.H(1)?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/152145

### Websites listed on Form ADV (Item 1.I)
- windroseadvisor.com
- LinkedIn @windrose-advisors

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $2,188,754,450 | 18 | May 27, 2021 |
| October 2022 | $2,475,166,409 | 18 | August 25, 2022 |
| October 2023 | $2,368,437,754 | 20 | March 29, 2023 |
| October 2024 | $2,503,397,523 | 23 | August 12, 2024 |
| October 2025 | $2,487,640,162 | 24 | July 3, 2025 |
| October 2026 | $2,669,012,816 | 23 | March 31, 2026 |

Regulatory assets under management: $2,188,754,450 in the October 2021 data and $2,669,012,816 in the October 2026 data, up 22%.
Total employees: 18 in October 2021 and 23 in October 2026.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Windrose Advisors LLC (CRD 152145): Form ADV filing data as of October 2026.