# Winter & Associates, Inc.

> Winter & Associates, Inc. is an SEC-registered investment advisory firm in St. Paul, MN, registered since 2022, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated August 18, 2026.

- CRD: 310349
- Filed as: WINTER & ASSOCIATES, INC.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: St. Paul, MN
- Filing period: October 2026
- Form ADV filing dated: August 18, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/310349
- AdvisorCensus page: https://advisorcensus.com/firm/winter-and-associates-inc-st-paul-mn-310349

## Quick answers

**How is Winter & Associates, Inc. compensated?**
On its Form ADV (Item 5.E, October 2026), Winter & Associates, Inc. reports these compensation arrangements: a percentage of assets under its management; hourly charges; fixed fees (other than subscription fees).

**Where is Winter & Associates, Inc. located?**
Winter & Associates, Inc.'s principal office is in St. Paul, MN, according to its Form ADV.

**Is Winter & Associates, Inc. registered with the SEC or a state?**
Winter & Associates, Inc. is an SEC-registered investment advisory firm, registered since 2022. Status as filed: Approved. CRD 310349.

**How much does Winter & Associates, Inc. manage?**
Winter & Associates, Inc. reports $179,734,556 in regulatory assets under management in its Form ADV filing dated August 18, 2026 (93% discretionary).

**How have Winter & Associates, Inc.'s assets and staff changed since 2022?**
In the Form ADV data for Winter & Associates, Inc.: Regulatory assets under management: $101,457,483 in the October 2022 data and $179,734,556 in the October 2026 data, up 77%. Total employees: 4 in October 2022 and 5 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Winter & Associates, Inc. serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (161); high net worth individuals (42); pension and profit sharing plans (but not the plan participants or government pension plans) (5).

**Which custodians does Winter & Associates, Inc. use?**
Winter & Associates, Inc.'s most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. and Pershing LLC as custodians holding 10% or more of its separately managed account assets.

**Does Winter & Associates, Inc. report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/310349

**Does Winter & Associates, Inc. state an account minimum?**
Its Form ADV Part 2A brochure dated August 18, 2026 says: "We have a household minimum of $500,000 of investable assets for engaging us in an asset management relationship. Exceptions are at our discretion."

**What changed in Winter & Associates, Inc.'s recent Form ADV filings?**
In the August 2026 filing data: Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Hourly charges
- Fixed fees (other than subscription fees)

### Fees and minimums (Form ADV Part 2A brochure dated August 18, 2026)

- Account minimum: $500,000 (the brochure says it may be waived or negotiated)

> We have a household minimum of $500,000 of investable assets for engaging us in an asset management relationship. Exceptions are at our discretion.

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

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., Inc.
- Pershing 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: $179,734,556
- Discretionary: $166,810,659
- Non-discretionary: $12,923,897

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 161 | $55,813,405 |
| High net worth individuals | 42 | $111,174,688 |
| Banking or thrift institutions | Not reported | $0 |
| Investment companies | Not reported | $0 |
| Business development companies | Not reported | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | Not reported | $0 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 5 | $12,746,463 |
| Charitable organizations | Not reported | $0 |
| State or municipal government entities (including government pension plans) | Not reported | $0 |
| Other investment advisers | Not reported | $0 |
| Insurance companies | Not reported | $0 |
| Sovereign wealth funds and foreign official institutions | Not reported | $0 |
| Corporations or other businesses not listed above | Not reported | $0 |
| Other | Not reported | $0 |

### Advisory services (Item 5.G)
- Financial planning services
- Portfolio management for individuals and/or small businesses
- Pension consulting services
- Selection of other advisers (including private fund managers)

### Firm details
- Registered since: 2022 (4 years)
- Employees: 5 total, 4 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, MA, MN, NE, NY, TX, WI
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- winterassoc.com
- Facebook @winterandassoc
- LinkedIn @winter-&-associates-inc.

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2022 | $101,457,483 | 4 | March 24, 2022 |
| October 2023 | $98,383,960 | 4 | September 27, 2023 |
| October 2024 | $116,218,893 | 4 | September 16, 2024 |
| October 2025 | $147,479,629 | 5 | April 24, 2025 |
| October 2026 | $179,734,556 | 5 | August 18, 2026 |

Regulatory assets under management: $101,457,483 in the October 2022 data and $179,734,556 in the October 2026 data, up 77%.
Total employees: 4 in October 2022 and 5 in October 2026.

## Changes in the filing (last 12 months)

### August 2026
- Updated its list of owners and control persons (Schedule A).

### May 2026
- Registered or notice-filed in WI.

### March 2026
- Regulatory assets under management went from $147,479,629 to $179,734,556 (+22%).
- Registered or notice-filed in NY.

### January 2026
- No longer registered or notice-filed in FL.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Winter & Associates, Inc. (CRD 310349): Form ADV filing data as of October 2026.