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Item 1: Cover Page
Firm Brochure
(Part 2A of Form ADV)
WindRock Wealth Management LLC
225 West Jefferson Avenue, Suite 2
Naperville, IL 60540
This Brochure provides information about the qualifications and business practices of WindRock
Wealth Management LLC (“WindRock”). If you have any questions about the contents of this
Brochure, please contact us at (312) 650-9593. The information in this Brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state
securities authority.
WindRock Wealth Management LLC is a registered investment adviser. Registration of an
Investment Adviser does not imply any level of skill or training. The oral and written
communications of an Investment Adviser provide you with information which you may use to
determine to hire or retain an Investment Adviser.
Additional information about WindRock Wealth Management LLC (IARD 166124) also is
available on the SEC’s website at www.adviserinfo.sec.gov.
March 2025
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Item 2: Material Changes
Form ADV 2 is divided into two parts: Part 2A and Part 2B. Part 2A (the “Disclosure Brochure”)
provides information about a variety of topics relating to an Advisor’s business practices and
conflicts of interest. Part 2B (the “Brochure Supplement”) provides information about advisory
personnel of WindRock.
WindRock believes that communication and transparency are the foundation of our
relationship and continually strive to provide you with the complete and accurate information
at all times. We encourage all current and prospective investors to read this Disclosure
Brochure and discuss any questions you may have with us. And of course, we always welcome
your feedback.
Material Changes since the Last Update
Since the annual amendment filing of this brochure in March 2024, the following material
changes have been:
• The firm has updated the amount of client assets under our management. Please refer
to Item 4 – Advisory Business for more specific information.
• The firm has enhanced our disclosures related to the Company Principal’s involvement
with Singularity Capital LLC and related entities, funds and investments (“SC Entities”)
please refer to the Conflicts of Interest section of Item 5 – Fees and Compensation for
more specific information.
FUTURE CHANGES
From time to time, we may amend this Disclosure Brochure to reflect changes in our business
practices, changes in regulations and routine annual updates as required by the securities
regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be
provided to each client annually and if a material change occurs in the business practices of
WindRock.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov.
To review the firm information for WindRock Wealth Management:
• Click Investment Advisor Search in the left navigation menu.
•
•
•
•
Select the option for Investment Advisor Firm and enter 166124 (our firm’s CRD number)
in the field labeled “Firm IARD/CRD Number”.
This will provide access to Form ADV Part 1 and Part 2.
Item 11 of the ADV Part 1 lists legal and disciplinary questions regarding the Advisor.
In the left navigation menu, Form ADV Part 2 is located near the bottom.
You may also request a copy of this Disclosure Brochure at any time, by contacting us at (312)
650-9593 or by email at assistant@windrockwealth.com.
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Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................. i
Item 2: Material Changes .................................................................................................................... ii
Item 3: Table of Contents ................................................................................................................... iii
Material Changes since the Last Update ................................................................................................. ii
Item 4: Advisory Business .................................................................................................................. 1
History and Ownership................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions .............................................................. 2
Wrap Fee Programs ......................................................................................................................................... 7
Item 5: Fees and Compensation ....................................................................................................... 7
Client Assets under Management ............................................................................................................... 7
Retirement Plan Services
Method of Compensation and Fee Schedule .......................................................................................... 7
............................................................................................................................ 9
Conflicts of Interest ........................................................................................................................................ 10
Item 6: Performance-Based Fees and Side-By-Side Management ..................................... 14
Additional Client Fees Charged ................................................................................................................. 14
Item 7: Types of Clients ..................................................................................................................... 15
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .............................. 15
Methods of Analysis ....................................................................................................................................... 15
Item 9: Disciplinary Information ................................................................................................... 18
Security Specific Material Risks ................................................................................................................ 17
Criminal or Civil Actions .............................................................................................................................. 18
Administrative Enforcement Proceedings ........................................................................................... 18
Item 10: Other Financial Industry Activities and Affiliations.............................................. 19
Self-Regulatory Organization Enforcement Proceedings .............................................................. 18
Broker-Dealer or Representative Registration .................................................................................. 19
Futures or Commodity Registration ....................................................................................................... 19
Material Relationships Maintained by this Advisory Business and Conflicts of Interest 19
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
................................................................................................................................................................................. 19
Trading ................................................................................................................................................... 20
Code of Ethics Description .......................................................................................................................... 20
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Item 12: Brokerage Practices ......................................................................................................... 20
Item 13: Review of Accounts ........................................................................................................... 21
Factors Used to Select Broker-Dealers for Client Transactions .................................................. 20
Item 14: Client Referrals and Other Compensation ................................................................ 21
Item 15: Custody .................................................................................................................................. 22
Item 16: Investment Discretion ..................................................................................................... 22
Item 17: Voting Client Securities ................................................................................................... 22
Item 18: Financial Information ...................................................................................................... 23
Brochure Supplement (Part 2B of Form ADV) – Brett K. Rentmeester ............................ 24
Brochure Supplement (Part 2B of Form ADV) – Christopher P. Casey ............................. 28
Brochure Supplement (Part 2B of Form ADV) – Brandy C. Maben .................................... 31
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Item 4: Advisory Business
History and Ownership
WindRock Wealth Management (“WindRock”) was formed in 2012 to create a wealth
management firm with an entrepreneurial-mindset to seize on unique
investment
opportunities fitting the macroeconomic backdrop. WindRock provides full portfolio advisory
services including asset allocation and research on a wide variety of public and private
investment opportunities.
Brett Rentmeester is the sole owner and Principal at WindRock (“Principal”) through
OceanRock LLC, an entity owned by the Principal. Brett is a veteran entrepreneur in the
investment business. Formerly, Brett was a founding partner of Altair Advisers, an investment
advisor in Chicago. Prior to that, Brett was a manager in Arthur Andersen’s Investment
Advisory Services practice in Chicago.
Types of Advisory Services
WindRock offers the following investment offerings detailed below.
FAMILY OFFICE SOLUTIONS
WindRock’s Family Office Solutions serve families typically with more than $10 million of
assets. We develop an intimate tie to the families we work with to understand their personal
situation, goals and objectives, and motives for investing their money. We serve as our clients’
investment strategist, serving to invest and oversee their portfolio in a holistic manner
coordinated with their other financial planning. We work closely with their other service
providers (e.g. estate planner, CPA, private banker, family office etc.) to assist in coordinating
their overall financial planning. We have found that most wealthy families struggle with
coordinating the information flow amongst their team of advisors, often costing them real
money and lost opportunity. Our process begins with an in-depth discussion with each client
to formulate an appropriate investment portfolio. This culminates in the written formation of
an investment policy statement, which serves as a blue-print for the investment strategy.
WEALTH MANAGEMENT SERVICES
WindRock’s Wealth Management Services are available typically starting at minimums of
$500,000. We work with clients to determine their risk tolerance and then to match them
appropriately to a portfolio representing our best thinking. We view the investment universe
in four broad categories – Global Equities & Tactical Allocators, Global Bonds, Hard Assets and
Unique Private Investments. Some clients engage us to advise them on their entire investment
portfolio and other clients engage us to advise them on a specific silo of their investment
portfolio, such as the Hard Asset and/or Unique Private Investment categories. Hard Assets
generally include a mix of assets that are positioned benefit from inflation with major sub-
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Investment category
includes private
investments such as the
categories including: precious metals (bullion and miners), diversified commodities (e.g.
energy, metals, agriculture/farmland), foreign currencies and unique trades. The Unique
Private
investment
opportunities through Iridius Entities, SCM Entities, and SC Entities, which are generally
available to accredited investors. These private investments are more fully detailed on page
10 “Conflicts of Interest”. Clients who inform WindRock of their intentions or desire to
diversify by including private investments in their portfolios and who also acknowledge they
are aware of the formal relationship between the Principal and Iridius, SCM and SC Entities,
shall be notified of any Iridius, SCM or SC Entity investment opportunities and shall have the
right to participate or decline. WindRock clients who invest in Iridius, SCM, or SC Entity
opportunities pay fees, which many include a management and/or incentive fees to Iridius,
SCM or SC Entities, where the Principal is an owner.
For clients that engage us to advise them on their overall portfolio, we formalize an investment
policy statement consistent with the strategy chosen. We communicate with clients primarily
through quarterly webcasts, discussions and meetings to discuss the strategies and our view
of the investment environment. Once an investment strategy is agreed upon for either Family
Office or Wealth Management Services, WindRock manages the portfolio within the confines
of the agreed parameters and reports results to clients. Assets are invested with various
investment managers, mutual funds, ETFs, derivatives and private investments. For assets that
have pre-determined investment choices, such as a 401(k) Plan, WindRock will assist clients in
finding appropriate investments that fit within the context of their overall asset allocation and
investment plan.
WindRock does not directly assist Wealth Management clients with financial planning services,
but will connect clients with particular needs to third-party service providers in areas such as
mortgage financing and lending, estate planning, certified public accountants, family office
concierge services, and other financial services. These providers will be selected based on their
services, reputation and fees. WindRock may receive referrals from these third-party providers
that work with our clients as well as other third-party providers that don’t work with WindRock
clients. WindRock is not responsible for the advice or actions of these third-party service
providers. There is no obligation for clients to utilize any of these providers, but we believe we
are providing valuable connections for clients that are seeking outside advisors.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objective. Clients may impose
restrictions on investing in certain securities or types of securities.
Agreements may not be assigned without written client consent.
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Retirement Plan Services
WindRock offers retirement plan services to retirement plan sponsors. For a corporate
sponsor of a retirement plan, our retirement plan services may include one or more of the
following services:
Fiduciary Consulting Services
WindRock provides the following fiduciary retirement plan consulting services:
• Non-Discretionary Investment Advice. WindRock will provide the retirement plan
sponsor (“Sponsor”) with general, non-discretionary investment advice regarding
assets classes and investment options, consistent with your plan’s investment policy
statement.
•
Investment Selection Services. WindRock will provide Sponsor with recommendations
of investment options consistent with ERISA section 404(c).
•
Investment Due Diligence Review. WindRock will provide Sponsor with periodic due
diligence reviews of the plan’s reports, investment options and recommendations.
•
Investment Monitoring. WindRock will assist in monitoring investment options by
preparing periodic investment reports that document investment performance,
consistency of fund management and conformation to the guidelines set forth in the
investment policy statement and WindRock will make recommendations to maintain
or remove and replace investment options.
• Default Investment Alternative Advice. WindRock will provide you with non-
discretionary investment advice to assist Sponsor with the development of qualified
default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-
5(e)(4)(i), for participants who are automatically enrolled in the plan or who
otherwise fail to make an investment election. You will retain the sole responsibility
to provide all notices to participants required under ERISA section 404(c)(5).
For Fiduciary Consulting Services, all recommendations of investment options and portfolios
will be submitted to Sponsor for their ultimate approval or rejection. The retirement plan
Sponsor client who elects to implement any recommendations are providing WindRock with
the power and authority to carry out these decisions by giving instructions, on Sponsor’s
behalf, to brokers and dealers and the qualified custodian(s) of the plan for management of
the designated retirement plan assets.
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Fiduciary Consulting Services are not management services, and WindRock does not serve as
administrator, plan fiduciary or trustee of the plan. WindRock does not act as custodian for
any client account or have access to client funds or securities (with the exception of, some
accounts, having written authorization from the client to deduct our fees).
WindRock acknowledges that in performing the Fiduciary Consulting Services listed above
that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee
Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-
discretionary investment advice only. WindRock will act in a manner consistent with the
requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such
services cause WindRock to be a fiduciary as a matter of law. However, in providing the
Fiduciary Consulting Services, WindRock (a) has no responsibility and will not (i) exercise any
discretionary authority or discretionary control respecting management of client’s
retirement plan, (ii) exercise any authority or control respecting management or disposition
of assets of client’s retirement plan, or (iii) have any discretionary authority or discretionary
responsibility in the administration of client’s retirement plan or the interpretation of client’s
retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38)
of ERISA and does not have the power to manage, acquire or dispose of any plan assets
without the express approval from the plan administrator.
Securities and other types of investments all bear different types and levels of risk. Those
risks are typically discussed with clients in defining the investment policies and objectives
that will guide investment decisions for their qualified plan accounts. Upon request, as part
of our retirement plan services, we can discuss those investments and investment strategies
that we believe may tend to reduce these risks for a particular client’s circumstances.
Clients must realize that obtaining higher rates of return on investments entails accepting
higher levels of risk. Based upon discussions with the client, WindRock will attempt to
identify the balance of risks and rewards that is appropriate and comfortable for the client. It
is still the clients’ responsibility to ask questions if the client does not fully understand the
risks associated with any investment. All clients are strongly encouraged to read
prospectuses, when applicable, and ask questions prior to investing.
We strive to render our best judgment for clients. Still, WindRock cannot assure that
investments will be profitable or assure that no losses will occur in their portfolios. Past
performance is an important consideration with respect to any investment or investment
advisor, but it is not necessarily an accurate predictor of future performance.
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WindRock will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c),
to Sponsor any change to the information that we are required to disclose under ERISA
Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60)
days from the date on which we are informed of the change (unless such disclosure is
precluded due to extraordinary circumstances beyond our control, in which case the
information will be disclose as soon as practicable).
In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within
thirty (30) days following receipt of a written request from the responsible plan fiduciary or
plan administrator (unless such disclose is precluded due to extraordinary circumstances
beyond our control, in which case the information will be disclosed as soon as practicable) all
information related to the Qualified Retirement Plan Agreement and any compensation or
fees received in connection with the Agreement that is required for the plan to comply with
the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and
schedules issued thereunder.
If we make an unintentional error or omission in disclosing the information required under
ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct
information as soon as practicable, but no later than thirty (30) days from the date on which
we learns of such error or omission.
Retirement Plan Rollover Recommendations
When WindRock provides investment advice about your retirement plan account or
individual retirement account (“IRA”) including whether to maintain investments and/or
proceeds in the retirement plan account, roll over such investment/proceeds from the
retirement plan account to a IRA or make a distribution from the retirement plan account,
we acknowledge that WindRock is a “fiduciary” within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as
applicable, which are laws governing retirement accounts. The way WindRock makes money
creates conflicts with your interests so WindRock operates under a special rule that requires
WindRock to act in your best interest and not put our interest ahead of you.
Under this special rule’s provisions, WindRock must as a fiduciary to a retirement plan
account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put the financial interests of WindRock ahead of you when making
recommendations (give loyal advice);
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• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that WindRock gives advice that
is in your best interest;
• Charge no more than is reasonable for the services of WindRock; and
• Give client basic information about conflicts of interest.
To the extent we recommend you roll over your account from a current retirement plan
account to an individual retirement account managed by WindRock, please know that
WindRock and our investment adviser representatives have a conflict of interest.
WindRock can earn increased investment advisory fees by recommending that you roll over
your account at the retirement plan to an IRA managed by WindRock. We will earn fewer
investment advisory fees if you do not roll over the funds in the retirement plan to an IRA
managed by WindRock.
Thus, our investment adviser representatives have an economic incentive to recommend a
rollover of funds from a retirement plan to an IRA which is a conflict of interest because our
recommendation that you open an IRA account to be managed by our firm can be based on
our economic incentive and not based exclusively on whether or not moving the IRA to our
management program is in your overall best interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial
conduct standard whereby our investment adviser representatives will (i) provide
investment advice to a retirement plan participant regarding a rollover of funds from the
retirement plan in accordance with the fiduciary status described below, (ii) not recommend
investments which result in WindRock receiving unreasonable compensation related to the
rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation
received by WindRock and our supervised persons and any material conflicts of interest
related to recommending the rollover of funds from the retirement plan to an IRA and
refrain from making any materially misleading statements regarding such rollover.
When providing advice to a retirement plan account or IRA, our investment advisor
representatives will act with the care, skill, prudence, and diligence under the circumstances
then prevailing that a prudent person acting in a like capacity and familiar with such matters
would use in the conduct of an enterprise of a like character and with like aims, based on the
investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without
regard to the financial or other interests of WindRock or our affiliated personnel.
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Wrap Fee Programs
Advisor does not participate in wrap fee programs.
Client Assets under Management
As of December 31, 2024, WindRock reported $290,562,560 of client assets under
management (“AUM”) on a discretionary basis. Assets under advisement (“AUA”), which
include a family office client whose assets are not discretionary, total $462,449,666.
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
Advisor bases its fees on a percentage of assets under management in general, but has some
relationships that pay an incentive fee.
ASSET MANAGEMENT
Advisor offers discretionary asset management services to advisory clients. The fees for these
services will be based on a percentage of Assets Under Advisement.
The annual Fee may be negotiable under a variety of situations, including when the same
household may be combined for a reduced fee. Fees are billed quarterly in advance based on
the amount of assets managed as of the close of business on the last business day of each
quarter. Valuations are normally fair market values provided by custodians for public
securities, but in the case of private investments, are based on the valuation methodology for
each investment. Private investments may be carried at cost, a lagged value, accrued value, or
estimated valuation depending on the nature of the investment. For example, private real
estate development equity investments are typically carried at original cost until an ultimate
sale or appraisal. Private real estate that is not in development may be reflected at a fair
market value from an appraisal, refinancing or internal valuation by the manager. Each
situation is unique and valuation criteria may vary, but this is the general framework. Venture
capital and private equity values are generally updated based on updates from the managers.
Quarterly advisory fees deducted from the clients' account by the custodian will be reflected
in a provided fee invoice as part of a quarterly report as fees are withdrawn or on a custodial
statement. Lower fees for comparable services may be available from other sources. Clients
may terminate their account within five business days of signing the Investment Advisory
Agreement for a full refund. Clients may terminate advisory services with 30 days written
notice. Advisor will be entitled to 30-day fee upon termination to assist in transitioning the
accounts. Client shall be given thirty (30) days prior written notice of any increase in fees.
Fees may be subject to different arrangements based on factors such as size and type of assets,
complexity and client needs. Fees are charged on assets under management and are based on
a tiered fee schedule ranging from 1.50% to .25% for Wealth Management Services. These
represent the WindRock advisor fees and exclude any fees payable to underlying investment
managers, private investments (including Iridius, SCM and SC opportunities), custody fees,
brokerage fees or other administrative fees. WindRock may waive or reduce the fee amount
it charges on a client-by-client basis. Additionally, WindRock charges its advisory fee on all
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investment opportunities, including the private placement investment opportunities offered
by Iridius, SCM, and SC.
In accordance with Illinois Securities Law Of 1953 Section 130.846, unless we deliver this
disclosure brochure to you at least forty-eight (48) hours prior to your signing the investment
advisory contract, you have the right to terminate the investment advisory contract within five
(5) business days of the signing of the investment advisory contract without incurring any
advisory fees.
Fee schedule for Wealth Management Services
Portfolio Size*
Advisor Fee
Percentage
first $500,000
1.50
Next $2,500,000
1.25
Next $5,000,000
0.90
Next $10,000,000
0.70
Thereafter
0.25
*Minimum quarterly fee of $1,875 for portfolios under $10 million; minimum quarterly
fee of $12,500 for portfolios exceeding $10 million
Fees are calculated based on a percentage of client assets under advisement. In certain
situations, WindRock may offer these same investment advisory services on a fixed fee basis.
The amount of the fixed fee would be determined on a client-by-client basis and is subject to
negotiation with the client based on the client’s needs and expectations. These fee
arrangements would vary with the complexity of the situation and the amount of time
involved. Level of complexity would depend on but not be limited to the following situations:
type of client account (e.g., family trust, corporate, estate, partnership, etc.), assets under
management, and special needs of the advisory client. Assets under advisement include those
mutually determined and agreed upon with the client. Our minimum annual fee is $7,500 for
Wealth Management Services and $50,000 for Family Office Solutions (e.g. portfolios greater
than $10 million), subject to negotiation.
Fees to WindRock do not include any fees due to various third-party investment managers,
mutual funds, ETFs, derivatives and private investments (including Iridius, SCM, SC or other
third-party investment managers). Fees also do not include any fees for brokerage, custody of
assets, or fees and commissions charged by the custodians.
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Fees for ongoing Family Office Solutions or Wealth Management Services are payable
quarterly in advance. Fees charged on assets under advisement are generally deducted
automatically from a client's investment accounts as authorized and designated by the client.
Accounts initiated or terminated during a calendar quarter are charged a prorated fee. Upon
termination of any account, any prepaid, unearned fees are refunded to the client.
Retirement Plan Services
For retirement plan Sponsor clients, WindRock will charge an annual fee that is calculated as
a percentage of the value of plan assets. This fee may vary based upon the complexity of the
plan, the size of the plan assets and the actual services requested.
Fee schedule for Retirement Plan Services
Portfolio Size*
Advisor Fee
Percentage
first $500,000
1.50%
Next $2,500,000
1.25%
Next $5,000,000
0.90%
Next $10,000,000
0.70%
Thereafter
0.25%
*Minimum quarterly fee of $1,875 for portfolios under $10 million; minimum quarterly
fee of $12,500 for portfolios exceeding $10 million
For retirement plan services, fees are billed quarterly in advance based on the fair market
value of Sponsor account as of the last business day of the current billing period. Fees are
prorated (based on the number of days service is provided during the initial billing period)
for an account opened at any time other than the beginning of the billing period.
Fee will be directly deducted from clients’ accounts. Clients are required to provide the
custodian with written authorization to deduct the fees from the account and pay the fees to
WindRock.
Either party may terminate services by providing written notice of termination to the other
party. If services are terminated within five business days of signing the client agreement,
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services are terminated without penalty. Any prepaid but unearned fees are promptly
refunded to the client at the effective date of termination.
Conflicts of Interest
In its advisory capacity, WindRock recommends various private investment opportunities.
WindRock believes that the private investment opportunities offered by WindRock are
appropriate for clients who appreciate an entrepreneurial and active model of investing, while
understanding the conflicts of interests that arise from the Principal’s direct involvement
and/or investment in these opportunities. This active involvement forms the basis for the
philosophy of being an entrepreneurial-minded advisor.
Some of the private investment opportunities recommended to clients are areas where
WindRock identifies an opportunity and has collaborated with another firm/outside partners
to create an investment vehicle. The Principal is often involved in these investment vehicles
when he finds opportunities that may lack other investment alternatives. In other situations,
the knowledge and skill set of the Principal, combined with the skill set of an outside group or
partners, come together to collaborate on an investment opportunity. As such, the majority
of the private investments are directly affiliated with the Principal. There are generally four
categories of involvement including by the Principal: (1) Active involvement from the Principal
& ownership (2) Strategic advisory role with no day-to-day operational or management
responsibilities & ownership (3) Ownership interest only (4) No involvement from the Principal
(investments sponsored by an independent third-party investment firm). These various
categories are outlined below:
Active Involvement & Ownership:
The Principal is one of the managers of Singularity Capital Advisors LLC, Singularity Capital
Management LLC, SCM Opportunity I LLC and affiliates (“SCM Entities”). The SCM Entities were
established to invest in one early-stage venture capital company, which is currently closed to
new investors. The Principal is one of the managers, but does not have power to access or
move the financial assets in the entity (this power resides with the other manager, G.S. Jaggi).
As such, this entity is not deemed to have custody of client assets from the perspective of
WindRock Wealth Management. One of the SCM Entities (Singularity Capital Advisors LLC) is
the manager of SCM Opportunity I LLC, which is the fund through which investments are
owned; it also receives an annual management fee (1.5%) on investor capital contributed to
its fund. One of the other SCM Entities (Singularity Capital Management LLC) is entitled to
additional profit participation after investor capital has been returned and any preferred
returns are paid. The Principal is a 33 1/3% pro-rata owner of Singularity Capital Advisors LLC
and Singularity Capital Management LLC (the other owners include a client of WindRock and
a trust where a WindRock employee is a beneficiary (“Employee-Related Trust”)). Owners are
entitled to receive pro-rata profit distributions from the business operations of these entities.
The Principal is also an investor as a limited partner in SCM Opportunity I LLC.
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Strategic Advisory Role & Ownership:
The Principal
is a strategic advisor with no day-to-day operating or management
responsibilities at Iridius Investment Advisors LLC, Iridius Real Estate Managers LLC and Iridius
Capital LLC (collectively, the “IC Entities”). The IC Entities, and their affiliates, manage various
private real estate investments including the Iridius Real Estate Development Funds (“IREDFs”)
and the Iridius Real Estate Opportunity Funds (“IREOFs”), collectively referred to as “Iridius
Real Estate Funds”. Apart from the Iridius Real Estate Funds, Iridius Capital LLC, through its
affiliates, also manages various private lending vehicles (Iridius Income Fund LLC, Iridius
Income Fund QP LLC and Iridius Real Estate Income Fund LLC), collectively “Iridius Lending
Entities”, where the Principal is not involved as a strategic advisor nor has any day-to-day
operating or management responsibilities. Together, the Iridius Real Estate Funds and the
Iridius Lending Entities shall be referred to as “Iridius Entities”. The principal of the Iridius
Entities is a current WindRock client, G.S. Jaggi. The Iridius Real Estate Funds are private
investment vehicles investing in real estate opportunities, including (i) multi-family apartment
developments, primarily those branded as Avilla Communities currently in Arizona, Texas,
Colorado, Florida and Georgia and (ii) hospitality, offices, and retail.
In addition to being a strategic advisor to the IC Entities, the Principal has a minority equity
and profit interest in the IC Entities. The Principal owns a 10% ownership in Iridius Investment
Advisors LLC and Iridius Real Estate Manager LLC, which are the entities that receive either
annual management fees or due diligence fees from the real estate projects associated with
the Iridius Real Estate Funds. The Principal also has a 10% net profit interest in Iridius Capital’s
profits related to the Iridius Real Estate Funds. The net profits interest is subject to investment
performance criteria on each of the individual real estate projects. The Principal does not have
any ownership in the Iridius Lending Entities, but the Principal is an investor in various Iridius
Entities investments as a limited partner.
The Principal is a strategic advisor, with no day-to-day operating or management
responsibilities, of Singularity Capital LLC (“SC”) and its affiliated funds and special purpose
vehicles (collectively, “SC Entities”). The SC Entities pursue a variety of venture capital and
growth investments. Even though the SC Entities are similarly named as the SCM Entities,
they are different legal entities with different ownership structures.. The Principal is an
investor and minority equity member in Singularity Capital VT II GP LLC (“GP”), which is the
general partner of one of the SC funds, V-Tech II LP. The GP will be entitled to receive
certain carried interest distributions and profits related to its investment in V-Tech II LP. As a
member of the GP, the Principal will be entitled to receive its pro-rata share of distributions
from the GP, typically once investment return thresholds to limited partners have been
satisfied. The Principal is also an investor in various SC Entities investments as a limited
partner.
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Ownership Interest Only:
The majority of IREDFs are developed and managed by NexMetro Communities LLC and
affiliates (“NexMetro Entities”), an entity in which the Principal has a minority ownership
stake. The Principal has no advisory or day-to-day operating or management responsibilities
in the NexMetro Entities. NexMetro Entities charge fees including, but not limited to,
management, development, due diligence and profit participation fees. NexMetro Entities
pay Iridius Capital LLC for certain due diligence services on certain real estate projects in
which those IREDFs invest. Iridius Real Estate Manager LLC receives a fee for performing due
diligence services at the request of Iridius Capital LLC and the Principal receives a profit share
or general partner interest. Owners are entitled to receive pro-rata profit distributions from
the business operations of these entities.
The Principal and the Employee-Related Trust have a minority equity ownership in Bandon
River Capital LLC (“Bandon River”), a company factoring receivables and an investment owned
in one of the funds in the Iridius Income Fund Series. Owners are entitled to receive pro-rata
profit distributions from the business operations of these entities.
Third Party Investments:
WindRock also advises clients on investments sponsored by third-party investment firms,
where the Principal does not have ownership or an economic interest, does not serve in a
board of director or advisory capacity, nor has any day-to-day operating or management
responsibilities. Such third-party investments are negotiated by WindRock on an arms-length
basis. WindRock does not receive any financial incentive, including fees, profit sharing or
ownership. WindRock receives no commissions or fees from client investments in any
recommended third-party investment manager, mutual fund, exchange-traded fund, private
investment, derivative, broker or custodian.
About Private Investments
In general, the Principal may serve as an active manager or strategic advisor of private
investment offerings recommended to clients or directly at the underlying company or project
that a recommended private investment offering has invested in. This generally gives the
Principal more visibility and access than would otherwise be possible as a passive investor.
Additionally, the Principal invests his own capital into some of the private investment
opportunities recommended to clients or directly into underlying companies or projects
owned by these private investment offerings or funds that are recommended to clients. The
financial involvement of the Principal in private offerings may include (but is not limited to)
investing in the following investment types: equity, preferred equity, debt, loans and
promissory notes, convertible notes, lines of credit or any other form of investment capital. In
some situations, the investment of the Principal may be senior in the capital structure to the
investment made by clients. However, this is typically only done if it is deemed to be in the
best interest of the underlying company or project. In most situations, these instances can
develop if an investment has liquidity needs that other investors are unable or unwilling to
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participate in. In those situations, it is typical for a company to first come to its board members
or advisors for necessary capital. Further, the Principal may be reimbursed or have expenses
paid on his behalf for expenses including, but not limited to administrative expenses,
conferences, travel, dinners and entertainment for outside business activities or in his capacity
as an advisor.
Overall, because of the close relationship between the Principal to the underlying investments
of Iridius Entities, SCM Entities, SC Entities, and NexMetro Entities, conflicts of interest exist.
Investments made by these management entities may not be negotiated at arms-length,
although they believe such investment terms to be fair and reasonable. Some of the
underlying projects or investments may compete directly or indirectly with one another (e.g.
two Avilla projects being developed in a similar geographic region).
WindRock believes that the private investment opportunities offered by WindRock are
appropriate for clients who appreciate this entrepreneurial and active model of investing,
while understanding the conflicts of interests that arise from the Principal’s direct involvement
and investment in these opportunities. This model gives the Principal an incentive to advise
clients to invest in particular investments he has ownership in or has invested in himself. This
conflict of interest is addressed by only recommending that clients invest in opportunities
which are suitable and that fit within the client’s needs and risk tolerance. Investments in
private offerings on behalf of investors are non-discretionary and require client approval.
Although they may be recommended to an investor, the investor has a right to participate or
decline in each opportunity by their own election. If they agree to participate, the investor will
review and sign subscription documents of the private firm sponsoring the investment.
Further, many of the private opportunities that the Principal is invested in were created so that
clients would have access to an investment area WindRock found attractive, but did not find
suitable alternatives for. WindRock believes its success is driven by client satisfaction and
putting its clients’ interest first.
Clients may be able to obtain access to some of the same investment managers, mutual funds,
ETFs, private investments and other investments facilitated by WindRock directly without
going through WindRock. However, in order to do so, they may have to invest at substantially
higher minimum investment and/or pay higher management fees associated with such
investments. Some clients affiliated with WindRock are not charged a fee, including G.S. Jaggi,
or receive discounted fees.
Project Fees
In addition to its normal investment advisory services, WindRock is available to assist with
specific client-initiated projects. While most client requests are covered under our existing
relationship, WindRock reserves the right to quote fees for projects that fall outside the scope
of our arrangement. Fees for such projects are based on hourly rates, which vary from $200
to $500 in advance per hour. The client will be billed for the actual time spent by WindRock,
assessed in 15-minute increments, and a partial increment will be treated as a whole. The
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particular hourly fee applicable to each project is based upon the professional performing the
service. Mr. Rentmeester charges $500/hour for such projects, while an advisor with less
experience and expertise may charge $200/hour. Alternatively, a flat-fee may be charged on
a project basis. Each specific client-initiated project and the fees related thereto will be set
forth in a separate client engagement letter governing the terms, scope of work, and fees
charged for the specific project. Project fees may apply to all types of clients and will be
negotiated for each unique engagement in advance of beginning project work. Examples of
projects that could be performed by WindRock would include but not be limited to the
following, which assume an hourly fee of $500:
Cash Flow and Budget Analysis - $1,500 and up (3.5 + hours)
Retirement Planning and Investment Analysis - $2,500 to $7,000 (5 – 14 hours)
College Planning - $1,500 and up (3.5 + hours)
Investment Analysis - $3,000 and up (6 + hours)
Insurance Analysis - $1,500 and up (3 + hours)
Basic Financial Plan - $5,000 to $10,000 (10 to 20 hours)
Investment Research Projects - $1,500 and up (3 + hours)
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain bonds, mutual funds,
equities and exchange-traded funds. The selection of the security is more important than the
nominal fee that the custodian charges to buy or sell the security.
Advisor, in its sole discretion, may charge a lesser investment advisory fee based upon certain
criteria (e.g., historical relationship, type of assets, anticipated future earning capacity,
anticipated future additional assets, dollar amounts of assets to be managed, related
accounts, account composition, negotiations with clients, etc.).
Item 6: Performance-Based Fees and Side-By-Side Management
WindRock offers a program in which we share in the capital gains or capital appreciation for
clients that desire to focus their investment activity on a select group of investments, primarily
in the unique private investment category or related to digital assets/cryptocurrencies. This
program is offered only to Qualified Clients and must meet certain requirements to be able to
participate in being charged performance based fees which include:
1. A natural person who, or a company that, immediately after entering into the contract
has at least $1,000,000 under the management of the investment advisors;
2. Has a net worth (together, in the case of a natural person, with assets held jointly with
a spouse) of more than $2,100,000. The persons’ residence must not be included as
an asset.
Fees for this arrangement are negotiable and typically represent a percent of the gross gain.
Some may have a pre-determined target return, which may be absolute or relative in nature,
and some may not.
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The client will pay an annual advisory fee based on the assets under management not to
exceed 2.0% and/or a performance fee not to exceed 30% of the agreed upon benchmark. To
the extent that we charge a performance–based fee, the performance-based fee will comply
with the requirements of Section 205 and Rule 205-3 under the Investment Advisers Act of
1940.
The simultaneous management of these different types of client accounts, with different fee
structures, creates certain conflicts of interest, as the fees for the management of some client
types are higher than for others. Nevertheless, when managing the assets of these accounts,
we have a duty to treat all accounts fairly and equitably over time.
Additionally, since performance-based fees reward us for strong performance in accounts
which are subject to such fees, we may have an incentive to favor these accounts over those
that have only asset-based fees (i.e., fees based simply on the amount of assets under
management in an account) with respect to areas such as trading opportunities, trade
allocation, and allocation of new investment opportunities.
To mitigate the conflict, we represent that it is not our intent to trade a client’s account in an
irresponsible, unethical or baseless manner, or to assume unnecessary risk given potential
perceived reward. We will never knowingly or intentionally breach the fiduciary duty we owe
to a client, and we believe the incentive or performance fee portion of its compensation aligns,
rather than divides, the interests of clients and us in addition, the client may choose to place
their account in the advisory fee only program.
Item 7: Types of Clients
WindRock oversees investment portfolios primarily for high net worth families, individuals,
family offices, and various entities associated with these individuals (e.g. private foundations,
family partnerships, etc.).
Client relationships vary in scope and length of service.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
WindRock serves as an investment strategist for clients and believes that an effective
investment strategy needs to incorporate a big-picture view on the macroeconomic state of
the world. Most investors are overwhelmed with data overload and need a trusted adviser
with a process that can filter all of this information to identify the key factors to focus on for
actionable decisions when managing portfolios. We believe that the “writing is often on the
wall” as to the macroeconomic direction ahead, but most investors do not see it because their
outlook is clouded by too much data overload. In hindsight, most investors now acknowledge
the technology bubble in 2000 and the housing bust of 2008, but at the time it is hard for most
to see. The first part of the process is to identify the key macroeconomic trends, which we
believe is a key to arriving at an appropriate asset allocation. We seek to identify the prevailing
themes looking out over a multi-year horizon. We subscribe to a group of third-party
macroeconomic forecasters and experts that we believe have historically gotten the big
15
picture direction of the stock market and the economy correct. These tend to be independent
firms not beholden to any particular point of view, allowing them to forecast honestly and
without bias. Our years in the industry have allowed us to identify who we believe to be the
key forecasters in this regard. We next funnel the views of these forecasters, focusing on
similarities in outlooks and trying to understand differences. We apply our judgment as a firm
and refine the multiple views into a macroeconomic outlook that drives our decision making.
In addition, we may gather views from other skilled investors in our network of influence
whether investment managers, sophisticated family offices or individual investors with
particular knowledge. The final judgment on the macroeconomic view resides with the
Principal. Once we have the key macroeconomic issues identified, we seek out investments
in different asset classes that we believe will benefit from our economic view, while keeping
diversification and risk management at the center of our process.
Traditional Investments
Our approach to finding traditional investment managers (e.g. stocks, bonds and certain
tactical allocation strategies in mutual fund, ETF or managed accounts) is to utilize the best
ideas of outside research providers combined with selections based on our own proprietary
research. We utilize outside research firms for their list of approved traditional investment
opportunities. We utilize research available to us through Charles Schwab, SpringTide
Partners and other sources as well as our own in-house research. We favor proven investment
managers who we determine have the ability to successfully navigate the market ahead as
well as low-cost index mutual funds and ETFs that mimic their respective investment markets.
In situations where a client has an outside asset with limited investment choices (such as a
predetermined roster of investment choices in a 401(k) plan) we recommend funds that fit the
client’s overall asset allocation strategy. We do not do extensive or ongoing due diligence on
these funds and rely on the client to provide updated information.
Alternative Investments
Our approach to identifying alternative investment managers (e.g. hard assets, tactical
strategies and unique situations) is to utilize the research of several third-party research firms
focused in the alternative investment space, some of which have a particular focus on hard
assets or commodities. Examples of such providers include SpringTide Partnersand resources
at Charles Schwab. Ultimately, the research in the area of hard assets culminates into a
diversified mix of assets that are positioned to benefit from inflation with major categories
including: precious metals (bullion and miners) diversified commodities (e.g. energy, metals,
and agriculture/farmland), foreign currencies and unique situations (including digital assets).
Private Investments
WindRock utilizes Iridius Entities, SCM Entities, SC Entities, as well as various third-party
managers to provide investors with unique private investment opportunities. Investors who
are notified of the private investment opportunities have the right to participate or decline by
16
their own election. They acknowledge (i) Their desire to diversify their portfolios by including
private investments in their portfolios, and (ii) That such investor is aware of the relationship
between WindRock, Iridius Entities, SCM Entities and SC Entities through disclosures.
Although not anticipated, there is a risk that an investor may lose their entire investment in a
private investment or only receive a partial return of their initial capital contribution. Further,
private investments are inherently illiquid and can sometimes remain illiquid for longer
periods than originally projected. Additionally, because of the close relationship between the
Principal and the majority of the private investment opportunities, underlying companies and
projects, the success of the private investments can be related to the success of the Principal
overall. General and specific risk associated with each private investment are more particularly
described in the offering documents sent to investors and should be reviewed very carefully.
In addition to providing private placement investment opportunities with Iridius Entities, SCM
Entities and SC Entities, WindRock evaluates third-party private investment opportunities that
we find through various third party research services and our informal network of investors,
investment managers, and family offices. With the exception of investment opportunities
through Iridius Real Estate Entities, SCM Entities and SC Entities, the Principal does not earn
any compensation for recommendations to outside investment firms.
Security Specific Material Risks
Any investment involves risk of loss that clients should be prepared to bear. Further, investing
in any private investments brings unique risks such as lack of liquidity, concentration risk, lack
of transparency, leverage and potential total loss of investment. Clients should only consider
private investments in situations where they don’t have a need for the money and could
sustain a total loss of capital.
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following investment
risks:
•
Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
political, economic and social conditions may trigger market events.
•
Inflation Risk: When any type of inflation is present, a dollar today will buy more than
a dollar next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also referred
to as exchange rate risk.
17
• Reinvestment Risk: This is the risk that future proceeds from investments may have to
be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily
relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding oil
and then refining it, a lengthy process, before they can generate a profit. They carry a
higher risk of profitability than an electric company which generates its income from a
steady stream of customers who buy electricity no matter what the economic
environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties are
not. Private investments can remain illiquid for longer than anticipated.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk
of profitability, because the company must meet the terms of its obligations in good
times and bad. During periods of financial stress, the inability to meet loan obligations
may result in bankruptcy and/or a declining market value.
• Digital Asset Risk: Digital assets (e.g. cryptocurrencies) have unique risks as it is a new
and unproven technology and investment category. Risks include extreme volatility,
potential for a full loss of capital, technology issues that result in wallets being hacked
and funds lost as well as regulatory and tax uncertainties.
• Lack of Diversification Risk: Many of the private investments are specifically related to
the principals and may be focused on concentrated areas (e.g. real estate), have key-
man risk, or other inherent risk of relying on one firm’s judgement in private
placements.
Item 9: Disciplinary Information
Criminal or Civil Actions
The firm and its management have no reportable criminal or civil actions to report.
Administrative Enforcement Proceedings
The firm and its management have not been involved in administrative enforcement
proceedings to report.
Self-Regulatory Organization Enforcement Proceedings
The firm and its management have not been involved in legal or disciplinary events that are
material to a client’s or prospective client’s evaluation of Advisor or the integrity of its
management.
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Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Advisor is not a broker-dealer and Brett Rentmeester is not a registered representative of a
broker-dealer.
Futures or Commodity Registration
Neither Advisor nor its employees are registered or has an application pending to register as
a futures commission merchant, commodity pool operator, or a commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
PRIVATE INVESTMENT OPPORTUNITIES
WindRock offers to its client’s private investment opportunities managed by Iridius Entities,
SCM Entities and SC Entities where the Principal has conflicts of interest, as more particularly
described in the section title “Conflicts of Interest” in Item 5 above.
In addition to private investments through Iridius Entities, SCM Entities, and SC Entities,
WindRock may also recommend private investments from outside third-party investment
firms. Any investments in such investments are negotiated by WindRock on an arms-length
basis and WindRock does not receive any financial incentive, including fees, profit sharing or
ownership. WindRock receives no commissions or fees from client investments in any
recommended third-party investment manager, mutual fund, exchange-traded fund, private
investment, derivative, broker or custodian.
Newsletters and Publications
From time to time WindRock distributes newsletters, updates, self-generated publications and
other media to its clients. These publications and newsletters are typically distributed through
email and through WindRock’s website at www.windrockwealth.com. All newsletters and self-
generated publications are available to all clients and are free of charge. For more information
and samples of WindRock’s content, please see the “Research and Analysis” section of
WindRock’s website at www.windrockwealth.com/research-and-analysis.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
From time to time, WindRock may also utilize the services of a sub-adviser/investment
manager to manage clients’ investment portfolios. Sub-advisors will maintain the models or
investment strategies agreed upon between Sub-advisor and WindRock. Sub-advisors execute
all trades on behalf of WindRock in client accounts. Such Advisors shall have all of the same
authority relating to the management of Client’s investment accounts as is granted to
WindRock in the Agreement. Fees charged by the Sub-Advisor are in addition to any fees
charged by WindRock.
WindRock will be responsible for the overall direct relationship with the client. WindRock
retains the authority to terminate the Sub-advisor relationship at WindRock’s discretion.
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics Description
WindRock has adopted a written Code of Ethics that mimics the Code of Ethics adopted by the
CFA Institute. We believe that the CFA Institute is leading authority in the investment
management field for ethics in the profession. The goal of the Code of Ethics is to identify
conflicts of interest and to oversee personal securities transactions of employees and officers.
Employees are allowed to engage in the purchase of securities, mutual funds, ETFs and private
investments as long as their behavior follows the Code of Ethics. WindRock’s focus is putting
client interests first and ensuring that no actions negatively impact clients. WindRock's Code
of Ethics requires individuals to report their personal securities transactions on a quarterly
basis to WindRock's compliance personnel, who review such reports to ensure compliance
with the Code of Ethics. A copy of the Code of Ethics will be furnished to any client or
prospective client upon request. All Employees have signed a copy and agree to adhere to the
Code of Ethics.
The Principal invests their own capital in some of the private investment opportunities offered
by Iridius Entities, SCM Entities, and SC Entities. The Principal may also serve as an advisory
board member, director or manager of the underlying project or company of a private
investment opportunity recommended to clients. These activities result in a conflict of interest.
WindRock follows the code of ethics described above and will provide full disclosure of such
relationships to its clients. For additional information on the Principal’s involvement in client
transactions, please see Item 5, “Conflicts of Interest”. The firm will provide a copy of the Code
of Ethics to any client or prospective client upon request.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
We generally process security sales and purchases through the client's custodian. Under these
circumstances, WindRock does not have any obligation to seek better execution services or
prices from other possible brokers or dealer. WindRock does not aggregate client transactions
for execution, which might cause the client to incur higher fees than they may have incurred
if the trade had been affected in aggregation with other clients.
Principals of the firm may recommend custodians or brokers that have agreed to preferred
pricing arrangements for WindRock clients such that all negotiated terms directly benefit the
client through enhanced services or reduced fees. Recommended brokers or custodians are
not necessarily the lowest cost provider, but are believed to be competitively priced for the
level of service provided. Recommended brokers or custodians are selected based on
WindRock’s consideration of the broker or custodian's general reputation, level of services
provided, competitiveness of fees or special expertise.
WindRock does not receive any cash compensation or research (typically referred to as “soft
dollar” payments) from brokers it recommends to clients. WindRock may occasionally receive
complimentary admittance for its employees to attend seminars and conferences sponsored
20
by the brokers it recommends. We do not receive travel or reimbursement for other expenses
related to attending these conferences.
WindRock generally recommends brokers to clients that have demonstrated the ability to
provide our clients with discounted transaction charges, preferred access to certain mutual
funds, including lower sales charges than for direct purchases and lower minimum purchase
amounts, and the ability to custody and safeguard derivative investments. These same
benefits are made available to WindRock's principals and employees. The benefits to
WindRock and its principals and employees are not a material factor in determining which
brokers to recommend. The primary considerations are the services provided to the client.
WindRock does not expect that clients will pay commissions to brokers we recommend that
are higher than those obtainable from other brokers for comparable client services, although
there can be no assurance that clients will pay the lowest possible commissions available.
When referring clients to outside brokers or dealers, WindRock will only recommend brokers
which are licensed in the same state as where the client resides.
Item 13: Review of Accounts
WindRock utilizes third-party technology to monitor client portfolios and accounts are
reviewed at least quarterly. Clients will meet with their WindRock contact as needed to review
their strategic investment plan, their overall financial situation and their investment portfolio.
Wealth Management clients have portfolios actively managed and reviewed at least quarterly,
communicated on a quarterly webcast.
Item 14: Client Referrals and Other Compensation
WindRock may refer clients to third parties in areas where clients need assistance (e.g. legal,
accounting, lending, etc.). WindRock has no affiliation to firms they may recommend and
receives no compensation for referring them. These same firms to which WindRock may refer
clients may make referrals to WindRock when clients need services such as WindRock
provides.
WindRock may also refer its clients to Iridius Entities, SCM Entities, and SC Entities. WindRock
has a formal relationship with these entities to provide select investors with unique private
investment opportunities, as described in Item 5 “Conflict of Interest” of Part 2A of this form
ADV. The Principal receives compensation from these entities as described in Item 5 of Part
2A of this form ADV. In addition to receiving compensation, there are additional conflicts of
interest that arise with the Principal offering private investment opportunities in these entities
to clients. Please refer back to Item 5 section title “Conflicts of Interest” above in the Part 2A
of this form ADV for a description of the conflicts of interest.
WindRock may, from time to time, enter into agreements with individuals and organizations,
which may be affiliated or unaffiliated with WindRock, that refer clients to WindRock in
exchange for compensation. All such agreements will be in writing and comply with the
requirements of Federal or State regulation. If a client is introduced to WindRock by a solicitor,
WindRock may pay that solicitor a fee. While the specific terms of each agreement may differ,
21
generally, the compensation will be based upon WindRock engagement of new clients and is
calculated using a varying percentage of the fees paid to WindRock by such clients. Any such
fee shall be paid solely from WindRock‘s investment management and/or incentive fee and
shall not result in any additional charge to the client.
Each prospective client who is referred to WindRock under such an arrangement will receive
a copy of this brochure and a separate written disclosure document disclosing the nature of
the relationship between the solicitor and WindRock and the amount of compensation that
will be paid by WindRock to the solicitor. The solicitor is required to obtain the client’s
signature acknowledging receipt of WindRock‘s disclosure brochure and the solicitor’s written
disclosure statement.
Item 15: Custody
Custody, as it applies to investment advisors, has been defined by regulators as having access
or control over client funds and/or securities. In other words, custody is not limited to
physically holding client funds and securities.
Some investors have standing letters of authorization to move funds from amongst their like-
registered custody, bank and other investment accounts. These arrangements are set up by
clients individually, requiring their approval for the standing authorization.
Clients receive statements at least quarterly from their custodian or other source as available,
whether electronically or as paper statements. WindRock’s reports may vary from the
statements due to accounting issues and methodology. A common example would be a late
dividend (posted after month-end, but attributable to the month) that is reflected in
WindRock’s figures but does not get reflected on the client’s statement with the custodian.
Item 16: Investment Discretion
At the inception of the client engagement, WindRock documents the scope of its discretionary
authority in a written engagement contract with clients. After developing an overall strategy
documented in a written Investment Policy Statement, signed by the client, that includes
investment guidelines, WindRock is directly responsible for making investment decisions on
behalf of those clients within the predetermined guidelines of that agreement. In all cases,
however, such discretion is exercised in a manner consistent with the stated investment
objectives for the particular client account. For private investment opportunities, clients must
always be the decision maker as it relates to participating or not.
Item 17: Voting Client Securities
WindRock does not vote proxies on securities. Clients are expected to vote their own proxies.
The client will receive their proxies directly from the custodian of their account or from a
transfer agent.
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Item 18: Financial Information
WindRock has no financial commitment that impairs its ability to meet contractual and
fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding.
WindRock does not have custody of client funds or securities or require or solicit prepayment
of more than $500 in fees per client six months in advance.
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Brochure Supplement (Part 2B of Form ADV) – Brett K. Rentmeester
Item 1 Cover
Supervised Person Brochure
Form ADV Part 2B
WindRock Wealth Management LLC
225 West Jefferson Avenue, Suite 2
Naperville, IL 60540
This brochure supplement provides information about Brett Rentmeester, which supplements
WindRock Wealth Management LLC’s (“WindRock”) brochure. You should have received a copy
of that brochure. If you have any questions about the contents of this brochure, please contact
WindRock at (312) 650-9593.
Additional information about Brett K. Rentmeester (CRD #2631078) is also available on the SEC’s
website at www.adviserinfo.sec.gov
March 2025
24
Supervised Person Brochure
Principal Executive Officer
Brett K. Rentmeester
• Year of birth: 1974
Item 2 Educational Background and Business Experience
Brett K. Rentmeester is the Principal and Managing Director of WindRock. Brett is a veteran
and entrepreneur in the investment business. Previously, he was a founding partner of Altair
Advisers, an investment advisor in Chicago. As a founding partner of Altair Advisers, Brett’s
role included client service, business development, and firm-wide strategy. Prior to forming
Altair Advisers, Brett was a manager in Arthur Andersen's Private Client Services practice,
specializing in investment advisory and wealth planning services.
Brett is a Chartered Financial Analyst®, (CFA®), charter holder and has earned the Chartered
Alternative Investment Analyst designation (CAIA).
Brett has an MBA from the Northwestern University Kellogg Graduate School of Management.
He graduated magna cum laude from the University of Arizona with a degree in Finance.
Item 3 Disciplinary Information
None to report
Item 4 Other Business Activities Engaged In
As more particularly described in Item 5 of Part 2A of this form ADV, Brett Rentmeester is
involved in a number of outside business activities.
Mr. Rentmeester is actively involved as a manager of Singularity Capital Advisors LLC,
Singularity Capital Management LLC, SCM Opportunity I LLC and affiliates (“SCM Entities”). The
SCM Entities made one investment in an early-stage company. The Principal is a 33 1/3% pro-
rata owner of Singularity Capital Advisors LLC and Singularity Capital Management LLC (the
other owners include a client of WindRock and a trust where a WindRock employee is a
beneficiary (“Employee-Related Trust”)). Owners are entitled to receive pro-rata profit
distributions from the business operations of these entities. He spends <1% of his time on
these activities.
Mr. Rentmeester is a strategic advisor with no day-to-day operating or management
responsibilities at Iridius Investment Advisors LLC, Iridius Real Estate Managers LLC and Iridius
Capital LLC (“IC Entities”) that manage a series of private real estate funds including the Iridius
Real Estate Development Funds (“IREDFs”) as well as the Iridius Real Estate Opportunity Funds
(“IREOs”), collectively referred to as “Iridius Real Estate Funds”. Apart from the Iridius Real
Estate Funds, Iridius Capital LLC, through its affiliates, also manages various private lending
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vehicles (Iridius Income Fund LLC, Iridius Income Fund QP LLC and Iridius Real Estate Income
Fund LLC), collectively “Iridius Lending Entities”, where the Principal is not involved as a
strategic advisor nor has any day-to-day operating or management responsibilities. Together,
the Iridius Real Estate Funds and the Iridius Lending Entities shall be referred to as “Iridius
Entities”.
In addition to being a strategic advisor to the IC Entities, the Principal has a minority equity
and profit interest in the IC Entities. The Principal owns a 10% ownership in Iridius Investment
Advisors LLC and Iridius Real Estate Manager LLC, which are the entities that receive either
annual management fees or due diligence fees from the real estate projects associated with
the Iridius Real Estate Funds. The Principal also has a 10% net profit interest in Iridius Capital’s
profits related to the Iridius Real Estate Funds. The net profits interest is subject to investment
performance criteria on each of the individual real estate projects. The Principal does not have
any ownership in the Iridius Lending Entities. The Principal, as one of the owners in the listed
entities, is entitled to receive pro-rata profit distributions from the business operations of
these entities. He spends <5% of his time on these activities.
is a strategic advisor, with no day-to-day operating or management
The Principal
responsibilities, of Singularity Capital LLC (“SC”) and its affiliated funds and special purpose
vehicles (collectively, “SC Entities”). The SC Entities pursue a variety of venture capital and
growth investments which are similarly named, but different legal entities with a different
ownership structure than Singularity Capital Management (“SCM Entities”). The Principal is an
investor and minority member in Singularity Capital VT II GP LLC (“GP”), which is the general
partner of one of the SC funds, V-Tech II LP. The general partner of V-Tech II LP will be entitled
to receive certain carried interest distributions and other fee compensation for its investment
in V-Tech II LP after investor capital has been returned and any preferred returns are paid. As
a member of the general partner, the Principal will be entitled to receive its pro-rata share of
distributions from the general partner, typically once investment return thresholds to limited
partners have been satisfied. He spends <5% of his time on these activities.
Mr. Rentmeester is a strategic advisor and Chief Investment Officer for the Jaggi Family Office.
He attends conferences, speaks at events and does due diligence on investment opportunities
and consults the family in this capacity. The investments researched for the Jaggi Family Office
may vary from investments made available to WindRock clients, but at times they are
opportunities that are offered to WindRock clients depending on suitability for each client.
Brett receives compensation for time spent on this activity. Further, Brett may be reimbursed
or paid for expenses including, but not limited to administrative, conferences, travel and
dinners/entertainment expenses for activities related to the Jaggi Family Office. He spends
<20% of his time on these activities.
In all situations other than his more active role as the Chief Investment Officer of the Jaggi
Family Office and as manager of the SCM Entities, Mr. Rentmeester provides an advisory role
function to the organizations not related to activities as an investment advisor at WindRock.
Time commitments vary based on the stage of development and other activities at each
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outside business activity, but are seen by Mr. Rentmeester as being additive to WindRock as
they bring additional knowledge and opportunities for WindRock to consider. For all listed
outside business activities, Mr. Rentmeester may be reimbursed for expenses or have
expenses paid on his behalf including, but not limited to administrative, conferences, travel,
room & board, dinners, and entertainment expenses.
Item 5 Additional Compensation
Brett Rentmeester receives compensation from Iridius Real Estate Entities, SCM Entities and
SC Entities as described in Item 5 of Part 2A of this form ADV or Item 4 above. In addition to
receiving compensation there are additional conflicts of interest that arise with Principal
offering private investment opportunities in these entities to clients. Please refer back to Item
5 section title “Conflicts of Interest” above in the Part 2A of this form ADV for a description of
the conflicts of interest. In his roles with outside business activities (including the Jaggi Family
Office), Mr. Rentmeester may be reimbursed for expenses or have expenses paid on his behalf
including, but not limited to administrative, conferences, travel, room & board, dinners, and
entertainment expenses.
Item 6 Supervision
Brett K. Rentmeester is the Chief Compliance Officer of WindRock. He is responsible for
overseeing and enforcing the firm’s compliance programs that have been established to
monitor and supervise the activities and services provided by the firm and its
representatives. Brett K. Rentmeester can be contacted at (312) 650-9593.
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Brochure Supplement (Part 2B of Form ADV) – Christopher P. Casey
Item 1 Cover
Supervised Person Brochure
Form ADV Part 2B
WindRock Wealth Management LLC
225 West Jefferson Avenue, Suite 2
Naperville, IL 60540
This brochure supplement provides information about Christopher P. Casey, which supplements
WindRock Wealth Management LLC’s (“WindRock”) brochure. You should have received a copy
of that brochure. If you have any questions about the contents of this brochure, please contact
WindRock at (312) 650-9593.
Additional information about Christopher P. Casey (CRD #6587454) is also available on the SEC’s
website at www.adviserinfo.sec.gov
March 2025
28
Supervised Person Brochure
Principal Executive Officer
Brett K. Rentmeester
• Year of birth: 1971
Item 2 Educational Background and Business Experience
Educational Background:
• University of Illinois; Bachelor of Arts – Economics; 1993
Business Experience:
• WindRock Wealth Management LLC; Investment Advisor Representative;
01/2016 - Present
• WindRock Wealth Management LLC; Managing Director; 01/2013 – Present
• Unemployed; 07/2012 – 12/2012
• Stout Risius Ross; Director; 02/2002 – 06/2012
Professional Certifications
Employees have earned certifications and credentials that are required to be explained in
further detail.
Chartered Financial Analyst (CFA): Chartered Financial Analysts designation is awarded by the
CFA Institute. CFA certification requirements:
• Hold a bachelor’s degree from an accredited institution or have equivalent education
or work experience.
• Successful completion of all three exam levels of the CFA Program.
• Have 48 months of acceptable professional work experience in the investment
decision-making process.
• Fulfill society requirements, which vary by society. Unless you are upgrading from
affiliate membership, all societies require two sponsor statements as part of each
application; these are submitted online by your sponsors.
• Agree to adhere to and sign the Member's Agreement, a Professional Conduct
Statement, and any additional documentation requested by CFA Institute.
Item 3 Disciplinary Information
None to report
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Item 4 Other Business Activities Engaged In
None
Item 5 Additional Compensation
Mr. Casey receives additional compensation in his role as Managing Director for WindRock
Wealth Management LLC. He does not receive any performance-based fees.
Mr. Casey is a beneficiary of a trust (“Employee-Related Trust”) that has a minority ownership
interest in Bandon River. Owners are entitled to receive pro-rata profit distributions from the
business operations of these entities.
Item 6 Supervision
Christopher Casey is supervised by Brett K. Rentmeester, Chief Compliance Officer. He reviews
Chris’ work through client account reviews and quarterly personal transaction reports, as well
as face-to-face and phone interactions. Mr. Rentmeester may be reached at (312) 650-9593 or
by email at brett.rentmeester@windrockwealth.com.
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Brochure Supplement (Part 2B of Form ADV) – Brandy C. Maben
Item 1 Cover
Supervised Person Brochure
Form ADV Part 2B
WindRock Wealth Management LLC
225 West Jefferson Avenue, Suite 2
Naperville, IL 60540
Located at: Private Residence,
Tucson, AZ
This brochure supplement provides information about Brandy C. Maben, which supplements
WindRock Wealth Management LLC’s (“WindRock”) brochure. You should have received a copy
of that brochure. If you have any questions about the contents of this brochure, please contact
WindRock at (312) 650-9593.
Additional information about Brandy C. Maben (CRD #6932952) is also available on the SEC’s
website at www.adviserinfo.sec.gov
March 2025
31
Supervised Person Brochure
Investment Advisor Representative
Brandy C. Maben
• Year of birth: 1985
Item 2 Educational Background and Business Experience
Educational Background:
• Louisiana State University; Master of Science – Sports Management; 2012
• University of Arizona; Bachelor of Science – Psychology, Communications &
Education; 2008
Business Experience:
• WindRock Wealth Management LLC; Investment Advisor Representative; 07/2022 -
Present
• Levin Funding Group; Solicitor; 06/2020 – 07/2022
• Arizona Swim Camp, LLC; Director & Owner; 06/2015 – Present
• Maben Insurance Services, LLC; Agent; 03/2020 – 07/2022
• Maben Funding Group, LLC; Investment Advisor Representative; 03/2020 – 07/2022
• KMS Financial Services; Investment Advisor Representative; 04/2018 – 03/2020
• Demont Family Swim School; Swim Lessons; 09/2017 – 12/2017
• University of Arizona; Head Recruiting Coordinator and Assistant Men’s & Women’s
Swim Coach; 09/2012 – 09/2017
Item 3 Disciplinary Information
None to report
Item 4 Other Business Activities Engaged In
Brandy C. Maben is the Director and Owner at Arizona Swim Camp, LLC, a swim camp run in
Flagstaff Arizona. She spends 5 hours per month during non-securities trading hours of her
time on these activities.
Item 5 Additional Compensation
Mrs. Maben receives compensation in her role as Owner of Arizona Swim Camp.
Item 6 Supervision
Brandy C. Maben is supervised by Brett K. Rentmeester, Chief Compliance Officer. He reviews
Chris’ work through client account reviews and quarterly personal transaction reports, as well as
face-to-face and phone interactions. Mr. Rentmeester may be reached at (312) 650-9593 or by
email at brett.rentmeester@windrockwealth.com.
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