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PART 2A OF FORM ADV
THE BROCHURE
LNW Wealth Management, LLC
801 Second Avenue, Suite 1600, Seattle, WA 98104
LNWadvisors.com
This brochure provides information about the qualifications and business practices of LNW Wealth Management,
LLC (“LNW”).
If you have any questions about the contents of this brochure, please contact us at 206-464-5100. 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.
LNW is a registered investment adviser. Registration as an investment adviser does not imply a certain level of skill
or training.
Additional information about LNW is also available on the SEC’s website at: www.adviserinfo.sec.gov.
LNW Wealth Management, LLC
Part 2A of Form ADV
2. Material Changes
This Brochure replaces the previous Brochure dated March 2024. Following is a summary of the material
changes that have been made to the Brochure since the previous update:
Item 5: This has been updated to reflect Assets Under Management (AUM) as of December 31, 2024.
Item 8: This has been revised to update certain risk factors for changes in the macroeconomic
environment and regulatory changes.
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3. Table of Contents
1. Cover Page ...........................................................................................................................................................................................1
2. Material Changes ............................................................................................................................................................................ 2
3. Table of Contents ............................................................................................................................................................................ 3
4. Advisory Business .......................................................................................................................................................................... 4
5. Fees and Compensation ............................................................................................................................................................... 6
6. Performance Based Fees and Side-by-Side Management .............................................................................................. 7
7. Types of Clients ................................................................................................................................................................................ 7
8. Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................................... 8
9. Disciplinary Information ............................................................................................................................................................. 14
10. Other Financial Industry Activities and Affiliations ......................................................................................................... 14
11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................... 14
12. Brokerage Practices .................................................................................................................................................................. 15
13. Review of Accounts ................................................................................................................................................................... 18
14. Client Referrals and Other Compensation......................................................................................................................... 19
15. Custody .......................................................................................................................................................................................... 19
16. Investment Discretion .............................................................................................................................................................. 20
17. Voting Client Securities ............................................................................................................................................................ 21
18. Financial Information ................................................................................................................................................................. 21
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4. Advisory Business
LNW Wealth Management, LLC (“LNW”) is a limited liability company founded in 2001 and owned by Laird
Norton Wetherby Trust Company, LLC. Both entities, along with its affiliates Laird Norton Wetherby Wealth
Management, LLC and LNW Trust Company of South Dakota, LLC, operate under the trade name of LNW
(also known as Laird Norton Wetherby).
LNW’s clients are predominantly wealthy individuals and families with complex holdings and a need for
comprehensive investment and financial advice. LNW may advise and provide services to many different
accounts and entities related to its clients, including personal and retirement accounts, education savings
accounts, accounts of minor children, revocable and irrevocable trusts, family partnerships, foundations,
charitable organizations and similar entities. The complexity of clients’ financial lives often requires that
LNW work in close collaboration with other advisors that the client has engaged, including other investment
advisors, attorneys, CPAs, insurance professionals, and bill payment services. LNW is not affiliated with, and
has no financial arrangements with, any of these other advisors.
To guide and inform its work with each client LNW will jointly formulate an investment policy statement (IPS)
that summarizes the client’s goals, objectives, constraints, risk tolerance and unique circumstances,
including such factors as time horizon, projected future liquidity needs, current holdings, tax considerations,
and personal market or investment views. A client may have more than one IPS; for example, when one
account or entity within a client relationship has a distinct legal status or unique goals, objectives,
constraints, circumstances or risk tolerance. The IPS guides LNW in objectively formulating suitable
investment and financial recommendations for each client.
As a consequence of the complexity of clients’ financial lives and the customized advice LNW offers, each
client’s investment portfolio is unique, although it may share common characteristics with portfolios that
have similar investment objectives. Because each portfolio is unique, investment results may vary, even
between accounts that have similar investment objectives or similar portfolios. Idiosyncratic factors that
can influence the composition of a client’s portfolio and investment results include (but are not limited to):
• Whether LNW has been given discretion over any part or all of the portfolio.
• Decisions made by the client whether to invest (or not invest) in any security or
investment product LNW may recommend from time to time.
• The timing of initiation of the portfolio, or any investment or part of the portfolio,
including amounts added to or withdrawn from the portfolio.
• Whether the portfolio contains any legacy holdings or positions (those that pre-date
engagement of LNW), or investments made by the client during the engagement that
have not been recommended by the team which LNW may agree to incorporate into
portfolio reporting or analysis as requested by the client.
•
Investment constraints and restrictions imposed by the client on the types of
investments that may be made or the types of securities that may be purchased for the
portfolio, which LNW may consent to but not recommend.
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• Regulatory constraints that may apply to any part or all of the portfolio.
LNW’s Integrated Investment & Wealth Advisory Offering
LNW offers personalized service and a comprehensive wealth management offering which scales in scope
and complexity for each client’s financial situation and goals.
LNW’s wealth management offering is tailored to each clients’ individual needs and goals – both initially and
as those needs and goals may change over time. Most commonly LNW is engaged to provide an integrated
offering that includes investment management, wealth planning, and collaborative professional services.
While not exhaustive, following are examples of the integrated services LNW offers:
•
Investment Management: (i) development of an Investment Policy Statement
customized for the client’s time horizon, risk tolerance and investment targets; (ii)
design of an asset allocation tailored to client-specific circumstances; (iii) development
of financial modelling or financial projections to test and support asset allocation
decisions; (iv) investment product due diligence, selection and recommendation; (v)
discretionary and/or non-discretionary investment implementation, ongoing
supervision, monitoring and portfolio rebalancing activities; (vi) quarterly client
investment and performance reporting; and (vii) periodic meetings with the client’s
wealth management team, either virtually, at LNW’s offices or at other mutually
convenient locations. In certain cases, LNW will accept direction from clients regarding
specific investments and will hold specific securities in the client’s account.
• Wealth Planning: The scope of wealth planning services is determined by the client and
may also include planning in connection with (i) financial independence/retirement
planning; (ii) capital and liquidity needs analysis and related financial modelling; (iii)
philanthropy planning and implementation; (iv) education planning; (v) employee stock
option planning; (vi) consideration and evaluation of financing transactions and risk
reduction strategies for concentrated equity positions; (vii) advice incident to major
asset purchases and sales; and (viii) managing philanthropic plans, tax strategies,
wealth transfer strategies, and legacy plans
as desired.
• Collaborative Services: LNW also provides, or coordinates the provision of, other
related financial services such as estate, financial and tax planning in consultation with
other professionals that the client has engaged, including attorneys and accountants.
Its team may: (i) coordinate with client’s CPA on matters of income tax planning and
reporting; (ii) coordinate with client's lawyer on matters of estate planning and gifting;
(iii) coordinate with client's third-party providers of life, disability, and other lines of
personal insurance; and (iv) coordinate with client's third-party bill payment service
provider.
Through this offering LNW will provide investment advice and recommendations regarding the types of
investments that LNW believes to be appropriate for its clients. When providing investment advice, LNW will
recommend the purchase of various publicly available funds such as mutual funds and exchange traded
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funds (“ETFs”). LNW may also recommend investments in private securities and/or hiring third party
investment managers. LNW may agree to manage individual stocks or bonds in limited circumstances.
LNW provides investment management services to LNWM Renewable Power Fund, L.P (the “Fund,”) a
privately offered pooled investment vehicle. Access to the Fund was limited to clients who met the Fund’s
qualification requirements. This Fund is now closed to new investors. LNW is the general partner and
investment advisor to this Fund, which is structured as a Washington domiciled limited partnership. An
investment in this Fund is considered illiquid and subject to limitations on withdrawals; it is not suitable for
all clients.
As of December 31, 2024, LNW managed $ 3,739,625,582.04 on a discretionary basis and $ 786,659,193.82
on a non-discretionary basis.
5. Fees and Compensation
LNW is paid exclusively by its clients. For some clients, LNW will charge a fee based on a percentage of the
market value of assets held in a client’s portfolio. For others, LNW will charge a retainer or other fixed fee to
cover investment and financial advisory services or for special accounts or projects. Whether charged
based on assets under management or as an annual retainer, annual fees range between .90% and .30% of
total assets managed by LNW and may be subject to an annual fee minimum. If services are being provided
to multiple accounts or entities related to a client family, fees may be allocated among the various accounts
or entities in a mutually agreeable manner. Other factors used to determine the method of charging fees
include the historical nature of the client relationship, number of accounts and entities, portfolio and
financial complexity, unique client circumstances, the variety and scope of the services provided, and
location or advisory team. Fee arrangements, schedules and account minimums for all services are
negotiable and LNW may consider additional factors such as the potential for additional assets under
management, the relationship with existing or prospective clients, the total dollar amount of assets to be
managed, or other considerations.
Fee arrangements may be amended by mutual written consent or, in some cases, upon advance written
notice to the client. Employees of LNW and their families may receive investment and financial advisory
services at fees that are lower than what LNW generally charges clients.
Neither LNW nor any of its employees accept compensation from the sale of securities or any other
investment products or services. LNW is independent of any broker-dealer or other investment
management firm.
Timing and Payment of Fees
Depending on contractual arrangements, fees are paid quarterly in advance. Fees are based upon the
market value of the portfolio for the previous quarter. Fees are charged for those accounts in which LNW
provides investment management services, other than accounts, if any, for which LNW has agreed to waive
fees (sometimes called “courtesy accounts”). Clients should refer to their investment advisory agreement
for additional provisions regarding fees. Clients may choose to have fees deducted directly from a custodial
account or, alternatively, clients may request to be billed.
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If a client terminates the investment advisory agreement with LNW during a billing period, LNW will refund
any unearned investment management fee to the client on a pro-rata basis based upon the time remaining
in the quarter. In cases where client fees are paid in arrears, LNW will only charge for fees earned through
the termination date.
Occasionally, LNW may provide investment consulting or financial planning services on a limited
engagement or special project basis. Special projects are highly customizable and idiosyncratic and may
include financial analysis, wealth transfer planning, investment or philanthropy education, and specialized or
custom investment due diligence. Any hourly rate or project fee would be set forth in an investment advisory
agreement with the client based on the projected complexity and scope of the analysis or services
requested and the training and skills of staff members providing the requested service.
Fees for Third Party Financial Products and Services
LNW’s fees are exclusive of all transaction fees, custodial fees, and direct investment manager fees or costs
for client investments, including for example brokerage commissions, management fees or costs of mutual
funds, exchange traded funds, managed accounts, investment partnerships or similar. All such fees and
costs incurred in connection with transactions for any client account will be paid out of the assets in the
account or billed separately to the client and are in addition to the investment management fees paid to LNW.
Fees Related to the LNW Renewable Power Fund, LP
Any client who invested in the LNW Renewable Power Fund will be allocated their pro rata share of fund
expenses. However, neither the Fund nor LNW charges a fee for managing the investments in the Fund.
(Please refer to the Fund documents for specific information regarding Fund fees and expenses, including
fees charged to the LNW Renewable Power Fund by the fund in which it invests.) The market value of the
client’s investment in the Fund will be included in the total market value of the client’s portfolio upon which
the client fee is calculated.
6. Performance Based Fees and Side-by-Side Management
LNW does not charge any performance fees. Some investment advisers experience conflicts of interest in
connection with the side-by-side management of accounts with different fee structures. Although these
conflicts of interest are not applicable to LNW, some third-party funds in which clients invest charge a
performance fee within that particular fund. Details of those investments are disclosed in the fund
documents for that fund. Of course, a fee based on a percentage of the market value of assets will increase
or decrease as the market value of those assets changes over time.
7. Types of Clients
LNW provides investment and financial advisory services predominantly to wealthy individuals and families,
as well as their trusts, estates, charitable organizations, corporations, business entities, foundations and
endowments. In certain limited circumstances, for example if a client owns a business, LNW may also
provide investment advice to its pension and profit-sharing plan; however, LNW does not act as a plan
administrator. LNW’s new account minimum is generally $10,000,000 in investable assets, however LNW
serves families with investable assets ranging from $1,000,000 to in excess of $200,000,000.
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8. Methods of Analysis, Investment Strategies and Risk of Loss
In providing services to its clients, LNW develops its asset allocation recommendations with financial
market and macroeconomic research and a focused on risk management. Client portfolios are constructed
with a combination of strategies from managers upon which LNW has conducted appropriate due diligence.
due diligence in selecting and monitoring professional asset managers by researching historical
performance metrics as well as analyzing both the firm and its personnel.
Due diligence generally includes quantitative and qualitative analysis of the merits of individual strategies as
well as analysis or review of the managing firm and its personnel.
Evaluation of Client Objectives
LNW constructs each client’s investment portfolios by beginning with an assessment of the client’s financial
goals. Next, LNW will consider those goals alongside the client’s risk tolerance. While constructing each
investment portfolio, LNW may consider other factors such as the client’s investment time horizon, tax
profile, liquidity needs, legal constraints and any unique considerations which may include a desire to
incorporate impact objectives or the incorporation of a concentrated stock position.
Strategic Asset Allocation
The establishment of a strategic asset allocation sets the framework for a client’s investment portfolio
construction. Asset allocation is the process of determining the asset classes and sub-asset classes in
which to invest and the percentage of the total portfolio that goes to each. That it is strategic speaks to
LNW’s discipline and long-term orientation.
Once implemented, each client’s strategic asset allocation is regularly reviewed to maintain their risk/return
characteristics via necessary rebalancing ,and in light of market and economic developments or for
opportunities to reduce the tax burden via tax loss harvesting.
Short -Term Adjustments
Any short-term adjustments on account of near-term opportunities or risks are based on analysis
conducted by LNW’s investment team which actively monitors a multitude of financial and economic
indicators to help gauge market cycles and the near-term attractiveness of investments. For example, the
team looks at the relative valuation of asset classes and sub-asset classes against both historical averages
and each other. When recommended, short-term strategy positions are sized to take advantage of large
discrepancies in the markets while not overpowering clients’ strategic allocations. Often these allocations
are simply overweight or underweight positions within the strategic rebalancing thresholds.
Globally Diversified Portfolios
Which geographic segment is likely to outperform the others over time can be difficult to predict.
Consequently, LNW employs a global approach and maintains exposure to non-U.S. developed and
emerging markets not only through equity allocations but in most asset classes. Although LNW will regularly
analyze world markets in terms of market capitalization, currency fluctuations, and GDP, LNW will tend to
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allocate globally in line with global market benchmark exposures and allow the managers LNW selects to add
value by overweighting countries and securities of their choosing.
Active Management and Core-Satellite
Where LNW recommends active management in portfolios, LNW will generally implement with a Core-
Satellite approach. This strategy combines a fundamental exposure to an asset class that LNW believes will
deliver on their assumptions for the asset class over time and, where possible, more idiosyncratic
exposures that may perform quite differently than market benchmarks over the short-term. The intention is
for clients to benefit from managers with unique strategies but still have a majority of exposure to more core
strategies.
Alternative Investments
LNW believes that alternative assets complement a traditional portfolio, reducing volatility by incorporating
strategies o less correlated to traditional stock and bond exposures and/or increasing return through the
exploitation of the illiquidity premium of private investments. That said, while LNW believes that adding
alternative investments to a traditional portfolio can be beneficial, LNW does recognize that these vehicles and
strategies are not suitable for all clients.
LNW focuses on three general alternative asset categories: “Diversifiers,” which includes but is not limited
to hedge funds and private debt, “Private Real Assets,” which includes real estate, infrastructure, and similar
exposures with the common thread of inflation sensitivity, and “Private Equity”. These categories are broad
enough to include several strategies offering diversification and return benefits to clients. For instance, an
allocation to private equity may include venture capital, buyout, distressed, and secondary strategies. The
dispersion of manager success is wide in the universe of alternative investments which means that a
rigorous due diligence approach is warranted.
Appropriate Investment Vehicles
LNW is not constrained to using a particular investment vehicle and LNW executes client exposures with the
structure that best suits the investment and the client. Consequently, LNW will use ETFs, mutual funds and
separately managed accounts for most positions in liquid markets. LNW may also offer clients investment
vehicles that LNW will help organize with the intention of providing access to third party strategies at
minimums and fees that would not otherwise be available to many of LNW’s clients.
Tax-Aware Investment Management
Where appropriate, LNW invests with a tax-aware lens. This means not avoiding the realization of gains or
losses but considering the consequences of gains or losses in the investment process. For example, LNW
seeks to incorporate consideration of taxes into the asset allocation and manager selection framework and
generally prefers managers who invest with an eye toward efficient tax-management. LNW will also attempt
to place managers and strategies in specific accounts to enhance the tax efficiency of the overall portfolio.
Impact Investing
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LNW may utilize various socially conscious investment approaches if a client desires. LNW may construct
portfolios that utilize mutual funds, ETFs, or private securities with the purpose of incorporating socially
conscious principles into a client’s portfolio. These portfolios may also be customized to reflect the personal
values of the client. This allows clients to invest in a way that aligns with their values. LNW may use mutual
funds and ETFs that incorporate Environmental, Social and Governance (“ESG”) research as well as positive
and negative screens related to specific business practices to determine the quality of an investment on
values-based merits. LNW will generally use third-party managers, including separately managed accounts,
or mutual fund or exchange traded fund managers, in constructing portfolios focused on impact
consideration. While LNW will review these managers’ own policies and practices with respect to
ESG/impact investing, LNW is highly dependent on their self-reported information.
LNW may also incorporate ESG criteria when constructing a portfolio at a client’s request that is based on
their investment intentions and personal goals. Sustainable investing decisions can encompass a variety of
approaches including, but not limited to, negative/positive screening, systematic consideration, and
inclusion of ESG factors, impact of investments structured to address specific environmental or social
problems, and/or innovative business models and/or financial structures designed to reach underserved
populations. When investing “sustainably,” LNW seeks to achieve a measurable social or environmental
outcome in addition to a competitive risk-adjusted financial return over a full market cycle (unless a client
has specifically stipulated the objective of investing for concessionary returns). For example, an investment
in a low-income housing project might satisfy both client objectives. Impact investing carries the same risks
as traditional investing, as well as the risk that the desired impact will not be achieved.
Consideration of ESG factors may affect the client’s exposure to certain companies, sectors, regions,
countries or types of investments, which could negatively impact client performance depending on whether
such investments are in or out of favor. Applying impact investing goals to investment decisions is
qualitative and subjective by nature, and there is no guarantee that the criteria utilized by LNW, or any
judgment exercised by LNW will reflect the beliefs or values of any particular client. In evaluating a potential
investment, LNW is dependent upon information and data obtained through voluntary or third-party
reporting that may be incomplete, inaccurate or unavailable, which could cause LNW to incorrectly assess a
investment’s ESG practices and/or related risks and opportunities. ESG-related practices differ by region,
industry and issue and are evolving accordingly, and a company’s ESG-related practices or the Adviser’s
assessment of such practices may change over time.
Risk of Loss
Investing in securities involves many inherent risks, including the risk of loss that clients should be prepared
to bear. Investments managed by LNW are no exception and LNW is unable to guarantee, represent or imply
that LNW’s services and methods of analysis can or will predict future results, successfully identify market
tops or bottoms, or insulate a client from losses due to market corrections or declines. Securities fluctuate
in value, depending on many factors that are unpredictable and outside of LNW’s control.
Below is a non-exclusive list of risks applicable to LNW investment strategies. Other risks also apply. Clients
should work with LNW on an on-going basis to understand and determine an appropriate risk tolerance for
their accounts.
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Market Risk. Market risk reflects the fact that there are certain general market conditions in which any given
investment strategy is unlikely to be profitable. Neither LNW nor the managers LNW recommend, have the
ability to control or predict such market conditions, including such important market conditions as the level
of economic activity and interest rates.
Cybersecurity Risk. Cybersecurity vulnerabilities may present weaknesses in information systems that
hackers could exploit. Investment advisors, the securities they recommend, and all service providers are all
subject to risks associated with a breach in their cybersecurity.
Business Catastrophic Risk. Clients may be subject to the risk of loss arising from exposure that it may
incur, indirectly, due to the occurrence of various events, including hurricanes, earthquakes, and other
natural disasters, or other catastrophic events such as a pandemic. These catastrophic risks of loss can be
substantial and could have a material adverse effect on investment advisory businesses and their clients’
portfolios.
Manager Risk. Manager risk encompasses the possibility of loss due to manager fraud, intentional or
inadvertent deviation from a predefined investment strategy, or simply poor judgment.
General Economic Conditions. General economic conditions can affect the level and volatility of interest
rates and the extent and timing of client participation in the markets for equities, interest sensitive
securities, commodities, and other investments. Unexpected volatility or illiquidity in the markets can result
in losses.
Government Policy Risk. Following the U.S. presidential election in 2024, there have been significant
changes and continue to be potentially significant changes to U.S. trade policies, legislation, treaties and
tariffs. Tariffs and other trade restrictions imposed by the Trump Administration have triggered, and could
continue to trigger, retaliatory actions by affected countries, possibly resulting in “trade wars.” At this time, it
is unknown whether and to what extent new legislation will be passed into law, pending or new regulatory
proposals will be adopted, international trade agreements will be negotiated, or the ultimate effect that any
such actions would have, either positive or negative. Recent market activity has been volatile due to the
recent imposition of “reciprocal” tariffs, and uncertainty surrounding tariff policies and global reactions to
them may continue to trigger increased market volatility, which increases the uncertainty of the investing
climate and affects the performance of various portfolio investments that are expected to be sensitive to
such market movements.
Bank Failures. The economic and regulatory environment has raised the risk of bank failures. Exposure to the
risk of bank failure for LNW can take effect directly through depositary accounts exceeding FDIC limits and
via exposure through loans, subscription facilities and security deposits through letters of credit issued by
such banks, which can no longer be drawn from. These risks can apply at the client and/or investment level.
LNW mitigates these risks by keeping track of various banking and custodial relationships and acting on
contractual provisions where a bank failure triggers a change and by limiting depositary account amounts to
the FDIC/SPIC insured levels where practical. LNW is reviewing direct banking relationships as part of our
ongoing diligence of key service providers. As of the date of this filing LNW has experienced no direct impact
from the current bank failures and expects no impact to near-term cash management.
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Market Disruptions and Governmental Intervention. Government intervention in the case of market
disruption can suddenly and substantially impact market participants’ ability to implement certain strategies
or manage the risk of portfolio positions. These interventions can be unclear in scope and application
resulting in confusion and uncertainty that can detrimentally impact investment strategies in unpredictable
ways.
Risks of Investments in Non-U.S. Securities. Non-U.S. investments, and those in emerging markets, involve
special risks. These risks include fluctuations in currency exchange rates, foreign government intervention
or expropriation, failure of markets to function properly, political or economic instability, and differences in
regulatory, financial disclosure, accounting, and auditing standards.
Inflation Risk. As interest rates rise, the value of fixed-income investments falls, and vice versa. Higher rates
of inflation generally adversely affect economies and financial markets and the ability of governments to
create conditions that stimulate or maintain economic growth. In addition, governmental measures to curb
inflation and speculation about future governmental measures may contribute to the negative economic
impact of inflation and may create general economic uncertainty. Future governmental economic measures,
such as interest rate increases, intervention in foreign exchange markets, and actions to adjust or fix
currency values, may trigger or exacerbate increases in inflation, and consequently have an adverse impact
on investment returns.
Extraordinary Events. Global terrorist activity and armed conflicts may negatively affect general economic
conditions, including sales, profits, and production, and may materially affect prices and/or impair LNW’s
trading facilities and infrastructure or the trading facilities and infrastructure of the exchanges or markets on
which LNW trades. The extent and duration of any military action, the possibility of a conflict expanding, and
resulting sanctions and other economic and political measures and future market disruptions in the region
and worldwide are impossible to predict but could be significant and have a severe adverse effect on the
region in conflict and collateral effects globally, including significant negative impacts on the global economy
and the markets for certain securities and commodities. Such effects and impacts could have a material
adverse effect on certain investments.
The impact of disease and epidemics may have a negative impact on the performance and financial position
of LNW and the funds it recommends. Outbreaks of existing or new epidemics could result in health or other
government authorities requiring the closure of offices or other businesses, as well as a general economic
decline. Consequently, LNW’s operations and business results, including with respect to LNW and/or its
funds it recommends, could be materially adversely affected by outbreaks in the near future.
Regulatory Developments. The legal, tax, and regulatory environment worldwide in the financial industry is
evolving, and changes in regulations affecting the financial industry, including LNW’s and the issuers of
financial instruments held in a client’s account, may have a material adverse effect on LNW’s ability to
pursue the investment strategies described above or the value of the instruments held in a client’s account.
There has been an increase in scrutiny of the financial industry by governmental agencies and self-
regulatory organizations. Various national governments have expressed concern regarding the disruptive
effects of speculative trading and the need to regulate the financial markets in general. New laws and
regulations or actions taken by regulators that restrict LNW’s ability to pursue investment strategies or
conduct business with broker-dealers and other counterparties could adversely affect a client’s account.
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ESG or Impact Risks. The potential non-financial risks associated with environmental, social, and
governance factors or impact investments could negatively impact a company’s reputation, earnings,
assets, cost of capital, and valuation. Examples of these may include but are not limited to: Environment:
Changes in weather patterns and extreme events associated with climate change, inefficient use or
pollution of the earth’s resources such as water and land, damage to ecosystems; Social: Poor labor
relations and policies, lack of gender and/or racial equality, discriminatory practices and products that are
detrimental to health or the environment; Governance: Poor corporate management and oversight
practices, lack of robust worker safety protocols, lack of diversity and outside representation on the board
which can create conflicts of interest as well as poor governance of executive management. ESG ratings of
companies are often based on subjective measures, and may include corporate self-reporting, different and
inconsistent third-party rating systems, as well as data points that are associated with positive or negative
outcomes but where causation has not been established. It is also possible that companies that do have
positive impact in the areas identified, or that successfully avoid some or most of the ESG risks noted, will
not have favorable financial returns. Accordingly, their stock prices could underperform their peers despite
alignment with ESG objectives.
Risks Specific To Private Funds
General Risk of Loss; Liquidity. Investing in securities involves risk of loss, including the possibility of losing
all of the initial investment as well as any unrealized gains on investments. In addition, investment vehicles
organized as private funds may underperform in comparison to the general securities markets or other
asset classes. These funds may be invested in a variety of unconventional securities and other assets. LNW
does not guarantee returns and cannot eliminate risk. In addition, general economic and market conditions,
such as interest rates, availability of credit, inflation rates, commodity prices, economic uncertainty,
changes in laws, trade barriers, currency fluctuations and controls, and national and international political
circumstances can materially affect the investments in a client’s account(s) or in the private funds. For
example, any of these factors may affect price volatility and the liquidity of instruments held. Even an
instrument that generally is, or recently was, liquid may unexpectedly and suddenly become illiquid. Such
volatility or illiquidity could result in substantial losses. Always refer to the offering documents for a private
fund for information on additional risks.
Lack of Diversification. Private funds are not as diversified as other investment vehicles. Accordingly,
investments in such funds could be subject to more rapid change in value than would be the case if they
were required to maintain a wide diversification among types of securities, geographical areas, issuers, and
industries.
Valuation. Private fund assets may, at any given time, include securities and other financial instruments or
obligations that are thinly traded or for which no market exists and/or which are restricted as to their
transferability under applicable securities laws. The sale of any such investments may be possible only at
substantial discounts, and it may be extremely difficult to accurately value any such investments.
Concentration. Private funds may hold highly concentrated positions in projects engaged in one or a few
industries. This increases the risk of loss relative to the market as a whole.
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Limited Withdrawal Rights. Private funds typically contain significant limitations on investors’ right to
withdraw from the investment or transfer their interests, which creates a higher liquidity risk. Accordingly, a
client should view an investment in a private fund as a long-term investment.
Limited Opportunities. In certain cases, LNW receives a limited allocation of pooled investment vehicles
across LNW’s client base. Based on the allocation amount LNW receives, not all clients may receive their
desired allocation.
9. Disciplinary Information
A registered investment advisor is required to disclose all legal or disciplinary events that would be material
to the evaluation of it as an investment advisor or regarding the integrity of its management. LNW has no
history of any legal or disciplinary events.
10. Other Financial Industry Activities and Affiliations
LNW is currently not registered nor has an application pending to register as:
• a broker-dealer or a registered representative of a broker-dealer; or
• a futures commission merchant, commodities pool operator, a commodity-trading
adviser, or an associated person of the foregoing entity
LNW is wholly owned by Laird Norton Wetherby Trust Company, LLC (“LNW Trust Co.”), a Washington state
chartered non-depository trust company. Additional information about LNW Trust Co. may be obtained from
the State of Washington’s Department of Financial Institutions, Division of Banks: www.dfi.wa.gov/banks.
LNW Trust Co. also owns LNW Trust Company of South Dakota, LLC (“LNW Trust Co. of SD”), a South Dakota
state chartered non-depository trust company. Additional information about LNW Trust Co. of SD may be
obtained from the State of South Dakota’s Department of Labor and Regulation – Division of Banking:
https://dlr.sd.gov.
Finally, LNW Trust Co. owns Laird Norton Wetherby Wealth Management, LLC, an SEC registered investment
advisor based in California that also operates under the trade name of “LNW.” Additional information about
LNW Wealth Management, LLC is available on the SEC’s website at: www.adviserinfo.sec.gov.
LNW employees who provide investment advisory services to LNW clients may provide similar services to
clients of its affiliates or the beneficiaries of trusts for which affiliates serve as trustee. There is a contract
between LNW and their affiliates that allows them to share office space, equipment, and other typical
business resources.
11. Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
LNW has adopted a Code of Ethics (the “Code”) that reflects LNW’s expectations of appropriate ethical
conduct by LNW’s employees. The Code provides guidance and specific standards of conduct for situations
where violations, inadvertent or otherwise, could occur in the conduct of business. Employees must avoid
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situations where their personal interest’s conflict with the interests of the company or LNW’s clients. The
Code describes appropriate conduct surrounding gifts, outside employment, fiduciary appointments, and
personal investments and trading activities. In addition, the Code prohibits dishonest and fraudulent acts
and reaffirms LNW’s commitment to client confidentiality. Every employee is required annually to sign a
statement acknowledging that he or she agrees to follow the standards set forth in the Code. A copy of
LNW’s Code of Ethics is available upon request by contacting LNW at the telephone number on the cover
page of this Brochure.
LNW and its employees can invest in funds and securities held in client accounts. In some cases, employees
can buy or sell funds or securities that are also recommended to their clients. Given the large size of these
funds and securities and the daily trading volume they experience, LNW does not believe there is a material
risk that employees’ personal trades placed at or near the time of client trades would in any way be
detrimental to LNW’s clients. LNW’s policy prohibits insider trading by any of LNW’s employees. In addition,
employees may occasionally invest in private funds in which LNW’s clients are also invested. The Code is
designed to provide that the personal securities transactions, activities, and interests of the employees of
LNW will not interfere with making decisions in the best interest of LNW’s advisory clients.
Employees may not “trade on” any knowledge they may have regarding the potential market impact of
transactions entered into on behalf of clients.
Generally, LNW or its employees do not buy or sell securities and private investments from LNW’s clients.
However, under exceptional circumstances, LNW or an employee may engage in a principal transaction. In
such circumstances, LNW will disclose to the client in writing the capacity in which LNW is acting and obtain
client consent prior to the transaction.
12. Brokerage Practices
LNW has negotiated what it believes to be a favorable commission schedule for clients with the Schwab
Institutional division of Charles Schwab & Co., Inc. (“Schwab” or “Schwab Institutional”), a FINRA-registered
broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. If
clients select Schwab to be their custodian, they will sign a separate agreement with Schwab. Schwab
provides custody and brokerage services, monthly reporting to clients, and daily electronic reporting to LNW
and its clients (via web-based access). Each client maintains one or more separate accounts with Schwab
for this purpose and pays Schwab directly for its custody and brokerage services. The amount of Schwab’s
fee is included in the agreement clients sign with Schwab. LNW believes its selection of Schwab as
custodian and broker is in the best interests of LNW’s clients because of the scope, quality, and price of
Schwab’s services. In some situations, LNW will consent to a client’s use of a different custodian with the
understanding that the client may pay custodial fees that are higher than those imposed by Schwab.
Schwab provides LNW with access to its institutional trading, consulting, and custody services, which are
typically not available to Schwab retail clients. These services generally are available to independent
investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of
the advisor’s clients’ assets are maintained in accounts at Schwab Institutional. These services are not
contingent upon LNW committing to Schwab any specific amount of business (assets in custody or trading
commissions). Schwab’s brokerage services include the execution of securities transactions, custody,
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research, and access to mutual funds and other investments that are otherwise generally available only to
institutional clients or would require a significantly higher minimum initial investment. For LNW client
accounts maintained in its custody, Schwab generally does not charge separately for custody services but is
compensated by account holders through commissions and other transaction-related or asset-based fees
for securities trades that are executed through Schwab or that settle into Schwab accounts.
• Schwab Institutional and other custodians/brokers also make available to LNW other
products and services that benefit LNW but do not necessarily benefit its clients’
accounts. Many of these products and services are used to service all or some
substantial number of LNW’s accounts, including accounts not maintained at Schwab
and other respective custodians/brokers who are providing said products and services.
Schwab’s products and services that assist LNW in managing and administering clients’
accounts include software and other technology that (i) provide access to client
account data (such as trade confirmations and account statements); (ii) facilitate trade
execution and allocate aggregated trade orders for multiple client accounts; (iii) provide
research, pricing, and other market data; (iv) facilitate payment of LNW’s fees from its
clients’ accounts; and (v) assist with back-office functions, recordkeeping, and client
reporting.
• Schwab Institutional or other custodians/brokers also offer other services intended to
help LNW manage and further develop its business enterprise. These services include:
(i) compliance and business consulting; (ii) publications and conferences on practice
management and business succession; and (iii) access to employee benefits providers,
human capital consultants, and insurance providers.
• Schwab Institutional and other custodians/brokers make available, arrange and/or pay
third-party vendors for the types of services rendered to LNW. Schwab Institutional and
other custodians/brokers often discount or waive fees it would otherwise charge for
some of these services or pay all or a part of the fees of a third party providing these
services to LNW.
• Schwab Institutional and other custodians/brokers also provide other benefits such as
access to and/or subsidies for hosted educational events or occasional business
entertainment of LNW personnel.
If LNW did not receive some of these types of services from Schwab, it would purchase them elsewhere at
additional cost. These products and services have economic value to LNW’s clients and also to LNW. These
unsolicited products include practice management aids (consulting, publications, conferences and
seminars) and compliance assistance.
Kristen Bauer, CEO of serves on the Schwab Advisor Services Advisory Board (the “Advisory Board”). LNW
may recommend that clients establish brokerage accounts with Schwab to maintain custody of the clients’
assets and effect trades for their accounts. The Advisory Board consists of representatives of independent
investment advisory firms who have been invited by Schwab management to participate in meetings and
discussions of Schwab Advisor Services’ services for independent investment advisory firms and their
clients. Generally, Board members serve for two-year terms.
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Ms. Bauer’s term ends in 2026. Advisory Board members enter into a nondisclosure agreement with Schwab
under which they agree not to disclose confidential information shared with them. This information generally
does not include material nonpublic information about the Charles Schwab Corporation, whose common
stock is listed for trading on the New York Stock Exchange (symbol SCHW). The Advisory Board meets in
person or virtually approximately twice per year and has periodic conference calls scheduled as needed.
Advisory Board members are not compensated by Schwab for their service, but Schwab does pay for or
reimburse Advisory Board members’ travel, lodging, meals, and other incidental expenses incurred in
attending Advisory Board meetings. Schwab may also provide members of the Advisory Board a fee waiver
for attendance at Schwab conferences such as IMPACT.
Soft Dollar Benefits
As stated above, Schwab may provide additional benefits or services to LNW and its clients Since clients do
not pay a higher commission for these services, none of these benefits are soft-dollar credit arrangements.
The Selection of Trading Counterparties
LNW can typically trade accounts held at Schwab using other broker/dealers. However, Schwab charges
clients trade-away fees that LNW believes outweigh any benefits from trading stocks, mutual funds, or ETFs
with other brokers. The availability and pricing of bonds varies more widely, so before placing a bond trade
LNW can solicit bids from several dealers (through a singular trading platform) and then execute the trade
with the dealer that offers sufficient liquidity and the most favorable pricing. Alternatively, LNW can transfer
the fixed-income security to a separate account manager to execute the trades since the separate account
manager has greater access to fixed-income dealers. The separate account manager is not affiliated
with LNW.
For clients who elect to have their accounts held by firms other than Schwab, LNW’s approach is generally to
trade stocks, mutual funds, and ETFs with the chosen custodian, and to trade bonds with the dealer that
offers sufficient liquidity and the most favorable pricing or to transfer the bond to a separate account
manager who has access to dealers that offer sufficient liquidity and favorable pricing.
Certain clients have requested LNW to execute all such clients’ securities transactions through one
registered representative at a particular broker-dealer. Such clients are cautioned on the following:
When possible, LNW will attempt to negotiate a more favorable fee schedule, but LNW cannot
guarantee that client-directed broker commissions, transaction fees, and other charges will be as
beneficial as those charged other clients not requesting directed brokerage arrangements. A client
that directs LNW to use a specific broker may not be able to participate in aggregate securities
transactions and may trade after such aggregate transactions and receive less favorable pricing
and execution.
The execution price, commissions paid, and the timing of trade execution can be negatively affected
by directed brokerage arrangements.
Best Execution Reviews
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Periodically, LNW evaluates the pricing and services offered by Schwab and other trading counterparties.
LNW has sought to make a good-faith determination that Schwab and other chosen trading counterparties
provide clients with good services at competitive prices. However, clients should be aware that this
determination could have been influenced by LNW’s receipt of products and services from Schwab.
Historically LNW has concluded that Schwab is as good as, or better than, the other firms that have been
considered. LNW would notify its clients if it were to determine that another firm offered better pricing and
services than Schwab.
Third-party managers typically determine the broker-dealers to be used to trade securities in the client
accounts they manage. Third-party investment managers making trades on behalf of LNW’s clients are
responsible for obtaining best execution for those trades.
Aggregated Trades
Blocking or aggregating trades is the practice of buying or selling a security for the accounts of multiple
clients in a single transaction. Blocking permits the trading of aggregate blocks of a security for multiple
client accounts so long as transaction costs are shared equally and on a pro-rated basis between all
accounts included in any blocked trade.
LNW typically aggregates client trades in an effort to treat all clients fairly. LNW’s policy is to allocate orders
among clients in a manner that is fair and equitable over time and does not favor one client or group of
clients. Allocations among clients will generally be based on consistently applied objective criteria tailored to
an investment strategy, including, but not limited to, pro rata based on the clients’ net asset values, total
assets, available cash, or target position.
For clients who invest in pooled investment vehicles, LNW will allocate opportunities on a randomized basis.
In many instances, there is greater client interest than there is capacity for the pooled investment vehicle.
LNW will seek to allocate to as many clients as possible, however, there could still be cases where clients do
not receive an allocation.
Client Referrals
LNW does not compensate Schwab or any other custodian or broker/dealer for referring client accounts to it.
13. Review of Accounts
Client portfolios managed by LNW are assigned to a client wealth management team (the “Team”) which has
the primary responsibility for the account. The Team reviews client portfolios as far as implementing any
changes in investment strategy or policy, or in the fundamentals of a security owned in a managed account.
The Team will generally meet as needed y, but no less frequently than annually, to review each portfolio.
Particularly in larger or newer accounts, or when dictated by circumstances, client meetings may be held
quarterly or more frequently as required or as desired by the client. A number of factors may trigger a
portfolio review, such as changes in the client's circumstances or objectives, a need to rebalance the
portfolio to reflect the asset allocation, or changes in the investment or tax environment that would impact
the portfolio performance.
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Clients receive account statements directly from their chosen custodian on at least a quarterly basis.
Clients are encouraged to compare these statements to information they receive from LNW on a regular
basis. Custodians also provide clients with additional reports, trade confirmations and tax information such
as 1099s and 5498s. Clients invested in private funds or other similar investment vehicles generally receive
financial statements directly from the fund. LNW may supplement these custodial statements with reports
provided during client meetings or as requested.
14. Client Referrals and Other Compensation
LNW does not directly or indirectly pay any third-party for client referrals. In addition, it does not directly or
indirectly receive any commissions or other compensation from brokers, dealers, custodians or other third
parties. The products and services provided by Schwab and how they benefit LNW are described above in
Item 12.
LNW does not currently use placement agents for clients or any funds it may recommend to clients.
IRA Rollovers
In appropriate circumstances, LNW may recommend that a client roll over an account held in a former
employer's retirement plan to an Individual Retirement Account ("IRA") for LNW to manage. When providing
investment advice to clients regarding retirement plan accounts or IRAs, LNW is a fiduciary within the
meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. LNW’s recommendation to roll over retirement
plan assets into an IRA creates a potential conflict of interest because such a recommendation may create
an incentive to recommend the rollover for the purpose of generating additional compensation rather than
solely based on the client’s needs. Accordingly, LNW will only recommend that a client roll over assets from
a retirement plan or an IRA to LNW if it concludes that it is in the client’s best interest and it has complied
with applicable regulatory guidance.
Client Investment Strategies
It is possible that certain advisory clients of LNW or an affiliate may serve in an ownership or managerial role
with respect to an investment strategy, issuer, or sponsor (a “Client Investment Strategy”) that is
recommended by LNW to its other clients. LNW addresses these conflicts of interest by providing specific
disclosure to clients to whom the Client Investment Strategy is recommended or offered. LNW will only
recommend Client Investment Strategies to clients when it believes such a recommendation to be in a
client’s best interest. For avoidance of doubt, other than any investment advisory fees paid by the client,
LNW receives no separate compensation in connection with a client’s decision to invest in the Client
Investment Strategy. Clients are encouraged to request further information from LNW regarding any Client
Investment Strategy or the foregoing conflicts of interest.
15. Custody
All client funds and securities are maintained with a qualified custodian; LNW does not take physical
possession of client assets. Clients will receive account statements and transaction confirmation notices
directly from the Custodian at least quarterly, which clients should carefully review. LNW urges clients to
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carefully compare the Custodian’s account statements with the periodic data clients receive from LNW and
to notify LNW promptly of any discrepancies.
LNW has the ability to deduct advisory fees directly from a client’s accounts based on a client’s written
authorization to do so, and this ability is technically considered “custody” but does not require separate
reporting or a surprise audit of LNW. In addition, in some cases, clients execute Standing Letters of
Authorization (“SLOAs”), which are written directives from the client authorizing LNW to initiate payments
from their custodial accounts to third parties specified by the client. Although SLOAs are initiated and
authorized by the client, LNW’s ability to facilitate the payments covered by the SLOAs is considered
“custody” under SEC guidance and requires LNW to report that they have custody over these account assets
on the ADV 1A. To the extent the SLOAs comply with certain conditions, however, including that clients have
the right to terminate the SLOA, and that the qualified custodian will confirm the status of the SLOA annually
directly with the client, LNW is not subject to a surprise custody audit for these accounts.
LNW is also subject to the SEC’s custody rule in respect of the Fund. However, LNW is not required to
comply with certain requirements of the custody rule with respect to the Fund because LNW complies with
the provisions of the so-called “audit exception” for pooled investment vehicles.
Among other things, the exception requires that the Fund be subject to audit at least annually by an
independent public accountant that is registered with, and subject to regular inspection by, the Public
Company Accounting Oversight Board, and requires that the Fund distribute its audited financial statements
to all investors within 120 days after the end of its fiscal year. Investors in the Fund receive periodic reports
from us, as described in Item 13 (Review of Accounts). LNW urges investors in the Fund to carefully review
those reports and compare the audited financial statements of the Fund to the reports provided by us.
16. Investment Discretion
LNW enters into written investment advisory agreements with clients that set the scope of its discretionary
authority. Unless otherwise directed by the client and except with respect to private placements which
require written authorization by the client, LNW’s discretionary authority allows LNW to purchase and sell
securities in client account(s), select and retain sub-advisors, and generally act on behalf of the client in
matters related to the accounts without prior review and approval by the client of each specific transaction.
Clients can place reasonable restrictions on LNW’s investment discretion. For example, some clients may
direct LNW not to buy securities issued by companies in certain industries, or not to sell certain securities
where the client has a particularly low tax basis. At all times, clients retain the authority to provide LNW with
direction regarding investments including limitations regarding types of securities and the timing of
transactions.
If LNW has not been granted discretionary authority with respect to certain accounts or investments, LNW
cannot execute any transactions without the client’s prior approval.
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17. Voting Client Securities
LNW’s policy is to vote proxies that are solicited for securities held in clients’ accounts unless the client has
retained the right. LNW’s policy is to vote proxies solely in the best interests of its clients, to retain records
of how LNW voted and why, and to provide information to the clients who wish to know how LNW voted.
LNW has retained a proxy administrator and voting service provider (the “Proxy Administrator”) to assist in
the proxy voting process. The Chief Compliance Officer (the “CCO”) manages LNW’s relationship with the
Proxy Administrator and ensures that all proxies are voted in accordance with the best interest of its clients.
In general, LNW will utilize the recommendations of the Proxy Administrator and has not identified any
material conflicts of interest in connection with past proxy votes. Absent specific client instructions, if LNW
identifies a material conflict of interest it will follow the voting recommendation of the Proxy Administrator
that it has retained. Both LNW and the Proxy Administrator will also retain certain required documents
associated with proxy voting.
In addition to maintaining oversight of individual proxy recommendations, LNW may also conduct a review of
the Proxy Administrator’s conflict management procedures to confirm that Proxy Administrator continues
to have the competency and capacity to vote proxies on an unbiased and informed basis.
Clients of LNW may obtain a copy of the proxy policies and procedures and details as to how the securities
or corporate actions were voted in their respective portfolios upon request to the CCO at LNW’s principal
address.
Clients who retain voting authority in their accounts will receive their proxies and other solicitations directly
from the custodian or transfer agent.
18. Financial Information
LNW does not require or solicit prepayment of fees six months or more in advance. LNW is not aware of any
financial condition that is expected to affect its ability to manage client accounts and has never filed for
bankruptcy.
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