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Item 1 – Cover Page
Form ADV Part 2 Brochure
December 15, 2025
First Washington Corporation
2001 6th Avenue, Suite 3400
Seattle, Washington 98121
(206)624-8320
www.first-wash.com
This Brochure provides information about the qualifications and business practices of
FIRST WASHINGTON CORPORATION [“First Washington” “FWCO”]. If you have any
questions about the contents of this Brochure, please contact us at (206) 624-8320 and/or
tmcintyre@first-wash.com. Currently, our Brochure may be requested free of charge by
contacting Teresa McIntyre at 206-624-8320 or tmcintyre@first-wash.com. Our Brochure
is also available on our web site www.first-wash.com , also free of charge.
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.
FIRST WASHINGTON CORPORATION 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 Adviser provide you with information about which you determine to
hire or retain an Adviser. Additional information about FIRST WASHINGTON
CORPORATION is also available on the SEC’s website at www.adviserinfo.sec.gov.
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Item 2 – Material Changes
There are no material changes.
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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
Item 4 – Advisory Business ................................................................................................................................................. 1
Item 5 – Fees and Compensation ...................................................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................... 3
Item 7 – Types of Clients ...................................................................................................................................................... 3
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................ 3
Item 9 – Disciplinary Information .................................................................................................................................... 4
Item 10 – Other Financial Industry Activities and Affiliations ............................................................................. 4
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 4
Item 12 – Brokerage Practices .......................................................................................................................................... 5
Item 13 – Review of Accounts ........................................................................................................................................... 9
Item 14 – Client Referrals and Other Compensation ................................................................................................. 9
Item 15 – Custody .................................................................................................................................................................. 10
Item 16 – Investment Discretion ..................................................................................................................................... 10
Item 17 – Voting Client Securities .................................................................................................................................. 10
Item 18 – Financial Information ...................................................................................................................................... 10
Item 19 – Other Information ............................................................................................................................................ 11
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Item 4 – Advisory Business
FIRST WASHINGTON CORPORATION (“FWCO”, we), founded in 1937, started its Registered
Investment Advisory in 2005. We are registered with the Securities and Exchange
Commission and the State of Washington as an Investment Advisor.
FWCO is owned by Lewis Investors, LLC. Mr. David D. Lewis, Managing Member, indirectly
owns 90% or more of First Washington.
AMOUNT OF MANAGED ASSETS
As of September 30, 2025, First Washington managed $501,201,045 on a discretionary
basis.
First Washington provides continuous advice to clients regarding the investment of client
funds based on the individual needs of the client. Through personal discussions, we
identify a client’s goals, objectives, time horizons, risk tolerance and liquidity needs.
PORTFOLIO MANAGEMENT SERVICES
First Washington Corporation provides discretionary advisory services through separately
managed accounts to individuals, corporations or other business entities, trusts, estates,
charitable organizations, and retirement plans.
Account supervision is guided by the client’s stated objectives (i.e., maximum capital
appreciation, growth, income, or growth and income), as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of
securities, or industry sectors.
First Washington focuses on individual stocks, bonds, cash and cash alternatives when
building a client’s portfolio. While we may recommend and provide advice on other types
of products, individual stocks are our primary focus.
Investment advisory services include, among other things, providing advice regarding asset
allocation and the selection of investments. Investment types advised upon or utilized may
be, but are not limited to, equity securities, which are listed on various exchanges, or
traded over the counter, or from foreign issuers, warrants, corporate debt securities,
commercial paper, certificates of deposit, municipal securities, mutual fund shares offered
by investment companies, and United States government securities.
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Because some types of investments involve certain additional degrees of risk, they will only
be implemented or recommended when consistent with the client’s stated investment
objectives, tolerance for risk, liquidity, and suitability.
Item 5 – Fees and Compensation
The fee schedule applicable as of this Brochure is as follows:
Client Assets
Up to $10,000,000
Over $10,000,000
Annual Fee (%) for all assets
1.00%
Negotiated
These fees are negotiable, and the final fee schedule is attached as Schedule A of the
Investment Advisory Agreement.
The specific manner in which fees are charged by FWCO is established in a client’s written
agreement with FWCO. FWCO will generally bill its fees on a quarterly basis. Clients may
elect to be billed in advance or arrears each calendar quarter. Clients may also elect to be
billed directly for fees or to authorize FWCO to directly debit fees from client accounts.
Management fees shall be prorated for each capital contribution and withdrawal made
during the applicable calendar quarter (with the exception of de minimis contributions and
withdrawals). Accounts initiated or terminated during a calendar quarter will be charged a
prorated fee. Upon termination of any account, any prepaid, unearned fees will be
promptly refunded, and any earned, unpaid fees will be due and payable. The client has the
right to terminate an agreement without penalty.
FWCO’s fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses which shall be incurred by the client. Clients may incur certain charges
imposed by custodians, brokers, third party investment and other third parties such as fees
charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. Mutual funds and exchange traded funds also charge
internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees
and commissions are exclusive of and in addition to FWCO’s fee, and FWCO shall not
receive any portion of these commissions, fees, and costs, unless disclosed to the client.
Item 12 further describes the factors that FWCO considers in selecting or recommending
broker-dealers for client transactions and determining the reasonableness of their
compensation (e.g., commissions).
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Item 6 – Performance-Based Fees and Side-By-Side Management
FWCO does not charge any performance-based fees (fees based on a share of capital gains
or on capital appreciation of the assets of a client).
Item 7 – Types of Clients
FWCO provides portfolio management services to high-net-worth individuals, individuals,
pension and profit-sharing plans, charitable organizations and businesses.
FWCO generally requires a minimum account of $250,000.00 to open a portfolio in our
advisory.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
The advisors of First Washington work to manage this risk for clients through proper
investment diversification and risk management. Advisors collaborate with clients to
ascertain their investment goals and risk tolerance. Using this information, we build
customized investment portfolios designed to maximize the chances of reaching these
investment goals.
FWCO’s investment philosophy is fundamentally oriented, based on the belief that over
time the investment process is rational. Current and future developments that impact
economies, industries, and individual securities can be evaluated. Disciplined investment
decisions are then made, reacting, and taking advantage of such developments. This style is
oriented toward growth at a reasonable price (GARP) with a value component added while
using all-cap universe. We use disciplined guidelines in both the purchase and sale of
securities.
Changing economics and markets may require FWCO’s portfolio managers to make
adjustments to clients’ holdings. Frequent trading can potentially affect investment
performance through increased transaction and tax costs.
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Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of First Washington
or the integrity of First Washington’s management.
First Washington has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliations
First Washington is no longer a registered nor does it have any pending application to
register as a broker-dealer. Neither First Washington nor any of their employees have any
Financial Industry Activities or Affiliations.
Item 11 – Code of Ethics , Participation in Client Transactions and Personal Trading
FWCO has adopted a Code of Ethics for all supervised persons of the firm describing its
high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics
includes provisions relating to the confidentiality of client information, a prohibition on
insider trading, a prohibition of rumor mongering, restrictions on the acceptance of
significant gifts and the reporting of certain gifts and business entertainment items, and
personal securities trading procedures, among other things. All supervised persons at
FWCO must acknowledge the terms of the Code of Ethics annually, or as amended.
FWCO anticipates that, in appropriate circumstances, consistent with clients’ investment
objectives, it will cause accounts over which FWCO has management authority to effect,
and will recommend to investment advisory clients or prospective clients, the purchase or
sale of securities in which FWCO, its affiliates and/or clients, directly or indirectly, have a
position of interest. FWCO’s employees and persons associated with FWCO are required to
follow FWCO’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers,
directors, and employees of FWCO and its affiliates may trade for their own accounts in
securities which are recommended to and/or purchased for FWCO’s clients. The Code of
Ethics is designed to assure that the personal securities transactions, activities, and
interests of the employees of FWCO will not interfere with (i) making decisions in the best
interest of advisory clients and (ii) implementing such decisions while, at the same time,
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allowing employees to invest for their own accounts. Under the Code certain classes of
securities have been designated as exempt transactions, based upon a determination that
these would materially not interfere with the best interest of FWCO’s clients. In addition,
the Code requires pre-clearance of many transactions and restricts trading in close
proximity to client trading activity. Nonetheless, because the Code of Ethics in some
circumstances would permit employees to invest in the same securities as clients, there is a
possibility that employees might benefit from market activity by a client in a security held
by an employee. Employee trading is continually monitored under the Code of Ethics, and
to reasonably prevent conflicts of interest between FWCO and its clients.
FWCO’s clients or prospective clients may request a copy of the firm's Code of Ethics by
contacting Teresa A. McIntyre.
It is FWCO’s policy that the firm will not affect any principal or agency cross securities
transactions for client accounts. FWCO will also not cross trades between client accounts.
Principal transactions are generally defined as transactions where an adviser, acting as
principal for its own account or the account of an affiliated broker-dealer, buys from or
sells any security to any advisory client. A principal transaction may also be deemed to
have occurred if a security is crossed between an affiliated hedge fund and another client
account. (Currently, FWCO has no affiliated broker dealers or hedge funds.) An agency
cross transaction is defined as a transaction where a person acts as an investment adviser
in relation to a transaction in which the investment adviser, or any person controlled by or
under common control with the investment adviser, acts as broker for both the advisory
client and for another person on the other side of the transaction. Agency cross
transactions may arise where an adviser is dually registered as a broker-dealer or has an
affiliated broker-dealer.
Item 12 – Brokerage Practices
First Washington will supervise and direct the investments of the client accounts subject to
such limitations as the client may impose in writing. FWCO, as agent and attorney-in-fact
with respect to the client’s account, without prior consultation with the client, may, (a)
direct the purchase, sell, exchange, conversion, and otherwise trade in stocks, bonds,
mutual funds, ETFs and other securities including money market instruments, (b) direct
the amount of securities purchased, sold, exchanged, and otherwise traded; (c) place orders
for the execution of such securities transactions with third-party broker dealers.
First Washington does not maintain custody of the assets that FWCO manages. Your assets
must be maintained in an account at a “qualified custodian”, generally a broker dealer or
bank. First Washington usually recommends U.S. Bank Institutional Trust & Custody as
custodian.
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U.S. Bank Institutional Trust & Custody provides custodial services and charges each client
a fee of 5 (five) basis points on their market value, with a minimum fee of $500.00 per year
($41.67 per month). U.S. Bank Institutional Trust & Custody provides: Safekeeping of
assets, Transaction settlement, Cash Management (all cash swept daily), Online account
access, Consolidated accounting & reporting, Income Collection, Corporate Action
Processing, Proxy distribution, Asset Valuation, and Class Action Proceeds collection.
First Washington’s advisory clients may choose their own “qualified custodian”. The
qualified custodian must be able to accept trade reports and settle trades on behalf of their
First Washington clients on a Cash-on-Delivery (COD) basis. First Washington will connect
with a client’s qualified custodian to establish these COD accounts.
With respect to ERISA clients any direction by the plan sponsor must be in the best
interests and for the exclusive benefit of the plan participants.
First Washington, as a matter of policy and practice, seeks to obtain best execution for
client transactions at all times (i.e., seeking to obtain not necessarily the lowest commission
but the best overall qualitative execution in the particular circumstances).
The firm utilizes broker dealers chosen based on criteria such as their recent involvement
in trading a specific security as well as their ability to execute quickly and professionally by
accessing the electronic marketplace using algorithmic tools. Research ideas
communicated to the portfolio management team are part of the criteria used to select a
broker-dealer.
The reasonableness of commissions is based on the broker's stability, reputation, ability to
provide professional services, competitive commission rates and prices, research, trading
platform, and other services which will help First Washington in providing investment
management services to clients. First Washington may, therefore, use a broker who
provides useful research and securities transaction services even though a lower
commission may be charged by a broker who offers no research services and minimal
securities transaction assistance. Research services may be useful in servicing all our
clients, and not all such research may be useful for the account for which the particular
transaction was effected.
Research and Other Soft Dollar Benefits
FWCO may select brokers and dealers at least partially in recognition of the value of
various research services or products, beyond transaction execution, that they provide to a
client or to FWCO. The amount of compensation (including markups and markdowns on
principal transactions with market-makers) paid by a client to a broker or dealer who
provides those services and/or products may be higher than what another, equally capable
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broker or dealer might charge. Selecting a broker or dealer in recognition of the provision
of services or products other than transaction execution is known as paying for those
services or products with "soft dollars."
FWCO may use soft dollars to acquire a variety of "research" and "brokerage" services and
products for which the client would not otherwise be required to pay. A federal statute,
Section 28(e) of the Securities Exchange Act of 1934, as amended, recognizes that, while a
conflict of interest could be involved in these activities, investment managers, such as
FWCO, should not be considered to be breaching any fiduciary duty to advisory clients by
engaging in the activity even if the brokerage commissions paid are higher than the lowest
available-if certain conditions and requirements are met. For these purposes, "research"
means services or products used to provide lawful and appropriate assistance to FWCO in
making investment decisions for its clients. "Brokerage" services and products are those
used to effect securities transactions for clients or to assist in effecting those transactions.
To be protected under Section 28(e), FWCO must, among other things, determine that
commissions paid are reasonable in light of the value of the "brokerage" and "research"
services and products acquired. Section 28(e)'s "safe harbor" protects the use of client soft
dollars even when FWCO uses research and brokerage services and products to benefit
clients other than the client whose soft dollars are used.
First Washington has one “soft dollar” relationship with Bloomberg Tradebook. First
Washington executes client trades with Bloomberg Tradebook, as an executing broker.
When a trade is directed to Tradebook, Tradebook charges First Washington clients a
commission of .033 cents per share and First Washington receives a soft dollar credit of
.023 per share, which is accumulated in First Washington’s “commission management”
account with Tradebook. In our fiscal year ending September 30, 2025, this “soft dollar”
credit was used to purchase the following services:
Bloomberg Terminal
NASDAQ OpenView Basic, Levels 1 and 2
Pink Sheets LV 2
Market Data Express Index
NYSE Enablement Fee
DeMark Services
Bloomberg Execution Management System (EMSX)
Our Portfolio Managers use many Bloomberg Terminal services or functions for research
and analysis of securities and industries. These functions include, but are not limited, to
the following reports: Analyst recommendations, Earnings summary and estimates,
Corporate actions, All large shareholders, Global equity performance, Bloomberg
Launchpad, Bloomberg alerts of price movements, Graphs, Company specific news,
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Historical pricing and volume, Dividends information, and Relative valuation against
competition.
The Bloomberg Execution Management System (EMSX) is considered a “brokerage service”
under the Section 28(e)'s "safe harbor.”
During the fiscal year ending September 30, 2025, the following broker-dealers may have
provided research as a result of trade execution services. This list may change from time to
time in the future and other brokers not identified may also be utilized:
B. Riley & Company, Bloomberg Tradebook LLC, B of A Securities, Cantor Fitzgerald, Craig -
Hallum, D.A. Davidson & Company, Goldman Sachs, J.P. Morgan Securities LLC,
JonesTrading Institutional Services LLC . LLC, Needham and Company LLC, O'Neil
Securities Inc., Oppenheimer & Co. Inc., Outset Global Trading Limited, RBC Capital Markets
LLC, Robert W. Baird & Company, Stifel Nicolaus & Co., Wall Street Access .
Block Trades
Transactions for each client may be affected independently, unless FWCO decides to
purchase or sell the same securities for several clients at approximately the same time.
FWCO may, but is not obligated to, combine multiple orders for shares of the same
securities purchased for advisory accounts FWCO manages (this practice is commonly
referred to as “block trading”). FWCO will then distribute a portion of the shares to
participating accounts in a fair and equitable manner. The distribution of the shares
purchased is typically proportionate to the size of the account, but it is not based on
account performance or the amount or structure of management fees. Subject to our
discretion regarding factual and market conditions, when FWCO combine orders, each
participating account pays an average price per share for all transactions and any “trade-
away” commissions.
Trade Errors
Occasionally, a trading error may occur where either FWCO, or our Advisors, are at fault. If
this occurs in your account, the error will be corrected, and your account will be restored
to where it would have been had the error never occurred.
However, in the process of restoring your account, we may realize a profit or suffer a loss in
connection with correcting this error. Neither losses nor gains will be passed on to you.
Client Directed Brokerage
If a client designates the broker dealer to execute and settle all security transactions in
their advisory account, this is a Client Directed Brokerage. Currently, First Washington has
no Client Directed Brokerage accounts.
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Regarding client directed brokerage, we are required to disclose that we may be unable to
negotiate commissions, block or batch client orders or otherwise achieve the benefits
described above, including best execution, if you limit our brokerage discretion. Directed
brokerage commission rates may be higher than the rates we might pay for transactions in
non-directed accounts. Also, clients that restrict our brokerage discretion may be
disadvantaged in obtaining allocations of new issues of securities that we purchase or
recommend for purchase in other clients’ accounts. It is our policy that such accounts do
not participate in allocations of new issues of securities obtained through brokers and
dealers other than those designated by the client. FWCO's ability to trade fixed income
securities for directed accounts may be limited by the inventory of that broker dealer.
Generally, we encourage each client to compare the possible costs or disadvantages of
directed brokerage against the value of the custodial or other services provided by the
broker to the client in exchange for the directed broker designation. Simply put, directing
brokerage may cost clients more money.
Item 13 – Review of Accounts
First Washington’s Portfolio Managers and Traders regularly review the holdings and
transactions in our clients’ accounts:
Each business day, we review prices on all supervised securities.
At least once each quarter, David Lewis and John P. Morbeck review all client portfolios on
a stand-alone basis, with regard to their target asset allocation, performance, change in
month-end account values, and unique needs and preferences. Account reviews are
performed more frequently when market conditions dictate.
Other conditions that may trigger a special review are new investment information,
changes in the tax laws, and changes in a client's own situation.
Item 14 – Client Referrals and Other Compensation
First Washington does NOT receive any economic benefit from anyone except our clients
for providing investment advice to our clients.
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Item 15 – Custody
Clients should receive at least quarterly statements from the broker dealer, bank or other
qualified custodian that holds and maintains the client’s investment assets. FWCO reports
may vary from custodial statements based on accounting procedures, reporting dates, or
valuation methodologies of certain securities.
FWCO urges all clients to advise us immediately if they do not receive their custodian or
brokerage statement. In addition, clients should compare any account information
provided by FWCO with account statements from their broker-dealer or custodian and
advise us of any discrepancies. The client’s broker-dealer or custodian maintains the
official record of the client’s account.
Item 16 – Investment Discretion
FWCO usually receives discretionary authority from the client at the outset of an advisory
relationship to select the identity and quantity of securities to be bought or sold. In all
cases, however, such discretion is to be exercised in a manner consistent with the stated
investment objectives for the particular client account.
When selecting securities and determining amounts, FWCO observes the investment
policies, limitations and restrictions of the clients for which it advises. For registered
investment companies, FWCO’s authority to trade securities may also be limited by certain
federal securities and tax laws that require diversification of investments and favor the
holding of investments once made.
Investment guidelines and restrictions must be provided to FWCO in writing.
Item 17 – Voting Client Securities
As a matter of firm policy and practice, FWCO does not have any authority to and does not
vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and
voting proxies for any and all securities maintained in client portfolios.
Item 18 – Financial Information
As an adviser exercising discretionary authority over transactions in client accounts, we
must disclose any financial condition reasonably likely to impair our ability to meet
contractual commitments to our clients:
There are none.
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Item 19 – Other Information
Submission of Paperwork and/or Approval of Class Action Litigation
FWCO does not accept responsibility in matters relating to class actions, including without
limitation, approval of class settlements, bankruptcies or otherwise and will not complete
or submit any paperwork on behalf of clients with regard to such matters.
Unsupervised Securities
Assets designated as "unsupervised" are neither managed nor charged a management fee
by FWCO. FWCO assumes no responsibility for these assets.
Clients should notify First Washington in writing if there are changes in a client's
financial situation, if their investment objectives should be modified, if they have
intentions of changing custodian or broker dealer, or if they have a change of
address.
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