Overview
Assets Under Management: $200 million
Headquarters: AUGUSTA, GA
High-Net-Worth Clients: 58
Average Client Assets: $3 million
Services Offered
Services: Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (ADV PART 2A & 2B SEC)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $50,000 | 1.00% |
| $10 million | $100,000 | 1.00% |
| $50 million | $500,000 | 1.00% |
| $100 million | $1,000,000 | 1.00% |
Clients
Number of High-Net-Worth Clients: 58
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 67.19
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 686
Discretionary Accounts: 686
Regulatory Filings
CRD Number: 281291
Last Filing Date: 2024-02-06 00:00:00
Website: https://wynncap.com
Form ADV Documents
Primary Brochure: ADV PART 2A & 2B SEC (2025-03-12)
View Document Text
F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U R E
Office Address:
965 Broad Street
Augusta, GA 30901
Tel:
706-869-3451
Fax:
706-869-2263
Email:
Info@wynncap.com
Website:
www.wynncap.com
March 12, 2025
This brochure provides information about the qualifications and business practices of Wynn
Capital LLC. Being registered as an investment adviser does not imply a certain level of skill or
training. If you have any questions about the contents of this brochure, please contact us at 706-
869-3451. The information in this brochure has not been approved or verified by the United
A D D I T I O N A L I N F O R M A T I O N A B O U T W Y N N C A P I T A L L L C ( C R D # 2 8 1 2 9 1)
States Securities and Exchange Commission, or by any state securities authority.
I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V
Item 2: Material Changes
Annual Update
Material Changes since the Last Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
•
This update is in accordance with the required annual update for Registered Investment
Advisors. Since the last filing of this brochure on February 6, 2024, the following changes
have been made:
Item 4 has been updated with the firm’s most recent assets under management
calculation.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm.
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Full Brochure Available .................................................................................................................................................. ii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 2
Wrap Fee Programs ......................................................................................................................................................... 2
Item 5: Fees and Compensation ....................................................................................................... 3
Client Assets under Management .............................................................................................................................. 2
Method of Compensation and Fee Schedule .......................................................................................................... 3
Client Payment of Fees ................................................................................................................................................... 3
Additional Client Fees Charged ................................................................................................................................... 4
Prepayment of Client Fees ............................................................................................................................................ 4
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 4
External Compensation for the Sale of Securities to Clients ........................................................................... 4
Item 7: Types of Clients ....................................................................................................................... 4
Sharing of Capital Gains ................................................................................................................................................. 4
Description .......................................................................................................................................................................... 4
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 4
Account Minimums .......................................................................................................................................................... 4
Methods of Analysis ......................................................................................................................................................... 4
Investment Strategy ........................................................................................................................................................ 5
Item 9: Disciplinary Information ..................................................................................................... 6
Security Specific Material Risks .................................................................................................................................. 6
Criminal or Civil Actions ................................................................................................................................................ 6
Administrative Enforcement Proceedings ............................................................................................................. 6
Item 10: Other Financial Industry Activities and Affiliations ............................................... 7
Self- Regulatory Organization Enforcement Proceedings ............................................................................... 7
Broker-Dealer or Representative Registration .................................................................................................... 7
Futures or Commodity Registration ......................................................................................................................... 7
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 7
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 7
Trading ..................................................................................................................................................... 7
Code of Ethics Description ............................................................................................................................................ 7
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest.... 8
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ... 8
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Item 12: Brokerage Practices ........................................................................................................... 8
Transactions and Conflicts of Interest ..................................................................................................................... 8
Factors Used to Select Broker-Dealers for Client Transactions .................................................................... 8
Item 13: Review of Accounts ........................................................................................................... 10
Aggregating Securities Transactions for Client Accounts ................................................................................ 9
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 10
Review of Client Accounts on Non-Periodic Basis ........................................................................................... 10
Item 14: Client Referrals and Other Compensation ................................................................ 10
Content of Client Provided Reports and Frequency ........................................................................................ 10
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 10
Item 15: Custody .................................................................................................................................. 10
Advisory Firm Payments for Client Referrals .................................................................................................... 10
Item 16: Investment Discretion ..................................................................................................... 11
Account Statements ...................................................................................................................................................... 10
Item 17: Voting Client Securities ................................................................................................... 11
Discretionary Authority for Trading...................................................................................................................... 11
Item 18: Financial Information ...................................................................................................... 11
Proxy Votes ...................................................................................................................................................................... 11
Balance Sheet .................................................................................................................................................................. 11
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 11
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 13
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 11
Principal Executive Officer – Robert Wynn, CFA .............................................................................................. 13
Item 2 - Educational Background and Business Experience ....................................................................... 13
Item 3 - Disciplinary Information ........................................................................................................................... 13
Item 4 - Other Business Activities ........................................................................................................................... 14
Item 5 - Additional Compensation .......................................................................................................................... 15
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 17
Item 6 - Supervision ..................................................................................................................................................... 15
®
Emmett Turner, CFP
, CPA ........................................................................................................................................ 17
Item 2 - Educational Background and Business Experience ....................................................................... 17
Item 3 - Disciplinary Information ........................................................................................................................... 18
Item 4 - Other Business Activities ........................................................................................................................... 19
Item 5 - Additional Compensation .......................................................................................................................... 20
Item 6 - Supervision ..................................................................................................................................................... 20
Item 4: Advisory Business
Firm Description
Types of Advisory Services
Wynn Capital LLC, doing business as Wynn Capital, was founded in August 2015 and began
offering advisory services in September 2015. Robert Wynn is 100% owner.
ASSET MANAGEMENT
Wynn Capital offers discretionary direct asset management services to advisory clients.
Wynn Capital will offer Clients ongoing asset management services through determining
individual investment goals, time horizons, objectives, and risk tolerance. Investment
strategies, investment selection, asset allocation, portfolio monitoring and the overall
investment program will be based on the above factors. The Client will authorize Wynn
Capital discretionary authority to execute selected investment program transactions as
stated within the Investment Advisory Agreement.
Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are
engaged directly by the client on an as-needed basis and may charge fees of their own. For
example, tax preparation and to the extent your estate plan needs to be updated, the tax
preparer and/or attorney will bill the client separately. Conflicts of interest will be
disclosed to the client in the event they should occur.
ERISA PLAN SERVICES
Wynn Capital provides service to qualified retirement plans including 401(k) plans, 403(b)
plans, pension and profit-sharing plans, cash balance plans, and deferred compensation
ERISA 3(38) Investment Manager.
plans. Wynn Capital may act as a 3(38) advisor:
Wynn Capital can also act as an ERISA 3(38) Investment
Manager in which it has discretionary management and control of a given retirement plan’s assets.
Wynn Capital would then become solely responsible and liable for the selection, monitoring and
replacement of the plan’s investment options.
1.
•
Fiduciary Services are:
•
Wynn Capital has discretionary authority and will make the final decision regarding
the initial selection, retention, removal and addition of investment options in
accordance with the Plan’s investment policies and objectives.
•
Assist the Client with the selection of a broad range of investment options consistent
with ERISA Section 404(c) and the regulations thereunder.
•
Assist the Client in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan.
Provide discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5).
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2.
•
Non-fiduciary Services are:
•
Assist in the education of Plan participants about general investment information
and the investment alternatives available to them under the Plan. Client
understands the Wynn Capital’s assistance in education of the Plan participants
shall be consistent with and within the scope of the Department of Labor’s definition
of investment education (Department of Labor Interpretive Bulletin 96-1). As such,
the Wynn Capital is not providing fiduciary advice as defined by ERISA to the Plan
participants. Wynn Capital will not provide investment advice concerning the
prudence of any investment option or combination of investment options for a
particular participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
Wynn Capital may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Wynn Capital and Client.
3.
Wynn Capital has no responsibility to provide services related to the following types of
•
assets (“Excluded Assets”):
•
•
•
•
•
•
not
Employer securities;
Real estate (except for real estate funds or publicly traded REITs);
Stock brokerage accounts or mutual fund windows;
Participant loans;
Non-publicly traded partnership interests;
Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
Other hard-to-value or illiquid securities or property.
Client Tailored Services and Client Imposed Restrictions
Excluded Assets will
be included in calculation of Fees paid to the Adviser on the ERISA
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2
disclosure.
Wrap Fee Programs
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities. Agreements may not be
assigned without written Client consent.
Client Assets under Management
Wynn Capital does not sponsor any wrap fee programs.
Wynn Capital has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$250,959,217
$0
Date Calculated:
December 31, 2024
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Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
Wynn Capital offers discretionary direct asset management services to advisory clients for
an annual fee of up to 1.00% of managed assets.
The annual fee may be negotiable. At their discretion, Wynn Capital, may reduce or waive
their annual fee. Any adjustments to the fee schedule will be summarized in the
Investment Advisory Agreement that is signed by the Client. Accounts within the same
household may be combined for a reduced fee. Fees are billed quarterly in arrears based on
the amount of assets managed as of the close of business on the last business day of the
previous quarter. If $10,000 or more in cash and/or securities are deposited into or
withdrawn from an existing account mid billing period a prorated fee will be charged for
that portion.
Quarterly advisory fees deducted from clients' accounts by the custodian will be reflected
on the quarterly statements as fees are withdrawn. Lower fees for comparable services
may be available from other sources. Clients may terminate their account within five (5)
business days of signing the Investment Advisory Agreement for a full refund. Clients may
terminate advisory services with thirty (30) days written notice. For accounts closed mid-
quarter, Wynn Capital will be entitled to a pro rata fee for the days service was provided in
the final quarter. Clients shall be given thirty (30) days prior written notice of any increase
in fees. Any increase in fees will be acknowledged by clients in writing.
ERISA PLAN SERVICES
The annual fee is based on the market value of the Included Assets and will not exceed
1.00%. Fees are charged quarterly in arrears based on the assets as calculated by the
custodian or record keeper of the Included Assets (without adjustments for anticipated
withdrawals by Plan participants or other anticipated or scheduled transfers or
distribution of assets) on the last business day of the previous quarter. If the services to be
provided start any time other than the first day of a quarter, the fee will be prorated based
on the number of days remaining in the quarter. If this Agreement is terminated prior to
the end of the fee period, Wynn Capital shall be entitled to a prorated fee based on the
number of days during the fee period services were provided.
Client Payment of Fees
The compensation of Wynn Capital for services provided is described in detail in Schedule
A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the Plan
Sponsor may elect to pay the fees. The Client may elect to be billed directly or have fees
deducted from Plan Assets. Wynn Capital does not reasonably expect to receive any
additional compensation, directly or indirectly, for its services under this Agreement. If
additional compensation is received, Wynn Capital will disclose this compensation, the
services rendered, and the payer of compensation. Wynn Capital will offset this
compensation against the fees agreed upon under this Agreement.
Fees for asset management services are deducted from a designated Client account to
facilitate billing.
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Fees for ERISA services will either be deducted from Plan assets or paid directly to Wynn
Capital.
Additional Client Fees Charged
The Client must consent in advance to direct debiting of their investment account.
Prepayment of Client Fees
Custodians may charge transaction fees other related costs on the purchases or sales of
mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money
market funds and exchange-traded funds also charge internal management fees, which are
disclosed in the fund’s prospectus. Wynn Capital does not receive any compensation from
these fees. All of these fees are in addition to the management fee you pay to Wynn Capital.
For more details on the brokerage practices, see Item 12 of this brochure.
External Compensation for the Sale of Securities to Clients
Wynn Capital does not require any prepayment of fees.
Wynn Capital does not receive any external compensation for the sale of securities to
Clients, nor do any of the investment advisor representatives of Wynn Capital.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
Wynn Capital does not use a performance-based fee structure because of the conflict of
interest. Performance based compensation may create an incentive for Wynn Capital to
recommend an investment that may carry a higher degree of risk to the Client.
Item 7: Types of Clients
Description
Account Minimums
Wynn Capital generally provides investment advice to individuals, high net worth
individuals, and pension/profit sharing plans. Client relationships vary in scope and length
of service.
Wynn Capital requires an account minimum of $500,000, which may be waived based on
the needs of the client and the complexity of the situation.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
When it comes to investing, Wynn Capital believes that simpler is better. In that spirit,
Wynn Capital invests the equity portion of client portfolios in a diverse cross-section of
large, well-established, publicly traded businesses with durable competitive advantages.
These investments are made with the intention that they be owned for decades.
- 4 -
Security analysis methods may include fundamental analysis, technical analysis, charting,
and cyclical analysis. Investing in securities involves risk of loss that Clients should be
prepared to bear. Past performance is not a guarantee of future returns.
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is that
the market will fail to reach expectations of perceived value.
Technical analysis attempts to predict a future stock price or direction based on market
trends. The assumption is that the market follows discernible patterns and if these patterns
can be identified then a prediction can be made. The risk is that markets do not always
follow patterns and relying solely on this method may not take into account new patterns
that emerge over time.
Charting analysis strategy involves using and comparing various charts to predict long and
short term performance or market trends. The risk involved in using this method is that
only past performance data is considered without using other methods to crosscheck data.
Using charting analysis without other methods of analysis would be making the
assumption that past performance will be indicative of future performance. This may not
be the case.
Cyclical analysis assumes that the markets react in cyclical patterns which, once identified,
can be leveraged to provide performance. The risks with this strategy are twofold: 1) the
markets do not always repeat cyclical patterns; and 2) if too many investors begin to
implement this strategy, then it changes the very cycles these investors are trying to
exploit.
Wynn Capital invests the fixed income portion of client portfolios in highly rated bonds for
current income and return of principle upon maturity. Specific bond maturities are often
selected to satisfy known future cash requirements in specific portfolios. Fixed income
securities are rarely sold prior to maturity.
Investment Strategy
Wynn Capital uses a variety of information sources to analyze and select securities
purchased in client accounts including financial newspapers and magazines, research
materials prepared by others, corporate rating services, annual reports, prospectuses, and
filings with the Securities and Exchange Commission.
The investment strategy for a specific Client is based upon the objectives stated by the
Client during consultations. The Client may change these objectives at any time by
providing written notice to Wynn Capital. Each Client executes a Client profile form or
similar form that documents their objectives and their desired investment strategy.
Wynn Capital client portfolios are composed of individual stocks, individual bonds and
cash. Broad market index funds are used in circumstances where buying individual
securities is impractical. Based on the client’s tax situation, Wynn Capital may decide to
hold other legacy investments with large, unrealized capital gains.
The relative size of the fixed income/cash portion of client portfolios varies depending on
each client’s ability and willingness to tolerate fluctuations in the value of their investments
- 5 -
Security Specific Material Risks
(fluctuation in the value of an investment or portfolio of investments is often referred to as
“risk”). Accounts where fluctuations in value are less of a concern are heavily invested in
equity. Accounts with shorter time horizons, or where capital preservation is a priority,
have a substantial allocation to cash and bonds.
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following investment
• Market Risk
risks and should discuss these risks with Wynn Capital:
•
: The prices of securities in which clients invest may decline in response to
certain events taking place around the world, including those directly involving the
companies whose securities are owned by a fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors
should have a long-term perspective and be able to tolerate potentially sharp declines
Interest-rate Risk
in market value.
•
: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
Inflation Risk
attractive, causing their market values to decline.
: When any type of inflation is present, a dollar today will buy more than a
• Management Risk:
dollar next year, because purchasing power is eroding at the rate of inflation.
• Long-term purchases
The advisor’s investment approach may fail to produce the intended
results. If the advisor’s assumptions regarding the performance of a specific asset class
or fund are not realized in the expected time frame, the overall performance of the
client’s portfolio may suffer.
• Trading risk
: Long-term investments are those vehicles purchased with the
intension of being held for more than one year. Typically the expectation of the
investment is to increase in value so that it can eventually be sold for a profit. In
addition, there may be an expectation for the investment to provide income. One of the
biggest risks associated with long-term investments is volatility, the fluctuations in the
financial markets that can cause investments to lose value.
: Investing involves risk, including possible loss of principal. There is no
assurance that the investment objective of any fund or investment will be achieved.
Item 9: Disciplinary Information
Criminal or Civil Actions
Administrative Enforcement Proceedings
Wynn Capital and its management have not been involved in any criminal or civil action.
Wynn Capital and its management have not been involved in administrative enforcement
proceedings.
- 6 -
Self- Regulatory Organization Enforcement Proceedings
Wynn Capital and its management have not been involved in any self-regulatory
organizational enforcement proceedings that are material to a Client’s or prospective
Client’s evaluation of Wynn Capital or the integrity of its management.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Futures or Commodity Registration
Wynn Capital is not registered as a broker-dealer and no affiliated representatives of Wynn
Capital are registered representatives of a broker-dealer.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Neither Wynn Capital nor its affiliated representatives are registered or have an
application pending to register as a futures commission merchant, commodity pool
operator, or a commodity trading advisor.
Wynn Capital does not maintain any material relationships outside of the Advisory
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
Business.
Wynn Capital does not select or recommend other investment advisors.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
include employees and/or
The affiliated persons (affiliated persons
independent
contractors) of Wynn Capital have committed to a Code of Ethics (“Code”). The purpose of
our Code is to set forth standards of conduct expected of Wynn Capital affiliated persons
and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated
persons of Wynn Capital. The Code reflects Wynn Capital and its supervised persons’
responsibility to act in the best interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for
their personal accounts and how to mitigate any conflict of interest with our Clients. We do
not allow any affiliated persons to use non-public material information for their personal
profit or to use internal research for their personal benefit in conflict with the benefit to
our Clients.
Wynn Capital’s policy prohibits any person from acting upon or otherwise misusing non-
public or inside information. No advisory representative or other affiliated person, officer
or director of Wynn Capital may recommend any transaction in a security or its derivative
to advisory Clients or engage in personal securities transactions for a security or its
derivatives if the advisory representative possesses material, non-public information
regarding the security.
Wynn Capital’s Code is based on the guiding principle that the interests of the Client are
our top priority. Wynn Capital’s officers, directors, advisors, and other affiliated persons
- 7 -
have a fiduciary duty to our Clients and must diligently perform that duty to maintain the
complete trust and confidence of our Clients. When a conflict arises, it is our obligation to
put the Client’s interests over the interests of either affiliated persons or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have
access to non-public information regarding any Clients' purchase or sale of securities, or
non-public information regarding the portfolio holdings of any reportable fund, who are
involved in making securities recommendations to Clients, or who have access to such
recommendations that are non-public.
Wynn Capital will provide a copy of the Code of Ethics to any Client or prospective Client
upon request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
Wynn Capital and its affiliated persons do not recommend to Clients securities in which we
have a material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
Wynn Capital and its affiliated persons may buy or sell securities that are also held by
Clients. In order to mitigate conflicts of interest such as trading ahead of Client
transactions, affiliated persons are required to disclose all reportable securities
transactions as well as provide Wynn Capital with copies of their brokerage statements.
The Chief Compliance Officer of Wynn Capital is Robert Wynn. He reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over associated persons’ transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
Wynn Capital does not have a material financial interest in any securities being
recommended. However, affiliated persons may buy or sell securities at the same time they
buy or sell securities for Clients. In order to mitigate conflicts of interest such as front
running, affiliated persons are required to disclose all reportable securities transactions as
well as provide Wynn Capital with copies of their brokerage statements.
The Chief Compliance Officer of Wynn Capital is Robert Wynn. He reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over associated persons’ transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
Wynn Capital will recommend the use of a particular broker-dealer based on their duty to
seek best execution for the client, meaning they have an obligation to obtain the most
favorable terms for a client under the circumstances. The determination of what may
constitute best execution and price in the execution of a securities transaction by a broker
- 8 -
involves a number of considerations and is subjective. Factors affecting brokerage selection
include the overall direct net economic result to the portfolios, the efficiency with which
the transaction is affected, the ability to effect the transaction where a large block is
involved, the operational facilities of the broker-dealer, the value of an ongoing
relationship with such broker and the financial strength and stability of the broker. Wynn
Capital will select appropriate brokers based on a number of factors including but not
limited to their relatively low transaction fees and reporting ability. Wynn Capital relies on
its broker to provide its execution services at the best prices available. Lower fees for
comparable services may be available from other sources. Clients pay for any and all
custodial fees in addition to the advisory fee charged by Wynn Capital. Wynn Capital does
not receive any portion of the trading fees.
• Research and Other Soft Dollar Benefits
Wynn Capital will require the use of Charles Schwab & Co., Inc. ("Schwab"), to maintain
custody of clients assets and to effect trades for their accounts.
The Securities and Exchange Commission defines soft dollar practices as
arrangement under which products or services other than execution services are
obtained by Wynn Capital from or through a broker-dealer in exchange for directing
Client transactions to the broker-dealer. Although Wynn Capital has no formal soft
dollar arrangements, Wynn Capital may receive products, research and/or other
services from custodians or broker-dealers connected to client transactions or “soft
dollar benefits”. As permitted by Section 28(e) of the Securities Exchange Act of
1934, Wynn Capital receives economic benefits as a result of commissions
generated from securities transactions by the custodian or broker-dealer from the
accounts of Wynn Capital. Wynn Capital cannot ensure that a particular client will
benefit from soft dollars or the client’s transactions paid for the soft dollar benefits.
Wynn Capital does not seek to proportionately allocate benefits to client accounts to
any soft dollar benefits generated by the accounts.
• Brokerage for Client Referrals
A conflict of interest exists when Wynn Capital receives soft dollars which could
result in higher commissions charged to Clients. This conflict is mitigated by the fact
that Wynn Capital has a fiduciary responsibility to act in the best interest of its
Clients and the services received are beneficial to all Clients.
• Directed Brokerage
Wynn Capital does not receive client referrals from any custodian or third party in
exchange for using that broker-dealer or third party.
Aggregating Securities Transactions for Client Accounts
Wynn Capital does not allow directed brokerage accounts.
Wynn Capital is authorized in its discretion to aggregate purchases and sales and other
transactions made for the account with purchases and sales and transactions in the same
securities for other Clients of Wynn Capital. All Clients participating in the aggregated
order shall receive an average share price with all other transaction costs shared on a pro-
rated basis. If aggregation if not allowed or infeasible and individual transactions occur
- 9 -
(e.g., withdrawal or liquidation requests, odd-lot trades, etc.) an account may potentially be
assessed higher costs or less favorable prices than those where aggregation has occurred.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Review of Client Accounts on Non-Periodic Basis
Account reviews are performed quarterly by the Chief Compliance Officer of Wynn Capital,
Robert Wynn. Account reviews are performed more frequently when market conditions
dictate. Reviews of Client accounts include, but are not limited to, a review of Client
documented risk tolerance, adherence to account objectives, investment time horizon, and
suitability criteria, reviewing target allocations of each asset class to identify if there is an
opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities.
Content of Client Provided Reports and Frequency
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation.
Clients receive written account statements no less than quarterly from the account
Custodian. Clients receive confirmations of each transaction from the Custodian as well as
an additional statement during any month in which a transaction occurs. Annual
performance reports are also provided upon request.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest
Advisory Firm Payments for Client Referrals
Wynn Capital receives additional economic benefits from external sources as described
above in Item 12.
Wynn Capital does not compensate for Client referrals.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to Clients at their address of record at least quarterly. Clients are urged
to carefully compare the account statements received directly from their custodians to any
documentation or reports prepared by Wynn Capital.
Wynn Capital is deemed to have limited custody solely because advisory fees are directly
deducted from Client’s accounts by the custodian on behalf of Wynn Capital.
- 10 -
Item 16: Investment Discretion
Discretionary Authority for Trading
Wynn Capital requires discretionary authority to manage securities accounts on behalf of
Clients. Wynn Capital has the authority to determine, without obtaining specific Client
consent, the securities to be bought or sold, and the amount of the securities to be bought
or sold.
Wynn Capital allows Clients to place certain restrictions, as outlined in the Client’s
Investment Policy Statement or similar document. These restrictions must be provided to
Wynn Capital in writing.
The Client approves the custodian to be used and the commission rates paid to the
custodian. Wynn Capital does not receive any portion of the transaction fees or
commissions paid by the Client to the custodian.
Item 17: Voting Client Securities
Proxy Votes
Wynn Capital does not vote proxies on securities. Clients are expected to vote their own
proxies. The Client will receive their proxies directly from the custodian of their account or
from a transfer agent.
When assistance on voting proxies
is requested, Wynn Capital will provide
recommendations to the Client. If a conflict of interest exists, it will be disclosed to the
Client. If the Client requires assistance or has questions, they can reach out to the
investment advisor representatives of the firm at the contact information on the cover page
of this document.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided to Clients because Wynn Capital does not
serve as a custodian for Client funds or securities and Wynn Capital does not require
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
prepayment of fees of more than $1,200 per Client and six months or more in advance.
Commitments to Clients
Bankruptcy Petitions during the Past Ten Years
Wynn Capital has no condition that is reasonably likely to impair our ability to meet
contractual commitments to our Clients.
Wynn Capital has not had any bankruptcy petitions in the last ten years.
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S U P E R V I S E D P E R S O N B R O C H U R E
Item 1 Cover Page
F O R M A D V P A R T 2 B
Robert Wynn, CFA
Office Address:
965 Broad Street
Augusta, GA 30901
Tel:
706-869-3451
Fax:
706-869-2263
Email:
Rob@wynncap.com
Website:
www.wynncap.com
March 12, 2025
This brochure supplement provides information about Robert Wynn and supplements the Wynn
Capital LLC brochure. You should have received a copy of that brochure. Please contact Robert Wynn
if you did not receive the brochure or if you have any questions about the contents of this
A D D I T I O N A L I N F O R M A T I O N A B O U T R O B E R T W Y N N ( C R D # 5 9 6 8 3 3 6) I S
supplement.
A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V .
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Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer – Robert Wynn, CFA
•
Item 2 - Educational Background and Business Experience
Year of birth: 1981
•
Educational Background
•
NYU Stern School of Business, Master of Business Administration –
Finance/Accounting; 05/2011
U.S. Naval Academy, Bachelor of Science – Political Science; 05/2004
Professional Certifications
Robert Wynn has earned certifications and credentials that are required to be explained in
further detail.
•
Chartered Financial Analyst (CFA): Chartered Financial Analysts designation is awarded by
the CFA Institute. CFA certification requirements:
•
Hold a bachelor’s degree from an accredited institution or have equivalent
educational or work experience.
•
Successful completion of all three exam levels of the CFA Program.
•
Have 48 months of acceptable professional work experience in the investment
decision-making process.
•
Fulfill society requirements, which vary by society. Unless you are upgrading from
affiliate membership, all societies require two sponsor statements as part of each
application; these are submitted online by your sponsors.
Agree to adhere to and sign the Member's Agreement, a Professional Conduct
Statement, and any additional documentation requested by CFA Institute.
•
Business Experience
•
Wynn Capital LLC; Managing Member/Chief Compliance Officer; 08/2015 to Present
•
Asset Advisors Corporation; Portfolio Manager; 06/2013 to 09/2015
•
JP Morgan Securities, LLC; Global Investment Specialist; 09/2011 to 04/2013
•
Extended Vacation; 05/2011 to 09/2011
•
NYU Stern School of Business; Full-time Student; 08/2009 to 05/2011
Item 3 - Disciplinary Information
U.S. Navy; Sub Officer; 05/2004 to 08/2009
A.
Robert Wynn has never been involved in a criminal or civil action in a domestic, foreign
or military court of competent jurisdiction for which he:
- 13 -
1.
Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony;
(b) misdemeanor that involved investments or an investment-related business,
fraud, false statement or omissions, wrongful taking of property, bribery, perjury,
counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses;
2.
Is the named subject of a pending criminal proceeding that involves an investment-
related business, fraud, false statements or omissions, wrongful taking of property,
bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of
these offenses;
3.
Was found to have been involved in a violation of an investment-related statute or
regulation; or
4.
Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order.
B.
Robert Wynn never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory
authority in which he:
1.
Was found to have caused an investment-related business to lose its authorization
to do business; or the subject of an order by the agency or authority;
2.
Was found to have been involved in a violation of an investment-related statute or
regulation or was the subject of an order by the agency or authority
(a)denying, suspending or revoking the authorization of the supervised person to
act in an investment-related business; (b) barring or suspending his association
with an investment-related business; (c) otherwise significantly limiting his
investment-related activities; or (d) imposing a civil money penalty of more than
$2,500 on him.
C.
Robert Wynn has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
1.
Was found to have caused an investment-related business to lose its authorization
to do business; or
2.
limited
Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members, or
was expelled
from
from membership; (b) otherwise significantly
investment-related activities; or (c) fined more than $2,500.
D.
Item 4 - Other Business Activities
any other hearing or formal adjudication in
Robert Wynn has not been involved in
which a professional attainment, designation, or license of the supervised person was
revoked or suspended because of a violation of rules relating to professional conduct.
Robert Wynn does not have any other business activities.
- 14 -
Item 5 - Additional Compensation
Robert Wynn does not receive any performance-based fees and does not receive any
additional compensation for performing advisory services other than what is described in
Item 6 - Supervision
Item 5 of Part 2A.
Since Robert Wynn is the sole owner and investment adviser representative of Wynn
Capital and is solely responsible for all supervision and formulation and monitoring of
investment advice offered to Clients. He will adhere to the policies and procedures as
described in the firm’s Compliance Manual. He can be reached at Rob@wynncap.com or
706-869-3451.
- 15 -
S U P E R V I S E D P E R S O N B R O C H U R E
Item 1 Cover Page
F O R M A D V P A R T 2 B
®
Michael “Emmett” Turner, CFP
, CPA
Office Address:
965 Broad Street
Augusta, GA 30901
Tel:
706-869-3451
Fax:
706-869-2263
Email:
Emmett@wynncap.com
Website:
www.wynncap.com
March 12, 2025
This brochure supplement provides information about Emmett Turner and supplements the Wynn
Capital LLC brochure. You should have received a copy of that brochure. Please contact Emmett
Turner if you did not receive the brochure or if you have any questions about the contents of this
A D D I T I O N A L I N F O R M A T I O N A B O U T E M M E T T T U R N E R ( C R D # 7 0 5 1 8 5 4)
supplement.
I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V .
- 16 -
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Emmett Turner, CFP®, CPA
•
Item 2 - Educational Background and Business Experience
Year of birth: 1983
•
Educational Background
•
Auburn University; Master of Accountancy Accounting; 2012
Augusta State University; Bachelor of Business Administration Accounting; 2005
Professional Certifications
Emmett Turner has earned certifications and credentials that are required to be explained
in further detail.
®
)
®
®
®
certification. You may find more information about CFP
CERTIFIED FINANCIAL PLANNER™ (CFP
I am certified for financial planning services in the United States by Certified Financial
Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a
professional, and I may use
CERTIFIED FINANCIAL PLANNER™ professional or a CFP
these and CFP Board’s other certification marks (the “CFP Board Certification Marks”).
certification is voluntary. No federal or state law or regulation requires financial
CFP
®
planners to hold CFP
certification at www.cfp.net.
®
®
professionals have met CFP Board’s high standards for education, examination,
professional, an individual must fulfill the
CFP
experience, and ethics. To become a CFP
Education
following requirements:
•
Examination
– Earn a bachelor’s degree or higher from an accredited college or
university and complete CFP Board-approved coursework at a college or university
through a CFP Board Registered Program. The coursework covers the financial
planning subject areas CFP Board has determined are necessary for the competent
and professional delivery of financial planning services, as well as a comprehensive
financial plan development capstone course. A candidate may satisfy some of the
coursework requirement through other qualifying credentials.
®
•
– Pass the comprehensive CFP
Experience
Certification Examination. The
examination is designed to assess an individual’s ability to integrate and apply a
broad base of financial planning knowledge in the context of real-life financial
planning situations.
•
Ethics
– Complete 6,000 hours of professional experience related to the
personal financial planning process, or 4,000 hours of apprenticeship experience
Fitness Standards for Candidates for CFP® Certification and
that meets additional requirements.
Former CFP® Professionals Seeking Reinstatement
•
– Satisfy the
and agree to be bound by CFP
- 17 -
Code of Ethics and Standards of Conduct (“Code and Standards”)
, which sets
®
Board’s
forth the ethical and practice standards for CFP
professionals.
Code and Standards
Ethics
Individuals who become certified must complete the following ongoing education and
ethics requirements to remain certified and maintain the right to continue to use the CFP
Board Certification Marks:
•
– Commit to complying with CFP Board’s
®
Continuing Education
. This includes a
commitment to CFP Board, as part of the certification, to act as a fiduciary, and
therefore, act in the best interests of the client, at all times when providing financial
advice and financial planning. CFP Board may sanction a CFP
professional who
®
does not abide by this commitment, but CFP Board does not guarantee a CFP
professional's services. A client who seeks a similar commitment should obtain a
written engagement that includes a fiduciary obligation to the client.
•
– Complete 30 hours of continuing education hours every
two years to maintain competence, demonstrate specified levels of knowledge,
Code and Standards
skills, and abilities, and keep up with developments in financial planning. Two of the
hours must address the
.
•
Certified Public Accountant (CPA): A Certified Public Accountant is licensed by their state
board of accountancy. While state laws and regulations vary, the education, experience and
testing requirements for licensure as a CPA generally include:
•
•
•
•
Bachelor’s degree from an accredited college or university with a concentration in
accounting.
Minimum experience levels (most states require at least one year of experience
providing services that
involve the use of accounting, attest, compilation,
management advisory, financial advisory, tax or consulting skills, all of which must
be achieved under the supervision of or verification by a CPA.)
Successful completion of the CPA Certification Exam.
Follow a rigorous Code of Professional Conduct which requires they act with
integrity, objectivity, due care, competence, and fully disclose conflicts of interest.
In order to maintain a CPA license, states generally require the completion of 40
hours of continuing professional education (CPE) each year (or 80 hours over a two-
year period, or 120 hours over a three-year period).
•
Business Experience
•
Wynn Capital LLC; Vice President/ Investment Adviser Representative; 12/2018 to
Present
•
Elliott Davis, LLC; Assurance Manager; 08/2012 – 11/2018
•
Student; 05/2011 – 07/2012
Item 3 - Disciplinary Information
Westminster Schools of Augusta; Accounting Assistant; 02/2011 – 05/2011
A.
Emmett Turner has never been involved in a criminal or civil action in a domestic,
foreign or military court of competent jurisdiction for which he:
- 18 -
1.
Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony;
(b) misdemeanor that involved investments or an investment-related business,
fraud, false statement or omissions, wrongful taking of property, bribery, perjury,
counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses;
2.
Is the named subject of a pending criminal proceeding that involves an investment-
related business, fraud, false statements or omissions, wrongful taking of property,
bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of
these offenses;
3.
Was found to have been involved in a violation of an investment-related statute or
regulation; or
4.
Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order.
B.
Emmett Turner never had an administrative proceeding before the SEC, any other
federal regulatory agency, any state regulatory agency, or any foreign financial
regulatory authority in which he:
1.
Was found to have caused an investment-related business to lose its authorization
to do business; or the subject of an order by the agency or authority;
2.
Was found to have been involved in a violation of an investment-related statute or
regulation or was the subject of an order by the agency or authority
(a)denying, suspending or revoking the authorization of the supervised person to
act in an investment-related business; (b) barring or suspending his association
with an investment-related business; (c) otherwise significantly limiting his
investment-related activities; or (d) imposing a civil money penalty of more than
$2,500 on him.
C.
Emmett Turner has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
1.
Was found to have caused an investment-related business to lose its authorization
to do business; or
2.
limited
Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members, or
was expelled
from
from membership; (b) otherwise significantly
investment-related activities; or (c) fined more than $2,500.
D.
Item 4 - Other Business Activities
any other hearing or formal adjudication in
Emmett Turner has not been involved in
which a professional attainment, designation, or license of the supervised person was
revoked or suspended because of a violation of rules relating to professional conduct.
Emmett Turner does not have any other business activities.
- 19 -
Item 5 - Additional Compensation
Emmett Turner does not receive any performance-based fees and does not receive any
additional compensation for performing advisory services other than what is described in
Item 6 - Supervision
Item 5 of Part 2A.
Emmett Turner is supervised by Robert Wynn, Managing Member/Chief Compliance
Officer of Wynn Capital. He reviews Emmett Turner’s work through client account reviews,
quarterly personal transaction reports, as well as face-to-face and phone interactions.
Robert Wynn can be reached at Rob@wynncap.com or 706-869-3451.
- 20 -
S U P E R V I S E D P E R S O N B R O C H U R E
Item 1 Cover Page
F O R M A D V P A R T 2 B
Joshua M. Baker, CPA
Office Address:
965 Broad Street
Augusta, GA 30901
Tel:
706-869-3451
Fax:
706-869-2263
Email:
josh@wynncap.com
Website:
www.wynncap.com
March 12, 2025
This brochure supplement provides information about Joshua M. Baker and supplements the Wynn
Capital LLC brochure. You should have received a copy of that brochure. Please contact Joshua Baker
if you did not receive the brochure or if you have any questions about the contents of this
A D D I T I O N A L I N F O R M A T I O N A B O U T J O S H U A M . B A K E R ( C R D # 7 6 6 1 1 6 6)
supplement.
I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V .
- 21 -
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Joshua M. Baker, CPA
•
Item 2 - Educational Background and Business Experience
Year of birth: 1996
•
Educational Background
•
University of Georgia; Master of Accountancy - Accounting; 2018
University of Georgia; Bachelor of Business Administration - Accounting; 2017
Professional Certifications
Joshua Baker has earned certifications and credentials that are required to be explained in
further detail.
•
Certified Public Accountant (CPA): A Certified Public Accountant is licensed by their state
board of accountancy. While state laws and regulations vary, the education, experience and
testing requirements for licensure as a CPA generally include:
•
•
•
•
Bachelor’s degree from an accredited college or university with a concentration in
accounting.
Minimum experience levels (most states require at least one year of experience
providing services that
involve the use of accounting, attest, compilation,
management advisory, financial advisory, tax or consulting skills, all of which must
be achieved under the supervision of or verification by a CPA.)
Successful completion of the CPA Certification Exam.
Follow a rigorous Code of Professional Conduct which requires they act with
integrity, objectivity, due care, competence, and fully disclose conflicts of interest.
In order to maintain a CPA license, states generally require the completion of 40
hours of continuing professional education (CPE) each year (or 80 hours over a two-
year period, or 120 hours over a three-year period).
•
Business Experience
•
Wynn Capital LLC; Investment Adviser Representative; 11/2022 to Present
•
Wynn Capital LLC; Investment Analyst; 08/2022 – Present
•
Serotta Maddocks Evans & Co., CPAs; CPA - Tax Accountant; 08/2020 – 07/2022
•
Deloitte Tax LLP; CPA - Tax Consultant; 01/2019 – 07/2020
•
Dixon Hughes Goodman LLP; Intern – Tax Accountant; 06/2018 – 07/2018
•
Student; 05/2010– 12/2018
Cherry Bekaert LLP; Intern – Tax Accountant; 06/2017 – 08/2017
- 22 -
Item 3 - Disciplinary Information
E.
Joshua Baker has never been involved in a criminal or civil action in a domestic, foreign
or military court of competent jurisdiction for which he:
5.
Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony;
(b) misdemeanor that involved investments or an investment-related business,
fraud, false statement or omissions, wrongful taking of property, bribery, perjury,
counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses;
6.
Is the named subject of a pending criminal proceeding that involves an investment-
related business, fraud, false statements or omissions, wrongful taking of property,
bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of
these offenses;
7.
Was found to have been involved in a violation of an investment-related statute or
regulation; or
8.
Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order.
F.
Joshua Baker never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory
authority in which he:
3.
Was found to have caused an investment-related business to lose its authorization
to do business; or the subject of an order by the agency or authority;
4.
Was found to have been involved in a violation of an investment-related statute or
regulation or was the subject of an order by the agency or authority
(a)denying, suspending or revoking the authorization of the supervised person to
act in an investment-related business; (b) barring or suspending his association
with an investment-related business; (c) otherwise significantly limiting his
investment-related activities; or (d) imposing a civil money penalty of more than
$2,500 on him.
G.
Joshua Baker has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
3.
Was found to have caused an investment-related business to lose its authorization
to do business; or
4.
limited
Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members, or
was expelled
from
from membership; (b) otherwise significantly
investment-related activities; or (c) fined more than $2,500.
H.
any other hearing or formal adjudication in
Joshua Baker has not been involved in
which a professional attainment, designation, or license of the supervised person was
revoked or suspended because of a violation of rules relating to professional conduct.
- 23 -
Item 4 - Other Business Activities
Item 5 - Additional Compensation
Joshua Baker does not have any other business activities.
Joshua Baker does not receive any performance-based fees and does not receive any
additional compensation for performing advisory services other than what is described in
Item 6 - Supervision
Item 5 of Part 2A.
Joshua Baker is supervised by Robert Wynn, Managing Member/Chief Compliance Officer
of Wynn Capital. He reviews Joshua Baker’s work through client account reviews, quarterly
personal transaction reports, as well as face-to-face and phone interactions.
Robert Wynn can be reached at Rob@wynncap.com or 706-869-3451.
- 24 -