Windham Capital Management, LLC

Windham Capital Management, LLC is an investment adviser registered with the SEC since 1988. The firm specializes in managing Private Fund Strategies, specifically the Risk Premia and Commodity strategies, primarily for high net worth and institutional investors meeting specific standards. Windham operates as a fiduciary for retirement accounts, ensuring advice is in the client's best interest. As of June 30, 2024, Windham managed approximately $192,054,346 in assets on a discretionary basis. For fees, Windham charges Private Fund clients around 1.00% per year based on the account's market value, with negotiable rates based on assets managed and client-specific guidelines. The Commodity Fund incurs a 10% performance-based fee. Clients are responsible for additional expenses like brokerage commissions and custody fees unless otherwise decided by Windham. Investment strategies include the Risk Premia Strategy, focusing on various asset classes, and the Commodity Strategy for uncorrelated returns. Windham discloses risks associated with foreign securities, futures, alternatives, and operational risks, including those related to information technology and the impact of events like the COVID-19 pandemic. Windham does not have physical custody of client assets, which are held by third-party institutions. The firm has full investment discretion for managing client accounts and has adopted Proxy Voting Policies to ensure votes align with clients' best interests. Windham has no financial commitments impairing its ability to meet client obligations and has not undergone bankruptcy proceedings.