Description of our Business Washburn Capital Management, Inc. is an investment advisor in Vero Beach, Florida. We are a Florida corporation and began doing business in January 1997 as Paradigm of Indian River County, Inc. The company changed its name to Washburn Capital Management, Inc. in 2005. Robert E. Washburn, President is the majority owner of Washburn Capital Management, Inc. David J. Washburn is the Vice President and is a minority owner. We provide discretionary investment management services to individuals, including high net worth individuals, and business entities.
Our brochure will hereafter refer to Washburn Capital Management, Inc. as "Washburn" and clients and prospective clients as "Client". The term "Associated Persons" includes officers, employees, and all individuals providing investment advice on behalf of Washburn.
Our sole objective is to meet the individual investment needs of each and every client. Washburn is client centric and we recognize each client has their own financial circumstances, risk tolerance, time horizon and set of investment goals. Our firm works closely with each client – through meetings and frequent formal and informal communications – to understand the client's financial situation, risk limitations and growth expectations.
Based on these meetings we partner with our clients, set realistic goals and devise strategies to achieve the desired goals. At this point, we also discuss any restrictions a client may wish to impose. Each and every client receives close, personal attention where we share our expertise and become personally involved in the development of the portfolio.
For each discretionary relationship a formal strategy and investment objective letter is created and approved by Washburn and the Client. This letter establishes the account's objective and provides asset allocation ranges. These agreements are used throughout the management of the portfolio and reviewed frequently for compliance.
Types of Investments We primarily offer advice on equity and fixed income

securities as well as exchange traded funds.
We may also advise our clients on any investment held in the portfolio at the inception of the advisory relationship.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice); 4
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of December 31, 2022, Washburn Capital managed $186,637,289 in client assets on a discretionary basis.