Twin Lights Capital Management LLC

Twin Lights Capital Management is an independent, single‑advisor registered investment adviser that provides discretionary investment management and occasional sub‑advisory services to a small client base of individuals, family offices and institutional investors such as endowments and trusts. As of December 31, 2025 the firm reported approximately $54.9 million in discretionary assets under management across eight client accounts and generally operates with a stated account minimum that may be waived in certain cases.

The firm specializes in U.S. growth equity strategies implemented in relatively concentrated portfolios, relying primarily on bottom‑up fundamental research supplemented by top‑down thematic analysis and a set of proprietary indicators. The brochure discloses that the strategy may employ hedging tools and leveraged ETFs and notes the adviser may use borrowing or leverage in separately managed accounts, and the firm does not conduct a full review of clients’ entire financial affairs or present its strategies as a complete financial plan.

Noteworthy items in the brochure that distinguish the firm from many peers include disclosure of predecessor performance in its marketing materials and the firm’s acceptance of institutional mandates despite being a solo practitioner, both of which are statistically uncommon for independent advisers of this size. The firm also discloses that the principal may serve as trustee on certain client accounts (subject to independent surprise examination) and emphasizes a concentrated, research‑driven approach that can increase single‑security and sector risk relative to more diversified managers.