Windham Financial Services, Inc., has prepared this report pursuant to U.S. Securities and Exchange Commission Rule 11Ac1-6 which requires all brokerage firms to make publicly available quarterly reports on their order routing practices. The report provides information on the routing of "non-directed orders" - any order that the customer has not specifically instructed to be routed to a particular venue for execution. For these non-directed orders, Windham Financial has selected the execution venue on behalf of its customers.  For purposes of the Rule, the term "customer orders" is defined as any orders that are not for the account of a broker-dealer.  Please note that Windham Financial will disclose to customers, upon request, the specific venues to which their individual orders were routed.

The report is divided into two sections: Part one is for securities listed on the New York Stock Exchange and reported as a Network A eligible security and one for securities listed on the American Stock Exchange or regional exchanges and reported as a Network B eligible security. Part two includes securities listed on the Nasdaq Stock Market  For each section, the report identifies the venue most often selected by Windham Financial, sets forth the percentage of various types of orders routed to the venue, and discusses the material aspects of Windham Financial's relationship with the venue.  Please note that it is Windham Financial's policy NOT to receive any payment, fees or commissions for directed orderflow.

SEC Rule 606 SUMMARY ANALYSIS FOR 3rd QUARTER of 2008 (JULY - SEPT, 2008)

PART ONE:

100% of Windham Financial's orders in listed equities on the New York and American Stock exchanges are routed to Knight Capital Markets, LLC.  There are no material aspects of our relationship with Knight that require any disclosure. 

CLICK TO VIEW RULE 605 DATA 

PART TWO:

100% of Windham Financial's orders on the Nasdaq Stock Exchange are routed to JP Morgan Clearing Corp.  Please note that JP Morgan Clearing Corp., holds all Windham Financial Client accounts and clears all customer transactions.

 In addition, JP Morgan Clearing Corp. routes all of Windham Financial's Option Orders.