A Headwater Investment Consulting, Inc. (“Headwater,” “firm,” “we,” “our,” and “us”) is an independent SEC registered investment advisory firm located in McMinnville, Oregon. We provide fee-only investment management services to clients (“you,” “your,” and “client”). The firm has been in business since 2004. The principal owners are Scott Chambers, Thomas Sherwood, and Kevin Chambers. Our investment advisory services are driven by and coordinated with each client’s individual financial goals. Our approach uses broadly diversified portfolios and a systematic strategy to manage investments. We follow strict fiduciary standards, putting our clients’ interests before our own and seeking to avoid conflicts of interest with our clients. We are compensated only by our clients. B, C We help clients coordinate and prioritize their financial lives with all aspects of their life goals. Integrating investments across all individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to the process. Client input and involvement are critical to the implementation of investment decisions. After client assets are invested, we continuously monitor their investments and provide advice related to ongoing financial and investment needs. We are objective advisors, and we always put our clients’ interests first. Headwater generally has discretionary authority over client funds. Discretionary authority means we have the authority to determine, without obtaining specific client consent, the securities bought or sold and the amount of securities bought or sold. The only restrictions on the above discretionary

authority are those set by the client on a case-by-case basis. Discretionary authority allows us to act on behalf of the client in most matters necessary or incidental to the handling of the account, including monitoring certain assets, without the client’s prior approval. Advice and services are tailored to the stated objectives of the client(s). We discuss with the client in detail critically important information such as the client’s risk tolerance, time horizon, and projected future needs to formulate an investment policy. This policy guides us in objectively and suitably managing the client’s account. We meet with clients as needed to review portfolio performance, discuss current issues, and re-assess goals and plans. Our approach uses broadly diversified portfolios and a systematic strategy to manage investments. Our investment recommendations generally include mutual funds and exchange traded funds. We also recommend certificates of deposit, municipal securities, U.S. government and agency securities, and money market funds. If clients hold other types of investments, we will advise them on those investments as well. Clients may impose restrictions on investing in certain securities or types of securities. We consider such restrictions when preparing the Investment Policy Statement. See Item 8 for a description of our investment strategy. D We do not participate in or sponsor any wrap fee programs E We manage $377,645,000 of client assets on a discretionary basis and $19,103,000 of client assets on a non-discretionary basis. This amount was calculated as of December 31, 2023. PART 2A OF FORM ADV 2