# Headwater Investment Consulting,inc.

> Headwater Investment Consulting,inc. is an SEC-registered investment advisory firm in McMinnville, OR, registered since 2005, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated March 18, 2026.

- CRD: 133009
- Filed as: HEADWATER INVESTMENT CONSULTING,INC.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: McMinnville, OR
- Filing period: October 2026
- Form ADV filing dated: March 18, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/133009
- AdvisorCensus page: https://advisorcensus.com/firm/headwater-investment-consulting-inc-mcminnville-or-133009

## Quick answers

**How is Headwater Investment Consulting,inc. compensated?**
On its Form ADV (Item 5.E, October 2026), Headwater Investment Consulting,inc. reports these compensation arrangements: a percentage of assets under its management.

**How much does Headwater Investment Consulting,inc. charge?**
Its Form ADV Part 2A brochure dated March 18, 2026 states: Asset-based fee: 0.75% of assets a year. Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Headwater Investment Consulting,inc. located?**
Headwater Investment Consulting,inc.'s principal office is in McMinnville, OR, according to its Form ADV.

**Is Headwater Investment Consulting,inc. registered with the SEC or a state?**
Headwater Investment Consulting,inc. is an SEC-registered investment advisory firm, registered since 2005. Status as filed: Approved. CRD 133009.

**How much does Headwater Investment Consulting,inc. manage?**
Headwater Investment Consulting,inc. reports $542,975,000 in regulatory assets under management in its Form ADV filing dated March 18, 2026 (96% discretionary).

**How have Headwater Investment Consulting,inc.'s assets and staff changed since 2021?**
In the Form ADV data for Headwater Investment Consulting,inc.: Regulatory assets under management: $297,908,000 in the October 2021 data and $542,975,000 in the October 2026 data, up 82%. Total employees: 6 in October 2021 and 7 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Headwater Investment Consulting,inc. serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (403); high net worth individuals (185); charitable organizations (42).

**Which custodians does Headwater Investment Consulting,inc. use?**
Headwater Investment Consulting,inc.'s most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Fidelity Brokerage Services LLC as a custodian holding 10% or more of its separately managed account assets.

**Does Headwater Investment Consulting,inc. report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/133009

**What changed in Headwater Investment Consulting,inc.'s recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $466,280,000 to $542,975,000 (+16%).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management

### Fees and minimums (Form ADV Part 2A brochure dated March 18, 2026)

- Asset-based fee: 0.75% of assets a year

> Headwater’s Standard Fee is 0.75% annually on all assets under management although this fee is negotiable.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- Fidelity Brokerage Services LLC

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $542,975,000
- Discretionary: $523,571,000
- Non-discretionary: $19,404,000

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 403 | $207,318,000 |
| High net worth individuals | 185 | $285,976,000 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | Fewer than 5 | $477,000 |
| Charitable organizations | 42 | $36,074,000 |
| Corporations or other businesses not listed above | 19 | $13,130,000 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses (other than small businesses) or institutional clients

### Firm details
- Registered since: 2005 (20 years)
- Employees: 7 total, 5 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AZ, CA, CO, ID, NH, NV, OR, TX, WA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- [headwater-ic.com](https://headwater-ic.com)
- [headwateric.com](https://headwateric.com)
- Facebook @HEADWATERINVESTMENTCONSULTING
- LinkedIn @HEADWATER-IC

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $297,908,000 | 6 | February 17, 2021 |
| October 2022 | $353,179,000 | 6 | March 3, 2022 |
| October 2023 | $319,468,000 | 6 | May 10, 2023 |
| October 2024 | $396,748,000 | 5 | May 7, 2024 |
| October 2025 | $466,280,000 | 5 | February 3, 2025 |
| October 2026 | $542,975,000 | 7 | March 18, 2026 |

Regulatory assets under management: $297,908,000 in the October 2021 data and $542,975,000 in the October 2026 data, up 82%.
Total employees: 6 in October 2021 and 7 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $466,280,000 to $542,975,000 (+16%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Headwater Investment Consulting,inc. (CRD 133009): Form ADV filing data as of October 2026.