Investor Summary
Fund Strategy
FUND PERFORMANCE AS OF 31st December 2025
| ANNUALIZED SINCE INCEPTION | QUARTERLY | YTD |
|---|---|---|
| - | - | - |
| ANNUALIZED SINCE INCEPTION | QUARTERLY | YTD |
|---|---|---|
| - | - | - |
Headwaters Capital's manager describes 2025 as one of the narrowest markets in history, with 65% of Russell 2000 returns driven by AI infrastructure plays and the remainder by speculative unprofitable companies. Market concentration has reached historic extremes, creating unprecedented valuation disparities between winners and losers. Quality businesses now trade at historically cheap multiples while the market remains levered to a singular AI infrastructure theme dependent on five companies' data center CAPEX spending. The manager believes this environment presents both significant opportunities and risks, with the potential for reversal in unprofitable company trades if earnings ultimately drive stock prices. The sustainability of the AI trade remains debatable given its concentration risk. In this context, the manager emphasizes the value of active management to navigate these disparities. The letter concludes with a business announcement that the manager will join ZWJ Investment Counsel as Portfolio Manager beginning April 1, 2026, continuing the same investment philosophy and approach.
In a historically concentrated market dominated by AI infrastructure and unprofitable companies, quality businesses trading at cheap multiples present compelling opportunities for active managers who can navigate valuation disparities.
The manager views the current market as presenting as many opportunities and risks as ever remembered, with quality businesses trading at historically cheap multiples while concentration reaches extreme levels.
| Date | Letter | Tickers | Keywords | Pitches | Quick Takes |
|---|---|---|---|---|---|
| Mar 17 2026 | 2025 Q4 | - | active management, AI, Concentration, Quality, small caps, valuation | - | AI infrastructure plays dominated market returns in 2025, with 65% of Russell 2000 returns coming from AI infrastructure. The market concentration is tied to AI… |
| Oct 10 2025 | 2025 Q3 | BSY, DRVN, INSP, MEDP, ORCL | AI, Autos, Capex, infrastructure, valuation | - | Headwaters argues the AI build-out has become a CAPEX-driven earnings bubble akin to the telecom boom, with $400B+ in projected annual data-center spend. The fund… |
| Jul 10 2025 | 2025 Q2 | GMED, TECH, TMDX | AI, Rotation, small caps, valuation | TECH | - |
| Apr 8 2025 | 2025 Q1 | BRO, CBZ, TRNS | - | - | - |
| Jan 14 2025 | 2024 Q4 | CLMB, PLTR, TMDX | - | - | - |
| Oct 7 2024 | 2024 Q3 | ASGTF, CSGP, EYE, FICO, MEDP | - | - | - |
| Jul 11 2024 | 2024 Q2 | INSP, PDFS, TMDX | - | - | - |
| Apr 20 2024 | 2024 Q1 | CLMB, QLYS, UFPT | - | - | - |
| Dec 1 2024 | 2023 Q4 | ABC LN, FICO, INSP, IPAR | - | - | - |
| Oct 26 2023 | 2023 Q3 | DHR, INSP, QLYS | - | - | - |
| Jul 25 2023 | 2023 Q2 | ABCM, CYRX, NSIT, TMDX | - | - | - |
| Apr 28 2023 | 2023 Q1 | EYE, FND | - | - | - |
| Oct 2 2023 | 2022 Q4 | CABO, FICO, ICFI, NOTV | - | - | - |
| QUARTER | THEMES | TAGS |
|---|---|---|
| 2025 Q4 |
AIThe extended federal government shutdown added volatility during what was otherwise a risk-on environment, with a mid-quarter shift in market behavior for AI-related equities as the exuberant narrative evolved to one more balanced in assessing the technology's enormous potential against staggering capital spending plans and high expectations. The team initiated a position in Credo Technology as a more diversified way to gain exposure to strong trends in AI-connectivity. |
Connectivity Semiconductors Infrastructure Capital Spending |
QualityThe portfolio has shifted toward higher quality businesses with better profitability, lower leverage, and less volatile earnings. Quality stocks underperformed significantly in 2025, creating attractive entry points for value investors. The manager maintains price discipline while seeking quality companies trading at discounts to intrinsic value. |
Quality Profitability Leverage Earnings | |
Small CapsThe fund invests in a portfolio of competitively advantaged small and medium-sized businesses, which remained out of favor for most of the quarter. The strategy of owning leading small-cap businesses has been the foundation since inception, delivering 354 basis points of annual outperformance over the benchmark since inception despite recent headwinds. |
Growth Outperformance Benchmark Russell Businesses | |
| 2025 Q3 |
AIThe extended federal government shutdown added volatility during what was otherwise a risk-on environment, with a mid-quarter shift in market behavior for AI-related equities as the exuberant narrative evolved to one more balanced in assessing the technology's enormous potential against staggering capital spending plans and high expectations. The team initiated a position in Credo Technology as a more diversified way to gain exposure to strong trends in AI-connectivity. |
Connectivity Semiconductors Infrastructure Capital Spending |
AutosGentex Corporation faced headwinds from mix-shift towards lower-end vehicle production due to tariff impacts in Europe and China. However, the Ford Bronco launch marked an important milestone for Full Display Mirror technology, which remains the company's most reliable growth driver as automakers increasingly adopt advanced technologies. |
Auto Parts Autos Auto Aftermarket Electric Vehicles Auto Dealers | |
InfrastructureDigital 9 Infrastructure holds telecom infrastructure assets including Arqiva stake. Despite poor 2025 performance, potential capital returns and asset sales could unlock value. Infrastructure assets provide defensive characteristics. |
Telecom Infrastructure Digital Infrastructure | |
| 2025 Q2 |
Rotation |
|
Small CapsThe fund invests in a portfolio of competitively advantaged small and medium-sized businesses, which remained out of favor for most of the quarter. The strategy of owning leading small-cap businesses has been the foundation since inception, delivering 354 basis points of annual outperformance over the benchmark since inception despite recent headwinds. |
Growth Outperformance Benchmark Russell Businesses |
| Date | Pitch Type | Author | Ticker | Company | Industry | Sub Industry | Bull / Bear | Exchange | Keywords | Action |
|---|---|---|---|---|---|---|---|---|---|---|
| Jul 10, 2025 | Fund Letters | Christopher Godfrey | TECH | Bio-Techne Corporation | Health Care | Life Sciences Tools & Services | Neutral | NASDAQ | Celltherapy, Consumables, Genomics, M&A, Nih, Reagents, valuation | Login |
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