Investor Summary
Fund Strategy
FUND PERFORMANCE AS OF 31st December 2025
| ANNUALIZED SINCE INCEPTION | QUARTERLY | YTD |
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| - | - | - |
| ANNUALIZED SINCE INCEPTION | QUARTERLY | YTD |
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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 | - | Market concentration reached historic extremes in 2025 with AI infrastructure and unprofitable companies dominating returns. Quality businesses trade at historically cheap multiples while the market remains levered to a singular AI theme. This creates significant opportunities for active managers to capitalize on valuation disparities between winners and losers. |
| Oct 10 2025 | 2025 Q3 | AMD, AMZN, BSY, BYD, DRVN, GOOGL, INSP, MEDP, META, MSFT, NVDA, ORCL, VVV | AI, Auto Aftermarket, Biotechnology, Bubble, Capex, mid cap, value | - | Headwaters underperformed due to extreme AI concentration driving market bifurcation, with non-AI stocks declining while AI names captured 148% of index gains. Manager views current $405B AI infrastructure spending as unsustainable earnings bubble, positioning portfolio in overlooked automotive aftermarket and biotech services trading at attractive valuations. Expects normalization to create opportunities in forgotten market segments. |
| Jul 10 2025 | 2025 Q2 | COIN, DHR, GMED, HOOD, MSTR, NVDA, PLTR, TECH, TMDX, TMO | AI, Biotechnology, mid cap, Risk Appetite, small caps, valuation |
TECH TECH |
Headwaters gained 7.3% in Q2 but lagged due to extreme market concentration in AI and speculative assets reminiscent of 1999. Unsustainable valuation spreads between momentum stocks and quality businesses create attractive opportunities in small caps. Added Bio-Techne at trough valuations while selling Transmedics. Positioned for eventual rotation from speculation to quality. |
| Apr 8 2025 | 2025 Q1 | BRO, CBZ, TRNS | Bear Market, Quality, small caps, Trade Policy, Valuations, volatility |
BRO TRNS CBZ |
Small cap manager navigating trade war volatility with Russell 2000 in bear market. Portfolio down 9.2% but positioned in quality companies approaching historically attractive valuations. Rotating from expensive positions into discounted opportunities while maintaining equity exposure. Extreme fear indicators and historical analysis suggest compelling risk/reward for patient investors despite near-term uncertainty. |
| Jan 14 2025 | 2024 Q4 | CLMB, PLTR, TMDX | cybersecurity, Data centers, mid cap, Quality, Risk Appetite, Speculation, value |
CLMB TMDX |
Headwaters delivered solid 14% annual returns despite Q4's 6.6% decline from speculation-driven rotation away from quality. Manager sees 2021 bubble parallels with extreme valuations like PLTR at 51x sales. Maintains conviction in quality-focused approach as earnings ultimately drive long-term performance. Current environment presents opportunistic entry point for disciplined value investors. |
| Oct 7 2024 | 2024 Q3 | ASGTF, CLMB, EYE, FICO, MEDP | Biotechnology, Buybacks, Commercial real estate, mid cap, Rate Cuts, small caps, software | ASGTF | Headwaters matched benchmarks in Q3 after strong outperformance streak. Manager sees continued small cap opportunity following Fed rate cuts, supported by cheap valuations and 2025 earnings growth outlook. Added commercial real estate software play Altus Group ahead of business sale catalyst. Portfolio focused on quality businesses with pricing power and disciplined capital allocation in attractive end markets. |
| Jul 11 2024 | 2024 Q2 | AMAT, ANSS, ASML, CDNS, INSP, INTC, KLAC, KLIC, NVDA, PDFS, SNPS, TMDX | AI, Medical Devices, mid cap, semiconductors, small caps, technology, value | - | Headwaters outperformed by 450bp in Q2 with growing conviction in small caps trading at historic discounts to large caps. TransMedics delivered strong results while Inspire faced temporary headwinds. New position in PDF Solutions capitalizes on semiconductor manufacturing complexity. AI concentration in large caps continues obscuring broader market weakness, creating opportunities in high-ROE small caps. |
| Apr 20 2024 | 2024 Q1 | CLMB, QLYS, SOPH.L, SWI, UFPT | cybersecurity, Distribution, growth, mid cap, software, technology, value | CLMB | Headwaters outperformed in Q1 with 10.4% net returns driven by strong stock selection in mid-cap technology names. Added cybersecurity distributor CLMB while maintaining full investment despite market strength. Manager sees reasonable valuations and earnings growth supporting continued opportunities, particularly in small caps trading at attractive multiples relative to historical periods. |
| Dec 1 2024 | 2023 Q4 | ABCM, DHR, FICO, INSP, IPAR | Beauty, Concentration, Fragrance, growth, small cap, value | IPAR | Headwaters delivered +33% net returns in 2023 through concentrated small cap growth investing. Manager sees exceptional opportunity ahead with small caps trading at cheapest relative valuations since 2000. Added Inter Parfums fragrance licensing business while maintaining focus on patient capital deployment in unique businesses with durable growth prospects and long-term compounding potential. |
| Oct 26 2023 | 2023 Q3 | ABCM, CYRX, DHR, INSP, ISRG, QLYS, TECH, TMO, UFPT | activism, cybersecurity, healthcare, Life Sciences, mid cap, small caps, value |
QLYS ASIC|CWAN|INSP|KRMN|KTOS|MAC|MEG|RH|WYNN |
Headwaters underperformed in Q3 due to healthcare exposure amid GLP-1 drug fears, but the manager views concerns as overblown. Small cap valuations have reached historically attractive levels below previous troughs when bond yields were similar. The fund added to positions during weakness while maintaining opposition to the undervalued Danaher-Abcam deal. |
| 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 |
AIAI infrastructure plays dominated 2025 returns, with 65% of Russell 2000's return coming from AI infrastructure. The manager questions whether this singular bet on five companies' data center CAPEX spending will persist, noting the market's extreme concentration around this theme. |
Infrastructure Data Centers CAPEX |
Small CapsSmall caps underperformed large caps in 2025's narrow market. The manager notes that small cap returns were dominated by AI infrastructure plays and speculative unprofitable companies, creating extreme bifurcation in performance within the asset class. |
Russell 2000 Performance Bifurcation | |
QualityQuality businesses trade at historically cheap multiples despite extreme valuation disparities between winners and losers. The manager sees this as creating opportunities for active management in a concentrated market. |
Valuation Multiples Cheap | |
| 2025 Q3 |
AIManager believes AI infrastructure spending represents a massive capital cycle similar to telecom buildout in late 1990s, with hyperscalers spending $405B annually by 2026. Views current AI investment as unsustainable earnings bubble driven by elevated CAPEX rather than valuation bubble. Cites Oracle-OpenAI $300B contract as example of irrational economics requiring OpenAI to reach Google Search scale in two years. |
Data Centers CAPEX Infrastructure Hyperscalers Bubble |
Auto AftermarketPortfolio includes Driven Brands, largest automotive services company in North America operating maintenance and repair franchises. Thesis centers on recurring revenue from non-discretionary automotive services and growth from Take 5 Oil Change expansion. Views automotive maintenance as defensive business with predictable cash flows. |
Franchises Maintenance Oil Change Recurring Revenue Defensive | |
BiotechnologyMedpace was top contributor with +64% return despite difficult biotech funding environment. Company demonstrated strong bookings growth and aggressive share repurchases, buying back 10% of shares over past year. Manager views biotech services as cyclical but with steady market share gains potential. |
CRO Bookings Buybacks Cyclical Market Share | |
| 2025 Q2 |
AIAI enthusiasm is driving large cap outperformance and creating narrow market breadth concentrated in AI beneficiaries. The manager believes AI is real with lasting benefits but excitement around valuations is reaching extremes similar to 1999. History suggests the AI cycle will eventually reach over-investment and excess capacity. |
Technology Valuation Momentum Infrastructure |
Small CapsCurrent market environment appears to be one of the most attractive investment opportunities for quality small cap businesses since 1999. Extreme valuation spreads between large and small caps are unsustainable, creating opportunity for patient investors willing to invest in quality businesses ignored by the market. |
Value Quality Opportunity Valuation | |
BiotechnologyBio-Techne represents a market leading life sciences reagents and instruments company with recurring consumable revenue and strong margins. The company is trading at trough valuations due to concerns around US academic funding cuts, creating an attractive entry point for a high-quality asset. |
Life Sciences Academic Funding Quality | |
Risk AppetiteElevated risk appetite is evident in the outperformance of speculative assets including crypto companies, quantum computing shares, and meme stocks. This speculation is reminiscent of the 2021 meme stock/SPAC market and represents later cycle behavior. |
Speculation Momentum Crypto Meme | |
| 2025 Q1 |
Trade PolicyTrump's tariff announcements created extreme uncertainty with 47% tariffs on all trading partners including Madagascar. Manager views broad tariffs as economically destructive, citing comparative advantage principles. Trade war dynamics are driving significant market volatility and creating difficult investment environment. |
Tariffs Trade War Economic Policy Uncertainty Volatility |
Small CapsSmall cap stocks experiencing severe bear market with Russell 2000 down 25% since November. Manager notes small caps are more vulnerable during uncertainty periods but historically recover. Portfolio positioned in quality small caps with competitive advantages and strong balance sheets. |
Russell 2000 Bear Market Volatility Quality Valuations | |
ValuationsRussell 2000 trading at 13.4x forward P/E, approaching trough levels seen only during Great Financial Crisis and 2022. Manager believes market is pricing in earnings cuts and approaching maximum pessimism. Historical analysis suggests attractive risk/reward at current levels. |
P/E Multiples Trough Valuations Earnings Risk Reward Historical Analysis | |
| 2024 Q4 |
QualityManager emphasizes focus on quality businesses with strong fundamentals, contrasting with market rotation into speculative assets. Quality stocks significantly lagged during Q4 as investors favored high beta and non-earning companies. The strategy maintains discipline in owning quality businesses at appropriate multiples. |
Quality Fundamentals Earnings ROE Discipline |
Risk AppetiteQ4 saw broad rotation into highly speculative assets with bitcoin returning 45% as poster child for increased risk appetite. Highest beta stocks generated best returns while profitable stocks lagged significantly. Market showed amnesia repeating mistakes from 2021 speculative bubble. |
Risk Appetite Speculation Beta Bubble Rotation | |
CybersecurityClimb Global's outperformance driven by cybersecurity focus as one of two healthy areas of IT spending. Company's specialty IT distribution benefits from continued strength in cybersecurity spending alongside data center investments. |
Cybersecurity IT Spending Distribution Growth | |
Data CentersData center focus identified as one of two healthy areas of IT spending driving Climb Global's organic growth. Company's specialty distribution model benefits from continued investment in data center infrastructure. |
Data Centers Infrastructure IT Growth | |
| 2024 Q3 |
Small CapsManager discusses small cap outperformance potential following Fed rate cuts, noting historical patterns where small caps benefit from easing cycles. Cheap valuations and faster earnings growth outlook for 2025 support continued outperformance opportunity. |
Small Cap Valuations Rate Cuts Outperformance Russell 2000 |
Commercial Real EstateExtensive analysis of Altus Group's position in commercial real estate software and valuation services. Discussion of frozen transaction markets due to wide bid-ask spreads from higher rates, with expected recovery as conditions normalize. |
CRE Valuation Transaction Volumes ARGUS Property Tax | |
BuybacksDetailed discussion of share repurchase programs as value creation mechanism, particularly highlighting Medpace's aggressive buyback strategy during cyclical downturns and Altus Group's significant cash position enabling potential 30% share count reduction. |
Share Repurchases Capital Allocation Cash Deployment Value Creation | |
BiotechnologyAnalysis of biotech funding cycles impacting Medpace's CRO business, noting cyclical pressures from reduced biotech funding while emphasizing secular growth opportunity from increased drug development by smaller biotechs. |
Biotech Funding CRO Clinical Trials Drug Development | |
CybersecurityClimb Global benefited from ongoing demand for cybersecurity software products distributed through their platform, contributing to strong Q2 results and positive earnings revisions. |
Cybersecurity Software Distribution Software Products | |
| 2024 Q2 |
SemiconductorsThe manager discusses semiconductor manufacturing complexity and the need for advanced yield optimization software. PDF Solutions is positioned to benefit from increasing complexity at advanced nodes and the emergence of new foundries investing at the leading edge. |
Yield optimization Manufacturing Foundries Advanced nodes EDA |
Small CapsThe manager expresses growing conviction in small cap opportunities, noting they continue to trade at historically wide discounts to large caps. High ROE small cap businesses are seen as attractive given their valuation discount and earnings growth potential. |
Valuation discount ROE Earnings growth Outperformance Russell Mid Cap | |
AIThe AI theme continues to dominate individual company performance and disproportionately benefits larger companies with scale. The market has concluded that larger companies are better positioned to capitalize on AI opportunities. |
Large cap bias Scale advantages Performance concentration Technology adoption | |
Medical DevicesThe portfolio includes exposure to medical device companies like TransMedics and Inspire Medical. TransMedics benefits from revolutionary organ care systems while Inspire faces temporary headwinds but has long-term growth potential in sleep apnea treatment. |
Organ care Sleep apnea FDA approval Utilization TAM | |
| 2024 Q1 |
CybersecurityCLMB is a specialty IT distributor focused on cybersecurity and data center software with deep expertise in the products it distributes. The cybersecurity focus supports faster growth rates than broader IT spend, with demand backdrop for cybersecurity broadly supporting organic revenue growth. QLYS remains a critical solution within the cybersecurity ecosystem despite Microsoft partnership ending. |
Software Distribution Vulnerability Management IT Security Channel Partners Threat Management |
Data CentersCLMB differentiates itself through focus on cybersecurity and data center software distribution. The company serves as an outsourced sales force for partners given their expertise with data center products they distribute. Data center focus combined with cybersecurity supports premium valuations and faster growth. |
Software Distribution Infrastructure Cloud Computing Enterprise Solutions IT Hardware | |
AIMarket performance during Q1 was characterized by three themes that carried over from Q4, with AI being the third major theme driving market returns. The letter notes AI, AI, AI as one of the key market drivers during the quarter. |
Technology Innovation Market Performance Growth Drivers Artificial Intelligence | |
| 2023 Q4 |
Small CapsManager believes small cap stocks are poised to lead the market over the next five years, trading at the cheapest absolute and relative multiple to large caps in decades. Profitable small cap stocks are trading at the cheapest relative multiple to large caps since 2000, with historical precedent showing 55% cumulative outperformance over 6 years from similar starting points. |
Small Cap Value Outperformance Multiples Growth |
BeautyExtensive discussion of Inter Parfums as a fragrance licensing specialist. The fragrance market requires scale and expertise better outsourced to third parties, with IPAR leveraging internal expertise across development, manufacturing, marketing and distribution. Company targets established brands with under-managed or nascent fragrance potential. |
Fragrance Licensing Beauty Brands Distribution | |
| 2023 Q3 |
GLP1Weight loss drugs created significant market fears during Q3, particularly impacting healthcare stocks. The manager believes concerns about GLP-1 drugs reducing obesity and affecting medical procedures are overblown, especially for companies like Inspire Medical which could actually benefit from patients reducing BMI into treatable ranges. |
Weight Loss Obesity Sleep Apnea Healthcare Medical Devices |
Life Science ToolsAcademic and government end markets remain stable and healthy according to industry peers, providing support for life science tools companies. The manager emphasizes that Abcam has minimal exposure to the bioprocessing weakness affecting other life science companies. |
Academic Research Government Funding Bioprocessing Research Tools Laboratory | |
CybersecurityDespite broad IT budget pressure, cybersecurity spending continues to be a priority for companies as global cyberattacks proliferate. This supported Qualys performance during the quarter as the top contributor to returns. |
IT Security Cyber Attacks Software Enterprise Security Cloud Security |
| 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 |
| Jul 10, 2025 | Fund Letters | Headwaters Capital | TECH | Bio-Techne Corporation | Health Care | Life Sciences Tools & Services | Bull | NASDAQ | Academic Research, Biotech, Cell Gene Therapy, Consumables, contrarian, Life Sciences Tools, M&A Target, Reagents, recurring revenue, Value | Login |
| Apr 8, 2025 | Fund Letters | Headwaters Capital | BRO | Brown and Brown | Financials | Insurance Brokers | Neutral | NYSE | EBITDA multiple, Flight to Safety, Insurance, M&A, P&C Brokerage, Pricing power, valuation | Login |
| Apr 8, 2025 | Fund Letters | Headwaters Capital | TRNS | Transcat | Industrials | Research & Consulting Services | Bull | NASDAQ | Calibration Services, FDA Regulated, life sciences, M&A Opportunities, Mission-Critical, Outsourcing Trend, recurring revenue | Login |
| Apr 8, 2025 | Fund Letters | Headwaters Capital | CBZ | CBIZ | Industrials | Research & Consulting Services | Bull | NYSE | accounting services, defensive business, Free Cash Flow, High retention, M&A strategy, SMB Focus, Tax Services | Login |
| Jan 14, 2025 | Fund Letters | Headwaters Capital | CLMB | Climb Global Solutions | Information Technology | Technology Distributors | Bull | NASDAQ | Bull, cybersecurity, data center, IT Distributor, organic growth, Specialty Distribution, technology | Login |
| Jan 14, 2025 | Fund Letters | Headwaters Capital | TMDX | TransMedics Group | Health Care | Health Care Equipment | Bull | NASDAQ | Bull, competitive moat, FDA approval, Healthcare Equipment, Logistics Network, market dominance, medical technology, Organ Transplant | Login |
| Oct 7, 2024 | Fund Letters | Headwaters Capital | ASGTF | Altus Group | Real Estate | Real Estate Services | Bull | Toronto Stock Exchange | Canada, commercial real estate, Data Analytics, divestiture, M&A Target, margin expansion, Real Estate Software, SaaS, turnaround, Valuation Services | Login |
| Apr 5, 2024 | Fund Letters | Headwaters Capital | CLMB | Climb Global Solutions | Information Technology | Technology Distributors | Bull | NASDAQ | Capital-light, cybersecurity, data center, growth, IT distribution, M&A, ROIC, software distribution, Specialty Distribution, Technology Distributor | Login |
| Jan 12, 2024 | Fund Letters | Headwaters Capital | IPAR | Inter Parfums | Consumer Discretionary | Personal Products | Bull | NASDAQ | brand partnerships, Capital-light, Consumer Discretionary, founder-led, Fragrance, growth, high-ROIC, insider ownership, Licensing, Personal Products, small-cap, Specialty Manufacturing | Login |
| Oct 26, 2023 | Fund Letters | Headwaters Capital | QLYS | Qualys Inc | Software & Services | Systems Software | Bull | NASDAQ | cloud solutions, cybersecurity, Free Cash Flow, IT Security, M&A Target, SaaS, Software | Login |
| Oct 26, 2023 | Fund Letters | Headwaters Capital | ASIC|CWAN|INSP|KRMN|KTOS|MAC|MEG|RH|WYNN | Inspire Medical Systems Inc | Health Care Equipment & Services | Health Care Equipment | Bull | NYSE | CPAP Alternative, GLP-1, healthcare, Medical Device, Neurostimulation, Obesity, sleep apnea | Login |
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