WHITEGATE INVESTMENT COUNSELORS, INC.

Item 1 Cover Page Part 2A of Form ADV: Firm Brochure 143 North Main Street, Suite 203 Concord, NH 03301 Telephone: 603-228-5471 Email: pwolfe@whitegateinvest.com Website: www.whitegateinvest.com March 28, 2025 This brochure provides information about the qualifications and business practices of Whitegate Investment Counselors, Inc. If you have any questions about the contents of this brochure, please contact us at 603-228-5471 or pwolfe@whitegateinvest.com. Whitegate Investment Counselors, Inc. is a registered investment adviser. Use of the term “registered investment adviser” does not imply any level of skill or training. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Whitegate Investment Counselors, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 1  Item 2 Material Changes This item summarizes only material changes, including new or revised information or disclosures, to this Firm Brochure since our last update dated June 14, 2024. Since that date, there have been no material changes made to this Firm Brochure. Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 2  Item 3 Table of Contents Page Item 1 Cover Page ..........................................................................................................................................1 Item 2 Material Changes .................................................................................................................................2 Item 3 Table of Contents ..................................................................................................................................3 Item 4 Advisory Business .................................................................................................................................4 Item 5 Fees and Compensation .......................................................................................................................6 Item 6 Performance-Based Fees and Side-By-Side Management ..................................................................8 Item 7 Types of Clients ....................................................................................................................................8 Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss ............................................................8 Item 9 Disciplinary Information ...................................................................................................................... 10 Item 10 Other Financial Industry Activities and Affiliations ............................................................................ 10 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................... 10 Item 12 Brokerage Practices .......................................................................................................................... 11 Item 13 Review of Accounts .......................................................................................................................... 12 Item 14 Client Referrals and Other Compensation ........................................................................................ 13 Item 15 Custody ............................................................................................................................................. 13 Item 16 Investment Discretion ....................................................................................................................... 14 Item 17 Voting Client Securities ..................................................................................................................... 14 Item 18 Financial Information ......................................................................................................................... 14 Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 3  Item 4 Advisory Business Firm Structure Whitegate Investment Counselors, Inc. (“WICI,” “Whitegate,” “firm”) is an SEC-registered investment adviser offering portfolio management services to individuals and businesses. WICI is wholly owned by Paulette W. Wolfe. Investment Services WICI advises clients regarding the investment of client funds based on the client's individual needs. Through personal discussions (including, but not limited to, one or more of the following communication methods: letters, e-mails, telephone conferences, in-person meetings, and forms that we request clients to complete to help us gather data about their family and financial situations) in which goals and objectives based on a client's particular circumstances are established, we develop an asset allocation and investment recommendations for each client. We then create and manage a portfolio based on that asset allocation. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, return expectations, expected deposit/withdrawal patterns, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, family composition, and background. Account supervision is guided by the client's stated risk tolerance, return expectations, expected deposit and withdrawal patterns, and tax considerations. WICI manages advisory accounts on a discretionary or non-discretionary basis, although most accounts are managed on a discretionary basis. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following types of securities:  Exchange-listed securities  Securities traded over-the-counter  American Depositary Receipts of foreign issuers  Warrants  Commercial Paper  Corporate debt securities  Certificates of deposit  Municipal Bonds  Mutual fund shares  United States governmental securities  Options contracts on securities  Interests in partnerships investing in real estate If warranted, we may also recommend the services of other investment advisers. Holding periods may vary considerably depending on market conditions. After-tax returns are considered for taxable accounts. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Participant Directed 401(k) Profit-Sharing Plan Services WICI offers investment advisory services to plan sponsors of participant directed 401(k) profit-sharing plans. Such services include selection of mutual funds to be offered to participants, information regarding the Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 4  benefits of participation in the plan, historical information on returns of various asset classes, asset allocation information, generic information on different types of mutual funds and specific information on risk levels, track records and management of the mutual funds selected for the plan. IRA Rollover Recommendations WICI may recommend clients roll assets from their employer’s retirement plan, such as a 401(k), 457, or 403(b) plan (Plan Account), to an individual retirement account, such as a Traditional IRA, Roth IRA, SIMPLE IRA, or SEP IRA (IRA) that we will advise on the client’s behalf. We may also recommend rollovers from IRA’s to Plan accounts, from Plan Accounts to Plan Accounts, and from IRA’s to IRA’s. If a client elects to roll the assets to an IRA that is subject to our advisement, we will charge the client an asset- based fee as set forth in the advisory agreement the client executed with WICI. This creates a potential conflict of interest because it creates a financial incentive for our firm to recommend that the client rollover over their Plan Account to an IRA managed by WICI. This creates additional receipt of fee-based compensation. Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if clients do complete the rollover, clients are under no obligation to have the assets in an IRA advised by WICI. Due to the potential conflict of interest, when WICI makes rollover recommendations, we operate under a special rule that requires us to act in our clients’ best interest and not put our interests ahead of our clients’. Under this special rule’s provisions, we must:  Meet a professional standard of care when making investment recommendations (give prudent advice).  Never put our financial interests ahead of our clients’ when making investment recommendations (give loyal advice).  Avoid misleading statements about conflicts of interest, fees, and investments.  Follow policies and procedures designed to ensure that we give advice that is in our clients’ best interests.  Charge no more than a reasonable fee for our services.  Give clients basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plans. Also, current employees may sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover of an IRA and to the extent the following options are available, a client should consider the cost and benefits. Former employees typically have four options: 1. Leaving the funds in their employer’s (former employer’s) plan. 2. Moving the funds to a new employer’s retirement plan 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA Rollover account. Each of the above options has advantages and disadvantages. Before making a change, we recommend clients speak with their tax preparer and a representative of their former employer’s plan. Consulting Services Clients can also receive investment advice on a more focused basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 5  Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. Tailored Relationships WICI tailors investment management services to each client’s individual needs, goals, tolerance for risk, and objectives. We will consider accepting restrictions on investment in certain securities, or types of securities or industry sectors on a best-efforts basis for a client if we feel the restrictions are reasonable and can be executed without compromising our ability to meet the client’s investment objectives. These restrictions can be discussed with portfolio managers at any time. Fiduciary Statement As a registered investment advisor subject to the Investment Advisers Act of 1940, WICI has a fiduciary responsibility to our clients. We are required to act in our clients’ best interests and put their interests ahead of our own. We are prohibited from engaging in any activity that conflicts with the interests of the client. Assets Under Management As of 12/31/2024, Whitegate Investment Counselors, Inc. actively manages $545,639,585 in clients assets, $535,393,403 of which is managed on a discretionary basis and $10,246,182 of which is managed on a non- discretionary basis. Item 5 Fees and Compensation Investment Supervisory Services and Individual Portfolio Management Fees WICI is normally compensated through fees assessed on the assets we are assigned to manage. WICI’s standard fee schedule is outlined below: Size (Value) of Account First $1,000,000 Annual Fee Rate 1.25% Next $2,000,000 1.10% Next $2,000,000 1.00% Above $5,000,000 0.75% Either party may terminate the contract at any time without cause upon 30 days written notice without a termination fee. Limited Negotiability of Advisory Fees WICI retains the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances, and needs will be considered when determining the fee schedule. These include the complexity of the client’s financial situation, assets to be placed under management, anticipated future additional assets, related accounts, portfolio style, account composition, concentrated low-cost positions, and reports, among other factors. The specific annual fee schedule will be identified in the contract between the adviser and each client. Discounts, not generally available to our advisory clients, may be offered to family members and friends of associated persons of our firm. As a result, clients could pay different fees. We may group certain related client accounts to determine the annualized fee. Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 6  Fees are billed quarterly in advance and may either be deducted directly from client accounts or billed directly to the client. Other Compensation Employees of WICI may not accept compensation for the sale of any security or investment product. Participant Directed 401(k) Profit Sharing Plan Services Fees Fees, generally a percentage of plan assets, are determined on a case-by-case basis and are based on the (i) size of the plan, (ii) number of investment options desired, (iii) frequency and extent of reporting desired and various other criteria but are generally lower than the Basic Fee Schedule for full investment advisory services. Consulting Services Fees WICI may, on occasion, perform services, including preparation of special reports for certain clients on investments presented to or managed for those clients by others and for which those clients specifically seek WICI’s advice, such as tax-deferred annuities and limited partnership or private placement investments. WICI may prepare such reports as part of its investment supervisory services or may charge an hourly fee at a billing rate ranging from $300 to $500 per hour. Time for Associates and Other Officers is billed at $150 to $300 per hour. The client will be billed in arrears based on actual hours accrued. General Information Termination of the Advisory Relationship: A client agreement may be canceled at any time by either party for any reason upon receipt of 30 days written notice. As disclosed above, fees for investment advisory and portfolio management services are paid in advance of services provided. Upon termination of any account, any fees so billed and paid in advance are refunded pro-rata with no termination fee. Mutual Fund and ETF Fees: All fees paid to WICI for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. A client may pay an initial or deferred sales charge if the fund also imposes sales charges. Generally, such funds are available to WICI clients at Net Asset Value without sales charges or sales loads. However, some mutual funds may charge redemption fees to restrict frequent trading. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker-dealers, including, but not limited to, any transaction charges imposed by a broker-dealer with which an independent investment manager affects transactions for the client's account(s). For additional information, please refer to the "Brokerage Practices" section (Item 12) of this Form ADV. ERISA Accounts: WICI neither seeks, receives, nor pays to or from brokers or anyone else any commissions, sales loads, or 12(b)1 fees of any type. Advisory Fees for Similar Services: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 7  Limited Prepayment of Fees: We do not require or solicit payment of fees in excess of $500 more than six months before services are rendered. Such prepayments will be promptly returned to the client. Item 6 Performance-Based Fees and Side-By-Side Management WICI does not accept performance-based fee arrangements. Item 7 Types of Clients WICI currently provides advisory services to individuals and high-net-worth individuals, pension and profit- sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Banks, thrift institutions, and investment companies could also be clients in the future. WICI seeks a mutually beneficial relationship with clients. Our minimum assignment is $1,000,000 in managed assets or $7,500 in annual fees. Accounts may be combined to meet the minimum asset requirement, and the fee minimum may be waived. The acceptance or retention of a client below the minimum level will be determined by several factors, including, but not limited to, the client’s total assets potentially available for management, the client’s choice of custodian, the client’s expected level of service, and pre-existing account relationships. Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss Methods of analysis Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. WICI uses the following methods of analysis in formulating our investment advice and/or managing client assets: Asset Allocation: We identify an appropriate ratio of equity securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. Risk cannot be eliminated, however. If return characteristics and correlations among asset class returns are inconsistent through time, these ratios may not perform as expected. In addition, a broadly diversified portfolio may not participate in sharp increases in a particular security, industry, or market sector. Also, the ratio of equity securities, fixed income, and cash will change over time due to position and market movements and, if not adjusted, will no longer be appropriate for the client’s goals. Our research process is intended to identify securities that offer a reasonable opportunity for long-term positive returns, but there is no guarantee that returns will not be negative. Diversification among individual holdings can reduce risk, but clients should be prepared to experience losses. Investing in securities involves risk of loss that clients should be prepared to bear. WICI does not represent or guarantee that our services or methods can or will predict future results or insulate clients from losses due to market corrections or declines. Past performance is not indicative of future performance. Mutual Fund and/or ETF Analysis: Major criteria that should be considered include but aren’t limited to the mutual fund’s track record versus its benchmark, management, and management “bench strength”, management ownership of the fund, expenses (loads, redemption fees, and management, distribution, Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 8  administrative and trading fees), compliance history, style drift, MPT statistics (standard deviation, R-squared and other fund statistics), asset base, tax efficiency and fund turnover. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Investment Strategies WICI uses the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases: We purchase securities with the idea of holding them in the client's account for a year or longer. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Short-term purchases: When utilizing this strategy, we purchase securities with the idea of selling them within a relatively short time (typically a year or less). WICI uses this strategy generally when a client has informed us that they may be making withdrawals from their account(s). Margin transactions: Generally, WICI does not make margin transactions and can only make them in client accounts that have a margin feature on their account(s). However, there are circumstances under which we may recommend margin be used as a bridge loan for a limited period. Some clients may choose to use margin on a long-term basis. Options: Infrequently, and depending on client and market circumstances, WICI may use options strategies including hedges, covered calls, and spreads. Risk of Loss: Securities investments are not guaranteed, and you may lose money on your investments. We ask that clients work with us to help us understand their tolerance for risk. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. Although we manage assets in a manner consistent with our clients’ investment objectives and risk tolerances, there is no guarantee that a client’s financial goals and objectives will be met. Investors face the following risks:  Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, a bond’s price may fall as interest rates rise due to yields on existing bonds becoming less attractive. Thus, the market value of an investment may be reduced when interest rates rise.   Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. Inflation Risk: when any type of inflation is present, a dollar next year will not buy as much next year, because purchasing power is eroding at the rate of inflation. Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 9   Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Item 9 Disciplinary Information None. Item 10 Other Financial Industry Activities and Affiliations Neither the firm nor any of its employees are registered as a broker-dealer. There are no registration applications pending. Neither the firm nor any of its employees are registered as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of any of the foregoing entities. There are no registration applications pending. Neither the firm nor any of its employees have relationships or arrangements that are material to our advisory business or to our clients with any of the following entities: Investment company or other pooled investment vehicle Insurance company or agency  Broker-dealer, municipal securities dealer, or government securities dealer or broker   Other investment adviser or financial planner  Futures commission merchant, commodity pool operator, or commodity trading advisor  Banking or thrift institution   Pension consultant  Real estate broker or dealer  Sponsor or syndicator of limited partnerships On occasion, a new or current client of WICI may request that we provide them with a list of potential tax preparers and/or attorneys. We provide this only as a courtesy to our clients and have no referral fee arrangements for these recommendations. On occasion, one or more of the tax preparers and/or attorneys that WICI may have mutual clients or do business with may recommend WICI to accounting clients in need of advisory services. Conversely, WICI may recommend one or more of those tax preparers and/or attorneys to advisory clients in need of accounting and/or legal services. Accounting and/or legal services provided by such firms are separate and distinct from WICI and our advisory services and are provided for by separate and typical compensation. There are no referral fee arrangements between our firms for these recommendations. No WICI client is obligated to use these firms for any accounting and/or legal services and conversely, no accounting or legal client is obligated to use the advisory services provided by WICI. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading WICI has adopted a Code of Ethics (“Code”) designed to comply with Rule 204A-1 under the Investment Advisers Act of 1940 (“Advisers Act”). The Code is based upon the principal that WICI and its employees owe a fiduciary duty to WICI’s clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 10  of their position with the firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. The Code establishes rules for all employees of WICI and is designed to, among other things, govern personal securities trading activities in the accounts of employees. The personal trading activities of WICI’s employees are monitored by the firm to ensure employee interests are not placed ahead of the interests of WICI’s clients. If an employee of WICI would like to invest in the same securities (or related securities, e.g. warrants, options or futures) that WICI recommends to clients, we will aggregate clients’ trades with the employee’s trades so that all trades are executed at the same time and at the same average price. In the instances where there is a partial fill of a particular batched order, we will allocate all purchases pro-rata, with each client account paying the average price. If it is not possible to aggregate the employee’s transaction with those of our clients, the clients’ transactions will be placed ahead of the employee’s. WICI employees must obtain prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. You may request a copy of our Code of Ethics by email sent to pwolfe@whitegateinvest.com or by calling us at 603-228-5471. Item 12 Brokerage Practices Custody and Brokerage WICI recommends that clients establish brokerage accounts with the Schwab Institutional division of Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. WICI recommends Schwab based upon (i) its ability to purchase, hold and sell a variety of investments, including no-load mutual funds and various types of bonds and stocks in one consolidated account, (ii) tax reporting capability, and (iii) its financial strength and reputation of as well as other services it provides to clients and to WICI. WICI is independently owned and operated and not affiliated with Schwab. While WICI recommends the custodial and brokerage services of Schwab, WICI has the ability to manage client assets held with other qualified custodians. Schwab provides WICI with access to its institutional trading and custody services, which may not be available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor’s clients’ assets is maintained in accounts at Schwab and is not otherwise contingent upon an advisor committing to any specific amount of business (assets in custody or trading). Schwab’s services include brokerage, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset- based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to our firm other products and services that benefit WICI but may not directly benefit our clients' accounts. Many of these products and services may be used to service all or some substantial number of our client accounts, including accounts not maintained at Schwab. Schwab's products and services that assist us in managing and administering our clients' accounts include software and other technology that provide access to client account data (such as trade confirmations and account statements): i. facilitate trade execution and allocate aggregated trade orders for multiple client accounts; ii. provide research, pricing and other market data; Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 11  iii. facilitate payment of our fees from clients' accounts; and iv. assist with back-office functions, recordkeeping, and client reporting. Schwab also offers other services intended to help us manage and further develop our business enterprise which may include: i. compliance, legal and business consulting; ii. publications and conferences on practice management and business succession; and iii. access to employee benefits providers, human capital consultants and insurance providers. Schwab may make available, arrange and/or pay third-party vendors for the types of services rendered to WICI. Schwab may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to our firm. Schwab may also provide other benefits such as educational events or occasional business entertainment of our personnel. In evaluating whether to recommend that clients to custody their assets at Schwab, we may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors we consider and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Trade Aggregation WICI will arrange block trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as no client’s transaction costs are greater than they would have been if the trade was not blocked with other clients. Block trading may allow us to execute equity trades in a timelier, more equitable manner, at an average share price. Item 13 Review of Accounts Investment Supervisory Services and Individual Portfolio Management Reviews: Accounts are reviewed at least quarterly. More frequent reviews may be triggered by firm-wide decisions on asset class shifts or individual securities, or by material changes in the market, political, or economic environment as well as changes in the client's individual circumstances. Account reviews are conducted by an employee with the Series 65 Investment Adviser Representative designation and a U-4 on file, as well as professional qualifications such as a college degree, the CFA or the CFP designation, or the equivalent experience in finance and investments. Currently, the following perform these duties: Paulette W. Wolfe, Principal and Portfolio Manager Colby W. Wolfe, Portfolio Manager and Research Analyst Sarah A. Burdette, Vice President of Client Service Reports: In addition to statements and trade confirmations received directly from their custodians, clients may also receive a variety of reports from WICI. These include periodic thought memos and individual portfolio reports. The portfolio reporting schedule is quarterly or annually depending upon the agreed-upon schedule. Consulting Services Reviews: While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Consulting Services clients unless otherwise Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 12  contracted for. Such reviews will be conducted at the client’s request by an employee with professional qualifications such as a college degree, the CFA or the CFP designation, or the equivalent experience in finance and investments. Currently, the following perform these duties: Paulette W. Wolfe, Principal and Portfolio Manager Colby W. Wolfe, Portfolio Manager and Research Analyst Sarah A. Burdette, Vice President of Client Service Reports: Consulting Services clients will not typically receive reports due to the nature of the service. Item 14 Client Referrals and Other Compensation It is WICI’s policy to not engage solicitors or to pay related or non-related persons for referring potential clients to our firm. WICI does not accept nor allow our related persons to accept or solicit any form of compensation or benefit, direct or indirect, monetary, or otherwise, including cash, rebates, sales awards or other prizes or gifts (other than items sent to employees on an unsolicited basis with a value less than $50) from a non-client in conjunction with the advisory services we provide to our clients. Item 15 Custody WICI does not offer custody services. Client assets must be maintained in an account at a “qualified custodian,” generally a broker dealer or a bank. Each client may select their own qualified custodian. If there is no present relationship, WICI may suggest one or more alternatives. We are independently owned and not affiliated with any of the custodians we may suggest. These custodians will hold client assets in a brokerage account and buy or sell securities when we instruct them to do so. While we may recommend custodians, each client will decide which custodian to use and will enter into an account agreement directly with them. We may assist in opening the account, but we cannot do this for clients. The custodian will send statements directly to clients. WICI urges clients to review these regularly and to compare them to the reports clients will receive from WICI. We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm may directly deduct advisory fees from client accounts. As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review the statements they receive directly from the custodian to verify the accuracy of the calculation. Clients should also review their custodian statements and trade confirmations for accuracy of deposits, withdrawals, income activity, trades and period end security and cash positions and valuations, among other things. Clients should compare the market values, deposits and withdrawals and fees, among other things shown on the reports they receive from WICI with the statements they receive from the custodian. Clients should contact WICI directly if they believe that there may be an error in their statement or report. Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 13  Item 16 Investment Discretion The custodian selected by the client will be identified on the contract between WICI and the client. WICI generally obtains a limited trading authorization from a client that allows WICI to place purchase and sale instructions on a discretionary basis on clients’ behalf. This limited trading authorization is granted on the contract between the advisor and the client as well as the custodian/broker-dealer account forms that the client must complete prior to opening an account at the custodian. After execution of a contract, no additional prior authorization is required from the client before WICI executes transactions on his behalf. Clients may also choose to designate WICI with the authority to effect certain transactions in their accounts. Authority may include the ability for WICI to transfer funds electronically between client investment accounts, client investment accounts and client bank accounts, or in some limited cases, disbursement of funds from client accounts to a third party – usually a tax authority. This authority is designated to WICI by the client in writing to the custodian and may be changed or withdrawn by the client by written notice to the custodian at any time. WICI does not have the authority to change payee or address information for any disbursements. WICI encourages clients to carefully review any transaction notices or statements they receive from custodians, as well as all reports they receive from WICI and to notify the custodian and WICI if they have any questions or concerns. Item 17 Voting Client Securities To avoid any potential conflict of interest, WICI recommends clients vote their own proxies on individual securities. WICI does not accept authority to vote proxies on client securities. Because WICI does not specifically accept authority on proxies, clients will maintain exclusive responsibility for: (i) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (ii) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. WICI does not offer any consulting assistance regarding proxy issues to clients. Item 18 Financial Information WICI does not require or solicit payment of fees in excess of $500 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement in our Form ADV Part 2. WICI has no financial circumstances likely to impair our ability to meet our contractual obligations. WICI has not been the subject of a bankruptcy petition at any time during the past ten years. Whitegate Investment Counselors, Inc. Form ADV, Part 2A As of 03/28/2025 Page: 14