WILLOW CREEK WEALTH MANAGEMENT, INC.

ITEM 1 – COVER PAGE FORM ADV PART 2 – DISCLOSURE BROCHURE Willow Creek Wealth Management, Inc.1 825 Highway 116 North, Suite 5 Sebastopol, CA 95472 www.willowcreekwealth.com Sonoma 707.829.1146 | Marin 415.925.1388 | Toll Free 800.696.8096 This Brochure provides information about the qualifications and business practices of Willow Creek Wealth Management, Inc. (the “Advisor” or “Company”). If you have any questions about the contents of this Brochure, please contact the Advisor at one of the telephone numbers listed below. The information in this Brochure has not been approved by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Willow Creek Wealth Management, Inc. is registered as an investment advisor with the U.S. Securities and Exchange Commission. Registration of an Investment Advisor does not imply any level of skill or training. An Investment Advisor's oral and written communications will give you information about whether to hire or retain an advisor. information about the Advisor is available on Additional the SEC’s website at www.adviserinfo.sec.gov. You can search this site by using a unique identifying number, known as a CRD number. The CRD number for Willow Creek Wealth Management, Inc. is 109240.  March 3, 2025 ITEM 2 – MATERIAL CHANGES The following material changes have occurred since March 22, 2024, the date on which we last made our ADV Disclosure Brochure annual offer. USPS Required Address Change – The USPS has updated the format of our mailing address. 'Gravenstein Highway North' is now 'Highway 116 North.' Note that we have not moved—only the way our address is written for mailing purposes has changed. Our official new address is 825 Highway 116 North, Suite 5, Sebastopol, CA 95472. 2  March 3, 2025 ITEM 3 – TABLE OF CONTENTS FORM ADV PART 2 – DISCLOSURE BROCHURE .................................................................................................... 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 ......................................................................................................................................... 8 ITEM 7 – TYPES OF CLIENTS ......................................................................................................................................................... 9 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....................................................................... 9 ITEM 9 – DISCIPLINARY INFORMATION ....................................................................................................................................... 9 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS..................................................................................... 9 ITEM 11 – CODE OF ETHICS ........................................................................................................................................................ 10 ITEM 12 – BROKERAGE PRACTICES ............................................................................................................................................ 11 ITEM 13 – REVIEW OF ACCOUNTS ............................................................................................................................................. 13 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .................................................................................................... 14 ITEM 15 – CUSTODY ................................................................................................................................................................... 14 ITEM 16 – INVESTMENT DISCRETION ........................................................................................................................................ 15 ITEM 17 – VOTING CLIENT SECURITIES ...................................................................................................................................... 15 ITEM 18 – FINANCIAL INFORMATION ........................................................................................................................................ 15 BROCHURE SUPPLEMENT(S) – ADVISOR BIOS .............................................................................................................................. 15 HEATHER C. BELLI, CFP®, CAP® - DISCLOSURE BROCHURE ................................................................................ 16 BRUCE J. DZIEZA, CFP® - DISCLOSURE BROCHURE ............................................................................................. 18 JASON R. GITTINS, CFP® - DISCLOSURE BROCHURE ........................................................................................... 20 MARK F. KEATING, CFP®, AEP® - DISCLOSURE BROCHURE ................................................................................ 22 DAVID D. HOMAN, M.S., CFP® - DISCLOSURE BROCHURE ................................................................................. 24 DAVID B. LAWRENCE, CFP® - DISCLOSURE BROCHURE ..................................................................................... 27 JACOB WEBER, CFP® – DISCLOSURE BROCHURE ............................................................................................... 30 RAWSON GULICK, CFP® – DISCLOSURE BROCHURE .......................................................................................... 32 ERIC KEATING, CFP® CHSNC® – DISCLOSURE BROCHURE .................................................................................. 35 ENDNOTES ................................................................................................................................................................................. 38 3  March 3, 2025 ITEM 4 – ADVISORY BUSINESS A. Description of the Company Willow Creek Wealth Management, Inc. (formerly Willow Creek Financial Services, Inc.) is a California corporation. The firm was founded in 1984 by Bruce J. Dzieza and incorporated in 1999. Today, Mr. Dzieza serves as the firm’s Chairman of the Board and remains a Partner. The firm is proud to be employee owned. B. Types of Investment and Advisory Service’s Offered Asset Management Asset management is an integral component of personalized wealth management and the financial planning process. Willow Creek Wealth Management, Inc. designs and manages portfolios utilizing a disciplined long-term strategy based on sound fundamentals proven to influence investment success. We provide investment advisory services to a variety of clientele, such as individuals, families, businesses, pension and profit-sharing plans, trusts, and charitable organizations. At the outset of each client relationship, our professionals meet with each client and create an investment policy statement (“IPS”) for investing assets and for monitoring and reviewing them on an ongoing basis. The IPS contains a “model” portfolio based upon your stated investment objectives, risk tolerance and financial circumstances. The model portfolio serves as a blueprint for allocating assets among asset classes. Realistic and measurable goals are set and the objectives to reach those goals are defined. As goals and objectives change over time, recommendations are made and implemented to reflect any new information. The foundation of Willow Creek’s investment management philosophy is based on rigorous academic research and financial science. Studies show that a properly diversified selection of uncorrelated asset classes, managed with a disciplined rebalancing methodology, may be the best approach to provide investors with the highest probability of attaining their financial goals. A number of empirical studies have also proven asset allocation (or asset class selection) – choice of riskier assets (e.g., stocks) vs. less risky assets (e.g., bonds or cash equivalents), for instance – is what matters most in determining the risk and return of a portfolio. A guiding principle of the Willow Creek discipline is keeping investment expenses transparent, straightforward, competitive, and low, which proportionately increases net returns. We maintain low portfolio management fees and utilize low-cost, institutional investment vehicles in client portfolios. 4  March 3, 2025 Once established, we will not change the asset allocation risk level within your model portfolio without consulting you and obtaining your prior approval. Our portfolio managers do have discretion to change the individual securities within established asset classes when they conclude that different holdings would better serve your goals and objectives. WCWM 401(k) Plan Investment Advisory Service Our 401(k) Investment Advisory Service provides pension management services to group 401(k) plans. These services are established in coordination with each plan’s administrator. We create an investment policy statement (“IPS”) for each plan which will include a selection of ‘target’ model portfolios, each designed with different financial goals and risk tolerances. In some cases, a selection of individual funds will also be offered. The plan’s trustees approve the IPS on behalf of the plan. The selection of an appropriate model portfolio will be made by each individual plan participant and should be based upon each plan participant's investment objectives, risk tolerance, and financial circumstances. Financial Planning Our financial planning professionals provide genuine expertise combined with a uniquely personal approach to help you make the most of your resources. When the power of our financial planning service is combined with our asset management service, we call it “wealth management.” Our financial planning process helps us identify your goals and resources and then establish steps to harness those resources in pursuit of your goals. Your financial plan may cover cash flow and tax planning, risk management, retirement and other goal planning, investment planning, and estate planning. The initial financial plan is developed for you during the first year of the engagement. Thereafter, the financial plan may be reviewed regularly to help ensure that you stay on track. Depending on your circumstances, the financial plan may include, but would not be limited to, a net worth statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing asset allocation recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations. General investment advice and asset allocation recommendations are provided as part of a financial plan. Implementation of the recommendations is at your discretion. 5  March 3, 2025 Financial Consulting For clients who may not need a full financial plan, we offer investment, financial planning, and tax advice on a more limited basis. This generally includes advice on only isolated areas of concern— for example, real estate consulting and outside investment portfolio reviews. C. Scope of Services We manage client assets under the powers conferred upon us by individual investment advisory agreements. The investment strategies and objectives of each client account may differ. In each case, the account is managed in accordance with investment guidelines set forth in the investment advisory agreement and any other written supplements that may accompany it. Clients may, and generally do, impose restrictions on investing in certain securities and types of securities. D. Wrap Fee Programs We do not offer wrap fee programs. E. Assets Under Management As of December 31, 2024, we had $1,945,693,379 in assets under management. This includes $1,842,646,301 in discretionary assets and $103,047,077 in non-discretionary assets under management. ITEM 5 – FEES AND COMPENSATION A. Types of Compensation Asset Management Clients pay a management fee calculated as a percentage of their invested assets in the account. (assets may include: individual stocks, bonds, mutual funds, ETF’s and cash, including any funds with a margin balance). The management fee is determined by your advisor’s title at Willow Creek Wealth Management. 6  March 3, 2025 WCWM Managing Partners Fee Schedule is the greater of $2,500 per quarter or the fee calculated based on a percentage of assets as determined from the schedule below Account Size The first $2,000,000 The next $3,000,000 The next $5,000,000 On amounts over $10,000,000 Annual Fee (%) 1.00% 0.75% 0.50% 0.35% WCWM Advisory Fee Schedule is the greater of $1,250 per quarter or the fee calculated based on a percentage of assets as determined from the schedule below Account Size The first $2,000,000 The next $3,000,000 The next $5,000,000 On amounts over $10,000,000 Annual Fee (%) 1.00% 0.75% 0.50% 0.35% Clients who established accounts with us before January 2025 may be managed under a previous fee schedule and some clients may have a negotiated fee schedule. Financial Planning Our fee for financial planning services is negotiated individually. Factors used in determining the cost of a financial plan include the complexity and nature of the client’s circumstances. Financial Consulting We charge for financial consulting on an hourly basis. Our current billing rate is $300 per hour for hourly planning work. We believe our fees are competitive; however, you may be able to obtain similar services from other advisors at a lower price B. Method of Billing Asset Management Fees Clients pay a management fee, in advance, at the beginning of each quarter based on a fixed percentage of assets in the account. Unless the client has made other arrangements, our 7  March 3, 2025 management fee is calculatedas of the last day of the quarter in accordance with the account custodian’s usual and customary practices. Financial Planning Services A retainer may be requested prior to proceeding with the financial planning services. The remainder of the fee is due when the plan is presented to the client. C. Other Fees and Costs In addition to the management fees set forth above, clients may pay some or all of the following costs and expenses: • Assets Transferred into Account(s): Clients may be charged transaction costs due to the sale of securities transferred into their WCWM account. Clients should be aware that there also may be transfer fees charged by their prior custodian. • Account Costs: All fees charged by WCWM are separate and distinct from any fees and expenses charged by any mutual funds or exchange-traded fund to their shareholders. These fees and expenses are described in each fund’s prospectus. • Custodial Fees: All custody costs and expenses are charged by the custodian to the account. • Trading and Transaction Costs: Clients pay all trade fees, mark-ups and similar transaction costs incurred in connection with the purchase and sale of individual securities. • Annual Account Fee: Client may be charged a $40 per year per account fee billed at $10 per quarter. D. Return of Unearned Management Fees When the investment advisory agreement commences or terminates between an account’s regular valuation dates, a pro-rata adjustment is made with respect to the asset management fee for the partial period. Upon termination of any account, any prepaid, unearned fees are promptly refunded, and any earned, unpaid fees are due and payable. E. Compensation from the Sale of Investment Products We do not accept compensation or commissions for the sale of securities or other investment products. ITEM 6 – PERFORMANCE-BASED FEES We do not charge performance-based fees. 8  March 3, 2025 ITEM 7 – TYPES OF CLIENTS We provide investment services to individual and institutional investors including, for example, individuals, high net worth individuals and families, corporate pension and profit-sharing plans, charitable institutions, foundations, and endowments. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Our portfolio managers utilize passive management fundamentals, taking advantage of Nobel Prize winning academic theory in the design of investment portfolios. Recognizing that risk and reward are inextricably intertwined we work closely with clients to establish an appropriate level of risk. Core investment strategies of our asset management program include: • Customizing tax-efficient portfolios to achieve the financial goals of our clients • Optimizing portfolio structure to compensate investors for the level of risk assumed • Minimizing unnecessary portfolio risk through diversification • Maintaining portfolio allocation via systematic rebalancing • Applying strict discipline in all aspects of portfolio management • Using low-cost, tax-efficient institutional class investments • Adhering to fiduciary standards so our clients’ interests are always the priority It is important to note that the performance of any investment is subject to numerous factors which are neither within the control of, nor predictable by WCWM or their portfolio managers. These factors include a wide range of economic, political, competitive, and other conditions which may affect investments in general or within specific industries or companies. ITEM 9 – DISCIPLINARY INFORMATION We have no legal or disciplinary events to report involving WCWM or our management. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Service Provider to Meritas Wealth Management We are a service provider and sub-manager to Meritas Wealth Management, LLC. Our services include maintenance of the firm’s client portfolio performance/transaction history, entering of securities transactions and reconciling trades, among other administrative functions. 9  March 3, 2025 ITEM 11 – CODE OF ETHICS As an investment adviser, we are a “fiduciary” to our clients. This means that we have a fundamental obligation to act in the best interests of our clients including providing investment advice. We owe our clients a duty of undivided loyalty and utmost good faith. We will not engage in any activity in conflict with the best interests of a client and will take steps reasonably necessary to fulfill our obligations including adhering to the “reasonable compensation” and fees standard set forth in federal ERISA law. We employ reasonable care to avoid misleading clients and provide full and fair disclosure of all material facts to our clients and prospective clients. When we provide investment advice to clients regarding retirement plan account(s) or individual retirement account(s), we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. We have adopted a code of ethics (“Code of Ethics”) for all our supervised persons describing our high standard of business conduct and fiduciary duties to our clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All our employees must acknowledge the terms of the Code of Ethics annually, or as it is amended. Our employees and persons associated with us are required to follow our Code of Ethics. Subject to satisfying this policy and applicable laws, employees of WCWM may trade for their own accounts in securities which are recommended to and/or purchased for our clients. Among other things, our Code of Ethics is designed to ensure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of an advisory client and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code of Ethics certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of our clients. However, the Code requires pre- clearance of many transactions and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between WCWM and our clients. Affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with our obligation of best execution. In such circumstances, the affiliated and client accounts will share commission costs equally and receive securities at a total average price. 10  March 3, 2025 We retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the order. You may request a copy of our Code of Ethics by contacting Heather Belli at one of the telephone numbers on the cover page. ITEM 12 – BROKERAGE PRACTICES Directed Brokerage Arrangements We recommend certain broker-dealers to clients—primarily Pershing, and Schwab (see below). However, clients may select a particular broker-dealer to which all of your brokerage business will be directed. In that case, you will have the sole responsibility to negotiate terms and arrangements with the Directed Broker and we will not seek better execution services or prices from other broker-dealers or be able to “batch” transactions for execution through other broker- dealers with orders for other accounts we manage. As a result, you may pay higher commissions or other transaction costs, encounter greater spreads, or receive less favorable net prices on transactions for the Account than would otherwise be the case. Pershing Advisor Solutions, LLC, a BNY Company We utilize custodial services from Pershing Advisor Solutions, LLC, a BNY Company. Pershing Advisor Solutions is a subsidiary of Pershing Group, LLC affiliated under the corporate brand of the BNY Company (“Pershing”), member FINRA/SPIC/NFA. Pershing is a SEC-registered broker-dealer and FINRA member. Pershing offers to independent investment advisors services that may include custody of client securities, trade execution and clearance and settlement of transactions. Pershing is a discount broker-dealer independent of and unaffiliated with WCWM and there is no employee or agency relationship between us. Pershing does not supervise WCWM and has no responsibility for WCWM’s management of client portfolios or our other advice or services to our clients. Charles Schwab & Co., Inc. We utilize custodial services from Schwab Advisor Services™ offered by Charles Schwab Corporation. 11  March 3, 2025 Schwab Advisor Services™ is a division of Charles Schwab Corporation (“Schwab”), member SPIC Schwab is a SEC-registered broker-dealer. Schwab offers independent investment advisors services that may include custody of client securities, trade execution and clearance and settlement of transactions. Schwab is a discount broker-dealer independent of and unaffiliated with WCWM and there is no employee or agency relationship between us. Schwab does not supervise WCWM and has no responsibility for WCWM’s management of client portfolios or our other advice or services to our clients. “Best Execution” and “Soft Dollars” Due to the conflicts of interest involved, our policy is to avoid the kind of “soft dollar” arrangements explained below. Federal law requires us to deal fairly and honestly with clients. This means that, among many other things, we have a fiduciary obligation to seek “best execution” for transactions executed on behalf of our client accounts. When determining whether we have obtained best execution, we are guided by Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Safe Harbor”). Under certain circumstances, the Safe Harbor presumptively reduces or eliminates our liability to clients when we use client brokerage to pay for research and other services that we might otherwise have to pay for ourselves. Investment advisors who use soft dollars are said to be “paying up.” In effect, they are agreeing to pay a broker or dealer more than the lowest available commission rate to compensate the broker for the broker’s research products and services. The difference between the “unbundled” commission rate (i.e., the lowest available commission that would be paid solely for basic execution services) and the “bundled” commission rate (i.e., the slightly higher commission rate paid by advisors that are also receiving research services) is referred to as a “soft dollar” credit. To rely on the Safe Harbor provision, the advisor must determine in good faith that the extent to which it is “paying up” for securities trades is reasonable in relation to the value of the research services it is receiving from the executing broker. When making this evaluation, the advisor must take into account not only the costs for a specific transaction but also its overall responsibility to its clients. The practice of using soft dollars to pay for research presents an apparent conflict of interest. Investment advisors generally have a duty to act only in the interests of clients and not to derive economic benefits at client expense. Under a typical soft dollar arrangement, a money manager avoids having to pay hard dollars (i.e., its own money) to obtain brokerage research. All the broker’s compensation—i.e., both execution and research, is paid by the advisor’s clients from its 12  March 3, 2025 client accounts. This saves the investment advisor money for research expenses that they would otherwise be forced to bear. The availability and use of soft dollars also could have some or all of the following consequences: (1) clients might pay higher transaction costs (including mark-ups and mark-downs on principle transactions with market makers) than the transaction costs charged by other brokers or dealers who do not provide additional services or products, (2) we may have an incentive to direct the investment partnership’s brokerage to brokers or dealers that do not provide the best possible price, and (3) we may have an incentive to effect more transactions in our client accounts than might otherwise be optimal. The extent of any of the foregoing conflicts of interest between WCWM and our clients depends largely on the nature and uses of the services and products acquired with soft dollars. These conflicts of interest are particularly influential to the extent that we use soft dollars to pay expenses that we consider essential to our investment advisory activities and that we would otherwise be required to pay ourselves. ITEM 13 – REVIEW OF ACCOUNTS Asset Management Clients - Portfolio Reviews Portfolio Reviews and Rebalancing of the client’s portfolio are undertaken: (1) periodically, (2) upon request, and (3) upon a substantial asset class increase or decline, under the following adopted policies and procedures: Periodic Portfolio Reviews are undertaken by our advisors to ascertain if the values in any asset class have strayed beyond their model account’s target minimums or maximums, and for the purpose of meeting a client’s cash flow needs. Even if one or more asset classes fall outside their target minimums or maximums, we may determine not to rebalance the asset class for various reasons, such as avoidance of short-term capital gains, deferring long-term capital gains realization, minimization of transaction costs, etc. Additional Portfolio Reviews are undertaken upon request by the client, such as when additional cash or securities are added to the investment portfolio. Portfolio Reports Provided to Clients We provide Quarterly Reports to each client which include a performance report and a consolidated inventory of the investments upon which we exercise investment discretion. Monthly or quarterly statements from the account custodian(s) are sent to each client directly from the corresponding brokers, banks, mutual funds, partnership sponsors etc., which hold the client’s investments. These statements disclose the assets in the custodian’s custody. We strongly encourage client(s) to review the monthly or quarterly account statements provided by the custodian(s). 13  March 3, 2025 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Solicitors We may engage independent solicitors to provide client referrals. If you are referred to us by a solicitor, this practice will be disclosed to you in writing by the solicitor. In these cases, we would pay the solicitor out of our own funds—specifically, we would generally pay the solicitor a portion of the fees we earn for managing the capital of the client or investor that was referred. The use of solicitors is strictly regulated under applicable federal and state law. Our policy is to fully comply with the requirements of Rule 206(4)-3, under the Investment Advisors Act of 1940, as amended, and similar state rules. ITEM 15 – CUSTODY Custody means holding, directly or indirectly, client funds or securities or having any authority to obtain possession of them. The Securities and Exchange Commission and the State of California have rules and regulations which are designed to safeguard client assets. We follow the rules of the SEC, which require us to follow the following procedures: Maintain Accounts with Qualified Custodians: We have all client funds and securities, except shares of mutual funds, maintained by a “qualified custodian” (i.e., a bank, registered broker- dealer) in separate accounts for each client. Although we may recommend a custodian, and generally do, the client may choose their own. Shares of mutual funds are held by the mutual funds transfer agent. Periodic Account Statements: We require each custodian to furnish account statements to our clients no less frequently than quarterly. We also require that this statement, at a minimum, identifies the amount of funds and of each security in the account at the end of the quarter and all transactions in the account during the quarter. Standing Letter of Authorization (SLOA): Based on the No-Action Letter submitted by the Investment Adviser Association dated February 21, 2017, the SEC indicates that an adviser generally has custody where a client grants the adviser power in a standing letter of authorization (“SLOA”) to conduct third party transfers (i.e. Instruct the qualified custodian to accept the adviser’s direction on the client’s behalf to move money to a third party designated in the SLOA). These SLOAs have been put in place upon the client’s written request and signature. For instance, the amount or timing of the transfers may not be on the SLOA submitted to the custodian; however, at a future date, a client will contact the Adviser requesting that the adviser submit 14  March 3, 2025 instructions to the custodian to remit a specific dollar amount from the account to the designated third-party (both of which are identified in the SLOA that is on file). As further outlined in the No- Action Letter, the Adviser is exempt from certain ongoing requirements of the Custody Rule as we comply with the stated conditions of the letter. ITEM 16 – INVESTMENT DISCRETION We manage client assets on a discretionary basis and do not allow for any limitations to be placed on our investment authority unless they are contained in the investment advisory agreement. ITEM 17 – VOTING CLIENT SECURITIES We do not vote or accept responsibility for voting proxies for any securities held in client accounts. If equity securities are held in an account, it will be the accountholder’s sole right and obligation to vote all proxies. If securities are held in any pension or profit-sharing plan, we will notify the custodian/trustee that WCWM is not authorized to vote proxies and instruct the custodian to forward (to you) all proxy materials in respect of shares held in the Account. ITEM 18 – FINANCIAL INFORMATION Registered investment advisors are required to provide you with certain financial information or disclosures about its financial condition. We have no financial commitments that impair our ability to meet contractual and fiduciary commitments to our clients, and we have not been the subject of a bankruptcy proceeding. BROCHURE SUPPLEMENT(S) – Advisor Bios Pages 16 - 37 15  March 3, 2025 Heather C. Belli, CFP®, CAP® - DISCLOSURE BROCHURE Chief Compliance Officer & Managing Partner, Wealth Advisor Willow Creek Wealth Management, Inc. 825 Highway 116 North, Suite 5 Sebastopol, CA 95472 www.willowcreekwealth.com Sonoma 707.829.1146 | Marin 415.925.1388 | Toll Free 800.696.8096 This Brochure Supplement provides information about Heather Belli, CFP® that supplements the Willow Creek Wealth Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact Heather Belli, Chief Compliance Officer, at the above telephone number or heather@willowcreekwealth.com if you did not receive Willow Creek’s Disclosure Brochure or if you have any questions about the content of this supplement. Additional information about Ms. Belli is available on the SEC’s website at www.adviserinfo.sec.gov. 16  March 3, 2025 ITEM 2 – EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Ms. Belli was born in 1970. She received her CFP® certification in 2000. Educational Background Degree CFP® Year 2000 Major(s) Financial Planning B.S. 1993 Business Administration School Name College for Financial Planning California State Polytechnic University, Humboldt Business Experience Employment Dates: Employer Name: Type of Business: Job Title and Duties: 1997 – Present Willow Creek Wealth Management, Inc. 1 Investment Advisory Firm Managing Partner – executive management, board member Chief Compliance Officer – compliance oversight and risk management Wealth Advisor - CERTIFIED FINANCIAL PLANNER® professional ITEM 3 – DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. Ms. Belli has no information of this type to report. ITEM 4 – OTHER BUSINESS ACTIVITIES Ms. Belli has no other business activities to report. ITEM 5 – ADDITIONAL COMPENSATION Ms. Belli does not receive any economic benefit from any non-client for providing advisory services. ITEM 6 – SUPERVISION Ms. Belli is supervised by Jason Gittins, Director of Advisory Services & Managing Partner. 17  March 3, 2025 Bruce J. Dzieza, CFP® - DISCLOSURE BROCHURE Founder and Chairman of the Board, Partner Willow Creek Wealth Management, Inc. 825 Highway 116 North, Suite 5 Sebastopol, CA 95472 www.willowcreekwealth.com Sonoma 707.829.1146 | Marin 415.925.1388 | Toll Free 800.696.8096 This Brochure Supplement provides information about Bruce Dzieza, CFP® that supplements the Willow Creek Wealth Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact Heather Belli, Chief Compliance Officer, at the above telephone number or heather@willowcreekwealth.com if you did not receive Willow Creek’s Disclosure Brochure or if you have any questions about the content of this supplement. Additional information about Mr. Dzieza is available on the SEC’s website at www.adviserinfo.sec.gov. 18  March 3, 2025 ITEM 2 – EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Bruce Dzieza was born in 1950. He received his CFP® certification in 1984. Educational Background School Name College for Financial Planning Sonoma State University Degree CFP® B.A. Year 1984 1972 Major(s) Financial Planning Liberal Arts Business Experience Employment Dates: Employer Name: Type of Business: Job Title and Duties: 1982 – Present Willow Creek Wealth Management, Inc. 1 Investment Advisory Firm Chairman of the Board – strategic firm planning and advisor support, board member Founder – founding member of Willow Creek Wealth Management, Inc. 1 ITEM 3 – DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. Mr. Dzieza has no information of this type to report. ITEM 4 – OTHER BUSINESS ACTIVITIES Mr. Dzieza is a licensed real estate broker. However, he does not receive any economic benefit from being a licensed real estate broker. Mr. Dzieza has no other business activities to report. ITEM 5 – ADDITIONAL COMPENSATION Mr. Dzieza does not receive any economic benefit from any non-client for providing advisory services. ITEM 6 – SUPERVISION Mr. Dzieza is supervised by Jason Gittins, Director of Advisory Services & Managing Partner. 19  March 3, 2025 Jason R. Gittins, CFP® - DISCLOSURE BROCHURE Director of Advisory Services, Managing Partner, Wealth Advisor Willow Creek Wealth Management, Inc. 825 Highway 116 North, Suite 5 Sebastopol, CA 95472 www.willowcreekwealth.com Sonoma 707.829.1146 | Marin 415.925.1388 | Toll Free 800.696.8096 This Brochure Supplement provides information about Jason Gittins, CFP® that supplements the Willow Creek Wealth Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact Heather Belli, Chief Compliance Officer, at the above telephone number or heather@willowcreekwealth.com if you did not receive Willow Creek’s Disclosure Brochure or if you have any questions about the content of this supplement. Additional information about Mr. Gittins is available on the SEC’s website at www.adviserinfo.sec.gov. 20  March 3, 2025 ITEM 2 – EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Mr. Gittins was born in 1974. He received his CFP® certification in 2000. Educational Background School Name College for Financial Planning Sonoma State University Santa Rosa Junior College Degree CFP® B.S. A.S. Year 2000 1997 1995 Major(s) Financial Planning Business Administration Business Administration Business Experience Employment Dates: Employer Name: Type of Business: Job Title and Duties: 1997 – Present Willow Creek Wealth Management, Inc. 1 Investment Advisory Firm Managing Partner – executive management, board member Director of Advisory Services – day-to-day supervision of the advisory team. Wealth Advisor - CERTIFIED FINANCIAL PLANNER® professional ITEM 3 – DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. Mr. Gittins has no information of this type to report. ITEM 4 – OTHER BUSINESS ACTIVITIES Mr. Gittins has no other business activities to report. ITEM 5 – ADDITIONAL COMPENSATION Mr. Gittins does not receive any economic benefit from any non-client for providing advisory services. ITEM 6 – SUPERVISION Mr. Gittins is supervised by Timothy Admire, President & CEO, Managing Partner. 21  March 3, 2025 Mark F. Keating, CFP®, AEP® - DISCLOSURE BROCHURE Chief Investment Officer, Managing Partner, Wealth Advisor Willow Creek Wealth Management, Inc. 825 Highway 116 North, Suite 5 Sebastopol, CA 95472 www.willowcreekwealth.com Sonoma 707.829.1146 | Marin 415.925.1388 | Toll Free 800.696.8096 This Brochure Supplement provides information about Mark Keating, CFP® that supplements the Willow Creek Wealth Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact Heather Belli, Chief Compliance Officer, at the above telephone number or heather@willowcreekwealth.com if you did not receive Willow Creek’s Disclosure Brochure or if you have any questions about the content of this supplement. Additional information about Mr. Keating is available on the SEC’s website at www.adviserinfo.sec.gov. 22  March 3, 2025 ITEM 2 – EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Mr. Keating was born in 1975. He received his CFP® certification in 2009. Educational Background School Name Golden Gate University Santa Clara University Degree CFP® B.S. Year 2009 1997 Major(s) Financial Planning Accounting Business Experience Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2008 – Present Willow Creek Wealth Management, Inc. 1 Investment Advisory Firm Managing Partner – executive management, board member; Chief Investment Officer – investment review and oversight; Wealth Advisor - CERTIFIED FINANCIAL PLANNER® professional Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2006 - 2008 Exchange Bank Wealth Management Division Financial Services Firm Investment Officer – client service ITEM 3 – DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. Mr. Keating has no information of this type to report. ITEM 4 – OTHER BUSINESS ACTIVITIES Mr. Keating has no other business activities to report. ITEM 5 – ADDITIONAL COMPENSATION Mr. Keating does not receive any economic benefit from any non-client for providing advisory services. ITEM 6 – SUPERVISION Mr. Keating is supervised by Jason Gittins, Director of Advisory Services & Managing Partner. 23  March 3, 2025 David D. Homan, M.S., CFP® - DISCLOSURE BROCHURE Partner, Wealth Advisor Willow Creek Wealth Management, Inc. 825 Highway 116 North, Suite 5 Sebastopol, CA 95472 www.willowcreekwealth.com Sonoma 707.829.1146 | Marin 415.925.1388 | Toll Free 800.696.8096 This Brochure Supplement provides information about David Homan, CFP® that supplements the Willow Creek Wealth Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact Heather Belli, Chief Compliance Officer, at the above telephone number or heather@willowcreekwealth.com if you did not receive Willow Creek’s Disclosure Brochure or if you have any questions about the content of this supplement. Additional information about Mr. Homan is available on the SEC’s website at www.adviserinfo.sec.gov. 24  March 3, 2025 ITEM 2 – EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Mr. Homan was born in 1977. He received his CFP® certification in 2007. Educational Background School Name Golden Gate University CA State University, Chico Degree M.S. B.S. Year 2007 2001 Major(s) Financial Planning Business Business Experience Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2013 – Present Willow Creek Wealth Management, Inc. 1 Investment Advisory Firm Wealth Advisor - CERTIFIED FINANCIAL PLANNER® professional Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2012 – 2023 Intersect Marketing Group, Inc. Online Marketing Owner Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2004 – 2012 Private Ocean Investment Advisory Firm Senior Wealth Manager – client account management Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2001 – 2004 Capco Financial Services Provider Research Analyst – data management services ITEM 3 – DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. Mr. Homan has no information of this type to report. 25  March 3, 2025 ITEM 4 – OTHER BUSINESS ACTIVITIES Mr. Homan Has no other business activities to report. ITEM 5 – ADDITIONAL COMPENSATION Mr. Homan does not receive any economic benefit from any non-client for providing advisory services. ITEM 6 – SUPERVISION Mr. Homan is supervised by Jason Gittins, Director of Advisory Services & Managing Partner. 26  March 3, 2025 David B. Lawrence, CFP® - DISCLOSURE BROCHURE Partner, Wealth Advisor Willow Creek Wealth Management, Inc. 825 Highway 116 North, Suite 5 Sebastopol, CA 95472 www.willowcreekwealth.com Sonoma 707.829.1146 | Marin 415.925.1388 | Toll Free 800.696.8096 This Brochure Supplement provides information about David Lawrence, CFP® that supplements the Willow Creek Wealth Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact Heather Belli, Chief Compliance Officer, at the above telephone number or heather@willowcreekwealth.com if you did not receive Willow Creek’s Disclosure Brochure or if you have any questions about the content of this supplement. Additional information about Mr. Lawrence is available on the SEC’s website at www.adviserinfo.sec.gov. 27  March 3, 2025 ITEM 2 – EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Mr. Lawrence was born in 1962. He received his CFP® certification in 2005. Educational Background School Name Golden Gate University Hamilton College Degree CFP® B.A. Year 2004 1985 Major(s) Financial Planning History Business Experience Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2016 – Present Willow Creek Wealth Management, Inc. 1 Investment Advisory Firm Wealth Advisor - CERTIFIED FINANCIAL PLANNER® professional Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2014 – 2015 Raub Brock Capital Investment Advisory Firm Advisor Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2004 – 2014 Mosaic Financial Partners Investment Advisory Firm Senior Financial Planner ITEM 3 – DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. Mr. Lawrence has no information of this type to report. ITEM 4 – OTHER BUSINESS ACTIVITIES Mr. Lawrence has no other business activities to report. ITEM 5 – ADDITIONAL COMPENSATION Mr. Lawrence does not receive any economic benefit from any non-client for providing advisory services. 28  March 3, 2025 ITEM 6 – SUPERVISION Mr. Lawrence is supervised by Jason Gittins, Director of Advisory Services & Managing Partner. 29  March 3, 2025 Jacob Weber, CFP® – DISCLOSURE BROCHURE Wealth Advisor Willow Creek Wealth Management, Inc. 825 Highway 116 North, Suite 5 Sebastopol, CA 95472 www.willowcreekwealth.com Sonoma 707.829.1146 | Marin 415.925.1388 | Toll Free 800.696.8096 This Brochure Supplement provides information about Jacob Weber, CFP® that supplements the Willow Creek Wealth Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact Heather Belli, Chief Compliance Officer, at the above telephone number or heather@willowcreekwealth.com if you did not receive Willow Creek’s Disclosure Brochure or if you have any questions about the content of this supplement. Additional information about Mr. Weber is available on the SEC’s website at www.adviserinfo.sec.gov. 30  March 3, 2025 ITEM 2 – EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Mr. Weber was born in 1992. He received his CFP® certification in 2019. Educational Background Year Major(s) School Name Santa Clara University CA State University, Chico Degree CFP® B.A. 2019 2014 Financial Planning Economics Business Experience Employment Dates: Employer Name: Type of Business: 2017 – Present Willow Creek Wealth Management, Inc. 1 Investment Advisory Firm Job Title and Duties: Wealth Advisor - CERTIFIED FINANCIAL PLANNER® professional Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2014 – 2017 Charles Schwab Investment Advisory Firm Associate Financial Advisor ITEM 3 – DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. Mr. Weber has no information of this type to report. ITEM 4 – OTHER BUSINESS ACTIVITIES Mr. Weber has no other business activities to report. ITEM 5 – ADDITIONAL COMPENSATION Mr. Weber does not receive any economic benefit from any non-client for providing advisory services. ITEM 6 – SUPERVISION Mr. Weber is supervised by Jason Gittins, Director of Advisory Services & Managing Partner. 31  March 3, 2025 Rawson Gulick, CFP® – DISCLOSURE BROCHURE Wealth Advisor Willow Creek Wealth Management, Inc. 825 Highway 116 North, Suite 5 Sebastopol, CA 95472 www.willowcreekwealth.com Sonoma 707.829.1146 | Marin 415.925.1388 | Toll Free 800.696.8096 This Brochure Supplement provides information about Rawson Gulick, CFP® that supplements the Willow Creek Wealth Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact Heather Belli, Chief Compliance Officer, at the above telephone number or heather@willowcreekwealth.com if you did not receive Willow Creek’s Disclosure Brochure or if you have any questions about the content of this supplement. Additional information about Ms. Gulick is available on the SEC’s website at www.adviserinfo.sec.gov. 32  March 3, 2025 ITEM 2 – EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Ms. Gulick was born in 1970. She received her CFP® certification in 2020. Educational Background Year Major(s) School Name College for Financial Planning Georgia Southern University Degree CFP® BA 2020 1996 Financial Planning History Business Experience Employment Dates: Employer Name: Type of Business: 2019 – Present Willow Creek Wealth Management, Inc. 1 Investment Advisory Firm Job Title and Duties: Wealth Advisor - CERTIFIED FINANCIAL PLANNER® professional Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2017 – 2018 Launchsail LLC Consulting Managing Director Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2010 – 2016 Broadmark Asset Management LLC Investment Advisory Firm Managing Director and Global Marketing Director Employment Dates: Employer Name: 2009 – 2009 Unemployed Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2000 – 2009 Morgan Stanley & Co. Inc. Financial Services Firm Vice President ITEM 3 – DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. Ms. Gulick has no information of this type to report. 33  March 3, 2025 ITEM 4 – OTHER BUSINESS ACTIVITIES Ms. Gulick has no other business activities to report. ITEM 5 – ADDITIONAL COMPENSATION Ms. Gulick does not receive any economic benefit from any non-client for providing advisory services. ITEM 6 – SUPERVISION Ms. Gulick is supervised by Jason Gittins, Director of Advisory Services & Managing Partner. 34  March 3, 2025 Eric Keating, CFP® ChSNC® – DISCLOSURE BROCHURE Wealth Advisor Willow Creek Wealth Management, Inc. 825 Highway 116 North, Suite 5 Sebastopol, CA 95472 www.willowcreekwealth.com Sonoma 707.829.1146 | Marin 415.925.1388 | Toll Free 800.696.8096 This Brochure Supplement provides information about Eric Keating, CFP® ChSNC® that supplements the Willow Creek Wealth Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact Heather Belli, Chief Compliance Officer, at the above telephone number or heather@willowcreekwealth.com if you did not receive Willow Creek’s Disclosure Brochure or if you have any questions about the content of this supplement. Additional information about Mr. Keating is available on the SEC’s website at www.adviserinfo.sec.gov. 35  March 3, 2025 ITEM 2 – EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Mr. Keating was born in 1975. He received his CFP® certification in 2021. Educational Background School Name Santa Clara University Santa Clara University Degree CFP® BS Finance Year 2017 1997 Major(s) Financial Planning Finance Business Experience Employment Dates: Employer Name: Type of Business: 2022 – Present Willow Creek Wealth Management, Inc. 1 Investment Advisory Firm Job Title and Duties: Wealth Advisor - CERTIFIED FINANCIAL PLANNER® professional Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2019 - 2022 JDH Wealth Management Investment Advisory Firm Advisor, Certified Financial Planner® professional Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2008 - 2018 Keating Wines LLC Wine Owner Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2006 – 2008 VJB Vineyard & Cellars Wine Tasting Room Manager Employment Dates: Employer Name: Type of Business: Job Title and Duties: 2002 –2005 First Albany Capital Financial Institutional Trader Employment Dates: Employer Name: Type of Business: Job Title and Duties: 1997 –2001 JPMorgan – Hambrecht & Quist Financial Institutional Trader 36  March 3, 2025 ITEM 3 – DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. Mr. Keating has no information of this type to report. ITEM 4 – OTHER BUSINESS ACTIVITIES Mr. Keating has no other business activities to report. ITEM 5 – ADDITIONAL COMPENSATION Mr. Keating does not receive any economic benefit from any non-client for providing advisory services. ITEM 6 – SUPERVISION Mr. Keating is supervised by Jason Gittins, Director of Advisory Services & Managing Partner. 37  March 3, 2025 ENDNOTES 1 Willow Creek Wealth Management, Inc. was formerly known as Willow Creek Financial Services, Inc. until May 1, 2013. 38