A. Firm Information Clare Market Investments, LLC (“Clare Market” or the “Advisor”) is a registered investment advisor located in the State of Texas, which is organized as a Limited Liability Company (“LLC”) under the laws of Texas. Clare Market was founded in January 2012 and is owned and operated by Keith A. Rhodus (Founder and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Clare Market. B. Advisory Services Offered Clare Market offers investment advisory services to individuals, high net worth individuals, families, trusts, estates and business clients in the State of Texas and other states (each referred to as a “Client”). Investment Management Services Clare Market provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and financial planning services. Clare Market focuses on long-term investing with a focus on financial and wealth planning. Clare Market works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Clare Market will then construct a portfolio consisting of its internal investments strategies and/or an allocation to unaffiliated money managers. The Advisor constructs portfolios consisting of individual equity and fixed income securities, oil and gas master limited partnerships and other types of investments. The Advisor may utilize mutual funds and/or exchange- traded funds (“ETFs”) to represent a particular asset class or sector. For fixed income allocations, the Advisor generally employs mutual funds and ETFs. For cash management, the Advisor will often invest in short-term government issues. Index and individual options may be used in risk management or to provide income for Clients. Clare Market’s investment strategy is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. In certain circumstances, positions may be held for a short period as well. Clare Market will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Clare Market evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Clare Market may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Clare Market may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Clare Market may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Clare Market accept or maintain custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. Selection of Sub-Advisors Clare Market may recommend to certain Clients that a portion of their investment portfolio be implemented by utilizing one or more unaffiliated money managers (an unaffiliated manager”). The Advisor will either engage an unaffiliated manager directly or select an unaffiliated manager that participates in a managed accounts program at the Client's Custodian. The Client may enter into an additional investment management agreement with the Page 5 unaffiliated manager and/or program sponsor, as applicable. The unaffiliated manager[s] will also have investment discretion over the Client’s account[s] allocated to the manager and will have the authority to purchase or sell investments without the prior approval of the Client, subject to any restrictions on the account[s]. The Advisor shall monitor the performance of the unaffiliated manager and shall have the discretionary authority to hire or fire any unaffiliated

manager. The Advisor will assist and advise the Client in establishing investment objectives for the account[s], the selection of the unaffiliated manager[s], and defining any restrictions on the account[s]. Clare Market will continue to provide oversight of the Client account[s] and ongoing monitoring of the activities of the unaffiliated manager[s]. Clare Market does not receive any compensation from these unaffiliated money managers or the Program Sponsor, other than Clare Market’s investment advisory fee (described in Item 5). The Client, prior to entering into an agreement with an unaffiliated manager or managed accounts program, will be provided with the Form ADV Part 2A (or a brochure that makes the appropriate disclosures) for the unaffiliated manager[s] and/or the program sponsor (as applicable). Financial Planning Services Clare Market will typically provide a variety of financial planning services to individuals and families, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. The Advisor provides a comprehensive wealth planning approach with its Clients. Planning services will typically include the preparation of a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting is often ongoing in nature. For certain Clients, a plan may be targeted and may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Clare Market may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a potential conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to execute the transaction through the Advisor. C. Client Account Management Prior to engaging Clare Market to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Clare Market, in connection with the Client, will develop an investment strategy targeted to achieve the Client’s investment goals and objectives. Page 6
• Asset Allocation – Clare Market will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client.
• Portfolio Construction – Clare Market will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Clare Market will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Clare Market does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Clare Market. E. Assets Under Management As of December 2022, Clare Market manages approximately $317,100,000 in discretionary assets. Clients may request more current information at any time by contacting the Advisor.