Clarity Investments + Planning LLC (Clarity or the Firm) was founded in December 2008. Antonia
Clearwaters (Annette) is the sole owner of Clarity. Clarity brings objective, high-quality financial
advice (including investment management and financial planning) to a broad range of clientele,
regardless of their existing wealth. As further discussed in response to Item 8,
Clarity
investment philosophy is based on principles of asset allocation, diversification, and minimizing
expenses.
Prior to engaging Clarity to provide any of the foregoing investment advisory services, the client
is required to enter into one or more written agreements with the firm setting forth the terms
and conditions under which Clarity renders its services (collectively the “Agreement”).
This Disclosure Brochure describes the business of Clarity. Certain sections will also describe the
activities of Supervised Persons. Supervised Persons are any of Clarity’s officers, partners,
directors (or other persons occupying a similar status or performing similar functions), or
employees, or any other person who provides investment advice on Clarity’s behalf and is
subject to Clarity’s supervision or control.
Financial Planning/Consulting Services
Clarity may provide its clients with a broad range of comprehensive financial planning and
consulting services. These services include retirement planning, cash flow projections,
education savings, and debt management, but may also address additional areas tailored to the
specific needs of clients.
In performing its services, Clarity is not required to verify any information received from the
client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly
authorized to rely on such information. Clarity may recommend the services of itself, and/or
other professionals to implement its recommendations. Clients are advised that a conflict of
interest exists if Clarity recommends its own services. The client is under no obligation to act
upon any of the recommendations made by Clarity under a financial planning engagement or to
engage the services of any such recommended professional, including Clarity itself. The client
retains absolute discretion over all such implementation decisions and is free to accept or reject
any of Clarity’s recommendations. Clients are advised that it remains their responsibility to
promptly notify Clarity if there is ever any change in their financial situation or investment
objectives for the purpose of reviewing, evaluating, or revising Clarity’s previous
recommendations and/or services.
Investment Management Services
Clients can engage Clarity to manage all or a portion of their assets on a discretionary basis. All
ongoing investment management clients are offered one (1) hour of complementary financial
planning each year.
Clarity primarily allocates clients’ investment management assets among mutual funds, and to a
lesser extent among exchange-traded funds (“ETFs”), Clarity also provides advice about any
type of investment held in clients' portfolios.
Clarity tailors its advisory services to the individual needs of clients. Clarity consults with clients
initially and on an ongoing basis to determine risk tolerance, time horizon and other factors
that may impact the clients’ investment needs (which may include the development of a
financial plan). Clarity ensures that clients’ investments are suitable for their investment needs,
goals, objectives and risk tolerance.
Clients are advised to promptly notify Clarity if there are changes in their financial situation or
investment objectives or if they wish to impose any reasonable restrictions upon Clarity’s
management services. Clients may impose reasonable restrictions or mandates on the
management of their account (e.g., require that a portion of their assets be invested in socially
responsible funds) if, in Clarity’s sole discretion, the conditions will not materially impact the
performance of a portfolio strategy or prove overly burdensome to its management efforts.
Wrap Fee Program
Clarity does not participate in a Wrap Fee Program.
Use of Independent Managers
As mentioned above, Clarity may recommend
that certain clients authorize the active
discretionary management of a portion of their assets by and/or among certain independent
investment managers (“Independent Managers”), based upon the stated investment objectives
of the client. The terms, compensation and conditions under which the client engages the
Independent Managers are set forth in a separate written agreement between the client and
the designated Independent Managers.
Clarity renders services to the client relative to the discretionary and/or non-discretionary
selection or recommendation of Independent Managers. Clarity also monitors and reviews the
account performance and the client’s investment objectives.
When recommending or selecting an Independent Manager for a client, Clarity reviews
information about the Independent Manager such as its disclosure statement and/or material
supplied by the Independent Manager or independent third parties for a description of the
Independent Manager’s investment strategies, past performance and risk results to the extent
available. Factors that Clarity considers in selecting or recommending an Independent Manager
include the client’s stated investment objectives, management style, performance, reputation,
reporting, pricing, and research. The investment management fees charged by the designated
Independent Managers, together with the fees charged by the corresponding designated
broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, Clarity’s
investment advisory fee.
In addition to Clarity’s written disclosure brochure, the client also receives the written
disclosure brochure of the designated Independent Managers. Certain Independent Managers
may impose more restrictive account requirements and varying billing practices than Clarity. In
such instances, Clarity may alter its corresponding account requirements and/or billing
practices to accommodate those of the Independent Managers.
Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act,
(“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing
retirement accounts.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Client Assets
As of December 31, 2023, Clarity had $ 105,894,329 of assets under management with
$104,922,511 managed on a discretionary basis and $971,818 managed on a non-discretionary
basis.