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Item 1 – Cover Page
Clarion Wealth Management Partners, LLC
12500 Fair Lakes Circle, Suite 250
Fairfax, Virginia 22033
(703) 631-4800
www.clarionwealth.com
Form ADV Part 2A
Firm Brochure
March 31, 2026
This disclosure Brochure provides information about the qualifications and business practices of
Clarion Wealth Management Partners (“Clarion,” “us,” “we,” “our”).
If clients (“you,” “your”) have any questions about the contents of this Brochure, please contact
us at (703) 631-4800. The information in this Brochure has not been approved or verified by the
United States Securities and Exchange Commission (SEC) or by any state securities authority.
We are a Registered Investment Adviser (RIA) with the SEC. Our registration as an Investment
Adviser does not imply any level of skill or training. Additional information about Clarion is
available on the SEC’s website at www.adviserinfo.sec.gov (click on the link, select “investment
adviser firm” and type in our firm name). The results will provide you with both Part 1 and 2 of our
Form ADV.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Item 2 – Material Changes
There have been no material changes to this brochure since it was last updated on May 15th,
2025.
In the future this section of the Brochure will address only those “material changes” that have
been incorporated since our last delivery or posting of this Brochure on the SEC’s public
disclosure website (IAPD) at www.adviserinfo.sec.gov. At any time we may update this disclosure
Brochure and deliver a copy to you with a summary of material changes, or deliver to you only a
summary of material changes that includes an offer to deliver you a copy of the full Brochure
[either by electronic means (email) or in hard copy form].
If you would like another copy of this Brochure, please download it from the SEC website (cited
above) or contact our President and Chief Compliance Officer, David W. Young, III, located at
12500 Fair Lakes Circle, Ste 250, Fairfax, Virginia 22033. Our phone number is (703) 631-4800.
You can also email Mr. Young at dyoung@clarionwealth.com.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Item 3 – Table of Contents
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 ......................................................................................................... 10
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 13
Item 7 – Types of Clients ........................................................................................................................ 14
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 14
Item 9 – Disciplinary Information ........................................................................................................... 18
Item 10 – Other Financial Industry Activities and Affiliations............................................................. 18
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading19
Item 12 – Brokerage Practices ............................................................................................................... 19
Item 13 – Review of Accounts ................................................................................................................ 23
Item 14 – Client Referrals and Other Compensation .......................................................................... 24
Item 15 – Custody .................................................................................................................................... 25
Item 16 – Investment Discretion ............................................................................................................ 25
Item 17 – Voting Client Securities (i.e., Proxy Voting) ........................................................................ 26
Item 18 – Financial Information .............................................................................................................. 26
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Item 4 – Advisory Business
Clarion Wealth Management Partners (“Clarion” or the “Firm”) is a privately-owned limited liability
company (LLC) organized and formed under the laws of the Commonwealth of Virginia on
November 6, 2004, and was originally known as DWY & Associates, LLC. Clarion is owned by
David W. Young, III and Margaret S. Young. Clarion is registered as an investment adviser with
the Securities and Exchange Commission (SEC) to provide advisory services.
Day-to-day operation of our advisory business is supervised and managed by our President,
David W. Young, III, from our office located in Fairfax, Virginia. We offer investment advisory and
financial planning services to individuals, couples and families (including high net worth
individuals, couples and families) as well as small business owners, charitable (non-profit)
organizations, employer-sponsored profit-sharing plans and corporations.
This disclosure Brochure provides you with information regarding our qualifications, business
practices, and the nature of advisory services that should be considered before becoming our
client and receiving advisory services from us.
If you have any questions about this disclosure Brochure, please contact David W. Young, III,
President and Chief Compliance Officer, at (703) 631-4800 or dyoung@clarionwealth.com.
Individuals associated with us who are qualified will provide investment advisory and financial
planning services on our behalf. Such individuals are known as Investment Adviser
Representatives (IARs) - they are also known as Wealth Managers and/or Financial Advisors.
Clarion will require IARs, Wealth Managers and/or Financial Advisors to be properly licensed and
registered, unless exempt, in states in which Clarion or such individuals are conducting
investment advisory business.
Below is a description of the investment advisory and financial planning services that Clarion
offers. For more detail on any product or service please reference your Investment Advisory
Agreement or speak with your Clarion Investment Adviser Representative (IAR), also known as
a Wealth Manager and/or Financial Advisor.
This Brochure is designed to provide detailed information relating to each item noted in the table
of contents. Certain disclosures are repeated in one or more items, and/or other items are referred
to in an effort to be as comprehensive as possible on the subject matters discussed.
Within this Brochure, certain terms in either upper- or lowercase are used as follows:
●
“Clarion,” “We,” “Us,” “The / Our firm” and “Our” refer to Clarion Wealth Management
Partners
●
“Wealth Manager(s)” and “Financial Advisor(s)” refer to person(s) who provide
investment advisory and/or financial planning services on behalf of Clarion
Wealth Manager(s) and Financial Advisor(s) are also known as Investment Adviser
Representatives (“IAR(s)”)
“You,” “Yours,” and “Client” refer to clients of Clarion and its advisors
●
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
A. Investment Advisory Services
Clarion offers two distinct investment advisory services programs.
1. Investment Management Program
This program provides clients with advice and services related to the investment
management of their financial or brokerage accounts only. It does not include advice and
services related to other aspects of their financial lives (such as estate or income tax
planning) nor does it include financial planning or retirement projections.
Should we offer and you choose to engage our firm for investment management only in
this program you will pay advisory fees to us based upon the value of your managed
account in this program. These fees are generally calculated, collected directly from
your account and paid quarterly, in advance, and will not exceed an annualized rate
of 1.25%. Since the advisory fees you pay are set and are asset-based, we have an
incentive to increase your account value which creates a conflict of interest. Mutual funds,
ETFs, and other “packaged” products have their own expenses - we will disclose these to
you. Investment product investment management fees (i.e. expense ratios) are in addition
to our advisory fee and we do not share in any portion of these fees.
You will pay additional account fees including but not limited to custodian, account
maintenance, trade execution costs, transaction or alternative investment fees.
2. Wrap Fee Program
This program provides clients with advice and services intended to be “all-inclusive” in
nature related to an array of aspects of their financial lives in addition to investment
management including but not limited to:
Estate (document review, monitoring and estate settlement issues) and legacy planning,
income tax strategies, portfolio design / construction, investment management, employer-
sponsored plan consultation, financial and/or retirement projections, education planning /
facilitation, protection planning (reviewing current life, disability, and long-term needs) and
other applicable financial planning issues (ex. Social Security election timing).
Should we offer and you choose to engage our firm for investment management only in
this program you will pay advisory fees to us based upon the value of your managed
account in this program. These fees are generally calculated, collected directly from
your account and paid quarterly, in advance, and will not exceed an annualized rate
of 1.50%. Since the advisory fees you pay are set and are asset-based, we have an
incentive to increase your account value which creates a conflict of interest. Mutual funds,
ETFs, and other “packaged” products have their own expenses - we will disclose these to
you. Investment product investment management fees (i.e. expense ratios) are in addition
to our advisory fee and we do not share in any portion of these fees.
Clarion will pay additional account fees including but not limited to custodian, account
maintenance, trade execution costs, transaction or alternative investment fees.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Fees and Costs Not Included or Covered by the Wrap Fee
Our wrap fee covers our advisory services and most brokerage services provided by
Schwab (including custody of assets, equity trades, ETFs, and agency transactions in
fixed income securities). As a result, we have an incentive to execute transactions for your
account at Schwab.
Our wrap fee does not cover all fees and costs. The fees not included in the wrap fee
include charges imposed directly by a mutual fund, index fund, or exchange traded fund
which shall be disclosed in the fund’s prospectus (i.e. fund management fees and other
fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees (such
as a commission or markup) for trades executed away from [Schwab/Custodian] at
another broker-dealer, margin interest, wire transfer fees and other cashiering fees and
taxes on brokerage accounts and securities transactions.
In both investment advisory services programs Clarion manages client portfolios and investment
accounts on either a discretionary or a non-discretionary basis. In general, clients will provide
discretionary authority enabling our financial advisors to place trades in your account in
accordance with the established objectives of the account, but without the need for the client to
approve each trade in advance.
Your portfolio and account(s) are monitored by your financial advisor on a regular basis, and your
advisor will meet with you no less than annually to review the account’s holdings and performance.
You can place reasonable restrictions or constraints on the way your account is managed;
however, such restrictions may affect the composition and performance of your overall portfolio.
For these reasons, the performance of your portfolio or account(s) may not be identical with our
average client.
Our financial advisors gather information on each client’s financial history, income and expenses,
goals and objectives and will assist clients in developing an appropriate asset allocation strategy
based on each client’s unique and individual needs and risk tolerance. Fees for our asset
management services are described in Item 5 of this Brochure and are based on the level of
assets in your managed account.
We offer a suite of investment services and financial products to our advisors to recommend and
utilize with clients. Our investment advisory services and strategies are designed to accommodate
a wide range of investment philosophies, goals, needs, investment objectives and risk tolerances.
Our advisors have access to a wide range of securities products, including but not limited to
individual common and preferred equities (stocks); individual municipal, corporate and
government fixed income securities (bonds); open-end and closed-end mutual funds; exchange-
traded products like ETFs (exchange traded funds); options and derivatives; UITs (unit investment
trusts); alternatives such as traded and non-traded REITs (real estate investment trusts) and
fixed, fixed-indexed, variable and long-term care insurance / annuity products. Our advisors may
also offer advice related to and utilize direct participation programs, private placements, and other
alternative investments, such as alternative energy programs, research and development
programs, leasing programs, business development companies, interval funds, non-traded
REITs, pooled commodities futures programs and 1031 exchange programs.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
B. Financial Planning Services
Should we offer and you choose to engage our firm for wealth management consulting only,
financial planning advice or non-profit or business consulting, you will pay a fixed fee for those
services. These fees are generally a flat dollar amount and are payable in advance and contract
our services for a specific amount of time; however, we may choose to charge on an hourly basis.
Annual financial planning or consulting fees generally begin at $5,000 and are usually no higher
than $25,000. Hourly rates will not exceed $750. Fixed fees are based on the complexity of each
particular situation, the anticipated scope of services, and actual work required and completed in
order to deliver these services to you.
In our sole discretion, for clients who are investing through us in the Investment Management
Program described above and have more than $1,000,000 under our management, we may
reduce or waive financial planning fees altogether.
For clients who are invested in the Wrap Fee Program described above, we waive these fixed
fees and provide financial planning services at no additional charge.
1. Wealth Management Consulting
We provide advisory consulting services also known as wealth management or financial
planning consulting. These services cover a wide range of topics, including but not limited
to comprehensive financial planning, budgeting and cash flow analysis, major purchases,
education planning, retirement income/longevity planning, portfolio analysis, estate
planning analysis, investment analysis, business succession planning, and fringe benefit
analysis. Clients may also elect to enter into consulting or financial planning engagements
with advisors separately from, in addition to or as part of their managed account program,
as may be agreed between the client and advisor.
2. Retirement Plan Consulting
Our advisors provide a fee-for-service consulting program whereby advisors offer one-
time or ongoing advisory services to businesses and non-profit organizations regarding
qualified retirement plans. Clients may engage our advisors for retirement plan consulting
services on a negotiated flat, fixed, or asset-based fee basis. Through the retirement plan
consulting program, advisors assist plan sponsors with their fiduciary duties and provide
individualized advice based upon the needs of the plan and/or plan participants regarding
investment management matters, such as investment policy statement creation and
support, investment selection and monitoring, overall portfolio composition and participant
advice programs.
3. Retirement Plan Participant Consulting
We provide a fee-for-service consulting program whereby advisors offer ongoing
advisory services to retirement plan participants. Through this program advisors
assist retirement plan participants with a variety of advisory services including but
not limited to:
Financial planning and portfolio analysis
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Education on the options available through retirement plan
Recommended asset allocation
In addition to complying with applicable SEC rules, Clarion is subject to certain rules and
regulations adopted by the U.S. Department of Labor (“DOL”) when we provide non-discretionary
investment advice to retirement plan participants and IRA owners. When these DOL rules apply,
our advisors and Clarion are “fiduciaries” for purposes of the Employee Retirement Income
Security Act of 1974 (“ERISA”), as amended, and the Internal Revenue Code of 1986 (“the
Code”), as amended. Therefore, Clarion and our advisors may not receive payments that create
conflicts of interest when providing fiduciary investment advice to plan sponsors, plan participants,
and IRA owners, unless we comply with a prohibited transaction exemption (“PTE”). Beginning
December 20, 2021, Clarion and our advisors will comply with ERISA and the Code by using PTE
2020-02. As fiduciaries under ERISA and the Code, we render advice that is in plan participants’
and IRA customers’ best interest. Clarion’s and our advisors’ status as an ERISA/Code fiduciary
is limited to ERISA/Code covered non-discretionary advice and recommendations regarding
rolling over a retirement account and does not extend to all situations.
C. IRA Rollover Considerations
As part of our financial planning and advisory services, we may provide recommendations and
advice to you concerning your employer-sponsored retirement plan (i.e. 401(k), 403(b)) or other
qualified retirement account (i.e. 457, 401a). When appropriate, we may recommend that you
withdraw the assets from your employer-sponsored retirement plan or other qualified retirement
account and “roll” the assets over to an individual retirement account (“IRA”) to be managed by
our firm. If you elect to roll the assets to an IRA under our management, we will charge you an
asset-based fee as described in Item 5.
This practice of providing recommendations and advice then rolling the funds to an account to be
managed by Clarion presents a conflict of interest because our Investment Adviser
Representative has an incentive to recommend a rollover to you for the purpose of generating
fee-based compensation rather than solely based on your needs. You are under no obligation,
contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover,
you are under no obligation to have your IRA assets managed in one of our programs. You have
the right to decide whether to complete the rollover and the right to consult with other financial
professionals.
Some employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs – usually after age 59 ½. In determining whether to complete the rollover to an
IRA, and to the extent the following options are available, you should consider the costs and
benefits of each.
As it relates to employer-sponsored plans, a current or former employee will typically have four
options:
● Leave the funds in your employer’s (or former employer’s) plan
● Roll over the funds to a new employer-sponsored retirement plan
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
● Cash out completely or partially and make a taxable distribution from the plan
● Roll the funds into an IRA rollover account.
Each option has advantages and disadvantages. Before making a change or coming to a
decision, we encourage you to speak with your financial advisor, CPA and/or tax attorney. Before
rolling over your retirement funds to an IRA for Clarion to manage, carefully consider the following
list. Please note: This list is not exhaustive.
● Determine whether the investment options in your employer-sponsored retirement plan
address your needs or whether other types of investments are needed.
● Employer-sponsored retirement plans generally:
o May have more limited investment options than IRAs
o May have unique investments not available to the public, such as employer
securities or previously closed funds
● Your current employer-sponsored plan may have lower fees than our fee and/or the
Third-Party Manager’s fee combined.
●
If you are interested in investing only in mutual funds, you should understand the cost
structure of the share classes available in your employer-sponsored retirement plan and
how the costs of those share classes compare with those available in an IRA.
● You should understand the various products and services available through an IRA
provider and their costs.
●
It is likely you will not be charged a management fee and will not receive ongoing asset
management services unless you elect to have such services. If your plan offers
management services, the fee associated with the service may be more or less than our
fee.
● Our management strategy may have higher risk than options provided in your plan.
● Your current plan may offer financial advice, guidance, management and/or portfolio
options at no additional cost.
●
If you keep your assets titled in a 401(k) or other type of retirement account, you could
potentially delay your required minimum distribution (RMD) beyond age 73, provided
you are still an active participant in the plan.
● Your 401(k) may offer more liability protection than a rollover IRA; each state varies.
Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA
assets have been generally protected from creditors in bankruptcies; however, there
can be exceptions. Consult an attorney if you are concerned about protecting your
retirement plan assets from creditors.
● You may be able to take out a loan on your 401(k) or other type of employer-sponsored
plan, but not from an IRA.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
●
IRA assets can be accessed any time; however, distributions are subject to ordinary
income tax and may also be subject to a 10% early distribution penalty (prior to 59 ½)
unless they qualify for an exception such as disability, higher education expenses, or a
home purchase.
●
If you own company stock in your plan, you may be able to liquidate those shares at a
lower capital gains tax rate.
● Your plan may allow you to hire us or another firm as the manager and keep the
assets titled in the plan name.
It is important that you understand your options, their features and their differences, and decide
whether a rollover is best for you. If you have questions, contact us at our main number listed on
the cover page of this Brochure.
D. Assets Under Management
As of December 31st, 2025, Clarion Wealth managed $393,487,696 in assets on a discretionary
basis and $1,324,755 in assets on a non-discretionary basis for a total of $394,812,451 in
assets under management.
Item 5 – Fees and Compensation
Advisory / Account- and Investment-Level Management Fees
The advisory fees we charge to manage your investments at the account level are based on a
percentage of the market value of assets under management - this typically includes cash and
cash equivalent investments: bank sweep programs, money market funds, CDs, and T-Bills.
Additionally, mutual funds, exchange traded funds (ETFs), unit investment trusts, real estate
investment trusts, other “packaged” products or third-party managers charge asset (or
investment-level) management fees. These fees are in addition to the advisory fee that Clarion
charges to manage your portfolio and account(s). The fees charged by such funds or managers
are disclosed in each fund’s prospectus or third-party investment manager’s Form ADV Part 2A.
Clarion does not share in any portion of these fees.
Advisory fees to manage your portfolio and accounts are determined and agreed upon by clients
and your advisor at the time you become a client. Advisory fees are negotiable at the sole
discretion of Clarion. The advisory fee to manage your account does not cover debit balances or
related margin interest or SEC fees or other fees or taxes required by law. In addition, certain
accounts may be required to pay custodian, account maintenance, trade execution, transaction
or alternative custodial fees - all fees will be detailed in your client agreement otherwise known
as the Investment Advisory Agreement.
Financial Planning / Wealth Management Consulting Fees
The fees we charge for wealth management consulting only, financial planning advice or non-
profit or business consulting are fixed fees. These fees are generally a flat dollar amount and are
payable in advance and contract our services for a specific amount of time, however, we may
choose to charge on an hourly basis. Annual financial planning or consulting fees generally begin
at $5,000 and are usually no higher than $25,000. Hourly rates will not exceed $750. Fixed fees
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
are based on the complexity of each particular situation, the anticipated scope of services, and
actual work required and completed in order to deliver these services to you.
In our sole discretion for clients who are investing through us in the Investment Management
Program described above and have more than $1,000,000 under our management, we may
reduce or waive financial planning fees altogether.
For clients who are invested in the Wrap Fee Program described above, we waive these fixed
fees and provide financial planning services at no additional charge.
Termination of Contracts
The Investment Advisory Agreement, as applicable, may be terminated by either party at any time
by giving the other party written notice. The effective termination date will be 30 days after written
notice is received unless otherwise stated. While the termination date can be the date of the
notification, the termination date cannot be prior to notification.
Fees paid in advance will be prorated to the effective date of termination and any unearned portion
of the fee will be refunded to you within a practical period of time. The advisory fee will be returned
to the account from which was deducted, if possible or, if not possible, sent via check. Online
access to your accounts through wealth management platforms (Investor360) provided by Clarion
will be held open for a maximum of 30 days after the effective date.
We provide a current copy of this Brochure to prospective clients before entering into an advisory
contract or, at the latest, at the time of entering into the contract. Detailed information on the
termination terms and fees that you may encounter if you close accounts can be found in the
applicable investment advisory agreement.
How You’re Charged and How We’re Compensated
Clients who elect to receive investment advisory services through one or more of Clarion’s
investment management programs will generally pay a fee to Clarion and their advisor for those
services. Your advisory fee is an annualized percentage of assets under management, including
cash and money market positions.
Clarion offers a breakpoint fee schedule. The breakpoint schedule is applied at the household
level (an individual or couple with or without college-aged children as an example).
Breakpoint Schedule
A breakpoint schedule looks at the account values in the household and compares it to a set fee
schedule. Based upon the value of the accounts in the household at the end of the billing period,
the billable fee rate will decline as the value of the account reaches the next fee rate, or
“breakpoint.” The total value of the accounts in the household is compared against the fee rate
for the respective value range that corresponds with the household values to determine the total
account fee for that period.
For example, assume the advisor and client negotiate the following breakpoint fee schedule:
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Account Value
Up to $2,000,000
$2,000,000 - $3,999,999
$4,000,000 - $5,999,999
Above $6,000,000
Fee
1.50%
1.25%
1.00%
0.80%
Also, assume the account value at the end of the billing period is $1,800,000. In this hypothetical
example, and assuming an advanced quarterly billing cycle is applied, the account fee for the
upcoming quarter would be assessed as follows: The $1,800,000 account value falls within the
fee schedule value range of up to $2,000,000 which corresponds with a fee rate of 1.50 percent.
Therefore, $1,800,000 x 1.50% = $27,000; $27,000 ÷ 4 = a $6,750 advance quarterly account
fee.
The maximum annual rate for account management at Clarion is 1.5%.
Clients are urged to carefully review and discuss the contents of this Brochure with their advisor,
including descriptions of the various programs and services offered, the fees and charges clients
will pay, the means by which Clarion and your advisor are compensated, and the conflicts of
interest that exist between the client and Clarion and your advisor with respect to each program
or service offered, to determine the most appropriate programs or services for your specific
needs.
In most cases, your advisory fee is calculated using the asset values on accounts within your
household on the last day of each calendar quarter and is usually deducted from each account
by the 10th day of the first month of each quarter. Fees are “in advance” and cover our services
for the upcoming quarter. In limited circumstances, estimated month-end values of alternative
investments provided by the product issuer may be used when calculating billable AUM.
All Clarion Wealth Management Partners advisory program and service fees are negotiable.
Clarion may waive or discount a particular fee, whether on an ongoing or a one-time basis, in its
sole discretion. In the event a client terminates an advisory agreement with Clarion, any unearned
fees resulting from payments made by clients in advance will be refunded to the client.
Our standard advisory fee schedule for asset management programs is as follows:
Assets Under Management (AUM)*
Maximum Advisory Fee Rate
Up to $2,000,000
1.50%
$2,000,000 - $3,999,999
1.25%
$4,000,000 - $5,999,999
1.00%
Above $6,000,000
0.80%
*AUM is per household. When AUM tiers are reached, fees are reduced for the next billing cycle.
Client assets are billed entirely at the tier they qualify for based on the value of the account.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
When managing a client's account on a wrap fee basis, we receive as compensation for our
investment advisory services the balance of the total wrap (or program) fee you pay after
custodial, trading and other management costs (including execution and transaction fees) have
been deducted.
Schwab generally does not charge commissions (or transaction fees) for online trades of U.S.
exchange-listed securities (including U.S. exchange-listed ETFs), options (subject to $0.65 per
contract fee), and no-transaction-fee (“NTF”) funds. This means that, in most cases, when we buy
these types of securities, we can do so without paying any commissions to Schwab. We
encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee
arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee
arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory
services separately.
Additional Compensation
Certain IARs or other associated persons of Clarion are licensed to sell insurance products,
including annuities, on behalf of various insurance companies. The appropriately licensed IARs
and Clarion will receive a portion of the overall commission for the sale of such products.
This creates a conflict of interest because we have an incentive to recommend insurance products
to clients based on the compensation received, rather than based on the clients’ needs. You are
under no obligation to purchase insurance products through any particular insurance agency or
IAR. Insurance products may be available to you elsewhere at lower cost. We manage this conflict
of interest by requiring all IARs who are licensed to offer insurance products to our clients to
review the potential sale of any products for the purpose of determining adherence to applicable
insurance suitability standards and fully disclosing to a client when a particular transaction will
result in the receipt of commissions or other associated fees.
As financial professionals serving as full-time fiduciaries, our IARs must act in your best interest
when recommending insurance products to you. Please be aware that you have the option to
purchase insurance as well as investment products that we recommend through other brokers or
agents that are not affiliated with Clarion.
Item 6 – Performance-Based Fees and Side-By-Side Management
A. Performance-Based Fees
Performance-based fees are advisory fees that are based on a share of a capital gain or capital
appreciation of a client's account. Clarion does not charge or accept performance-based fees.
Our compensation structure is disclosed in detail in Item 5 above.
B. Side-by-Side Management
Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged
performance-based fees. Clarion does not engage in side-by-side management of accounts.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Item 7 – Types of Clients
Clarion provides investment advisory and financial planning services to a variety of clients.
Individuals, couples and families (including high net worth individuals, couples and families) as
well as small business owners, charitable (non-profit) organizations, employer-sponsored profit-
sharing plans and corporations can all be clients of Clarion. Each client is considered by Clarion
as a “household.”
In general, Clarion requires each household to have a minimum of $500,000 that is managed by
Clarion. We may waive this minimum at our discretion. We have found that our investment
strategies are best employed with amounts at or above $500,000.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Our investment strategies include long-term buy and hold as well as short-term trading strategies.
We primarily provide investment advice concerning equities, fixed income, certificates of deposit,
investment company securities (mutual funds) and variable insurance products. We also may
provide investment advice concerning partnership interests, including but not limited to real
estate, oil and gas interests, and other business or industry.
Each portfolio will be initially designed to meet particular investment goals and objectives taking
into account your financial situation, circumstances, and risk tolerance. You have the opportunity
to place reasonable restrictions or constraints on the way your account is managed; however,
such restrictions may affect the composition and performance of your portfolio.
We base our investment advice in part upon information gathered from financial newspapers,
magazines, and research materials prepared by others. We also utilize Morningstar, which
provides support services in portfolio design and strategy implementation, and Riskalyze, which
helps us analyze the level of risk our clients may currently have.
In determining the investment advice to give to you, we may utilize charting to determine trends
and project future values. In a fundamental analysis, we analyze the financial statements and
health of a business, its management and competitive advantages, and its competitors and
markets but usually focusing on growth or value (or sometimes a combination of both) to
determine if such security meets your needs and objectives. We will take into consideration when
making investment decisions the stages of the business during a given point in time. We may
also perform a security analysis discipline, known as technical analysis, in forecasting the
direction of prices through the study of past market data, primarily price and volume.
There are inherent risks involved in each investment strategy or method of analysis we use and
the particular types of security we recommend. Investing in securities involves risk of loss which
you should be prepared to bear. It is impossible to name all possible types of risks. Among the
risks are the following:
General Market Risks
Financial markets fluctuate in response to news releases or for no understandable reason
at all. This sometimes means that the price of specific securities could go up or down
without real reason and may take some time to recover any lost value. Adding additional
securities does not minimize this risk as all securities are affected by market fluctuations.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
● Political Risk
Most investments have a global component, even U.S.-based domestic stocks. Political
events anywhere in the world may have unforeseen consequences to world-wide financial
markets.
● Currency Risk
Global investments are subject to fluctuations in the value of the U.S. dollar against the
currency of the investment’s originating country. This is also referred to as “exchange rate
risk.”
● Regulatory Risk
Changes in laws and regulations from any government can change the value of a given
company and its accompanying securities. Certain industries are more susceptible to
government regulation. Zoning, tax structure, or laws impact the return on these
investments.
● Tax Risks Related to Short Term Trading
Clarion may engage in short-term trading transactions. These transactions may result in
short term gains or losses for federal and state tax purposes, which may be taxed at a
higher rate than long term strategies. Clarion endeavors to invest and transact client
assets in a tax efficient manner, but all clients are advised to consult with their tax
professionals regarding the transactions in their accounts. Frequent trading can affect
investment performance, particularly through increased brokerage and other transaction
costs and taxes.
● Risks Related to Investment Term
If you require us to liquidate your portfolio during a period in which the price of the security
is low, you will not realize as much value as you would have had the investment had the
opportunity to regain its value, as investments frequently do, or had we been able to
reinvest in another security.
● Purchasing Power Risk
Purchasing power risk is the risk that your investment’s value will decline as the price of
goods rises (inflation). The investment’s value itself does not decline, but its relative value
does, which is the same thing. Inflation can happen for a variety of complex reasons,
including a growing economy and a rising money supply.
● Business Risk
These risks are associated with a particular industry or a particular company within an
industry. For example, oil-drilling companies depend on finding oil and then refining it, a
lengthy process, before they can generate a profit. They carry a higher risk of profitability
than an electric company, which generates its income from a steady stream of customers
who buy electricity no matter what the economic environment is like.
● Liquidity Risk
Liquidity is the ability to readily convert an investment into cash. For example, Treasury
Bills are highly liquid, while real estate properties are not. Some securities are highly liquid
while others are highly illiquid. Illiquid investments carry more risk because it can be
difficult to sell them.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
● Financial Risk
Excessive borrowing to finance a business’s operations decreases the risk of profitability,
because the company must meet the terms of its obligations in good times and bad. During
periods of financial stress, the inability to meet loan obligations may result in bankruptcy
and/or a declining market value.
● Default Risk
This risk pertains to the ability of a company to service their debt. Ratings provided by
several rating services help to identify those companies with more risk. Obligations of the
U.S. government are said to be free of default risk.
● Risks Specific to Sub-advisers and Other Managers
If we invest some of your assets with another adviser, including a private placement, there
are additional risks. These include risks that the other manager is not as qualified as we
believe them to be, that the investments they use are not as liquid as we would normally
use in your portfolio, or that their risk management guidelines are more liberal than we
would normally employ.
● Risks of Investments in Mutual Funds, ETFs, and Other Investment Pools
As described above, Clarion may invest client portfolios in mutual funds, ETFs, and other
investment pools (“pooled investment funds”). Investments in pooled investment funds are
generally less risky than investing in individual securities because of their diversified
portfolios; however, these investments are still subject to risks associated with the markets
in which they invest. In addition, pooled investment funds’ success will be related to the
skills of their particular managers and their performance in managing their funds. Pooled
investment funds are also subject to risks due to regulatory restrictions applicable to
registered investment companies under the Investment Company Act of 1940.
● Equity Market Risks
Clarion will generally invest portions of client assets directly into equity investments, either
individual stocks or into pooled investment funds that invest in the stock market. As noted
above, while pooled investments have diversified portfolios that may make them less risky
than investments in individual securities, funds that invest in stocks and other equity
securities are nevertheless subject to the risks of the stock market. These risks include,
without limitation, the risks that stock values will decline due to daily fluctuations in the
markets, and that stock values will decline over longer periods (e.g. bear markets) due to
general market declines in the stock prices for all companies, regardless of any individual
security’s prospects.
● Option Risks
The purchaser of a put or call option can lose all of the cost of the option (the premium).
Most options expire “out of the money,” meaning the purchaser will lose his or her premium
on most options purchased. Selling puts and/or calls in a particular equity does not affect
the downside risk of owning that equity, as described in “Equity Market Risks” above.
There are additional significant risks involved in selling uncovered or “naked” puts or calls,
that is, puts or calls on securities in which you as the client do not already own an
underlying position in the security.
● Risks Related to Alternative Investment Vehicles
From time to time and as appropriate, Clarion may invest a portion of a client’s portfolio in
alternative vehicles. The value of client portfolios will be based in part on the value of
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
alternative investment vehicles in which they are invested, for which the success of each
will depend heavily upon the efforts of their respective managers. When the investment
objectives and strategies of a manager are out of favor in the market or a manager makes
unsuccessful investment decisions, the alternative investment vehicles managed by the
manager may lose money. A client account may lose a substantial percentage of its value
if the investment objectives and strategies of many or most of the alternative investment
vehicles in which it is invested are out of favor at the same time, or many or most of the
managers make unsuccessful investment decisions at the same time.
● Fixed Income Risks
Clarion may invest portions of client assets directly into fixed income instruments, such as
bonds and notes, or may invest in pooled investment funds that invest in bonds and notes.
While investing in fixed income instruments, either directly or through pooled investment
funds, is generally less volatile than investing in stock (equity) markets, fixed income
investments nevertheless are subject to risks. These risks include, without limitation,
interest rate risk (risk that changes in interest rates will devalue the investments), credit
risk (risks of default by borrowers), or maturity risk (risks that bonds or notes will change
value from the time of issuance to maturity).
● Foreign Securities Risks
Clarion may invest portions of client assets into pooled investment funds that invest
internationally. While foreign investments are important to the diversification of client
investment portfolios, they carry risks that may be different from U.S. investments. For
example, foreign investments may not be subject to uniform audit, financial reporting or
disclosure standards, practices or requirements comparable to those found in the U.S.
Foreign investments are also subject to foreign withholding taxes and the risk of adverse
changes in investment or exchange control regulations. Finally, foreign investments may
involve currency risk, which is the risk that the value of the foreign security will decrease
due to changes in the relative value of the U.S. dollar.
Investments may also be affected by currency controls; different accounting, auditing, financial
reporting, disclosure, and regulatory and legal standards and practices; expropriation (occurs
when governments take away a private business from its owners); changes in tax policy; greater
market volatility; different securities market structures; higher transaction costs; and various
administrative difficulties, such as delays in clearing and settling portfolio transactions or in
receiving payment of dividends. These risks may be heightened in connection with investments
in developing countries. Investments in securities issued by entities domiciled in the United States
may also be subject to many of these risks.
Any of the common risks described above could adversely affect the value of your portfolio and
account performance, and you can lose money. Even though these risks exist, Clarion will still
earn the fees and other compensation described in the Wrap Fee Program Brochure. Clients
should carefully consider the risks of investing and the potential that they may lose principal while
Clarion continues to earn fees and other forms of compensation.
Your investments are not bank deposits and are not insured or guaranteed by the FDIC or any
other governmental agency, entity, or person, unless otherwise noted and explicitly disclosed as
such, and as such may lose value.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Item 9 – Disciplinary Information
We are obligated and required to disclose to you any legal, regulatory, or disciplinary events that
are material to a client’s or prospective client’s evaluation of Clarion when considering a new or
ongoing Client-Adviser relationship with us.
Neither Clarion, as an advisory services firm, nor any management person including our President
and Chief Compliance Officer, David W. Young, III, has been involved in any arbitration claim or
found liable in any civil, self-regulatory organization or administrative proceeding that would
require disclosure under applicable SEC rules.
Individual Investment Adviser Representatives, otherwise known as Wealth Managers and/or
Financial Advisors, include any required disciplinary disclosures in the Form ADV Part 2B.
Clarion is pleased to report that none of our IARs have reportable disclosure as of the publication
of this Brochure.
Item 10 – Other Financial Industry Activities and Affiliations
consultant,
real estate broker or
Clarion does not have a related person, nor does the firm or its management personnel have a
relationship with any individual/entity who is an investment company/pooled investment vehicle,
other investment adviser/financial planner, futures commission merchant/commodity pool
operator, banking/thrift institution, accountant/accounting firm, lawyer/law firm, insurance
limited partnership
company/agency, pension
sponsor/syndicator.
Clarion has chosen to contract with Commonwealth Financial Network (Commonwealth) to
provide certain services, including but not limited to fee billing and account performance reporting
through Investor360, to our firm and clients. For the services it provides, Commonwealth charges
Clarion a flat administrative fee. This administrative fee is calculated at the same time clients are
assessed their asset-based advisory management fees. The administrative fee is charged to and
paid by Clarion rather than clients and is calculated as a percentage of the total account assets,
including cash and money market positions, held by the advisor’s clients.
Clarion has chosen to contract with Halo Securities LLC, a FINRA registered broker-dealer
(“Halo”), to provide certain two types of services for variable annuity and variable insurance
products for our clients. 1) Halo serves as the broker of record of a group of “legacy” or
commission-based variable annuity contracts or variable universal life policies that our clients
invested in prior to Clarion becoming a full-time fiduciary and fee-based advisory services
company. Halo receives commission trails on these investments and pays Clarion a fee
(expressed as a percentage of the trails) to serve as the investment adviser for these contracts /
policies. 2) Halo assists Clarion with new business for advisory fee-based insurance products,
including variable annuities. When Halo assists Clarion with new business they receive
compensation directly from the insurance company. Clarion receives the advisory fee that clients
pay for new business – this fee is either deducted from the insurance product or is charged to an
alternative source (account).
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, as amended, Clarion Wealth
Management Partners has adopted a Code of Ethics that governs a number of conflicts of interest
we have when providing our advisory services to you. Our Code of Ethics is designed to ensure
that we meet our fiduciary obligations to you and to foster a culture of compliance throughout our
firm.
Our Code of Ethics is comprehensive and is designed to help us detect and prevent violations of
securities laws and to help ensure that we keep your interests first at all times. We distribute our
Code of Ethics to each supervised person at the time of his or her initial affiliation with our firm;
we make sure it remains available to each supervised person for as long as he or she remains
associated with our firm, and we ensure that updates to our Code of Ethics are communicated to
each supervised person as changes are made.
Our Code of Ethics sets forth certain standards of conduct and addresses conflicts of interest
between our firm, our employees, our agents, our advisors, and our advisory clients.
Clients and prospective clients of Clarion may request a copy of our Code of Ethics at any time.
Clarion and its advisors often invest in the same securities that we recommend to clients. We also
recommend securities to and buy and sell securities for, client accounts at or about the same time
that we buy or sell the same securities for our own accounts. These activities create a conflict of
interest between us and our clients. Our firm policy prohibits “trading ahead” of clients’
transactions to the detriment of clients. When Clarion and its advisors are purchasing or selling
securities for their own accounts, priority will be given to client transactions, or trades will be
aggregated together to obtain an average execution price for the benefit of all parties. Clarion has
implemented surveillance and exception reports that are designed to identify and correct
situations in which firm or advisor transactions are intentionally placed ahead of client transactions
to the detriment of clients.
Item 12 – Brokerage Practices
How We Select Brokers/Custodians
We do not maintain physical custody of your assets; although we are deemed to have custody of
your assets under SEC rules if you give us authority to withdraw advisory fees from your account
or if you provide us with authorization for money movement to third parties (see Item 15 - Custody
below). Client assets must be maintained by a qualified custodian. We seek to recommend a
custodian who will hold client assets and execute transactions on terms that are overall most
advantageous when compared to other available providers and their services. The factors
considered are:
● Combination of transaction execution services and asset custody services
● Capability to execute, clear and settle trades (buy and sell securities for your account)
● Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, etc.)
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
● Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds [ETFs], limited partnerships)
● Availability of investment research and tools that assist us in making investment decisions
● Quality of services
● Competitiveness of the price of those services and willingness to negotiate the prices
● Reputation, financial strength, and stability
● Prior service to us and our other clients
● Availability of other products and services that benefit us
With this in consideration, our firm has an arrangement with Schwab Advisor Services (“Schwab”),
a qualified custodian from whom our firm is independently owned and operated. Schwab offers
services to independent investment advisers which includes custody of securities, trade
execution, clearance and settlement of transactions. Schwab enables us to obtain many no-load
mutual funds without transaction charges and other no-load funds at nominal transaction charges.
Schwab does not charge client accounts separately for custodial services. Client accounts will be
charged transaction fees, commissions or other fees on trades that are executed or settle into the
client’s custodial account. Transaction fees may be charged via individual transaction charges.
These fees are negotiated with Schwab and are generally discounted from customary retail
commission rates. This benefits clients because the overall fee paid is often lower than would be
otherwise. Substantially all client brokerage accounts are custodied at Schwab and not Clarion.
Services provided under some or all of these options may be available from other providers for
lower fees.
Schwab may make certain research and brokerage services available at no additional cost to our
firm. Research products and services provided by Schwab may include: research reports on
recommendations or other information about particular companies or industries; economic
surveys, data and analyses; financial publications; portfolio evaluation services; financial
database software and services; computerized news and pricing services; quotation equipment
for use in running software used in investment decision-making; and other products or services
that provide lawful and appropriate assistance by Schwab to our firm in the performance of our
investment decision-making responsibilities. The aforementioned research and brokerage
services qualify for the safe harbor exemption defined in Section 28(e) of the Securities Exchange
Act of 1934.
Schwab does not make client brokerage commissions generated by client transactions available
for our firm’s use. The aforementioned research and brokerage services are used by our firm to
manage accounts for which our firm has investment discretion. Without this arrangement, our firm
might be compelled to purchase the same or similar services at our own expense.
As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by our
firm or our related persons creates a potential conflict of interest and may indirectly influence our
firm’s choice of Schwab as a custodial recommendation. Our firm examined this potential conflict
of interest when our firm chose to recommend Schwab and have determined that the
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
recommendation is in the best interest of our firm’s clients and satisfies our fiduciary obligations,
including our duty to seek best execution.
Clients may pay a transaction fee or commission to Schwab that is higher than another qualified
broker-dealer might charge to affect the same transaction where our firm determines in good faith
that the commission is reasonable in relation to the value of the brokerage and research services
provided to the client as a whole.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether
the transaction represents the best qualitative execution, taking into consideration the full range
of a broker-dealer’s services, including the value of research provided, execution capability,
commission rates, and responsiveness. Although our firm will seek competitive rates to the benefit
of all clients, our firm may not necessarily obtain the lowest possible commission rates for specific
client account transactions.
Among others, our firm may receive the following benefits from Schwab:
● A certain amount of funding in credits to be used toward qualifying third-party service
providers used in connection with the initial set up of our firm’s research, technology and
software platforms. The amount credited will depend on the amount of assets that our
firm has on Schwab's platform, which is a conflict of interest since this creates an
incentive for our firm to recommend Schwab
● Receipt of duplicate client confirmations and bundled duplicate statements
● Access to a trading desk that exclusively services its institutional traders
● Access to block trading which provides the ability to aggregate securities transactions
and then allocate the appropriate shares to client accounts
● Access to an electronic communication network for client order entry and account
information.
Clarion clients may receive additional benefits from Schwab in the form of reimbursements of
certain transfer fees, the receipt of which are conditioned upon our firm bringing over a certain
level of assets to Schwab. A conflict of interest exists because these benefits provide an incentive
for our firm to recommend Schwab especially because benefits are contingent upon clients
transferring a certain amount of assets to Schwab.
Periodically, we will review alternative broker-dealers and custodians in the marketplace to ensure
that the custodians we use are meeting our duty to provide best execution for our clients. Best
execution does not simply mean the lowest transaction cost. When examining firms, we will
compare overall expertise, cost competitiveness and financial condition. The quality of execution
by the custodians we use will be reviewed using publicly available trade execution data and other
sources as needed. No single criteria will validate nor invalidate a custodian, but rather, all criteria
taken together will be used in evaluating the currently utilized custodian.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Economic Benefits
Economic Benefits is an independent area of disclosure with its own specific sample disclosure
language. The language is updated periodically and is currently available on SAC.com. Please
visit the link below for the most current language.
https://si2.schwabinstitutional.com/SI2/Published/Direct/public/file/p-6921287?amp;cv73
Products and Services Available to Us from Commonwealth
Commonwealth provides Clarion with various products and services that enable us to both serve
our clients and grow our business. For accounts held at National Financial Services (“NFS”),
Commonwealth provides us and our clients with access to its brokerage services – trading,
custody, reporting, and related services.
Commonwealth also makes available various support services. Some of those services help us
manage or administer our client accounts, while others help us manage and grow our business.
Commonwealth’s support services include:
Services That Benefit You
For clients custodied at NFS, Commonwealth’s brokerage services include access to a broad
range of investment products, execution of securities transactions by Commonwealth’s clearing
firms, and custody of client assets via their clearing firms.
Services That Do Not Directly Benefit You
Commonwealth also makes available to Clarion other products and services that benefit our firm
and our advisors but do not directly benefit you or your account. These products and services
assist us in managing and administering our clients’ accounts. They include investment research,
both Commonwealth’s and that of third parties. We use this research to service substantially all
our client accounts, including accounts not maintained at Commonwealth. In addition to
investment research, Commonwealth also makes available software and other technology that:
● Provide access to client account data (such as duplicate trade confirmations and account
statements) – for accounts custodied at NFS
● Facilitate trade execution – for accounts custodied at NFS
● Provide pricing and other market data
● Facilitate payment of our fees from our client accounts
● Assist with back-office functions, recordkeeping and client reporting
Services That Generally Benefit Only Us
Commonwealth also offers other services intended to help us manage and further develop our
business enterprise. These services include:
● Complementary or discounted attendance at conferences and events
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
● Consulting on technology, compliance, legal and business needs
● Publications and conferences on practice management and business succession
Soft Dollars
Clarion does not use commissions to pay for research and brokerage services (i.e. soft dollar
transactions). Research, along with other products and services other than trade execution, are
available to Clarion on a cash basis from various vendors.
Administrative Trade Errors
From time-to-time, Clarion or one of our advisors may make an error in submitting a trade order
on your behalf. Trading errors may include a number of situations, such as:
The wrong security is bought or sold for a client
The wrong amount or number of shares is bought or sold
A security is bought instead of sold or vice-versa
A transaction is executed or securities are allocated to the wrong account
Securities transactions are completed for a client that had a restriction on such security
When this occurs, we may place a correcting trade with the custodian. If an investment gain
results from the corrective action, the gain will remain in your account unless it is legally not
permissible for you to retain the gain, or we confer with you and you decide to forego the gain
(e.g. due to tax or other reasons). If an investment loss results from the corrective action, the loss
will be “covered” – in other words you will be made whole.
In the event Clarion aggregates trade orders, the allocation procedure will be equitable and fair
to all accounts. No account will be favored over another account unless reasons, consistent with
the best interests of each account, are documented. All allocation costs are shared on a pro rata
basis based on a client’s participation.
You will receive confirmations of transactions within and money movement into and out of your
accounts. It is in your best interest to review these confirmations within a reasonable period. We
believe a reasonable period of time is 30 days. Should you find that an error was made please
contact our office and speak to your advisor within 30 days of the trade date. \Once 30 days have
elapsed, we will consider all matters related your confirmations closed.
Item 13 – Review of Accounts
Either Chief Compliance Officer David W. Young III or his delegate, your financial advisor, will
meet with you to monitor and review your accounts at least annually or at a cadence that is
mutually agreed upon. Clients will receive a written report at the time of the review and may
receive a follow-up summary of our recommendations. A more frequent review of your accounts
will be conducted upon your request.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Reviews of investment accounts typically look at portfolio consistency with regards to your risk
tolerance, investment time horizon, performance objectives, and asset allocation instructions. We
will also review account holdings, transactions, charges, and performance as provided on such
statements and other account reports. We monitor the investments that make up the majority of
our clients’ holdings on a weekly basis. If you receive financial planning advice, reviews are made
at least once annually for clients with accounts managed by Clarion, based on the cooperation of
clients. Reviews cover progress toward financial independence, anticipated distributions toward
family legacy goals, anticipated distributions for social capital or charitable goals, as well as other
goals communicated by you. In either type of review, accounts will also be reviewed upon notice
of changes in your circumstances.
You are provided with written monthly account statements from the custodian, depending on the
activity in the account. Reports include details of your holdings, asset allocation, and other
transaction information. Comparisons to market indices and account performance may be used
to evaluate account performance in review with you.
Item 14 – Client Referrals and Other Compensation
Other than as described herein, particularly in Items 5 and 12, we receive no compensation from
third parties for providing advice to our clients, nor do we compensate for client referrals.
Commonwealth offers our firm and our firm’s advisory representatives one or more forms of
financial benefits based on our advisory representatives’ total AUM as an affiliate of
Commonwealth or financial assistance for advisory representatives transitioning from another firm
to become an affiliate of Commonwealth. The types of financial benefits Commonwealth provides
include, but may not be limited to forgivable or unforgivable loans provided at below-market rates,
equity ownership investments into our firm’s business, discounts or waivers on transaction,
platform, and account fees, technology fees, research package fees, financial planning software
fees, administrative fees, brokerage account fees, account transfer fees, licensing and insurance
costs, referral fees for recruiting new advisors to affiliate with Commonwealth, and the cost of
attending conferences and events. The financial benefits that our firm or our advisory
representatives may receive from Commonwealth are a conflict of interest and provide a financial
incentive for our firm and our advisory representatives may receive from Commonwealth are a
conflict of interest and provide a financial incentive for our firm and our advisory representatives
to select Commonwealth as broker-dealer for your accounts over other broker-dealers from which
we may not receive similar financial benefits. We attempt to mitigate this conflict of interest by
disclosing the conflict in this brochure and engaging in a regular review of our relationship with
Commonwealth to ensure the relationship continues to be appropriate in all respects for our firm’s
clients.
You should be aware that the receipt of additional compensation itself creates a conflict of interest
and may affect the judgment of Clarion and its IARs when making recommendations. Clarion
endeavors at all times to put your interest first as part of our fiduciary duty.
We do not have any arrangement under which we compensate, or receive compensation from
another for client referrals, nor do we compensate others for referring clients to us.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Item 15 – Custody
Clarion does not maintain physical custody of your assets. Under SEC rules, we are deemed to
have custody of your assets if you authorize us to instruct your account custodian to deduct our
advisory fees directly from your account, if you provide us with authorization to transfer funds from
your account to a third party or if we are granted power of attorney or similar authority over your
account that permits us to move assets or effect disbursements on your behalf. In certain limited
circumstances, Clarion or its associated persons may act as a Power of Attorney (“POA”) for a
client account, which may also cause us to be deemed to have custody under applicable SEC
rules. Clarion maintains a relationship with Commonwealth who, as described previously in this
brochure, maintains a clearing relationship for the execution of client transactions with Charles
Schwab as the account custodian. In all cases, the name and address of the account custodian
will be identified in the respective managed account client agreement.
Clients who establish a managed account with Clarion will receive custodial account statements
directly from the respective custodian that holds those assets, such as Schwab or a direct product
sponsor. Clients should carefully review the statements they receive from their account
custodians and should promptly report material discrepancies to Clarion.
Our clients may also receive portfolio summary or performance reporting for their managed
accounts from us or their advisor that are in addition to the account statements clients receive
directly from the respective account custodian. We urge you to compare the account statements
you receive from your account custodian with any account summary statements or reports you
receive from us or your advisor. Although account holdings and asset valuations should generally
match, for purposes of calculating performance and account valuations on your account, our
summary or performance reporting month-end market values sometimes differ from custodial
account statement month-end market values. The three most common reasons why these values
may differ are differences in the manner in which accrued interest is calculated, the date upon
which “as of” dividends and capital gains are reported, and settlement versus trade date
valuations.
If you believe there are material discrepancies between your custodial statement and the
summary statements or reports you receive from Clarion or your advisor, please contact us.
Item 16 – Investment Discretion
Clarion renders investment advice to the majority of its managed account clients on a
discretionary basis, pursuant to written authorization granted by the client to the firm. This
authorization grants to Clarion and your advisor the discretion to buy, sell, exchange, convert, or
otherwise trade in securities and/or insurance and annuity products, and to execute orders for
such securities and/or insurance products with or through any distributor, issuer, or broker-dealer
as Clarion or your advisor may select.
Your advisor may, without obtaining your consent, determine which products to purchase or sell
for your managed account, as well as when to purchase or sell such products, and the prices to
be paid.
Neither Clarion nor your advisor, however, is granted authority to take possession of your assets.
You may terminate this discretionary authorization at any time by providing written notice to us.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A
Clients may impose reasonable restrictions on their managed account, including but not limited
to the type, nature, or specific names of securities to be bought, sold, or held in their managed
account, as well as the type, nature, or specific names of securities that may not be bought, sold,
or held in their managed account.
Clients generally grant Clarion and their advisor discretionary trading authority over their managed
accounts. If not specifically requested otherwise by the client, discretionary authority will be
established at the time the account is first opened.
As a matter of firm policy, neither Clarion nor its advisors have or will accept the authority to file
class action claims on behalf of clients.
This policy reflects our recognition that Clarion does not have the requisite expertise to advise
clients with regard to participating in class actions. Clarion and its advisors have no obligation to
determine if securities held by the client are subject to a pending or resolved class action
settlement or verdict. Clarion and its advisors also have no duty to evaluate a client’s eligibility or
to submit a claim to participate in the proceeds of a securities class action settlement or verdict.
Furthermore, Clarion and its advisors have no obligation or responsibility to initiate litigation to
recover damages on behalf of clients who may have been injured because of actions, misconduct,
or negligence by corporate management of issuers whose securities are held by clients. The
decision to participate in a class action or to sign a release of claims when submitting a proof of
claim may involve the exercise of legal judgment, which is beyond the scope of services provided
to clients by Clarion or your advisor. In all cases, clients retain the responsibility for evaluating
whether it is prudent to join a class action or to opt out.
Item 17 – Voting Client Securities (i.e., Proxy Voting)
Our clients receive proxies directly from their Custodian(s) or Investment Sponsor(s).
We do not vote or assist in voting proxies. Our clients are responsible for directing their own
proxies solicited by issuers of securities.
Clients are responsible for making elections relative to mergers, acquisitions, tender offers,
bankruptcy proceedings and other type events pertaining to the securities in clients’ account(s).
Proxy and other solicitation information will be delivered either by US mail or email to clients from
the account custodian. Please follow the instructions for proxy voting included in the mailing.
Item 18 – Financial Information
Clarion has no financial condition that is reasonably likely to impair our ability to meet contractual
commitments to clients, nor has Clarion been the subject of a bankruptcy proceeding.
CLARION WEALTH MANAGEMENT PARTNERS FORM ADV PART 2A