Claro Advisors Inc.

Part 2A of Form ADV: Firm Brochure APRIL 27, 2026 CLARO ADVISORS INC. 100 High Street, Suite 950 Boston, MA 02110 Phone: (800) 604-2838 | Fax: (800) 508-1983 www.claroadvisors.com This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Claro Advisors Inc. (“Claro” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact the Advisor at (800) 604-2838 or by email at info@claroadvisors.com. Claro is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Claro to assist you in determining whether to retain the Advisor. Additional information about Claro and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 160294. 1 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure I T E M 2 . Material Changes Form ADV 2 is divided into two parts: Part 2A and Part 2B. Part 2A (the “Disclosure Brochure”) provides information about a variety of topics re- lating to an Advisor’s business practices and conflicts of interest. The Part 2B (”Brochure Supplement”) provides information about the Advisory Persons of Claro. For convenience, the Advisor has combined these docu- ments into a single disclosure document. Claro believes that communication and transparency are the foundation of its relationship with Clients and continually strive to provide you with complete and accurate information at all times. Claro encourages all cur- rent and prospective Clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. MATERIAL CHANGES The following material changes have been made to this Disclosure Bro- chure since the annual amendment filing on March 31st, 2025: • The Advisor will assist interested Clients with establishing a dig- ital currency account through Fidelity Digital Asset Services, LLC (“FDAS”). Please see Items 4 and 8 for additional information. • The Advisor will introduce Clients to available non-purpose loan pro- grams (“Lending Program”) through UPTIQ, Inc. Please see Items 4, 8, and 10 for additional information. • Claro Advisors Inc. is organized as a corporation under the laws of the State of Delaware. The firm previously operated as a limited lia- bility company and completed a corporate conversion. This change did not result in a change in control or impact existing client rela- tionships. Please see Item 4 for additional information. • The Advisor is deemed to have custody of certain Client accounts. Please see Item 15 for additional information. • Claro provides customized investment solutions, including propri- etary and internally managed strategies. Please see Items 4, 5, and 10 for additional information. FUTURE CHANGES From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of Claro. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo. sec.gov by searching with the Advisor’s firm name or CRD# 160294. You may also request a copy of this Disclosure Brochure at any time, by con- tacting the Advisor at (800) 604-2838 or by email at info@claroadvisors. com. Claro Advisors Inc. Form ADV Part 2A: Firm Brochure 02  I T E M 3 . Table of Contents I T E M 1 . Cover Page 01 3 I T E M 2 . Material Changes 02 4 5 I T E M 3 . Table of Contents 03 6 I T E M 4 . Advisory Services 04 I T E M 5 . Fees and Compensation 06 I T E M 6 . Performance-Based Fees and Side-By-Side Management 09 I T E M 7 . Types of Clients 09 I T E M 8 . Methods of Analysis, Investment Strategies and Risk of Loss 09 I T E M 9 . Disciplinary Information 11 I T E M 1 0 . Other Financial Industry Activities and Affiliations 11 I T E M 1 1 . Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 12 I T E M 1 2 . Brokerage Practices 12 I T E M 1 3 . Review of Accounts 13 I T E M 1 4 . Client Referrals and Other Compensation 13 I T E M 1 5 . Custody 14 I T E M 1 6 . Investment Discretion 14 I T E M 1 7 . Voting Client Securities 14 I T E M 1 8 . Financial Information 15 P R I V A C Y P O L I C Y 03  I T E M 4 . 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 the Client, gen- Advisory Business erating cash to meet Client needs, or any risk deemed unacceptable for A . F I R M I N F O R M A T I O N the Client’s risk tolerance. Claro Advisors Inc. (“Claro” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Corporation under the laws of the State of Dela- Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement ware, located in the Commonwealth of Massachusetts. Claro was founded accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title in January 2012, and is owned and operated by Ryan S. Belanger (Princi- I of the Employee Retirement Income Security Act (“ERISA”) and/or the pal). This Disclosure Brochure provides information regarding the qualifi- Internal Revenue Code (“IRC”), as applicable, which are laws governing cations, business practices, and the advisory services provided by Claro. retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution B . A D V I S O R Y S E R V I C E S O F F E R E D from an ERISA retirement account or to roll over the assets to an IRA, or Claro offers investment advisory services to individuals, high net worth in- recommend a similar transaction including rollovers from one ERISA dividuals, trusts, estates, businesses, and retirement plans (each referred sponsored Plan to another, one IRA to another IRA, or from one type of to as a “Client”). account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Ad- The Advisor serves as a fiduciary to Clients, as defined under the appli- visor will earn a new (or increase its current) advisory fee as a result of the cable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate transaction. No Client is under any obligation to roll over a retirement ac- count to an account managed by the Advisor. potential conflicts of interest. Claro’s fiduciary commitment is further de- scribed in the Advisor’s Code of Ethics. For more information regarding At no time will Claro accept or maintain custody of a Client’s funds or se- the Code of Ethics, please see Item 11 – Code of Ethics, Participation or curities, except for the limited authority as outlined in Item 15 – Custody. Interest in Client Transactions and Personal Trading. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the agreement, please see Item 12 – Investment Management Services Brokerage Practices. Claro provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and inter- action while providing discretionary and non-discretionary investment Use of Independent Managers - Claro may recommend that a Client utilize one or more unaffiliated investment managers or investment plat- management and consulting services. Claro works with each Client to forms (collectively “Independent Managers”) for a portion of a Client’s identify their investment goals and objectives as well as risk tolerance and investment portfolio. In such instances, the Client may be required to en- financial situation in order to create a portfolio strategy. Claro will then ter into an advisory agreement with the Independent Manager[s] that de- construct an investment portfolio, consisting of mutual funds and/or ex- fines the terms in which the Independent Manager[s] will provide invest- change-traded funds (“ETFs”) to achieve the Client’s investment goals. ment management and related services. The Advisor may also assist in The Advisor may also utilize individual stocks, bonds, options, non-traded the development of the initial policy recommendations and managing the REITs, margins, digital assets, and unaffiliated money managers (as de- ongoing Client relationship. The Advisor will perform initial and ongoing fined below) to meet the needs of its Clients. The Advisor may retain cer- oversight and due diligence over the selected Independent Manager[s] tain legacy investments based on portfolio fit and/or tax considerations, to ensure the Independent Managers’ strategies and target allocations or other reasons as identified between the Advisor and the Client. remain aligned with its clients’ investment objectives and overall best in- terests. The Client, prior to entering into an agreement with unaffiliated Claro’s investment approach is primarily long-term focused, but the Advi- investment manager[s] or investment platform[s], will be provided with sor may buy, sell or re-allocate positions that have been held for less than the Independent Manager’s Form ADV 2A (or a brochure that makes the one year to meet the objectives of the Client or due to market conditions. appropriate disclosures). Claro 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 Digital Assets – The Advisor will assist interested Clients with establish- ing a digital currency account through Fidelity Digital Asset Services, LLC restrictions on the types of investments to be held in their respective port- (“FDAS”). FDAS is a platform for Digital Assets which the Advisor offers as folio, subject to the acceptance by the Advisor. a possible portfolio management diversification strategy for Clients that express an interest in exposure to digital assets. “Digital Asset” shall mean Claro evaluates and selects investments for inclusion in Client portfolios a digital asset (also called a “cryptocurrency,” “virtual currency,” “digital only after applying their internal due diligence process. Claro may rec- currency,” or “digital commodity”), such as bitcoin, which is based on the ommend, on occasion, redistributing investment allocations to diversify cryptographic protocol of a computer network that may be (i) centralized the portfolio. Claro may recommend specific positions to increase sector or decentralized, (ii) closed or open-source, and (iii) used as a medium of or asset class weightings. The Advisor may recommend employing cash exchange and/or store of value. Clients will establish a Digital Asset ac- positions as a possible hedge against market movement. Claro may rec- count and transfer funds into an account opened on the FDAS platform. ommend selling positions for reasons that include, but are not limited to, 04 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure tion gathering process and enter into an advisory agreement with Claro Non-Purpose Loans – When deemed to be in the Client’s best interest, the Advisor will introduce Clients to available non-purpose loan programs prior to receiving ongoing investment management services from Claro. (“Lending Program”) through UPTIQ, Inc. (“UPTIQ”), an unaffiliated inter- net-based lending platform. In such instances, the Client’s assets in their Clients who engage through CGP typically: account[s] at the Custodian will be utilized as collateral for a non-purpose loan. The recommendation of a Lending Program presents a conflict of in- • Complete an information gathering process with Claro personnel terest as the Advisor will continue to receive investment advisory fees for • Enter into an advisory agreement with Claro managing the collateralized assets in the Client’s account[s]. Clients are • Are assigned to a Claro advisory professional for ongoing relation- not obligated to engage the Advisor for the Lending Program through UP- ship management and investment advice TIQ. For additional information related to the risks involved non-purpose loans, please see Item 8 – Methods of Analysis, Investment Strategies and Claro has financial incentives associated with the CGP, which create con- Risk of Loss. For additional information related to the Advisor’s relation- flicts of interest. Additional information regarding these conflicts and re- ship with UPTIQ, please see Item 10 – Other Financial Industry Activities lated compensation is described in Item 14. and Affiliations. Portfolio Boost™ Financial Planning and Consulting Services Claro offers a portfolio overlay service referred to as Portfolio Boost™, Claro will typically provide a variety of financial planning services to indi- which can include services such as: viduals and families, pursuant to a written financial planning or consulting agreement. Services are offered in several areas of a Client’s financial sit- • Cash management and yield optimization uation, depending on their goals and objectives. Tax-aware portfolio monitoring and implementation support • • Automated rebalancing and portfolio adjustments Generally, such financial planning services will involve preparing a finan- • Household-level portfolio coordination and oversight cial plan or rendering a financial consultation based on the Client’s fi- • Technology-enabled portfolio monitoring and operational support nancial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment plan- Portfolio Boost™ is an ongoing service applied at the Client relationship ning, retirement planning, personal savings, education savings, insurance level, pursuant to the terms of the Client’s advisory agreement, and gen- needs and other areas of a Client’s financial situation. erally supports the Advisor’s investment management services. Portfolio Boost™ is offered either as a standalone service, as part of CGP, or may not A financial plan developed for or financial consultation rendered to the be provided to a Client at all, depending on the Client’s suitability, objec- Client will usually include general recommendations for a course of ac- tives, and agreed upon services. Claro has financial incentives associated tivity or specific actions to be taken by the Client. For example, recom- with Portfolio Boost™, which create conflicts of interest. Additional infor- mendations may be made that the Client start or revise their investment mation regarding these conflicts and related compensation is described programs, commence or alter retirement savings, establish education in Item 14. savings and/or charitable giving programs. Claro may also refer Clients Claro Intelligent Strategies™ to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor Claro offers proprietary and/or internally managed investment strategies will provide a written summary of Client’s financial situation, observations, collectively referred to as Claro Intelligent Strategies™. These strategies and recommendations. For consulting or ad-hoc engagements, the Advi- include, among others: sor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information • Claro Personalized Indexing™ and documents requested are provided promptly. • Claro Lifestyle Protection™ • Claro Enhanced Treasuries™ Financial planning and consulting recommendations pose a potential • Claro Hedged Equity™ conflict between the interests of the Advisor and the interests of the Cli- ent. For example, the Advisor has an incentive to recommend that Clients Claro Intelligent Strategies™ may be applied to a portion of a Client’s engage the Advisor for investment management services or to increase portfolio based on suitability, Client objectives, risk tolerance, and the ad- the level of investment assets with the Advisor, as it would increase the ad- visor’s fiduciary judgment. Clients are not required to invest in Claro Intel- visory fees paid to the Advisor. Clients are not obligated to implement any ligent Strategies™. As described in Item 5, an additional fee may apply to recommendations made by the Advisor or maintain an ongoing relation- assets invested in Claro Intelligent Strategies™. Claro has financial incen- ship with the Advisor. If the Client elects to act on any of the recommenda- tives associated with Claro Intelligent Strategies™, which create conflicts tions made by the Advisor, the Client is under no obligation to implement of interest. Additional information regarding these conflicts and related the transaction through the Advisor. compensation is described in Item 14. Retirement Plan Advisory Services Claro Growth Program™ (“CGP”) Claro offers a program referred to as the Claro Growth Program™ (“CGP”). Claro provides retirement plan advisory services on behalf of the retire- CGP is a structured service model through which Claro engages, onboards, ment plans (each a “Plan”) and the company (the “Plan Sponsor”). The and services Clients. Clients who participate in CGP complete an informa- Advisor’s retirement plan advisory services are designed to assist the Plan 05 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure Sponsor in meeting its fiduciary obligations to the Plan and its Plan Partic- with the Client, will develop a strategy that seeks to achieve the Cli- ipants. Each engagement is customized to the needs of the Plan and Plan ent’s goals and objectives. Sponsor. Services generally include: • Asset Allocation – Claro will develop a strategic asset allocation that • Vendor Analysis is targeted to meet the investment objectives, time horizon, finan- • Employee Enrollment and Education Tracking cial situation and tolerance for risk for each Client. • Investment Policy Statement (“IPS”) Design and Monitoring • Investment Oversight Services (ERISA 3(21)) • Portfolio Construction – Claro will develop a portfolio for the Client • Performance Reporting that is intended to meet the stated goals and objectives of the Client. • Ongoing Investment Recommendation and Assistance • Benchmarking Services • Investment Management and Supervision – Claro will provide in- vestment management and ongoing oversight of the Client’s invest- These services are provided by Claro serving in the capacity as a fiduciary ment portfolio. under the Employee Retirement Income Security Act of 1974, as amended D . W R A P F E E P R O G R A M S (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Claro’s fiduciary status, the spe- Claro does not manage or place Client assets into a wrap fee program. In- cific services to be rendered and all direct and indirect compensation the vestment management services are provided directly by Claro. Advisor reasonably expects under the engagement. E . A S S E T S U N D E R M A N A G E M E N T Financial Institution Consulting Services Claro provides investment consulting services to brokerage customers As of March 19, 2026, Claro manages $1,407,659,698 in Client as- sets, $1,376,745,142 of which are managed on a discretionary basis and (herein “Brokerage Customers”) of Mutual Securities, Inc. (herein “MSI”) $30,914,556 on a non-discretionary basis. Clients may request more cur- who provide written consent requesting to receive the Advisor’s con- rent information at any time by contacting the Advisor. sulting services, pursuant to a written agreement with Claro. Consulting services are strictly on products where MSI serves as the broker-dealer. I T E M 5 . Please see Item 10 – Other Financial Industry Activities and Affiliations for additional details. Fees and Compensation Private Fund Advisor Services Claro Bain Technology Opportunities Fund (the “Fund”) is a private fund The following paragraphs detail the fee structure and compensation formed under the laws of the State of Delaware in 2021. The Advisor serves methodology for services provided by the Advisor. Each Client engaging as the investment manager of the Fund pursuant to the agreement be- the Advisor for services described herein shall be required to enter into tween the Fund and the Advisor. The manager has the exclusive right and one or more agreements with the Advisor. power to manage the operations of the Fund and in this capacity, it has A . F E E S F O R A D V I S O R Y S E R V I C E S engaged the Advisor to provide investment management services for the I n v e s t m e n t M a n a g e m e n t S e r v i c e s Fund. Claro charges an annual investment advisory fee ranging from 0.50% to The Fund is a technology opportunities fund that seeks long term, value 1.50% of assets under management, depending on the scope of services, driven returns through capital appreciation, portfolio hedges, and expo- complexity of the relationship, level of assets to be managed, portfolio re- sure to high quality technology and cybersecurity companies throughout strictions, reporting requirements, and overall relationship with the Ad- the global market. visor. Relationships with multiple objectives, specific reporting require- ments, portfolio restrictions, and other complexities may be charged a Clients should refer to the Fund’s offering documents for more complete higher fee within this range. information on the investment objectives and qualifications. There is no assurance that the Fund and its strategies will achieve its investment ob- Investment advisory fees are typically paid quarterly, in advance of each jectives. Certain Clients of the Advisor may invest in the Fund. In these in- calendar quarter, pursuant to the terms of the Client agreement. Invest- stances, Clients will pay fees in accordance with the offering documents ment advisory fees are generally based on the market value of assets un- and will not pay any additional investment advisory fees to the Advisor on der management at the end of the prior calendar quarter. Investment ad- assets invested in the Fund. The Fund requires a minimum investment of visory fees for individual and/or self-directed 401(k) and 403(b) accounts $200,000. are paid quarterly in arrears and are based on the market value of assets under management at the end of each calendar quarter. Certain legacy C . C L I E N T A C C O U N T M A N A G E M E N T Clients may not be subject to the billing methodology stated above. Prior to engaging Claro to provide investment advisory services, each Cli- ent is required to enter into one or more agreements with the Advisor that The investment advisory fees are prorated from the inception date of the define the terms, conditions, authority and responsibilities of the Advisor account[s] to the end of the first quarter. Fees are negotiable at the sole and the Client. These services may include: discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held • Establishing an Investment Policy Statement – Claro, in connection in accounts managed by Claro will be independently valued by the Custo- 06 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure dian. Claro will conduct periodic reviews of the Custodian’s valuations to As noted in Item 4, the Advisor may implement a portion of a Client’s ensure accurate billing. investment portfolio utilizing one or more Independent Managers. The Client’s overall fees may include Claro’s investment advisory fee plus in- The Advisor’s fee is exclusive of, and in addition to, any applicable securi- vestment management fees and/or platform fees charged by the Inde- ties transaction fees, custody fees, Portfolio Boost™ fees, Claro Intelligent pendent Manager[s], as applicable. In certain cases, the Advisor and the Strategies™ fees, Independent Manager fees, and other related costs and Independent Manager will collect fees separately. The total blended fee, expenses described in Item 5.C below, which may be incurred by the Client. including the Advisor’s fee and the Independent Manager’s fee, will not exceed 3.00% annually. Portfolio Boost™ Fee Financial Planning and Consulting Services Portfolio Boost™ is a service offered for an additional fee, either as part of the Claro Growth Program™ service model or through separate enroll- Claro offers financial planning or consulting services on an hourly basis at ment by the Client’s advisor. The Portfolio Boost™ fee is: a rate of up to $300 per hour or on a fixed fee basis, which may be negotia- ble depending on the nature and complexity of each Client’s circumstanc- • Up to 0.06% annually es. An estimate for total hours and/or costs will be determined prior to es- • Billed monthly in arrears tablishing the advisory relationship. For these engagements, the Advisor • Applied across assets supported by the service, as defined in the Cli- shall complete all services within six (6) months. ent agreement, at the end of each month Claro may also offer financial planning and consulting services based Portfolio Boost™ fees are separate from, and in addition to, the Client’s on an annual retainer of up to $6,500 a year. Retainer fees are quoted at investment advisory fee and any applicable Claro Intelligent Strategies™ fees and may be waived at the sole discretion of the Advisor. the onset of the engagement and are fixed for at least one year. In gen- eral, fees for financial planning retainer arrangements may be negotiable depending on the nature and complexity of the services to be provided Claro Intelligent Strategies™ Fees and the overall relationship with the Advisor. Fees are billed quarterly, in Client assets that are placed and managed under the Claro Intelligent advance of each calendar quarter, unless the annual fee is below $1,200 Strategies™ are charged fees in addition to the investment advisory fees whereby the fees may be billed in advance for the year. disclosed above. The Claro Intelligent Strategies™ fee is: • Up to 0.12% annually Estate Planning - Clients are charged a separate flat fee ranging from $500 to $2,500 depending on the complexity and scope of services. Cla- • Billed monthly in arrears ro Advisors does not provide legal advice or draft legal documents. • Based on the assets invested in Claro Intelligent Strategies™ at the Retirement Plan Advisory Services end of each month Fees for retirement plan advisory services are charged an annual as- These fees are separate from, and in addition to, the Client’s investment set-based fee of up to 1.00%, billed quarterly, in advance of each calen- advisory fee and any applicable Portfolio Boost™ fee. These fees may be dar quarter, pursuant to the terms of the agreement. Retirement plan fees waived at the sole discretion of the Advisor. are based on the market value of assets under management at the end of the prior calendar quarter. The Advisor may also charge a flat fee of up to Claro Growth Program™ Fee Structure $40,000, billed quarterly, in advance. Fees are negotiable depending on Clients participating in the Claro Growth Program™ are subject to a bun- the size and complexity of the Plan. dled service model that includes Portfolio Boost™ as a core component. Financial Institution Consulting Services For CGP Clients: Claro receives a consulting fee based on the assets under MSI’s manage- • The Portfolio Boost™ fee of up to 0.06% annually applies to CGP Cli- ment from Brokerage Customers who have provided written consent to ent assets MSI to receive the consulting service from Claro. The consulting fee is cal- • Additional fees of up to 0.12% annually apply only to assets invested culated from the assets under MSI’s management as of the end of a cal- in Claro Intelligent Strategies™ endar quarter period multiplied by the annualized rate of 65 basis points. • Strategy fees are separate from and in addition to the Portfolio The initial fee is paid only after the completion of one full calendar quarter Boost™ fee period following the date of the executed agreement with MSI. • Such fees are billed monthly in arrears Private Fund Advisor Services The CGP is designed as a streamlined, bundled service model and may be Clients should refer to the Fund’s offering documents for more informa- offered at a lower overall fee structure than certain customized or legacy tion regarding the Fund’s fees. Qualified investors of the Fund may pay a advisory relationships. The total combined fees for Investment Advisory management fee, attributable to their interest in a particular Series, which Services, Portfolio Boost™, and Claro Intelligent Strategies™ within CGP is detailed in the offering documents. Clients should note that the fee may will not exceed 0.93% (93 basis points) annually for assets serviced under not be charged to the manager, investment manager, and affiliates and CGP, pursuant to the terms of the Client agreement. may be waived at the discretion of the fund’s manager. Use of Independent Managers B . F E E B I L L I N G 07 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure I n v e s t m e n t M a n a g e m e n t S e r v i c e s Financial Institution Consulting Services Investment advisory fees are calculated by the Advisor and deducted from MSI shall pay Claro for its consulting services on or before thirty (30) days the Client’s account[s] at the Custodian. Fees are calculated based on past the end of each calendar quarter. assets under management, as more specifically described in the Client Private Fund Advisor Services agreement. Clients should refer to the Fund’s offering documents for more informa- The Advisor shall send an invoice to the Custodian indicating the amount tion regarding the Fund’s fees. of the fees to be deducted from the Client’s account[s] at the beginning C . O T H E R F E E S A N D E X P E N S E S of the quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Cla- Clients may incur certain fees or charges imposed by third parties, other ro at the end of the prior calendar quarter. The amount due for 401(k) and than Claro, in connection with investment made on behalf of the Client’s 403(b) accounts is calculated by applying the quarterly rate (annual rate account[s]. The Client is responsible for all custody and securities execu- divided by 4) to the balance of the assets under management with Claro at tion fees charged by the Custodian, as applicable. The Advisor’s recom- the end of each calendar quarter. mended Custodian does not charge securities transaction fees for ETF and equity trades in a Client’s account, provided that the account meets the Portfolio Boost™ fees generally apply broadly across assets supported by terms and conditions of the Custodian’s brokerage requirements. How- the service. Claro Intelligent Strategies™ fees apply only to assets invest- ever, the Custodian typically charges for mutual funds and other types of ed in those strategies. Both services are charged monthly in arrears, based investments. The investment advisory fee charged by Claro is separate on the level of assets serviced and/or managed at the end of the month, and distinct from these custody and execution fees. Aside from trade exe- pursuant to the Client agreement. cution fees, the Custodian charges a prime brokerage trade away fee dis- cussed in Item 12 – Prime Brokerage. Clients will be provided with a statement, at least quarterly, from the Cus- In addition, all fees paid to Claro for investment advisory services are todian reflecting deduction of the investment advisory fee. Clients are separate and distinct from the expenses charged by mutual funds and urged to also review and compare the statement from the Custodian, as ETFs to their shareholders, if applicable. These fees and expenses are the Custodian does not perform a verification of fees. Clients provide writ- described in each fund’s prospectus. These fees and expenses will gen- ten authorization permitting advisory fees to be deducted by Claro to be erally be used to pay management fees for the funds, other fund ex- paid directly from their account[s] held by the Custodian as part of the penses, account administration (e.g., custody, brokerage and account investment advisory agreement and separate account forms provided by reporting), and a possible distribution fee. A Client could invest in these the Custodian. products directly, without the services of Claro, but would not receive the services provided by Claro which are designed, among other things, Use of Independent Managers to assist the Client in determining which products or services are most For Client accounts implemented through an Independent Manager, the appropriate to each Client’s financial situation and objectives. Accord- Client’s overall fees may include Claro’s investment advisory fee (as noted ingly, the Client should review both the fees charged by the fund[s] and above) plus investment management fees and/or platform fees charged the fees charged by Claro to fully understand the total fees to be paid. by the Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may assume responsibility for cal- D . A D V A N C E P A Y M E N T O F F E E S A N D T E R M I N A T I O N culating the Client’s fees and deduct all fees from the Client’s account[s]. Investment Management Services Financial Planning and Consulting Services Claro is compensated for its services in advance of the quarter in which Project-based planning and consulting engagements are invoiced by the the investment advisory services are rendered. Either party may termi- Advisor and are due upon receipt of the agreed-upon deliverable[s]. An- nate an investment advisory agreement, at any time, by providing written nual/Ongoing Retainer fees are billed at a fixed annual rate, and generally notice to the other party. The Client shall be responsible for investment payable quarterly upon completion of the initial financial plan and there- advisory fees up to and including the effective date of termination. Upon after at the beginning of each calendar quarter. The Advisor will provide termination, the Advisor will refund any unearned, prepaid investment ad- a detailed invoice to the Client regarding amounts due pursuant to their visory fees from the effective date of termination to the end of the quarter. financial planning agreement. The Client’s investment advisory agreement with the Advisor is non-trans- ferable without Client’s prior consent. Estate Planning - Fees are invoiced directly and not deducted from advi- Portfolio Boost and Claro Intelligent Strategies sory accounts. Initial deposit or the partial fee is billed in advance, upon execution of the agreement. The remaining balance is billed upon delivery Portfolio Boost and Claro Intelligent Strategies fees are billed monthly in of the final estate planning summary or other agreed-upon deliverables. arrears for services rendered. Either party may terminate the investment advisory agreement, or the applicable service or strategy authorization, Retirement Plan Advisory Services pursuant to the terms of the Client agreement. Upon termination, the Cli- Fees may be directly invoiced to the Plan Sponsor or deducted from the ent shall be responsible for fees earned through the effective date of ter- assets of the Plan, depending on the terms of the retirement plan advisory mination. Because Portfolio Boost and Claro Intelligent Strategies fees are agreement. billed in arrears, no refund is typically required unless otherwise provided in the Client agreement. 08 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure Use of Independent Managers In the event that a Client should wish to terminate their relationship with By-Side Management the Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and the Independent Man- Claro does not charge performance-based fees for its investment advisory ager. Claro will assist the Client with the termination and transition as ap- services. The fees charged by Claro are as described in Item 5 above and propriate. are not based upon the capital appreciation of the funds or securities held by any Client. Financial Planning and Consulting Services Claro may be compensated for its financial planning and consulting ser- Claro does not manage any proprietary investment funds or limited part- vices in advance of services rendered, as described above. Either party nerships (for example, a mutual fund or a hedge fund) and has no financial may terminate a planning or consulting agreement at any time by provid- incentive to recommend any particular investment options to its Clients. ing advance written notice to the other party. In addition, the Client may also terminate the agreement within five (5) business days of signing the ITEM 7. Advisor’s financial planning or consulting agreement at no cost to the Cli- ent. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will Types of Clients be due and payable by the Client. Refunds will be given on a pro-rata basis. The Client’s financial planning agreement with the Advisor is non-trans- Claro offers investment advisory services to individuals, high net worth ferable without Client’s prior consent. individuals, trusts, estates, businesses, and retirement plans. These Retirement Plan Advisory Services amounts may change over time and are updated at least annually by the Advisor. The amount of each type of Client is available on Claro’s Form ADV Claro is compensated for its services at the beginning of the quarter before Part 1A. These amounts will change over time. Claro generally does not im- advisory services are rendered. Either party may terminate the retirement pose a minimum account size for establishing a relationship. plan advisory agreement, at any time, by providing advance written notice to the other party. Upon termination, the Client shall be responsible for I T E M 8 . investment advisory fees up to and including the effective date of termi- nation. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the Advisor is non-trans- ferable without the Client’s prior consent. Methods of Analysis, Investment Strategies and Risk of Loss Financial Institution Consulting Services A . M E T H O D S O F A N A L Y S I S Either party may terminate the consulting agreement by providing thirty Claro primarily employs fundamental analysis in developing investment (30) days advance written notice to the other party. The Advisor will be strategies for its Clients. Research and analysis from Claro are derived from entitled to fees up to the date of termination. numerous sources, including financial media companies, third-party re- search materials, Internet sources, and review of company activities, includ- Private Fund Services ing annual reports, prospectuses, press releases and research prepared by Clients should refer to the Fund’s offering documents for more in- others. formation regarding the Fund’s fees and termination provisions. Fundamental analysis utilizes economic and business indicators as invest- ment selection criteria. These criteria are generally ratios and trends that E . C O M P E N S A T I O N F O R S A L E S O F S E C U R I T I E S may indicate the overall strength and financial viability of the entity being Claro does not buy or sell securities to generate commission income for analyzed. Assets are deemed suitable if they meet certain criteria to indicate any Client accounts. Claro is compensated through the fees noted above. that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential invest- As described above and in Item 4, Claro has a financial incentive to include ment, it does not guarantee that the investment will increase in value. Assets Clients in CGP, which includes Portfolio Boost™ as a core component, and meeting the investment criteria utilized in the fundamental analysis may to recommend allocations to Claro Intelligent Strategies™ that generate lose value and may have negative investment performance. additional fees. Claro addresses this conflict by evaluating recommen- dations based on the Client’s best interest, disclosing applicable fees in The Advisor monitors these economic indicators to determine if adjustments advance, and allowing Clients flexibility in strategy selection. Additional to strategic allocations are appropriate. More details on the Advisor’s review details regarding these services are described in Item 4. process are included in Item 13 - Review of Accounts. As noted above, Claro generally employs a long-term investment approach I T E M 6 . for its Clients, as consistent with their financial goals. Claro will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs Performance-Based Fees and Side- 09 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure of Clients. At times, Claro may also buy and sell positions that are more short- possible loss of principal. The price of the mutual funds will fluctuate with term in nature, depending on the goals of the Client and/or the fundamen- the value of the underlying securities that make up the funds. The price tals of the security, sector or asset class. of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund Artificial Intelligence - AI is used as an umbrella term that encompasses a purchased later that same day. broad spectrum of different technologies and applications. Claro defines AI Options Contracts as computer systems able to perform tasks that normally require human in- telligence, such as visual perception, speech recognition, decision-making, Investments in options contracts have the risk of losing value in a relative- and translation between languages, more commonly known as generative AI. ly short period of time. Option contracts are leveraged instruments that al- As part of our investment management process the Firm uses AI as part of its low the holder of a single contract to control many shares of an underlying investment, research or decision process. stock. This leverage can compound gains or losses. B . R I S K O F L O S S Margin Borrowings Investing in securities involves certain investment risks. Securities may The use of short-term margin borrowings may result in certain additional fluctuate in value or lose value. Clients should be prepared to bear the po- risks to a Client. For example, if securities pledged to brokers to secure a tential risk of loss. Claro will assist Clients in determining an appropriate Client’s margin accounts decline in value, the Client could be subject to strategy based on their tolerance for risk and other factors noted above. a “margin call” pursuant to which it must either deposit additional funds However, there is no guarantee that a Client will meet their investment with the broker or be the subject of mandatory liquidation of the pledged goals. securities to compensate for the decline in value. Real Estate Investment Trusts (“REITs”) Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon, tolerance for risk and other factors Investing in Real Estate Investment Trusts (“REITs”) involves certain dis- to develop an appropriate strategy for managing a Client’s account. Client tinct risks in addition to those risks associated with investing in the real participation in this process, including full and accurate disclosure of re- estate industry in general. For example, equity REITs may be affected by quested information, is essential for the analysis of a Client’s account[s]. changes in the value of the underlying property owned by the REITs, while The Advisor shall rely on the financial and other information provided by mortgage REITs may be affected by the quality of credit extended. REITs the Client or their designees without the duty or obligation to validate the are subject to heavy cash flow dependency, default by borrowers and accuracy and completeness of the provided information. It is the respon- self-liquidation. REITs, especially mortgage REITs, are also subject to in- sibility of the Client to inform the Advisor of any changes in financial con- terest rate risk (i.e., as interest rates rise, the value of the REIT may decline). dition, goals or other factors that may affect this analysis. Digital Assets Risks The risks associated with a particular strategy are provided to each Cli- Digital assets are highly speculative and volatile investments that may ent in advance of investing Client accounts. The Advisor will work with become illiquid at any time. Digital assets are loosely regulated. A Client each Client to determine their tolerance for risk as part of the portfolio could lose the entire value of their investment in digital assets and is only construction process. Following are some of the risks associated with the suitable for Clients with a high risk tolerance. Advisor’s investment approach: Special Purpose Acquisition Company Market Risks A Special Purpose Acquisition Company (“SPAC”) is a company with no The value of a Client’s holdings may fluctuate in response to events specif- commercial operations that is formed strictly to raise capital through an ic to companies or markets, as well as economic, political, or social events initial public offering (IPO) for the purpose of acquiring an existing com- in the U.S. and abroad. This risk is linked to the performance of the overall pany going public. SPACs may lack trading history, a track record of re- financial markets. porting to investors, and widely available research coverage. IPOs are sub- ject to extreme price volatility and speculative trading. In addition, IPOs ETF Risks may share similar illiquidity risks of private equity and venture capital. The The performance of ETFs is subject to market risk, including the possi- ownership of many IPOs often includes large holdings by venture capital ble loss of principal. The price of the ETFs will fluctuate with the price of and private equity investors who seek to sell their shares in the public the underlying securities that make up the funds. In addition, ETFs have market in the months following an IPO when shares restricted by lock-up a trading risk based on the loss of cost efficiency if the ETFs are traded are released, causing greater volatility and possible downward pressure actively and a liquidity risk if the ETFs has a large bid-ask spread and low during the time that locked-up shares are released. trading volume. The price of an ETF fluctuates based upon the market Private Funds movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one Private investment funds generally involve various risk factors, including, point in the day may have a different price than the same ETF purchased but not limited to, potential for complete loss of principal, liquidity con- or sold a short time later. straints and lack of transparency. A complete discussion of these risks are set forth in each fund’s respective offering documents, which will be Mutual Fund Risks provided to each Client for review and consideration. Unlike liquid invest- The performance of mutual funds is subject to market risk, including the ments that a Client may maintain, private investment funds do not provide 10 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure daily liquidity or pricing. attitude of speculators and investors. Non-Purpose Loans Past performance is not a guarantee of future returns. Investing in se- curities and other investments involve a risk of loss that each Client Non-Purpose Loans carry a number of risks, including but not limited to should understand and be willing to bear. Clients are reminded to dis- the risk of a market downturn, tax implications if collateralized securities cuss these risks with the Advisor. are liquidated, and an increase in interest rates. A decline in the market value of collateralized assets held in the account[s] at the Custodian, may result in a reduction in the draw amount of the Client’s loan, a demand For more information on the Advisor’s investment management services, from the Lending Program that the Client deposit additional funds or se- please contact us at (800) 604-2838 or via email at info@claroadvisors. curities in the Client’s collateral account[s], or a forced sale of securities in com. the Client’s collateral account[s]. Artificial Intelligence I T E M 9 . The use of artificial intelligence-based solutions may rely on historical data, assumptions, or third-party inputs that are incomplete, outdated, inaccu- Disciplinary Information rate, or misleading, and may not fully reflect current market conditions or issuer-specific developments. In addition, such tools may incorporate modeling limitations, simplified assumptions, or unintended biases and may fail to anticipate unusual or rapidly changing market events, which There are no legal, regulatory or disciplinary events involving Claro or any of its management persons. Claro values the trust Clients place in the Advisor. The Advisor encourages you to perform the requisite due could result in under-performance or losses. diligence on any advisor or service provider the Client engages. The back- grounds of the Advisor and its Advisory Persons are available on the In- Structured Products vestment Adviser Public Disclosure website at www.adviserinfo.sec.gov by Structured products are securities derived from another asset, such as a searching with the Advisor’s firm name or CRD# 160294. security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside I T E M 1 0 . participation in the reference asset. Structured products are senior unse- cured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the is- suer does not affect or enhance the likely performance of the investment Other Financial Industry Activities and Affiliations other than the ability of the issuer to meet its obligations. Any payments Insurance Agency Affiliations due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, Certain Advisory Persons are licensed insurance professionals. Implemen- may be adversely impacted if the issuer’s credit rating is downgraded. tations of insurance recommendations are separate and apart from one’s Some structured products offer full protection of the principal invested, role with the Advisor. As an insurance professional, the Advisory Person others offer only partial or no protection. will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons Investors may be sacrificing a higher yield to obtain the principal guaran- are not required to offer the products of any particular insurance compa- tee. In addition, the principal guarantee relates to nominal principal and ny. Commissions generated by insurance sales do not offset investment does not offer inflation protection. An investor in a structured product advisory fees. This presents a conflict of interest in recommending certain never has a claim on the underlying investment, whether a security, zero products of the insurance companies. Clients are under no obligation to coupon bond, or option. There may be little or no secondary market for implement any recommendations made by the Advisor or Advisory Per- the securities and information regarding independent market pricing for sons. the securities may be limited. This is true even if the product has a ticker Financial Institution and Consulting Services symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in Claro has an agreement with MSI to provide investment consulting ser- the account (e.g., income may be taxed as ordinary income even though vices to Brokerage Customers, as noted in Item 4 above. MSI compen- payment is not received until maturity). Structured CDs that are insured sates Claro for providing consulting services to Brokerage Customers who by the FDIC are subject to applicable FDIC limits. have purchased products through MSI. This consulting arrangement does not include assuming discretionary authority over Brokerage Customers’ Precious Metal Risks brokerage accounts or the monitoring of securities. These consulting ser- Metals such as Gold, Silver, Platinum, or Palladium Bullion backed “elec- vices offered to Brokerage Customers includes a general review of Broker- tronic shares” (not physical metals) may be negatively impacted by sever- age Customers’ investment holdings, which will result in Claro’s Advisory al unique factors. These factors include (1) large sales by the official sector Persons making specific securities recommendations or offering general which own a significant portion of aggregate world holdings in gold and investment advice. other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the This relationship presents conflicts of interest. Conflicts are mitigated 11 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure by Brokerage Customers consenting to receive consulting services from reporting procedures. When trading for personal accounts, Supervised Claro. In addition, Claro will not accept or bill for additional compensation Persons of Claro have a conflict of interest if trading in the same securities. on asset under MSI’s management, beyond the consulting fees disclosed The fiduciary duty to act in the best interest of its Clients can be violated in Item 5 above. Advisory Persons of the Advisor will not engage or hold if personal trades are made with more advantageous terms than Client itself as a registered representative of MSI, as Advisory Persons are not trades, or by trading based on material non-public information. This risk registered to conduct commission-based activities under a broker-dealer. is mitigated by Claro requiring reporting of personal securities trades by its Supervised Persons for review by the Supervised Person’s supervisor or UPTIQ, Inc. (“UPTIQ”) the Chief Compliance Officer (“CCO”). The Advisor has also adopted writ- Claro has engaged UPTIQ, an unaffiliated internet-based lending platform, ten policies and procedures to detect the misuse of material, non-public to provide Clients with a network of lenders who can assist with different information. types of personal and business loans available through non-purpose loan D . P E R S O N A L T R A D I N G A T S A M E T I M E A S C L I E N T programs. When a Client utilizes UPTIQ’s platform, UPTIQ is not compen- sated by the Client, and is only compensated by the lender. UPTIQ offers a While Claro allows Supervised Persons to purchase or sell the same se- share of its compensation from the lender with the Advisor. This relation- curities that may be recommended to and purchased on behalf of Clients, ship creates a conflict of interest as the Advisor has a financial incentive such trades are typically aggregated with Client orders or traded after- for Clients to utilize the UPTIQ platform. Clients are under no obligation to ward. At no time, will Claro or any Supervised Person of Claro, transact in utilize the UPTIQ platform. any security to the detriment of any Client. I T E M 1 1 . I T E M 1 2 . Brokerage Practices A . R E C O M M E N D A T I O N O F C U S T O D I A N [ S ] Claro does not have discretionary authority to select the broker-dealer/ custodian for custody and execution services. The Client will engage the Code of Ethics, Participation or Interest in Client Transactions and Personal Trading broker-dealer/custodian (herein the “Custodian”) to safeguard Client as- A . C O D E O F E T H I C S sets and authorize Claro to direct trades to the Custodian as agreed upon Claro has implemented a Code of Ethics (the “Code”) that defines the Ad- in the investment advisory agreement. Further, Claro does not have the visor’s fiduciary commitment to each Client. This Code of Ethics applies to discretionary authority to negotiate commissions on behalf of Clients on all persons associated with Claro (“Supervised Persons”). The Code was a trade-by-trade basis. The Client may also grant the Advisor limited au- developed to provide general ethical guidelines and specific instructions thority to place trades away from the Custodian. Please see Prime Broker- regarding the Advisor’s duties to the Client. Claro and its Supervised Per- age Authorization below. sons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Claro Supervised Persons to adhere not only to the spe- Where Claro does not exercise discretion over the selection of the Cus- cific provisions of the Code, but also to the general principles that guide todian, it may recommend the Custodian[s] to Clients for custody and the Code. The Code of Ethics covers a range of topics that may address execution services. Clients are not obligated to use the Custodian recom- employee ethics and conflicts of interest. To request a copy of the Code mended by the Advisor and will not incur any extra fee or cost associated of Ethics, please contact the Advisor at (800) 604-2838 or via email at with using a custodian not recommended by Claro. However, the Advisor info@claroadvisors.com. may be limited in the services it can provide if the recommended Custodi- an is not utilized. Claro may recommend the Custodian based on criteria B . P E R S O N A L T R A D I N G W I T H M A T E R I A L I N T E R E S T such as, but not limited to, reasonableness of commissions charged to the Claro allows Supervised Persons to purchase or sell the same securities Client, services made available to the Client, and its reputation and/or the that may be recommended to and purchased on behalf of Clients. Claro location of the Custodian’s offices. does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Claro generally recommends that Clients establish their account[s] at Claro does not have a material interest in any securities traded in Client National Financial Services LLC and Fidelity Clearing & Custody Solutions accounts. (collectively, and together with all affiliates, “Fidelity”). Fidelity serves as a “qualified custodians”, FINRA registered broker-dealers and member SIPC. C . P E R S O N A L T R A D I N G I N S A M E S E C U R I T I E S A S C L I E N T S Claro maintains an institutional relationship with Fidelity, whereby the Ad- Claro allows Supervised Persons to purchase or sell the same securities visor receives economic benefits. Please see Item 14 below. that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients Claro will also recommend that Clients establish their account[s] at presents a potential conflict of interest that, as fiduciaries, must be dis- Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-deal- closed and mitigated through policies and procedures. As noted above, er and member SIPC. Schwab will serve as the Client’s “qualified custo- the Advisor has adopted a Code of Ethics, which addresses insider trad- dian”. Claro maintains an institutional relationship with Schwab, whereby ing (material non-public information controls) and personal securities the Advisor receives economic benefits from Schwab. Please see Item 14 12 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure A . F R E Q U E N C Y O F R E V I E W S below. Securities in Client accounts are monitored on a regular and continuous Following are additional details regarding the brokerage practices of the basis by Advisory Persons and periodically by the CCO. Formal reviews Advisor: are generally conducted at least annually or more frequently depending on the needs of the Client. Soft Dollars B . C A U S E S F O R R E V I E W S • Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted the broker-dealer/custodian in exchange for research and other services. Claro does not participate in soft dollar programs sponsored or offered more frequently at the Client’s request. Accounts may be reviewed as a by any broker-dealer/custodian. However, the Advisor receives certain result of major changes in economic conditions, known changes in the economic benefits from the Custodian. Please see Item 14 below. Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Claro if changes oc- Brokerage Referrals cur in Client’s personal financial situation that might adversely affect the • Claro does not receive any compensation from any third party in connection Client’s investment plan. Additional reviews may be triggered by material with the recommendation for establishing an account. market, economic or political events. Directed Brokerage C . R E V I E W R E P O R T S • All Clients are serviced on a “directed brokerage basis”, where Claro will The Client will receive brokerage statements no less than quarterly from place trades within the established account[s] at the Custodian designat- ed by the Client. Further, all Client accounts are traded within their respec- the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access tive account[s]. The Advisor will not engage in any principal transactions to the Custodian’s website so that the Client may view these reports and (i.e., trade of any security from or to the Advisor’s own account) or cross their account activity. Client brokerage statements will include all posi- transactions with other Client accounts (i.e., purchase of a security into tions, transactions and fees relating to the Client’s account[s]. The Advisor one Client account from another Client’s account[s]). Claro will not be ob- may also provide Clients with periodic reports regarding their holdings, al- ligated to select competitive bids on securities transactions and does not locations, and performance. have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. I T E M 1 4 . Prime Brokerage • The Advisor may execute securities transactions either through the Cus- todian or through another unaffiliated broker-dealer in connection with a prime brokerage relationship established with the Custodian. Should a Cli- Client Referrals and Other Compensation ent’s account[s] make use of prime brokerage, the Client is required to ex- A . C O M P E N S A T I O N R E C E I V E D B Y C L A R O ecute additional agreement[s] with the Custodian authorizing the Advisor CGP, Portfolio Boost™, and Claro Intelligent Strategies™ to trade-away from and settle to the Client’s established account[s] at the Custodian. The Custodian will charge an additional trade-away fee for these Claro has financial incentives to enroll Clients in the Claro Growth Pro- transactions in addition to the normal securities transaction costs. gram™ (“CGP”), as CGP includes Portfolio Boost™ and may result in the use of Claro Intelligent Strategies™, both of which is inclusive of a platform B . A G G R E G A T I N G A N D A L L O C A T I N G T R A D E S fee that generates additional revenue for the Advisor. This presents a con- The primary objective in placing orders for the purchase and sale of securi- flict of interest, as Claro benefits financially from Clients participating in ties for Client accounts is to obtain the most favorable net results taking into these services and strategies. Claro addresses this conflict by disclosing account such factors as 1) price, 2) size of the order, 3) difficulty of execution, the applicable fees and conflicts, making recommendations based on the 4) confidentiality and 5) skill required of the Custodian. Claro will execute its Client’s best interest, not requiring Clients to use proprietary strategies as transactions through the Custodian as directed by the Client, unless other- a condition of receiving advisory services, and charging a combined fee for wise authorized by the Client through a trade-away agreement. For certain the bundled services that is generally lower than Claro’s standard invest- equity or ETF transactions, Claro may choose to aggregate orders in a block ment management fee schedule, for Clients not engaged in CGP. trade or trades when the same securities are purchased or sold through the Participation in Institutional Advisor Platform - Fidelity Custodian for multiple (discretionary) accounts. The Advisor transacts in securities that does not consistently advantage or disadvantage particular Claro has established an institutional relationship with Fidelity to assist the Client accounts. Advisor in managing Client account[s]. Access to the platform is provided at no charge to the Advisor. The Advisor receives access to software and relat- ed support without cost because the Advisor renders investment manage- I T E M 1 3 . ment services to Clients that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put Review of Accounts the interests of its Clients first. Clients should be aware, however, that the 13 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure receipt of economic benefits from a custodian creates a potential conflict of ing state securities requirements. Any such compensation shall be paid interest since these benefits may influence the Advisor’s recommendation solely from the investment advisory fees earned by the Advisor, and shall of this custodian over one that does not furnish similar software, systems not result in any additional charge to the Client. support, or services. I T E M 1 5 . Additionally, the Advisor may receive the following benefits from Fidelity: re- ceipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional partici- Custody pants; access to block trading which provides the ability to aggregate se- curities transactions and then allocate the appropriate shares to Client ac- The Advisor is authorized to deduct its advisory fees directly from Client ac- counts; and access to an electronic communication network for Client order counts maintained at a qualified custodian. Clients are required to maintain entry and account information. their assets with a qualified custodian that maintains custody of funds and securities and provides account statements directly to the Client. Clients Participation in Institutional Advisor Platform - Schwab should carefully review statements provided by the qualified custodian and Claro has established an institutional relationship with Schwab through its compare them to any reports provided by the Advisor. For more information “Schwab Advisor Services” unit, a division of Schwab dedicated to serving about custodians and brokerage practices, see Item 12 – Brokerage Prac- independent advisory firms like Claro. As a registered investment advisor tices. participating on the Schwab Advisor Services platform, Claro receives ac- cess to software and related support without cost because the Advisor ren- If a Client authorizes the Advisor to transfer funds between accounts, the ders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor Advisor may be deemed to have custody of those assets. To mitigate this risk, the Advisor and the qualified custodian have established procedures and many, but not all services provided by Schwab will benefit Clients. In designed to ensure that such transfers are made in accordance with the Cli- fulfilling its duties to its Clients, the Advisor endeavors at all times to put ent’s instructions. the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of As a result of advisory persons acting as trustee for certain Client accounts, interest since these benefits may influence the Advisor’s recommendation the Advisor is deemed to have custody of certain Client assets. The Advisor of this custodian over one that does not furnish similar software, systems engages an independent public accounting firm to conduct an annual sur- support, or services. prise examination of those assets in accordance with applicable regulatory requirements. The related reports are filed with the SEC and are publicly Services that Benefit the Client – Schwab’s institutional brokerage services available on the SEC’s Investment Adviser Public Disclosure website. include access to a broad range of investment products, execution of se- curities transactions, and custody of Client’s funds and securities. Through I T E M 1 6 . Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds Investment Discretion and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Claro generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent Services that May Indirectly Benefit the Client – Schwab provides partic- or approval from the Client. However, these purchases or sales may be ipating advisors with access to technology, research, discounts and other subject to specified investment objectives, guidelines, or limitations pre- services. In addition, the Advisor receives duplicate statements for Client viously set forth by the Client and agreed to by Claro. Discretionary author- accounts, the ability to deduct advisory fees, trading tools, and back-office ity will only be authorized upon full disclosure to the Client. The granting support services as part of its relationship with Schwab. These services are of such authority will be evidenced by the Client’s execution of an invest- intended to assist the Advisor in effectively managing accounts for its Cli- ment advisory agreement containing all applicable limitations to such au- ents, but may not directly benefit all Clients. thority. All discretionary trades made by Claro will be in accordance with each Client’s investment objectives and goals. Services that May Only Benefit the Advisor – Schwab also offers other ser- vices to Claro that may not benefit the Client, including: educational con- I T E M 1 7 . ferences and events, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of in- Voting Client Securities terest. Claro believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Claro does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will B . C O M P E N S A T I O N F O R C L I E N T R E F E R R A L S . assist in answering questions relating to proxies, however, the Client re- If a Client is introduced to the Advisor by either an unaffiliated or affiliated tains the sole responsibility for proxy decisions and voting. party (herein a “Promoter”), the Advisor compensates that Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any correspond- 14 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure I T E M 1 8 . Financial Information Neither Claro, nor its management has any adverse financial situations that would reasonably impair the ability of Claro to meet all obligations to its Clients. Neither Claro, nor any of its management persons, has been subject to a bankruptcy or financial compromise. Claro is not re- quired to deliver a balance sheet along with this Disclosure Brochure as the firm does not collect fees of $1,200 for services to be performed six months or more in the future. 15 Claro Advisors Inc. Form ADV Part 2A: Firm Brochure 100 High Street Suite 950 Privacy Policy Boston, MA 02110 (800) 604-2838 APRIL 30, 2026 www.claroadvisors.com O U R C O M M I T M E N T T O Y O U Claro Advisors Inc. (“Claro” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Claro (also referred to as “we”, “our” and “us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Claro does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable busi- ness purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. W H Y Y O U N E E D T O K N O W ? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. W H A T I N F O R M A T I O N D O W E C O L L E C T F R O M Y O U ? • Social security or taxpayer identification number • Assets and liabilities Income and expense • Name, address and phone number[s] • Investment activity • E-mail address[es] • Investment experience and goals • Account information (including other institutions) • W H A T I N F O R M A T I O N D O W E C O L L E C T F R O M O T H E R S O U R C E S ? • Custody, brokerage and advisory agreements • Account applications and forms Investment questionnaires and suitability documents • Other advisory agreements and legal documents • • Transactional information with us or others • Other information needed to service account H O W D O W E P R O T E C T Y O U R I N F O R M A T I O N ? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These in- clude such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Claro Advisors Inc. Privacy Notice 01  H O W D O W E S H A R E Y O U R I N F O R M A T I O N ? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis for Sharing Do we share? Can you limit? Servicing our clients Yes No We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial in- stitutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes No Not shared Claro does not disclose, and does not intend to disclose, personal information with non-af- filiated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Cla- ro or the Client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Yes Yes Your non-public personal information may be disclosed to you and persons that we be- lieve to be your authorized agent[s] or representative[s]. Information About Former Clients No Not shared Claro does not disclose and does not intend to disclose, non-public personal informa- tion to non-affiliated third parties with respect to persons who are no longer our Clients. S T A T E - S P E C I F I C R E G U L A T I O N S Massachusetts In response to Massachusetts law, the Client must “opt-in” to share non-public personal information with non-affil- iated third parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execu- tion of authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other written consent by the Client, as appropriate and consistent with applicable laws and regulations C H A N G E S T O O U R P R I V A C Y P O L I C Y We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, how- ever, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. A N Y Q U E S T I O N S ? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (800) 604-2838 or via email at info@claroadvisors.com. Claro Advisors Inc. Privacy Notice 02