Overview
- Headquarters
- Radnor, PA
- Total Firm Assets
- $1.1 billion
- Average High-Net-Worth Client Portfolio Size
- $2.5 million
- Minimum Account Size
- $1,000,000
Fee Structure
Primary Fee Schedule (ADV 2A - FIRM DISCLOSURE BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.50% |
| $1,000,001 | $3,000,000 | 1.25% |
| $3,000,001 | $4,000,000 | 0.90% |
| $4,000,001 | $5,000,000 | 0.80% |
| $5,000,001 | and above | Negotiable |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $57,000 | 1.14% |
| $10 million | Negotiable | Negotiable |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- High-Net-Worth Share of Firm Assets
- 82.16%
- Number of High-Net-Worth Clients
- 349
- Total Client Accounts
- 803
- Discretionary Accounts
- 803
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Regulatory Filings
- SEC CRD Number
- 286168
Additional Brochure: ADV 2A - FIRM DISCLOSURE BROCHURE (2026-06-25)
View Document Text
Form ADV Part 2A — Clearview Financial Partners, LLC
Item 1 — Cover Page
Registered as Clearview Financial Partners, LLC | CRD No. 286168
Doing Business As: Clearview Financial Partners
Form ADV Part 2A - Disclosure Brochure
100 Matsonford Road – Building #5, Suite 110 | Radnor, PA 19087
Phone: (610) 293-9211
June 15, 2026
NOTICE TO PROSPECTIVE CLIENTS: READ THIS DISCLOSURE BROCHURE IN ITS ENTIRETY
This brochure provides information about the qualifications and business practices of Clearview Financial Partners.
If you have any questions about the contents of this brochure, please contact us at (610) 293-9211 or
david@cvfpartners.com. The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority. Additional information about Clearview
Financial Partners is also available on the SEC's website at www.adviserinfo.sec.gov. Registration does not imply a
certain level of skill or training.
Clearview Financial Partners, LLC
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Item 2 — Material Changes
This Item discusses only the specific material changes made to this Brochure since the last annual update and provides
clients with a summary of those changes. We will also reference the date of our last annual update of our Brochure.
We will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days
of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material
changes as necessary. We will further provide you with a new Brochure as necessary based on changes or new
information, at any time, without charge.
Currently, our Disclosure Brochure may be requested by contacting us at (610) 293-9211. Additional information
about Clearview Financial Partners is available via the SEC’s website at www.adviserinfo.sec.gov.
The following changes are not material because affected clients have already been made aware of such changes where
the From ADV 2A is not the exclusive means of client disclosure.
• The termination of the broker/dealer relationship previously described throughout the brochure;
• The addition of advisory services to and management of a private pooled investment vehicle, Clearview Fund I LP; and,
• Corresponding updates to fee, conflict, custody, and performance-fee disclosures. CCO to finalize the material-changes
summary and date once the underlying facts are confirmed.
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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 – Fee and Compensation ……………………………………………………………………………….….…... 9
Item 6 – Performance-Based Fees and Side-by-Side Management ……………………………………………...…… 14
Item 7 – Types of Clients …………………………………………………………………………………….…..…… 14
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ………………………………..….………... 14
Item 9 – Disciplinary Information ……………………………………………………………………………..….….. 21
Item 10 – Other Financial Industry Activities and Affiliations ……………………………………….….……….….. 22
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .……….………..… 22
Item 12 – Brokerage Practices ……………………………………………………………………….………….….… 23
Item 13 – Review of Accounts ……………………………………………………………………………….…..…... 24
Item 14 – Client Referrals and Other Compensation ……………………………………………….………….…..… 25
Item 15 – Custody …………………………………………………………………………………….………..…….. 25
Item 16 – Investment Discretion ………………………………………………………………….…………..……… 25
Item 17 – Voting Client Securities …………………………………………………………….……………..………. 26
Item 18 – Financial Information ……………………………………………………………….……………..……… 26
Appendix-1 Wrap Fee Program Brochure ……………………………………………………………….…….…… 27
Privacy Policy ………………………………………………………………………………………………………. 34
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Item 4 — Advisory Business
The Firm
Clearview Financial Partners, LLC (“Clearview Financial Partners,” the “Firm,” or the “Adviser”) is an independent
registered investment adviser that offers asset management and financial planning services. The Firm’s investment
adviser representatives (“IARs”) are also insurance agents appointed with various insurance carriers to offer insurance
products in a separate capacity.
• The Firm offers discretionary asset management services on a wrap or non-wrap fee basis as further described
below.
• The Firm does not directly hold securities or have direct access to client assets, except with respect to the private
fund described below, for which the Firm is deemed to have custody. Client securities accounts are maintained
at one or more qualified custodians.
Principal Owner
David L. Fitzgerald (CRD No. 1927550) is the principal owner with a 100% ownership interest. He also serves as the
President and Chief Compliance Officer (CCO). Mr. Fitzgerald has worked in the financial services field since 1989
after graduating from Drexel University with dual degrees in Finance and Marketing.
Asset Management
IARs of Clearview Financial Partners primarily provide discretionary fee-based asset management services to
individuals, high-net-worth individuals, and small businesses (client approval is required in advance of any non-
discretionary transaction). The Firm provides advice on the purchase and sale of various types of investments, such
as mutual funds, exchange-traded funds (“ETFs”), real estate investment trusts (“REITs”), equities, and fixed income
securities. Non-discretionary fee-based asset management services are also available.
Clearview Financial Partners offers an open-architecture custodial account in which IARs directly select and manage
specific securities based on a client’s investment profile. The Firm also offers advisory programs in which the
underlying investments are selected and managed by independent professional portfolio managers. Accounts are
reviewed on a regular basis and rebalanced as necessary according to each client’s investment profile.
The account minimum for an asset management account is generally $1,000,000; however, the Firm reserves the right
to open an account for a lesser amount at the discretion of management.
Assets Under Management
Discretionary
Non-Discretionary
$1,058,194,989
$0.00
Wrap Fee Program
In a wrap fee account, your advisory fee and transaction costs are combined into one annual fee (usually a percentage
of your assets). This simplifies your billing and makes your total cost predictable.
Important considerations:
• Single Fee: Clients are charged one all-inclusive advisory fee, typically expressed as a percentage of assets
under management (AUM). This fee covers both the advisory services provided by the investment advisor
and the transaction costs incurred when buying or selling securities within the client’s account.
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• Simplicity and Predictability: The wrap fee simplifies billing by consolidating various fees into one predictable
charge, making it easier for clients to understand their costs.
• Cost Predictability: Clients benefit from knowing their total investment costs upfront, without worrying about
fluctuating transaction fees.
• Aligned Interests: This fee structure can align the advisor’s interests with those of the client, as the advisor is
compensated based on the client's total assets managed rather than the volume of trades executed.
• Comprehensive Services: Clients receive a bundle of services, which may include portfolio management,
financial planning, and ongoing advisory support.
• Cost Comparison: Depending on the level of trading activity, a wrap fee program may be more or less
expensive than paying for advisory services and transaction fees separately. Clients with low trading activity
might end up paying more under a wrap fee structure.
• Reverse Churning Risk: There is a potential conflict of interest known as "reverse churning," where an advisor
might limit trading activity to maintain profitability under the fixed wrap fee, possibly compromising the active
management of the account.
• Active Traders: For clients who engage in frequent trading, a wrap fee program can be cost-effective, as it
may result in lower overall fees compared to paying individual transaction charges.
• Passive Investors: Clients with less active trading strategies might find that the wrap fee exceeds what they
would pay if they were charged separately for advisory services and each transaction.
Clients should evaluate their trading patterns and investment strategy to determine if a wrap fee program is financially
beneficial. It's important to assess the range of services included in the wrap fee and ensure they align with personal
financial needs and goals. A wrap fee program offers a streamlined and predictable fee structure that can be
advantageous for clients with higher trading activity. However, it requires careful consideration of the client’s
investment behavior and financial goals to ensure it provides the best value.
Wrap Fee Program – Other Fees
While the wrap fee covers advisory services and transaction costs, it does not include the expenses charged by mutual
funds, ETFs, or other investment products within the portfolio. These underlying fund expenses, such as management
fees and operating costs, are deducted from the fund's assets and can impact overall returns.
Clients can incur additional charges not covered by the wrap fee, such as account maintenance fees, wire transfer fees,
and fees for specific account activities (e.g., account termination or transfers). It's important to review these costs in
the account agreement or fee schedule.
• Conflict of interest: Because we pay the transaction costs in a wrap fee account, we have an incentive to trade
less frequently. This could work against active management of your account. We manage this conflict through
our fiduciary duty to act in your best interest.
•
If you trade infrequently, a wrap fee may cost more than paying for advisory services and transaction fees
separately. We will help you evaluate which structure is right for you.
See Appendix 1 for the full Wrap Fee Program Brochure
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Sub-Advisers
We may engage sub-advisers to manage part of your portfolio when specialized expertise would benefit you. We
remain responsible for selecting and overseeing any sub-adviser, for client communication, and for ensuring the sub-
adviser’s actions align with your goals. Any additional fees are disclosed before you are enrolled.
Sub-advisors are external investment professionals or firms engaged by Advisor to manage all or a portion of a client's
portfolio. Engaging sub-advisors allows the primary advisor to leverage specialized expertise and strategies that may
be outside their own firm's capabilities.
• Specialization and Expertise: Sub-advisors often bring specific expertise in particular asset classes, investment
strategies, or geographic regions, providing clients with access to a broader range of investment opportunities
and professional management.
• Delegation of Management: The primary advisor delegates part of the investment management process to the
sub-advisor, who then makes day-to-day decisions regarding the portfolio segment they manage. This can
include selecting securities, determining asset allocation, and executing trades.
• Due Diligence and Oversight: The primary advisor is responsible for conducting due diligence before hiring
a sub-advisor and continues to monitor the sub-advisor’s performance and adherence to the agreed-upon
investment mandate. This oversight ensures that the sub-advisor’s actions align with the client's objectives
and risk tolerance.
• Client Communication: While the sub-advisor manages a portion of the portfolio, the primary advisor
maintains the client relationship, handles communication, and provides consolidated reporting that includes
the sub-advisor’s activities.
• Fee Structure: There may be additional fees associated with using a sub-advisor, which should be disclosed to
the client. These fees are typically incorporated into the overall fee structure agreed upon with the primary
advisor.
• Regulatory Compliance: Both the primary advisor and the sub-advisor must comply with relevant regulations,
including registration and disclosure requirements. The primary advisor remains responsible for ensuring that
the sub-advisor’s activities comply with applicable laws and regulations.
• Contractual Agreements: The relationship between the primary advisor and the sub-advisor is governed by a
contractual agreement outlining the scope of services, performance expectations, compensation, and
compliance requirements.
By utilizing sub-advisors, the primary advisor can enhance the depth and breadth of investment management services
offered to clients, potentially improving portfolio diversification and performance outcomes.
Private Fund - Clearview Fund I LP
The Firm, through an affiliated general partner, sponsors and manages Clearview Fund I LP (the “Partnership” or
the “Fund”), a privately offered pooled investment vehicle available only to investors who are “accredited investors”
under Regulation D and, where applicable, “qualified clients” under Rule 205-3 of the Investment Advisers Act of
1940 (the “Advisers Act”). The Fund is not registered under the Investment Company Act of 1940 in reliance on an
available exclusion, and interests in the Fund are not registered under the Securities Act of 1933 in reliance on an
available private-placement exemption.
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The Partnership’s investment objective is to pursue a growth investment strategy designed to generate meaningful
capital appreciation over the term of the Fund by allocating across private equity, private credit, private real estate,
co-investments, and direct investments. Investments focus on companies and assets with identifiable competitive
advantages, secular tailwinds, and clear catalysts for value creation through earnings growth, revenue acceleration,
margin expansion, mergers and acquisitions, operational improvements, capital structure optimization, and strategic
repositioning. The Partnership invests in private equity funds (“Underlying Funds”) and in direct investments in
public securities, and seeks to achieve its objective through the careful selection of portfolio investments, including
the managers of Underlying Funds (each, a “Portfolio Manager”). The actual allocation of portfolio investments may
vary from time to time and over time.
Because the Fund pools capital from accredited investors to make illiquid, long-term investments in private markets,
public details regarding the Fund’s specific holdings, sector allocations, or target returns are limited and are generally
not accessible without a secure investor portal. Prospective investors should rely solely on the Fund’s confidential
private placement memorandum, limited partnership agreement, and subscription documents (collectively, the “Fund
Offering Documents”), which contain a complete description of the Fund’s strategy, terms, fees, conflicts, and risk
factors. In the event of any conflict between this brochure and the Fund Offering Documents, the Fund Offering
Documents govern.
Financial Planning Services
Clearview Financial Partners, through its IARs, generally provides financial planning as part of a comprehensive asset
management engagement. Financial planning is also available separately for a separate fee. The type of plan can vary
greatly depending on the scope and complexity of an individual’s financial situation and may address retirement,
college/education, insurance needs, estate planning, cash-flow/budget planning, wealth accumulation, tax planning,
investment planning, and inheritance planning for families and individuals, as well as business entity planning, qualified
retirement plans, stock option planning, key person planning, executive benefits, deferred compensation, and business
succession planning for businesses.
Retirement Plan Consulting
IARs may assist clients that are trustees or other fiduciaries to retirement plans (“Plans”) by providing fee-based
consulting and/or advisory services, which may include assistance with an investment policy statement (“IPS”), acting
as a liaison to service providers, ongoing monitoring of investments, performance reporting, ongoing
recommendations, committee education, and participant enrollment support, as selected by the client in the client
agreement.
If a Plan makes available publicly traded employer stock (“company stock”) as an investment option, IARs do not
provide investment advice regarding company stock and are not responsible for the decision to offer it. IARs do not
provide individualized advice to Plan participants regarding brokerage windows, mutual fund windows, participant
loans, or their Plan assets generally.
ERISA Fiduciary Status
Where a client engages an IAR to perform ongoing investment monitoring and ongoing investment recommendation
services to a Plan subject to ERISA, such services constitute “investment advice” under Section 3(21)(A)(ii) of ERISA,
and the IAR will be deemed a “fiduciary” under that section in connection with those services. To the extent the IAR
is engaged to perform other services, those services are not “investment advice” under ERISA and the IAR is not an
ERISA fiduciary with respect to them.
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Retirement Plan Rollovers
An employee generally has four options for a retirement plan when leaving an employer: (1) leave the assets in the
former employer’s plan, if permitted; (2) roll the assets to a new employer’s plan, if available and permitted; (3) roll
the assets to an Individual Retirement Account (IRA); or (4) cash out the account, which has significant tax
consequences. The Firm may recommend that retirement plan assets be rolled over into an IRA managed by the Firm.
The Firm has a financial incentive to recommend such a rollover, which is a conflict of interest mitigated by the Firm’s
fiduciary duty to act in the client’s best interest.
Use of Artificial Intelligence (AI)
Artificial Intelligence (AI) is the simulation of human intelligence in machines designed to think and learn like humans.
AI encompasses a range of technologies that enable systems to perform tasks such as recognizing speech, making
decisions, and understanding complex ideas. AI enhances our services, improves operational efficiency, and delivers
overall better outcomes. By integrating AI into our processes, we aim to stay at the forefront of technological
innovation while maintaining a strong commitment to ethical practices and data privacy.
We use AI tools to assist with portfolio analysis, administrative tasks, and note-taking during web-based calls. When
AI is recording a call, we will notify all participants, and you may opt out. AI tools support — but do not replace —
human judgment. We maintain oversight of all AI-assisted functions to ensure they align with your best interests.
Examples of AI include all or some of the following:
• Algorithmic Trading: AI algorithms can analyze vast amounts of market data to identify trends and execute
trades at optimal times, improving the efficiency and effectiveness of portfolio management.
• Risk Assessment: AI tools can evaluate the risk profiles of different investments more accurately by analyzing
historical data and predicting potential future risks, allowing RIAs to construct more resilient portfolios.
• Market Analysis: AI can process and analyze large datasets from various sources, including news articles, social
media, and economic reports, to provide insights into market dynamics and help forecast market movements.
• Predictive Analytics: AI-driven predictive models can help RIAs anticipate market trends and client behavior,
enabling more proactive and informed investment decisions.
• Customized Investment Strategies: AI can analyze individual client data to create personalized investment
strategies that align with each client’s goals, risk tolerance, and financial situation.
• Behavioral Analysis: AI systems can evaluate clients’ past behaviors and preferences to offer customized
advice and improve client engagement.
• Automation of Administrative Tasks: AI can automate routine tasks such as data entry, compliance checks,
and report generation, freeing advisors to focus on higher-value activities.
• Enhanced Client Communication: Chatbots and virtual assistants powered by AI can handle basic client
inquiries, schedule meetings, and provide updates, improving responsiveness and client satisfaction.
• Regulatory Compliance: AI tools can monitor transactions and communications to ensure compliance with
regulatory requirements, reducing the risk of violations and associated penalties.
• Fraud Detection: Advanced AI algorithms can identify unusual patterns or anomalies that may indicate
fraudulent activity, enhancing the security of client accounts.
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• Scenario Analysis: AI can simulate various market scenarios and their potential impact on investment
portfolios, helping advisors and clients make more informed decisions.
• Strategic Asset Allocation: AI tools can optimize asset allocation by considering a wide range of factors,
including market conditions, client objectives, and economic forecasts.
• Notetaking: Advisor uses AI for real-time note-taking during web calls to enhance accuracy, efficiency, and
productivity. The AI tool transcribes spoken content, generates summaries, and identifies key takeaways from
web-based calls. Participants are informed of AI usage and have the right to opt out of AI-generated note-
taking during web-based calls. Should a client have any questions or concerns, please contact us at our email
address, phone number, or through our website.
By leveraging AI technology, Advisor can enhance their analytical capabilities, deliver more personalized services,
improve operational efficiency, and ultimately provide better outcomes for their clients. However, while AI offers
significant advantages, Advisor maintains human oversight to ensure that AI-driven functions align with clients' best
interests and fiduciary requirements.
Item 5 — Fees and Compensation
IARs may only provide services and charge fees based on the account agreement. The specific services and fees
charged to a particular client depend on the representative working with the client and the individual needs of each
client.
• Fees are deducted by the qualified custodian, in advance or in arrears on a quarterly basis, and are debited from
the account depending on the custodian selected.
• Depending on the custodian selected, clients may enter into a separate agreement regarding how fees are
collected.
• The qualified custodian sends clients a quarterly statement that details the amount of the fee charged, the amount
of assets subject to the fee, and the time period covered by the fee.
The specific fee is negotiated based on the schedule below and is subject to account specifics such as account size,
management style, complexity of holdings, investment type, management strategy, and the expected amount of time
and effort required.
Assets Under Management
Annual Fee*
$0 – $1,000,000
1.50%
$1,000,001 – $3,000,000
1.25%
$3,000,001 – $4,000,000
0.90%
$4,000,001 – $5,000,000
0.80%
Over $5,000,000
Negotiable
* There is generally an additional 0.10% fee for a wrap fee account, in addition to the ranges above.
Clients may also incur certain charges imposed by third parties in connection with investments in the account,
including (without limitation) investment-manager fees, mutual fund management and administrative servicing fees,
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mutual fund 12b-1 fees, deferred sales charges on previously purchased mutual funds, clearing, custody, postage and
handling, transaction charges and service fees (e.g., account transfer, wire transfer, and termination fees), interest on
debit balances, and IRA/qualified retirement plan fees. Further information regarding fund-level charges is available
in the applicable prospectus or disclosure statement.
Mutual Fund Share Class Disclosure and Fiduciary Duty (12b-1 Fees)
Section 206 of the Advisers Act imposes a fiduciary duty to act in a client’s best interests and prohibits an investment
adviser, directly or indirectly, from engaging in any transaction, practice, or course of business that operates as a fraud
or deceit upon any client or prospective client. When selecting a mutual fund for a client’s advisory account, the IAR
has a fiduciary duty to select the share class that appropriately manages the overall fee structure of the account.
However, the fiduciary duty to which advisers are subject is not specifically defined in the Advisers Act or the
Commission rules but reflects a Congressional recognition “of the delicate fiduciary nature of an investment advisory
relationship” as well as a Congressional intent to eliminate, or at least expose, all conflicts of interest which might
incline an investment adviser, consciously or unconsciously, to render advice which was not disinterested. The
purpose of 12b-1 fees, as approved by the SEC, are to cover marketing expenses and shareholder services such as the
support services. Mutual funds offer different share classes, each with varying fee structures and features, to
accommodate different types of investors. Below is a breakdown of the most common mutual fund share classes.
• Class A Shares: These shares typically charge a front-end sales load, which is a fee paid when the shares are
purchased. This fee is a percentage of the total investment.
• Class B Shares: Class B shares often have a contingent deferred sales charge (CDSC), which is a fee paid when
shares are sold, typically decreasing over time (usually over six to eight years).
• Class C Shares: Class C shares typically charge a level load, which is an annual fee as long as the shares are
held, in addition to higher ongoing expenses.
• Class I Shares: also known as Institutional Shares, are a class of mutual fund shares designed primarily for
institutional investors, such as pension funds, endowments, and large-scale investment managers.
• R Shares: Designed for retirement plans like 401(k) plans.
• NTF (No Transaction Fee) Mutual Funds: Mutual funds without a transaction fee or commission to the
brokerage or platform through which they are purchased.
• Direct Purchase Mutual Funds: Often available directly from the mutual fund company. Direct purchase
mutual funds can be a cost-effective option for knowledgeable investors who are comfortable managing their
own investments and wish to avoid intermediary fees. However, it requires a proactive approach to research
and decision-making.
The choice of the most beneficial mutual fund share class involves considering ticket charges, 12b-1 fees and the asset
management fee. Fees are considered in totality, not in isolation. Sometimes, investing in a share class with 12b-1 fees
can be the more cost-effective option rather than simply avoiding 12b-1 fees. Advisor has a fiduciary duty to select
the share class that best serves the client's interests, ensuring a comprehensive fee analysis to determine the optimal
choice.
For a wrap fee account, a different conflict of interest is introduced because the advisor has an incentive to not trade
as frequently (reverse churning) to avoid the ticket charges which can compromise active management. This conflict
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is mitigated by the fiduciary duty to act in a client’s best interest while also considering the higher asset management
fee charged for wrap fee accounts.
Legacy Mutual Fund Holdings
When a client moves their assets into a managed account, the portfolio advisor reviews the client's mutual fund
holdings. If the mutual funds are not part of the Advisor's recommended list, they are generally sold unless selling
would result in a taxable gain that outweighs the benefits of the preferred holdings or higher fee structure. If it is
determined that converting the legacy positions to a different share class is in the clients best interest, Advisor will
execute on such changes.
• Assessment: Advisor first conducts a thorough assessment of the client's current mutual fund holdings. This
involves evaluating the fees, performance, and fit within the client's overall investment strategy and objectives.
• Comparison: Advisor compares the current share class with alternative options available. This comparison
includes analyzing expense ratios, 12b-1 fees, potential loads, and any other costs associated.
• Eligibility & Requirements: Advisor ensures that the client meets any minimum investment amounts and other
eligibility criteria required for the new share class.
• Benefit Analysis: Advisor evaluates the potential benefits of conversion, such as lower fees, better alignment
with investment goals, or improved tax efficiency. The goal is to determine whether the conversion will result
in cost savings or other advantages for the client.
After a conversion or decision to maintain a legacy position, Advisor continues to monitor the investment to ensure
it remains aligned with the client’s goals. This ongoing review helps in making any necessary adjustments in the future.
Conflict of interest - wrap fee accounts: In a wrap fee account, we pay the transaction costs. This creates an
incentive to trade less frequently to keep our costs down (“reverse churning”). We manage this conflict through
our fiduciary duty to act in your best interest.
Valuation
Securities valuation is the process of determining the intrinsic value of a financial asset, such as stocks, bonds, or other
investments, to assess its worth relative to its current market price. The goal of securities valuation is to help investors
make informed decisions about buying, holding, or selling securities. Advisor will not have the authority or
responsibility to value portfolio securities. Valuation is a function of the independent custodian.
Cash Sweep Program
Investment portfolios often include a cash allocation to maintain liquidity, manage risk, and provide funds for
opportunistic investments. Cash allocations can serve as a buffer against market volatility and ensure that funds are
readily available for future investment opportunities or withdrawals. Sweep programs automatically transfer
uninvested cash from a brokerage account into a money market fund or other short-term investment vehicle at the
custodian. This process is automated and occurs regularly, often at the end of each business day. While the cash is
held in the sweep account, it earns interest. This ensures that even idle cash is generating some return, albeit typically
lower than other investment options.
By automating the movement of cash, sweep programs reduce the need for manual transfers, saving time and
minimizing the risk of human error in managing cash balances. Sweep accounts provide quick access to cash for
reinvestment or withdrawals, enhancing liquidity management within the portfolio. Minimizing manual cash
management tasks reduces administrative burdens for both the investor and the advisor, allowing them to focus on
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strategic investment decisions. Sweep programs often offer lower interest rates compared to other short-term
investments like high-yield savings accounts or CDs. This is due to the liquidity and convenience they provide. While
convenient, the lower interest rates mean that investors can miss out on higher returns if cash is kept in the sweep
account for extended periods. Advisor uses sweep programs strategically to manage cash flows within a portfolio,
ensuring that cash is readily available for investment opportunities without sacrificing significant returns. Sweep
accounts can also be used to facilitate regular transactions, such as automatic withdrawals for living expenses or
periodic investments in other asset classes. While sweep programs offer convenience and liquidity, they require careful
consideration as part of an overall investment strategy. Advisors and clients should weigh the benefits of liquidity and
automation against the potential for higher returns through alternative cash management strategies.
Fees for Family and Friends
We may waive or reduce fees for family members and friends. Minimum account requirements are also negotiable in
certain circumstances.
Industry Professionals
When it serves the best interests of the client, Advisor recommends the services of other professionals, such as
attorneys or accountants, for non-investment-related needs. These introductions can be valuable in providing clients
with comprehensive support and expertise beyond the Advisor's direct offerings, ensuring clients receive well-
rounded assistance in various aspects of their financial and legal matters. Introducing clients to other professionals
creates a conflict of interest because the referred professional might feel an implicit obligation to reciprocate by
referring potential new clients back to the Advisor. This could influence recommendations, prioritizing professionals
likely to reciprocate rather than solely considering the client's best interests. Clients are under no obligation to use the
services of a recommended professional. They are free to seek advice and services from other professionals of their
choosing. Recommendation are merely a suggestion based on perceived quality and suitability; clients retain full
discretion over whether to engage with the suggested professionals. If a client decides to engage with a referred
professional and a dispute arises, the client’s recourse is solely against the engaged professional. Advisor does not
assume responsibility for the actions or outcomes of services provided by third-party professionals. Clients should
conduct their own due diligence and ensure they are comfortable with the terms and conditions proposed by the
referred professional.
Training Event & Due Diligence Visits
Our representatives are sometimes invited to attend training events or due diligence visits sponsored by investment
managers or product companies. Sponsors may pay for travel, meals, and entertainment — including events at luxury
resorts. These benefits could unconsciously influence us to favor those sponsors when making recommendations. We
manage this risk through our fiduciary duty and by disclosing it to you.
Additional Compensation
Advisor can receive economic benefits from sources other than the client for providing advisory services. These
benefits can take various forms, including sales awards, gifts, meals, or entertainment such as tickets to concerts,
shows, or sporting events. Here's a more detailed explanation:
Sales Awards
Recognitions or bonuses given for achieving certain targets or performance metrics, often provided by product
sponsors or financial institutions.
Gifts
These can range from small tokens of appreciation to more significant items, potentially offered by business partners
or vendors.
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Meals & Entertainment
Occasional meals, invitations to events, or tickets to entertainment activities provided by third-party entities, such as
product sponsors or other financial service providers. These economic benefits create a conflict of interest, as they
can unconsciously influence decisions regarding the selection of products and/or services. For instance, an advisor
might be more inclined to recommend products from a sponsor that offers more generous incentives. This influence
can affect the objectivity of recommendations; however, Advisor has a fiduciary duty to act in a client’s best interest.
Other Fees and Expenses
Clients (not in a wrap fee program) will incur transaction charges for trades executed in their accounts. These
transaction fees are separate from our fees. Also, clients will pay the following separately incurred expenses, which
we do not receive any part of such as, 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). If a
Client’s assets are invested in mutual funds or other pooled investment products, clients should be aware that there
will be two layers of advisory fees and expenses for those assets. Client will pay a fee to the fund manager and other
expenses as a shareholder of the fund. Most of the mutual funds available in the program may be purchased directly.
Therefore, Clients could generally avoid the second layer of fees by not using the management services of Advisor
and by making their own investment decisions. Further information regarding fees assessed by a mutual fund is
available in the appropriate prospectus.
Wrap Fee Program
Clearview Financial Partners is the sponsor and acts as the portfolio manager of a wrap fee program. Please see the
separate Wrap Fee Program Brochure (Appendix 1) for additional details. The fee structure of a wrap fee program
warrants additional consideration with respect to the selection of mutual fund share classes.
Private Fund Compensation
With respect to Clearview Fund I LP, the affiliated general partner and/or the Adviser receives a management fee
and may receive a performance-based allocation (carried interest) as described in the Fund Offering Documents. To
the extent a client’s separately managed account assets are invested in the Fund, the Adviser will not charge its
separate-account advisory fee on those assets in addition to the Fund-level management fee, so that clients are not
charged advisory fees at two levels on the same assets.
Termination
Clients may terminate the agreement without penalty for a full refund of fees within five business days of signing an
agreement. Thereafter, clients may terminate the agreement with 30 days’ written notice. If the advisory agreement is
terminated before the end of the quarterly period, the client is entitled to a pro-rated refund of any pre-paid quarterly
advisory fee based on the number of days remaining in the quarter after the termination date, which will be processed
by the custodian. Interests in Clearview Fund I LP are subject to the separate withdrawal, redemption, and lock-up
provisions set forth in the Fund Offering Documents and are generally illiquid.
Financial Planning and Retirement Plan Consulting Fees
If financial planning is provided separately, the fee is generally based on the estimated time required multiplied by a
negotiated hourly rate of up to $300, depending on the complexity involved and credentials required. As circumstances
warrant, an hourly rate of more than $300 may be negotiated. Payment is generally 50% in advance and the balance
upon completion. A financial planning engagement is considered terminated upon delivery of a plan. The fee for
Retirement Plan Consulting is set out in a separate agreement and is debited quarterly in advance or in arrears.
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Item 6 — Performance-Based Fees and Side-by-Side Management
The affiliated general partner of Clearview Fund I LP may receive a performance-based allocation (commonly called
carried interest) with respect to the Fund, as described in the Fund Offering Documents. Performance-based
compensation is charged only to investors who meet the “qualified client” standard of Rule 205-3 under the Advisers
Act. Because the Advisor manages both the Fund (which bears a performance-based allocation) and separately
managed accounts (which are charged asset-based fees), the Advisor engages in side-by-side management. Side-by-
side management creates a conflict of interest because the Adviser has a financial incentive to favor the account or
vehicle that pays performance-based compensation when allocating investment opportunities or time. The Advisor
addresses this conflict through its allocation policies and procedures, which are designed to allocate investment
opportunities fairly and equitably over time, and through its fiduciary duty to act in the best interests of all clients.
REGULATORY CITATION
Advisers Act Section 205(a)(1) and Rule 205-3 (qualified client exemption); Section 206 (anti-fraud / fiduciary duty).
Item 7 — Types of Clients
Clearview Financial Partners generally provides advice to individuals and high-net-worth individuals. The advisory
services offered are also available to small businesses, banks and thrift institutions, estates, charitable organizations,
state and municipal government entities, corporations, and pension plans as opportunities arise. In addition, the
Adviser provides investment management services to a pooled investment vehicle, Clearview Fund I LP, whose
investors must be accredited investors and, where performance-based compensation applies, qualified clients.
• The account minimum for an asset management account is generally $1,000,000.
• The minimum investment in Clearview Fund I LP is set forth in the Fund Offering Documents.
Item 8 — Methods of Analysis, Investment Strategies, and Risk of Loss
A client’s portfolio may include assets of publicly held companies in the United States and foreign markets, including
both equities and fixed income assets. Other holdings may include domestic and foreign debt instruments, REITs,
mutual funds, and private placements. Analysis and strategies are generally based on publicly available data, a client’s
net worth, risk tolerance, goals for investment account funds, and third-party research.
Each client portfolio is initially designed to meet a particular investment goal determined to be appropriate for the
client’s circumstances. The portfolio is reviewed regularly and, if appropriate, rebalanced based on the client’s
individual needs, stated goals, and objectives.
Investing in securities involves risk of loss that clients should be prepared to bear.
There are different types of investments that involve varying degrees of risk, and it should not be assumed that future
performance of any specific investment or investment strategy will be profitable or equal any specific performance
level. Past performance is not indicative of future results.
General Risks of Loss
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• AI-Related Risk: Advisor utilizes Artificial Intelligence (AI) and/or Machine Learning (ML) technologies in
certain aspects of its advisory services. While these technologies aim to enhance efficiency, accuracy, and
investment outcomes, their use introduces specific risks that clients should consider. The use of AI in decision-
making can result in overreliance on technology, potentially reducing human oversight. Unexpected system
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malfunctions, algorithmic errors, or misinterpretations of AI-generated insights could adversely affect
investment outcomes. Advisor requires human oversight of AI tools. Clients are encouraged to discuss any
concerns about AI-related risks.
• Cybersecurity Risk: We and our service providers depend on technology systems that could be compromised
by cyberattacks. A breach could disrupt trading, expose your personal data, or result in financial loss. The
computer systems, networks and devices used by us and our service providers employ a variety of protections
designed to prevent damage or interruption from computer viruses, network and computer failures and
cyberattacks. Despite such protections, systems, networks and devices potentially can be breached. Cyberattacks
include, but are not limited to, gaining unauthorized access to digital systems for purposes of corrupting data,
or causing operational disruption, as well as denial-of- service attacks on websites. Cyber incidents may cause
disruptions and impact business operations, potentially resulting in financial losses, the inability of us or our
service providers to trade, violations of privacy and other laws, regulatory fines, reputational damage,
reimbursement costs and additional compliance costs, as well as the inadvertent release of confidential
information.
• Exchange Traded Fund and Mutual Fund Risk: The risk of owning an ETF or mutual fund generally reflects
the risks of owning the underlying securities the ETF or mutual fund holds. Clients may incur additional costs
associated with ETFs and mutual funds (see Item 5). Consumer Discretionary ETF Shares are listed for trading
on NYSE Arca and can be bought and sold on the secondary market at market prices. Although it is expected
that the market price of a Consumer Discretionary ETF Share typically will approximate its net asset value
(NAV), there may be times when the market price and the NAV vary significantly. Thus, the client may pay
more or less than NAV when the Consumer Discretionary ETF Shares are purchased on the secondary market,
and the client may receive more or less than NAV when you sell those shares. Although Consumer Discretionary
ETF Shares are listed for trading on NYSE Arca, it is possible that an active trading market may not be
maintained and Trading of Consumer Discretionary ETF Shares on NYSE Arca may be halted by the activation
of individual or market wide "circuit breakers" (which halt trading for a specific period of time when the price
of a particular security or overall market prices decline by a specified percentage). Trading of Consumer
Discretionary ETF Shares may also be halted if the shares are delisted.
• Market Risk: the risk that the value of securities may rise or fall, sometimes rapidly or unpredictably, due to
factors affecting securities markets generally or particular industries
• Interest Rate Risk: the risk that fixed income securities will decline in value because of an increase in interest
rates; longer-duration instruments are more sensitive to rate changes.
• Credit Risk: the risk that an investor could lose money if the issuer or guarantor of a fixed income security is
unable or unwilling to meet its obligations.
• Liquidity Risk: the possibility that an investor may not be able to buy or sell an investment when desired, or in
sufficient quantities, because opportunities are limited.
• Inflationary Risk: the risk that future inflation will cause the purchasing power of cash flow from an investment
to decline.
• Currency/Exchange Rate Risk: the risk of a change in the price of one currency against another.
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• Pandemic Risk: Large-scale outbreaks of infectious disease that can greatly increase morbidity and mortality
over a wide geographic area, crossing international boundaries, and causing significant economic, social, and
political disruption. For example, the novel coronavirus known as COVID-19 involves significant risk of a
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sustained increase in the volatility of global markets, which volatility could continue for the foreseeable future.
Market responses to decisions made by governments and scientists around the world, including measures to
contain the spread of the virus, availability of healthcare and treatments, and rolling shutdowns of markets
across the globe would negatively impact markets and pose a significant risk of loss to investment principal. The
pandemic also poses a risk from a human capital and resource perspective.
Private Fund and Private Markets Risks
An investment in Clearview Fund I LP involves a high degree of risk, including the risk of loss of the entire investment,
and is suitable only for sophisticated investors who can bear such risk. These risks are described in full in the Fund
Offering Documents and include, among others:
• Illiquidity and Lock-Up: Fund interests are illiquid, are not freely transferable, and are subject to significant
withdrawal restrictions and lock-up periods. There is no public market for Fund interests.
• Long-Term Horizon: the Fund’s private equity, private credit, and private real estate investments are long-term
and may not produce returns or distributions for an extended period.
• Valuation Uncertainty: the Fund holds assets for which market quotations are not readily available; valuations
are estimates and may not reflect realizable value.
• Underlying Fund / Multi-Manager Risk: the Fund invests in Underlying Funds managed by third-party Portfolio
Managers and bears its proportionate share of those funds’ fees and expenses, resulting in layered fees; the
Adviser has limited control over, and limited transparency into, Underlying Funds.
• Leverage: the Fund and Underlying Funds may use leverage, which magnifies both gains and losses.
• Concentration: the Fund may hold concentrated positions in particular companies, sectors, or assets, increasing
the impact of adverse developments.
• Limited Information: because the Fund invests in private markets, detailed holdings, sector allocations, and
target-return information are limited and generally available only through a secure investor portal.
Methods of Analysis and Investment Strategies
We use a combination of the following analytical approaches:
• Fundamental Analysis: This method involves examining a company’s financial statements, market position,
management quality, and economic conditions to estimate its intrinsic value. It helps investors identify stocks
that are mispriced by the market.
• Technical Analysis: Focuses on historical price movements and trading volumes to forecast future price
trends. Technical analysts use charts and other tools to identify patterns and indicators that suggest buying or
selling opportunities.
• Behavioral Analysis: Examines psychological factors and market sentiment that can affect investor behavior
and market outcomes. It explores how cognitive biases and emotions can lead to irrational investment
decisions.
• Quantitative Analysis: Relies on mathematical models and statistical techniques to evaluate investment
opportunities. This method often involves analyzing data sets to identify trends, correlations, and potential
arbitrage opportunities.
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• Cyclical Analysis: Involves studying economic cycles to determine the optimal timing for investment decisions.
This approach is useful for identifying opportunities related to business cycles and economic expansions or
contractions. Helps identify buy and sell opportunities based on economic cycles. Useful for timing
investments in cyclical industries.
• Charting Analysis: Utilizes visual representations of price data to identify trends and potential reversal points.
This method is often used in conjunction with technical analysis for a more nuanced understanding of market
dynamic. Offers a visual representation of price movements and patterns. Useful for identifying trends and
potential reversal points. Can be used in conjunction with technical indicators for more precise analysis.
• Efficient Market Strategies: Based on the Efficient Market Hypothesis, this approach assumes that asset prices
reflect all available information. Strategies here might focus on passive investing, such as index tracking, to
align with market performance. Emphasizes diversification and long-term investment strategies. Reduces the
need for active management and frequent trading. Aligns with the philosophy that markets incorporate all
available information.
• Tactical Analysis: Allows for adaptive changes to portfolios based on short-term market forecasts and
conditions. This strategy aims to exploit transient market opportunities while managing risks. Allows for
active adjustments to portfolios based on short-term market forecasts. Can capitalize on market opportunities
or avoid potential downturns. Provides flexibility to shift asset allocations in response to changing market
conditions.
• Modern Portfolio Theory (MPT): a mathematical framework for constructing a portfolio of assets such that
the expected return is maximized for a given level of risk, defined as variance. Developed by Harry Markowitz
in the 1950s, MPT emphasizes the benefits of diversification and is foundational in investment management.
Types of Investments
Investments encompass a wide range of asset classes and financial instruments, each offering distinct features, risk
profiles, and potential returns. Each investment type has unique attributes that can align with different financial goals,
risk tolerances, and investment horizons. Diversification across these types can help manage risk and optimize potential
returns. The following types of investments are considered.
• Annuities: Retirement products for those who may have the ability to pay a premium now and want to guarantee
they receive certain monthly payments or a return on investment later in the future. Annuities are contracts
issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a
life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other
long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and
insurance company charges may apply if you withdraw your money early. Variable annuities also involve
investment risks, just as mutual funds do.
• Multi-Year Guaranteed Annuity (MYGA): A MYGA, or Multi-Year Guaranteed Annuity, is a type of fixed
annuity that offers a guaranteed interest rate for a specified period, typically ranging from 3 to 10 years. It
functions similarly to a Certificate of Deposit (CD), but instead of being offered by a bank, it is provided by an
insurance company. Reported quarter-end values may be slightly off due to estimation of values.
• Fixed Rate Single Premium Annuity: A fixed rate single premium annuity is an insurance product designed to
provide a stable income stream over a specified period in exchange for a one-time upfront payment, known as
the single premium. Income distributions can be structured to last for a specific number of years, until death,
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or for a combination of both. A fixed rate single premium annuity provides a lower-risk investment option than
variable annuities or other market-dependent investments. Annual contracts and features vary by state and may
not be available in all states. Fixed-rate annuities do not adjust for inflation, meaning the purchasing power of
the income payments will decrease over time. Annuities are backed by the financial strength and claims-paying
ability of the issuing life insurance carrier.
• Cash Positions: Based on a perceived or anticipated market conditions and/or events, certain assets will be
taken out of the market and held in a defensive cash position. The firm invests cash balances in money
market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government-
backed debt instruments. Cash positions are subject to the agreed upon advisory fee as they are managed as
part of the overall active investment strategy. The firm does not hold cash positions for an extended period
of time.
• Cryptocurrency: Cryptocurrencies refer to the actual virtual currency (decentralized digitized money) that allows
individuals or entities to transfer funds online without the need for a bank or credit card company, such as
Bitcoin, Ethereum, Cardona, and Litecoin. Cryptocurrency is Cryptocurrencies were not designed to be
investments and have not been deemed to be a security. They were designed to be mediums of exchange and
seen as an alternative to traditional sovereign currencies. Cryptocurrency-related products refer to securities that
either directly purchase cryptocurrencies or are involved in the cryptocurrency space, such as through mining
cryptocurrency, investing in companies that develop and use blockchain technology, etc. The SEC, CFTC,
NFA, and FINRA have issued investor alerts and advisories on the risks of cryptocurrencies and initial coin
offerings (ICOs). These regulators continue to warn investors to keep in mind that actual cryptocurrency and
cryptocurrency-related products continue to be speculative and extremely volatile investments. Due to the
unregulated nature and lack of transparency surrounding the operations of crypto exchanges, they may
experience fraud, market manipulation, security failures or operational problems, which can adversely affect the
value of cryptocurrencies and, consequently, the value of the shares of cryptocurrency-related products.
• Emerging Markets: The risks of foreign investments typically are greater in less developed countries,
sometimes referred to as emerging markets. For example, political and economic structures in these countries
may be less established and may change rapidly. These countries also are more likely to experience high levels
of inflation, deflation, or currency devaluation, which can harm their economies and securities markets and
increase volatility. Restrictions on currency trading that may be imposed by emerging market countries will
have an adverse effect on the value of the securities of companies that trade or operate in such countries.
• Equity: Investment generally refers to buying shares of stocks in return for receiving a future payment of
dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in
response to specific situations for each company, industry conditions and the general economic environment.
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• Exchange Traded Funds (ETFs): An ETF is a portfolio of securities invested to track a market index similar
to an index mutual fund, but the shares are traded on an exchange like an equity. An ETF share price
fluctuates intraday depending on market conditions instead of having a net asset value (NAV) that is calculated
once at the end of the day. The shares may trade at a premium or discount; and as a result, investors pay more
or less when purchasing shares and receive more or less than when selling shares. The supply of ETF shares
is regulated through a mechanism known as creation and redemption that involves large, specialized investors,
known as authorized participants (APs). Authorized participants are large financial institutions with a high
degree of buying power, such as market makers, banks or investment companies that provide market liquidity.
When there is a shortage of shares in the market, the authorized participant creates more (creation).
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Conversely, the authorized participant will reduce shares in circulation (redemption) when supply falls short
of demand. Multiple authorized participants help improve the liquidity of a particular ETF and stabilize the
share price. To the extent that authorized participants cannot or are otherwise unwilling to engage in creation
and redemption transactions, shares of an ETF tend to trade at a significant discount or premium and may
face trading halts and delisting from the exchange. The performance of ETFs is subject to market risk,
including the complete loss of principal. ETFs also have a trading risk based on cost inefficiency if the ETFs
are actively traded and a liquidity risk if the ETFs has a large price spread and low trading volume. In addition,
investors buying or selling shares in the secondary market pay brokerage commissions, which may be a
significant proportional cost not incurred by mutual funds.
• Exchange-Traded Notes (ETNs): An ETN is a senior unsecured debt obligation designed to track the total
return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for
example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on
an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual
fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more
common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of
any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the
trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is
downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated
in a specific sector, asset class or country and may therefore carry specific risks.
• Fixed Income: Investments generally pay a return on a fixed schedule, though the amount of the payments can
vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield,
and investment grade debt and structured products, such as mortgage and other asset-backed securities, although
individual bonds may be the best-known type of fixed income security. In general, the fixed income market is
volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and
vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry
inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of
default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting
(extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal.
• Hedge Funds and Managed Futures: Hedge and managed futures funds are available for purchase in the program
by clients meeting certain qualification standards. Investing in these funds involves additional risks including,
but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment
practices and the lack of liquidity and performance volatility. In addition, these funds are not required to provide
periodic pricing or valuation information to investors and may involve complex tax structures and delays in
distributing important tax information. Client should be aware that these funds are not liquid as there is no
secondary trading market available. At the absolute discretion of the issuer of the fund, there may be certain
repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the
fund during the repurchase offer.
• Mutual Funds: Mutual funds are investment vehicles that pool money from multiple investors to invest in a
diversified portfolio of stocks, bonds, money market instruments, and similar assets. Open-End Mutual Funds
issue an unlimited number of shares and will buy back shares when investors decide to sell. They carry the risk
of losing money, and all mutual funds have costs that can lower returns. Closed-End Mutual Funds raise a fixed
amount of capital through an initial public offering (IPO) and trade on stock exchanges like stocks. They are
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not as easily marketable, and investors might not be able to sell their shares easily. To provide some liquidity,
these funds may periodically repurchase shares at net asset value. Alternative Investment Funds invest primarily
in alternative assets or strategies, which might not be suitable for all investors. These funds involve special risks
like those related to commodities, real estate, and derivatives, including issues of leverage and liquidity.
• Options: A contract granting the right to either buy or sell a specific amount or value of a particular underlying
interest at a fixed exercise price by exercising the option by or before its specific expiration date. The purchase
or sale of an option involves the payment or receipt of a premium by the investor and the corresponding right
or obligation, as the case may be, to either purchase or sell the underlying security, basket of securities,
commodity or other instrument for a specific price at a certain time or during a certain period. Purchasing
options involves the risk that the underlying instrument will not change price in the manner expected, so that
the investor loses the premium paid. Selling options, on the other hand, involves potentially greater risk
because the investor is exposed to the extent of the actual price movement in the underlying security (which
could result in a potentially unlimited loss) rather than only the loss of the premium payment received. Prior
to buying or selling an option, investors must read a copy of the Characteristics and Risks of Standardized
Options, also known as the options disclosure document (ODD). It explains the characteristics and risks of
exchange traded options.
• Margin Accounts: Client should be aware that margin borrowing involves additional risks. Margin borrowing
will result in increased gain if the value of the securities in the account go up, but will result in increased losses
if the value of the securities in the account goes down. The custodian, acting as the client’s creditor, will have
the authority to liquidate all or part of the account to repay any portion of the margin loan, even if the timing
would be disadvantageous to the client. For performance illustration purposes, the margin interest charge will
be treated as a withdrawal and will, therefore, not negatively impact the performance figures reflected on the
quarterly advisory reports.
• Precious Metal: Metals such as Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal)
specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector
which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant
increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude
of speculators and investors.
• Real Estate Investment Trusts (REITs): A real estate investment trust (REIT) is a company that owns,
operates, or finances income-generating real estate. Modeled after mutual funds, REITs pool the capital of
numerous investors. This makes it possible for individual investors to earn dividends from real estate
investments—without having to buy, manage, or finance any properties themselves. REITs are designed to
generate a steady income stream for investors but offer little in the way of capital appreciation. Most REITs
are publicly traded like stocks, which makes them highly liquid (unlike physical real estate investments). REITs
invest in most real estate property types, including apartment buildings, cell towers, data centers, hotels,
medical facilities, offices, retail centers, and warehouses. In general, REITs specialize in a specific real estate
sector. However, diversified and specialty REITs may hold different types of properties in their portfolios,
such as a REIT that consists of both office and retail properties.
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• Regulation D Private Placements: Under the federal securities laws, any offer or sale of a security must either
be registered with the SEC or meet an exemption. Regulation D under the Securities Act provides a number
of exemptions from the registration requirements, allowing some companies to offer and sell their securities
without having to register the offering with the SEC. However, a "Form D" must be electronically filed with
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the SEC after they first sell their securities. Form D is a brief notice that includes the names and addresses of
the company’s promoters, executive officers and directors, and some details about the offering, but contains
little other information about the company.
• Short Sales: A short sale involves the sale of a security that the Client does not own in the hope of purchasing
the same security at a later date at a lower price. To make delivery to the buyer, the Client must borrow the
security and is obligated to return the security to the lender, which is accomplished by a later purchase of the
security. The Client realizes a profit or a loss as a result of a short sale if the price of the security decreases or
increases respectively between the date of the short sale and the date on which the Client covers its short
position, i.e., purchases the security to replace the borrowed security. A short sale involves the theoretically
unlimited risk of an increase in the market price of the security that would result in a theoretically unlimited
loss.
• Structured Products: Structured products are securities derived from another asset, such as a security or a basket
of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit
the upside participation in the reference asset. Structured products are senior unsecured 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 issuer does not affect or enhance
the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments
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, may be adversely impacted if the issuer’s credit rating is downgraded. Some
structured products offer full protection of the principal invested, others offer only partial or no protection.
Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee
relates to nominal principal and does not offer inflation protection. An investor in a structured product never
has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little
or no secondary market for the securities and information regarding independent market pricing for the
securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing
on an exchange. Tax treatment of structured products may be different from other investments held in the
account (e.g., income may be taxed as ordinary income even though payment is not received until maturity).
Structured CDs that are insured by the FDIC are subject to applicable FDIC limits.
• Unit Investment Trust (UIT): An investment company that offers a fixed, unmanaged portfolio, generally of
stocks and bonds, as redeemable "units" to investors for a specific period of time. It is designed to provide
capital appreciation and/or dividend income. UITs can be resold in the secondary market. A UIT may be either
a regulated investment corporation (RIC) or a grantor trust. The former is a corporation in which the investors
are joint owners; the latter grants investors proportional ownership in the UIT's underlying securities.
Item 9 — Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that
would be material to a client’s evaluation of the Firm or the integrity of the Firm’s management. There are no legal
or material disciplinary events to disclose. Information is publicly available by selecting the Investment Adviser Search
option at www.adviserinfo.sec.gov.
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Item 10 — Other Financial Industry Activities and Affiliations
Broker-Dealer Registration
Advisor does not have a broker/dealer affiliation.
Material Relationships and Affiliations
Advisor does not have an insurance agency affiliation.
Futures/Commodity Registration
Neither Advisor nor any of the management persons are registered or has a registration pending to register as a
futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of
the foregoing entities.
Recommendation of Other Investment Advisers
Advisor does not recommend or select other investment advisers for its clients, and does not receive compensation
directly or indirectly from other advisers that would create a material conflict of interest. Advisor does not have
business relationships with other investment advisers that create material conflicts of interest with clients.
Insurance Agency Affiliations
Certain Investment Advisor Representatives are also a licensed insurance agents. Insurance Agents earn commission
compensation for selling insurance products. Commissions generated by insurance sales do not offset regular advisory
fees. This represents a conflict of interest. Clients are under no obligation to implement any recommendations made.
IARs of Clearview Financial Partners can also be insurance agents/brokers and may offer insurance products and
receive customary commissions, in states where the representative is properly licensed. An IAR is not paid both an
advisory fee and a commission for the same product. The conflict created by differing payment structures is mitigated
by the IAR’s fiduciary duty to act in the client’s best interest.
Affiliated General Partner of Clearview Fund I LP
The Adviser is affiliated with the general partner of Clearview Fund I LP and manages the Fund. This affiliation is a
material conflict of interest: the Adviser has a financial incentive to recommend that eligible clients invest in the Fund
because the affiliated general partner and/or the Adviser receives management fees and may receive a performance-
based allocation from the Fund. The Adviser addresses this conflict by recommending the Fund only to clients for
whom it is suitable and who meet applicable eligibility standards (accredited investor and, where applicable, qualified
client), by providing the Fund Offering Documents, and through its fiduciary duty. Clients are under no obligation to
invest in the Fund.
Other Affiliations
Mr. Fitzgerald is the owner of a separate legal entity, Blue Skies Financial LLC, held solely for tax and investment
purposes; the entity does not provide services or conduct business, and there are no conflicts of interest to disclose.
Item 11 — Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading
Clearview Financial Partners maintains a Code of Ethics that establishes a standard of business conduct for all
supervised persons based on the principles of openness, integrity, honesty, and trust. The Code of Ethics includes
guidelines regarding personal securities transactions, an Insider Trading policy, and Personal Securities Transactions
policies and procedures. Upon employment or affiliation, and at least annually thereafter, all supervised persons sign
an acknowledgment that they have read, understand, and agree to comply with the Code of Ethics.
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• The Code requires our staff to put your interests ahead of their own.
• You may request a copy of the Code at any time by contacting us.
As a fiduciary, the Adviser has a duty to provide fair and full disclosure of all material facts and to act solely in the
best interest of each client at all times. The Code of Ethics permits supervised persons and related persons to invest
in the same or different securities that an IAR may purchase for clients in program accounts; this creates a conflict of
interest that is monitored under the Code of Ethics.
Personal Trading in Same Securities as Clients
Advisor allows our Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities, we recommend (purchase or sell) to you presents a
conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As
noted above, we have adopted a Code of Ethics to address insider trading (material non-public information controls);
gifts and entertainment; outside business activities and personal securities reporting.
Personal Trading at Same Time as Clients
Supervised Persons may not purchase or sell any security immediately prior to or immediately after a transaction being
implemented for an advisory account, thereby preventing an employee from benefiting from transactions placed on
behalf of advisory accounts.
Participation or Interest in Client Transactions - Private Fund
The Advisor and its related persons have a financial interest in Clearview Fund I LP through the affiliated general
partner. When the Adviser recommends that an eligible client invest in the Fund, the Adviser is recommending a
security in which a related person has a financial interest, which is a conflict of interest. This conflict is disclosed in
Items 5, 6, and 10, is mitigated by the Adviser’s fiduciary duty and eligibility screening, and is subject to review by the
CCO. Related-person investments in the Fund and personal securities transactions are reported and reviewed under
the Code of Ethics.
Item 12 — Brokerage Practices
We consider the following when recommending a custodian: execution quality, commission rates, range of investment
options, research and technology support, and financial stability. We are not required to select the custodian with the
lowest commissions if other factors better serve your interests.
Best Execution
Best Execution 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.
Accordingly, although we will seek competitive rates, for the benefit of all clients, we may not necessarily obtain the
lowest possible commission rates for specific client account transactions. Our recommendations to our clients are
based on our clients’ interests in receiving best execution and the level of competitive, professional services.
Soft Dollars
Clearview Financial Partners receives soft dollar and support services and/or products from their custodians which
assist the firm to better monitor and service client accounts. These support services and/or products may be received
without cost, at a discount, and/or at a negotiated rate, and may include the following: investment-related research;
pricing information and market data; software and other technology that provide access to client account data;
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compliance and/or practice management-related publications; consulting services; attendance at conferences,
meetings, and other educational and/or social events; marketing support; computer hardware and/or software; and,
other products and services used in furtherance of investment advisory business operations. These support services
are provided to Clearview Financial Partners based on the overall relationship between Clearview Financial Partners.
Trade Aggregation
Clearview Financial Partners and its related persons may aggregate transactions in equity and fixed income securities
for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual
prices applicable to the aggregated transactions will be averaged, and the client account will be deemed to have
purchased or sold its proportionate share of the securities involved at the average price obtained. Clearview Financial
Partners and its related persons may determine not to aggregate transactions, for example, based on the size of the
trades, number of client accounts, the timing of trades, and the liquidity of the securities and the discretionary or
nondiscretionary nature of the trades. If Clearview Financial Partners or its related persons do not aggregate orders,
some clients purchasing securities around the same time may receive a less favorable price than other clients. This
means that this practice of not aggregating may cost clients more money.
Brokerage for Client Referrals
Advisor does not receive any compensation from any third party in connection with the recommendation for
establishing a brokerage account.
Directed Brokerage
Advisor recommends that clients establish a brokerage account with a selected qualified custodian for custody and
trade execution purposes. Advisor does not otherwise direct clients to use a specific broker-dealer for trade execution
beyond the recommended custodian. This recommendation is made in order to receive certain support services from
the custodian, which represents a potential conflict of interest. Clients are not required to use the recommended
custodian, but doing so is a condition of participating in certain services offered by the Advisor. Where a client directs
brokerage to a specific broker-dealer, the Advisor may be unable to achieve the most favorable execution of client
transactions, and the practice may cost clients more money. For example, in a directed brokerage account, the client
may pay higher brokerage commissions because the Advisor may not be able to aggregate orders to reduce transaction
costs, or the client may receive less favorable prices.
Item 13 — Review of Accounts
Account surveillance is conducted on an ongoing basis by David Fitzgerald, the Chief Compliance Officer. Client
review periods are generally annual, depending on market conditions, the client’s funding needs, and changes in
investment objectives. If a client experiences a change in financial situation, the Firm performs a review to confirm
the portfolio remains appropriate. Clients receive, at least quarterly, written transaction confirmations and summary
account statements directly from the qualified custodian and/or program sponsor.
• Clients are responsible for advising of any changes in their investment objectives and/or financial situation.
• Clients are encouraged to review financial planning issues, investment objectives, and account performance with
their IAR on an annual basis.
Private Fund Reporting
Investors in Clearview Fund I LP receive reporting as described in the Fund Offering Documents, which may include
periodic capital account statements, audited annual financial statements, and tax reporting (e.g., Schedule K-1).
Detailed Fund holdings information is generally available only through a secure investor portal.
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Item 14 — Client Referrals and Other Compensation
Any cash or non-cash compensation arrangement with a promoter for client referrals will comply with the SEC
Marketing Rule (Advisers Act Rule 206(4)-1), including required promoter disclosures and, where applicable, written
agreements and oversight. Clients referred through any such arrangement will not pay a higher fee as a result of the
referral.
REGULATORY CITATION
Advisers Act Rule 206(4)-1 (Marketing Rule), as amended (compliance date November 4, 2022), replacing former Rules
206(4)-1 and 206(4)-3.
Item 15 — Custody
Except as described below with respect to the private fund, Clearview Financial Partners does not have physical
custody of client funds or securities but is deemed to have limited custody as a result of its authority to deduct advisory
fees directly from client accounts. The qualified custodian sends account statements at least quarterly to clients,
showing all disbursements, including the amount of advisory fees paid, the value of client assets on which the fee was
based, and the manner in which the fee was calculated. Clients should review the fee calculated and deducted by the
custodian to confirm it was calculated correctly.
• Clients may authorize advisory fees to be deducted in advance from the client advisory account, or may receive
an invoice for fees deducted in arrears.
• Payment of fees may result in the liquidation of a client’s positions if there are insufficient funds in the account.
• Fees are assessed on all assets in the account(s), including securities, cash, and money market balances. Margin
debits do not reduce the value of the assets for billing purposes.
Custody of Private Fund Assets
Because the Adviser is affiliated with the general partner of Clearview Fund I LP and has authority over Fund assets,
the Adviser is deemed to have custody of the Fund’s assets under Advisers Act Rule 206(4)-2. The Adviser intends
to comply with the custody rule by relying on the “audited financial statements” exception: the Fund will be audited
at least annually by an independent public accountant registered with, and subject to inspection by, the PCAOB, and
audited financial statements prepared in accordance with U.S. GAAP will be distributed to all Fund investors within
120 days of the Fund’s fiscal year-end (180 days for a fund of funds).
REGULATORY CITATION
Advisers Act Rule 206(4)-2 (Custody Rule); pooled-vehicle audited-financial-statement exception, Rule 206(4)-2(b)(4).
Item 16 — Investment Discretion
Clearview Financial Partners provides investment advisory services on a discretionary basis. Before the Firm assumes
discretionary authority over a client’s account, the client must grant permission by executing an advisory agreement
naming the Firm as the client’s attorney-in-fact and agent. This authority grants the Firm full discretion to buy and
sell the type and amount of securities on behalf of the client, or otherwise effect investment transactions involving
the assets in the client’s discretionary account. With respect to Clearview Fund I LP, the Adviser exercises investment
discretion over Fund assets in accordance with the Fund Offering Documents.
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Item 17 — Voting Client Securities
Clearview Financial Partners does not vote client proxies. Clients receive their proxies and other solicitations directly
from their custodian and retain exclusive responsibility for voting proxies and for making elections relating to mergers,
acquisitions, tender offers, bankruptcy proceedings, and similar events for securities in their accounts. Clients may
contact the Firm at (610) 293-9211 with questions about a particular solicitation; for assistance on a proxy voting
issue, clients should contact the offering company. Third-party money managers selected or recommended by the
Firm may vote proxies for clients; except where a third-party manager votes proxies, clients maintain exclusive proxy-
voting responsibility.
Item 18 — Financial Information
Clearview Financial Partners does not require or solicit prepayment of more than $1,200 in fees per client six or more
months in advance. There are no financial conditions reasonably likely to impair the Firm’s ability to meet contractual
commitments to clients. The Firm has not been the subject of a bankruptcy petition.
[Remainder of Page Intentionally Left Blank]
Clearview Financial Partners, LLC
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Form ADV Part 2A — Clearview Financial Partners, LLC
Item 1 — Cover Page
Registered as Clearview Financial Partners, LLC | CRD No. 286168
Doing Business As: Clearview Financial Partners
Wrap Fee Program Brochure
(Appendix 1 to Form ADV Part 2A)
100 Matsonford Road – Building #5, Suite 110 | Radnor, PA 19087 | Phone: (610) 293-9211
NOTICE TO PROSPECTIVE CLIENTS: READ THIS DISCLOSURE BROCHURE IN ITS ENTIRETY
June 15, 2026
This brochure provides information about the qualifications and business practices of Clearview Financial Partners.
If you have any questions about its contents, please contact us at (610) 293-9211 or david@cvfpartners.com. The
information in this brochure has not been approved or verified by the SEC or by any state securities authority.
Additional information is available at www.adviserinfo.sec.gov. Registration does not imply a certain level of skill or
training. If a copy of this brochure is not provided at least 48 hours prior to signing a contract, clients have five (5)
business days to cancel without penalty.
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Item 2 — Material Changes
There are no material changes to disclose since the previous annual amendment filed on March 15, 2025. We will
ensure that you receive a summary of any material changes within 120 days of the close of our fiscal year and will
provide a new Brochure as necessary, without charge.
1. There are no additional material changes to disclose
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Item 3 — Table of Contents
Item 1 — Cover Page .......................................................................................................................................................... 27
Item 2 — Material Changes ................................................................................................................................................. 28
Item 3 — Table of Contents ............................................................................................................................................... 29
Item 4 — Services, Fees, and Compensation .................................................................................................................... 30
Item 5 — Account Requirements and Types of Clients ................................................................................................... 31
Item 6 — Portfolio Manager Selection and Evaluation .................................................................................................... 32
Item 7 — Client Information Provided to Portfolio Managers ....................................................................................... 32
Item 8 — Client Contact with Portfolio Managers ........................................................................................................... 32
Item 9 — Additional Information ...................................................................................................................................... 32
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Form ADV Part 2A — Clearview Financial Partners, LLC
Item 4 — Services, Fees, and Compensation
Services
Clearview Financial Partners offers discretionary asset management services on a wrap or non-wrap fee basis. The
Firm does not directly hold securities or have direct access to client assets except with respect to its affiliated private
fund. Client accounts are maintained at one or more qualified custodians.
Firm Management
David L. Fitzgerald (CRD No. 1927550) is the principal owner with a 100% ownership interest and serves as President
and Chief Compliance Officer (CCO). Mr. Fitzgerald is also an insurance agent of various unaffiliated insurance
carriers. He has worked in financial services since 1989 after graduating from Drexel University with dual degrees in
Finance and Marketing.
Fees
In the Clearview Financial Partners Wrap program, clients pay a single annual advisory fee for advisory services and
the execution of transactions. Clients do not pay brokerage commissions, markups, or transaction charges in addition
to the advisory fee. The advisory fee is negotiable and is set out in the advisory agreement. The fee is a percentage of
all assets in the account, including cash.
Assets Under Management
Annual Fee
$0 – $1,000,000
1.60%
$1,000,001 – $3,000,000
1.35%
$3,000,001 – $4,000,000
1.00%
$4,000,001 – $5,000,000
0.90%
Over $5,000,000
Negotiable
The advisory fee will be calculated and deducted quarterly, in advance or in arrears, based on written client
authorization. If the agreement is terminated before the end of a quarter, the client is entitled to a pro-rated refund
of any pre-paid fee for the remaining days in the quarter, processed by the custodian.
Mutual Fund Share Class Disclosure and Fiduciary Duty (12b-1 Fees)
Section 206 of the Advisers Act imposes a fiduciary duty to act in a client’s best interests. When selecting a mutual
fund share class, the IAR has a fiduciary duty to select the share class that appropriately manages the overall fee
structure of the account. In a wrap program, A-share ticket charges are paid by the adviser and included in the wrap
fee, so A shares do not offer the same client benefit as in a non-wrap account; conversely, the adviser then has an
incentive to trade less frequently to avoid ticket charges, which is mitigated by the IAR’s fiduciary duty and the higher
wrap fee.
Other Types of Fees and Charges
Program accounts incur additional third-party fees not shared by the Firm, including custodian and executing broker-
dealer charges, mutual fund/ETF expenses (a second layer of fees for pooled products), contingent deferred sales
charges, redemption and frequent-trading fees, and variable annuity mortality, expense, administrative, and rider
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charges. Clients are notified of custodial charges at account opening, and further information is available in the
applicable prospectus.
Private Fund Within the Wrap Context
To the extent an eligible client allocates assets to the Firm’s affiliated private fund, Clearview Fund I LP, those assets
are subject to the separate fee, conflict, and risk disclosures in the Form ADV Part 2A and the Fund Offering
Documents, and are generally not held in a wrap program account. The Firm will not charge a wrap or separate-
account advisory fee on assets invested in the Fund in addition to the Fund-level management fee.
Other Considerations
The advisory fee may cost more than purchasing the program services separately or holding assets in a brokerage
account; clients following a buy-and-hold strategy or not wishing ongoing advice should consider a brokerage account.
The Firm receives compensation for recommending the program, creating an incentive to recommend it over other
programs, mitigated by the Firm’s fiduciary duty. Investment products available in the program may be purchased
elsewhere. IARs who are insurance agents may earn commissions, a conflict subject to CCO review.
Retirement Plan Consulting, ERISA, and Rollovers
IARs may provide fee-based retirement plan consulting (IPS assistance, liaison services, monitoring, performance
reporting, recommendations, committee education, and enrollment support). Where engaged to provide ongoing
monitoring and recommendations to an ERISA plan, the IAR is an ERISA fiduciary under Section 3(21)(A)(ii); other
services are not ERISA “investment advice.” For rollovers, the Firm may recommend rolling retirement assets into
an IRA it manages and has a financial incentive to do so, mitigated by its fiduciary duty.
Third-Party Investment Advisers
The Firm may refer clients to third-party advisers (properly registered/notice-filed) and receives compensation for
such referrals and ongoing services, typically a percentage of the third-party adviser’s fee. This creates an incentive to
recommend one third-party adviser over another, mitigated by the Firm’s fiduciary duty. Clients receive full disclosure,
including the third-party adviser’s Form ADV 2A and a solicitation disclosure statement.
eMoney Advisor Platform and Artificial Intelligence
The Firm may provide clients access to the eMoney Advisor platform to view complete asset allocation, including
Excluded Assets, and to use financial planning tools. The Firm exercises a fiduciary duty only when engaged to manage
otherwise-excluded assets or to provide guidance using the planning tools. The Firm may use supervised, transparent
AI tools (e.g., real-time note-taking, research, and project management) consistent with its data-privacy and ethics
commitments; participants are informed of AI usage and may opt out of AI-generated note-taking.
Item 5 — Account Requirements and Types of Clients
The Firm generally provides advice to individuals, high-net-worth individuals, and small businesses, and also to
banks/thrifts, estates, charitable organizations, government entities, corporations, and pension plans. The account
minimum is generally $1,000,000; the Firm may open a smaller account at management’s discretion.
The Firm also manages the affiliated private fund, Clearview Fund I LP, available only to accredited investors and,
where performance-based compensation applies, qualified clients.
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Item 6 — Portfolio Manager Selection and Evaluation
In the wrap program, Clearview Financial Partners is responsible for the investment advice and management. IARs
serve as the portfolio manager and are generally required to have several years of experience and a college degree
and/or professional designation. Because IARs serve directly as portfolio manager, there is no selection process for
outside portfolio managers. Performance reports are provided quarterly by the Firm or the custodian. The wrap
program is managed the same way as other accounts; the Firm may charge up to 1.60% and the combined total fee
will not exceed 1.60%.
Methods of Analysis, Investment Strategies, and Risk of Loss
Analysis and strategies are generally based on publicly available data, a client’s net worth, risk tolerance, goals, and
third-party research. Each portfolio is designed for a particular goal and reviewed and rebalanced as appropriate.
Investing involves risk of loss that clients should be prepared to bear; past performance is not indicative of future
results. Principal risks include market, interest-rate, credit, business, liquidity, inflation, and currency risk, among
others. Clients eligible for the affiliated private fund should review the private-markets risk factors in the Form ADV
Part 2A and the Fund Offering Documents (illiquidity, valuation uncertainty, leverage, concentration, and multi-
manager/underlying-fund risk).
Item 7 — Client Information Provided to Portfolio Managers
Because IARs of Clearview Financial Partners serve as the portfolio manager for wrap program accounts, client
information gathered to determine suitability (financial situation, investment objectives, risk tolerance, and time
horizon) is used directly by the IAR managing the account. Where the Firm refers a client to a third-party adviser,
relevant client information is provided to that adviser as described in the applicable agreements and disclosures.
Item 8 — Client Contact with Portfolio Managers
Clients may contact their IAR (who serves as portfolio manager) without restriction during normal business hours to
discuss their account, investment objectives, or financial situation.
Item 9 — Additional Information
Disciplinary Information and Other Financial Industry Activities
There are no legal or material disciplinary events to disclose. IARs may be licensed insurance agents who earn
commissions (a conflict subject to CCO review) and the Firm is affiliated with the general partner of Clearview Fund
I LP (a conflict disclosed in the Form ADV Part 2A).
Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading
The Firm maintains a Code of Ethics establishing standards of business conduct, an insider-trading policy, and
personal-securities reporting requirements. The Firm and its related persons have a financial interest in the affiliated
private fund; recommending the Fund to eligible clients is a conflict disclosed in the Form ADV Part 2A and
monitored under the Code of Ethics. A copy of the Code of Ethics is available upon request.
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Review of Accounts
IARs review client accounts at least annually for consistency with stated objectives, and upon triggering events such
as a change in objectives or financial situation, market corrections, or client request. Clients are responsible for
advising the Firm of changes in their objectives or financial situation.
Client Referrals and Other Compensation
The Firm and its associated persons can receive non-cash compensation from product sponsors (e.g., gifts, occasional
meals or event tickets, training/education reimbursement) not tied to product sales. The Firm may receive support
services from its custodian(s) (research, market data, software, compliance publications, consulting, conference
attendance, marketing support, and hardware/software). Clients do not pay more for services as a result, and there is
no commitment to direct a specific amount of client assets in exchange. Receipt of such economic benefits is a
potential conflict that may influence the Firm’s choice of custodian, mitigated by its fiduciary duty and best-execution
obligations.
Financial Information and Custody
The qualified custodian(s) maintain custody of client funds and securities in separate accounts under each client’s
name; the Firm is deemed to have limited custody as a result of fee deduction. With respect to Clearview Fund I LP,
the Firm is deemed to have custody under Advisers Act Rule 206(4)-2 and intends to comply via the annual-audit
exception (PCAOB-registered auditor; audited GAAP statements distributed to investors within 120/180 days).
The Firm does not require or solicit prepayment of more than $1,200 in fees per client six or more months in advance,
has no financial condition reasonably likely to impair its commitments, and has never been the subject of a bankruptcy
petition.
Brokerage Practices, Trade Aggregation, and Cash Sweep
In seeking best execution, the determinative factor is the best qualitative execution considering the full range of a
broker-dealer’s services, not solely the lowest cost. The Firm may aggregate equity and fixed income transactions
across clients to improve execution; aggregated transactions receive an averaged price, and the Firm may decline to
aggregate based on size, number of accounts, timing, liquidity, and discretionary/non-discretionary nature. The Firm
uses custodian cash-sweep programs to manage liquidity; swept cash earns interest, typically at lower rates than other
short-term options, and clients should weigh liquidity and convenience against potential returns.
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Privacy Policy
Our Commitment to You
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. Advisor (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. Advisor does not sell your non-public personal information to anyone. Nor do we provide
such information to others except for discrete and reasonable business 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.
Why?
Financial companies choose how they share your personal information. Federal law gives consumers
the right to limit some but not all sharing. Federal law also requires us to tell you how we collect,
share, and protect your personal information. Please read this notice carefully to understand what we
do.
As a registered investment adviser, we are required by federal and state law to share some of your personal information
in order to service your account. The law also gives you the right to limit certain sharing.
What Information Do We Collect From You?
Account Information (including other institutions)
Account numbers, balances
Assets and Liabilities
Date of Birth
E-mail Address(es)
Employment Information and/or Government ID
Expenses
Income
Investment Activity
Investment Experience
Investment Objectives
Licenses
Name, Address, and Phone Number(s)
Net worth information
Professional credentials
Risk tolerance
Social Security or Taxpayer Identification Number
Transaction history
What Information Do We Collect From Other Sources?
Custody, brokerage, and advisory agreements
Account terms and conditions
Other advisory agreements and legal documents
Legal and advisory arrangements
Transactional information with us or others
Transaction records
Account applications and forms
Application data
Investment questionnaires and suitability documents
Risk and suitability data
How We Protect Your Information?
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We use physical, procedural, and electronic safeguards to protect your information — including encrypted file storage,
secure passwords, and a secure office environment. We train our staff on privacy obligations and require third-party
service providers to protect the information we share with them.
Yes
No
How and When We Share Your Information
Servicing .
We share non-public personal information with non-affiliated third parties (such as
administrators, brokers, custodians, regulators, credit agencies, consultants, or other financial
institutions) as necessary to provide agreed-upon services, including processing transactions,
general account maintenance, responding to regulators or legal investigations, and credit
reporting.
No
N/A
Marketing Purposes.
We do not disclose, and do not intend to disclose, personal information with non-affiliated third
parties to offer you services. We will only share information for purposes of servicing your
accounts, not for marketing purposes.
Yes
Yes
Authorized Users.
Your non-public personal information may be disclosed to you and persons that we believe to
be your authorized agent(s) or representative(s) such as accountant or attorney.
No
N/A
Former Clients.
We do not disclose and do not intend to disclose non-public personal information to non-
affiliated third parties with respect to persons who are no longer our Clients.
Affiliate Marketing.
Yes
Yes
Non-Affiliated Marketing
No
N/A
Other Important Information
Information for California, North Dakota, and Vermont Customers. In response to applicable state law, if the
mailing address provided for your account is in California, North Dakota, or Vermont, we will automatically treat
your account as if you do not want us to disclose your personal information to non-affiliated third parties for
purposes of them marketing to you, except as permitted by the applicable state law.
Changes to This Policy
If we make a material change we will send you an updated policy make material changes, we will send you an updated
copy. We will not change this Policy to permit new sharing without first notifying you and giving you the opportunity
to opt out.
Questions?
Contact us at (610) 293-9211 or david@cvfpartners.com
Clearview Financial Partners, LLC
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