View Document Text
Item 1 Cover Page
Registered as Clearview Financial Partners, LLC | CRD No. 286168
Doing Business As: Clearview Financial Partners
100 Matsonford Road – Building #5, Suite 110 | Radnor, PA 19087
Phone: (610) 293-9211
ADV 2A – Firm Disclosure Brochure
February 27, 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.
Page 1 of 28
Item 2 – Material Changes
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.
• There are no material changes to disclose since the previous annual amendment filed on 03/15/2025.
• 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 Web Site
www.adviserinfo.sec.gov. The SEC’s Web Site also provides information about any persons affiliated with
Clearview Financial Partners who are registered, or are required to be registered, as investment adviser
representatives of Clearview Financial Partners.
Page 2 of 28
Item 3 – Table of Contents
Part 2A
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 ……………………………………………………………………………….….…... 12
Item 6 – Performance-Based Fees and Side-by-Side Management ……………………………………………...…… 15
Item 7 – Types of Clients …………………………………………………………………………………….…..…… 16
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ………………………………..….………... 16
Item 9 – Disciplinary Information ……………………………………………………………………………..….….. 21
Item 10 – Other Financial Industry Activities and Affiliations ……………………………………….….……….….. 21
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .……….………..… 21
Item 12 – Brokerage Practices ……………………………………………………………………….………….….… 22
Item 13 – Review of Accounts ……………………………………………………………………………….…..…... 25
Item 14 – Client Referrals and Other Compensation ……………………………………………….………….…..… 26
Item 15 – Custody …………………………………………………………………………………….………..…….. 27
Item 16 – Investment Discretion ………………………………………………………………….…………..……… 27
Item 17 – Voting Client Securities …………………………………………………………….……………..………. 28
Item 18 – Financial Information ……………………………………………………………….……………..……… 28
Page 3 of 28
Item 4 – Advisory Business
The Firm
The firm became an independent registered investment adviser in 2017 in order to directly offer asset
management and financial planning services. Investment Adviser Representatives of the firm are also
registered representatives of LPL Financial, a FINRA/SIPC member broker/dealer, to offer brokerage
services under the Doing Business Name of Clearview Financial Partners, founded in 2017. Clearview
Financial Partners is a separate, independent entity that is legally unaffiliated with LPL Financial.
Investment advisor representatives are also insurance agents appointed with various insurance carriers
to offer insurance products.
• The firm offers discretionary asset management services for 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. The firm has a
custodial relationship with LPL Financial LLC (LPL), and Charles Schwab & Co., Inc.
(Schwab) for the safekeeping of client assets.
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). In addition to offering advisory services,
Mr. Fitzgerald is a registered representative of LPL Financial to offer securities transaction in a separate
and unaffiliated capacity as well as an insurance agent of various unaffiliated insurance carriers.
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
Investment advisor representatives of Clearview Financial Partners primarily provide discretionary fee-
based asset management services to individual clients and high-net worth individuals as well as small
businesses (client approval is required in advance of any non-discretionary transaction). More
specifically, they provide 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 where investment advisor
representatives directly select and manage the specific securities based on a client’s investment profile.
The firm also offers advisory programs where the underlying investments are selected and managed by
independent professional portfolio managers. A broad range of portfolio managers and multiple
investment styles are available, including equity, fixed income, asset classes, mutual funds, ETFs, and
specialty strategies. More specific account information and acknowledgements are detailed in the
account opening documents. These programs are managed based on the investment objective of the
portfolio without regard for particular clients of Clearview Financial Partners.
Page 4 of 28
Clearview Financial Partners is responsible to:
• obtain the necessary financial data from each client;
• select the proper advisory program;
• determine the investment allocation; and,
• provide tailored investment advice based on a client’s investment objective.
Accounts are reviewed on a regular basis and rebalanced as necessary according to each client’s
investment profile. Depending on the anticipated level of trading and account size, investment advisor
representatives of Clearview Financial Partners will work with each client to determine the most cost-
effective fee structure.
The account minimum for an asset management account is generally $1,000,000.00; however, the firm
reserves the right to open an account for a lesser amount to accommodate a client referral or family
member as well as other reasons at the discretion of management.
Assets Under Management
Discretionary
$1,058,194,989
Non-Discretionary
$0.00
Sub-Advisor
Discretionary asset management includes the ability to hire and fire 3rd party investment managers. The
fees for a 3rd party investment manager can be either paid by direct deduction from the clients’ account at
the custodian or paid by Clearview Financial Partners from the fees the Advisor deducted for asset
management services.
Wrap Fee Program
A wrap fee program is a comprehensive advisory account with a single fee that covers a bundle of
services, such as, portfolio management, advice, and investment research as well as trade execution,
custody and reporting fee. The fee is not based directly upon advisory services or the execution of
transactions. Clearview Financial Partners is the sponsor and acts as the portfolio manager of a wrap
fee program – please see Appendix 1 (offered separately) for additional details.
Financial Planning Services
Clearview Financial Partners through its investment advisor representatives generally provides
financial planning as part of a comprehensive asset management engagement. However, financial
planning is available separately for a separate fee. The type of plan can vary greatly depending on the
scope and complexity of a particular individual’s financial situation but may include:
Planning Strategies for Families and Individuals
• Retirement – planning an investment strategy with the objective of providing inflation-adjusted
income for life.
Page 5 of 28
• College / Education – planning to pay the future college / education expenses of a child or
grandchild.
• Insurance Needs – planning for the financial needs of survivors to satisfy such financial obligations
as housing, dependent childcare and spousal arrangements as well as education.
• Estate Planning – planning that focuses on the most efficient and tax friendly option to pass on an
estate to a spouse, other family members or a charity.
• Cash Flow/ Budget Planning – planning to manage expenses against current and projected income.
• Wealth Accumulation – planning to build wealth within a portfolio that takes into consideration
risk tolerance and time horizon.
• Tax Planning – planning a tax efficient investment portfolio to maximize deductions and off-setting
losses.
• Investment Planning – planning an investment strategy consistent with a particular objectives, time
horizons and risk tolerances.
• Inheritance Planning – planning for a tax efficient method to pass wealth to the next generation.
Planning Strategies for Businesses
• Business Entity Planning – review the various forms of business structures in relation to liability
and income tax considerations.
• Qualified Retirement Plans – evaluate the types of retirement plans established by an employer for
the benefit of the company’s employees.
• Stock Option Planning – planning to maximize the value of employer issued stock options and
optimize what to exercise and what to hold.
• Key Person Planning – evaluate the life insurance needs required in the event of the sudden loss of
a key executive in order to buy time to find a new person or to implement other strategies to continue
the business.
• Executive Benefits – planning to attract, reward and retain top executive talent.
• Deferred Compensation Plans – planning for the use of tax deferred funds to be withdrawn and
taxed at some point in the future.
Page 6 of 28
• Business Succession Planning – planning for the continuation of a business after key executives
move on to new opportunities, retire or pass away with the use of buy-sell agreements, key-man
insurance and engaging independent legal counsel as needed.
Retirement Plan Consulting
Investment advisor representatives of Clearview Financial Partners may assist clients that are trustees
or other fiduciaries to retirement plans (“Plans”) by providing fee-based consulting and/or advisory
services. Investment advisor representatives may perform one or more of the following services, as
selected by the client in the client agreement:
• Assistance in the preparation or review of an investment policy statement (“IPS”) for the Plan
based upon consultation with client to ascertain Plan’s investment objectives and constraints.
• Acting as a liaison between the Plan and service providers, product sponsors or vendors.
• Ongoing monitoring of investment manager(s) or investments in relation to the criteria
specified in the Plan’s IPS or other written guidelines provided by the client.
• Preparation of reports describing the performance of Plan investment manager(s) or
investments, as well as comparing the performance to benchmarks.
• Ongoing recommendations, for consideration and selection by client, about specific
investments to be held by the Plan or, in the case of a participant-directed defined contribution
plan, to be made available as investment options under the Plan.
• Education or training for the members of the Plan investment committee with regard to
various matters, including plan features, retirement readiness matters, service on the
committee, and fiduciary responsibilities.
• Assistance in enrolling Plan participants in the Plan, including conducting an agreed upon
number of enrollment meetings. As part of such meetings, IARs may provide participants
with information about the Plan, which may include information on the benefits of Plan
participation, the benefits of increasing Plan contributions, the impact of pre-retirement
withdrawals on retirement income, the terms of the Plan and the operation of the Plan.
If the Plan makes available publicly traded employer stock (“company stock”) as an investment option
under the Plan, investment advisor representatives do not provide investment advice regarding company
stock and are not responsible for the decision to offer company stock as an investment option. In
addition, if participants in the Plan may invest the assets in their accounts through individual brokerage
accounts, a mutual fund window, or other similar arrangement, or may obtain participant loans,
investment advisor representatives do not provide any individualized advice or recommendations to the
participants regarding these decisions. Furthermore, investment advisor representatives do not provide
individualized investment advice to Plan participants regarding their Plan assets.
Page 7 of 28
Retirement Plan Rollovers
An employee generally has four (4) options for their retirement plan when they leave an employer:
1. Leave the money in his/her former employer’s plan, if permitted
2. Rollover the assets to his/her new employer’s plan, if one is available and permitted
3. Rollover to an Individual Retirement Account (IRA), or
4. Cash out the account value, which has significant tax considerations
Clearview Financial Partners may recommend that retirement plan assets be rolled-over into an IRA
Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement
funds to an IRA for us to manage here are a few points to consider before you do so:
• Determine whether the investment options in your employer's retirement plan address your
needs or whether you might want to consider other types of investments.
• Employer retirement plans generally have a more limited investment menu than IRAs.
• Employer retirement plans may have unique investment options not available to the public
such as employer securities, or previously closed funds.
• Your current plan may have lower fees than our fees.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the agreement you executed with our firm. This practice presents a
conflict of interest because Investment Advisor Representatives have an incentive to recommend a
rollover to you for the purpose of generating fee-based compensation rather than solely based on your
needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if
you do complete the rollover, you are under no obligation to have the assets in an IRA managed by
our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following
options are available, you should consider the costs and benefits of each. An employee will typically
be investing only in mutual funds, you should understand the cost structure of the share classes,
available in your employer's retirement plan and how the costs of those share classes compare with
those available in an IRA. Clients should understand the various products and services they might
take advantage of at an IRA provider and the potential costs of those products and services.
• Our strategy may have higher risk than the option(s) provided to you in your plan.
• Your current plan may also offer financial advice.
•
If you keep your assets titled in a 401k or retirement account, participants could potentially
delay their required minimum distribution beyond age.
• A 401(k) may offer more liability protection than a rollover IRA; each state may vary.
Page 8 of 28
• Participants may be able to take out a loan on your 401k, but not from an IRA.
•
IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they qualify for an
exception such as disability, higher education expenses or the purchase of a home.
•
If company stock is owned in a plan, participants may be able to liquidate those shares at a
lower capital gains tax rate.
• Plans may allow Advisor to be hired as the manager and keep the assets titled in the plan
name.
Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have
been generally protected from creditors in bankruptcies. However, there can be some exceptions to
the general rules so you should consult with an attorney if you are concerned about protecting your
retirement plan assets from creditors.
It is important to understand the differences between these types of accounts and to decide whether a
rollover is the best option. Prior to proceeding, if you have questions contact your Investment Adviser
Representative, or call our main number as listed on the cover page of this brochure.
When Advisor provides investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws
governing retirement accounts. The way we make money creates some conflicts with your interests,
so we operate under a special rule that requires us to act in your best interest and not put our interest
ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give
prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Advisor also provides educational services to retirement plan participants with assets that could
potentially be rolled-over to an IRA advisory account. Education is based on a particular Client’s
financial circumstances and best interests. Again, Advisor has an incentive to recommend such a
rollover based on the compensation received, which is mitigated by the fiduciary duty to act in a
Client’s best interest and acting accordingly.
ERISA Fiduciary
Such services provided as an investment advisor are subject to the Investment Advisers Act of
1940 (“Advisers Act”), and the advisor is a fiduciary under the Advisers Act with respect to such
Page 9 of 28
services. In addition, if client elects to engage an investment advisor representative to perform ongoing
investment monitoring and ongoing investment recommendation services to a Plan subject to ERISA in
the client agreement, such services will constitute “investment advice” under Section 3(21)(A)(ii) of
ERISA. Therefore, the investment advisor representatives will be deemed a “fiduciary” as such term is
defined under Section 3(21)(A)(ii) of ERISA in connection with those services. Clients should
understand that to the extent the investment advisor representative is engaged to perform services other
than ongoing investment monitoring and recommendations, those services are not “investment advice”
under ERISA and therefore, the investment advisor representative will not be a “fiduciary” under ERISA
with respect to those other services.
From time to time the investment advisor representative may make the Plan or Plan participants aware
of and may offer services available from IAR that are separate and apart from the services provided
under Retirement Plan Consulting. Such other services may be services to the Plan, to a client with
respect to client's responsibilities to the Plan and/or to one or more Plan participants. In offering any
such services, the investment advisor representative is not acting as a fiduciary under ERISA with
respect to such offering of services. If any such separate services are offered to a client, the client will
make an independent assessment of such services without reliance on the advice or judgment of the IAR.
Conflicts of Interest
Investment adviser representatives must fully disclose all material facts concerning any conflict
and should avoid even the appearance of a conflict of interest and abide by honest and ethical
business practices.
•
•
Investment advisor representatives of Clearview Financial Partners are also registered
representatives of LPL Financial to other securities transactions for a commission.
Investment advisor representatives of Clearview Financial Partners are also investment adviser
representatives with other registered investment advisors.
•
Investment advisor representatives of Clearview Financial Partners are also insurance agents
appointed with multiple insurance carriers to sell insurance products for a commission.
o The recommendation that a client purchase a commission product from an
investment advisor representative in their separate capacity as a registered
representative of LPL or as an agent of an insurance company presents a conflict of
interest, as the receipt of commissions provides an incentive that may not be in a
client’s best interests.
•
Investment advisor representatives must not induce trading in a client's account that is
excessive in size or frequency in view of the financial resources and character of the account.
•
•
Investment advisor representatives must make recommendations with reasonable grounds to
believe that they are appropriate based on the information furnished by the client.
Investment advisor representatives may not borrow money or securities from or lend money or
securities to a client.
Page 10 of 28
•
Investment advisor representatives must not place an order for the purchase or sale of a
security if the security is not registered, or the security or transaction is not exempt from
registration in the specific state.
• Product sponsors may pay for or reimburse Clearview Financial Partners for the costs
associated with, education or training events.
• The code of ethics permits employees and investment advisor representatives or related
persons to invest for their own personal accounts in the same or different securities that an
investment advisor representative may purchase for clients in program accounts.
Such conflicts and risk of misconduct are mitigated by an investment adviser representative’s fiduciary
duty to act in the best interests of its clients and acting accordingly. The firm’s Chief Compliance
Officer, David Fitzgerald, is available to address any questions regarding conflicts of interest.
eMoney Advisor Platform
Clearview Financial Partners may provide clients with access to an online platform hosted by
“eMoney Advisor” (“eMoney”). The eMoney platform allows a client to view his/her complete asset
allocation, including those assets not managed by Clearview Financial Partners, known as “Excluded
Assets”. The eMoney tool also has financial planning tools. That can be used directly by a client.
Clearview Financial Partners is only able to exercise a fiduciary duty when engaged to manage
otherwise excluded assets or provide guidance and oversight when using the financial planning tools
provided with the eMoney platform.
Artificial Intelligence
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 tools can be used to
enhance our services, improve operational efficiency, and deliver 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. For example, real-time note-
taking to enhance accuracy, efficiency, and productivity. AI can also be used to analyze large volumes
of data and identifying patterns to help develop preliminary concepts, streamline research processes,
and enhance decision-making.
While artificial intelligence technologies aim to enhance efficiency, accuracy, and investment
outcomes, their use introduces specific risks that clients should consider. Using AI in decision-making
can result in overreliance on technology, potentially reducing human oversight. Unexpected system
malfunctions, algorithmic errors, or misinterpretations of AI-generated insights could adversely affect
investment outcomes. Clearview Financial Partners requires human oversight of AI tools. Clients are
encouraged to discuss any concerns about AI-related risks.
Page 11 of 28
Other Considerations
Neither the firm nor any investment advisor representative are registered or have an application pending to
register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or a
representative of the foregoing. Clearview Financial Partners is not a law firm or an accounting firm and
does not offer legal or accounting services. Accordingly, Clearview Financial Partners does not prepare
legal documents or prepare tax returns. Clearview Financial Partners may introduce clients to other
professionals for such non-investment related services, which in some cases may be an investment adviser
representative of Clearview Financial Partners acting in an unaffiliated separate individual capacity.
Clients are under no obligation to use these professionals and should conduct their own due diligence prior
to engaging their services. Clearview Financial Partners should not be considered a party to any disputes
that may arise. Certain mutual funds recommended by investment adviser representatives of Clearview
Financial Partners are publicly available for purchase without engaging the services of Clearview
Financial Partners. However, if a client elects to make such direct purchases, they do so without the
benefit of the on-going advisory services offered by Clearview Financial Partners.
Item 5 – Fees and Compensation
Investment advisor representatives may only provide services and charge fees based on the account
agreement. However, the exact service and fees charged to a particular client are dependent upon the
representative that is working with the client. Investment advisor representative will consider the
individual needs of each client when recommending an advisory platform. Furthermore, investment
strategies and recommendations are tailored to 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 of Clearview Financial Partners may enter into a
separate agreement regarding how fees are collected.
• The qualified custodian sends clients of Clearview Financial Partners quarterly performance
report that details the:
time period covered by the fee.
o amount of the fee charged;
o amount of assets subject to the fee; and,
o
The specific fee charged is negotiated based on the below fee schedule and 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.
Asset Under Management
$0 - $1,000,000
$1,000,001 to $3,000,000
$3,000,001 - $4,000,000
$4,000,001 - $5,000,000
Over $5,000,000
Annual Fee*
1.50%
1.25%
0.90%
0.80%
Negotiable
* There is generally an additional .10% fee for a wrap fee account that is in addition to the above ranges.
Page 12 of 28
Clients may also incur certain charges imposed by third-parties in connection with investments made
in the account(s), including , but not necessarily limited to, the following types of charges: investment
managers, mutual fund management fees and administrative serving fees, mutual fund 12b-1 fees,
certain deferred sales charges on previously purchased mutual funds, clearing, custody, postage and
handling, other transaction charges and service fees (i.e. account transfer fees, wire transfer fees,
termination fees, etc.) interest on debt balances, IRA Qualified Retirement Plan fees, and other costs or
charges with securities transactions mandated by law. Further information regarding charges and fees
assessed by a mutual fund or other securities sponsors is available in the appropriate prospectus or
disclosure statement.
Mutual Fund Share Class Disclosure and Fiduciary Duty (12b-1 Fees)
Section 206 of the Investment Advisers Act of 1940 (“Advisers Act”) imposes a fiduciary duty to act in
a client’s best interests and specifically prohibits investment advisers, directly or indirectly, from
engaging in any transaction, practice, or course of business which operates as a fraud or deceit upon
any client or prospective client.
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.
When selecting a mutual fund for a client’s advisory account, the investment advisor representative has
a fiduciary duty to select the share class that helps manage the overall fee structure of the account. The
overall fee structure includes such fees as:
• Asset Management Fee (Not to exceed 2%)
• Expense ratio, which includes 12b-1 fees, generally .25% for A shares.
• Trade Ticket Charges
o Equities and ETFs are $9.
o Mutual Funds, range from $0 to $26.50.
A Shares include 12b-1 fees but there are no ticket charges.
I Shares do not include 12b-1 fees there are ticket charges.
The more beneficial share class depends on an analysis of ticket charges and expected 12b-1 fees.
Investing in a 12b-1 fee paying share class can be less expensive for a client than investing in the I
Share class with a lower expense ratio if the ticket charges on the lower-cost share class exceed the
amount of ongoing 12b-1 fees.
A fee comparison for a $100,000 account verses a $1,000,000 account helps to demonstrate the
application of the different fee structures.
• For a $100,000 account the overall fee is $750 less when A shares are selected.
Page 13 of 28
Conversely, the overall fees are $1,705 more when the A shares are selected for a
$1,000,000 account.
Management Fee
Total
1.25%
1.00%
$1,250
$10,000
$1,500
$12,500
Management Fee
Total
Investment
Amount
$100,000
$1,000,000
Investment
Amount
$100,000
$1,000,000
A shares
(.25% basis Points)
$250
$2,500
I Shares
($26.50 for 30 trades)
$795
$795
1.25%
1.00%
$1,250
$10,000
$2,045
$10,795
Please note that same asset management fee is used for both A shares and I shares as a control but
accounts with I shares generally have a higher asset management fee to account for the ticket charges
which would reduce the $1,705 fee difference. Another consideration is that most accounts do not
contain a single asset class or identical mutual fund share classes, instead accounts have a
diversification of holdings that include asset classes other than mutual funds.
• Mutual funds normally offer multiple share classes, including lower-cost share classes
that do not charge 12b-1 fees and therefore less expensive.
•
Investment adviser representatives will invest client funds in 12b-1 fee paying share
classes even when a lower-cost share class is available as appropriate to account for the
overall fee structure of the account.
•
Investment adviser representatives benefit from investing clients in 12b-1 fee paying share
classes because they avoid paying LPL’s transaction charges.
• A Share mutual funds do not always have an otherwise equivalent I Share alternative.
• Not all investors will qualify for I Shares, which can have a higher minimum investment
amount.
• 12b-1 fees are not retained by Clearview Financial Partners, LLC or an investment advisor
representative.
o 12b-1 fees are retained by LPL Financial, an unaffiliated member FINRA/SIPC
broker/dealer.
o LPL Financial does not share 12b-1 fees with individual investment adviser
representatives of Clearview Financial Partners, LLC in their capacity as registered
representatives of LPL Financial.
Depending on the anticipated trading volume, and the asset management fee that that is determined
based on account size, complexity and time requirements, investment advisor representatives have a
fiduciary duty to determine the mutual fund share class that is in the best interest of each client as part
of the overall fee analysis.
Page 14 of 28
Wrap Fee Program
Clearview Financial Partners, LLC. is the sponsor and acts as the portfolio manager of a wrap fee
program – please see Appendix 1 (offered separately) for additional details. In particular, the fee
structure of a wrap fee program warrants additional consideration pertaining to the selection of the
mutual fund share class.
Termination
Clients may terminate the agreement without penalty for a full refund of the 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, 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.
Financial Planning
Financial planning may be incorporated as part of a comprehensive asset management engagement or it
may be provided separately. If financial planning is provided separately, the fee is generally based on
the estimated amount of time required multiplied by a negotiated hourly rate up to $300 depending on
the complexities involved and specific 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. In the event that a client terminates the services they will be entitled to a refund of any
unearned fees by subtracting the earned fees from the amount paid in advance. Financial planning fees
are payable by check to Clearview Financial Partners, LLC. A financial planning engagement is
considered terminated upon delivery of a plan (written or non-written).
Retirement Plan Consulting
The fee for Retirement Plan Consulting will generally not exceed 2% of plan assets under management.
The total estimated fee, as well as the ultimate fee that we charge you, is based on the scope and
complexity of our engagement with you. The fee-paying arrangement for Retirement Plan Consulting
will be outlined in a separate agreement and debited on a quarterly basis from the account in advance
or arrears.
Item 6 – Performance-Based Fees and Side-by-side Management
Clearview Financial Partners does not accept performance-based fees.
• Fees based on a share of capital gains; or,
• Capital appreciation of assets (such as a client that is a hedge fund or other pooled investment
vehicle).
Clearview Financial Partners does not participate in side-by-side management.
• Management of accounts that are both charged a performance-based fee and accounts that are
charged another type of fee, such as an hourly or fixed fee or an asset-based fee.
Page 15 of 28
Item 7 – Types of Clients
Clearview Financial Partners generally provides advice for individuals and high net worth individuals.
However, the advisory services offered by Clearview Financial Partners are also available to small
businesses, banks and thrift institutions, estates, charitable organizations as well as state and municipal
government entities, corporations and pension plans as such opportunities may arise.
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. This may include both equities and fixed income assets. Other options may include domestic
and foreign debt instruments (i.e., government and corporate bonds), real estate investment trusts and
mutual funds or private placements that invest in natural resources or managed futures (markets such
as, and not limited to, currency, commodity, agriculture and energy).
Each market may function and change in different ways depending on supply and demand, current
events and investor behaviors. While our goal is to help increase a client's net worth, there is potential
for losses in market, principal, and interest values. These changes may also affect a client's tax
situation and filings.
Analysis and strategies are generally based on:
• Publicly Available Data
• A Client's Net Worth
• Risk Tolerance
• Goals for Investment Account Funds
• 3rd Party Research
Each client portfolio will be initially designed to meet a particular investment goal, which we
determine to be appropriate for the client’s circumstances. Once the portfolio has been determined, we
regularly review the portfolio and if appropriate, rebalance it based upon 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(s). Past performance is not indicative of future results. The firms’ methods of
analysis and investment strategies do not represent any significant or unusual risks however all
strategies have inherent risks and performance limitations.
Risk of Loss
• Market Risk – the risk that the value of securities may go up or down, sometimes rapidly or
unpredictably, due to factors affecting securities markets generally or particular industries. This is
a risk that will affect all securities in the same manner caused by some factor that cannot be
controlled by diversification
Page 16 of 28
• Interest Rate Risk – the risk that fixed income securities will decline in value because of an
increase in interest rates; a bond or a fixed income fund with a longer duration will be more
sensitive to changes in interest rates than a bond or bond fund with a shorter duration.
• 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 financial obligations.
• Business Risk – the measure of risk associated with a particular security. It is also known as
unsystematic risk and refers to the risk associated with a specific issuer of a security. Generally
speaking, all businesses in the same industry have similar types of business risk. More
specifically, business risk refers to the possibility that the issuer of a particular company stock or a
bond may go bankrupt or be unable to pay the interest or principal in the case of bonds.
Taxability Risk – the risk that a security that was issued with tax-exempt status could potentially
lose that status prior to maturity. Since municipal bonds carry a lower interest rate than fully
taxable bonds, the bond holders would end up with a lower after-tax yield than originally planned.
• Call Risk – the risk specific to bond issues and refers to the possibility that a debt security will be
called prior to maturity. Call risk usually goes hand in hand with reinvestment risk because the
bondholder must find an investment that provides the same level of income for equal risk. Call risk
is most prevalent when interest rates are falling, as companies trying to save money will usually
redeem bond issues with higher coupons and replace them on the bond market with issues with
lower interest rates.
• Inflationary Risk – the risk that future inflation will cause the purchasing power of cash flow
from an investment to decline.
• Liquidity Risk – the possibility that an investor may not be able to buy or sell an investment as
and when desired or in sufficient quantities because opportunities are limited.
• Reinvestment Risk – the risk that falling interest rates will lead to a decline in cash flow from an
investment when its principal and interest payments are reinvested at lower rates.
• Social/Political Risk – the possibility of nationalization, unfavorable government action or social
changes resulting in a loss of value.
• Legislative Risk – the risk of a legislative ruling resulting in adverse consequences.
• Currency/Exchange Rate Risk – the risk of a change in the price of one currency against another.
• 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.
Types of Investments (Examples, not limitations)
• Mutual Funds – a pool of funds collected from many investors for the purpose of investing in
Page 17 of 28
securities such as stocks, bonds, money market instruments and similar assets.
o Open-End Mutual Funds – a type of mutual fund that does not have restrictions on the
amount of shares the fund will issue and will buy back shares when investors wish to sell.
Investing in mutual funds carries the risk of capital loss and thus you may lose money
investing in mutual funds. All mutual funds have costs that lower investment returns. The
funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature
o Closed-End Mutual Funds – a type of mutual fund that raises a fixed amount of capital
through an initial public offering (IPO). The fund is then structured, listed and traded like a
stock on a stock exchange. Clients should be aware that closed-end funds available within
the program are not readily marketable. In an effort to provide investor liquidity, the funds
may offer to repurchase a certain percentage of shares at net asset value on a periodic basis.
Thus, clients may be unable to liquidate all or a portion of their shares in these types of
funds.
• Alternative Strategy Mutual Funds – Certain mutual funds available in the program invest
primarily in alternative investments and/or strategies. Investing in alternative investments and/or
strategies may not be suitable for all investors and involves special risks, such as risks associated
with commodities, real estate, leverage, selling securities short, the use of derivatives, potential
adverse market forces, regulatory changes and potential illiquidity. There are special risks
associated with mutual funds that invest principally in real estate securities, such as sensitivity to
changes in real estate values and interest rates and price volatility because of the fund’s
concentration in the real estate industry.
• 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. 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.
• 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.
• Exchange Traded Funds (ETFs) – an ETF is an investment fund traded on stock exchanges,
similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in
the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in
products and increasing complexity, conflicts of interest and the possibility of inadequate
regulatory compliance. Precious Metal ETFs (e.g., 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
Page 18 of 28
activities by producers of gold or other precious metals, (3) a significant change in the attitude of
speculators and investors.
• 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. Risks of investing in foreign fixed income securities also include the
general risk of non-U.S. investing described below.
• 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
Page 19 of 28
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.
• 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.
• Annuities – are a retirement product 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.
• Variable Annuities – If client purchases a variable annuity that is part of the program, client
will receive a prospectus and should rely solely on the disclosure contained in the prospectus
with respect to the terms and conditions of the variable annuity. Client should also be aware
that certain riders purchased with a variable annuity may limit the investment options and the
ability to manage the subaccounts.
• Non-U.S. Securities – present certain risks such as currency fluctuation, political and economic
change, social unrest, changes in government regulation, differences in accounting and the
lesser degree of accurate public information available.
• 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 goes
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.
• Long-Term Purchases – are securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Page 20 of 28
• Short-Term Purchases – are securities purchased with the expectation that they will be sold
within a relatively short period of time, generally less than one year, to take advantage of the
securities' short-term price fluctuations.
• Inverse / Enhanced Market Strategies – the purchase of mutual funds, ETFs or other exchange
traded notes that are designed perform inversely to certain market indices as an investment
strategy in order to hedge against downside market risk or for the purpose of increasing gains in
an advancing market.
• Cash Positions – based on perceived or anticipated market conditions and/or events, certain
assets may be taken out of the market and held in a defensive cash position. All cash positions
shall be included as assets subject to the agreed upon advisory fee.
Other investment types may be included as appropriate for a particular client and their respective
trading objectives.
Item 9 – Disciplinary Information
Registered investment advisors are required to disclose all material facts regarding any legal or
disciplinary events that would be material to the evaluation of an advisory firm or the integrity of the
firm’s management. Any such disciplinary information for the company and the company’s investment
advisor representatives would be provided herein and publicly accessible by selecting the Investment
Advisor Search option at http://www.adviserinfo.sec.gov. There are no legal or material disciplinary
events to disclose.
Item 10 – Other Financial Industry Activities and Affiliations
Investment adviser representatives of Clearview Financial Partners may receive compensation for the
sale of securities or other investment products in their capacity as a registered representative of LPL.
Investment advisor representatives of Clearview Financial Partners may also be insurance
agents/brokers and offer insurance products and receive customary fees as a result of insurance sales.
Insurance products will only be offered in states where the representative offering insurance is properly
licensed.
An investment advisor representative is not paid both an advisory fee and a commission for the same
product. The conflict of interest created by the different payment structures is mitigated by an
investment advisor representative’s fiduciary duty to act in the best interest of their client and to act
accordingly.
Mr. Fitzgerald is the owner of a separate legal entity, Blue Skies Financial LLC, solely for tax and
investment purposes. The entity does not provide and services or conduct any business. 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, which serves to establish a standard of
business conduct for all employees that are based upon fundamental principles of openness, integrity,
honesty and trust.
Page 21 of 28
• The code of ethics includes guidelines regarding personal securities transactions of its
employees and investment advisor representatives.
o As disclosed in the Conflicts of Interests section, the code of ethics permits employees
and investment advisor representatives or related persons to invest for their own
personal accounts in the same or different securities that an investment advisor
representative may purchase for clients in program accounts.
o Neither Clearview Financial Partners nor a related person recommends to clients, or
buys or sells for client accounts, securities in which they or a related person has a
material financial interest.
• An investment adviser is considered a fiduciary.
o As a fiduciary, it is an investment adviser’s responsibility to provide fair and full
disclosure of all material facts and to act solely in the best interest of each of our clients
at all times.
o Our fiduciary duty is considered the core underlying principle for our Code of Ethics
which also includes Insider Trading and Personal Securities Transactions Policies and
Procedures.
o All of our supervised persons must conduct business with the highest level of ethical
standards and to comply with all federal and state securities laws at all times.
o Upon employment or affiliation and at least annually thereafter, all supervised persons
will sign an acknowledgement that they have read, understand, and agree to comply with
the Code of Ethics.
This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or
a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly
upon request.
Item 12 – Brokerage Practices
Clearview Financial Partners can recommend the use of multiple custodians, such as LPL Financial,
and Charles Schwab & Co., Inc. (Schwab) (collectively, the “Custodians”). Clearview Financial
Partners is independently owned and operated and not affiliated with any of the aforementioned
custodians.
LPL Financial LLC (LPL)
Clearview Financial Partners can receive an economic benefit from LPL Financial such as, financial
assistance or the sponsorship of conferences and educational sessions, marketing support, incentive
awards, payment of travel expenses, and tools to assist investment advisor representative in providing
various services to clients.
Clearview Financial Partners and employees can receive additional compensation from product
Page 22 of 28
sponsors. However, such compensation may not be tied to the sales of any products. Compensation
may include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a
sporting event, or reimbursement in connection with educational meetings with investment advisor
representative, client workshops or events, marketing events or advertising initiatives, including
services for identifying prospective clients. Product sponsors may also pay for or reimburse Clearview
Financial Partners for the costs associated with, education or training events that may be attended by
Clearview Financial Partners employees and investment advisor representatives and for Clearview
Financial Partners sponsored conferences and events. Such additional compensation represents a
conflict of interest however investment advisor representatives of Clearview Financial Partners have a
fiduciary duty to act in the client’s best interest.
Charles Schwab & Co., Inc.
Schwab provides access to its institutional trading and custody services, which are typically not
available to Schwab retail investors. These services generally are available to independent investment
advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the
advisor’s clients’ assets are maintained in accounts at Schwab the firm Services. Schwab’s services
include brokerage services that are related to the execution of securities transactions, custody, research,
including that in the form of advice, analyses and reports, and access to mutual funds and other
investments that are otherwise generally available only to institutional investors or would require a
significantly higher minimum initial investment.
For client accounts maintained in its custody, Schwab generally does not charge separately for custody
services but is compensated by account holders through commissions or other transaction-related or
asset-based fees for securities trades that are executed through Schwab or that settle into Schwab
accounts.
While, as a fiduciary, the firm endeavors to act in its clients’ best interests, recommendations that
clients maintain their assets in accounts at Schwab may be based in part on the benefits received and
the availability of some of the foregoing products and services and other arrangements, not solely on
the nature, cost or quality.
Clients should be aware that for accounts where Schwab serves as the custodian, the firm is limited to
offering services and investment vehicles that are approved by Schwab, and may be prohibited from
offering services and investment vehicles that may be available through other broker/dealers and
custodians, some of which may be more suitable for a client’s portfolio than the services and
investment vehicles offered through Schwab.
Clients should understand that not all investment advisers recommend that clients custody their
accounts and trade through specific broker/dealers.
As discussed previously, certain associated persons of Clearview Financial Partners are registered
representatives of LPL. As a result of this relationship, LPL may have access to certain confidential
information (e.g., financial information, investment objectives, transactions and holdings) about
Clearview Financial Partner’s clients, even if client does not establish any account through LPL. If
Page 23 of 28
you would like a copy of the LPL privacy policy, please contact David Fitzgerald at (610) 293-9211.
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;
software and other technology that provide access to client account data;
•
• pricing information and market data;
•
• 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.
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.
Trade Aggregation
For advisory services, 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 non-
discretionary 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.
Transition Assistance
Page 24 of 28
Clearview Financial Partners has received transitional assistance from their custodians in order to help
facilitate moving assets to be held by the particular custodian. The amount of transitional assistant
increases with the amount of assets moved to the custodian, so Clearview Financial Partners has an
incentive to move assets based on the transitional assistance received. This creates a conflict of
interest, which is mitigated by the fiduciary duty to act in a client’s best interest and acting
accordingly. Clearview Financial Partners also reviews trades for best execution and pricing as well as
the financial strength of the custodian to further mitigate this conflict of interest. Clients are under no
obligation to transfer assets to a particular 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 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 helps
ensure that even idle cash generates some return, albeit typically lower than other investment options.
By automating cash movement, 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 investors and advisors,
allowing them to focus on strategic investment decisions. Sweep programs often offer lower interest
rates than short-term investments like high-yield savings accounts or CDs. This is due to their liquidity
and convenience. 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.
The 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.
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 annually depending on market conditions, the client's
funding needs and changes in investment objectives. Occasionally a review may result in a "no
change" recommendation. If a client has a change in their financial situation Clearview Financial
Partners will perform a review to make sure that the portfolio is appropriate for the client and meets
their cash needs. Clients are provided, at least quarterly, with written transaction confirmation notices
and regular written summary account statements directly from the broker-dealer/custodian and/or
program sponsor for accounts.
Page 25 of 28
• All clients are advised that it remains their responsibility to advise Clearview Financial
Partners of any changes in their investment objectives and/or financial situation.
• All clients (in person or via telephone) are encouraged to review financial planning issues
(to the extent applicable), investment objectives and account performance with their
investment advisor representative on an annual basis.
The surveillance process focuses on accounts that have potential issues in the following areas:
Position Concentration
Asset Allocation
Risk Tolerance
Senior Suitability
Market Performance
Trading Inactivity
High Cash Balance
Item 14 – Client Referrals and Other Compensation
Clearview Financial Partners has agreements in place to receive solicitors’ fees for introducing a client
to a different registered investment advisor in accordance with the requirements of Rule 206(4)-1 of
the Investment Adviser Act of 1940. All fees received and the written separate disclosures made to you
regarding these fees comply with applicable state statutes and rules. The separate written disclosures you
need to be provided include:
• a copy of the Registered Investment Adviser’s Form ADV 2A;
• all relevant Brochures;
• a Solicitation Disclosure Statement detailing the exact fees we are paid; and,
• a copy of the privacy policy.
• a higher fee will not be charged due to introduction.
The other Registered Investment Adviser will establish and maintain their own separate billing
processes over which we have no control. In general, they will directly bill you and describe how this
works in their separate written disclosure documents.
Clearview Financial Partners has arrangements in place to compensate persons, registered with
Clearview Financial Partners as unaffiliated non-employee endorsers for client referrals. Such
compensation is in the form of a portion of the total advisory fee consistent with the requirements of
Rule 206(4)-1 of the Investment Advisers Act of 1940. The total advisory fee charged is not more
because a portion goes towards a referral fee.
Endorsers will be registered as unaffiliated non-employee solicitors at the time they join the firm and
will receive a portion of the advisory fees by agreement with disclosure. Clearview Financial Partners
does not receive any other economic benefit for providing investment advice or other advisory service
from someone who is not a client.
• There are no other economic benefits provided by someone who is not a client for providing
investment advice.
Page 26 of 28
• Clearview Financial Partners will not utilize unaffiliate non-employee solicitors in
Pennsylvania until such time as they are properly registered under the 1972 Act.
Item 15 – Custody
Clearview Financial Partners does not have actual custody of client funds but does have limited
custody as a result of fee deduction. Depending on the custodian used for a particular client, advisory
fees will be deducted in advance by a direct agreement with the custodian (LPL) or by an invoice
provided by Clearview Financial Partners (TD Ameritrade).
• The custodian sends statements at least quarterly to clients showing all disbursements in account
including the amount of the advisory fees paid to advisor, the value of client assets upon which
advisor’s fee was based, and the specific manner in which advisor’s fee was calculated.
• Clients may provide authorization permitting advisory fees to be deducted in advance from client
advisory account or 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 or money market
balances.
• Margin debits do not reduce the value of the assets in the account for billing purposes.
• Accounts where LPL is the custodian, clients must provide authorization to LPL, per their
agreement with LPL, for any increase in fees as a safeguard.
• Accounts where Schwab is the custodian, Clearview Financial Partners will:
o Possess written authorization from the client to deduct advisory fees from an account held
by a qualified custodian;
o Send the qualified custodian written notice of the amount of the fee to be deducted from
the client’s account; and,
o Send the client a written invoice itemizing the fee, including any formulae used to
calculate the fee, the time period covered by the fee and the amount of assets under
management on which the fee was based.
Clients should review the fee calculated and deducted by the custodian to ensure that the fees were
calculated correctly.
Item 16 - Investment Discretion
Clearview Financial Partners provides investment advisory services on a discretionary basis. Prior to
Clearview Financial Partners assuming discretionary authority over a client’s account, the client shall
be required to grant permission by executing an advisory agreement, naming Clearview Financial
Partners as the client’s attorney and agent-in-fact. Such an agreement, grants Clearview Financial
Partners full authority to buy and/or sell the type and amount of securities on behalf of a client, or
Page 27 of 28
otherwise effect investment transactions involving the assets in the client’s name found in the
discretionary account.
Item 17 – Voting Client Securities
Clearview Financial Partners does not vote client proxies. Clients will otherwise receive their proxies
or other solicitations directly from their custodian. Clients may contact Clearview Financial Partners at
(610) 293-9211 to discuss any questions they may have with a particular solicitation. To request
assistance on a proxy voting issue please contact the offering company.
However, third party money managers selected or recommended by our firm may vote proxies for
clients. Therefore, except in the event a third-party money manager votes proxies, clients maintain
exclusive responsibility for:
(1) directing the manner in which proxies solicited by issuers of securities beneficially owned by
the client shall be voted; and,
(2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings
or other type events pertaining to the client’s investment assets.
Therefore (except for proxies that may be voted by a third-party money manager), our firm and/or you
shall instruct your qualified custodian to forward to you copies of all proxies and shareholder
communications relating to your investment assets.
Item 18 – Financial Information
Clearview Financial Partners does not require or solicit prepayment of more than $500 in fees per
client, six months or more in advance. There are no financial conditions that are reasonably likely to
impair the firm’s ability to meet contractual commitments to clients. At no time has Clearview
Financial Partners been the subject of a bankruptcy petition.
Page 28 of 28