Overview
Assets Under Management: $1.1 billion
Headquarters: RADNOR, PA
High-Net-Worth Clients: 297
Average Client Assets: $2 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Fee Structure
Primary Fee Schedule (WRAP FEE PROGRAM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $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% |
| $5,000,001 | and above | Negotiable |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $16,000 | 1.60% |
| $5 million | $62,000 | 1.24% |
| $10 million | Negotiable | Negotiable |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
Number of High-Net-Worth Clients: 297
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 80.66
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 1,030
Discretionary Accounts: 1,030
Regulatory Filings
CRD Number: 286168
Last Filing Date: 2024-12-09 00:00:00
Website: https://cvfpartners.com
Form ADV Documents
Additional Brochure: ADV 2A - FIRM DISCLOSURE BROCHURE (2025-03-15)
View Document Text
Item 1 – Cover Page
Registered as Clearview Financial Partners, LLC | CRD No. 286168
Doing Business As: Clearview Financial Partners
Wrap Fee Program Brochure
100 Matsonford Road – Building #5, Suite 110 | Radnor, PA 19087
Phone: (610) 293-9211
March 15, 2025
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.
If a copy of this disclosure brochure is not provided at least 48 hours prior to signing a contract, clients
have five (5) business days to cancel the contract without a penalty.
Page 1 of 27
Item 2 – Material Changes
There are no material changes to disclose since the previous annual amendment filed on March 28, 2024.
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 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 27
Item 3 – Table of Contents
Item 1 – Cover Page ........................................................................................................................ 1
Item 2 - Material Changes ……………………………………………………………………….. 2
Item 3 – Table of Contents .............................................................................................................. 3
Item 4 – Services, Fees and Compensation ..................................................................................... 4
Item 5 – Account Requirements and Types of Clients .................................................................. 13
Item 6 – Portfolio Manager Selection and Evaluation .................................................................. 14
Item 7 – Client Information Provided to Portfolio Managers ....................................................... 21
Item 8 - Client Contact with Portfolio Managers ………………………………………………. 21
Item 9 – Additional Information ................................................................................................... 21
Page 3 of 27
ITEM 4 – Services, Fees and Compensation
Services
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 the below qualified custodians for the safekeeping of client
assets.
▪ LPL Financial LLC (LPL)
▪ Charles Schwab & Co., Inc (Schwab)
Firm Management
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.
Fees
In the Clearview Financial Partners Wrap program, clients pay Clearview Financial Partners a
single annual advisory fee for advisory services and execution of transactions. Clients do not pay
brokerage commissions, markups or transaction charges for execution of transactions in addition to
the advisory fee. The advisory fee is negotiable between the client and Clearview Financial Partners
and is set out in the advisory agreement.
The advisory fee is a percentage based on the value of all assets in the account, including cash
holdings. The maximum advisory fee is generally 1.6% subject to the below fee schedule.
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
1.60%
1.35%
1.00%
0.90%
Negotiable
• The advisory fee is paid to Clearview Financial Partners and is shared between
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Clearview Financial Partners and its associated persons.
• The advisory fee may be higher than the fee charged by other investment advisors for
similar services.
• Participation in the program may cost more or less than purchasing such services
separately.
• Clearview Financial Partners does not accept performance-based fees for program
accounts.
The advisory fees will be calculated and deducted on a quarterly basis in advance or in arrears based
on a written authorization from the client. 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.
Although clients do not pay a transaction charge for transactions in a program account, clients
should be aware that Clearview Financial Partners pays the custodian transaction charges for the
transactions. The transaction charges paid by Clearview Financial Partners vary based on the type
of transaction (e.g., mutual fund, equity or fixed income security) and range from $0 to $50.
Because Clearview Financial Partners pays the transaction charges in program accounts, there is a
conflict of interest. Clients should understand that the cost to Clearview Financial Partners of
transaction charges may be a factor that Clearview Financial Partners considers when deciding
which securities to select and how frequently to place transactions in a program account. This
conflict is mitigated by the investment advisor representative’s fiduciary duty to act in the client’s
best interest an acting accordingly.
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.
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•
Trade Ticket Charges
o Equities and ETFs are $0 to $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.
Ticket charges for A shares held in a wrap fee program require special consideration because the
ticket charges are included as part of the wrap fee program and paid by the adviser. Consequently,
A share do not offer the same level of benefit to a client that they do in a non-wrap fee account.
However, a different conflict of interet is introduced because the advisor now has an incentive to not
trade as frequently to aviod the ticket charges which can compromise the activie management of an
advisory account. This conflict is mitigated by an investment adviser representative’s fiduciary
duty to act in a clients best interest while also considering the higher asset management fee charged
for wrap fee accounts.
• Mutual funds normally offer multiple share classes, including lower-cost share
classes that do not charge 12b-1 fees and herefore 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.
• IARs 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.
• 12b-1 fees are retained by LPL Financial, an unaffiliated member FINRA/SIPC
broker/dealer.
• 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 Finacial.
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
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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.
Other Types of Fees and Charges
Program accounts will incur additional fees and charges from parties other than Clearview Financial
Partners as noted below. These fees and charges are in addition to the advisory fee paid to
Clearview Financial Partners. Clearview Financial Partners does not share in any portion of these
third-party fees.
The custodian and executing broker-dealer will impose certain fees and charges. Clients are
notified of these charges at account opening. The custodian will deduct these fees and charges
directly from the client’s program account.
There are other fees and charges that are imposed by other third parties that apply to investments in
program accounts. Some of these fees and charges are described below.
•
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 an advisory fee to the fund manager and other expenses as a shareholder of
the fund. Client will also pay Clearview Financial Partners the advisory fee with respect to
those assets. 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 Clearview Financial Partners and by making their own investment
decisions.
• Certain mutual funds impose fees and charges such as contingent deferred sales charges,
early redemption fees and charges for frequent trading. These charges may apply if client
transfers into or purchases such a fund with the applicable charges in a program account.
•
If client holds a variable annuity as part of an account, there are mortality, expense and
administrative charges, fees for additional riders on the contract and charges for excessive
transfers within a calendar year imposed by the variable annuity sponsor.
Further information regarding fees assessed by a mutual fund, or variable annuity is available in the
appropriate prospectus, which is available upon request from Clearview Financial Partners or from
the product sponsor directly.
Other Important Considerations
• The advisory fee is an ongoing wrap fee for investment advisory services, the execution of
transactions and other administrative and custodial services. The advisory fee may cost the
client more than purchasing the program services separately, for example, paying an
advisory fee plus commissions for each transaction in the account. Factors that bear upon
the cost of the account in relation to the cost of the same services purchased separately
include the type and size of the account, historical and or expected size or number of trades
for the account, and number and range of supplementary advisory and client-related services
provided to the client.
• The advisory fee also may cost the client more than if assets were held in a traditional
brokerage account. In a brokerage account, a client is charged a commission for each
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transaction, and the representative has no duty to provide ongoing advice with respect to the
account. If the client plans to follow a buy and hold strategy for the account or does not wish
to purchase ongoing investment advice or management services, the client should consider
opening a brokerage account rather than a program account.
• Clearview Financial Partners by recommending the program to the client receives
compensation as a result of the client’s participation in the program. This compensation
includes the advisory fee and also may include other compensation, such financial assistance
or the sponsorship of conferences and educational sessions, marketing support, incentive
awards, payment of travel expenses, and tools to assist with providing various services to
clients. The amount of this compensation may be more or less than what Clearview
Financial Partners would receive if the client participated in other LPL programs, programs
of other investment advisors or paid separately for investment advice, brokerage and other
client services. Therefore, Clearview Financial Partners may have a financial incentive to
recommend a program account over other programs and services.
• The investment products available to be purchased in the program can be purchased by
clients outside of a program account, through broker-dealers or other investment firms not
affiliated with Clearview Financial Partners.
•
Investment advisor representatives may also be licensed insurance agents. In the capacity of
an insurance agent, they may recommend the purchase of certain insurance-related products
on a commission basis in addition to advisory fees.
• The purchase of securities and/or insurance commission product presents a conflict of
interest, as the receipt of commissions provides an incentive to recommend investment
products based on commissions received, rather than on a particular client’s need. No client
is under any obligation to purchase any commission products from Investment advisor
representatives of the firm. Clients may purchase investment products recommended by
investment advisor representatives through other, non-affiliated broker/dealers or insurance
agents. Such conflicts are subject to review by the Chief Compliance Officer for consistency
with the firm’s Code of Ethics.
• Clearview Financial Partners may establish agreements with a third-party adviser where that
third-party adviser offers various types of directly sponsored programs. Clearview Financial
Partners will ensure that any third-party adviser is properly registered and/or notice-filed
with the Department.
• Clearview Financial Partners has a conflict of interest and an incentive to recommend one
third-party advisers over another; however, the firm has a fiduciary duty to act in the best
interests of the client.
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:
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• 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.
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
managed by Clearview Financial Partners based on a particular client’s financial circumstances.
Clearview Financial Partners 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.
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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
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.
Third Party Investment Advisers
Clearview Financial Partners has entered into agreements with various third-party advisers. Under
these agreements, the Adviser offers clients various types of programs sponsored by these advisers.
All third-party investment advisers to whom the Adviser will refer clients will be licensed as
investment advisers by their resident state and any applicable jurisdictions or registered investment
advisers with the SEC.
After gathering information about a client's financial situation and investment objectives, the Adviser
will assist the client in selecting a particular third-party program. The Adviser receives compensation
pursuant to its agreements with these third-party advisers for introducing clients to these third-party
advisers and for certain ongoing services provided to clients. In such situations, the third-party
investment adviser shall have the day-to-day responsibility for the active management of the
allocated program assets.
This compensation is disclosed to the client in a separate disclosure document and is typically equal
to a percentage of the investment advisory fee charged by that third-party adviser or a fixed fee. The
disclosure document provided by the Adviser will clearly state the fees payable to the Adviser and
the impact to the overall fees due to these payments.
Since the compensation an adviser receives may differ depending on the agreement with each third-
party adviser, the adviser may have an incentive to recommend one third-party advisers over another,
if the compensation arrangements are more favorable. Since the independent third-party adviser may
pay the fee for the investment advisory services of the Adviser, the fee paid to the Adviser is not
negotiable, under most circumstances. Such a conflict is mitigated by Clearview Financial Partner’s
fiduciary duty to act in the best interest of their clients and acting accordingly.
Page 10 of 27
Clients who are referred to third-party investment advisers will receive full disclosure, including
services rendered and fee schedules, at the time of the referral, by delivery of a copy of the relevant
third-party adviser's Form ADV 2A at the same time as the Form ADV 2A of the Adviser.
In addition, if the investment program recommended to a client is a wrap fee program the client will
also receive the wrap fee brochure provided by the sponsor of the program. The Adviser will provide
to each client all appropriate disclosure statements, including disclosure of solicitation fees to the
Adviser and its advisory associates.
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 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.
•
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.
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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.
Third-Party Advisory Services
Clearview Financial Partners is paid by third party money managers when we refer you to them
and you decide to open a managed account. Third party money managers pay us a portion of the
investment advisory fee that they charge you for managing your account. Fees paid to us by third
party money manager are generally ongoing. All fees we receive from third party money managers
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 third-party money manager’s Form ADV 2A;
all relevant Brochures;
a Solicitation Disclosure Statement detailing the exact fees we are paid; and,
a copy of the third-party money manager’s privacy policy.
The fees for such managers and their services are different to the fees described above. However,
the total advisory fee for an account utilizing these managers shall not exceed a 2.99% annual fee.
The third-party money managers we recommend will not charge you a higher fee than they would
have charged without our introduction.
Third party money managers 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.
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. Our AI tool
transcribes spoken content, generates summaries, and identifies key takeaways. Participants are
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informed of AI usage and have the right to opt out of AI-generated note-taking. Should a client
have any questions or concerns, please contact us at our email address, phone number, or
website. In addition to real-time note-taking, [Advisor] uses AI to gather general insights and
manage projects. By analyzing large volumes of data and identifying patterns, AI helps us
develop preliminary concepts, streamline research processes, and enhance decision-making. This
allows [Advisor] to focus on more complex and creative aspects of our work, ultimately delivering
more comprehensive and effective solutions for our clients. We ensure that any use of AI is
supervised and conducted with transparency, maintaining the highest standards of data privacy and
ethical practices.
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 – Account Requirements and Types of Clients
Clearview Financial Partners generally provides advice for individuals and high net worth
individuals as well as small businesses. However, the advisory services offered by Clearview
Financial Partners are also available to banks and thrift institutions, estates, charitable organizations
as well as state and municipal government entities, corporations and pension plans as such
opportunities may arise. 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
$850,402,568
Non-Discretionary
$0.00
Item 6 – Portfolio Manager Selection and Evaluation
In the Clearview Financial Partners Wrap program, Clearview Financial Partners is responsible for
the investment advice and management offered to clients.
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Investment advisor representatives of Clearview Financial Partners serve as the portfolio manager
and are generally required to have several years of experience dealing with individuals and small
business as well as a college degree and/or industry professional designation. Since investment
advisor representatives directly serve as the portfolio manager there is not a selection process for
replacing or recommending outside portfolio managers.
Account performance reports are provided by Clearview Financial Partners or the custodian on a
quarterly basis.
There is no differences between how the wrap fee program is managed and how other accounts are
managed. However, Clearview Financial Partners may charge a higher fee, up to 1.6%, and receive
a portion of the wrap fee for services provided. The combined total fee will not exceed 1.6%. The
program may cost more or less than purchasing such services separately.
The other programs provided by the adviser include:
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. 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.
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 (non-discretionary accounts require client approval prior to a transaction being
executed). 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.
An investment advisor representative recommending the wrap fee program receives compensation
as a result of a client’s participation in the program. The amount of this compensation may be more
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than what the person would receive if the client participated in other programs or paid separately for
investment advice, brokerage, and other services. Therefore, investment advisor representatives
may have a financial incentive to recommend the wrap fee program over other programs or
services.
There may be additional fees on assets help in the wrap program, such as mutual fund expenses and
mark-ups, mark-downs, or spreads paid to market makers. A more detailed description of these fees
and circumstances is detailed above in Item 4 above.
Neither the firm or any supervised persons accepts performance-based fees, fees based on a share of
capital gains on or capital appreciation of the assets of a client such as a hedge fund or other pooled
investment vehicle. Neither the firm or any supervised persons manages side-by- side accounts that
are charged a performance-based fee and accounts that are charged another type of fee, such as an
hourly or flat fee or an asset-based fee.
Investment advisor representatives are restricted to providing services and charging fees based in
accordance with the descriptions detailed in this document and 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 representatives are instructed to consider the individual
needs of each client when recommending an advisory platform. Investment strategies and
recommendations are tailored to the individual needs of each client.
For more information about the investment advisor representative managing the account, client
should refer to the Brochure Supplement for the associated person, which client should have
received along with this Brochure at the time client opened the account.
The Custodian(s) perform certain administrative services for Clearview Financial Partners,
including generation of quarterly performance reports for program accounts. Client will receive an
individual quarterly performance report, which provides performance information on a time
weighted basis. The performance reports are intended to inform clients as to how their investments
have performed for a period, both on an absolute basis and compared to leading investment indices.
Methods of Analysis and Investment Strategies
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
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•
•
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
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.
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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
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 of time. It is
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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
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
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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.
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 go up,
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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.
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.
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:
directing the manner in which proxies solicited by issuers of securities beneficially owned by the client
shall be voted; and,
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 7 – Client Information Provided to Portfolio Managers
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In the Clearview Financial Partners Wrap program, Clearview Financial Partners is responsible for
account management; there is no separate portfolio manager involved. Clearview Financial Partners
obtains the necessary financial data from the client and assists the client in setting an appropriate
investment objective for the account. Clearview Financial Partners obtains this information by
having the client complete an advisory agreement and other documentation. Clients are encouraged
to contact Clearview Financial Partners if there have been any changes in the client’s financial
situation or investment objectives or if they wish to impose any reasonable restrictions on the
management of the account or reasonably modify existing restrictions. Client should be aware that
the investment objective selected for the program is an overall objective for the entire account and
may be inconsistent with a particular holding and the account’s performance at any time. Client
should further be aware that achievement of the stated investment objective is a long-term goal for
the account.
The Firm policy requires an annual client meeting (one review every 12 months) to determine if
there have been any changes in the client's financial situation, investment objectives, or restrictions.
In addition, the meeting should incorporate the account performance, appropriateness of the
account, and any other information determined pertinent to the client situation. The annual meeting
may occur by phone, in person, via e-mail, or via video conference and documentation will be
maintained to evidence that at a minimum the following topics were reviewed:
Investment Objective and Goals
• The client’s financial status
• Risk Tolerance
• Time Horizon
•
• Asset Allocation and/or Account Holdings
Additionally, on an annual basis, IARs should review the performance of the client's advisory
account and investment objectives.
Item 8 – Client Contact with Portfolio Managers
Client should contact Clearview Financial Partners at any time with questions regarding program
account.
Item 9 – Additional Information
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of an advisory firm or the integrity of a
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 disciplinary events
to disclose.
Other Financial Industry Activities and Affiliations
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Investment advisor representatives may also be registered representatives of LPL Financial, an
unaffiliated SEC registered and FINRA/SIPC member broker/dealer. Clients may choose to engage
an investment advisor representative in their capacity as a registered representative of the
unaffiliated LPL Financial broker/dealer, to implement investment recommendations on a
commission basis. Investment advisor 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 Financial.
Representatives of our firm may also be insurance agents/brokers. They may 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.
A conflict of interest may arise as these insurance sales may create an incentive to recommend
products based on the compensation Clearview Financial Partners and/or our supervised persons
may earn and may not necessarily be in the best interests of the client. Such potential conflicts of
interest are subject to review by the Chief Compliance Officer.
• Neither Clearview Financial Partners 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.
• Clearview Financial Partners will ensure third party investment advisers are properly
registered, licensed, and/or notice-filed with the appropriate state(s).
• Clearview Financial Partners may or may not have discretion over client funds as
indicated in the advisory agreement.
• 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 Clearview Financial Partners been
the subject of a bankruptcy petition.
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. The code of ethics includes guidelines regarding personal securities
transactions of its employees and investment advisor representatives. 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. This presents a potential conflict of interest because trading by an
employee or investment advisor representatives in a personal securities account in the same or
different security on or about the same time as trading by a client could potentially disadvantage the
client. Clearview Financial Partners addresses this conflict of interest by requiring in its code of
ethics that employees and investment advisor representatives report certain personal securities
transactions and holdings to the Chief Compliance Officer for review.
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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. 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. Clearview Financial Partners has a fiduciary duty to all
clients. 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. We
require all of our supervised persons to conduct business with the highest level of ethical standards
and to comply with all federal and state securities laws at all times. 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 our Code of Ethics. Our firm and supervised persons
must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might
negatively affect or appear to affect our duty of complete loyalty to all clients. 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.
Review of Accounts
Investment advisor representatives conduct reviews of client advisory accounts on a periodic basis
(at least annually) for consistency with the client's stated investment objectives, among other
factors. All investment advisory clients are advised that it remains their responsibility to advise
Clearview Financial Partners of any changes in their investment objectives and/or financial
situation. IARs, may also conduct account reviews based on the occurrence of a triggering event,
such as a change in client investment objectives and/or financial situation, market corrections and
by client request.
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
All clients (in person or via telephone) are encouraged to review financial planning issues (t the
extent applicable), investment objectives and account performance with their IAR on an annual
basis.
During any month that there is activity in the program account, client will receive a monthly
account statement from LPL showing account activity as well as positions held in the account at
month end. Additionally, client will receive a confirmation of each transaction that occurs within
the program account unless the transaction is the result of a systematic purchase, redemption or
exchange. Client will also receive a detailed quarterly report showing performance, positions and
activity from LPL Financial.
For advisory accounts held at custodians and third-party advisors other than LPL, accounts will be
reviewed based on similar criteria.
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Other Compensation
Clearview Financial Partners and its associated persons may receive additional non-cash
compensation from product 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 or marketing or advertising initiatives. Product sponsors may also pay for education or
training events that may be attended by Clearview Financial Partners’ employees and associated
persons.
There are no other economic benefits provided by someone who is not a client for providing
investment advice. However, financial assistance or the sponsorship of conferences and educational
sessions, marketing support, incentive awards, payment of travel expenses, and tools to assist IAR
in providing various services to clients may be provided by LPL Financial.
Financial Information Custody
The qualified custodians collectively maintain custody of client funds and securities in a separate
account for each client under the client’s name. Clearview Financial Partners is deemed to have
limited custody as a result of fee deduction.
o LPL Financial LLC (LPL)
o Charles Schwab & Co., Inc. (Schwab)
The Custodians send out account statements showing all transactions, positions, and all deposits and
withdrawals of principal and income. The custodian sends account statements monthly when the
account has had activity or quarterly if there has been no activity. Clients should carefully review
those account statements. Clearview Financial Partners may also provide advisory services on
assets held at different third-party custodians. The fee structure disclosed above will apply
regardless of the custodian where assets are held.
• 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.
Although most securities available in the program accounts are custodied with a third party
qualified custodian, there are certain securities managed as part of the account that are held at with
an investment sponsor. For example, variable annuities, hedge funds and managed futures are often
held directly with the investment sponsor. For those outside positions, client will receive
confirmations and statements directly from the investment sponsor.
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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.
Brokerage Practices
In the Clearview Financial Partners Wrap program, Clearview Financial Partners requires that
clients with assets custodied at LPL Financial, direct LPL Financial as the sole and exclusive
broker-dealer to execute transactions in the account. LPL Financial is not paid a commission for
executing transactions. Because associated persons of the Clearview Financial Partners are licensed
with LPL Financial, this presents a conflict of interest. Clients should understand that not all
advisors require their clients to direct brokerage. By directing brokerage to LPL Financial, clients
may be unable to achieve the most favorable execution of client transactions. Therefore, directed
brokerage may cost clients more money.
Clearview Financial Partners may receive support services and/or products from LPL Financial,
which assist Clearview Financial Partners to better monitor and service program accounts
maintained at LPL Financial. These support services and/or products may be received without cost,
at a discount, and/or at another 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
• 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
• other products used by Clearview Financial Partners in furtherance of its investment
advisory business operations
Clients do not pay more for services as a result of this arrangement. There is no corresponding
commitment made by Clearview Financial Partners to LPL Financial or any other entity to invest
any specific amount or percentage of client assets in any specific securities as a result of the
arrangement.
Clearview Financial Partners also custodies assets with Schwab. Schwab is an independent and
unaffiliated SEC-registered broker/dealer. Schwab offers to independent investment Advisors
services which include custody of securities, trade execution, clearance and settlement of
transactions. Advisor receives some benefits from Schwab through its participation in the
program.
Clearview Financial Partners, through its participation in the program, may receive discounts on
compliance, marketing, technology, and practice management products or services provided to the
Firm by third party vendors. Such services represent a potential conflict of interest disclosure. The
Firm’s receipt of general platform services does not diminish the Firm’s duty to act in the best
interests of its clients, including seeking best execution of trades for client accounts. As part of its
fiduciary duties to clients, advisor is obligated at all times to put the interests of their clients first.
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Clients should be aware, however, that the receipt of economic benefits by adviser or its related
persons in and of itself creates a potential conflict of interest and may indirectly influence the
adviser’s choice of Schwab for custody and brokerage services.
Trade Aggregation
Clearview Financial Partners 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 may determine not to aggregate transactions,
for example, based on the size of the trades, the number of client accounts, the timing of the trades,
the liquidity of the securities and the discretionary or non-discretionary nature of the trades. If
Clearview Financial Partners does 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.
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.
Transition Assistance
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
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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.
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Primary Brochure: WRAP FEE PROGRAM BROCHURE (2025-03-15)
View Document Text
Item 1 – Cover Page
Registered as Clearview Financial Partners, LLC | CRD No. 286168
Doing Business As: Clearview Financial Partners
Wrap Fee Program Brochure
100 Matsonford Road – Building #5, Suite 110 | Radnor, PA 19087
Phone: (610) 293-9211
March 15, 2025
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.
If a copy of this disclosure brochure is not provided at least 48 hours prior to signing a contract, clients
have five (5) business days to cancel the contract without a penalty.
Page 1 of 27
Item 2 – Material Changes
There are no material changes to disclose since the previous annual amendment filed on March 28, 2024.
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 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 27
Item 3 – Table of Contents
Item 1 – Cover Page ........................................................................................................................ 1
Item 2 - Material Changes ……………………………………………………………………….. 2
Item 3 – Table of Contents .............................................................................................................. 3
Item 4 – Services, Fees and Compensation ..................................................................................... 4
Item 5 – Account Requirements and Types of Clients .................................................................. 13
Item 6 – Portfolio Manager Selection and Evaluation .................................................................. 14
Item 7 – Client Information Provided to Portfolio Managers ....................................................... 21
Item 8 - Client Contact with Portfolio Managers ………………………………………………. 21
Item 9 – Additional Information ................................................................................................... 21
Page 3 of 27
ITEM 4 – Services, Fees and Compensation
Services
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 the below qualified custodians for the safekeeping of client
assets.
▪ LPL Financial LLC (LPL)
▪ Charles Schwab & Co., Inc (Schwab)
Firm Management
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.
Fees
In the Clearview Financial Partners Wrap program, clients pay Clearview Financial Partners a
single annual advisory fee for advisory services and execution of transactions. Clients do not pay
brokerage commissions, markups or transaction charges for execution of transactions in addition to
the advisory fee. The advisory fee is negotiable between the client and Clearview Financial Partners
and is set out in the advisory agreement.
The advisory fee is a percentage based on the value of all assets in the account, including cash
holdings. The maximum advisory fee is generally 1.6% subject to the below fee schedule.
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
1.60%
1.35%
1.00%
0.90%
Negotiable
• The advisory fee is paid to Clearview Financial Partners and is shared between
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Clearview Financial Partners and its associated persons.
• The advisory fee may be higher than the fee charged by other investment advisors for
similar services.
• Participation in the program may cost more or less than purchasing such services
separately.
• Clearview Financial Partners does not accept performance-based fees for program
accounts.
The advisory fees will be calculated and deducted on a quarterly basis in advance or in arrears based
on a written authorization from the client. 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.
Although clients do not pay a transaction charge for transactions in a program account, clients
should be aware that Clearview Financial Partners pays the custodian transaction charges for the
transactions. The transaction charges paid by Clearview Financial Partners vary based on the type
of transaction (e.g., mutual fund, equity or fixed income security) and range from $0 to $50.
Because Clearview Financial Partners pays the transaction charges in program accounts, there is a
conflict of interest. Clients should understand that the cost to Clearview Financial Partners of
transaction charges may be a factor that Clearview Financial Partners considers when deciding
which securities to select and how frequently to place transactions in a program account. This
conflict is mitigated by the investment advisor representative’s fiduciary duty to act in the client’s
best interest an acting accordingly.
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.
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•
Trade Ticket Charges
o Equities and ETFs are $0 to $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.
Ticket charges for A shares held in a wrap fee program require special consideration because the
ticket charges are included as part of the wrap fee program and paid by the adviser. Consequently,
A share do not offer the same level of benefit to a client that they do in a non-wrap fee account.
However, a different conflict of interet is introduced because the advisor now has an incentive to not
trade as frequently to aviod the ticket charges which can compromise the activie management of an
advisory account. This conflict is mitigated by an investment adviser representative’s fiduciary
duty to act in a clients best interest while also considering the higher asset management fee charged
for wrap fee accounts.
• Mutual funds normally offer multiple share classes, including lower-cost share
classes that do not charge 12b-1 fees and herefore 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.
• IARs 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.
• 12b-1 fees are retained by LPL Financial, an unaffiliated member FINRA/SIPC
broker/dealer.
• 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 Finacial.
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
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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.
Other Types of Fees and Charges
Program accounts will incur additional fees and charges from parties other than Clearview Financial
Partners as noted below. These fees and charges are in addition to the advisory fee paid to
Clearview Financial Partners. Clearview Financial Partners does not share in any portion of these
third-party fees.
The custodian and executing broker-dealer will impose certain fees and charges. Clients are
notified of these charges at account opening. The custodian will deduct these fees and charges
directly from the client’s program account.
There are other fees and charges that are imposed by other third parties that apply to investments in
program accounts. Some of these fees and charges are described below.
•
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 an advisory fee to the fund manager and other expenses as a shareholder of
the fund. Client will also pay Clearview Financial Partners the advisory fee with respect to
those assets. 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 Clearview Financial Partners and by making their own investment
decisions.
• Certain mutual funds impose fees and charges such as contingent deferred sales charges,
early redemption fees and charges for frequent trading. These charges may apply if client
transfers into or purchases such a fund with the applicable charges in a program account.
•
If client holds a variable annuity as part of an account, there are mortality, expense and
administrative charges, fees for additional riders on the contract and charges for excessive
transfers within a calendar year imposed by the variable annuity sponsor.
Further information regarding fees assessed by a mutual fund, or variable annuity is available in the
appropriate prospectus, which is available upon request from Clearview Financial Partners or from
the product sponsor directly.
Other Important Considerations
• The advisory fee is an ongoing wrap fee for investment advisory services, the execution of
transactions and other administrative and custodial services. The advisory fee may cost the
client more than purchasing the program services separately, for example, paying an
advisory fee plus commissions for each transaction in the account. Factors that bear upon
the cost of the account in relation to the cost of the same services purchased separately
include the type and size of the account, historical and or expected size or number of trades
for the account, and number and range of supplementary advisory and client-related services
provided to the client.
• The advisory fee also may cost the client more than if assets were held in a traditional
brokerage account. In a brokerage account, a client is charged a commission for each
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transaction, and the representative has no duty to provide ongoing advice with respect to the
account. If the client plans to follow a buy and hold strategy for the account or does not wish
to purchase ongoing investment advice or management services, the client should consider
opening a brokerage account rather than a program account.
• Clearview Financial Partners by recommending the program to the client receives
compensation as a result of the client’s participation in the program. This compensation
includes the advisory fee and also may include other compensation, such financial assistance
or the sponsorship of conferences and educational sessions, marketing support, incentive
awards, payment of travel expenses, and tools to assist with providing various services to
clients. The amount of this compensation may be more or less than what Clearview
Financial Partners would receive if the client participated in other LPL programs, programs
of other investment advisors or paid separately for investment advice, brokerage and other
client services. Therefore, Clearview Financial Partners may have a financial incentive to
recommend a program account over other programs and services.
• The investment products available to be purchased in the program can be purchased by
clients outside of a program account, through broker-dealers or other investment firms not
affiliated with Clearview Financial Partners.
•
Investment advisor representatives may also be licensed insurance agents. In the capacity of
an insurance agent, they may recommend the purchase of certain insurance-related products
on a commission basis in addition to advisory fees.
• The purchase of securities and/or insurance commission product presents a conflict of
interest, as the receipt of commissions provides an incentive to recommend investment
products based on commissions received, rather than on a particular client’s need. No client
is under any obligation to purchase any commission products from Investment advisor
representatives of the firm. Clients may purchase investment products recommended by
investment advisor representatives through other, non-affiliated broker/dealers or insurance
agents. Such conflicts are subject to review by the Chief Compliance Officer for consistency
with the firm’s Code of Ethics.
• Clearview Financial Partners may establish agreements with a third-party adviser where that
third-party adviser offers various types of directly sponsored programs. Clearview Financial
Partners will ensure that any third-party adviser is properly registered and/or notice-filed
with the Department.
• Clearview Financial Partners has a conflict of interest and an incentive to recommend one
third-party advisers over another; however, the firm has a fiduciary duty to act in the best
interests of the client.
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:
Page 8 of 27
• 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.
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
managed by Clearview Financial Partners based on a particular client’s financial circumstances.
Clearview Financial Partners 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.
Page 9 of 27
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
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.
Third Party Investment Advisers
Clearview Financial Partners has entered into agreements with various third-party advisers. Under
these agreements, the Adviser offers clients various types of programs sponsored by these advisers.
All third-party investment advisers to whom the Adviser will refer clients will be licensed as
investment advisers by their resident state and any applicable jurisdictions or registered investment
advisers with the SEC.
After gathering information about a client's financial situation and investment objectives, the Adviser
will assist the client in selecting a particular third-party program. The Adviser receives compensation
pursuant to its agreements with these third-party advisers for introducing clients to these third-party
advisers and for certain ongoing services provided to clients. In such situations, the third-party
investment adviser shall have the day-to-day responsibility for the active management of the
allocated program assets.
This compensation is disclosed to the client in a separate disclosure document and is typically equal
to a percentage of the investment advisory fee charged by that third-party adviser or a fixed fee. The
disclosure document provided by the Adviser will clearly state the fees payable to the Adviser and
the impact to the overall fees due to these payments.
Since the compensation an adviser receives may differ depending on the agreement with each third-
party adviser, the adviser may have an incentive to recommend one third-party advisers over another,
if the compensation arrangements are more favorable. Since the independent third-party adviser may
pay the fee for the investment advisory services of the Adviser, the fee paid to the Adviser is not
negotiable, under most circumstances. Such a conflict is mitigated by Clearview Financial Partner’s
fiduciary duty to act in the best interest of their clients and acting accordingly.
Page 10 of 27
Clients who are referred to third-party investment advisers will receive full disclosure, including
services rendered and fee schedules, at the time of the referral, by delivery of a copy of the relevant
third-party adviser's Form ADV 2A at the same time as the Form ADV 2A of the Adviser.
In addition, if the investment program recommended to a client is a wrap fee program the client will
also receive the wrap fee brochure provided by the sponsor of the program. The Adviser will provide
to each client all appropriate disclosure statements, including disclosure of solicitation fees to the
Adviser and its advisory associates.
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 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.
•
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.
Page 11 of 27
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.
Third-Party Advisory Services
Clearview Financial Partners is paid by third party money managers when we refer you to them
and you decide to open a managed account. Third party money managers pay us a portion of the
investment advisory fee that they charge you for managing your account. Fees paid to us by third
party money manager are generally ongoing. All fees we receive from third party money managers
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 third-party money manager’s Form ADV 2A;
all relevant Brochures;
a Solicitation Disclosure Statement detailing the exact fees we are paid; and,
a copy of the third-party money manager’s privacy policy.
The fees for such managers and their services are different to the fees described above. However,
the total advisory fee for an account utilizing these managers shall not exceed a 2.99% annual fee.
The third-party money managers we recommend will not charge you a higher fee than they would
have charged without our introduction.
Third party money managers 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.
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. Our AI tool
transcribes spoken content, generates summaries, and identifies key takeaways. Participants are
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informed of AI usage and have the right to opt out of AI-generated note-taking. Should a client
have any questions or concerns, please contact us at our email address, phone number, or
website. In addition to real-time note-taking, [Advisor] uses AI to gather general insights and
manage projects. By analyzing large volumes of data and identifying patterns, AI helps us
develop preliminary concepts, streamline research processes, and enhance decision-making. This
allows [Advisor] to focus on more complex and creative aspects of our work, ultimately delivering
more comprehensive and effective solutions for our clients. We ensure that any use of AI is
supervised and conducted with transparency, maintaining the highest standards of data privacy and
ethical practices.
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 – Account Requirements and Types of Clients
Clearview Financial Partners generally provides advice for individuals and high net worth
individuals as well as small businesses. However, the advisory services offered by Clearview
Financial Partners are also available to banks and thrift institutions, estates, charitable organizations
as well as state and municipal government entities, corporations and pension plans as such
opportunities may arise. 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
$850,402,568
Non-Discretionary
$0.00
Item 6 – Portfolio Manager Selection and Evaluation
In the Clearview Financial Partners Wrap program, Clearview Financial Partners is responsible for
the investment advice and management offered to clients.
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Investment advisor representatives of Clearview Financial Partners serve as the portfolio manager
and are generally required to have several years of experience dealing with individuals and small
business as well as a college degree and/or industry professional designation. Since investment
advisor representatives directly serve as the portfolio manager there is not a selection process for
replacing or recommending outside portfolio managers.
Account performance reports are provided by Clearview Financial Partners or the custodian on a
quarterly basis.
There is no differences between how the wrap fee program is managed and how other accounts are
managed. However, Clearview Financial Partners may charge a higher fee, up to 1.6%, and receive
a portion of the wrap fee for services provided. The combined total fee will not exceed 1.6%. The
program may cost more or less than purchasing such services separately.
The other programs provided by the adviser include:
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. 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.
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 (non-discretionary accounts require client approval prior to a transaction being
executed). 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.
An investment advisor representative recommending the wrap fee program receives compensation
as a result of a client’s participation in the program. The amount of this compensation may be more
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than what the person would receive if the client participated in other programs or paid separately for
investment advice, brokerage, and other services. Therefore, investment advisor representatives
may have a financial incentive to recommend the wrap fee program over other programs or
services.
There may be additional fees on assets help in the wrap program, such as mutual fund expenses and
mark-ups, mark-downs, or spreads paid to market makers. A more detailed description of these fees
and circumstances is detailed above in Item 4 above.
Neither the firm or any supervised persons accepts performance-based fees, fees based on a share of
capital gains on or capital appreciation of the assets of a client such as a hedge fund or other pooled
investment vehicle. Neither the firm or any supervised persons manages side-by- side accounts that
are charged a performance-based fee and accounts that are charged another type of fee, such as an
hourly or flat fee or an asset-based fee.
Investment advisor representatives are restricted to providing services and charging fees based in
accordance with the descriptions detailed in this document and 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 representatives are instructed to consider the individual
needs of each client when recommending an advisory platform. Investment strategies and
recommendations are tailored to the individual needs of each client.
For more information about the investment advisor representative managing the account, client
should refer to the Brochure Supplement for the associated person, which client should have
received along with this Brochure at the time client opened the account.
The Custodian(s) perform certain administrative services for Clearview Financial Partners,
including generation of quarterly performance reports for program accounts. Client will receive an
individual quarterly performance report, which provides performance information on a time
weighted basis. The performance reports are intended to inform clients as to how their investments
have performed for a period, both on an absolute basis and compared to leading investment indices.
Methods of Analysis and Investment Strategies
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
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•
•
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
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.
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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
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 of time. It is
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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
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
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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.
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 go up,
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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.
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.
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:
directing the manner in which proxies solicited by issuers of securities beneficially owned by the client
shall be voted; and,
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 7 – Client Information Provided to Portfolio Managers
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In the Clearview Financial Partners Wrap program, Clearview Financial Partners is responsible for
account management; there is no separate portfolio manager involved. Clearview Financial Partners
obtains the necessary financial data from the client and assists the client in setting an appropriate
investment objective for the account. Clearview Financial Partners obtains this information by
having the client complete an advisory agreement and other documentation. Clients are encouraged
to contact Clearview Financial Partners if there have been any changes in the client’s financial
situation or investment objectives or if they wish to impose any reasonable restrictions on the
management of the account or reasonably modify existing restrictions. Client should be aware that
the investment objective selected for the program is an overall objective for the entire account and
may be inconsistent with a particular holding and the account’s performance at any time. Client
should further be aware that achievement of the stated investment objective is a long-term goal for
the account.
The Firm policy requires an annual client meeting (one review every 12 months) to determine if
there have been any changes in the client's financial situation, investment objectives, or restrictions.
In addition, the meeting should incorporate the account performance, appropriateness of the
account, and any other information determined pertinent to the client situation. The annual meeting
may occur by phone, in person, via e-mail, or via video conference and documentation will be
maintained to evidence that at a minimum the following topics were reviewed:
Investment Objective and Goals
• The client’s financial status
• Risk Tolerance
• Time Horizon
•
• Asset Allocation and/or Account Holdings
Additionally, on an annual basis, IARs should review the performance of the client's advisory
account and investment objectives.
Item 8 – Client Contact with Portfolio Managers
Client should contact Clearview Financial Partners at any time with questions regarding program
account.
Item 9 – Additional Information
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of an advisory firm or the integrity of a
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 disciplinary events
to disclose.
Other Financial Industry Activities and Affiliations
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Investment advisor representatives may also be registered representatives of LPL Financial, an
unaffiliated SEC registered and FINRA/SIPC member broker/dealer. Clients may choose to engage
an investment advisor representative in their capacity as a registered representative of the
unaffiliated LPL Financial broker/dealer, to implement investment recommendations on a
commission basis. Investment advisor 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 Financial.
Representatives of our firm may also be insurance agents/brokers. They may 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.
A conflict of interest may arise as these insurance sales may create an incentive to recommend
products based on the compensation Clearview Financial Partners and/or our supervised persons
may earn and may not necessarily be in the best interests of the client. Such potential conflicts of
interest are subject to review by the Chief Compliance Officer.
• Neither Clearview Financial Partners 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.
• Clearview Financial Partners will ensure third party investment advisers are properly
registered, licensed, and/or notice-filed with the appropriate state(s).
• Clearview Financial Partners may or may not have discretion over client funds as
indicated in the advisory agreement.
• 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 Clearview Financial Partners been
the subject of a bankruptcy petition.
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. The code of ethics includes guidelines regarding personal securities
transactions of its employees and investment advisor representatives. 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. This presents a potential conflict of interest because trading by an
employee or investment advisor representatives in a personal securities account in the same or
different security on or about the same time as trading by a client could potentially disadvantage the
client. Clearview Financial Partners addresses this conflict of interest by requiring in its code of
ethics that employees and investment advisor representatives report certain personal securities
transactions and holdings to the Chief Compliance Officer for review.
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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. 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. Clearview Financial Partners has a fiduciary duty to all
clients. 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. We
require all of our supervised persons to conduct business with the highest level of ethical standards
and to comply with all federal and state securities laws at all times. 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 our Code of Ethics. Our firm and supervised persons
must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might
negatively affect or appear to affect our duty of complete loyalty to all clients. 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.
Review of Accounts
Investment advisor representatives conduct reviews of client advisory accounts on a periodic basis
(at least annually) for consistency with the client's stated investment objectives, among other
factors. All investment advisory clients are advised that it remains their responsibility to advise
Clearview Financial Partners of any changes in their investment objectives and/or financial
situation. IARs, may also conduct account reviews based on the occurrence of a triggering event,
such as a change in client investment objectives and/or financial situation, market corrections and
by client request.
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
All clients (in person or via telephone) are encouraged to review financial planning issues (t the
extent applicable), investment objectives and account performance with their IAR on an annual
basis.
During any month that there is activity in the program account, client will receive a monthly
account statement from LPL showing account activity as well as positions held in the account at
month end. Additionally, client will receive a confirmation of each transaction that occurs within
the program account unless the transaction is the result of a systematic purchase, redemption or
exchange. Client will also receive a detailed quarterly report showing performance, positions and
activity from LPL Financial.
For advisory accounts held at custodians and third-party advisors other than LPL, accounts will be
reviewed based on similar criteria.
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Other Compensation
Clearview Financial Partners and its associated persons may receive additional non-cash
compensation from product 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 or marketing or advertising initiatives. Product sponsors may also pay for education or
training events that may be attended by Clearview Financial Partners’ employees and associated
persons.
There are no other economic benefits provided by someone who is not a client for providing
investment advice. However, financial assistance or the sponsorship of conferences and educational
sessions, marketing support, incentive awards, payment of travel expenses, and tools to assist IAR
in providing various services to clients may be provided by LPL Financial.
Financial Information Custody
The qualified custodians collectively maintain custody of client funds and securities in a separate
account for each client under the client’s name. Clearview Financial Partners is deemed to have
limited custody as a result of fee deduction.
o LPL Financial LLC (LPL)
o Charles Schwab & Co., Inc. (Schwab)
The Custodians send out account statements showing all transactions, positions, and all deposits and
withdrawals of principal and income. The custodian sends account statements monthly when the
account has had activity or quarterly if there has been no activity. Clients should carefully review
those account statements. Clearview Financial Partners may also provide advisory services on
assets held at different third-party custodians. The fee structure disclosed above will apply
regardless of the custodian where assets are held.
• 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.
Although most securities available in the program accounts are custodied with a third party
qualified custodian, there are certain securities managed as part of the account that are held at with
an investment sponsor. For example, variable annuities, hedge funds and managed futures are often
held directly with the investment sponsor. For those outside positions, client will receive
confirmations and statements directly from the investment sponsor.
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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.
Brokerage Practices
In the Clearview Financial Partners Wrap program, Clearview Financial Partners requires that
clients with assets custodied at LPL Financial, direct LPL Financial as the sole and exclusive
broker-dealer to execute transactions in the account. LPL Financial is not paid a commission for
executing transactions. Because associated persons of the Clearview Financial Partners are licensed
with LPL Financial, this presents a conflict of interest. Clients should understand that not all
advisors require their clients to direct brokerage. By directing brokerage to LPL Financial, clients
may be unable to achieve the most favorable execution of client transactions. Therefore, directed
brokerage may cost clients more money.
Clearview Financial Partners may receive support services and/or products from LPL Financial,
which assist Clearview Financial Partners to better monitor and service program accounts
maintained at LPL Financial. These support services and/or products may be received without cost,
at a discount, and/or at another 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
• 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
• other products used by Clearview Financial Partners in furtherance of its investment
advisory business operations
Clients do not pay more for services as a result of this arrangement. There is no corresponding
commitment made by Clearview Financial Partners to LPL Financial or any other entity to invest
any specific amount or percentage of client assets in any specific securities as a result of the
arrangement.
Clearview Financial Partners also custodies assets with Schwab. Schwab is an independent and
unaffiliated SEC-registered broker/dealer. Schwab offers to independent investment Advisors
services which include custody of securities, trade execution, clearance and settlement of
transactions. Advisor receives some benefits from Schwab through its participation in the
program.
Clearview Financial Partners, through its participation in the program, may receive discounts on
compliance, marketing, technology, and practice management products or services provided to the
Firm by third party vendors. Such services represent a potential conflict of interest disclosure. The
Firm’s receipt of general platform services does not diminish the Firm’s duty to act in the best
interests of its clients, including seeking best execution of trades for client accounts. As part of its
fiduciary duties to clients, advisor is obligated at all times to put the interests of their clients first.
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Clients should be aware, however, that the receipt of economic benefits by adviser or its related
persons in and of itself creates a potential conflict of interest and may indirectly influence the
adviser’s choice of Schwab for custody and brokerage services.
Trade Aggregation
Clearview Financial Partners 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 may determine not to aggregate transactions,
for example, based on the size of the trades, the number of client accounts, the timing of the trades,
the liquidity of the securities and the discretionary or non-discretionary nature of the trades. If
Clearview Financial Partners does 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.
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.
Transition Assistance
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
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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.
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