Overview
- Headquarters
- St. Charles, IL
- Average Client Assets
- $2.1 million
- Minimum Account Size
- $10,000
- SEC CRD Number
- 142728
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A, MARCH 2026)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 2.50% |
| $250,001 | $500,000 | 2.25% |
| $500,001 | $1,000,000 | 1.75% |
| $1,000,001 | and above | 1.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $20,625 | 2.06% |
| $5 million | $80,625 | 1.61% |
| $10 million | $155,625 | 1.56% |
| $50 million | $755,625 | 1.51% |
| $100 million | $1,505,625 | 1.51% |
Clients
- HNW Share of Firm Assets
- 69.18%
- Total Client Accounts
- 2,569
- Discretionary Accounts
- 2,554
- Non-Discretionary Accounts
- 15
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Educational Seminars
Regulatory Filings
Additional Brochure: FORM ADV PART 2A, MARCH 2026 (2026-03-16)
View Document Text
525 Tyler Road, Suite T
St. Charles, IL 60174
Phone: (630) 762-9352
Fax: (630) 587-9170
www.totalclaritywealth.com
Form ADV Part 2A Brochure
March 17, 2026
This brochure provides information about the qualifications and business practices of Total Clarity Wealth
Management, Inc. that should be considered before becoming a client. If you have any questions about the
contents of this Brochure, please contact us at (630) 762-9352 and/or info@totalclaritywealth.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 Total Clarity Wealth Management, Inc. is also available on the SEC’s website
at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Total Clarity Wealth Management, Inc.
is 142728.
Any reference to Total Clarity Wealth Management, Inc. as a registered investment adviser or its related
persons as registered Advisory Representatives does not imply a certain level of skill or training.
Item 2 Material Changes
At least annually, this section will discuss only specific material changes that are made to the Total
Clarity Wealth Management, Inc. brochure and brochure supplements and provide you with a summary
of such changes. Additionally, reference to the date of the last annual update to the brochure and
brochure supplements will be provided.
Since our last annual updating amendment dated March 24, 2025 we have made the following material
changes:
Item 2 Material Changes: Added the ability to opt out of sharing data with a representative that
leaves Total Clarity.
A copy of our updated brochure and brochure supplements may be requested by contacting us at
(630) 762-9352 and/or info@totalclaritywealth.com. These documents are available to you free of
charge and are also available on our website at www.totalclaritywealth.com.
Additional information about Total Clarity Wealth Management, Inc. is also available via the SEC’s
website www.adviserinfo.sec.gov. Our IARD number is 142728. The SEC’s website also provides
information about any persons affiliated with Total Clarity Wealth Management, Inc. who are
registered, or are required to be registered, as Advisory Representatives of Total Clarity Wealth
Management, Inc.
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Item 3 Table of Contents
Item 2 Material Changes ................................................................................................................. 2
Item 3 Table of Contents ................................................................................................................ 3
Item 4 Advisory Business ............................................................................................................... 4
Item 5 Fees and Compensation .................................................................................................... 13
Item 6 Performance-Based Fees .................................................................................................. 24
Item 7 Types of Clients ................................................................................................................. 25
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 25
Item 9 Disciplinary Information ..................................................................................................... 29
Item 10 Other Financial Industry Activities and Affiliations ........................................................... 29
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 31
Item 12 Brokerage Practices ........................................................................................................ 31
Item 13 Review of Accounts ......................................................................................................... 33
Item 14 Client Referrals and Other Compensation ....................................................................... 34
Item 15 Custody ............................................................................................................................ 35
Item 16 Investment Discretion ...................................................................................................... 36
Item 17 Voting Client Securities .................................................................................................... 36
Item 18 Financial Information ....................................................................................................... 36
Item 19 Requirements For State Registered Advisers ................................................................. 37
Item 20 Additional Information ...................................................................................................... 37
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Item 4 Advisory Business
Total Clarity Wealth Management, Inc. (hereinafter referred to as "Total Clarity") is a financial planning
and investment advisory firm offering wealth management services customized to your individual
needs.
4 A. Total Clarity is a corporation formed under the laws of the State of Illinois in 2006 and filed for
investment adviser registration with the Securities and Exchange Commission in April of 2007. On
March 1, 2015, David J. Hubbard (CRD number 1122248) became the majority shareholder of Total
Clarity. Terrance (Terry) Murphy (CRD number 2191779) remains as President and Jeanne Tackett
(CRD number 5257777) is the Chief Compliance Officer and the Vice President of Operations. Terry,
Jeanne, and David are the principal owners of Total Clarity Wealth Management. David Hubbard
entered the financial services industry in 1980. Terry has been in the financial services industry since
1991, and Jeanne became involved in the financial services industry beginning in 2006. Additional
business information about Dave, Terry, Jeanne and the other Advisory Representatives who work
with clients is disclosed on the Supplemental Brochures ADV Part 2B for each Advisory
Representative.
4 B. Total Clarity offers the following advisory services, a complete description of each is described
below:
Asset Allocation and Management/Portfolio Monitoring Services
Advisory Services to ERISA Account Plan Sponsors (Employer 401K programs)
Financial Planning
Special Projects and Retainer Programs
Total Clarity's Advisory Representatives are independent contractors and engage in other financial
businesses as further disclosed under Item 10, resulting in additional forms of compensation. Each
Advisory Representative determines the advisory services and fees based on Total Clarity's fee
structure disclosed in Item 5 below. Therefore, your Advisory Representative could charge more or
less than another Total Clarity Advisory Representative for similar services. The fees charged are not
correlated to education or experience.
Since our advisors are independent contractors with Total Clarity, they are able to retain your personal
private information, such as your name, contact information, account registration and account
numbers, even if they are no longer associated with us. Total Clarity also retains this information.
You may opt out of allowing your representative to take your personal information with them if they
decide to leave Total Clarity by contacting us at (630) 762-9352 or email us at
info@totalclaritywealth.com. Opt-out requests will remain effective unless revoked and do not apply to
disclosures permitted or required by law. Please allow a reasonable period of time for your request to
be processed.
Asset Allocation and Management/Portfolio Monitoring Services
When Total Clarity completes its analysis of your existing investments and overall financial
circumstances, our Advisory Representative will determine an asset allocation customized to your
financial goals, objectives and risk tolerance. One of the tools available for use by our Advisory
Representatives are portfolio models provided by a third party through Schwab at no charge to Total
Clarity or the client, although the third party could benefit from internal expenses charged by the
holdings. Your Advisory Representative can use these models as a guide in managing your account,
but he is responsible to make all decisions and complete all trades himself. Advisory representatives
also have available, the use of separately managed accounts through LPL that use another firm to
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manage the holdings in the account. Some of these programs are available at no charge to the client
while others may result in an additional fee. No other party outside of Total Clarity will have the ability
to trade assets within your account without your approval. Since our investment strategies and advice
are based on each client’s specific financial situation, the investment advice we provide to you may be
different or conflicting with the advice we give to other clients regarding the same security or
investment. We customize your portfolio allocation taking into consideration your limitations or
restrictions, the market and economy at the time, your current financial status, and future goals and
objectives. We offer five managed account programs: the Total Clarity Vision Account, which is a wrap
fee program, the Total Clarity Value account, the Total Clarity PreActive account, and the Total Clarity
Vision CB account, another wrap program, and the Value CB account. Both the Vision CB and the
Value CB accounts have billing adjustments for all client cash deposits or withdrawals and limited
reporting. The Total Clarity Vision and Vision CB Accounts wrap all of the transaction charges in with
the advisory fee, whereas the Value, Value CB and PreActive Accounts charge an advisory fee and
transaction charges are billed directly to the account. Please refer to the Total Clarity PreActive
Brochure for additional information on these accounts which are only available to sophisticated
investors and have higher risk and volatility than the Vision, Value, Vision CB and Value CB Accounts.
Your Advisory Representative will schedule a meeting with you and present the recommended portfolio
allocation. Upon your approval, we will implement the initial portfolio allocation. After we implement the
initial portfolio allocation, with your written approval as indicated in the Vision, Vision CB and Value CB,
Value or PreActive Account Agreement, we will provide continuous and ongoing management of your
account. By signing the custodian's Account Application you provide your Advisory Representative with
discretionary approval for your account, he will determine the securities to be purchased and sold in
the account and will alter the securities holdings from time to time, without prior consultation with you.
Unless otherwise expressly requested by you, Total Clarity will manage the account and will make
changes to the allocation as deemed appropriate by the firm and your Advisory Representative. You
can discuss with your Advisory Representative your desire to be notified of any recommendations
before buying or selling any securities in your account, but in order to trade at our custodians, the
Advisory Representative must be given discretion on all accounts. All clients will be sent, by the
custodian of your account, either by mail or electronically, confirmations of any trades done in your
account. Depending on your specific goals, objectives and market circumstances, we will generally
hold positions in your account for a long term, even more than a year, or actively trade some securities
held in your account for periods of 30 days or less.
Our Advisory Representatives primarily use open-ended mutual funds, exchange traded funds (ETFs)
and stocks, including no-load and load waived mutual funds purchased at net asset value (NAV).
Registered investment company securities such as mutual funds, and variable products offer the
securities in various share classes. Different share classes are priced differently and share classes
other than institutional share classes will involve higher internal costs that over time will cost you more.
Institutional share classes often have higher trading costs though the internal expenses are lower. An
Advisory Representative needs to consider the amount being invested and the length of anticipated
holding to make a decision as to the share class most suitable to the client. Please read the
disclosures under Item 10 below for important information about the advice and recommendations
offered by advisory representatives and registered representatives. Representatives will select the
lowest share class funds available and appropriate to the situation. However, in selecting the lowest
share class, trading costs are sometimes higher. Selecting the lowest share class appropriate to the
situation does not imply the lowest cost share class but means what the Representative deems lowest
cost for the situation. Representatives consider the anticipated holding period, cost structure, and
administrative and transaction costs associated with selecting a share class. However, there is no way
to predict the future and there could be occasions where a holding is liquidated sooner or held longer
resulting in higher costs to the client. Additional information about share classes can be found in an
Investor Alert issued by the Securities and Exchange Commission at
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https://www.investor.gov/additional-resources/news-alerts/alerts-bulletins/investor-bulletin-mutual-fund-
classes and https://www.investor.gov/additional-resources/news-alerts/alerts-bulletins/investor-bulletin-
mutual-fund-classes. Additionally, the SEC and FINRA provides investor information at www.sec.gov
and www.finra.org.
However, managed accounts are not exclusively limited to mutual funds and stocks and your account
could include one or more of the following types of securities - bonds, certificates of deposits,
government securities, stock options (such as covered calls and long puts), Unit Investments Trusts
(UITs), money markets and variable annuities. In the case of UITs, many are not purchased into the
account at NAV; they are purchased at the public offering price (NAV plus maximum sales charge).
Therefore, these products will have higher internal expenses. PreActive accounts at times will also
hold leveraged and inverse ETFs and margin accounts will give the Advisory Representative the ability
to short stocks. Please refer to disclosures in Item 8 regarding risks associated with leveraged and
inverse ETFs. Some Advisory Representatives also invest in "Alternative Investment" products, such
as Real Estate Investment Trusts (REITs) and private equities. These are held in the Account as a
courtesy to the client(s) and are not part of any wrap fee program. Refer to additional disclosure about
alternative investments and the cost and compensation structure and conflicts of interest in Item 5
below.
Transactions in the account, account reallocations and rebalancing may trigger a taxable event, with
the exception of IRA accounts, 403(b) accounts and other qualified retirement accounts.
After making the initial asset allocation recommendation, we will monitor your account on a periodic
basis and make investment recommendations and will provide continuous and ongoing management
of the assets.
As further described below, Total Clarity has entered into relationships to offer you brokerage and
custodial services through LPL Financial (LPL) an unaffiliated SEC registered Broker/Dealer and
Member FINRA/SIPC as well as with Schwab Institutional, a division of Charles Schwab & Co., Inc.
("Schwab") an unaffiliated SEC registered Broker/Dealer and FINRA member. For accounts held at
Schwab, LPL does not provide brokerage services. Additionally, 529 type accounts with Total Clarity
can be held directly at the mutual fund company or at Charles Schwab and variable annuities are held
at the annuity company. There is no affiliation between Total Clarity and LPL or Schwab.
If you select another brokerage firm for custodial and/or brokerage services you will not be able to
receive on-going asset management services from Total Clarity. Many of our Advisory Representatives
are also registered representatives with LPL. These Advisory Representatives must adhere to FINRA
rules and regulations and the policies and procedures of LPL Financial. FINRA rules prohibit our
Advisory Representatives from conducting transactions at a broker/dealer for which approval has not
been obtained from LPL. Additionally, certain of our Advisory Representatives are also Advisory
Representatives with LPL, but being registered with two RIAs is only allowed under limited exceptions.
Schwab has been approved to offer services which include custody of securities, trade execution, and
clearance and settlement of transactions to Total Clarity. Total Clarity receives some benefits from
Schwab through its participation in the Schwab programs but there is no direct link between Total
Clarity's participation in the program and the advice it gives to its clients.
You can deposit assets on which a commission was previously paid, including mutual funds on which a
sales charge was paid, to a fee-based account. However, Total Clarity generally does not permit
securities purchased on a commission basis to be transferred into a fee-based account for a minimum
2 year period for A shares and 4 years for B shares after the securities were purchased if your Total
Clarity Advisory Representative received the commission on these mutual funds. These restrictions are
not required if the securities were originally purchased by an outside firm and representative, and are
6
being transferred into a Total Clarity Vision, Vision CB, Value CB, Value Account or PreActive Account
under the management of our Advisory Representative. A shares or other 12b-1 paying share classes
will be converted to advisory share classes within 30 days of transfer into a Total Clarity account held
at Schwab or LPL Financial unless a comparable advisory share class is not available.
Total Clarity does not allow 'C' shares to be held within any of its programs. If they are transferred in
from another account, they will be sold without a commission, if possible, as soon as they are brought
into the Total Clarity account. The purpose of this prohibition is to prevent you from paying duplicative
or extra charges. If the account would be charged a Contingent Deferred Sales Charge (CDSC) when
the C shares were sold, the Advisory Representative must disclose this to you and receive your
permission to complete the sale or he will cover this charge. If necessary, the C shares will be held in
the account until the surrender period has passed and they can be sold without this charge. These C
shares will not be included in the account value for fee calculation purposes.
Advisory Services to Employer 401(k) Plan Sponsors
Total Clarity offers on-going advisory services for Employer 401(k) Plan Sponsors. These services
include providing recommendations of the asset classes and investment choices to be offered within
the 401(k) plan and a review of the investment choices at least once a year or when requested by the
Plan Sponsor. Total Clarity will also provide non-fiduciary services for these programs including
working with the TPA of the plan, assisting with rollovers due to termination or retirement of Plan
participants and for new participants and providing educational seminars to the plan participants at
least once a year if requested by the plan sponsor(s) (educational seminars will be of general topics
such as how the Plan works, Roth conversions, 529s and economic updates, but we will not be
providing any specific investment advice at these seminars).
Neither Total Clarity nor the IAR will initiate trades, have custody of any Plan assets, recommend
individual stocks, bonds, or mutual funds within the Plan to the Plan Participants, nor design or write
Plan Documents. Please see form TCWM_348, ERISA Advisory Services Agreement for more
information.
LPL's Strategic Market Solution Program
Clients in the Strategic Market Solution Program (SMS) may select Total Clarity to provide the advisory
and consulting services described below through one of their Advisory Representatives. Please refer to
LPL's Retirement Plan Programs Brochure for complete details about the SMS program
If the Plan is subject to ERISA, LPL will be a “fiduciary” and serve as “investment manager” (as that
term is defined in Section 3(38) of ERISA) in connection with the Fiduciary Selection Services. None
of the services offered under SMS other than the Fiduciary Selection Services will constitute
“investment advice” under 3(21)(A)(ii) of ERISA, or otherwise cause LPL or Advisory Representatives
or Total Clarity, as applicable, to be deemed a fiduciary.
In addition to the Fiduciary Selection Services, the Plan Sponsor may also select from a number of
non-fiduciary consulting services available under SMS that are provided by the Advisory
Representatives or Total Clarity, as applicable. These consulting services may include, but are not
limited to: general education, and support regarding the Plan and the investment options selected by
Plan Sponsor; assistance regarding the selection of, and ongoing relationship management for, record
keepers and other third-party vendors; Plan participant enrollment support; and participant-level
education regarding investment in the Plan. These consulting services do not include any
individualized investment advice to the Plan Sponsor or Plan participants with respect to Plan assets,
and LPL and the Advisory Representatives or Total Clarity, as applicable, do not act as fiduciaries
under ERISA in providing such consulting services.
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Retirement Plan Participant Account Management with Discretion
We use a third-party platform to facilitate management of held-away assets such as 401(k) participant
accounts with discretion. These held-away assets are not maintained at one of our approved
custodians but rather the accounts are held at the custodian selected by the Plan
trustees. The platform allows us to avoid having custody of Client funds since we do not have direct
access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way
and receive no compensation from them for using their platform. A link will be provided to the Client
allowing them to connect their account(s) to the platform. Once Client account(s) are connected to the
platform, Total Clarity will review the current account allocations. When deemed necessary, Adviser
will rebalance the account considering client investment goals and risk tolerance, and any change in
allocations will consider current economic and market trends. The goal is to improve account
performance over time, reduce loss during difficult markets, and manage internal fees that harm
account performance. Client accounts will be reviewed at least quarterly and allocation changes will be
made as deemed necessary by Total Clarity.
For held-away accounts, Client agrees to the Pontera End User Terms and Conditions and Privacy
Policy. Client agrees to promptly address any requests to update its login credentials when requested
by the Pontera system. In the event of any delay by the Client to update its login credentials, Client
acknowledges that the Adviser will not have access to view or manage the Client's Held Away
Account(s), which may result in investment losses or inadvertently incorrect valuations being used in
the billing process. Client acknowledges and agrees that Total Clarity and the IAR are not responsible
for any losses arising from the Client's delays in updating its login credentials through the Pontera
system and agrees that Total Clarity and the IAR are under no obligation to credit any fees for
valuations made in good faith during periods when they did not have access to any held-away account
in calculating its fees.
Third-Party Created Model Portfolios
Total Clarity has entered into an agreement with a service provider which provides us with access to
certain model portfolios as well as trading instructions. These services allow us to provide model
portfolios comprised of stocks and exchange-traded fund products but other products such as mutual
funds are also available to us.
Total Clarity does not pay the provider for these services and the advisory fees you pay are not
increased because we use these services. These services allow us to provide our clients with
operational and advisory efficiencies which may create a conflict of interest since the models use
mutual funds and exchange-traded funds that may pay fees to the service provider. It is possible that
there are other exchange-traded funds and mutual funds not included in these models that may be in
our clients' best interest. In all cases we strive to recommend only products and services that we
believe are in your best interest and have the lowest cost share class. We have the ability to make
substitutions to the investment selections listed in the models and to deviate from the trading
instructions provided to us.
Accounts invested in these investment models that include mutual funds may be subject to short-term
redemption fees imposed by custodians and/or the mutual fund sponsor. Total Clarity is not
responsible for these short-term redemption fees. They are the responsibility of the client.
These models are available for use with qualified and non-qualified accounts. Advisory
Representatives will pay approximately 10 to 20 basis points (0.10% to 0.20%) to Total Clarity from
their portion of the advisory fee you pay to cover our administration and operational costs. Clients are
not billed directly for the use of these models.
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Separately Managed Accounts
Total Clarity provides advisory services through certain programs sponsored by LPL Financial. These
programs are managed by LPL or an approved third-party manager on a discretionary basis. All
accounts under any of these programs are held at LPL Financial. Each program is described below
and additional information such as any fees that apply and potential conflicts of interest are available
on the associated Account Agreement and LPL’s Form ADV, Part 2A.
When selecting a Separately Managed Account for a client, Total Clarity shall review information about
the program such as its disclosure statement and/or material supplied by the Independent Manager or
independent third parties for a description of the Independent Manager’s investment strategies, past
performance, and risk results to the extent available. Factors that Total Clarity shall consider in
selecting an account type, the model and third-party manager, include the stated client investment
objective(s), management style, performance, reputation, financial strength, reporting, pricing, and
research.
Manager Access Select Program (MAS) – this program offers Total Clarity the ability to
work with the client to identify a third-party portfolio manager (SMA Portfolio Manager) from
a list of SMA Portfolio Managers made available by LPL and the SMA Portfolio Manager
will manage the client’s assets on a discretionary basis. Total Clarity will provide initial and
ongoing assistance regarding the SMA Portfolio Manager selection process and review of
the account. The minimum account size is $25,000 for the Program, but can be higher
depending on the particular SMA Portfolio Manager strategy or Model Portfolio selected.
The SMA Portfolio Manager will have discretion to invest among a broad variety of security
types, including but not limited to equities, fixed income securities, options, mutual funds,
closed-end funds, and exchange-traded funds (“ETFs”).
The fees paid to SMA Portfolio Managers in the SMA Platform are generally less than fees
those advisors would charge a client seeking to establish a direct relationship with them
outside of a wrap program. This is principally due to the fact that LPL absorbs many of the
billing, administrative, and marketing expenses that would otherwise be borne by those
advisors, including trading expenses.
Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a third party managed account using
Optimum Fund mutual funds. The client will authorize LPL on a discretionary basis to
purchase and sell Optimum Funds pursuant to investment objectives chosen by the client.
Total Clarity will assist the client in determining the suitability of OMP and in setting an
appropriate investment objective. Total Clarity will have discretion to select a mutual fund
asset allocation portfolio designed by LPL consistent with the client’s investment objective.
A minimum account value of $10,000 is required for OMP account.
Model Wealth Portfolios (MWP)
Model Wealth Portfolios (MWP) offers clients a professionally managed mutual fund or ETF
asset allocation program. Total Clarity will work with the client to obtain the client’s
suitability information and to determine the suitability of the MWP program and an
appropriate investment objective. Total Clarity will work with the client to open the MWP
account at LPL and to select a model portfolio designed by LPL’s Research Department.
LPL ‘s Research Department, a third party portfolio strategist or the Advisory
Representative may act as portfolio strategist responsible for selecting the mutual funds or
ETFs within a model portfolio and for making changes to these holdings. The minimum
account size is $10,000 for the MWP accounts, but can be higher depending on the
particular Model Portfolio selected.
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The client will authorize LPL or the SMA Portfolio Manager to act on a discretionary basis
to purchase and sell mutual funds, ETFs, stocks and fixed income products and to liquidate
previously held securities in any of these three program types. The client also authorizes
LPL to effect rebalancing for accounts in these programs.
Financial Planning Services
Total Clarity offers financial, insurance, and retirement planning services and renders advice on estate
and tax matters within the context of the financial planning process. Our Advisory Representative will
schedule a meeting with you to gather your financial information and history and to discuss your
retirement and financial goals, investment objectives, investment horizon, financial needs, cash flow
analysis, cost of living needs, education needs, savings tendencies, and other applicable financial
information in order to provide the planning services you request. Total Clarity will prepare a written
financial plan and present the analysis of your financial circumstances along with our
recommendations for steps to be taken to assist you as you work toward your financial goals.
The Plan is based on your financial situation at the time and on the financial information you disclosed
to our Advisory Representative. You need to be aware that certain assumptions will be made with
respect to interest and inflation rates, as well as the use of past trends and performance of the market
and economy. However, past performance is in no way an indication of future performance. Total
Clarity cannot offer any guarantees or promises that your financial goals and objectives will be met.
Further, you must continue to review the plan and update the plan based upon changes in your
financial situation, goals, or objectives or changes in the economy. If your financial status, investment
goals or objectives change, you must notify Total Clarity promptly of the changes. Depending on the
services you request, the advice offered by Total Clarity is limited and is not comprehensive in nature.
Based on your specific needs or situation, you should seek the services of other professionals such as
an insurance adviser, attorney and/or accountant.
You are not obligated to implement planning advice through Total Clarity or your Advisory
Representative. If you do choose to implement the plan with one of our Advisory Representatives, they
will receive commissions or other compensation in addition to the fee you paid for the planning
services if insurance products are purchased, you open an advisory account with Total Clarity or
implementation occurs through LPL Financial.
Donor Advised Funds
Total Clarity offers door advised funds through Schwab Giving 360™ and Renaissance Charitable.
A donor-advised fund account is a simple, tax-smart investment solution for charitable giving. An
account is opened with one of these providers and the client makes a charitable donation by
contributing cash, securities, or appreciated assets. The client is then eligible for a current-year tax
deduction and can be more strategic about their giving decisions. As a tax-smart way to manage
giving, the client will be able to contribute cash, appreciated assets, or investments that have been
held for more than a year without paying capital gains taxes and make grants to charity at any time, not
just at year-end.
Administrative fees, investment fees, and account minimums vary depending on the account and how
it's invested. The client will work with their Investment Advisor to choose which type of account best
supports their philanthropic goals and needs:
There is no minimum contribution requirement to open a Schwab Giving 360™ core account.
The minimum initial contribution required to open a Renaissance Charitable Foundation (RCF)
Donor-Advised Fund (DAF) is $5,000. Subsequent contributions must be at least $1,000.
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Once the client makes an irrevocable contribution, you can give to charities immediately or you
may invest your charitable assets for potential tax-free growth.
Your Investment Advisor may mange the holdings in your account for any size account with
Renaissance Charitable and for accounts with a minimum of $100,000 for Schwab Giving
360™.
Additional details about the program, including the options, requirements, fees and costs are included
in the Schwab Giving 360™ account agreement and other documents provided by Schwab Giving
360™ and in the Renaissance Charitable Circular. Information on the fees charged by Total Clarity is
included under Item 5, Fees and Compensation.
Special Projects & Retainer Programs
In addition to the financial planning services indicated above, Total Clarity can provide guidance and
assistance for special projects as a one-time project or on an on-going basis. If it is on an on-going
basis it is a Total Clarity Retainer Program. These projects include services such as providing advice
on assets held outside of Total Clarity or doing an Asset Review, which is a review of all of your assets
including corporate retirement plans, family trusts, etc. They can also include a review of all of your
estate planning, such as beneficiaries on all of your accounts wherever they are held, or a review of
your Social Security benefits and timing. These projects are dependent on the needs of each client.
A special project can be a one-time service, or be provided on an ongoing basis. If it is on an ongoing
basis, it will be a retainer program and your fee will be invoiced monthly or quarterly. It can be invoiced
with your other Total Clarity advisory accounts and be deducted from an existing account you have
with Total Clarity (upon your written authorization) or it can be invoiced separately and paid by ACH,
credit card or check.
4 C. We tailor the advisory services we offer to your individual needs. You are able to request that
your Advisory Representative add reasonable trading restrictions (“Reasonable Restrictions”) to your
advisory account at any time during the management of your account. Your Advisory Representative
or Total Clarity has the option to decline or terminate the account if we feel your elected Reasonable
Restrictions are too prohibitive, and we do not feel the account can be managed within our program.
Restrictions imposed on management of an account, even those considered reasonable, will affect
your account performance and may mean the performance in the account is different than the
performance of other similarly managed accounts.
We will ask you to complete an Account Application for all accounts and a Suitability Questionnaire if
your account is being opened at Charles Schwab to assist us with obtaining information about your
financial situation and history. Additionally, one or more of our Advisory Representatives will meet with
you and conduct an interview and data gathering session to continue the due diligence process. The
information gathered by Total Clarity will assist the firm in providing you with the requested services
and customize the services to your financial situation.
Depending on the services you have requested, we will gather various financial information and history
from you including, but not limited to:
Retirement and financial goals
Investment objectives
Investment time horizon
Existing portfolio statements, including retirement account information
Financial needs
Education savings needs
Cash flow analysis
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Cost of living needs
Savings tendencies
Other applicable financial information required by our Advisory Representative in order to
provide the investment advisory services you have requested.
4 D. Total Clarity's Vision and Vision CB Accounts are wrap fee programs. Our Advisory
Representatives do not manage the assets in these programs any differently than the assets in the
Total Clarity Value and Value CB accounts. PreActive accounts are managed using a much more
active trading strategy and at times using leverage and inverse ETFs which are not allowed in Vision,
Vision CB, Value CB and Value accounts. An additional strategy in the PreActive accounts includes
using options and shorting stocks, when appropriate and suitable, for clients.
Total Clarity will receive a portion of the advisory/wrap fee for our services. For some of our Advisory
Representatives, an additional portion of the net advisory fee is paid to the Advisory Representative's
supervisor and/or branch manager, and the remainder of the fee is paid to your Advisory
Representative.
The Vision, Vision CB, Value CB, Value and PreActive Account Agreements may be terminated by
either party upon receipt of a written notice of termination. Termination by a Client is effective upon
receipt of the notice by Total Clarity unless a specific date is requested in the notice. You may
terminate the agreement without penalty within 5 days of signing the account agreement. If you
terminate an account(s) within the first calendar year after opening the account(s), you will be charged
a $200 administrative fee which will be deducted from any refund of fees. This fee can be waived at
Total Clarity's sole discretion. This fee is not charged on accounts that are closed due to a transfer of
the assets to another Total Clarity account. After one calendar year, if an account is terminated, Total
Clarity will refund any advisory fees charged in advanced based on a pro-rata calculation based on the
value of the account at the beginning of the quarter and the number of days the account was open
during the quarter. If a flat fee has been negotiated (see Item 5), we will also refund any of those fees,
paid in advance, on a pro-rated basis. Upon termination, early redemption fees or similar fees for
mutual funds or other products held in the account are applicable as described in the fund's
prospectus. Some broker-dealers will not accept certain assets that are held in your account. Total
Clarity will use reasonable efforts to follow your instructions regarding the disposition of the assets in
your account to the extent permitted by law and policies of the firm.
Please Note: Total Clarity will discontinue billing after the date specified in the termination notice even
if the assets are still in the account, but Total Clarity and our Advisory Representatives have no
fiduciary responsibilities once the Total Clarity Agreement has been terminated.
4 E. As of December 31, 2023, we have approximately $752,900,000 of client assets under our
discretionary management and approximately $2,500,000 of non-discretionary client assets under
management.
IRA Rollover Recommendations
For purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”)
where applicable, we are providing the following acknowledgment to you. When we provide
investment advice to you regarding your retirement plan account or individual retirement account, we
are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the
Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we
make money creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s
provisions, we must:
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Meet a professional standard of care when making investment recommendations (give prudent
advice);
Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
General Information
The investment recommendations and advice offered by Total Clarity and your Advisory
Representative are not legal advice or accounting advice. You should coordinate and discuss the
impact of the financial advice we provide with your attorney and/or accountant. Total Clarity's primary
goal is to help our clients identify and pursue their financial goals, thereby enhancing the overall quality
of their lives.
Item 5 Fees and Compensation
Asset Management Services
5 A. The Total Clarity Vision and Vision CB Account programs are wrap fee programs which bundle
advisory and transaction charges into one asset-based fee. The Total Clarity Value, Value CB and
PreActive programs are also asset management programs, but in addition to the advisory fees for
these accounts, you will pay transaction fees for securities transactions executed in your account in
accordance with the custodian's transaction fee schedule. You should understand that a wrap fee
program could be more costly to you than if you obtained security trading and investment advisory
services separately. Additionally, you should be aware that a wrap fee account, as compared to a
traditional commission-based account, will be more costly during periods when trading activity is lower.
Your overall fees could be lower if you obtain the services in an unbundled program and purchase
each service separately. However, during periods when trading activity is heavier, such as when the
account is first opened and during periods of increased market movements, wrap fee accounts result in
lower costs than a brokerage account.
Fees will not be the same between the two billing schedules and one may be less expensive for you
than the other available selection. Fees for Vision CB and Value CB accounts may be billed on a First
Next Next Schedule or a Breakpoint Schedule as selected on the Account Agreement. The Advisory
Representatives with Vision CB and Value CB accounts joined Total Clarity during late 2023 and this
breakpoint fee schedule closely mirrors their previous account billing.
Our fees are negotiable and are not based on a share of capital gains or capital appreciation of the
funds, but rather on the value of the account. Advisory fees for our Vision, Vision CB, Value CB and
Value Account Programs will be charged in advance on a quarterly basis, based on the account
balance on the last working day of the previous quarter. Advisory fees for our PreActive Account
Program will be charged in arrears on a quarterly basis, based on the average daily balance of the
account over the previous quarter. The blended fee schedules are as follows:
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Total Clarity Vision (Wrap) and Value Account Programs
Total Clarity Vision and Value Accounts are billed based on the account value as of the last day of the
quarter. Advisory fees will be adjusted each quarter for any client inflows and outflows of cash and
holdings equal to or over $10,000 in a single day.
"First Next Next" Billing Schedule
Account Size
$0 to $50,000
Next $50,001 to $100,000
Next $100,001 to $250,000
Next $250,001 to $500,000
Next $500,001 to $1,000,000
Next $1,000,001 to $3,000,000
Next $3,000,001 to $5,000,000
$5,000,001 and above
Vision Maximum
Annual Fee
2.75%
2.75%
2.75%
2.50%
2.00%
1.75%
1.75%
1.75%
Value Maximum
Annual Fee
2.50%
2.50%
2.50%
2.25%
1.75%
1.50%
1.50%
1.50%
Total Clarity Vision CB (Wrap) and Value CB Account Programs
Total Clarity Vision CB and Value CB Accounts are billed based on the account value as of the last day
of the quarter. Advisory fees will be adjusted each quarter for any client inflows and outflows of cash
and holdings. Fees may be calculated on a First Next Next schedule or a Breakpoint schedule.
"Breakpoint" Billing Schedule
Household Total Assets in
Advisory Accounts
$0 to $50,000
Next $50,001 to $100,000
Next $100,001 to $250,000
Next $250,001 to $500,000
Next $500,001 to $1,000,000
Next $1,000,001 to $3,000,000
Next $3,000,001 to $5,000,000
$5,000,001 and above
Vision Maximum
Annual Fee
2.75%
2.75%
2.75%
2.50%
2.00%
1.75%
1.75%
1.75%
Value Maximum
Annual Fee
2.50%
2.50%
2.50%
2.25%
1.75%
1.50%
1.50%
1.50%
"First Next Next" Billing Schedule
Account Size
$0 to $50,000
Next $50,001 to $100,000
Next $100,001 to $250,000
Next $250,001 to $500,000
Next $500,001 to $1,000,000
Next $1,000,001 to $3,000,000
Next $3,000,001 to $5,000,000
$5,000,001 and above
Vision CB Maximum
Annual Fee
2.75%
2.75%
2.75%
2.50%
2.00%
1.75%
1.75%
1.75%
Value CB Maximum
Annual Fee
2.50%
2.50%
2.50%
2.25%
1.75%
1.50%
1.50%
1.50%
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Total Clarity PreActive Account Program
Total Clarity PreActive Accounts are billed in arrears base on the average daily balance of the account
as of the last business day of the quarter.
Maximum Annual Fee
"First Next Next" Billing Schedule
Account Size
$0 to $500,000
Next $500,001 to $1,000,000
Next $1,000,001 to $3,000,000
Next $3,000,000 to $5,000,000
$5,000,0001 and above
2.50%
2.50%
2.50%
2.50%
2.50%
Your Advisory Representative will negotiate your specific fee with you, based on the fee schedules
outlined above. We make exceptions to our general fee schedules under certain circumstances (e.g.,
responsibilities involved, accounts or groups of accounts which are expected to have significant capital
additions in the future, anticipated future earning capacity, related accounts, account composition, pre-
existing client, account retention, pro bono activities, etc.). In such cases, lower fees or different
payment arrangements can be negotiated with each client separately and will be described in your
Vision, Vision CB, Value CB, Value or PreActive Account Agreement. Fees vary from client-to-client
and are detailed on the Total Clarity Vision, Vision CB, Value CB, Value and PreActive Account
Agreements you will sign; however, fees will not exceed the schedules shown above. Therefore, your
Advisory Representative can charge more or less than another Advisory Representative. Further,
certain Advisory Representatives have an active trading strategy that can result in the total fee
(advisory fee plus transaction fees) for Value, Value CB and PreActive accounts being high and could
be excessive compared to industry standards.
Breakpoint Fee Schedules are based on the total advisory assets under management of the
household. These accounts will be reviewed on a semi-annual basis to determine if the account has
reached the next breakpoint. If so, the fees will be adjusted on the following quarter's billing.
The First Next Next fee schedules are tiered schedules. More than one fee rate will apply to the
account if the total account value is $50,001 or more at the time of valuation for the purposes of the fee
calculation.
If negotiated, Total Clarity will charge a flat fee, not to exceed the rate % noted above, billed in
advance for Vision, Vision CB and Value CB and Value accounts and billed in arrears for PreActive
accounts. Total Clarity will pro-rate a flat fee for the first quarter based on (the number of days the
account is opened) / (the total number of days in the quarter) multiplied by the fee. We will also refund
any flat fees paid in advance a pro-rated portion based on the fee multiplied by (the number of days
the account was open) / (number of days in the quarter) if an account is closed.
Total Clarity retains a portion of the advisory fees equal to 0.08% - 0.20% of the account value
annually to cover administrative costs. The amount is based on the Advisory Representative’s assets
in Total Clarity accounts. This may encourage some Advisory Representatives to open advisory
accounts for clients to earn a reduction in the fees they pay us, but Total Clarity does not believe this is
a material issue. All advisory accounts are reviewed to be sure the account is in the best interest of the
client, and we feel this overrides the possibility of opening an advisory account that is not suitable for
the client. For some of the Advisory Representatives a portion of the net advisory fee will be paid to
the Advisory Representative's supervisor and/or branch manager. LPL Financial will receive an annual
oversight fee of 0.03%- 0.05% times the value of each account, that is managed by Advisory
15
Representatives who are also registered with LPL and is held at Schwab for supervision and back-
office administration. This fee is pulled from the advisory fee before the remainder of the fee is paid to
your Advisory Representative and is only assessed to Representatives who are also Registered
Representatives with LPL. Total Clarity could change the above fee schedules upon 30-days prior
written notice to you.
At the discretion of the Advisory Representative, all accounts from one household are added together
to obtain a higher total of account values for fee calculations. In this way, your annual asset
management fee will then be lower if a breakpoint is reached, since it is based on an aggregate value
of all accounts within your household, than if the fee for each account was calculated independently of
the other accounts. This practice varies by Advisory Representative; so you could pay more or less for
management services depending on the Advisory Representative with whom you work.
You are able to make additions to or withdrawals from the account, provided the account continues to
meet minimum account size requirements. Advisory fees will be adjusted each quarter for any inflows
and outflows of cash and holdings over or equal to $10,000 in a single day. This is often referred to as
Cash Flow Billing. For example, if $10,000 is withdrawn from an account midway through a quarter, a
pro-rated amount which is equal to the annual fee on that $10,000 divided by the number of days in the
year to get a daily rate and then multiplied by the number of days remaining in the quarter, will be
credited toward the advisory fee for the next quarter. If a tiered fee schedule is used, the total account
value at the end of the quarter will determine the tier breakpoints. If $10,000 is added to an account
midway through a quarter, a pro-rated amount which is equal to the annual fee on that $10,000 divided
by the number of days in the year to get a daily rate and then multiplied by the number of days
remaining in the quarter, will be added to the advisory fee for the next quarter. If a tiered fee schedule
is used, the total account value on the day of the deposit will determine the tier breakpoints. No fee
adjustments will be made for appreciation or depreciation of the account during a quarter or typically
for transfers between two Total Clarity accounts with the same account owner.
Note: No fee adjustments are made for PreActive accounts since they are billed based on the average
daily balance of the account, which takes into account the additions and withdrawals of cash and
holdings. Cash flow adjustments will not be made on flat fee client accounts.
Note: Vision CB and Value CB Accounts allow for Cash Flow Billing fee adjustments on any client
deposits and withdrawals regardless of amount.
Account values in the Orion reporting system will be used for Total Clarity's quarterly fee calculations
for advisory accounts. The custodian account values will be used for quarterly fee calculations for
Vision CB and Value CB accounts. Although account holdings and asset valuations should generally
match, month-end market values reflected in Orion's reporting system sometimes differ from those
provided by the custodian on their month-end statements. The three most common reasons why these
values may differ are (i) differences in the manner in which accrued interest is calculated, (ii)
differences in the date upon which “as of” dividends and capital gains are reported, and (iii) differences
in whether settlement date valuations or trade date valuations are used. If you have any questions or
believe there are material discrepancies between your custodial statement and Orion's reporting
system, please contact Total Clarity at (630) 762-9352. You may request a copy the Orion report
valuations from your Total Clarity Advisory Representative.
If your account has securities that are excluded from billing ("Excluded Securities"), the market value
for the Excluded Securities is deducted from the account's total market value before the fees are
calculated.
Please note that Total Clarity advisory fees cannot be deducted from 529 accounts held directly at a
16
mutual fund company. Advisory fees also cannot be deducted from Variable Annuities held directly at a
Variable Annuity company nor from a Plan Participant Account. Fees for these accounts must be
pulled from a Total Clarity account held at either Schwab or LPL Financial.
5 B. If the account is established during the middle of a quarter, you will pay a pro-rated portion of the
advisory fee based upon the number of days the account was under Total Clarity's management. The
initial pro-rated fee is charged in arrears and is based on the inflow of cash and assets and the
proportion of the number of days remaining in the quarter on the date these assets were delivered into
the account. Subsequent fees are billed in advance for Vision, Vision CB, Value CB and Value
Accounts. Advisory fees for all periods will be charged to and collected directly from your account early
in each quarter. You will need to authorize us to deduct the fee directly from your account; this is done
as part of the Vision, Vision CB, Value CB, Value or PreActive Agreement. If contracted for the service,
you will be provided with a fee notification, included in your Quarterly Client Review, that identifies the
advisory fee, the value of the account, and from which account(s) the fee will be deducted. Not all
clients receive Quarterly Client reviews. For example, Vision CB and Value CB accounts do not
receive Quarterly Client reviews and therefore do not receive a fee notification. If the account does not
contain sufficient funds to pay the advisory fees, Total Clarity has limited authority to sell or redeem
securities in sufficient amounts to pay the advisory fee. You are allowed to reimburse the account for
advisory fees paid to us, except for ERISA and IRA accounts.
5 C. For all three Asset Management Programs you will also pay fees for custodial services, account
maintenance fees, taxes, and other fees associated with maintaining the account. These fees are not
charged by Total Clarity, but rather are charged by the product company, broker/dealer or account
custodian. Total Clarity does not share in any portion of these fees. Additionally, you will pay your
proportionate share of the fund's management and administrative fees and sales charges as well as the
mutual fund adviser's fee of any mutual fund they purchase. Custodians may charge brokerage
commissions, transaction fees, and other related costs on the purchases or sales of mutual funds,
equities, bonds, options, margin interest, and exchange-traded funds. Mutual funds, money market
funds, and exchange-traded funds may also charge internal management fees, which are disclosed in
the fund’s prospectus. For more details on the brokerage practices, see Item 12 of this brochure. These
advisory fees are not shared with Total Clarity and are compensation to the fund-manager or
custodian.
Qualified retirement accounts held at LPL are charged a $60 annual maintenance fee. Schwab does
not charge annual maintenance fees for IRAs. Certain "no load" fund shares are required to be held for
a minimum holding period and are subject to a redemption fee if sold before the minimum holding
period is met. This redemption fee is not covered by the management fee but is charged by and paid to
the mutual fund company as described in the prospectus. We do not receive nor control any portion of
these fees. These fees are also charged in the Total Clarity Value and PreActive Accounts along with
transaction fees. Transaction fees are due and payable at the time orders are placed. Total Clarity and
its IARs receive no portion of any of these fees. At LPL and Schwab, advisory share classes (share
classes that do not pay 12b-1 fees) of mutual funds are typically charged a higher transaction fee for
purchases and sells of these products. However, these funds have lower expenses and therefore
should result in being a lower cost to the customer, but this varies for each fund. LPL offers some of
these advisory share class mutual funds with no transaction fees which results in a conflict of interest
for your Advisory Representative to purchase these specific funds to save himself the transaction fee
for a Vision or Vision CB Account or to save the client the fee for a Value, Value CB or PreActive
Account.
Some custodians also charge a foreign Transaction Tax on certain foreign equity security purchases.
This tax is levied by the foreign government and is used to offset the tax incurred by the custodian as a
result of executing the transaction on your behalf. At account opening, you will receive notification from
17
your custodian about miscellaneous fees and charges they impose for certain transactions (such as
wire or overnight fees). You should keep this documentation for your records.
Although clients do not pay a transaction charge for transactions in Vision and Vision CB accounts,
clients should be aware that your Advisory Representative would cover these charges. The transaction
charges paid by your Advisory Representative vary based on the type of security (ex. mutual fund,
equity, or ETF) and for mutual funds the charge is based on whether or not the mutual fund pays 12b-
1s fees and/or recordkeeping fees to the custodian. Transaction charges paid by your Advisory
Representative for mutual funds range from $0 - $26.50/ transaction which, therefore, results in a
conflict of interest since the Advisory Representative would consider this cost when deciding which
securities to select and how frequently to place transactions in a Vision or Vision CB account. Mutual
fund A share classes typically will have a lower or no transaction charge, so to help mitigate the conflict
of interest in selecting a share class and since 12b-1s fees for accounts held at Schwab or LPL cannot
be refunded, Total Clarity as a general policy has Advisory Representatives use only non-12b-1 paying
share classes, unless clients are better served with another share class.
Schwab and LPL will also charge a $50 fee when purchasing Alternative Investments within Total
Clarity accounts as well as an annual holding fee of $35 - $250 per Alternative Investment. These fees
will not be refunded back to the account since these holdings are not part of the wrap fee program and
are not included in billing calculations. Total Clarity receives no portion of any of the above fees.
Separately Managed Programs
Manager Access Select (MAS)
The Account Fee for Manager Access Select Accounts includes all fees and charges for
the services of SMA Portfolio Manager or Model Advisor, LPL, and Total Clarity including
brokerage commissions for transactions effected through LPL. Client understands that the
Advisory Parties, in connection with the performance of their respective services, shall be
entitled to and will share in the Account Fees payable hereunder. The SMA Portfolio
Manager or Model Advisor will receive the Manager Fee which ranges from 0% - 0.60%.
The Advisory Fee has a maximum of 1.75%, For MAS accounts the SMA Portfolio
Manager fee is charged separately from the Advisory Fee. The total Maximum Annual
Account Fee is 2.35%.
Optimum Market Portfolios (OMP)
The maximum flat Advisory Fee will not exceed 1.75%. Upon request, the Advisory Fee
may be structured on a tiered basis, with a reduced percentage rate based on reaching
certain thresholds. The Account Fee is charged for the asset management services of LPL
and Total Clarity, as well as the administrative and custodial services of LPL. The Account
Fee is negotiable and is based on the value of the assets in the Account, including cash
holdings, and payable quarterly in advance.
Model Wealth Portfolios (MWP)
The Advisory Fee is charged for the investment advisory services of Total Clarity, as well
as the investment advisory, administrative, trading, custodial and clearing services of LPL.
The maximum flat Advisory Fee is 1.75% but may be higher if a tiered schedule is used
that has higher percentages for lower tiers. Depending upon the model(s) selected for the
account, clients pay a Manager Fee set by LPL for the use of each model portfolio. The
Manager Fee is based on the value of the assets in the account, including cash holdings,
and payable quarterly in advance. This fee ranges from 0% to 0.60% and is in addition to
the Advisory Fee. Therefore, the Maximum Total Account Fee would be 2.35%
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Clients should consider the level and complexity of the advisory services to be provided
when negotiating the account fee (or the advisor fee portion of the account fee, as
applicable) with Total Clarity. For accounts utilizing third-party portfolio managers
under aggregate, all-in-one account fee structures (including MAS, OMP & MWP fee
structure), Total Clarity has a financial incentive to select one portfolio instead of another
portfolio because the portion of the account fee retained by Total Clarity varies depending
on the portfolio strategist fee associated with a portfolio.
Please refer to the relevant LPL Form ADV program brochure for a more detailed
discussion of conflicts of interest.
Alternative Investments
The Total Clarity Vision, Vision CB, Value CB or Value Accounts can also hold Alternative Investments
such as Real Estate Investment Trusts (REITs), Business Development Companies (BDCs), and
private equities, but advisory fees will not be charged on these holdings, since in this case
commissions are paid to the registered representative at the time that they are purchased. Transaction
costs and annual holding fees for Alternative Investment products are not covered within the wrap fee
agreement. Total Clarity receives no portion of commissions paid on these holdings.
However, alternative investment products are sold by Advisory Representatives to clients on a
commissionable basis in their capacity as a registered representative. Such advisory representatives
will receive a commission. Alternative investments typically pay a higher commission than other
securities products. Therefore, there is an incentive to recommend alternative investments over other
securities products. This is a conflict of interest. Further, total compensation received by advisory
representatives including commissions and advisory fees on the other holdings in the account could
approach or exceed 3% which is considered excessive by industry standards. To mitigate this conflict
of interest you are informed of these conflicts.
Variable Annuities
For variable annuities held within Total Clarity accounts, there is no sales charge that is paid to your
Advisory Representative upon purchase of the annuity. All expenses or charges, such as mortality &
expense charges and fees for any riders related to the variable annuity are pulled directly from the
variable annuity. These fees typically vary between 0.30% and 1.50% annually and are pulled quarterly
or annually depending on your contract and are in addition to the advisory fee. Please see your
Variable Annuity contract for a list of these fees. Total Clarity receives no portion of these amounts.
Variable products are complex products with higher internal expenses compared to other securities
products and are therefore more expensive.
5 D. As mentioned previously, the asset management fees for Vision, Vision CB, Value CB and Value
Accounts will be charged in advance on a quarterly basis based on the account balance on the last
working day of the previous quarter. The initial pro-rated fee will be charged in arrears and is
calculated as an Addition as described in Item 5A. The value of the addition multiplied by the fee rate
multiplied by the number of days in the account divided by the number of days in the year. Subsequent
fees will be billed in advance. PreActive Accounts are billed in arrears based on the average daily
balance of the account the previous quarter. If you terminate our asset management services during a
quarter, you will be charged a pro-rata portion of the advisory fee for the quarter up to the date assets
are transferred out of the account (termination date). This is equal to (the number of days the account
was open) / (number of days in the quarter) multiplied by the fee for the full quarter. Any refund due will
be calculated based on the fee previously paid for the quarter minus the pro-rata fee described above.
Refunds will be credited to the account from which the management fees were pulled, to the new Total
Clarity account if a Total Clarity to Total Clarity transfer, or a check will be mailed to the client's
address of record. (See Note above for flat rate fees.)
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Examples of the maximum fee calculation for all management programs is shown below:
Fee calculation "First Next Next" billing example for Total Clarity Vision & Vision
Rate % Annual Fee
CB Accounts valued at $1.2 million:
(Amount x Rate % = Annual Fee)
First Next Next Fee Schedule
Amount
First $50,000
Next $50,000 ($100,000 – $50,000 = $50,000)
Next $150,000 ($250,000 – $100,000 = $150,000)
Next $250,000 ($500,000 – $250,000 = $250,000)
Next $500,000 ($1,000,000 – $500,000 = $500,000)
Next $200,000 ($1,200,000 – $1,000,000 = $200,000)
2.75
2.75
2.75
2.50
2.00
1.75
$1,375.00
$1,375.00
$4,125.00
$6,250.00
$10,000.00
$3,500.00
$26,625.00
Example Total Annual Fee:
Example Quarterly Fee for Vision or Vision CB Accounts: ($26,625.00
multiplied by number of days in the quarter/ number of days in the year).
$6,656.25
Fee calculation "breakpoint" example for Total Clarity Vision CB Accounts with a total of all
Total Clarity Accounts valued at $1.2 million:
(Amount x Rate % = Annual Fee)
A household with a total balance of all Total Clarity advisory accounts of $1,200,000 on the breakpoint
fee schedule would be billed at 1.75% per year. The total annual fee is $21,000 ($1,200,000 * 1.75%)
and the quarterly billing (for a 90 day quarter) is $5,178.08. The quarterly calculation is: ($21,000 / 365
days) * 90 days.
Fee calculation example for a Total Clarity Value & Value CB Accounts valued at $1.2
million:
(Amount x Rate % = Annual Fee)
Rate %
2.50
2.50
2.50
2.25
2.00
1.50
Annual Fee
$1,250.00
$1,250.00
$3,750.00
$5,625.00
$10,000.00
$3,000.00
$24,875.00
Breakpoint Fee Schedule
Amount
$50,000
$50,000 ($100,000 – $50,000 = $50,000)
$150,000 ($250,000 – $100,000 = $150,000)
$250,000 ($500,000 – $250,000 = $250,000)
$500,000 ($1,000,000 – $500,000 = $500,000)
$200,000 ($1,200,000 – $1,000,000 = $200,000)
Example Annual Fee:
Example Quarterly Fee: ($24,875 multiplied by number of days in
the quarter/ number of days in the year)
$6,218.70
Fee calculation example for a Total Clarity PreActive Account valued at $1.2 million average
daily balance:
(Amount x Rate % = Annual Fee)
20
Rate %
2.50
2.25
2.00
Annual Fee
$12,500.00
$11,250.00
$4,000.00
$27,750.00
First Next Next Fee Schedule
Amount
$500,000
$500,000 ($1,000,000 – $500,000 = $500,000)
$200,000 ($1,200,000 – $1,000,000 = $200,000)
Example Annual Fee:
Example Quarterly Fee: ($24,875 multiplied by number of days in
the quarter/ number of days in the year)
$6,937.50
5 E. As previously indicated, many of the Advisory Representatives of Total Clarity are Dually
Registered as Registered Representatives of LPL Financial, a registered Broker/Dealer, member of
FINRA and SIPC. Advisory Representatives of Total Clarity who are Registered Representatives will
earn commissions for the sale of securities or investment products that they recommend for brokerage
clients and executed through LPL Financial. They do not earn commissions on the sale of securities or
investment products recommended or purchased in advisory accounts through Total Clarity. Clients
have the option of purchasing many of the securities and investment products we make available to
you through another broker-dealer or investment advisor. However, when purchasing these securities
and investment products away from Total Clarity, you will not receive the benefit of the advice and
other services we provide. Load and certain no-load mutual funds pay annual distribution charges,
sometimes referred to as 12b-1 fees. 12b-1 fees come from fund assets, therefore, indirectly from your
assets. Mutual fund share classes that pay 12b-1s will not be allowed to be held in Total Clarity
accounts at Schwab or LPL Financial unless a comparable advisory share class (this share class could
also be titled "institutional", "investor", "Class I" or "platform" share class) cannot be found. 12b-1s paid
for any mutual funds held within your account will be paid to the custodian/broker firm for your account.
Total Clarity and its Advisory Representatives receive no portion of these fees.
Although clients with Vision and Vision CB accounts with Total Clarity do not pay a transaction charge
for transactions in their account, clients should be aware that their Advisory Representative pays LPL
or Schwab these charges. Because some mutual funds are offered with a $0 transaction charge
versus a standard transaction charge for others, and equities and ETF transaction charges range from
$0 to a standard, non-discounted fee per transaction, this results in a conflict of interest for your
Advisory Representative. Additionally, Schwab charges no transaction fees for ETFs and exchange
traded equities and a standard, non-discounted fee for OTC equities. Clients should understand that
the cost to your Advisory Representative of the transaction charges is a factor that he considers when
deciding which securities to select and how frequently to place transactions in your Vision or Vision
CB account.
Termination Provisions for Asset Management Services
You may terminate investment advisory services obtained from Total Clarity, without penalty, upon
verbal or written notice within five (5) business days after entering into the advisory agreement with
Total Clarity. You will be responsible for any fees and charges incurred from third parties as a result of
maintaining the Account such as transaction fees for any securities transactions executed and Account
maintenance or custodial fees. Thereafter, you may terminate investment advisory services with 15-
days written or verbal notice to Total Clarity. If you terminate your account within the first calendar year
after it is opened, you agree to pay a fee ("Administrative Fee") of two hundred dollars ($200) to defray
initial account setup and administration costs. This fee will be paid in the same manner as the Asset-
Based Fee or an invoice will be sent to the client if the assets are no longer in the account. Total
Clarity can waive the "Administrative Fee" at our discretion.
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Fees for Advisory Services to 401(k) Plan Sponsors
Fees charged for services to ERISA accounts are paid by the 401k plan sponsor or pulled from the
plan participants' accounts. This is decided by the plan sponsor. Fees will be pulled as indicated on the
Total Clarity ERISA Advisory Services Agreement. If the fees are paid by the plan sponsor, an invoice
will be sent each month or each quarter (dependent on the agreement) to the plan sponsor for one-
twelfth or one-fourth the annual fee. Fees will be billed beginning as of the effective date shown on the
plan Agreement or later and are billed in arrears.
Total Clarity does not have a standard fee schedule for ERISA Advisory Services. Fees are set in the
initial agreement and are a flat annual fee based on an estimate of the number of hours required to
provide services to the plan. The maximum allowable fee is $6,000 annually, if assets within the Plan
are less than $500,000; for all other accounts, the fee will not exceed 2% of the total assets in the plan
at the time of the Plan review. A flat fee is a specific dollar amount that you as the client will pay for
consulting services. Fees are paid for in arrears, payable on a quarterly basis. This means that a
Plan's fees pay for services that the Plan received in the ERISA Advisory Services Program in the prior
quarter. Fees are to be paid from Plan assets or by check. If fees will be paid from Plan assets, the
Plan authorizes the Plan Custodian to calculate the appropriate fee using the following
calculation: Annual fee x # days in quarter/365 = quarterly fee. The quarterly fee per account will then
be determined by its % of the total Plan assets and will be charged an amount equal to (Amount of fee
per period x % of value of Plan assets/100). So those with a higher balance will pay a higher amount
than those with a smaller account value. The quarterly fee will be charged on this pro-rata basis across
all of the plan participants based on the account value at the end of the quarter.
Under the executed Advisory Agreement, the fee is debited from Plan assets and forwarded to Total
Clarity for payment to the Advisor. It is the Plan's responsibility to verify the accuracy of fee
calculations made by the Plan Custodian. The value of Plan assets for fee calculation purposes will be
as reported by the Plan Custodian. Total Clarity will receive 10% of the total annual fee per plan with a
minimum of $5,000 total per advisor per year. At their discretion, the Advisory Representative's
supervisor or branch manager receives up to 10% of the remaining fee, and the IAR will then receive
the balance of the fee. Fees will be reviewed annually with the Plan Sponsor or Investment Committee.
Any changes to the fees charged must be approved by the Plan Investment Committee or the Plan
Sponsor.
LPL's Strategic Market Solution Program
Under SMS, clients pay LPL a fee (the “SMS Fee”) for the advisory services of LPL Research and the
services provided by the Advisory Representative or Total Clarity, as applicable, up to an annual
maximum of 0.85%. The SMS Fee paid by the client is inclusive of an LPL program fee for the
investment advisory services provided by LPL Research, and an advisor fee for the services provided
by the Advisory Representative or Total Clarity, as applicable. The LPL program fee is 0.10%, based
on an annualized percentage of assets held in the Plan, subject to a minimum program fee of
$250. LPL may offer program fee discounts based upon the amount of assets held in the Plan or other
criteria. The advisor fee is negotiable at the discretion of each Advisory Representative or Total
Clarity, as applicable, up to a maximum of 0.75%. LPL shares up to 100% of the advisor fee (typically
90%) with the Advisory Representative or Total Clarity as applicable, based on the agreement between
LPL and the Advisory Representative or Total Clarity. The SMS Fee will be payable to LPL in arrears
on the frequency agreed upon between Client and Advisory Representative or Total Clarity, as
applicable. For the SMS Plans Total Clarity will retain 10% of the advisory fee.
Termination Provisions for Services to 401(k) Plan Sponsors
You may terminate advisory services for ERISA accounts without penalty within five (5) business days
of the date of the Agreement. Either party may terminate the Agreement with written or verbal notice to
the other parties without penalty. Total Clarity will discontinue billing after the date specified in the
22
termination notice even if the assets are still at the custodian, but Total Clarity and our Advisory
Representatives have no fiduciary responsibilities once the Total Clarity Agreement has been
terminated.
Fees for Retirement Plan Participant Account Management Services
Fees charged for assets in the Retirement Plan Participant Account Management Services will be the
same or less than those listed above for the Total Clarity Value Accounts. Of the management fee
paid by the client, 30 basis points will be paid to the platform provider for the program and the balance
will be split between Total Clarity and your Total Clarity adviser. Either party may terminate the
Agreement with written or verbal notice to the other parties without penalty. Total Clarity will
discontinue billing after the date specified in the termination notice.
Total Clarity will only be able to select from the available funds and share classes available in the
participant's plan selection. Total Clarity has no input in the selection of investments for the plan and is
not a fiduciary to the participant's plan. Depending on the available selections, some mutual funds
may include 12b-1 fees or higher internal expenses that are not shared with Total Clarity but will have
an impact on the participant's returns.
Fees for Financial Planning Services
Fees charged for planning services are separate and unrelated to fees and/or commissions for
additional services that are obtained, such as asset management or products purchased (e.g.,
securities or insurance).
We offer advisory services on an hourly and/or fixed fee basis. Planning fees are negotiated at the
discretion of your Advisory Representative and are based on an hourly rate or a fixed flat fee agreed
upon prior to initiating services. Your specific rate will be stated in your agreement but will not exceed
$500/hour. Fixed fees will range from $250 to $5,000. Your fees will be dependent on several factors
including the amount of time spent with your Total Clarity adviser, the number of meetings and
complexity of your situation, the amount of research involved, the services requested and/or staff
resources utilized.
Hourly and fixed fees will be billed to you directly and are due upon completion of the Plan Delivery
Form. Generally, one half (1/2) of the fixed fee is payable at the signing of the Client Agreement with
the remaining payable at the completion of the project. Fees for financial plans can also be paid on a
monthly or quarterly basis. Credit card or ACH methods of payment can be used through our bill pay
service provider AdvicePay.
Fees for Retainer Program
Fees charged for retainer program services are typically separate and unrelated to fees and/or
commissions for additional services that are obtained, such as asset management or products
purchased (e.g., securities or insurance).
We offer advisory services on an hourly and/or fixed fee basis. On-going retainer fees are negotiated
at the discretion of your Advisory Representative and are based on an estimated hourly rate or a fixed
annual flat fee agreed upon prior to initiating services. Your specific rate will be stated in your
agreement but will not exceed $500/hour. Fixed fees will range from $250 to $50,000 annually. Your
fees will be dependent on several factors including the amount of time spent with your Total Clarity
adviser, the number of meetings and complexity of your situation, the amount of research involved, the
services requested and/or staff resources utilized.
Hourly and fixed fees will be billed to you directly and are due upon receipt of the invoice or may be
paid quarterly from an existing Total Clarity advisory account. Note, this will depend on the type of
23
services being provided and whether the existing account is a qualified retirement account. Credit card
or ACH methods of payment can be used through our bill pay service provider AdvicePay. On-going
retainer fees cannot be paid by check.
Fees for Donor-Advised Funds
All Fees and Expenses as detailed in the Schwab Program Policies apply. Schwab Giving 360 donor-
advised fund accounts are assessed an annual administrative fee of 60 bps of the account value. This
administrative fee is charged to the investment pool on a daily basis and affects the net asset value of
the account pool holdings. Accounts with assets in excess of $500,000 are eligible for reduced fees
(see their pricing schedule) and receive a quarterly credit for the difference between the reduced fee
and the 60 bps charged to the pools. For Accounts managed by Total Clarity, fees are charged
quarterly directly to the account and are listed as a separate line item on the account statements.
Total Clarity's maximum investment advisory fee to manage your Donor-Advised Fund is 1% per
annum. Specifics on the fee that will be charged are included on your Schwab Giving 360 Investment
Advisory Agreement - Exhibit A.
For Renaissance Charitable Donor Advised Accounts all Fees and Expense are provide in the
Renaissance Charitable Circular provided at account opening. All custodian fees and expenses for
these are accounts are the same as for our other advisory accounts. Renaissance accounts can be
held at Schwab or LPL. Renaissance will charge a tiered fee based on the account size at the end of
each quarter The Renaissance Charitable Foundation (RCF) Donor-Advised Fund (DAF) program
charges annual administration fees based on the fund's balance, with a minimum fee of $250 annually.
The fee structure is as follows:
First $500,000:
Next $500,000:
Next $1,500,000:
Above $2,500,000:
0.65% (65 basis points)
0.35% (35 basis points)
0.25% (25 basis points)
0.20% (20 basis points)
These fees are charged quarterly and are pulled from the account.
Special Projects
Due to the flexible nature of special project services, your Advisory Representative will work with you
to determine your fee on a per project basis. It will be outlined in detail in your Advisory Services
Agreement.
Termination Provisions for Financial Planning Services, Retainer Program and Special Projects
You may terminate special projects, retainer agreements or financial planning services within five (5)
business days after entering into the advisory agreement without penalty. After five (5) business days
of entering into the advisory agreement, you may terminate upon our receipt of your written notice to
terminate. You will be responsible for any time spent by Total Clarity in providing advisory services or
analyzing your situation. You will receive a refund of any unearned, prepaid advisory fees for planning
services and special projects within 30 days of the termination request. Retainer Programs are billed
in arrears, therefore upon termination of the agreement, could result in a final invoice to the client pro-
rated for the number of days services were provided for the specified period.
Item 6 Performance-Based Fees
This section is not applicable to Total Clarity since Total Clarity does not charge performance based
fees.
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Item 7 Types of Clients
Total Clarity's services are geared toward individuals and high net worth individuals, trusts, estates,
charitable organizations, corporations or other business entities.
The minimum investment required in the Total Clarity Asset Management Program is generally
$10,000 for Vision and Value Accounts and $100,000 for PreActive Accounts. Accounts below these
minimums are accepted on an individual basis at our discretion. Such circumstances include, but are
not limited to either additional assets will soon be deposited or the client has other accounts with Total
Clarity. You should be aware that in smaller accounts, performance will suffer due to difficulties with
diversification of assets and risk controls being compromised. Only sophisticated investors with over
$1M in adjusted Net Worth (excluding their primary residence) or an income of $200,000/year will be
allowed to open PreActive accounts and only 50% or less of their liquid Net Worth can be invested in
PreActive accounts due to their increased volatility and risk. Any exception requires prior written
approval from the Chief Compliance Officer or designee.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
8 A. Total Clarity's Advisory Representatives (IARs) act as portfolio managers for their advisory clients.
In that role, they use various investment strategies to reach the Clients' goals and manage investment
risk by conducting economic analyses and attempting to identify relevant market trends. Additionally,
IARs conduct fundamental analyses, which generally involves assessing a company's or security's
value based on factors such as sales, assets, cash flow, market position, expected growth,
management, products and services, earnings, and financial structure.
As previously stated under Item 4, IARs are independent contractors of Total Clarity and each IAR has
their own method of analysis and philosophy of management. There is no one method or analysis that
can predict future market events or will prevent loss. The experience and level of education of IARs
varies and the type of management style varies. Therefore, investment performance and asset
allocations will vary. Some IARs use software and investment analyzing tools that include projections
of returns based on historical information and speculate future tax, educational expense, social
security, etc. conditions, payments, and costs. These systems are a guideline only and cannot be
relied upon to provide complete accuracy or assurances. Your account can also be based on a
portfolio model provided through the custodian. These models have the ability to be modified by your
Advisory Representative who can use the model for a portion of the account or for all of the account.
These models are a guideline and are managed by a third party, but your Advisory Representative is
the one who makes all decisions and trades. Advisory Representatives may also use Separately
Managed Accounts which are managed by LPL Financial or a third party manager or firm. Internal
costs and transaction fees for the holdings in either of these model portfolios could be higher than for
other available mutual funds or ETFs.
PreActive accounts are all managed by the same Advisory Representative. He uses various tools to
manage the PreActive accounts, including augmented intelligence (a proprietary algorithm) that looks
at fundamental factors of stocks such as the balance sheet, income statement and money flow of a
company vs the market. It also looks at pricing trends and historical returns. Please refer to the
PreActive Brochure for more information on the investment strategies used for these accounts.
Investment strategies are also used by IARs to strive to improve the performance and balance the risk
of an account. Asset allocation is one of the strategies all Advisors use to attempt to optimize the risk
and reward of your portfolio by investing among several asset classes. However, it cannot prevent or
insulate a portfolio from market fluctuations or risk.
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While not a standard analysis method used by our Advisors, some Advisors offer services that attempt
to time security performance. This essentially means they try to purchase or sell immediately
preceding an increase or decrease in a security's price. This type of investing can substantially
increase the amount of your brokerage transaction costs due to a higher trading frequency. Also, many
mutual funds or variable annuities prohibit excessive trading within their fund in a short period of time.
Total Clarity monitors client accounts for excessive trading as well as to ensure investments are
appropriate for each client.
8 B. It is important to understand that investing in securities involves risk of loss, including the possible
loss of the principal money you are investing. Therefore, your participation in any of the management
programs offered by Total Clarity requires you to be prepared to bear the risk of loss as well as the
fluctuating performance of your accounts. The market values of investments are subject to fluctuations
based on market conditions.
We do not represent, warrantee or imply that the services or methods of analysis we use can or will
predict future results, successfully identify market tops or bottoms or insulate you from losses due to
major market corrections or crashes. Past performance is no indication of future performance. No
guarantees can be offered that your goals or objectives will be achieved. Further, no promises or
assumptions can be made that the advisory services offered by Total Clarity or our Advisory
Representatives will provide a better return than other investment strategies.
The table below describes some of the risks associated with most types of investing, followed by in
8.C, some investment products that are used in our advisory programs and have risks unique to that
particular investment:
Management
Risk
The services we offer involve your Advisor developing and implementing an
investment strategy for you. A profitable investment strategy inherently involves
making decisions about the future behavior of the securities markets as a whole as
well as markets for individual securities. Because there is no available method to
accurately predict future market behavior, there is no guarantee that any specific
investment strategy will be successful.
Market Risk
This is the risk that the value of any security could go up or down at any time due to
factors affecting securities markets in general or particular industries.
Interest Rate
Risk
This risk affects fixed income securities which can decline in value because of an
increase in interest rates; a bond or fund with a longer duration will be more
sensitive to rate fluctuations.
Credit Risk
This is the risk that an investor could lose money if the issuer of a fixed income
security is unable or unwilling to meet its financial obligations.
Concentrated
Investment
Strategy
Risk
Certain investment strategies are concentrated in a specific sector or industry.
Portfolios using this strategy are more likely to sharply increase or decrease in value
with changes in the market. Concentrated strategies are more volatile because the
risk associated with each company or sector represents a large percentage of your
overall portfolio value.
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8 C. The following are types of investments and related risks that Total Clarity Advisors use in client
portfolios:
Mutual Funds:
The risks with mutual funds include the costs and expenses within the fund that can
impact performance, change of fund managers and/or the fund straying from its stated
investment objective. Open ended mutual funds do not typically have a liquidity issue
and the price does not fluctuate throughout the trading day. Interval funds are also used
in some Total Clarity accounts.
Interval
Funds:
These are a type of mutual fund product that traditionally invests in real estate. Interval
Funds have limited liquidity and could have periods of no liquidity. These funds will
typically offer to repurchase (or buy back) a portion of shares from shareholders pursuant
to restrictions noted in the prospectus. Such restrictions are a limited buy back
percentage, specific timeframes to make redemptions, applicable redemption fees or
ability by the sponsor company to deny redemption requests, therefore, they are
considered to have a higher risk and reduced liquidity. Mutual fund fees and interval fund
fees are described in the fund's prospectus, which will be mailed or emailed directly to
the client following any purchase of a mutual fund that is new to the client's account. In
addition, a prospectus is available online at each mutual fund company's web site. At the
client's request, Total Clarity will direct the client to the appropriate web page to access
the prospectus.
Equity
Securities
In general, prices of equity securities are more volatile than fixed income securities, and
respond to a number of factors that can affect entire financial markets or industries.
Options:
Exchange
Traded Funds
(ETFs)
Certain types of option trading are permitted in order to generate income or hedge a
security; namely, the selling (writing) of covered call options or the purchasing of put
options on a security. The use of options involves additional risks. The risks of covered
call writing include the possibility for the market to rise sharply and the security could get
called away. The risk of buying long puts is limited to the loss of the premium paid for the
put if the option is not exercised or otherwise sold.
The shares of an ETF commonly represent an interest in a portfolio of securities that
track an underlying benchmark or index. A leveraged ETF generally seeks to deliver
multiples of the daily performance of the index or benchmark that it tracks. An inverse
ETF generally seeks to deliver the opposite of the daily performance of the index or
benchmark that it tracks. Inverse ETFs often are marketed as a way for investors to profit
from, or at least hedge their exposure to, downward-moving markets. Some ETFs are
both inverse and leveraged, meaning that they seek a return that is a multiple of the
inverse performance of the underlying index. To accomplish their objectives, leveraged
and inverse ETFs use a range of investment strategies, including swaps, futures
contracts and other derivative instruments.
ETFs (including leveraged, inverse, and leveraged inverse) trade on an auctionable
market. Therefore, there is more price fluctuation with ETFs than with mutual funds since
ETFs trade throughout the day, whereas mutual funds are priced once a day. Also, since
most ETFs only mirror a market index, such as the S&P 500, they won't outperform the
index. A significant amount of principal could be lost in these securities rapidly and tax
laws could change and affect the tax treatment of this investment.
Traditional ETFs are generally not actively managed. This means that securities in the
27
portfolio will not be purchased or sold in attempt to take advantage of changing market
conditions. A traditional ETF continues to hold securities even though their market value
and dividend yields have changed. An ETF generally carries the same investment risk as
the portfolio of securities within the ETF. Securities in a portfolio can depreciate, and the
ETF does not achieve its intended objective. In addition, each ETF is subject to specific
risks that vary depending on each ETF’s investment objectives and portfolio composition.
Additionally, while premiums and discounts from net asset value (“NAV”) are generally
small among ETFs, there is a risk for severe dislocation from NAV.
Exchange
Traded Funds
(ETFs)
(continued)
The use of leverage in an investment portfolio can magnify any price movements,
resulting in high volatility and significant loss of principal. ETFs do not track the
underlying Index due to imperfect correlation between the ETF’s portfolio securities and
those in the underlying Index, rounding prices, changes to the underlying Index and
regulatory requirements. This risk is heightened during times of increased market
volatility or other unusual market conditions. Tracking error also results because the ETF
incurs fees and expenses while the underlying Index does not.
Non-traditional ETFs, including leveraged and inverse ETFs, are not suitable for most
investors. Non-traditional ETFs are trading vehicles in which daily rebalancing and
market volatility have a significant impact on the realized return. The effects of
mathematical compounding can grow significantly over time, leading to scenarios
whereby performance over the long run can differ significantly from the performance (or
inverse performance) of their underlying index or benchmark during the same period of
time. Leveraged, inverse, and leveraged inverse ETFs are more volatile and riskier than
traditional ETFs due to their exposure to leverage and derivatives, particularly total return
swaps and futures. In addition, these instruments are typically designed to achieve their
desired exposure on a daily (in a few cases, monthly) basis. Holding leveraged, inverse,
and leveraged inverse ETFs for longer periods of time increases their risk due to the
effects of compounding and the inherent difficulty in market timing. Non-traditional ETFs
are volatile and not suitable for all investors. Positions in non-traditional ETFs should be
monitored closely due to their volatile nature and inability to track the underlying index
over an extended period of time. Non-traditional ETFs are not intended to be held long
term. ETFs over a period longer than one day can differ significantly from their stated
performance objectives.
Some ETFs are thinly traded which could impact the ability to sell shares quickly. Non-
traditional ETFs and futures-linked ETFs enter into total return swaps with a counter
party. If the counterparty becomes unable to deliver its share of the contract, it will default
on the swap, therefore negatively affecting the value of the non-traditional ETF.
Alternative
Investments:
Non-traded Real Estate Investment Trusts (REITs), non-traded Business Development
Companies (BDC’s), limited partnerships, and direct alternatives are subject to various
risks such as limitations on liquidity (can take 30 days or more to liquidate), pricing
mechanisms, and specific risk factors associated with the particular product, which for
products associated with real estate, would include but not limited to, property
devaluation based on adverse economic and real estate market conditions. Redemption
can be at more or less than the original amount invested. As a result, they are not
suitable for all investors. A prospectus that discloses all risks, fees and expenses, and
risk factors, will be provided by your Advisor. Please read the prospectus carefully
before investing. Investors considering Alternative Investments should understand that
they are generally considered speculative in nature and involve a high degree of risk,
particularly if concentrated within one industry. These risks are greater and substantially
28
different than those associated with traditional equity or fixed income investments. The
products are risky and for sophisticated investors only who meet qualified investor
requirements. Further, these products are sold on a commission basis through a
broker/dealer. Therefore, IARs will receive commissions and such commissions are
higher than other securities products. This is a conflict of interest. To mitigate this conflict
of interest we are informing you of this information and encourage you to read offering
memorandums.
Variable
Annuities:
For variable annuities held within Total Clarity accounts, your variable annuity contract
has exclusions, limitations, reductions of benefits and terms under which the contract will
be continued in force or be discontinued. Be sure to discuss costs and the complete
details of coverage with your Advisor. Guarantees of the annuity are backed by the
financial strength of the underlying insurance company. Investment sub-account values
will fluctuate with changes in market conditions. As stated above, variable products are
complex products with higher costs. Further, variable products pay higher commissions
than other securities products. This creates a conflict of interest. To mitigate this conflict
of interest we only allow advisory class Variable Annuities to be held in Total Clarity
accounts. These variable annuities do not pay commissions to your Advisory
Representative, but Variable Annuities purchased outside of your Total Clarity agreement
through your Advisory Representative do pay higher commissions than other security
products. This creates a conflict of interest for your IAR to sell you a Variable Annuity that
is not part of your Total Clarity account. To mitigate this conflict of interest we encourage
you to read the offering memorandum for any variable annuity you purchase and are
informing you of this information.
Item 9 Disciplinary Information
There is no reportable disciplinary information required for Total Clarity or its management persons
that is material to your evaluation of Total Clarity, its business or its management persons.
Item 10 Other Financial Industry Activities and Affiliations
10 A& B. Total Clarity does not have a related person who is a: broker/dealer or other similar type of
broker or dealer, investment company or other pooled investment vehicle, other investment adviser,
futures commission merchant or commodity pool operator, banking or thrift institution, insurance
company or agency, pension consultant, or sponsor or syndicator of a limited partnership. We do have
an affiliated person who is a lawyer and one that is a real estate broker. The three principal owners of
Total Clarity also own an advisor services company which recruits, trains, supports and supervises
representatives of LPL Financial. One of the principal owners is also an owner of an accounting and
tax practice, Exemplar Accounting and Tax Advisors, Inc. (EATA). Advisory Representatives refer
clients to EATA, which results in a conflict of interest, whereby an owner benefits from clients utilizing
services of both companies. You are under no obligation to purchase accounting services through
EATA.
Certain Advisory Representatives are Dually Registered with LPL Financial. LPL is independently
owned and operated and is not affiliated with Total Clarity. Please refer to Item 12 for a discussion of
the benefits Total Clarity receives from LPL and the conflicts of interest associated with a receipt of
such benefits.
29
10 C. As previously stated in Item 5E, many of the Advisory Representatives are dually registered as
Advisory Representatives of Total Clarity and as Registered Representatives of LPL Financial. You are
under no obligation to purchase or sell securities through your Advisory Representative. However, if
we develop a financial or retirement plan for you and you choose to implement the plan with our
assistance, commissions on brokerage business will be earned in addition to any fees you paid for the
other advisory services. Commissions sometimes are higher or lower at LPL than at other
broker/dealers. Advisory Representatives will have a conflict of interest in having you purchase
securities and/or insurance related products through LPL in that the higher their production with LPL
the greater potential for obtaining a higher pay-out on commissions earned. Additionally, certain of our
Advisory Representatives are also Advisory Representatives with LPL. This is only allowed under
limited exceptions. Due to these relationships with LPL, LPL Financial will have access to certain
confidential information such as financial information, investment objectives, transactions and holdings,
about Total Clarity's clients, even if the client does not establish an account through LPL. If you would
like a copy of the LPL Financial Privacy Policy, please contact Total Clarity's Home office at 630-762-
9352.
It is important to understand investment advisers have a fiduciary obligation to provide advice and
services through the investment adviser that are in the best interest of the client. However, when
advisory representatives act in the capacity of a registered representative, their obligation is to make
recommendations and conduct transactions that are suitable to you but are not necessarily be in your
best interest.
Under the rules and regulations of the FINRA, LPL has an obligation to perform supervisory functions
regarding certain activities engaged in by Advisory Representatives who are also Registered
Representatives of LPL. For this supervisory function, LPL will receive a portion of the transaction fees
previously mentioned, for trades done in accounts custodied at LPL, however they also receive a
portion of our advisory fees from our clients' accounts that are custodied at Schwab. There is no
affiliation between Total Clarity and LPL or Schwab.
Advisory Representatives are licensed with various insurance companies. This is a conflict of interest
since your Total Clarity adviser will earn commissions if you purchase insurance products through
them. You are under no obligation to purchase insurance products or services through your Advisory
Representative.
Total Clarity attempts to mitigate the conflicts of interest relating to the receipt of commissions by
providing you with these disclosures. As a Registered Representative with LPL, Advisory
Representatives are subject to a supervisory structure at LPL for all securities business.
Some of our Advisory Representatives are lawyers, accountants or real estate agents. If you require
legal, accounting or real estate services, we will recommend that you use the services of our affiliated
persons. Fees for these services are in addition to the fees paid for advisory services. You are under
no obligation and have the right to decide whether or not to engage these individuals for these
services.
10. D. After the completion of an analysis of your existing investments, our Advisory Representative
can recommend the use of third-party portfolio managers through LPL. For accounts utilizing third-
party managers under aggregate, all-in-one account fee structures (including MAS, OMP & MWP fee
structure), Total Clarity has a financial incentive to select one portfolio instead of another portfolio
because the portion of the account fee retained by Total Clarity varies depending on the portfolio
strategist fee associated with a portfolio. The use of a third-party portfolio manager is based upon your
financial needs, investment goals, risk tolerance and investment objectives. There is no affiliation
between Total Clarity, LPL, or the third-party portfolio managers.
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Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics
11. A. Total Clarity has a fiduciary duty to you to act in your best interest and always place your
interests first and foremost. Total Clarity takes seriously its compliance and regulatory obligations and
requires all staff to comply with such rules and regulations as well as our policies and procedures.
Also, we strive to handle your non-public information in such a way to protect information from falling
into the hands of anyone who has no business reason to know such information. We provide you with
our Privacy Policy which details our procedures for handling your personal information whenever there
is a substantial change to the policy. Total Clarity maintains a code of ethics for its Advisory
Representatives, supervised persons and office staff. The Code of Ethics contains provisions for
standards of business conduct in order to comply with federal securities laws, personal securities
reporting requirements, pre-approval procedures for certain transactions, code violations reporting
requirements, and safeguarding of material non-public information about your transactions. Our Code
of Ethics establishes our firm's expectation for business conduct. A copy of our Code of Ethics will be
provided to you upon request.
11 B. Neither Total Clarity nor its associated persons recommends buys or sells for client accounts any
securities in which they have a material financial interest.
11 C. Total Clarity and its associated persons at times, buy or sell securities identical to those
securities recommended to you. Therefore, Total Clarity and/or its associated persons have an interest
or position in certain securities that are also recommended and bought or sold to you. They will not put
their interests before your interest. Neither Total Clarity nor any associated person will trade in such a
way as to obtain a better price for themselves than for you or other clients. If such a trade did occur,
the trade would be corrected so that both the client and the related person received the same price or
the affected account will be credited toward the next advisory fee an amount equal to the difference in
an average share price to the client’s actual share price, multiplied by the number of shares traded in
that account.
11 D. Total Clarity is required to maintain a list of all securities holdings for its associated persons and
develop procedures to supervise the trading activities of associated persons who have knowledge of
your transactions and their related family accounts at least quarterly. Further, associated persons are
prohibited from trading on non-public information or sharing such information. You have the right to
decline any investment recommendation. Total Clarity and its associated persons are required to
conduct their securities and investment advisory business in accordance with all applicable Federal
and State securities regulations.
Item 12 Brokerage Practices
12 A. As previously stated, some Advisory Representatives are Registered Representatives of LPL. As
a result, they are subject to FINRA Conduct Rule 3040 which restricts them from conducting securities
transactions away from LPL unless LPL provides them with written authorization.
You are advised that not all investment advisers require you to maintain accounts at a specific
broker/dealer. You are also advised that you can maintain accounts at another broker/dealer.
However, the services provided by Total Clarity will then be limited to advice only and will not include
implementation. If you select another brokerage firm for custodial and/or brokerage services you will
not be able to receive asset management services from Total Clarity.
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In initially selecting LPL and Schwab, Total Clarity conducted due diligence. Our evaluation and criteria
included LPL's and Schwab's ability to service you, their staying power as a company, their industry
reputation, their ability to report to you and to us, the trading platform used, the products and services
available, and their technology and educational resources.
Periodically, we will review alternative broker/dealers and custodians in the marketplace to ensure LPL
and Schwab are meeting our duty to provide best execution for your accounts. The review will include
a comparison between Schwab and LPL, which involves evaluating criteria such as overall expertise,
cost competitiveness and financial condition. The quality of execution by Schwab and by LPL will be
reviewed through quarterly trade execution evaluations. However, best execution does not simply
mean the lowest transaction cost. Therefore, no single criteria will validate nor invalidate a custodian,
but rather, all criteria taken together will be used in evaluating the currently utilized custodian
and broker/dealer.
Additionally, product sponsors such as variable annuity and investment companies which are
recommended to you from time to time provide support to Total Clarity and our Advisory
Representatives. Such support includes research, educational information, and monetary support for
due diligence trips and client events.
LPL covers costs for certain trainings and conferences, including travel, accommodations, and
conference fees, based on production. You are advised there is an incentive for Total Clarity and your
Advisory Representative to recommend LPL over other Broker/Dealers based on the products and
services that we will receive rather than your best interest.
LPL has a wide range of approved securities products for which they perform due diligence prior to
selection. As LPL Registered Representatives, advisors are required to adhere to these products when
implementing securities transactions through LPL. Commissions charged for these products vary
between Broker/Dealers and therefore could be higher or lower than commissions you would be able
to obtain if transactions were implemented through another Broker/Dealer. LPL also provides our
Advisory Representatives, and therefore Total Clarity, with back-office operational, technology, and
other administrative support. Other services include consulting, publications and conferences on
practice management, information technology, business succession planning, regulatory compliance
and marketing. Such services are intended to help us and our Advisory Representatives manage and
further develop our business enterprise.
Schwab and LPL also make available to Total Clarity other products and services that benefit Total
Clarity but do not directly benefit you. Some of these other products and services assist Total Clarity
with managing and administering your accounts. These include software and other technology that
provide access to your account data (such as trade confirmation and account statements); facilitate
trade execution; provide research, pricing information and other market data; facilitate payment of
Total Clarity's fees from your accounts; and assist with back-office functions, recordkeeping and client
reporting. Many of these services are used to service all of or a substantial number of our accounts.
LPL and Schwab also make available to Total Clarity other services intended to help Total Clarity
manage and further develop its business. These support services and/or products will be provided
without cost, at a discount, and/or a negotiated rate, and include practice management-related
publications, consulting services, attendance at conferences and seminars, meetings, and other
educational and/or social events or marketing support; and other products and services used by Total
Clarity in furtherance of the operation and development of its investment advisory business. Total
Clarity also receives discounts on compliance, marketing, technology, and practice management
products or services provided to the firm through third party vendors. These benefits do not depend on
32
the amount of brokerage transactions directed to Schwab or LPL Financial.
These products and services are provided to Total Clarity as part of its overall relationship with LPL
Financial and Schwab. While as a fiduciary Total Clarity endeavors to act in its clients' best interests,
the receipt of these benefits creates a conflict of interest because Total Clarity's recommendation that
clients custody at one of these custodians is based in part on the benefit Total Clarity receives from
these services and products and not solely on the nature, cost or quality of custody or brokerage
services provided by LPL Financial and Schwab. Total Clarity's receipt of some of these benefits is
based on the amount of advisory assets custodied at each of these platforms.
12 B. With Total Clarity Vision, Vision CB, Value CB, Value and PreActive Accounts, trades at times
will be made using "order blasting", or block trading, an aggregate order of one security for several
accounts at once at the discretion of the IAR. This results in an average price/share for all accounts
included in the trade. Aggregated orders will not reduce the transaction costs to participating clients.
We conduct aggregated transactions (order blasts) in a manner designed to ensure that no
participating client is favored over another client. If the aggregate order is not filled in its entirety, when
possible, securities purchased or sold in an aggregated transaction will be allocated pro-rata to the
participating client accounts in proportion to the size of the orders placed for each account. Under
certain circumstances, the amount of securities will be increased or decreased to avoid holding odd-lot
or a small number of shares for particular clients.
Item 13 Review of Accounts
13A. If you are participating in any of the Asset Management Programs, your accounts will be reviewed
at least quarterly by your Advisory Representative and you will be contacted not less than annually or
as agreed by you and your Advisory Representative for a review meeting. You can request more
frequent reviews and set thresholds for triggering events that would cause a review to take place. You
are advised that you must notify your Advisory Representative promptly of any changes to your
financial goals, objectives or financial situation as such changes would require him to review the
portfolio allocation and make recommendations for changes. Each Advisory Representative is
responsible for ensuring timely reviews and suitable recommendations. The level of experience of
Advisory Representatives will vary. Accounts are also randomly reviewed by the Chief Compliance
Officer or the designee for suitability to your goals, objectives, risk tolerance, and time horizon.
13B. Your Advisory Representative will monitor your accounts for changes or shifts in the economy,
changes to the management and structure of a mutual fund or company in which your assets are
invested, and market shifts and corrections.
13C. You will be provided statements, for both qualified and non-qualified accounts, at least quarterly
directly from LPL or from Schwab, depending on where your account is held. Additionally, you will
receive confirmations of all transactions occurring in both qualified and non-qualified accounts directly
from LPL or from Schwab. If contracted, Total Clarity provides a report each quarter, showing all
holdings within each account, along with performance data for each account beginning either on
01/01/12, or from the date of its inception, if the account was opened after that time. This is due to a
change of reporting systems to Morningstar Office. Total Clarity uses Orion Advisor for reporting as of
02/01/21. Total Clarity does not provide these reports to Vision CB and Value CB accounts.
For 529 accounts held directly at the mutual fund company and variable annuities held at annuity
companies, you will receive custodial statements in accordance with their reporting schedule.
You should compare the report you receive from Total Clarity with statements received directly from
the account custodian. Should there be any discrepancy the account custodian's report will prevail.
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13D. If you are participating solely in Financial Planning Services you will not receive regular reviews.
Total Clarity recommends you have at least an annual review and an update to any plans; however,
the time and frequency of the reviews is solely your decision. Additionally, you will be charged review
fees based on the Financial Planning Agreement you signed. Other than the initial plan or analysis,
there will be no other reports issued unless you have an on-going agreement. For on-going Retainer
services, you will be provided with reviews and updates as specified in your Retainer Program
Agreement.
Item 14 Client Referrals and Other Compensation
14 A. Product vendors recommended by Total Clarity provide monetary and non-monetary assistance
with client events in addition to providing educational tools and resources. We do not select products
as a result of any monetary or non-monetary assistance. The suitability and quality of a product is of
first and foremost importance. Total Clarity's due diligence of a product does not take into
consideration any assistance it receives.
In their role as Registered Representatives of LPL Financial, some of our Advisory Representatives will
earn commissions. The amount of commissions paid by LPL to the Representative will fluctuate based
on overall production. Therefore, the more business placed by them through LPL will enable them to
reach another threshold and earn a higher payout.
LPL Financial provides various benefits and payments to Dually Registered Persons that are new to
the LPL Financial platform to assist the representative with the costs (including foregone revenues
during account transition) associated with transitioning his or her business to the LPL Financial
platform (collectively referred to as "Transition Assistance"). The proceeds of such Transition
Assistance payments are intended to be used for a variety of purposes, including but not necessarily
limited to, providing working capital to assist in funding the Dually Registered Person's business,
satisfying any outstanding debt owed to the Dually Registered Person's prior firm, offsetting account
transfer fees (ACATs) payable to LPL Financial as a result of the Dually Registered Person's clients
transitioning to LPL Financials’ custodial platform, technology set-up fees, marketing and mailing costs,
stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and
termination fees associated with moving accounts.
The amount of the Transition Assistance payments is often significant in relation to the overall revenue
earned or compensation received by the Dually Registered Person at the prior firm. Such payments
are generally based on the size of the Dually Registered Person's business established at the prior firm
and/or assets under custody with LPL Financial. There is a conflict of interest for representatives to
select a broker/dealer based on the amount of transition assistance to be received. Furthermore, LPL
Financial provides the transition assistance in the form of a forgivable note. The transition assistance
dollars are forgiven over a five-year period based on the representative remaining with LPL Financial.
Therefore, there is a conflict of interest for the representative to remain with LPL Financial when it is
not in the best interests for clients because of the forgivable note period having not expired.
LPL Financial also rewards representatives for achieving production thresholds by covering expenses
to various conferences and offering award conferences. This is considered a conflict of interest.
Total Clarity and your Advisory Representative attempt to mitigate any conflicts of interest by
evaluating and recommending that clients use LPL services based on the benefits that each service
provides to their clients, rather than to the Transition Assistance earned by them. We also try to
mitigate the risks by having multiple choices in where to custody your accounts. Lastly to help mitigate
the conflicts of interest, this disclosure has been provided to you.
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If you have any concerns about the appropriateness of your Advisory Representative's
recommendations based on your financial situation, you should discuss these recommendations with
another financial professional.
Other conflicts of interest are disclosed throughout this disclosure document.
14 B. Product vendors recommended by Total Clarity provide monetary and non-monetary assistance
with client events in addition to providing educational tools and resources. Advisory Representatives
do not select products as a result of any monetary or non-monetary assistance. Total Clarity’s due
diligence of a product does not take into consideration any assistance it receives. The suitability and
quality of a product for our clients is of first and foremost importance.
Total Clarity may enter into promoter arrangements pursuant to which it compensates third-party
intermediaries for client referrals that result in the provision of investment advisory services by Total
Clarity. Total Clarity will disclose these promoter arrangements to affected investors, and these
arrangements will comply with the SEC’s Marketing Rule. Solicitors introducing clients to Total Clarity
may receive compensation from Total Clarity, such as a retainer, a flat fee per referral and/or a
percentage of introduced capital or of the advisory fee prior to payment to the Advisory Representative.
The cost of any such fees will be borne entirely by Total Clarity and not by any affected client.
Item 15 Custody
The account custodian will directly debit your account(s) for the payment of our advisory fees. This
ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over
your funds or securities. We do not have physical custody of any of your funds and/or securities. Your
funds and securities will be held with a bank, broker-dealer, or other qualified custodian. You will
receive account statements from the qualified custodian(s) holding your funds and securities at least
quarterly. The account statements from the account custodian will indicate the amount of our advisory
fees deducted from your account(s) each billing period. You should carefully review account
statements for accuracy.
Standing Letter of Authorization
When requested, our firm, or Advisory Representatives, will effect transfers from client accounts to one
or more third parties designated, in writing, by the client without obtaining written client consent for
each separate, individual transaction, as long as the client has provided us with written authorization to
do so. Such written authorization is known as a Standing Letter of Authorization. An adviser with
authority to conduct such third-party transfers has access to the client's assets, and therefore has
custody of the client's assets in any related accounts.
However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by
reason of having custody, as long as the following criteria are met:
1. You provide a written, signed instruction to the qualified custodian that includes the third party’s
name and address or account number at a custodian;
2. You authorize us in writing to direct transfers to the third party either on a specified schedule or
from time to time;
3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a
transfer of funds notice to you promptly after each transfer;
4. You can terminate or change the instruction;
5. We have no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party;
6. We maintain records showing that the third party is not a related party to us nor located at the
35
same address as us; and
7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an
annual notice reconfirming the instruction.
When we engage in third party standing letters of authorization, Total Clarity complies with the
conditions of the safe harbor provisions and is therefore exempt from the annual surprise exam
requirement for Advisers that have custody.
Item 16 Investment Discretion
You will grant Total Clarity authorization to manage your account on a discretionary basis.
Discretionary authority will give Total Clarity the authority to buy, sell, exchange and convert securities
in your managed accounts or to engage, disengage, or reallocate assets to third party managers. You
will grant such authority to Total Clarity by execution of the Vision, Vision CB, Value CB, Value or
PreActive Agreement. You are able to terminate discretionary authorization at any time upon receipt of
written notice by Total Clarity, but this will result in the closing of the account since discretion is
required by our custodians to be able to trade in an account.
Discretionary authority will be limited to Total Clarity having the authority to determine the securities to
be bought or sold for a client's account, the amount of securities to be bought or sold for a client's
account, or the third-party managers to which assets are allocated for management.
Additionally, you are advised that:
1. You are able set parameters with respect to when an account should be rebalanced and set
trading restrictions or limitations;
2. Your written consent is required to establish any mutual fund, variable annuity, or brokerage
accounts;
3. If you elect to implement recommendations through your Advisory Representative, we require
the use of LPL Financial or Schwab as the account custodian.
Item 17 Voting Client Securities
Total Clarity does not vote your securities. Unless you suppress proxies, securities proxies will be sent
directly to you by the account custodian or transfer agent. You can contact your Advisory
Representative about questions you have and opinions on how to vote the proxies. However, the
voting and how you vote the proxies is solely your decision.
Item 18 Financial Information
18 A. Total Clarity does not require you to prepay more than $1,200 more than six months in advance,
so a balance sheet is not required.
18 B. Total Clarity has discretionary authority over client accounts; however, that authority does not
extend to the withdrawal of any client assets, with the exception of deduction of Total Clarity's advisory
fees from your accounts. We are financially stable. There is no financial condition that is likely to impair
our ability to meet our contractual commitment to you or any other client.
18 C. Neither Total Clarity nor any of its Advisory Representatives has ever been the subject of a
bankruptcy petition.
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Item 19 Requirements For State Registered Advisers
This section is not applicable to Total Clarity since Total Clarity is not state registered. Total Clarity is
registered with the Securities and Exchange Commission.
Item 20 Additional Information
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position
it should have been in had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account and/or
applying a credit toward advisory fees.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you
are eligible to participate in class action settlements or litigation nor do we initiate or participate in
litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or
negligence by issuers of securities held by you.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets
from your employer's retirement plan and roll the assets over to an individual retirement account
("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you an asset based fee as set forth in the agreement you executed with
our firm. This practice presents a conflict of interest because persons providing investment advice on
our behalf have an incentive to recommend a rollover to you for the purpose of generating fee based
compensation rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options
are available, you should consider the costs and benefits of:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer’s retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage here are a few
points to consider before you do so:
1. Determine whether the investment options in your employer's retirement plan address your
needs or whether you might want to consider other types of investments.
I.
II.
Employer retirement plans generally have a more limited investment menu than IRAs.
Employer retirement plans may have unique investment options not available to the
public such as employer securities, or previously closed funds.
2. Your current plan may have lower fees than our fees.
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I.
II.
If you are interested in investing only in mutual funds, you should understand the cost
structure of the share classes available in your employer's retirement plan and how the
costs of those share classes compare with those available in an IRA.
You should understand the various products and services you might take advantage of
at an IRA provider and the potential costs of those products and services.
3. Our strategy may have higher risk than the option(s) provided to you in your plan.
4. Your current plan may also offer financial advice.
5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your
required minimum distribution beyond age 72.
6. Your 401k may offer more liability protection than a rollover IRA; each state may
vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA
assets have been generally protected from creditors in bankruptcies. However, there can be
some exceptions to the general rules so you should consult with an attorney if you are
concerned about protecting your retirement plan assets from creditors.
7. You may be able to take out a loan on your 401k, but not from an IRA.
8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they qualify for an exception
such as disability, higher education expenses or the purchase of a home.
9. If you own company stock in your plan, you may be able to liquidate those shares at a lower
capital gains tax rate.
10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand the differences between these types of accounts and to decide
whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment
adviser representative, or call our main number as listed on the cover page of this brochure.
Should you have any questions regarding our Form ADV or any other document you have received
from Total Clarity, please speak with your Advisory Representative.
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Primary Brochure: PREACTIVE WRAP BROCHURE MARCH 2026 (2026-03-16)
View Document Text
525 Tyler Rd. Suite T
St. Charles, IL. 60174
Phone: 630-762-9352
Fax: 630-587-9170
www.totalclaritywealth.com
SEC Registration # 801-67755
Total Clarity PreActive Account BROCHURE
March 17, 2026
This brochure provides clients with information about the qualifications and business practices of Total Clarity Wealth
Management, Inc. and the Total Clarity PreActive Account that should be considered before becoming a client. If you have any
questions about the contents of this Brochure, please contact us at (630) 762-9352 and/or info@totalclaritywealth.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 Total Clarity Wealth Management, Inc. is also available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Total Clarity Wealth Management, Inc. is 142728.
Any reference to Total Clarity Wealth Management, Inc. as a registered investment adviser or its related persons as registered
Advisory Representatives does not imply a certain level of skill or training.
ITEM 2: MATERIAL CHANGES
This section will discuss only specific material changes that are made to the Brochure and provide you with a
summary of such changes. Additionally, reference to the date of the last update to this Brochure will be
provided.
Since our last update dated June 27, 2025 we made the following material changes:
No material changes were made.
A copy of our updated brochure and brochure supplements may be requested by contacting us at (630) 762-9352
and/or info@totalclaritywealth.com. These documents are available to you free of charge and are also available
on our website at www.totalclaritywealth.com or on PreActive’s website www.preactiveinvestments.com.
Additional information about Total Clarity Wealth Management, Inc. is also available via the SEC’s website
www.adviserinfo.sec.gov. Our IARD number is 142728. The SEC’s website also provides information about any
persons affiliated with Total Clarity Wealth Management, Inc. who are registered, or are required to be registered,
as Advisory Representatives of Total Clarity Wealth Management, Inc.
Page 2 of 17
Table of Contents
ITEM 1: COVER PAGE .............................................................................................................1
ITEM 2: MATERIAL CHANGES .............................................................................................2
ITEM 3: TABLE OF CONTENTS ............................................................................................3
ITEM 4: SERVICES, FEES & COMPENSATION .................................................................4
ITEM 5 : ACCOUNT REQUIREMENTS & TYPES OF CLIENTS ....................................10
ITEM 6: PERFORMANCE BASED FEES .............................................................................11
ITEM 7: TYPES OF CLIENTS………………………………………………………………11
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGY & RISK OF LOSS………11
ITEM 9: ADDITIONAL INFORMATION ..............................................................................14
ITEM 10: REQUIREMENTS FOR STATE-REGISTERED ADVISORS ............................17
Page 3 of 17
INTRODUCTION
Total Clarity Wealth Management, Inc. (Total Clarity) is an investment adviser registered with the Securities
and Exchange Commission. Total Clarity Wealth Management offers advice regarding mutual funds and stocks
as well as other products such as: bonds, options, government securities, certificates of deposit, Unit Investment
Trusts (UITs), Exchange Traded Funds (ETFs) and 529 College Savings Plans. Total Clarity Wealth
Management utilizes the clearing and custody services of Schwab Institutional, a division of Charles Schwab &
Co., Inc. ("Schwab") an unaffiliated SEC registered Broker/Dealer and FINRA member for PreActive
Accounts.
ITEM 4 - SERVICES, FEES & COMPENSATION
In its capacity as a registered investment adviser, Total Clarity Wealth Management offers various advisory
services as further disclosed in its ADV Part 2A Brochure. The programs offered include a fee-based program
entitled the “Total Clarity PreActive Account”. The PreActive Account is not a wrap fee program since each
transaction charge is billed directly to the client’s account.
Advisory Services
Total Clarity Wealth Management PreActive Accounts offer clients a fee-based account for which the client will
pay a quarterly fee for portfolio review and on-going asset management services. Clients will maintain an account
that contains any of the following: stocks, bonds, options, government securities, Exchange Traded Funds (ETFs),
Unit Investment Trusts (UITs), and/or certain types and classes of mutual funds, cash, and cash equivalents.
PreActive Accounts at times will utilize leverage meaning the account will use borrowed capital (for an
investment), expecting the profits made to be greater than the interest payable, through the use of Exchange
Traded Funds (ETFs) that short equities or through shorting specific equities. Selling securities short, means to
borrow securities and then sell them with the anticipation that the price will go lower than the price at which they
were sold. This strategy is often utilized to hedge investments but runs the risk of losing an amount greater than
the initial margin requirements in a relatively short period of time.
The Total Clarity Wealth Management PreActive Account program offers clients portfolio review and asset
management services on a discretionary basis only. Discretionary asset management services allow the Advisory
Representative to make buys, sells and exchanges within the account as the Advisory Representative deems
appropriate, without obtaining the client’s prior consent to the transaction(s). Discretion approval is given when
the client signs the PreActive Account Agreement and initials Section 2 of this agreement. The Advisory
Representative will determine the securities to be purchased and sold in the account and will alter the securities
holdings from time to time without prior consultation with the client. Unless otherwise expressly requested by
the client, Total Clarity will manage the account and will make changes to the allocation as deemed appropriate
by the firm and the Advisory Representative. The client is able to discuss with the Advisory Representative their
desire to discuss any recommendations before buying or selling any securities in their account, but in order to
trade at our custodian, the Advisory Representative must be given discretion on all accounts. All clients will be
sent, by the custodian of their account, either by mail or electronically, confirmations of any trades done in their
account. If a client decides they no longer want discretion granted, it will result in the closing of the account.
Depending on the client's specific goals, objectives and market circumstances, we will generally hold positions
in an account for a long term, even more than a year, or, depending on market conditions, we will actively trade
some securities held in an account for periods of 30 days or less. Advisory Representatives will be reasonably
available to the client to provide advice, make recommendations and execute transactions. Since our investment
strategies and advice are based on each client’s specific financial situation, the investment advice we provide to
you may be different or conflicting with the advice we give to other clients regarding the same security or
investment.
Page 4 of 17
Advisory Representatives will gather information on the client’s financial history, goals, objectives and financial
concerns and assist the client in determining if a PreActive Account is suitable for them. Clients must have an
annual income of $200,000 annually over the last 2 years or an adjusted Net Worth (excluding primary residence)
of $1,100,000 or more to be able to open a PreActive Account with Total Clarity. Clients must also select a
Moderately Aggressive or Significant Risk Tolerance on the Total Clarity Risk Tolerance Questionnaire or on
the Total Clarity Suitability Questionnaire. The client will establish an account with Schwab and then the
Advisory Representative will modify the portfolio of the account to match the current PreActive Strategy.
Advisory Representatives will contact clients at least annually, or at the client’s request, to discuss the Total
Clarity Wealth Management PreActive Account investment portfolio and to update the client’s financial
information when any changes have occurred. Clients can request more frequent reviews and set thresholds for
triggering events that would cause a review to take place. Generally, Advisory Representatives will make changes
to clients’ portfolios based on many factors including shifts in the economy, changes in the management of a fund
or company in which clients’ assets are invested, and market shifts and/or corrections.
You are able to request that your Advisory Representative add reasonable trading restrictions (“Reasonable
Restrictions”) to your advisory account at any time during the management of your account. Your Advisory
Representative or Total Clarity has the option to decline or terminate the account if we feel your elected
Reasonable Restrictions are too prohibitive, and we do not feel the account can be managed within our program.
Restrictions imposed on management of an account, even those considered reasonable, will affect your account
performance and may mean the performance in the account is different than the performance of other similarly
managed accounts.
The strategies employed by the manager of PreActive Accounts requires a special skill set and experience,
therefore if the manager is not able to actively manage the accounts for an indefinite amount of time, all leveraged
positions will be settled to reduce the risk to all PreActive Accounts.
Generally, the Advisory Representative who solicited the client will conduct the annual review. Clients are
advised they should notify their Advisory Representative promptly of any changes to their goals, objectives or
financial situation. Failure of the client to notify the Advisory Representative of any such changes could result
in investment recommendations that do not match the client’s needs.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance
Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction
Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to
you. When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or
the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make
money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your
best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
Meet a professional standard of care when making investment recommendations (give prudent advice);
Never put our financial interests ahead of yours when making recommendations (give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best interest;
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
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We benefit financially from the rollover of your assets from a retirement account to an account that we manage
or provide investment advice, because the assets increase our assets under management and, in turn, our advisory
fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets from your
employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will
manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge
you an asset based fee as set forth in the agreement you executed with our firm. This practice presents a conflict
of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover
to you for the purpose of generating fee based compensation rather than solely based on your needs. You are
under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the
rollover, you are under no obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also, current
employees can sometimes move assets out of their company plan before they retire or change jobs. In determining
whether to complete the rollover to an IRA, and to the extent the following options are available, you should
consider the costs and benefits of:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer’s retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage you to speak
with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to
consider before you do so:
1. Determine whether the investment options in your employer's retirement plan address your needs or
whether you might want to consider other types of investments.
1. Employer retirement plans generally have a more limited investment menu than IRAs.
2. Employer retirement plans may have unique investment options not available to the public such
as employer securities, or previously closed funds.
2. Your current plan may have lower fees than our fees.
1. If you are interested in investing only in mutual funds, you should understand the cost structure
of the share classes available in your employer's retirement plan and how the costs of those share
classes compare with those available in an IRA.
2. You should understand the various products and services you might take advantage of at an IRA
provider and the potential costs of those products and services.
3. Our strategy may have higher risk than the option(s) provided to you in your plan.
4. Your current plan may also offer financial advice.
5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required
minimum distribution beyond age 72.
6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. Generally,
federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally
protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so
you should consult with an attorney if you are concerned about protecting your retirement plan assets
from creditors.
7. You may be able to take out a loan on your 401k, but not from an IRA.
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8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may
also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability,
higher education expenses or the purchase of a home.
9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital
gains tax rate.
10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand the differences between these types of accounts and to decide whether a
rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative,
or call our main number as listed on the cover page of this brochure.
Advisory Fees
Opening an Account (initial fees): The initial pro-rated fee is charged in arrears and is based on the average daily
balance of the account over the previous quarter. Initial advisory fees will be collected directly from the account,
provided the client has given Total Clarity Wealth Management written authorization to do so.
An Established Account (ongoing fees): Ongoing fees will be charged quarterly, in arrears, based on the average
daily value of the account over the previous quarter. Fees are charged to and collected directly from the advisory
account early in the quarter. Clients will be provided with a fee invoice that identifies:
1. The average daily value of the account on the last day of the previous quarter (from which the advisory fee
is calculated)
2. The quarterly advisory fee to be charged to the account(s)
3. The account(s) from which the fee will be deducted
Account values in the Orion reporting system will be used for Total Clarity's quarterly fee calculations for
advisory accounts. Although account holdings and asset valuations should generally match, month-end market
values reflected in Orion's reporting system sometimes differ from those provided by the custodian on their
month-end statements. The average daily balance used for billing calculations will not match the custodian value
which is the value on the last day of the quarter. The actual account value though should match except for these
these most common reasons. The three most common reasons why these values may differ are (i) differences in
the manner in which accrued interest is calculated, (ii) differences in the date upon which “as of” dividends and
capital gains are reported, and (iii) differences in whether settlement date valuations or trade date valuations are
used. If you have any questions or believe there are material discrepancies between your custodial statement and
Orion's reporting system, please contact Total Clarity at (630) 762-9352. You may request a copy of
the Orion report valuations from your Total Clarity Advisory Representative.
If your account has securities that are excluded from billing (“Excluded Securities”), the market value for the
Excluded Securities is not included in the average daily balance calculations.
At the discretion of the Advisory Representative, all accounts from one household are added together to obtain a
higher total of account values for fee calculations. In this way, your annual asset management fee will then be
lower if a breakpoint is reached, since it is based on an aggregate value of all accounts within your household,
than if the fee for each account was calculated independently of the other accounts. This practice varies by
Advisory Representative, so you could pay more or less for management services depending on the Advisory
Representative with whom you work.
If the account does not contain sufficient funds to pay the quarterly advisory fee, Total Clarity Wealth
Management has limited authority to sell or redeem securities within the advisory account in a sufficient amount
to pay the fee. The client may reimburse the account for advisory fees paid to Total Clarity Wealth Management,
with the exception of a qualified retirement account.
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Clients can make additions to or withdrawals from the account, provided the account continues to meet minimum
account size requirements of $100,000.
Fees are based solely on account average balances and are not based on a share of capital gains upon or capital
appreciation of the funds or any portion of the funds. Fees are in accordance with the following blended fee
schedule:
TOTAL CLARITY PREACTIVE STANDARD FEE SCHEDULE
Minimum Initial Investment: $100,000
Account Value
$0 to $500,000
Next $500,001 to $1,000,000
Next $1,000,001 to $3,000,000
Next $3,000,001 to $5,000,000
Next $5,000,001 and above
Maximum Annual
Fee
2.50%
2.50%
2.50%
2.50%
2.50%
Your Advisory Representative will negotiate your specific fee with you, based on the maximum fee schedule
outlined above. We make exceptions to our general fee schedules under certain circumstances (e.g.,
responsibilities involved, accounts or groups of accounts which are expected to have significant capital additions
in the future, anticipated future earning capacity, related accounts, pre-existing client, account retention, etc.). In
such cases, lower fees, stepped fees or different payment arrangements can be negotiated with each client
separately and will be described in your PreActive Account Agreement. Fees vary from client-to-client and are
detailed on the Total Clarity PreActive Agreement you will sign; however, fees will not exceed the schedule
shown above. Therefore, your Advisory Representative will charge more or less than another Advisory
Representative. Further, the PreActive Accounts have an active trading strategy that can result in the total fee
(advisory fee plus transaction fees) for these accounts being high and could be excessive compared to industry
standards.
The fee schedules can be tiered schedules or a flat annual fee. The flat annual fee option charges an annual cost
for management of your account(s) with 25% billed each quarter. For a tiered schedule, more than one fee rate
will apply to the account fees calculation and if a fee schedule is agreed upon that reduces the fee, the larger the
account value. Total Clarity retains a portion of the advisory fees equal to 0.05% of the account value at the end
of each quarter to cover administrative costs. The amount is based on the Advisory Representative’s assets in
Total Clarity accounts. This may encourage some Advisory Representatives to open advisory accounts for clients
to earn a reduction in the fees they pay us, but Total Clarity does not believe this is a material issue. All advisory
accounts are reviewed to be sure the account is in the best interest of the client, and we feel this overrides the
possibility of opening an advisory account that is not suitable for the client. The remainder of the fee is paid to
your Advisory Representative. Total Clarity is able to change the above fee schedules upon 30-days prior written
notice to you.
Asset-Based fees are determined based on the average daily balance of the account over the entire previous
calendar quarter and are payable on or about the fifteenth (15th) day after the beginning of each quarter.
If negotiated, Total Clarity will charge a flat fee, not to exceed the rate % noted above, billed in arrears for
PreActive accounts. Total Clarity will pro-rate a flat fee for the first quarter based on (the number of days the
account is open) / (the total number of days in the quarter) multiplied by the fee.
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Costs Associated with a Total Clarity Wealth Management PreActive Account
The Total Clarity Wealth Management PreActive Account program will cost the client more or less than if the
client purchased services separately. Costs that will affect the services if obtained separately or that the client can
control if services are purchased separately include trading costs and the asset management fee. Additionally,
clients are advised that an advisory account, as compared with a traditional commission based account, will be
more costly to the client, particularly during periods when trading activity is less. Consequently, clients will find
that maintaining the advisory account at times will result in a higher annual cost. During periods when trading
activity is heavier, such as when the account is first opened and during periods of increased market movements,
advisory accounts can result in lower annual costs.
Additional Fees & Transaction Charges
In addition to the advisory fee, you will also pay fees for any custodial services, account maintenance fees, taxes,
and other fees associated with maintaining the account. Total Clarity and its Advisory Representatives do not
control or share in any portion of such fees.
Furthermore, the client will pay additional fees to the Exchange Traded Fund (ETF) companies from which any
were purchased. Such fees are compensation to the fund manager and are not shared with Total Clarity Wealth
Management. Total Clarity offers a wide range of Exchange Traded Funds.
Total Clarity offers a wide range of mutual funds at Schwab. At our custodian, Institutional or Advisory share
classes (share classes that do not pay 12b-1 fees) of mutual funds are typically charged a higher transaction fee
for buys and sells of these products. However, these funds have lower expenses and therefore should result in
being a lower cost to the customer, but this varies for each fund. Schwab charge no transaction fees for ETFs and
exchange traded equities and a standard, non-discounted fee for OTC equities.
Custodians may charge brokerage commissions, transaction fees, and other related costs on the purchases or sales
of mutual funds, equities, bonds, options, margin interest, and exchange-traded funds. Mutual funds, money
market funds, and exchange-traded funds may also charge internal management fees, which are disclosed in the
fund’s prospectus.
Some custodians also charge a foreign Transaction Tax on certain foreign equity security purchases. This tax is
levied by the foreign government and is used to offset the tax incurred by the custodian as a result of executing
the transaction on your behalf. At account opening, you will receive notification from your custodian about
miscellaneous fees and charges they impose for certain transactions (such as wire or overnight fees). You should
keep this documentation for your records.
Termination of a Total Clarity PreActive Account
In the event an account is closed, the advisory fee will be calculated based on the average daily value of the
account from the beginning of the previous quarter until the termination date (or the date the assets were
transferred out of the account or the date Total Clarity is notified that the account will be closing). Flat fees will
be pro-rated based on the number of days the account was open for the quarter. Final fees will be debited from
the account from which the management fees were pulled or an invoice will be mailed to the client’s address of
record.
The Total Clarity Wealth Management PreActive Account Agreement will be terminated by either party upon
receipt of a written or verbal notice of termination. Termination by a Client is effective upon receipt of the notice
by Total Clarity unless a specific date is requested in the notice. A Client may terminate the agreement without
penalty within 5 days of signing the account agreement. If you terminate an account(s) within the first calendar
year after opening the account(s), you will be charged a $200 administrative fee which will be added to any final
advisory fees. This fee can be waived at Total Clarity’s sole discretion. This fee is not charged on accounts that
are closed due to a transfer of the assets to another Total Clarity account for the same account owner. This fee
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will be paid in the same manner as the Asset-Based Fee or an invoice will be sent to the client if the assets are no
longer in the account. If an account is terminated, a final invoice will be sent to the client indicating fees due for
the past quarter. These fees will be based on the average daily balance of the account while it was opened or if a
flat fee is charged, a pro-rated amount based on the number of days the account was opened for the quarter.
Upon termination, early redemption fees or similar fees for mutual funds or other products held in the account
will be applicable as described in the fund’s prospectus. Some other broker-dealers will not accept certain assets
that are held in your account. Total Clarity will use reasonable efforts to follow your instructions regarding the
disposition of the assets in your account to the extent permitted by law and policies of the firm. Please Note: Total
Clarity will discontinue billing after the date specified in the termination notice even if the assets are still in the
account, but Total Clarity and our Advisory Representatives have no fiduciary responsibilities for the account,
once the Total Clarity Agreement has been terminated.
Conflicts of Interest
Advisory Representatives recommending clients participate in the Total Clarity Wealth Management PreActive
Account program will receive compensation as a result of a client’s participation in the program. The amount of
compensation paid to Total Clarity Wealth Management and the Advisory Representative will be more than what
Total Clarity and the Advisory Representative would have received if the client participated in other programs
available through another broker/dealer or paid separately for investment advice, brokerage and other services.
Clients are advised that Advisory Representatives have a financial incentive to recommend advisory account
programs (i.e., Total Clarity Wealth Management PreActive Accounts) over other programs or services.
Total Clarity and Advisory Representatives buy or sell securities for themselves that are also recommended and
bought or sold for Clients. Total Clarity Wealth Management, its officers, directors, employees and Advisory
Representatives should not trade in such a way as to obtain a better price for themselves than for clients.
To mitigate these conflicts of interest, this disclosure has been provided to you. If you have any concerns about
the appropriateness of your Advisory Representative’s recommendations based on your financial situation, you
should discuss these recommendations with another financial professional
ITEM 5: ACCOUNT REQUIREMENTS & TYPES OF CLIENTS
Minimum Account Size
Total Clarity requires a minimum amount of assets to be held in an account for the purpose of obtaining asset
management services. A minimum deposit of $100,000 (cash or securities) to a brokerage account at Schwab is
necessary in order to participate in investment advisory services through a PreActive Account.
However, under certain circumstances, Total Clarity waives the minimum investment size requirement and accept
clients with less than $100,000. Such circumstances include but are not limited to, situations in which additional
assets will soon be deposited; or when the client has other accounts with Total Clarity since the consolidation of
these accounts for the purposes of quarterly fee calculations would bring the value of the accounts closer to a fee
schedule breakpoint.
Total Clarity Wealth Management does not represent, warrantee or imply that the services or methods of analyses
used by Total Clarity can or will predict future results, successfully identify market tops or bottoms, or insulate
clients from losses due to major market corrections or crashes. No guarantees can be offered that a client’s goals
or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services offered
by Total Clarity Wealth Management will provide a better return than other investment strategies.
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Clients
Total Clarity generally offers the Total Clarity Wealth Management PreActive Accounts to individuals and high
net worth individuals (i.e. a net worth of $1,100,000 or more), trusts, corporations or other business entities.
Clients must have an annual income of $200,000 annually over the last 2 years or an adjusted Net Worth
(excluding primary residence) of $1,100,000 or more to be able to open a PreActive Account with Total Clarity.
Clients must also select a Moderately Aggressive or Significant Risk Tolerance on the Total Clarity Risk
Tolerance Questionnaire.
ITEM 6: PERFORMANCE-BASED FEES
This section is not applicable to Total Clarity since Total Clarity does not charge performance-based fees.
ITEM 7: TYPES OF CLIENTS
Total Clarity’s services are geared toward individuals and high net worth individuals (i.e. a net worth of
$1,100,000 or more), trusts, corporations or other business entities.
The minimum investment required in the Total Clarity Asset Management Program is generally $100,000 for
investment advisory accounts. Accounts below these minimums at times will be accepted on an individual basis
at our discretion. Such circumstances include, but are not limited to either additional assets will soon be deposited
or the client has other accounts with Total Clarity. You should be aware that in smaller accounts, performance
will suffer due to difficulties with diversification of assets and risk controls potentially being compromised.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
A. Total Clarity’s Advisory Representatives act as portfolio managers for their advisory clients. In that role, they
use various investment strategies to reach the Clients’ goals and manage investment risk by conducting economic
analyses and attempting to identify relevant market trends. Additionally, IARs conduct fundamental analyses,
which generally involves assessing a company’s or security’s value based on factors such as sales, assets, cash
flow, market position, expected growth, management, products and services, earnings, and financial structure.
The Advisory Representative of PreActive Accounts uses a proprietary algorithm that evaluates many of these
items as well as others to assist the Advisor is making security and transaction decisions. This is one of tools that
the PreActive Advisory Representative uses to manage clients’ accounts. Some IARs use software and investment
analyzing tools that include projections of returns based on historical information and speculate future tax,
educational expense, social security, etc. conditions, payments, and costs. These systems are a guideline only and
cannot be relied upon to provide complete accuracy or assurances.
Investment strategies are also used by IARs to improve the performance and balance the risk of an account. Asset
allocation is one of the strategies all Advisors use to attempt to optimize the risk and reward of your portfolio by
investing among several asset classes. However, it cannot prevent or insulate a portfolio from market fluctuations
or risk.
While not a standard analysis method used by our Advisors, some Advisors offer services that attempt to time
security performance. This essentially means they try to purchase or sell immediately preceding an increase or
decrease in a security’s price. This type of investing can substantially increase the amount of your brokerage
transaction costs due to a higher trading frequency. Also, many mutual funds prohibit excessive trading within
their fund in a short period of time. Total Clarity monitors client accounts for excessive trading as well as to
ensure investments are appropriate for each client but the PreActive Strategy is an active trading strategy and
therefore is expected to have a higher than typical amount of trading.
B. It is important to understand that investing in securities involves risk of loss, including the potential loss of the
principal money you are investing. Therefore, your participation in any of the management programs offered by
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Total Clarity requires you to be prepared to bear the risk of loss as well as the fluctuating performance of your
accounts. The market values of investments are subject to fluctuations based on market conditions.
We do not represent, warrantee or imply that the services or methods of analysis we use can or will predict future
results, successfully identify market tops or bottoms or insulate you from losses due to major market corrections
or crashes. Past performance is no indication of future performance. No guarantees can be offered that your
goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services
offered by Total Clarity or our Advisory Representatives will provide a better return than other investment
strategies.
The table below describes some of the risks associated with most types of investing, followed by section C, some
investment products that are used in our advisory programs and have risks unique to that particular investment:
Management Risk
The services we offer involve your Advisor developing and implementing an investment strategy
for you. A profitable investment strategy inherently involves making decisions about the future
behavior of the securities markets as a whole as well as markets for individual securities. Because
there is no available method to accurately predict future market behavior, there is no guarantee
that any specific investment strategy will be successful.
Market Risk
This is the risk that the value of any security may go up or down at any time due to factors affecting
securities markets in general or particular industries.
Interest Rate Risk
This risk affects fixed income securities which can decline in value because of an increase in
interest rates; a bond or fund with a longer duration will be more sensitive to rate fluctuations.
Credit Risk
This is the risk that an investor could lose money if the issuer of a fixed income security is unable
or unwilling to meet its financial obligations.
Concentrated
Investment Strategy
Risk
Certain investment strategies are concentrated in a specific sector or industry. Portfolios using this
strategy are more likely to sharply increase or decrease in value with changes in the market.
Concentrated strategies are more volatile because the risk associated with each company or sector
represents a large percentage of your overall portfolio value.
Risk with Shorting
Securities and Use
of Leverage
The use of leverage in an investment portfolio can magnify any price movements, resulting in
high volatility and significant loss of principal. Leverage means the account will use borrowed
capital (for an investment), expecting the profits made to be greater than the interest payable.
Selling securities short, means to borrow securities and then sell them with the anticipation that
the price will go lower than the price at which they were sold runs the risk of losing an amount
greater that the initial margin requirements in a relatively short period of time.
C. The following are types of investments and related risks that Total Clarity Advisors use in client portfolios:
The risks with mutual funds include the costs and expenses within the fund that can impact
performance, change of fund managers and/or the fund straying from its stated investment
objective. Open ended mutual funds do not typically have a liquidity issue and the price does not
Mutual Funds:
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fluctuate throughout the trading day. Interval funds are used in Total Clarity accounts but not
PreActive Accounts.
Equity Securities
In general, prices of equity securities are more volatile than fixed income securities, and respond to
a number of factors that can affect entire financial markets or industries.
Options:
Certain types of option trading are permitted in order to generate income or hedge a security;
namely, the selling (writing) of covered call options or the purchasing of put options on a security.
The use of options involves additional risks. The risks of covered call writing include the potential
for the market to rise sharply and the security could get called away. The risk of buying long puts
is limited to the loss of the premium paid for the put if the option is not exercised or otherwise
sold.
The shares of an ETF commonly represent an interest in a portfolio of securities that track an
underlying benchmark or index. A leveraged ETF generally seeks to deliver multiples of the daily
performance of the index or benchmark that it tracks. An inverse ETF generally seeks to deliver
the opposite of the daily performance of the index or benchmark that it tracks. Inverse ETFs often
are marketed as a way for investors to profit from, or at least hedge their exposure to, downward-
moving markets. Some ETFs are both inverse and leveraged, meaning that they seek a return that
is a multiple of the inverse performance of the underlying index. To accomplish their objectives,
leveraged and inverse ETFs use a range of investment strategies, including swaps, futures contracts
and other derivative instruments.
leveraged,
inverse, and
leveraged
inverse)
ETFs (including
trade on an auctionable
market. Therefore, there is more price fluctuation with ETFs than with mutual funds since ETFs
trade throughout the day, whereas mutual funds are priced once a day. Also, since most ETFs only
mirror a market index, such as the S&P 500, they won't outperform the index. A significant amount
of principal could be lost in these securities rapidly and tax laws could change and affect the tax
treatment of this investment.
Exchange-Traded
Funds (ETFs)
Traditional ETFs are generally not actively managed. This means that securities in the portfolio
will not be purchased or sold in attempt to take advantage of changing market conditions. A
traditional ETF continues to hold securities even though their market value and dividend yields
have changed. An ETF generally carries the same investment risk as the portfolio of securities
within the ETF. Securities in a portfolio can depreciate, and the ETF does not achieve its intended
objective. In addition, each ETF is subject to specific risks that vary depending on each ETF’s
investment objectives and portfolio composition. Additionally, while premiums and discounts
from net asset value (“NAV”) are generally small among ETFs, there is a risk for severe dislocation
from NAV.
The use of leverage in an investment portfolio can magnify any price movements, resulting in high
volatility and significant loss of principal. ETFs do not track the underlying Index due to imperfect
correlation between the ETF’s portfolio securities and those in the underlying Index, rounding
prices, changes to the underlying Index and regulatory requirements. This risk is heightened during
times of increased market volatility or other unusual market conditions. Tracking error also results
because the ETF incurs fees and expenses while the underlying Index does not.
Non-traditional ETFs, including leveraged and inverse ETFs, are not suitable for most investors.
Non-traditional ETFs are trading vehicles in which daily rebalancing and market volatility have a
significant impact on the realized return. The effects of mathematical compounding can grow
significantly over time, leading to scenarios whereby performance over the long run can differ
significantly from the performance (or inverse performance) of their underlying index or
benchmark during the same period of time. Leveraged, inverse, and leveraged inverse ETFs are
more volatile and riskier than traditional ETFs due to their exposure to leverage and derivatives,
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particularly total return swaps and futures. In addition, these instruments are typically designed to
achieve their desired exposure on a daily (in a few cases, monthly) basis. Holding leveraged,
inverse, and leveraged inverse ETFs for longer periods of time increases their risk due to the effects
of compounding and the inherent difficulty in market timing. Non-traditional ETFs are volatile
and not suitable for all investors. Positions in non-traditional ETFs should be monitored closely
due to their volatile nature and inability to track the underlying index over an extended period of
time. Non-traditional ETFs are not intended to be held long term. ETFs over a period longer than
one day can differ significantly from their stated performance objectives.
Exchange-Traded
Funds (ETFs)
(continued)
Some ETFs are thinly traded which could impact the ability to sell shares quickly. Non-traditional
ETFs and futures-linked ETFs enter into total return swaps with a counter party. If the counterparty
becomes unable to deliver its share of the contract, it will default on the swap, therefore negatively
affecting the value of the non-traditional ETFs.
Some ETFs may include digital assets. The investment characteristics of Digital Assets generally
differ from those of traditional securities, currencies, commodities. Digital Assets are not backed
by a central bank or a national, 21 international organization, any hard assets, human capital, or
other form of credit and are relatively new to the marketplace. Digital Assets are market based: a
Digital Asset's value is determined by (and fluctuates often, according to) supply and demand
factors, its adoption in the traditional commerce channels, and/or the value that various market
participants place on it through their mutual agreement or transactions. The lack of history to these
types of investments entail certain unknown risks, are very speculative and are not appropriate for
all investors.
Structured
Products:
Used less frequently, 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. Depending
upon the underlying asset or product, there can be different
risks associated with the product. An investor in a structured product never has a claim on the
underlying investment. At times there is little or no secondary market. Tax treatment is different
than other investments. Structured CDs that are insured by the FDIC are subject to applicable FDIC
limits.
ITEM 9: ADDITIONAL INFORMATION
Disciplinary Information & other Financial Industry Activities & Affiliations
There is no reportable disciplinary information required for Total Clarity or its management persons that is
material to your evaluation of Total Clarity, its business or its management persons.
Total Clarity does not have a related person who is a: broker/dealer or other similar type of broker or dealer;
investment company or other pooled investment vehicle, other investment adviser, futures commission merchant
or commodity pool operator; banking or thrift institution; insurance company or agency; pension consultant; real
estate broker or dealer; or sponsor or syndicator of a limited partnership. We do have multiple affiliated persons
who are a lawyer/attorney. You are under no obligation to use these services. The three principal owners of Total
Clarity also own an advisor services company which recruits, trains, supports and supervises representatives of
LPL Financial. One of the principal owners is also an owner of an accounting and tax practice, Exemplar
Accounting and Tax Advisors, Inc. (EATA). Advisory Representatives refer clients to EATA, which results in a
conflict of interest, whereby an owner benefits from clients utilizing services of both companies. You are under
no obligation to purchase accounting services through EATA.
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Certain Advisory Representatives are Dually Registered with LPL Financial. LPL is independently owned and
operated and is not affiliated with Total Clarity. Your Advisory Representative for PreActive Accounts is not
registered with LPL and as such, receives no compensation from LPL.
Some Total Clarity Advisory Representatives are licensed with various insurance companies. This is a conflict of
interest since your Total Clarity adviser will earn commissions if you purchase insurance products through them.
You are under no obligation to purchase insurance products or services through your Advisory Representative.
Total Clarity attempts to mitigate the conflicts of interest relating to the potential receipt of commissions by
providing you with these disclosures.
Code of Ethics
Total Clarity has a fiduciary duty to you to act in your best interest and always place your interests first and
foremost. Total Clarity takes its compliance and regulatory obligations seriously and requires all staff to comply
with such rules and regulations as well as our policies and procedures. We strive to handle your non-public
information in such a way as to protect it from falling into the hands of anyone who has no business reason to
know such information. We provide you with our Privacy Policy which specifies our procedures for handling
your personal information.
Total Clarity maintains a Code of Ethics for its Advisory Representatives, supervised persons and office staff.
The Code of Ethics contains provisions for standards of business conduct in order to comply with federal
securities laws, personal securities reporting requirements, pre-approval procedures for certain transactions, code
violation reporting requirements, and safeguarding of material non-public information about your transactions.
Our Code of Ethics establishes our firm’s expectation for business conduct. A copy of our Code of Ethics will
be provided to you upon request.
Neither Total Clarity nor its associated persons recommend buys or sells for client accounts any securities in
which they have a material financial interest. Total Clarity and its associated persons also buy or sell securities
identical to those securities recommended to you. They will not put their interests before your interest. Total
Clarity’s Code of Ethics bans our Advisory Representatives and any associated person from trading in such a way
as to obtain a better price for themselves than for clients.
Total Clarity is required to maintain a list of all securities holdings for its associated persons and their related
family accounts at least annually and to develop procedures to supervise the trading activities of associated
persons who have knowledge of client transactions. Further, associated persons are prohibited from trading on
non-public information or sharing such information.
You have the right to decline any investment recommendation. Total Clarity and its associated persons are
required to conduct their securities and investment advisory business in accordance with all applicable Federal
and State securities regulations.
Review of Accounts
As part of the Total Clarity PreActive Account program, your accounts will be reviewed at least quarterly and
you will be contacted not less than annually for a review meeting. This is discussed in more detail on page 4 under
“Advisory Services”. You are advised that you must notify your Advisory Representative promptly of any
changes to your financial goals, objectives or financial situation as such changes could require him/her to review
the portfolio allocation and make recommendations for changes. Each Advisory Representative is responsible
for ensuring timely reviews and suitable recommendations. The level of experience of Advisory Representatives
will vary.
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You will be provided statements at least quarterly directly from the custodian. These reports are provided by
Schwab. Additionally, you will receive confirmations of all transactions that occur within your account directly
from your custodian. Total Clarity provides a report every quarter showing all holdings within each account,
along with performance data for each account beginning from the date of its opening at Schwab.
You should compare the report you receive from Total Clarity with statements received from your custodian.
Should there be any discrepancy between reports, the account custodian’s report will prevail.
Client Referrals & Other Compensation
Product vendors recommended by Total Clarity provide monetary and non-monetary assistance with client events
in addition to providing educational tools and resources. Advisory Representatives do not select products as a
result of any monetary or non-monetary assistance. Total Clarity’s due diligence of a product does not take into
consideration any assistance it receives. The suitability and quality of a product for our clients is of first and
foremost importance.
Total Clarity may enter into solicitor arrangements pursuant to which it compensates third-party intermediaries
for client referrals that result in the provision of investment advisory services by Total Clarity. Total Clarity will
disclose these solicitation arrangements to affected investors, and any cash solicitation arrangements will comply
with Rule 206(4)-3 of the Advisers Act. Solicitors introducing clients to Total Clarity may receive compensation
from Total Clarity, such as a retainer, a flat fee per referral and/or a percentage of introduced capital or of the
advisory fee prior to payment to the Advisory Representative. Such compensation will be paid pursuant to a
written agreement with the solicitor and generally may be terminated by either party from time to time. The cost
of any such fees will be borne entirely by Total Clarity and not by any affected client.
Custody
The account custodian will directly debit your account(s) for the payment of our advisory fees. This ability to
deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or
securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will
be held with a bank, broker-dealer, or other qualified custodian. You will receive account statements from the
qualified custodian(s) holding your funds and securities at least quarterly. The account statements from the
account custodian will indicate the amount of our advisory fees deducted from your account(s) each billing period.
You should carefully review account statements for accuracy.
Standing Letter of Authorization
When requested, our firm, or Advisory Representatives, will affect ACHs from client accounts to one or more
third parties designated, in writing, by the client without obtaining written client consent for each separate,
individual transaction, as long as the client has provided us with written authorization to do so. Such written
authorization is known as a Standing Letter of Authorization. An adviser with authority to conduct such third
party transfers has access to the client's assets, and therefore has custody of the client's assets in any related
accounts.
However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by reason of
having custody, as long as the following criteria are met:
1. You provide a written, signed instruction to the qualified custodian that includes the third party’s name
and address or account number at a custodian;
2. You authorize us in writing to direct transfers to the third party either on a specified schedule or from
time to time;
3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a transfer of
funds notice to you promptly after each transfer;
4. You can terminate or change the instruction;
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5. We have no authority or ability to designate or change the identity of the third party, the address, or any
other information about the third party;
6. We maintain records showing that the third party is not a related party to us nor located at the same
address as us; and
7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual
notice reconfirming the instruction.
When we engage in third party standing letters of authorization, Total Clarity complies with the conditions of the
safe harbor provisions and is therefore exempt from the annual surprise exam requirement for Advisers that have
custody.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position it should
have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include
canceling the trade, adjusting an allocation, reimbursing the account, and/or applying a credit toward advisory
fees.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible
to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover
damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held
by you.
Financial Information
Total Clarity will not require you to prepay more than $1,200 six or more months in advance of receiving the
advisory service; therefore, a balance sheet is not required to be attached. Total Clarity has discretionary authority
over client accounts; however, that authority does not extend to the withdrawal of any client assets, with the
exception of the deduction of Total Clarity’s advisory fees from your accounts.
We are financially stable. There is no financial condition that is likely to impair our ability to meet our contractual
commitment to you or any other client. Neither Total Clarity nor any of its Advisory Representatives have ever
been the subject of a bankruptcy petition.
ITEM 10: REQUIREMENTS FOR STATE-REGISTERED ADVISERS
This section is not applicable to Total Clarity. Total Clarity is not state registered. Total Clarity is registered
with the Securities and Exchange Commission.
Should you have any questions regarding our PreActive Brochure or any other document you have received from
Total Clarity, please speak with your Advisory Representative or the Chief Compliance Officer of Total Clarity.
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Additional Brochure: WRAP VISION ACCOUNT BROCHURE MARCH 2026 (2026-03-16)
View Document Text
525 Tyler Road, Suite T
St. Charles, IL 60174
Phone: (630) 762-9352
Fax: (630) 587-9170
w ww.totalclaritywealth.com
Total Clarity Vision Account
WRAP FEE BROCHURE
March 17, 2026
This brochure provides clients with information about the qualifications and business practices of Total
Clarity Wealth Management, Inc. and the Total Clarity Vision Wrap Program that should be considered
before becoming a client. If you have any questions about the contents of this Brochure, please contact us at
(630) 762-9352 and/or i nfo@totalclaritywealth.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 Total Clarity Wealth Management, Inc. is also available on the SEC’s website
at w ww.adviserinfo.sec.gov. The searchable IARD/CRD number for Total Clarity Wealth Management, Inc.
is 142728.
Any reference to Total Clarity Wealth Management, Inc. as a registered investment adviser or its related
persons as registered Advisory Representatives does not imply a certain level of skill or training.
Item 2 MATERIAL CHANGES
At least annually, this section will discuss only specific material changes that are made to the Total
Clarity Wealth Management, Inc. Wrap Vision Account Brochure and provide you with a summary of
such changes. Additionally, reference to the date of the last annual update to the brochure will be
provided.
Since our last annual updating amendment dated March 24, 2025 we have made the following material
changes:
No material changes were made.
A copy of our updated brochure and brochure supplements may be requested by contacting us at
(630) 762-9352 and/or info@totalclaritywealth.com. These documents are available to you free of
charge and are also available on our website at www.totalclaritywealth.com..
Additional information about Total Clarity Wealth Management, Inc. is also available via the SEC’s
website www.adviserinfo.sec.gov. Our IARD number is 142728. The SEC’s website also provides
information about any persons affiliated with Total Clarity Wealth Management, Inc. who are
registered, or are required to be registered, as Advisory Representatives of Total Clarity Wealth
Management, Inc.
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Item 3 TABLE OF CONTENTS
Item 2 MATERIAL CHANGES ........................................................................................................ 2
Item 3 TABLE OF CONTENTS ....................................................................................................... 3
Item 4 SERVICES, FEES & COMPENSATION .............................................................................. 4
Item 5 ACCOUNT REQUIREMENTS & TYPES OF CLIENTS ..................................................... 17
Item 6 PERFORMANCE-BASED FEES ....................................................................................... 17
Item 7 TYPES OF CLIENTS ......................................................................................................... 18
Item 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............. 18
Item 9 ADDITIONAL INFORMATION ........................................................................................... 22
Item 10 REQUIREMENTS FOR STATE-REGISTERED ADVISERS ........................................... 26
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Item 4 SERVICES, FEES & COMPENSATION
INTRODUCTION
Total Clarity Wealth Management, Inc. is an investment adviser registered with the Securities and
Exchange Commission. Total Clarity Wealth Management offers advice regarding mutual funds and
stocks as well as other products such as: variable annuities, bonds, options, government securities,
certificates of deposit, Unit Investment Trusts (UITs), Exchange Traded Funds (ETFs) and 529 College
Savings Plans. Total Clarity Wealth Management utilizes the clearing and custody services of Schwab
Institutional, a division of Charles Schwab & Co., Inc. ("Schwab") an unaffiliated SEC registered
Broker/Dealer and FINRA member. Total Clarity has also entered into a relationship to offer you
brokerage and custodial services through LPL Financial (LPL) an unaffiliated SEC registered Broker-
dealer and Member FINRA/SIPC.
In its capacity as a registered investment adviser, Total Clarity Wealth Management offers various
advisory services as further disclosed in its Part 2A Brochure. The programs offered include two
available wrap fee programs entitled the "Total Clarity Vision Account" and the "Total Clarity Vision CB
Account". Both Vision wrap accounts "wrap" all of the transaction charges in with the advisory fee,
versus having each transaction charge billed directly to the client's account.
Advisory Services
The wrap fee programs offer clients a fee-based account for which the client will pay a quarterly fee for
portfolio review and on-going asset management services and brokerage services. Clients will
maintain an account that will contain one or more of the following: stocks, bonds, options (such as
covered calls and long puts), government securities, Exchange Traded Funds (ETFs), Unit Investment
Trusts (UITs), and certain types and classes of variable annuities and mutual funds. Some accounts
also hold Alternative Investments such as Real Estate Investment Trusts (REITs), Business
Development Companies (BDCs), and private equities, as a courtesy to the client. These products are
not part of the Wrap Fee Program and therefore advisory fees will not be charged on these holdings,
but a commission will be paid to the Advisory Representative (in their role as a Registered
Representative of LPL) at the time of purchase. Transaction or holding costs for Alternative Investment
products are not covered within the wrap fee agreement.
The Total Clarity Vision Account and the Total Clarity Vision CB Account programs offer clients
portfolio review and asset management services on a discretionary basis. Discretionary asset
management services allow the Advisory Representative to make buys, sells and exchanges within the
account as the Advisory Representative deems appropriate, without obtaining the client's prior consent
to the transaction(s). Discretionary approval is given when the client signs the Schwab or LPL
Financial Account Application. By signing the custodian's Account Application, the client provides the
Advisory Representative with discretionary approval for their account. The Advisory Representative will
determine the securities to be purchased and sold in the account and will alter the securities holdings
from time to time, without prior consultation with the client. Unless otherwise expressly requested by
the client, Total Clarity will manage the account and will make changes to the allocation as deemed
appropriate by the firm and the Advisory Representative. The client can discuss with the Advisory
Representative their desire to be notified of any recommendations before buying or selling any
securities in their account, but in order to trade at our custodians, the Advisory Representative must be
given discretion on all accounts. All clients will be sent, by the custodian of their account, either by mail
or electronically, confirmations of any trades done in their account. If a client decides they no longer
want discretion granted, it will result in the closing of the account.
Depending on the client's specific goals, objectives and market circumstances, we will generally hold
positions in an account for a long term, even more than a year, or, depending on market conditions, we
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will actively trade some securities held in an account for periods of 30 days or less. Advisory
Representatives will be reasonably available to the client to provide advice, make recommendations
and execute transactions. Since our investment strategies and advice are based on each client’s
specific financial situation, the investment advice we provide to you may be different or conflicting with
the advice we give to other clients regarding the same security or investment.
Advisory Representatives will gather information on the client's financial history, goals, objectives and
financial concerns and assist the client in developing an asset allocation strategy. The client will
establish an account with Schwab or LPL Financial. Based on the client's investment objectives, risk
tolerance and financial situation, the Advisory Representative will provide the level of services
requested by the client (i.e., asset management on a continuous and ongoing basis or portfolio review
services). Some Total Clarity Advisory Representatives manage portfolio models, and other of our
advisors customize the holdings within each account according to the client's financial history, status
and risk tolerance. One of the tools available for use by our Advisory Representatives are portfolio
models provided by a third party through Schwab or directly from the third party's website at no charge
to Total Clarity or the client, although the third party could benefit from internal expenses charged by
the holdings. Your Advisory Representative can use these models as a guide in managing your
account, but he is responsible to make all decisions and complete all trades himself. Advisory
representatives also have available, the use of separately managed accounts through LPL that use
another firm to manage the holdings in the account. Some of these programs are available at no
charge to the client while others may result in an additional fee. No other party outside of Total Clarity
will have the ability to trade assets within your account without your approval. Therefore, strategies will
vary between clients having the same Advisory Representative, as well as for clients with different
Advisory Representatives.
You are able to request that your Advisory Representative add reasonable trading restrictions
(“Reasonable Restrictions”) to your advisory account at any time during the management of your
account. Your Advisory Representative or Total Clarity has the option to decline or terminate the
account if we feel your elected Reasonable Restrictions are too prohibitive, and we do not feel the
account can be managed within our program. Restrictions imposed on management of an account,
even those considered reasonable, will affect your account performance and may mean the
performance in the account is different than the performance of other similarly managed accounts.
Advisory Representatives will contact clients at least annually, or at the client's request, to discuss the
Total Clarity Vision Account or the Total Clarity Vision CB Account investment portfolio and to update
the client's financial information when any changes have occurred. Clients are able to request more
frequent reviews and set thresholds for triggering events that would cause a review to take place.
Generally, Advisory Representatives will recommend changes to clients' portfolios based on many
factors including: shifts in the economy, changes in the management and/or structure of a mutual fund
or company in which clients' assets are invested, to rebalance the portfolio and market shifts and/or
corrections.
Generally, the Advisory Representative who solicited the client will conduct the annual review. Clients
are advised they should notify their Advisory Representative promptly of any changes to their goals,
objectives or financial situation. Failure of the client to notify the Advisory Representative of any such
changes could result in investment recommendations that do not match the client's needs.
Third-Party Created Model Portfolios
Total Clarity has entered into an agreement with a service provider which provides us with access to
certain model portfolios as well as trading instructions. These services allow us to provide model
portfolios comprised of stocks and exchange-traded fund products but other products such as mutual
funds are also available to us.
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Total Clarity does not pay the provider for these services and the advisory fees you pay are not
increased because we use these services. These services allow us to provide our clients with
operational and advisory efficiencies which may create a conflict of interest since the models use
mutual funds and exchange-traded funds that may pay fees to the service provider. It is possible that
there are other exchange-traded funds and mutual funds not included in these models that may be in
our clients' best interest. In all cases we strive to recommend only products and services that we
believe are in your best interest and have the lowest cost share class. We have the ability to make
substitutions to the investment selections listed in the models and to deviate from the trading
instructions provided to us.
Accounts invested in these investment models that include mutual funds may be subject to short-term
redemption fees imposed by custodians and/or the mutual fund sponsor. Total Clarity is not
responsible for these short-term redemption fees. They are the responsibility of the client.
These models are available for use with qualified and non-qualified accounts. Advisory
Representatives will pay approximately 10 to 20 basis points (0.10% - 0.20%) to Total Clarity from their
portion of the advisory fee you pay to cover our administration and operational costs. Clients are not
billed directly for the use of these models.
Separately Managed Accounts
Total Clarity provides advisory services through certain programs sponsored by LPL Financial. These
programs are managed by LPL or an approved third-party manager on a discretionary basis. All
accounts under any of these programs are held at LPL Financial. Each program is described below
and additional information such as any fees that apply and potential conflicts of interest are available
on the associated Account Agreement and LPL’s Form ADV, Part 2A.
When selecting a Separately Managed Account for a client, Total Clarity shall review information about
the program such as its disclosure statement and/or material supplied by the Independent Manager or
independent third parties for a description of the Independent Manager’s investment strategies, past
performance, and risk results to the extent available. Factors that Total Clarity shall consider in
selecting an account type, the model and third-party manager, include the stated client investment
objective(s), management style, performance, reputation, financial strength, reporting, pricing, and
research.
Manager Access Select Program (MAS) – this program offers Total Clarity the ability to work with
the client to identify a third-party portfolio manager (SMA Portfolio Manager) from a list of SMA
Portfolio Managers made available by LPL and the SMA Portfolio Manager will manage the client’s
assets on a discretionary basis. Total Clarity will provide initial and ongoing assistance regarding
the SMA Portfolio Manager selection process and review of the account. The minimum account
size is $25,000 for the Program, but can be higher depending on the particular SMA Portfolio
Manager strategy or Model Portfolio selected.
The SMA Portfolio Manager will have discretion to invest among a broad variety of security types,
including but not limited to equities, fixed income securities, options, mutual funds, closed-end
funds, and exchange-traded funds (“ETFs”).
The fees paid to SMA Portfolio Managers in the SMA Platform are generally less than fees those
advisors would charge a client seeking to establish a direct relationship with them outside of a wrap
program. This is principally due to the fact that LPL absorbs many of the billing, administrative, and
marketing expenses that would otherwise be borne by those advisors, including trading expenses.
Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a third party managed account using Optimum Fund
mutual funds. The client will authorize LPL on a discretionary basis to purchase and sell Optimum
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Funds pursuant to investment objectives chosen by the client. Total Clarity will assist the client in
determining the suitability of OMP and in setting an appropriate investment objective. Total Clarity
will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent
with the client’s investment objective. A minimum account value of $10,000 is required for OMP
account.
Model Wealth Portfolios (MWP)
Model Wealth Portfolios (MWP) offers clients a professionally managed mutual fund or ETF asset
allocation program. Total Clarity will work with the client to obtain the client’s suitability information
and to determine the suitability of the MWP program and an appropriate investment objective. Total
Clarity will work with the client to open the MWP account at LPL and to select a model portfolio
designed by LPL’s Research Department. LPL ‘s Research Department, a third party portfolio
strategist or the Advisory Representative may act as portfolio strategist responsible for selecting
the mutual funds or ETFs within a model portfolio and for making changes to these holdings. The
minimum account size is $10,000 for the MWP accounts, but can be higher depending on the
particular Model Portfolio selected.
The client will authorize LPL or the SMA Portfolio Manager to act on a discretionary basis to
purchase and sell mutual funds, ETFs, stocks and fixed income products and to liquidate
previously held securities in any of these three program types. The client also authorizes LPL to
effect rebalancing for accounts in these programs.
IRA Rollover Recommendations
For purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”)
where applicable, we are providing the following acknowledgment to you. When we provide
investment advice to you regarding your retirement plan account or individual retirement account, we
are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the
Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we
make money creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s
provisions, we must:
Meet a professional standard of care when making investment recommendations (give prudent
advice);
Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our and, in turn, our advisory
fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets
from your employer's retirement plan and roll the assets over to an individual retirement account
("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you an asset based fee as set forth in the agreement you executed with
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our firm. This practice presents a conflict of interest because persons providing investment advice on
our behalf have an incentive to recommend a rollover to you for the purpose of generating fee based
compensation rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options
are available, you should consider the costs and benefits of:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer’s retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage here are a few
points to consider before you do so:
1. Determine whether the investment options in your employer's retirement plan address your
needs or whether you might want to consider other types of investments.
1. Employer retirement plans generally have a more limited investment menu than IRAs.
2. Employer retirement plans may have unique investment options not available to the
public such as employer securities, or previously closed funds.
2. Your current plan may have lower fees than our fees.
1. If you are interested in investing only in mutual funds, you should understand the cost
structure of the share classes available in your employer's retirement plan and how the
costs of those share classes compare with those available in an IRA.
2. You should understand the various products and services you might take advantage of
at an IRA provider and the potential costs of those products and services.
3. Our strategy may have higher risk than the option(s) provided to you in your plan.
4. Your current plan may also offer financial advice.
5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your
required minimum distribution beyond age 72.
6. Your 401k may offer more liability protection than a rollover IRA; each state may
vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA
assets have been generally protected from creditors in bankruptcies. However, there can be
some exceptions to the general rules so you should consult with an attorney if you are
concerned about protecting your retirement plan assets from creditors.
7. You may be able to take out a loan on your 401k, but not from an IRA.
8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they qualify for an exception
such as disability, higher education expenses or the purchase of a home.
9. If you own company stock in your plan, you may be able to liquidate those shares at a lower
capital gains tax rate.
10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand the differences between these types of accounts and to decide
whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment
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adviser representative, or call our main number as listed on the cover page of this brochure.
Advisory Fees
Opening an Account (initial fees): The initial pro-rated fee is charged in arrears and is based on the
inflow of cash and assets and the proportion of the number of days remaining in the quarter on the
date these assets were delivered into the account. Initial advisory fees will be collected directly from
the account, provided the client has given Total Clarity Wealth Management written authorization to do
so.
An Established Account (ongoing fees): Ongoing fees will be charged quarterly, in advance - based on
the value of the account* on the last day of the previous quarter. Fees are charged to and collected
directly from the advisory account early in the quarter. Clients will be provided with a fee invoice that
identifies:
1. The value of the account on the last day of the previous quarter (from which the advisory fee is
calculated).
2. The quarterly advisory fee to be charged to the account(s).
3. The accounts(s) from which the fee will be deducted.
Account values in the Orion reporting system will be used for Total Clarity's quarterly fee calculations
for advisory accounts. Although account holdings and asset valuations should generally match,
month-end market values reflected in Orion's reporting system sometimes differ from those
provided the custodian on their month-end statements. The three most common reasons why these
values may differ are (i) differences in the manner in which accrued interest is calculated, (ii)
differences in the date upon which “as of” dividends and capital gains are reported, and (iii) differences
in whether settlement date valuations or trade date valuations are used. If you have any questions or
believe there are material discrepancies between your custodial statement and Orion's reporting
system, please contact Total Clarity at (630) 762-9352. You may request a copy of the Orion report
valuations from your Total Clarity Advisory Representative. The custodian account values will be used
for the quarterly fee calculation for Vision CB accounts.
If the account does not contain sufficient funds to pay the quarterly advisory fee, Total Clarity Wealth
Management has limited authority to sell or redeem securities within the advisory account in a
sufficient amount to pay the fee. The client can reimburse the account for advisory fees paid to Total
Clarity Wealth Management, with the exception of an IRA account.
Our fees are negotiable and are not based on a share of capital gains or capital appreciation of the
funds, but rather on the value of the account. Advisory fees for our Total Clarity Vision Account and
the Total Clarity Vision CB Account programs will be charged in advance on a quarterly basis, based
on the account balance on the last working day of the previous quarter.
Clients can make additions to or withdrawals from the account, provided the account continues to meet
minimum account size requirements. Advisory fees will be adjusted each quarter for any inflows and
outflows of cash and holdings over or equal to $10,000 in a single day. For example, if $10,000 is
withdrawn from an account midway through a quarter, a pro-rated amount which is equal to the annual
fee on that $10,000 divided by the number of days in the year to get a daily rate and then multiplied by
the number of days remaining in the quarter, will be credited toward the advisory fee for the next
quarter. If a tiered fee schedule is used, the total account value at the end of the quarter will determine
the tier breakpoints. If $10,000 is added to an account midway through a quarter, a pro-rated amount
which is equal to the annual fee on that $10,000 divided by the number of days in the year to get a
daily rate and then multiplied by the number of days remaining in the quarter, will be added to the
advisory fee for the next quarter. If a tiered fee schedule is used, the total account value on the day of
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the deposit will determine the tier breakpoints. No fee adjustments will be made for appreciation or
depreciation of the account during a quarter or typically for transfers between two Total Clarity
accounts with the same account owner. Cash flow adjustments on Vison CB accounts are made for
ANY client additions or withdrawals regardless of size. Cash flow adjustments will not be made on flat
fee client accounts.
Not all clients receive Quarterly Client reviews. For example, Vision CB accounts do not receive
Quarterly Client reviews and therefore do not receive a fee notification.
Fees are based solely on account balance(s) and are not based on a share of capital gains upon or
capital appreciation of the funds or any portion of the funds. Fees are in accordance with the following
fee schedules:
Total Clarity Vision (Wrap) Program
Total Clarity Vision Accounts are billed based on the account value as of the last day of the
quarter. Advisory fees will be adjusted each quarter for any client inflows and outflows of cash and
holdings equal to or over $10,000 in a single day.
"First Next Next" Billing Schedule
Account Size
$0 to $50,000
Next $50,001 to $100,000
Next $100,001 to $250,000
Next $250,001 to $500,000
Next $500,001 to $1,000,000
Next $1,000,001 to $3,000,000
Next $3,000,001 to $5,000,000
$5,000,001 and above
Vision Maximum
Annual Fee
2.75%
2.75%
2.75%
2.50%
2.00%
1.75%
1.75%
1.75%
Total Clarity Vision CB (Wrap) Program
Total Clarity Vision CB Wrap Accounts are billed based on the account value as of the last day of the
quarter. Advisory fees will be adjusted each quarter for any client inflows and outflows of cash and
holdings. Fees may be calculated on a First Next Next schedule or a Breakpoint schedule.
"Breakpoint" Billing Schedule
Household Total Assets in
Advisory Accounts
$0 to $50,000
Next $50,001 to $100,000
Next $100,001 to $250,000
Next $250,001 to $500,000
Next $500,001 to $1,000,000
Next $1,000,001 to $3,000,000
Next $3,000,001 to $5,000,000
$5,000,001 and above
Vision CB Maximum
Annual Fee
2.75%
2.75%
2.75%
2.50%
2.00%
1.75%
1.75%
1.75%
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"First Next Next" Billing Schedule
Account Size
$0 to $50,000
Next $50,001 to $100,000
Next $100,001 to $250,000
Next $250,001 to $500,000
Next $500,001 to $1,000,000
Next $1,000,001 to $3,000,000
Next $3,000,001 to $5,000,000
$5,000,001 and above
Vision CB Maximum
Annual Fee
2.75%
2.75%
2.75%
2.50%
2.00%
1.75%
1.75%
1.75%
Your Advisory Representative will negotiate your specific fee with you, based on the fee
schedule outlined above. We make exceptions to our general fee schedule under certain
circumstances (e.g., responsibilities involved, accounts or groups of accounts which are expected to
have significant capital additions in the future, anticipated future earning capacity, related accounts,
account composition, pre-existing client, account retention, pro bono activities, etc.). In such cases,
lower fees or different payment arrangements can be negotiated with each client separately and will be
described in your Vision Account Agreement. Fees vary from client-to-client and are detailed on the
Total Clarity Vision or Vision CB Account Agreement you will sign; however, fees will not exceed the
schedule shown above. Therefore, your Advisory Representative will charge more or less than another
Advisory Representative.
The First Next Next fee schedule is a tiered schedule. More than one fee rate will apply to the account
if the total account value* is $50,001 or more at the time of valuation for the purposes of the fee
calculation. Total Clarity retains a portion of the advisory fees equal to 0.08%-0.16% of the account
value annually to cover administrative costs. The amount is based on the Advisory Representative’s
assets in Total Clarity accounts. This may encourage some Advisory Representatives to open advisory
accounts for clients to earn a reduction in the fees they pay us, but Total Clarity does not believe this is
a material issue. All advisory accounts are reviewed to be sure the account is in the best interest of the
client, and we feel this overrides the possibility of opening an advisory account that is not suitable for
the client. In certain situations, a portion of the net advisory fee will be paid to the Advisory
Representative's supervisor and/or branch manager. LPL Financial will receive an annual oversight fee
of 0.03%-0.05% times the value of each account that is managed by Advisory Representatives who
are also registered with LPL and that is held at Schwab, for supervision and back office administration.
This fee is pulled from the advisory fee before the remainder of the fee is paid to your Advisory
Representative and is only assessed to Representatives who are also Registered Representatives with
LPL. The remainder of the fee is paid to your Advisory Representative. Total Clarity is allowed to
change the above fee schedule upon 30-days prior written notice to you.
The quarterly fee is calculated based on the number of days in the quarter and not on the annual fee
divided by four. For example, an annual fee of $5,000 is multiplied by the number of days in the quarter
and divided by the number of days in the year to arrive at the quarterly fee.
If negotiated, Total Clarity will charge a flat fee, not to exceed the rate % noted above, billed in
advance for Vision and Vision CB accounts. Total Clarity will pro-rate a flat fee for the first quarter
based on (the number of days the account is open) / (the total number of days in the quarter) multiplied
by the fee. We will also refund any flat fees paid in advance a pro-rated portion based on the
fee multiplied by (the number of days the account was open) / (number of days in the quarter) if an
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account is closed.
At the discretion of the Advisory Representative, all accounts from one household are added together
to obtain a higher total of account values for fee calculations. In this way, your annual asset
management fee will then be lower if a breakpoint is reached, since it is based on an aggregate value
of all accounts within your household, than if the fee for each account was calculated independently of
the other accounts. This practice varies by Advisory Representative, so you could pay more or less for
management services depending on the Advisory Representative with whom you work.
Account values in the Orion reporting system will be used for Total Clarity's quarterly fee calculations
for advisory accounts. The custodian account values will be used for quarterly fee calculations for
Vision CB accounts. Although account holdings and asset valuations should generally match, month-
end market values reflected in Orion's reporting system sometimes differ from those provided by the
custodian on their month-end statements. The three most common reasons why these values may
differ are (i) differences in the manner in which accrued interest is calculated, (ii) differences in the date
upon which “as of” dividends and capital gains are reported, and (iii) differences in whether settlement
date valuations or trade date valuations are used. If you have any questions or believe there are
material discrepancies between your custodial statement and Orion's reporting system, please
contact Total Clarity at (630) 762-9352. You may request a copy the Orion report valuations from your
Total Clarity Advisory Representative.
If your account has securities that are excluded from billing ("Excluded Securities"), the market value
for the Excluded Securities is deducted from the account's total market value before the fees are
calculated.
Closing an Account (refund of fees): Since fees are billed in advance, Total Clarity will refund to the
client a portion of the final fee which was collected from the advisory account(s). Details regarding final
fee calculations and refunds can be found under "Termination of a Total Clarity Vision or Vision CB
Account." (See Note above for flat rate fees.)
Examples of the maximum fee calculation for all management programs is shown below:
Fee calculation "First Next Next" billing example for a Total Clarity Vision & Vision
CB Account valued at $1.2 million:
(Amount x Rate % = Annual Fee)
Amount
Annual Fee
Rate
%
2.75 $1,375.00
2.75 $1,375.00
2.75 $4,125.00
2.50 $6,250.00
2.00 $10,000.00
1.75 $3,500.00
$26,625.00
$6,656.25
First $50,000
Next $50,000 ($100,000 – $50,000 = $50,000)
Next $150,000 ($250,000 – $100,000 = $150,000)
Next $250,000 ($500,000 – $250,000 = $250,000)
Next $500,000 ($1,000,000 – $500,000 = $500,000)
Next $200,000 ($1,200,000 – $1,000,000 = $200,000)
Example Annual Fee:
Example Quarterly Fee for Total Clarity Vision or Vision CB
Accounts: ($26,625.00 multiplied by number of days in the quarter/
number of days in the year).
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Fee calculation "breakpoint" example for a Total Clarity Vision CB Account with a total of all
Total Clarity Accounts valued at $1.2 million:
(Amount x Rate % = Annual Fee)
A household with a total balance of all Total Clarity advisory accounts of $1,200,000 on the breakpoint
fee schedule would be billed at 1.75% per year. The total annual fee is $21,000 ($1,200,000 * 1.75%)
and the quarterly billing (for a 90 day quarter) is $5,178.08. The quarterly calculation is: ($21,000 / 365
days) * 90 days.
Costs Associated with a Wrap Fee Account
The Total Clarity Vision and Total Clarity Vision CB Account programs at times will cost the client more
or less than if the client purchased services separately. Costs that affect the services if obtained
separately or that the client is able to control if services are purchased separately include trading costs
and the asset management fee. Additionally, clients are advised that a wrap fee account, as compared
with a traditional commission based account, will be more costly to the client during periods when
trading activity is less. Consequently, clients find that maintaining the wrap fee account can result in a
higher annual cost. During periods when trading activity is heavier, such as when the account is first
opened and during periods of increased market movements, wrap fee accounts will result in lower
annual costs than a brokerage account.
Current business practices of the custodians we use has led to the reduction or elimination of many
transaction charges (commissions). Therefore, our commission costs for trading in certain types of
securities within the wrap fee program have been reduced or eliminated which means we retain a
larger portion of the advisory fee we charge you, depending on the types of securities transacted in
your account. This presents a conflict of interest as we have not reduced our fees to you in conjunction
with these savings. We have no way of predicting how the custodian will assess transaction costs in
the future, and trading costs may be higher or lower. We believe our wrap fee is fair and reasonable
based on the services we provide and the advice we deliver.
Additional Fees & Transaction Charges
In addition to the advisory fee, you will also pay fees for custodial services, account maintenance fees,
taxes, and other fees associated with maintaining the account. For all qualified accounts held at LPL
Financial, a $60 annual IRA maintenance will be charged. Annual IRA maintenance fees are not
charged by Schwab. Total Clarity and its Advisory Representatives do not control or share in any
portion of such fees.
Custodians may charge brokerage commissions, transaction fees, and other related costs on
the purchases or sales of mutual funds, equities, bonds, options, margin interest, and
exchange-traded funds. Mutual funds, money market funds, and exchange-traded funds may
also charge internal management fees, which are disclosed in the fund’s prospectus.
Furthermore, the client will pay fees to the mutual fund company from which they were purchased.
Such fees are compensation to the fund manager and are not shared with Total Clarity Wealth
Management. Total Clarity offers a wide range of mutual funds at both LPL and Schwab. Institutional
Advisory share classes (share classes that do not pay 12b-1 fees) of mutual funds are typically
charged a higher transaction fee for purchases and sells of these products. However, these funds have
lower expenses and therefore should result in being a lower cost to the customer, but this varies for
each fund. LPL offers some of these advisory share class mutual funds and Schwab offers some
Exchange Traded Funds (ETFs) with no transaction fees which results in a conflict of interest for your
Advisory Representative to purchase these specific funds to save himself the transaction fee for a
Vision Account. Schwab charge no transaction fees for ETFs and exchange traded equities and a
standard, non-discounted fee for OTC equities.
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Although clients do not pay a transaction charge for transactions in Vision or Vision CB accounts,
clients should be aware that your Advisory Representative would cover these charges. The transaction
charges paid by your Advisory Representative vary based on the type of security (ex. mutual fund,
equity, or ETF) and for mutual funds the charge is based on whether or not the mutual fund pays 12b-
1s fees and/or recordkeeping fees to the custodian. Transaction charges paid by your Advisory
Representative for mutual funds range from $0 - $26.50/ transaction which, therefore, results in a
conflict of interest since the Advisory Representative would consider this cost when deciding which
securities to select and how frequently to place transactions in a Vision or Vision CB account. Mutual
fund A share classes typically have a lower or no transaction charge, so to help mitigate the conflict of
interest in selecting a share class and since 12b-1s fees for accounts held at Schwab or LPL cannot be
refunded, Total Clarity as a general policy has Advisory Representatives use only non-12b-1 paying
share classes, unless clients are better served with another share class. Advisory Representatives
must select the share class that is in your best interest.
Some custodians also charge a foreign Transaction Tax on certain foreign equity security
purchases. This tax is levied by the foreign government and is used to offset the tax incurred by the
custodian as a result of executing the transaction on your behalf. At account opening, you will receive
notification from your custodian about miscellaneous fees and charges they impose for certain
transactions (such as wire or overnight fees). You should keep this documentation for your records.
LPL Financial and Schwab will also charge a $50 fee when purchasing Alternative Investments within
Total Clarity accounts as well as an annual holding fee of between $35 and $250 per Alternative
Investment. These fees will not be refunded back to the account since these holdings are not part of
the wrap fee program and are not included in billing calculations. Total Clarity receives no portion of
any of the above fees.
Separately Managed Programs
Manager Access Select (MAS)
The Account Fee for Manager Access Select Accounts includes all fees and charges for the
services of SMA Portfolio Manager or Model Advisor, LPL, and Total Clarity including brokerage
commissions for transactions effected through LPL. Client understands that the
Advisory Parties, in connection with the performance of their respective services, shall be entitled
to and will share in the Account Fees payable hereunder. The SMA Portfolio Manager or Model
Advisor will receive the Manager Fee which ranges from 0% - 0.60%. The Advisory Fee has a
maximum of 1.75%, For MAS accounts the SMA Portfolio Manager fee is charged separately from
the Advisory Fee. The total Maximum Annual Account Fee is 2.35%.
Optimum Market Portfolios (OMP)
The maximum flat Advisory Fee will not exceed 1.75%. Upon request, the Advisory Fee may be
structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds.
The Account Fee is charged for the asset management services of LPL and Total Clarity, as well
as the administrative and custodial services of LPL. The Account Fee is negotiable and is based
on the value of the assets in the Account, including cash holdings, and payable quarterly in
advance.
Model Wealth Portfolios (MWP)
The Advisory Fee is charged for the investment advisory services of Total Clarity, as well as the
investment advisory, administrative, trading, custodial and clearing services of LPL. The maximum
flat Advisory Fee is 1.75% but may be higher if a tiered schedule is used that has higher
percentages for lower tiers. Depending upon the model(s) selected for the account, clients pay a
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Manager Fee set by LPL for the use of each model portfolio. The Manager Fee is based on the
value of the assets in the account, including cash holdings, and payable quarterly in advance. This
fee ranges from 0% to 0.60% and is in addition to the Advisory Fee. Therefore, the Maximum
Total Account Fee would be 2.35%
Clients should consider the level and complexity of the advisory services to be provided when
negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with Total
Clarity. For accounts utilizing third-party portfolio managers
under aggregate, all-in-one account fee structures (including MAS, OMP & MWP fee structure),
Total Clarity has a financial incentive to select one portfolio instead of another portfolio because
the portion of the account fee retained by Total Clarity varies depending on the portfolio strategist
fee associated with a portfolio.
Please refer to the relevant LPL Form ADV program brochure for a more detailed discussion of
conflicts of interest.
Alternative Investments
Transaction charges and annual holding fees for alternative investments such as REITs, Business
Development Companies (BDCs), and private equities will be charged to the account, as they are
being held in the account as a courtesy to the client, and are not considered part of the Wrap Fee
Program. Your Advisory Representative will receive commissions through LPL for the purchase of
Alternative Investments that are held in the account.
Variable Annuities
For variable annuities held within Total Clarity accounts, there is no sales charge that is paid to your
Advisory Representative upon purchase of the annuity. All expenses or charges, such as mortality &
expense charges and fees for any riders related to the variable annuity are pulled directly from the
variable annuity. These fees typically vary between 0.30% and 1.50% annually and are pulled quarterly
or annually depending on your contract and are in addition to the advisory fee. Total Clarity receives no
portion of these amounts. Please see your Variable Annuity contract for a list of these fees. Variable
products are complex products with higher internal expenses compared to other securities products
and are therefore more expensive.
Commissions & Sales Charges
Some Advisory Representatives of Total Clarity are also Registered Representatives of LPL Financial,
a registered Broker/Dealer, member of FINRA (Financial Industry Regulatory Authority) and SIPC
(Securities Investor Protection Corporation). Load and certain no-load mutual funds pay annual
distribution charges, sometimes referred to as 12b-1 fees. 12b-1 fees come from fund assets,
therefore, indirectly from your assets. Since neither Schwab nor LPL Financial refund 12b-1s into Total
Clarity accounts, it is recommended that mutual fund share classes that pay 12b-1s not be held in
Total Clarity accounts at these custodians unless there is no comparable non 12b-1 paying share class
available.
Your Advisory Representative will receive commissions through LPL for the purchase of Alternative
Investments that are held in the account. Alternative investments typically pay a higher commission
than other securities products. Therefore, there is an incentive to recommend alternative investments
over other securities products. This is a conflict of interest. Further, total compensation received by
advisory representatives including commissions and advisory fees on the other holdings in the account
could approach or exceed 3% which is considered excessive by industry standards. To mitigate this
conflict of interest you are informed of these conflicts.
Total Clarity receives no portion of the above mentioned 12b-1 fees or commissions from Alternative
15
Investments. You are able to purchase the securities recommended by Total Clarity directly or through
other brokers or agents not affiliated with Total Clarity for a similar or lower cost.
Termination of a Total Clarity Vision or Vision CB Account
In the event an account is closed, the advisory fee will be calculated based on the value of the account
on the date the fees were assessed, and the termination date (or the date the assets were transferred
out of the account). The fee charged will be a pro-rata portion of the advisory fee for the quarter up to
the date assets are transferred out of the account (termination date). This is equal to (the number of
days the account was open) / (number of days in the quarter) multiplied by the fee for the full quarter.
Any refund due will be calculated based on the fee previously paid for the quarter minus the pro-rata
fee described above. Refunds will be credited to the account from which the management fees were
pulled or a check will be mailed to the client's address of record. We will also refund any flat fees paid
in advance a pro-rated portion based on the fee multiplied by (the number of days the account was
open) / (number of days in the quarter).
The Vision and Vision CB Account Agreements can be terminated by either party upon receipt of
written or verbal notice of termination. Termination by a Client is effective upon receipt of the notice by
Total Clarity unless a specific date is requested in the notice. You may terminate the agreement
without penalty within 5 days of signing the account agreement. If you terminate an account(s) within
the first calendar year after opening the account(s), you will be charged a $200 administrative fee
which will be deducted from any refund of fees. This fee can be waived at Total Clarity's sole
discretion. This fee is not charged on accounts that are closed due to a transfer of the assets to
another Total Clarity account. This fee will be paid in the same manner as the Asset-Based Fee or an
invoice will be sent to the client if the assets are no longer in the account. After one calendar year, if an
account is terminated, Total Clarity will refund any advisory fees charged in advance based on a pro-
rata calculation, as described above.
Upon termination, early redemption fees or similar fees for mutual funds or other products held in the
account will be applicable as described in the fund's prospectus. Some broker-dealers will not accept
certain assets that are held in your account. Total Clarity will use reasonable efforts to follow your
instructions regarding the disposition of the assets in your account to the extent permitted by law and
policies of the firm. Please Note: Total Clarity will discontinue billing after the date specified in the
termination notice even if the assets are still in the account, but Total Clarity and our Advisory
Representatives have no fiduciary responsibilities for the account once the Total Clarity Agreement
has been terminated.
Conflicts of Interest
Advisory Representatives recommending clients participate in the Total Clarity Vision or Vision CB
Account programs will receive compensation as a result of a client's participation in the program. The
amount of compensation paid to Total Clarity Wealth Management and the Advisory Representative
could be more than what Total Clarity and the Advisory Representative would have received if the
client participated in other programs available through another broker/dealer or paid separately for
investment advice, brokerage and other services. Clients are advised that Advisory Representatives
have a financial incentive to recommend a wrap fee program (i.e., Total Clarity Vision Account or Total
Clarity Vision CB Account) over other programs or services.
LPL covers costs for certain trainings and conferences, including travel, accommodations, and
conference fees, based on production. You are advised there is an incentive for Total Clarity and your
Advisory Representative to recommend LPL over other Broker/Dealers based on the products and
services that they will receive rather than your best interest.
These products and services are provided to Total Clarity as part of its overall relationship with LPL
16
Financial and Schwab. While as a fiduciary Total Clarity endeavors to act in its clients' best interests,
the receipt of these benefits creates a conflict of interest because Total Clarity's recommendation that
clients custody at one of these custodians is based in part on the benefit Total Clarity received from
these services and products and not solely on the nature, cost or quality of custody or brokerage
services provided by LPL or Schwab. Total Clarity's receipt of some of these benefits is based on the
amount of advisory assets custodied at each of these platforms.
Total Clarity and Advisory Representatives buy and sell securities for themselves that are also
recommended and bought or sold for Clients. Total Clarity Wealth Management, its officers,
employees and Advisory Representatives are directed to not trade ahead of clients or trade in such a
way as to obtain a better price for themselves than for clients.
To mitigate these conflicts of interest, this disclosure has been provided to you. If you have any
concerns about the appropriateness of your Advisory Representative's recommendations based on
your financial situation, you should discuss these recommendations with another financial professional.
Item 5 ACCOUNT REQUIREMENTS & TYPES OF CLIENTS
Minimum Account Size
Total Clarity requires a minimum amount of assets to be held in an account for the purpose of
obtaining asset management services. A minimum deposit of $10,000 (cash or securities) to a
brokerage account is necessary in order to participate in investment advisory services.
However, under certain circumstances, Total Clarity waives the minimum investment size requirement
and accepts clients with less than $10,000. Such circumstances include but are not limited to,
situations in which additional assets will soon be deposited; or when the client has other accounts with
Total Clarity since the consolidation of these accounts for the purposes of quarterly fee calculations
would bring the value of the accounts closer to a fee schedule breakpoint, or the client has expressed
a desire to have all of their accounts in the same program and custodian.
Smaller accounts are defined as accounts holding less than $25,000 in assets. Clients are advised that
performance will be affected more in these accounts due to the difficulties with diversifying smaller
accounts and risk controls being compromised. Performance of smaller accounts varies from the
performance of accounts with more dollars invested because fluctuations in the market have a greater
impact.
Total Clarity Wealth Management does not represent, warrantee or imply that the services or methods
of analyses used by Total Clarity can or will predict future results, successfully identify market tops or
bottoms, or insulate clients from losses due to major market corrections or crashes. No guarantees can
be offered that a client's goals or objectives will be achieved. Further, no promises or assumptions can
be made that the advisory services offered by Total Clarity Wealth Management will provide a better
return than other investment strategies.
Clients
Total Clarity's generally offers the Total Clarity Vision and Vision CB Account programs to individuals
and high net worth individuals, trusts, estates, charitable organizations, corporations or other business
entities.
Item 6 PERFORMANCE-BASED FEES
This section is not applicable to Total Clarity since Total Clarity does not charge performance based
fees.
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Item 7 TYPES OF CLIENTS
Total Clarity's services are geared toward individuals and high net worth individuals, trusts, estates,
charitable organizations, corporations or other business entities.
The minimum investment required in the Total Clarity Asset Management Program is generally
$10,000 for investment advisory accounts. Accounts below these minimums will be accepted on an
individual basis at our discretion. Such circumstances include, but are not limited to either additional
assets will soon be deposited or the client has other accounts with Total Clarity. You should be aware
that in smaller accounts, performance will suffer due to difficulties with diversification of assets and risk
controls being compromised.
Item 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF
LOSS
8 A. Total Clarity's Advisory Representatives (IARs) act as portfolio managers for their advisory clients.
In that role, they use various investment strategies to reach the Clients' goals and manage investment
risk by conducting economic analyses and attempting to identify relevant market trends. Additionally,
IARs conduct fundamental analyses, which generally involves assessing a company's or security's
value based on factors such as sales, assets, cash flow, market position, expected growth,
management, products and services, earnings, and financial structure.
As stated in Item 4 of the Total Clarity ADV 2A, IARs are independent contractors of Total Clarity and
each IAR has their own method of analysis and philosophy of management. There is no one method or
analysis that can predict future market events or will prevent loss. The experience and level of
education of IARs varies and the type of management style varies. Therefore, investment performance
and asset allocations will vary. Some IARs use software and investment analyzing tools that include
projections of returns based on historical information and speculate future tax, educational expense,
social security, etc. conditions, payments, and costs. These systems are a guideline only and cannot
be relied upon to provide complete accuracy or assurances. Your account can also be based on a
portfolio model provided through the custodian. These models have the ability to be modified by your
Advisory Representative who can use the model for a portion of the account or for all of the account.
These models are a guideline and are managed by a third party, but your Advisory Representative is
the one who makes all decisions and trades. Advisory Representatives may also use Separately
Managed Accounts which are managed by LPL Financial or a third party manager or firm. Internal
costs for the holdings in either of these model portfolios could be higher than for other available mutual
funds or ETFs.
Investment strategies are also used by IARs to strive to improve the performance and balance the risk
of an account. Asset allocation is one of the strategies all Advisors use to attempt to optimize the risk
and reward of your portfolio by investing among several asset classes. However, it cannot prevent or
insulate a portfolio from market fluctuations or risk.
While not a standard analysis method used by our Advisors, some Advisors offer services that attempt
to time security performance. This essentially means they try to purchase or sell immediately
preceding an increase or decrease in a security's price. This type of investing can substantially
increase the amount of your brokerage transaction costs due to a higher trading frequency. Also, many
mutual funds or variable annuities prohibit excessive trading within their fund in a short period of time.
Total Clarity monitors client accounts for excessive trading as well as to ensure investments are
appropriate for each client.
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8 B. It is important to understand that investing in securities involves risk of loss, including the possible
loss of the principal money you are investing. Therefore, your participation in any of the management
programs offered by Total Clarity requires you to be prepared to bear the risk of loss as well as the
fluctuating performance of your accounts. The market values of investments are subject to fluctuations
based on market conditions.
We do not represent, warrantee or imply that the services or methods of analysis we use can or will
predict future results, successfully identify market tops or bottoms or insulate you from losses due to
major market corrections or crashes. Past performance is no indication of future performance. No
guarantees can be offered that your goals or objectives will be achieved. Further, no promises or
assumptions can be made that the advisory services offered by Total Clarity or our Advisory
Representatives will provide a better return than other investment strategies.
The table below describes some of the risks associated with most types of investing, followed by in 8
C, some investment products used in our advisory programs and have risks unique to that particular
investment:
Management
Risk
The services we offer involve your Advisor developing and implementing an investment
strategy for you. A profitable investment strategy inherently involves making decisions
about the future behavior of the securities markets as a whole as well as markets for
individual securities. Because there is no available method to accurately predict future
market behavior, there is no guarantee that any specific investment strategy will be
successful.
Market Risk
This is the risk that the value of any security could go up or down at any time due to factors
affecting securities markets in general or particular industries.
Interest Rate
Risk
This risk affects fixed income securities which can decline in value because of an increase
in interest rates; a bond or fund with a longer duration will be more sensitive to rate
fluctuations.
Credit Risk
This is the risk that an investor could lose money if the issuer of a fixed income security is
unable or unwilling to meet its financial obligations.
Certain investment strategies are concentrated in a specific sector or industry. Portfolios
using this strategy are more likely to sharply increase or decrease in value with changes in
the market. Concentrated strategies are more volatile because the risk associated with
each company or sector represents a large percentage of your overall portfolio value.
Concentrated
Investment
Strategy
Risk
8 C. The following are types of investments and related risks that Total Clarity Advisors use in client
portfolios:
Mutual Funds:
The risks with mutual funds include the costs and expenses within the fund that can impact
performance, change of fund managers and/or the fund straying from its stated investment
objective. Open ended mutual funds do not typically have a liquidity issue and the price does
not fluctuate throughout the trading day. Interval funds are also used in Total Clarity accounts.
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Interval Funds: These are a type of mutual fund product that traditionally invests in real estate. Interval Funds
have limited liquidity and could have periods of no liquidity. These funds will typically offer to
repurchase (or buy back) a portion of shares from shareholders pursuant to restrictions noted
in the prospectus. Such restrictions may be a limited buy back percentage, specific timeframes
to make redemptions, applicable redemption fees or ability by the sponsor company to deny
redemption requests, therefore, they are considered to have a higher risk and reduced
liquidity. Mutual fund fees and interval fund fees are described in the fund's prospectus, which
will be mailed or emailed directly to the client following any purchase of a mutual fund that is
new to the client's account. In addition, a prospectus is available online at each mutual fund
company's web site. At the client's request, Total Clarity will direct the client to the appropriate
web page to access the prospectus.
Equity
Securities
In general, prices of equity securities are more volatile than fixed income securities, and
respond to a number of factors that can affect entire financial markets or industries.
Options:
Certain types of option trading are permitted in order to generate income or hedge a security;
namely, the selling (writing) of covered call options or the purchasing of put options on a
security. The use of options involves additional risks. The risks of covered call writing include
the possibility for the market to rise sharply and the security could get called away. The risk of
buying long puts is limited to the loss of the premium paid for the put if the option is not
exercised or otherwise sold.
The shares of an ETF commonly represent an interest in a portfolio of securities that track an
underlying benchmark or index. A leveraged ETF generally seeks to deliver multiples of the
daily performance of the index or benchmark that it tracks. An inverse ETF generally seeks to
deliver the opposite of the daily performance of the index or benchmark that it tracks. Inverse
ETFs often are marketed as a way for investors to profit from, or at least hedge their exposure
to, downward-moving markets. Some ETFs are both inverse and leveraged, meaning that they
seek a return that is a multiple of the inverse performance of the underlying index. To
accomplish their objectives, leveraged and inverse ETFs use a range of investment strategies,
including swaps, futures contracts and other derivative instruments.
Exchange-
Traded Funds
(ETFs)
ETFs (including leveraged, inverse, and leveraged inverse) trade on an auctionable
market. Therefore, there is more price fluctuation with ETFs than with mutual funds since
ETFs trade throughout the day, whereas mutual funds are priced once a day. Also, since
most ETFs only mirror a market index, such as the S&P 500, they won't outperform the index.
A significant amount of principal could be lost in these securities rapidly and tax laws could
change and affect the tax treatment of this investment.
Traditional ETFs are generally not actively managed. This means that securities in the portfolio
will not be purchased or sold in attempt to take advantage of changing market conditions. A
traditional ETF continues to hold securities even though their market value and dividend yields
have changed. An ETF generally carries the same investment risk as the portfolio of securities
within the ETF. Securities in a portfolio can depreciate, and the ETF does not achieve its
intended objective. In addition, each ETF is subject to specific risks that vary depending on
each ETF’s investment objectives and portfolio composition. Additionally, while premiums and
discounts from net asset value (“NAV”) are generally small among ETFs, there is a risk for
severe dislocation from NAV.
The use of leverage in an investment portfolio can magnify any price movements, resulting in
high volatility and significant loss of principal. ETFs do not track the underlying Index due to
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imperfect correlation between the ETF’s portfolio securities and those in the underlying Index,
rounding prices, changes to the underlying Index and regulatory requirements. This risk is
heightened during times of increased market volatility or other unusual market conditions.
Tracking error also results because the ETF incurs fees and expenses while the underlying
Index does not.
Non-traditional ETFs, including leveraged and inverse ETFs, are not suitable for most
investors. Non-traditional ETFs are trading vehicles in which daily rebalancing and market
volatility have a significant impact on the realized return. The effects of mathematical
compounding can grow significantly over time, leading to scenarios whereby performance over
the long run can differ significantly from the performance (or inverse performance) of their
underlying index or benchmark during the same period of time. Leveraged, inverse, and
leveraged inverse ETFs are more volatile and riskier than traditional ETFs due to their
exposure to leverage and derivatives, particularly total return swaps and futures. In addition,
these instruments are typically designed to achieve their desired exposure on a daily (in a few
cases, monthly) basis. Holding leveraged, inverse, and leveraged inverse ETFs for longer
periods of time increases their risk due to the effects of compounding and the inherent
difficulty in market timing. Non-traditional ETFs are volatile and not suitable for all investors.
Positions in non-traditional ETFs should be monitored closely due to their volatile nature and
inability to track the underlying index over an extended period of time. Non-traditional ETFs
are not intended to be held long term. ETFs over a period longer than one day can differ
significantly from their stated performance objectives.
Some ETFs are thinly traded which could impact the ability to sell shares quickly. Non-
traditional ETFs and futures-linked ETFs enter into total return swaps with a counter party. If
the counterparty becomes unable to deliver its share of the contract, it will default on the swap,
therefore negatively affecting the value of the non-traditional ETFs.
Structured
Products:
Used less frequently, 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. Depending upon the underlying asset or product, there can be different risks
associated with the product. An investor in a structured product never has a claim on the
underlying investment. There may be little or no secondary market. Tax treatment may be
different than other investments. Structured CDs that are insured by the FDIC are subject to
applicable FDIC limits.
Alternative
Investments:
Non-traded Real Estate Investment Trusts (REITs), non-traded Business Development
Companies (BDC’s), limited partnerships, and direct alternatives are subject to various
risks such as limitations on liquidity ( can take 30 days or more to liquidate), pricing
mechanisms, and specific risk factors associated with the particular product, which for
products associated with real estate, would include but not limited to, property
devaluation based on adverse economic and real estate market conditions. Redemption
can be at more or less than the original amount invested. As a result, they are not
suitable for all investors. A prospectus that discloses all risks, fees and expenses, and
risk factors, will be provided by your Advisor. Please read the prospectus carefully
before investing. Investors considering Alternative Investments should understand that
they are generally considered speculative in nature and involve a high degree of risk,
particularly if concentrated within one industry. These risks are greater and substantially
different than those associated with traditional equity or fixed income investments. The
products are risky and for sophisticated investors only who meet qualified investor
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requirements. Further, these products are sold on a commission basis through a
broker/dealer. Therefore, IARs will receive commissions and such commissions are
higher than other securities products. This is a conflict of interest. To mitigate this
conflict of interest we are informing you of this information and encourage you to read
offering memorandums.
Variable
Annuities
For variable annuities held within Total Clarity accounts, your variable annuity contract has
exclusions, limitations, reductions of benefits and terms under which the contract will be
continued in force or be discontinued. Be sure to discuss costs and the complete details of
coverage with your Advisor. Guarantees of the annuity are backed by the financial strength of
the underlying insurance company. Investment sub-account value will fluctuate with changes
in market conditions. As stated above, variable products are complex products with higher
costs. Further, variable products pay higher commissions than other securities products. This
creates a conflict of interest. To mitigate this conflict of interest we only allow advisory class
Variable Annuities to be held in Total Clarity accounts. These variable annuities do not pay
commissions to your Advisory Representative, but Variable Annuities purchased outside of
your Total Clarity agreement through your Advisory Representative do pay higher
commissions than other security products. This creates a conflict of interest for your IAR to sell
you a Variable Annuity that is not part of your Total Clarity account. To mitigate this conflict of
interest we encourage you to read the offering memorandum for any variable annuity you
purchase and are informing you of this information.
Item 9 ADDITIONAL INFORMATION
Disciplinary Information & other Financial Industry Activities & Affiliations
There is no reportable disciplinary information required for Total Clarity or its management persons
that is material to your evaluation of Total Clarity, its business or its management persons.
Total Clarity does not have a related person who is a: broker/dealer or other similar type of broker or
dealer; investment company or other pooled investment vehicle, other investment adviser, futures
commission merchant or commodity pool operator; banking or thrift institution; insurance company or
agency; pension consultant; real estate broker or dealer; or sponsor or syndicator of a limited
partnership. We do have an affiliated person who is a lawyer, and one who is a CPA. You are under no
obligation to use these services. The three principal owners of Total Clarity also own an advisor
services company which recruits, trains, supports and supervises representatives of LPL Financial.
One of the principal owners is also an owner of an accounting and tax practice, Exemplar Accounting
and Tax Advisors, Inc. (EATA). Advisory Representatives refer clients to EATA, which results in a
conflict of interest, whereby an owner benefits from clients utilizing services of both companies. You
are under no obligation to purchase accounting services through EATA.
Certain Advisory Representatives are dually registered as Advisory Representatives of Total Clarity
and as Registered Representatives of LPL. LPL is independently owned and operated and is not
affiliated with Total Clarity. You are under no obligation to purchase or sell securities through your
Advisory Representative. However, if we develop a financial or retirement plan for you and you choose
to implement the plan with our assistance, commissions on brokerage business will be earned in
addition to any fees you paid for the other advisory services. Commissions could be higher or lower at
LPL than at other broker/dealers. Advisory Representatives will have a conflict of interest in having you
purchase securities and/or insurance related products through LPL in that the higher their production
with LPL the greater the potential for obtaining a higher payout on commissions earned.
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Under the rules and regulations of FINRA, LPL has an obligation to perform supervisory functions
regarding certain activities engaged in by Advisory Representatives who are also Registered
Representatives of LPL. Additionally, certain of our Advisory Representatives are also Advisory
Representatives with LPL. This is only allowed under limited exceptions. Due to these relationships
with LPL, LPL Financial will have access to certain confidential information such as financial
information, investment objectives, transactions and holdings, about Total Clarity's clients, even if the
client does not establish an account through LPL. If you would like a copy of the LPL Financial Privacy
Policy, please contact Total Clarity's Home office at 630-762-9352 LPL will receive a portion of our
advisory fees from our clients' accounts that are held at Schwab. There is no affiliation between Total
Clarity and LPL or Schwab.
Advisory Representatives are licensed with various insurance companies. This is a conflict of interest
since your Total Clarity adviser will earn commissions if you purchase insurance products through
them. You are under no obligation to purchase insurance products or services through your Advisory
Representative.
Total Clarity attempts to mitigate the conflicts of interest relating to the receipt of commissions by
providing you with these disclosures.
Code of Ethics
Total Clarity has a fiduciary duty to you to act in your best interest and always place your interests first
and foremost. Total Clarity takes seriously its compliance and regulatory obligations and requires all
staff to comply with such rules and regulations as well as our policies and procedures. We strive to
handle your non-public information in such a way as to protect it from falling into the hands of anyone
who has no business reason to know such information. We provide you with our Privacy Policy which
details our procedures for handling your personal information.
Total Clarity maintains a Code of Ethics for its Advisory Representatives, supervised persons and
office staff. The Code of Ethics contains provisions for standards of business conduct in order to
comply with federal securities laws, personal securities reporting requirements, pre-approval
procedures for certain transactions, code violation reporting requirements, and safeguarding of
material non-public information about your transactions. Our Code of Ethics establishes our firm's
expectation for business conduct. A copy of our Code of Ethics will be provided to you upon request.
Neither Total Clarity nor its associated persons recommend buys or sells for client accounts any
securities in which they have a material financial interest. Total Clarity and its associated persons buy
or sell securities identical to those securities recommended to you. They will not put their interests
before your interest. Total Clarity and any associated person are directed to not trade ahead of you or
trade in such a way as to obtain a better price for themselves than for you or other clients.
Total Clarity is required to maintain a list of all securities holdings for its associated persons and
develop procedures to supervise the trading activities of associated persons who have knowledge of
your transactions and their related family accounts at least quarterly. Further, associated persons are
prohibited from trading on non-public information or sharing such information.
You have the right to decline any investment recommendation. Total Clarity and its associated persons
are required to conduct their securities and investment advisory business in accordance with all
applicable Federal and State securities regulations.
Review of Accounts
As part of the Total Clarity Vision and Vision CB Account programs, your accounts will be reviewed at
least quarterly and you will be contacted not less than annually for a review meeting. You are advised
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that you must notify your Advisory Representative promptly of any changes to your financial goals,
objectives or financial situation as such changes will require him to review the portfolio allocation and
make recommendations for changes. Each Advisory Representative is responsible for ensuring timely
reviews and suitable recommendations. The level of experience of Advisory Representatives will vary.
You will be provided statements at least quarterly directly from the custodian. These reports are
provided from Schwab or from LPL Financial, depending on where your account is held. Additionally,
you will receive confirmations of all transactions that occur within your account directly from Schwab or
from LPL. If contracted, Total Clarity provides a report every quarter showing all holdings within each
account, along with performance data for each account beginning either on 01/01/12, or from the date
of its inception, if the account was opened after that time. This is due to a change of reporting systems
to Morningstar Office. Total Clarity uses Orion Advisor for reporting as of 02/01/21. Total Clarity does
not provide these reports to Vision CB accounts.
You should compare the report you receive from Total Clarity with statements received from the
account custodian. Should there be any discrepancy between reports, the account custodian's report
will prevail.
Client Referrals & Other Compensation
Product vendors recommended by Total Clarity provide monetary and non-monetary assistance with
client events in addition to providing educational tools and resources. Advisory Representatives do not
select products as a result of any monetary or non-monetary assistance. Total Clarity's due diligence of
a product does not take into consideration any assistance it receives. The suitability and quality of a
product for our clients is of first and foremost importance.
Total Clarity may enter into solicitor arrangements pursuant to which it compensates third-party
intermediaries for client referrals that result in the provision of investment advisory services by Total
Clarity. Total Clarity will disclose these solicitation arrangements to affected investors, and any cash
solicitation arrangements will comply with Rule 206(4)-3 of the Advisers Act. Solicitors introducing
clients to Total Clarity may receive compensation from Total Clarity, such as a retainer, a flat fee per
referral and/or a percentage of introduced capital or of the advisory fee prior to payment to the
Advisory Representative. Such compensation will be paid pursuant to a written agreement with the
solicitor and generally may be terminated by either party from time to time. The cost of any such fees
will be borne entirely by Total Clarity and not by any affected client.
Custody
The account custodian will directly debit your account(s) for the payment of our advisory fees. This
ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over
your funds or securities. We do not have physical custody of any of your funds and/or securities. Your
funds and securities will be held with a bank, broker-dealer, or other qualified custodian. You will
receive account statements from the qualified custodian(s) holding your funds and securities at least
quarterly. The account statements from the account custodian will indicate the amount of our advisory
fees deducted from your account(s) each billing period. You should carefully review account
statements for accuracy.
Standing Letter of Authorization
When requested, our firm, or Advisory Representatives, will effect ACHs from client accounts to one or
more third parties designated, in writing, by the client without obtaining written client consent for each
separate, individual transaction, as long as the client has provided us with written authorization to do
so. Such written authorization is known as a Standing Letter of Authorization. An adviser with authority
to conduct such third-party transfers has access to the client's assets, and therefore has custody of the
client's assets in any related accounts.
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However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by
reason of having custody, as long as the following criteria are met:
1. You provide a written, signed instruction to the qualified custodian that includes the third party’s
name and address or account number at a custodian;
2. You authorize us in writing to direct transfers to the third party either on a specified schedule or from
time to time;
3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a transfer
of funds notice to you promptly after each transfer;
4. You can terminate or change the instruction;
5. We have no authority or ability to designate or change the identity of the third party, the address, or
any other information about the third party;
6. We maintain records showing that the third party is not a related party to us nor located at the same
address as us; and
7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an
annual notice reconfirming the instruction.
When we engage in third party standing letters of authorization, Total Clarity complies with the
conditions of the safe harbor provisions and is therefore exempt from the annual surprise exam
requirement for Advisers that have custody.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position
it should have been in had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation reimbursing the account and/or
applying a credit toward advisory fees.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you
are eligible to participate in class action settlements or litigation nor do we initiate or participate in
litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or
negligence by issuers of securities held by you.
Financial Information
Total Clarity will not require you to prepay more than $1,200 and six or more months in advance of
receiving the advisory service; therefore, a balance sheet is not required to be attached. Total Clarity
has limited discretionary authority over client accounts; however, that authority does not extend to the
withdrawal of any client assets, with the exception of the deduction of Total Clarity's advisory fees from
your accounts.
We are financially stable. There is no financial condition that is likely to impair our ability to meet our
contractual commitment to you or any other client. Neither Total Clarity nor any of its Advisory
Representatives has ever been the subject of a bankruptcy petition.
Other Compensation
Product vendors recommended by Total Clarity provide monetary and non-monetary assistance with
client events in addition to providing educational tools and resources. We do not select products as a
result of any monetary or non-monetary assistance. The suitability and quality of a product is of first
and foremost importance. Total Clarity's due diligence of a product does not take into consideration
any assistance it receives.
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In their role as Registered Representatives of LPL Financial, some of our Advisory Representatives will
earn commissions. The amount of commissions paid by LPL to the Representative will fluctuate based
on overall production. Therefore, the more business placed by them through LPL will enable them to
reach another threshold and earn a higher payout.
LPL Financial provides various benefits and payments to Dually Registered Persons that are new to
the LPL Financial platform to assist the representative with the costs (including foregone revenues
during account transition) associated with transitioning his or her business to the LPL Financial
platform (collectively referred to as "Transition Assistance"). The proceeds of such Transition
Assistance payments are intended to be used for a variety of purposes, including but not necessarily
limited to, providing working capital to assist in funding the Dually Registered Person's business,
satisfying any outstanding debt owed to the Dually Registered Person's prior firm, offsetting account
transfer fees (ACATs) payable to LPL Financial as a result of the Dually Registered Person's clients
transitioning to LPL Financial's custodial platform, technology set-up fees, marketing and mailing costs,
stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and
termination fees associated with moving accounts.
The amount of the Transition Assistance payments is often significant in relation to the overall revenue
earned or compensation received by the Dually Registered Person at the prior firm. Such payments
are generally based on the size of the Dually Registered Person's business established at the prior firm
and/or assets under custody with LPL Financial. There is a conflict of interest for representatives to
select a broker/dealer based on the amount of transition assistance to be received. Furthermore, LPL
Financial provides the transition assistance in the form of a forgivable note. The transition assistance
dollars are forgiven over a five year period based on the representative remaining with LPL Financial.
Therefore, there is a conflict of interest for the representative to remain with LPL Financial when it is
not in the best interests for clients because of the forgivable note period having not expired.
LPL Financial also rewards representatives for achieving production thresholds by covering expenses
to various conferences and offering award conferences. This is considered a conflict of interest.
Total Clarity and your Advisory Representative attempt to mitigate any conflicts of interest by
evaluating and recommending that clients use LPL services based on the benefits that each service
provides to their clients, rather than to the Transition Assistance earned by them. We also try to
mitigate the risks by having multiple choices in where to custody your accounts. Lastly to help mitigate
the conflicts of interest, this disclosure has been provided to you.
If you have any concerns about the appropriateness of your Advisory Representative's
recommendations based on your financial situation, you should discuss these recommendations with
another financial professional.
Item 10 REQUIREMENTS FOR STATE-REGISTERED ADVISERS
This section is not applicable to Total Clarity. Total Clarity is not state registered. Total Clarity is
registered with the Securities and Exchange Commission.
Should you have any questions regarding our Wrap Fee Brochure or any other document you have
received from Total Clarity, please speak with your Advisory Representative.
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