VERITY INVESTMENT PARTNERS

FORM ADV PART 2A Firm Brochure Verity and Verity, LLC d/b/a Verity Investment Management Principal Office 2015 Boundary Street, 2nd Floor Beaufort, South Carolina, 29902 Verity Investment Management 210 Bluffton Road, 2nd Floor Bluffton, SC 29910 Phone: 843-288-0242 https://www.verityim.com/ March 13, 2026 This brochure provides information about the qualifications and business practices of Verity Investment Management. If you have any questions about the contents of this brochure, please contact us at: 843-379-6661 or by email at info@verityvip.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 Verity Investment Management is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable CRD number for Verity Investment Management is 119630 and the SEC File Number is 801-63829. Verity Investment Management is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Verity & Verity, LLC 1  Item 2 Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Verity and Verity, LLC has not made any material changes to this brochure since our last filing in March 2025. Verity & Verity, LLC 2  Item 3 Table of Contents Item 2 Summary of Material Changes ................................................................................... 2 Item 3 Table of Contents ....................................................................................................... 3 Item 4 Advisory Business ...................................................................................................... 4 Item 6 Performance-Based Fees and Side-By-Side Management ........................................ 6 Item 7 Types of Clients .......................................................................................................... 7 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................... 7 Item 9 Disciplinary Information .............................................................................................. 8 Item 10 Other Financial Industry Activities and Affiliations .................................................... 8 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................................................................................................................................... 8 Item 12 Brokerage Practices ................................................................................................. 9 Item 13 Review of Accounts ................................................................................................ 10 Item 14 Client Referrals and Other Compensation .............................................................. 11 Item 15 Custody ................................................................................................................... 11 Item 16 Investment Discretion ............................................................................................. 11 Item 17 Voting Client Securities ........................................................................................... 12 Item 18 Financial Information .............................................................................................. 12 Item 19 Requirement for State-Registered Advisers ........................................................... 12 Item 20 Additional Information ............................................................................................. 12 Verity & Verity, LLC 3  Item 4 Advisory Business Description of Services Verity and Verity, LLC d/b/a Verity Investment Management and Verity Investment Partners is a registered investment adviser based in Beaufort, South Carolina with offices in Bluffton, South Carolina, Edwards, Colorado and San Antonio, Texas. We are organized as a limited liability company under the laws of the State of South Carolina. We have been providing investment advisory services since 2002. William W. Verity is our firm's principal owner. The following paragraphs describe the services offered through Verity Investment Management. Services offered through Verity Investment Partners are detailed in a separate ADV 2A Brochure. Please refer to the description of each investment advisory service listed below for information on our service offerings. As used in this brochure, the words "we", "our" and "us" refer to Verity Investment Management and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. We offer discretionary investment management services as a third-party manager or sub-advisory basis (referred to as “SMA” accounts in this brochure) and non-discretionary investment portfolios on a model delivery basis. Our investment portfolios are designed with the goal of providing an innovative income growth solution for institutions and financial professionals to utilize. We monitor our portfolio's performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions. We require you to grant our firm discretionary authority to manage your account if we are acting as a third-party manager or sub-advisor. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for accounts in our strategies without prior approval for each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, trading authorization forms, or sub- advisory agreements. You may not limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) when utilizing our services as a discretionary asset manager. Sub-Advisory Services to Registered Investment Advisers We serve as a sub-adviser to unaffiliated registered investment advisers per the terms and conditions of a written agreement. With respect to sub-advisory services, the unaffiliated investment advisers that engage our sub-advisory services maintain both the initial and ongoing day-to-day relationship with the account owner, including initial and ongoing determination of client suitability for our designated investment strategies. Third Party Asset Management Services We serve as a third-party asset manager to unaffiliated investment advisors and retail clients through various investment platforms or marketplaces. With respect to these services, we enact a tri-party agreement with the investment advisor, platform or marketplace and the end client. As part of this agreement, we only provide investment management services for our strategies and do not assess suitability of investments, investment objectives or maintain an ongoing day to day relationship with the account owner. Model Delivery: Investment Strategy and Research Services to Registered Investment Advisers We may provide our portfolios or investment recommendations to unaffiliated registered investment Verity & Verity, LLC 4  advisers (third party) for their use in managing their underlying clients’ accounts on a “Model Delivery” basis. Per the terms of the written agreement with the unaffiliated registered investment adviser, we do not have an advisory, fiduciary or other relationship with any of the third party’s underlying client(s). The unaffiliated registered investment adviser is exclusively responsible for determining the suitability of the model portfolio for their underlying client(s) and whether to implement any of the model portfolio trades or changes we recommend. investment management services Investment Management Services for Institutional Clients We offer our to Pension Plans, Endowments, Charitable Organizations and other types of Institutional Clients which may contract with us directly (“Direct Contract”) to utilize our investment strategies. The type of Investment Management Services utilized will be detailed in your agreement with our firm. Types of Investments In general, we offer advice on equity securities, ETFs, corporate debt securities, commercial paper, certificates of deposit, municipal securities, mutual funds, U.S. Government securities, interests in partnerships investing in real estate and oil and gas interests and other investments. You generally may not request that we refrain from investing in particular securities or certain types of securities in SMA accounts. Client Obligation In performing our services, Verity Investment Management shall not be required to verify any information received from the client or from the client's other professionals and is expressly authorized to rely thereon. Each client is advised that it remains his/her responsibility to promptly notify their investment advisor in writing if there is ever any change in his/her financial situation or investment objectives for the purpose of reviewing/evaluating/revising our services. If we are providing services to you through a Direct Contract or Model Delivery basis we request that you keep us advised of any changes of contact or other relevant information. Assets Under Management As of December 31, 2025, Verity provides continuous management services for $1,396,818,690 in client assets on a discretionary basis as well as $2,784,771 on a non-discretionary basis. Of this, all are assets managed by Verity Investment Management. As of December 31, 2025 Verity Investment Management also had $8,175,253 in Assets Under Advisement. Item 5 Fees and Compensation For the investment management services provided, VIM charges a fee to its clients. Fees are generally quoted on an annualized basis as a percentage of the client’s assets under management. Our standard fees and minimum account size are set forth below. The fee schedules stated below are all negotiable and vary by investment strategy, product type, account size, customization requirements and required service levels. Our standard fees and minimums for our service types are as follows: Service Type Sub-Advisor Third Party Asset Manager Model Delivery Direct Contract Fee 50 BPS / 0.50% 50 BPS / 0.50% 30 BPS / 0.30% Custom Minimum $100,000 $100,000 None Custom Verity & Verity, LLC 5  Basis Point Fee (BPS) amounts are an annual fee billed based on the assets under management. The advisory fees charged by VIM are confirmed in writing in the client’s (or their intermediary’s) investment advisory/sub-advisory agreement with us. Fees are typically charged as a percentage of the client portfolio’s AUM as of the last business day of the quarter, but we may agree with clients to other billing methodologies, including average monthly or daily valuation or billing in advance as deemed appropriate by us and memorialized in our agreement. Verity Investment Management may enter into various advisory agreements with investment advisers and other financial intermediaries or platforms with respect to investment programs they offer. Typically, we negotiate fees with the intermediaries, and not with individuals participating in such programs. Payment for our Fees is typically facilitated based on these contracts and may be incorporated into other fees charged by the intermediary. Fees for Direct Contract clients vary and are reflected in the Investment Management Contract with our firm. In cases where we deduct our fee directly from accounts through the qualified custodian holding the funds and securities, we will deduct our advisory fee only when we have written authorization permitting the fees to be paid directly from the account. Further, the qualified custodian will deliver an account statement to the account owner at least quarterly. These account statements will show all disbursements from the account. You may terminate any agreement with us at any time based on the termination clause of the agreement. You will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. Additional Fees and Expenses Our fees are exclusive of platform fees, investment marketplace fees, separate investment adviser fees, brokerage commissions, transaction fees, and other related costs and expenses. Clients are responsible for certain charges imposed by custodians, broker-dealers and other third parties, including but not limited to: fees charged by other investment advisors, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, withholding fees, country tax or delivery fees, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. We do not share in any portion of the fees charged by any outside party including brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost an account will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to the "Brokerage Practices" section of this brochure. Item 6 Performance-Based Fees and Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Performance- based fees are fees that are based on a share of capital gains or capital appreciation of a client's account. Our fees are calculated as described in the Advisory Business section above and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account. Verity & Verity, LLC 6  Item 7 Types of Clients VIM provides portfolio management services to a range of client types which can include: individuals; high net-worth individuals; corporations; corporate pension and profit-sharing plans; charitable institutions, foundations and endowments; registered investment companies; trust programs; other investment advisers; or other U.S. and international institutions. In general, we require a minimum of $100,000 to open and maintain an SMA account. Verity Investment Management, in its sole discretion, may charge a lesser investment management fee and/or waive the minimum account size. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: • Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company's industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. • Technical Analysis - involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. The risk of market timing based on technical analysis is that charts may not accurately predict future price movements. Current prices of securities may reflect all information known about the security and day to day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. • Long Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Long term purchases may be affected by unforeseen long-term changes in the company in which you are invested or in the overall market. Our strategies and investments may have unique and significant tax implications. However, tax efficiency is not our primary consideration in the management of our investment strategies. Moreover, as a result of revised IRS regulations, custodians and broker-dealers report the cost basis of equities acquired in client accounts on or after January 1, 2011. The account owner is responsible for contacting their tax adviser to determine if the cost basis method utilized by the custodian is the right choice for them. If the tax adviser believes another accounting method is more advantageous, the account owner should provide written notice to their custodian immediately. Please note that decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. It should not be assumed that the future performance investment strategies of any specific investment strategy (including the investments and/or Verity & Verity, LLC 7  recommended or undertaken by Verity Investment Management) will be profitable or equal to any specific performance level. Investment Risk Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments or investment strategies recommended or undertaken by Verity Investment Management) will be profitable or equal any specific performance level(s). Dividend Strategy Risk Clients invested in strategies designed to invest in dividend paying securities will be subject to certain risks. These include issuers which have historically paid dividends reducing or ceasing to pay dividends in the future, which could additionally negatively impact the price of the security. In times of economic stress, large amounts of issuers could reduce or eliminate dividends, impacting the ability of VIM to execute its desired strategy. Recommendation of Particular Types of Securities As disclosed under the "Advisory Business" section in this Brochure, we generally recommend equities with a history of dividend growth. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it. Item 9 Disciplinary Information Neither our firm nor any of our Associated Persons has any reportable disciplinary information. Item 10 Other Financial Industry Activities and Affiliations We are not related, through control or ownership, with any type of the following entities: • broker-dealer, municipal securities dealer, or government securities dealer or broker • investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) • other investment adviser or financial planner • futures commission merchant, commodity pool operator, or commodity trading advisor • banking or thrift institution • accountant or accounting firm • lawyer or law firm • pension consultant • real estate broker or dealer • sponsor or syndicator of limited partnerships We provide model portfolios or sub-advisory services to unaffiliated registered investment advisers (third party) for their use in or by directly managing their underlying clients’ accounts. The unaffiliated registered investment adviser is exclusively responsible for determining the suitability of the model portfolio for their underlying client(s) and whether to implement any of the model portfolios. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Verity & Verity, LLC 8  Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All of our Associated Persons are expected to adhere strictly to these guidelines. Our Code of Ethics also requires that certain persons associated with our firm submit reports of their personal account holdings and transactions to a qualified representative of our firm who will review these reports on a periodic basis. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this brochure. Participation or Interest in Client Transactions Neither our firm nor any of our Associated Persons has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in which you are already invested. We may also combine our orders to purchase securities with your orders to purchase securities ("block trading"). Please refer to the "Brokerage Practices" section in this brochure for information on our block trading practices. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that neither our Associated Persons nor we shall have priority over your account in the purchase or sale of securities. Item 12 Brokerage Practices Best Execution VIM has a fiduciary obligation to act, at all times, in the best interest of its clients and to seek best overall execution in client trading. For SMA accounts, the firm generally has the authority to execute trades through any broker-dealer, dealer and/or exchange it deems appropriate, and may negotiate commission and similar fees and expenses. seeks to affect transactions at the price, commission and other relevant factors that provide the most favorable total overall cost or proceeds reasonably attainable given the circumstances. VIM may consider various factors when selecting a broker-dealer, including but not limited to: the nature of the portfolio transaction; the size of the transaction; the client’s custodian, the execution, clearing and settlement capabilities of the broker-dealer; the broker- dealer’s experience and ability to execute trades; access to markets; the reputation, financial and credit strength and stability of the broker-dealer; availability of alternative trading platforms; the desired timing of the transaction, and confidentiality. The firm’s Investment Committee reviews best execution and trade practices at least quarterly during its investment committee meetings. Directed Brokerage Verity Investment Management may accept directed brokerage arrangements for its SMA accounts. In such directed arrangements, the client or their investment adviser will negotiate terms and arrangements for their account with their broker-dealer/custodian of choice, and VIM will not seek better execution services or prices from other broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers with orders for other accounts managed by VIM. As a result, a client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net Verity & Verity, LLC 9  prices, on transactions for the account than would otherwise be the case. Please Note: In the event that the client directs Verity Investment Management to effect securities transactions for the client’s accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative clearing arrangements. Higher transaction costs adversely impact account performance. Please Also Note: Transactions for directed accounts will generally be executed following a trade rotational policy for the execution of SMA account transactions. Order Aggregation/Block trades Transactions for each custodian or trade platform will generally be combined or “bundled" (aka block traded) to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among Verity Investment Management clients’ differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. These allocations are made at the custodian level. Verity Investment Management shall not receive any additional compensation or remuneration as a result of such aggregation. Verity Investment Management has implemented a trade rotation policy which defines the order in which each custodial or trade platform will be traded in a set rotational pattern. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Non-Soft Dollar Research and Additional Benefits Verity Investment Management may receive from various broker-dealer/custodians, investment managers, platforms or vendors, without cost (and/or at a discount) support services and/or products, certain of which assist Verity Investment Management to better access and trade client accounts maintained at such institutions. Included within the support services that may be obtained by Verity Investment Management may be investment-related research, pricing information and market data, software and other technology that provide access to client account data, trade execution services or discounts, compliance and/or practice management-related publications, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by Verity Investment Management in furtherance of its investment management operations. As indicated above, certain of the support services and/or products that may be received may assist Verity Investment Management in managing and administering client accounts. Others do not directly provide such assistance, but rather assist Verity Investment Management to manage and further develop its business enterprise. Verity Investment Management’s Chief Compliance Officer, Tanya Olvera, remains available to address any questions that a client or prospective client may have regarding the above arrangements and any corresponding perceived conflict of interest such arrangements may create. Item 13 Review of Accounts The firm’s Investment Management Team monitors account(s) on an ongoing basis to ensure that the portfolio management services provided are consistent with our stated strategy objectives. We do not continuously monitor client accounts for suitability of investment with personal financial goals and risk Verity & Verity, LLC 10  tolerance levels. We may provide you with written reports as requested. Reports we provide can include the following: asset allocation, portfolio summary, account performance and billing information. Account trade confirmations and monthly or quarterly statements are sent from your account custodian(s). Item 14 Client Referrals and Other Compensation Client Referrals Verity Investment Management participates in referral arrangements with affiliated and unaffiliated third parties, which are made in accordance with Rule 206(4)-1. Before we compensate a third party for referrals, clear and prominent disclosures are provided on the material terms of the compensation arrangement between the referral source and Verity, whether there is any affiliation between the referral source and Verity, and whether the client bears any costs with respect to the referral. Additionally, we disclose that fees paid by a referred client may differ from fees paid by other similarly situated clients who are not introduced to Verity through a referral. We strongly recommend prospective clients review the disclosures carefully to help address any potential conflicts of interest. Other Compensation As referenced in Item 12 above, Verity Investment Management may receive from various custodial or trade platforms, without cost (and/or at a discount), support services, research, and/or products. There is no corresponding commitment made by Verity Investment Management to any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of the above arrangements. VIM does not receive any additional compensation for our investment management services. Verity Investment Management’s Chief Compliance Officer, Tanya Olvera, remains available to address any questions that a client or prospective client may have regarding the above arrangements and any corresponding conflicts of interest such arrangements may create. Item 15 Custody In some instances where we are the sub-advisor or third-party asset manager, your independent custodian may 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 independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian (s) will indicate the amount of fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. Item 16 Investment Discretion Verity Investment Management receives discretionary authority for sub-advisory and third party asset management Clients to select the identity and quantity of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the investment strategy being utilized. Please refer to the "Advisory Business" section in this brochure for more information on our discretionary management services. Verity & Verity, LLC 11  Item 17 Voting Client Securities Proxy Voting As a matter of policy and practice, we do not vote proxies on behalf of clients. In most cases, you will receive proxy materials directly from the account custodian. 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. Item 18 Financial Information We are not required to provide financial information to our clients because we do not: • require the prepayment of more than $1,200 in fees and six or more months in advance, or • take custody of client funds or securities, or • have a financial condition that is reasonably likely to impair our ability to meet our commitments to you. Item 19 Requirement for State-Registered Advisers Our firm is SEC registered therefore this section is not applicable. Item 20 Additional Information Information Security Information We view protecting your private information as a top priority. Pursuant to applicable information security requirements, we have instituted policies and procedures to ensure that we reduce the risk regarding your personal and confidential information being breached. Your Privacy We do not disclose any nonpublic personal information about you to any non-affiliated third parties, except as permitted by law or required to complete our contracted services. In the course of managing your account, we may share some information with our service providers, such as transfer agents, custodians, broker-dealers, or fin-tech platforms. We restrict internal access to nonpublic personal information about you to employees, who need that information to provide products or services to you. We maintain physical and procedural safeguards that comply with regulatory standards to guard your nonpublic personal information and to ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone. We do not share your information unless it is required to process a transaction, at your request, or required by law. You will receive a copy of our privacy notice prior to or at the time you sign an agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Please contact our main office at the telephone number on the cover page of this brochure if you have any questions regarding this policy. Trade Errors Verity & Verity, LLC 12  On occasion, VIM, a broker-dealer, or a third party will make an error when ordering, executing, or settling a securities transaction on behalf of a client account. In accordance with its fiduciary obligation to each client, when a trade error is the fault of VIM, we will seek to correct trade errors promptly, fairly, and consistently. VIM will not correct an error in a manner which favors one client at the expense of another client. Our policy is to reimburse a client for a loss resulting from a VIM error or subsequent VIM actions taken to correct the error in the client’s account. Verity & Verity, LLC 13 

FORM ADV PART 2A Firm Brochure Verity and Verity, LLC d/b/a Verity Investment Partners 2015 Boundary Street, 2nd Floor Beaufort, South Carolina, 29902 Phone: 843-379-6661 https://verityvip.com/ March 13, 2026 This brochure provides information about the qualifications and business practices of Verity Investment Partners. If you have any questions about the contents of this brochure, please contact us at: 843-379-6661 or by email at info@verityvip.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 Verity Investment Partners is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable CRD number for Verity Investment Partners is 119630 and the SEC File Number is 801-63829. Verity Investment Partners is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Verity & Verity, LLC 1  Item 2 Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last filing in March of 2025 we have made the following changes: Item 5 – Fee Billing: We have removed our minimum fee for accounts under our standard account value threshold. Verity & Verity, LLC 2  Item 3 Table of Contents Item 2 Summary of Material Changes ................................................................................... 2 Item 3 Table Of Contents ....................................................................................................... 3 Item 4 Advisory Business ...................................................................................................... 4 Item 5 Fees and Compensation ............................................................................................. 6 Item 6 Performance-Based Fees and Side-By-Side Management ........................................ 8 Item 7 Types of Clients .......................................................................................................... 8 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................... 8 Item 9 Disciplinary Information ............................................................................................ 10 Item 10 Other Financial Industry Activities and Affiliations .................................................. 10 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................... 10 Item 12 Brokerage Practices ............................................................................................... 11 Item 13 Review of Accounts ................................................................................................ 13 Item 14 Client Referrals and Other Compensation .............................................................. 14 Item 15 Custody ................................................................................................................... 14 Item 16 Investment Discretion ............................................................................................. 14 Item 17 Voting Client Securities ........................................................................................... 15 Item 18 Financial Information .............................................................................................. 15 Item 19 Requirement for State-Registered Advisers ........................................................... 15 Item 20 Additional Information ............................................................................................. 15 Verity & Verity, LLC 3  Item 4 Advisory Business Description of Services Verity and Verity, LLC d/b/a Verity Investment Partners and Verity Investment Management is a registered investment adviser based in Beaufort, South Carolina with offices in Bluffton, South Carolina, Edwards, Colorado and San Antonio, Texas. We are organized as a limited liability company under the laws of the State of South Carolina. We have been providing investment advisory services since 2002. William W. Verity is our firm's principal owner. The following paragraphs describe the services offered through Verity Investment Partners (“VIP”). Services offered through Verity Investment Management are detailed in a separate ADV 2A Brochure. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Verity Investment Partners and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. Investment Management We offer discretionary investment management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you ongoing and focused investment advice and/or to make investments on your behalf. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. We request you grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the Investment Management Agreement (“IMA”) you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. Financial Planning We offer financial planning services but do not charge separately for this service. Our financial planning services may be general in nature or focused on particular areas of interest or request, depending on each client's unique circumstances and goals. Financial planning advice is offered in the areas of goal setting, cash flow and debt management, retirement planning, investment planning, college education funding, tax planning and estate planning as applicable. We offer such services as requested by the client and the client is responsible for implementing, accepting or rejecting any plans we may present. We do not serve as an attorney, accountant, insurance agent and no portion of our services should be construed as same. Limitations of Financial Planning To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purposes. You are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation Verity & Verity, LLC 4  decisions and is free to accept or reject any recommendation that we make. Please note: If the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to resolve the dispute directly with the engaged professional. Advisory Services to Retirement Plans and Plan Participants As disclosed above, we offer investment advisory and financial planning services. For Plans that allow participants to have self-directed accounts, we provide our services to employee benefit plan participants (“Participants”) or pooled accounts. The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act (“ERISA”). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below). The services we provide to your Plan and the compensation we receive for these services are described above, and in the service agreement that you have previously signed. We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our fee from the plan or directs the plan record-keeper to issue payment for our fee out of the plan. If we receive any other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you. IRA Rollover Considerations and Recommendations 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. We comply with the Department of Labor (“DOL”) Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable. Our firm is providing the following additional acknowledgment: When we provide investment advice to individuals regarding a retirement plan account or individual retirement account, the firm is deemed a fiduciary 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 potential conflicts with a client’s interest. Therefore, we, operate under a special rule which requires the firm to act in a client’s best interest and not put our interests ahead of the client. 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 a client when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees and investments; • Follow policies and procedures designed to ensure advice given is in the client’s best interest; • Charge no more than is reasonable for services; and • Provide basic information about conflicts of interest. We benefit financially from the rollover of a client’s assets from a retirement account to an account managed by the firm. This is a primary conflict of interest because when we provide investment advice, the assets increase the firm assets under management and, in turn, advisory fees. To meet the fiduciary responsibility we only recommend a rollover when it is deemed in the client’s best interest. Verity & Verity, LLC 5  Status In providing services to the Plan and Participants, our status is that of an investment adviser registered under the Investment Advisers Act of 1940, and we are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we are acting as a discretionary fiduciary of the plan as defined in Section 3(38) under ERISA. Family Office Services Some of our advisors offer Family Office Services which include strategic and/or tactical advisory consulting including but not limited to: Wealth Strategy, Asset Protection & Portfolio Implementation, Family Governance & Decision Making, Liquidity and Exit Planning, Learning and Development, Philanthropic Consulting, Tax Planning & Projections, Cash and Liquidity Management, Estate Planning, Trust Review, Banking and Credit Consulting, Lifestyle Services, Bill Pay and Book Keeping. The specific services which will be performed and fees for those services are memorialized in the Family Office Services Consulting Agreement with our firm. Types of Investments In general, we offer advice on equity securities, ETFs, corporate debt securities, commercial paper, certificates of deposit, municipal securities, mutual funds, U.S. Government securities, interests in partnerships investing in real estate and oil and gas interests and other investments. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Client Obligation In performing our services, Verity Investment Partners shall not be required to verify any information received from the client or from the client's other professionals and is expressly authorized to rely thereon. Each client is advised that it remains his/her responsibility to promptly notify us in writing if there is ever any change in his/her financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. We also request that you keep us advised of any changes of address, phone, email and the like. Assets Under Management As of December 31, 2025, Verity & Verity provides continuous management services for $1,396,818,690 in client assets on a discretionary basis as well as $2,784,771 on a non-discretionary basis. Of this, all are assets managed by Verity Investment Management. As of December 31, 2025 Verity Investment Management also had $8,175,253 in Assets Under Advisement. Item 5 Fees and Compensation Our fee for advisory services is based on a percentage according to the value of the assets we manage for you and is set forth in the following fee schedule*: Assets Under Management First $2,000,000 Next $2,000,000 and $5,000,000 $5,000,000 and above Annual Fee 1.00% 0.75% 0.50% Verity & Verity, LLC 6  *Older client relationships may be subject to a different fee schedule. Fee schedules are always outlined in your IMA with our firm. Employee accounts and their families receive a lower management fee. Our minimum account size is generally $1 Million and as a result, our minimum fee is generally $10,000 per year. At our sole discretion we may accept accounts which do not meet our minimum asset requirement. The amount of the fee is reviewed on a case-by-case basis depending upon several factors including assets invested, amount of attention required to manage the relationship and the amount of work involved. Our annual advisory fee is billed and payable quarterly in arrears. Fees are based on the average daily balance of your account(s). If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable, based on the average daily account balance, in proportion to the number of days in the quarter for which you are a client. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our stated fee schedule. Prior to engaging Verity Investment Partners to provide investment management services, the client will be required to enter into a formal Investment Management Agreement with Verity Investment Partners setting forth the terms and conditions under which Verity Investment Partners shall advise on the client's assets, and a separate custodial/clearing agreement with each designated broker- dealer/custodian. We will send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. We will also receive a duplicate copy of your account statements. You may terminate the portfolio management agreement at any time. You will incur a pro rata charge for services rendered prior to the termination of the portfolio management agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. Family Office Services Fees The specific services which will be performed and fees for those services are memorialized in the Family Office Services Consulting Agreement with our firm. Fees for these services are negotiated based on the scope of Services to be performed. Additional Fees and Expenses As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction charges and/or Verity & Verity, LLC 7  brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to the "Brokerage Practices" section of this brochure. Retirement Rollovers-Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in their former retirement plan, if permitted, (ii) roll over the assets to the new employer's plan, if available and permitted, (iii) roll over to an IRA or (iv) cash out the account value (which could have adverse tax consequences). If we recommend that a client roll over their retirement plan assets into an account to be managed by Verity Investment Partners, such a recommendation creates a conflict of interest if Verity Investment Partners will earn an advisory fee on the rolled over assets. No client is under any obligation to roll over retirement plan assets to an account managed by Verity Investment Partners. Verity Investment Partners' Chief Compliance Officer, Tanya Olvera, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such roll over recommendation. Item 6 Performance-Based Fees and Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a client's account. Our fees are calculated as described in the Advisory Business section above and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account. Item 7 Types of Clients We offer investment advisory services to individuals, pension and profit-sharing plans or participants, trusts, estates, charitable organizations, corporations, and other business entities. In general, we require a minimum of $1,000,000 to open and maintain an advisory account. Verity Investment Partners, in its sole discretion, may charge a lesser investment management fee and/or waive the $1,000,000 minimum portfolio size based upon certain criteria (i.e., anticipated future earning capacity, anticipated, future additional assets, dollar amount of assets to be managed, related accounts, composition, negotiations, employee accounts, etc.) We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. Please Note: If your account balance is below our minimum of $1,000,000 and you are being charged the stated minimum annual fee you will be paying above our normal stated management fees. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: • Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the Verity & Verity, LLC 8  experience and expertise of the company's management, and the outlook for the company's industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. • Technical Analysis - involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. The risk of market timing based on technical analysis is that charts may not accurately predict future price movements. Current prices of securities may reflect all information known about the security and day to day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. • Long Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Long term purchases may be affected by unforeseen long-term changes in the company in which you are invested or in the overall market. Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Moreover, as a result of revised IRS regulations, custodians and broker-dealers report the cost basis of equities acquired in client accounts on or after January 1, 2011. Your custodian will default to the Tax- Efficient accounting method for calculating the cost basis of your investments. You are responsible for contacting your tax adviser to determine if this accounting method is the right choice for you. If your tax adviser believes another accounting method is more advantageous, please provide written notice to our firm immediately and we will alert your account custodian of your individually selected accounting method. Please note that decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. It should not be assumed that the future performance of any specific investment strategy (including the investments and/or investment strategies recommended or undertaken by Verity Investment Partners) will be profitable or equal to any specific performance level. Investment Risk Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments or investment strategies recommended or undertaken by Verity Investment Partners) will be profitable or equal any specific performance level(s). Verity & Verity, LLC 9  Dividend Strategy Risk We recommend the use of Verity Investment Management’s dividend portfolios to most clients. Clients invested in strategies designed to invest in dividend paying securities will be subject to certain risks. These include issuers which have historically paid dividends reducing or ceasing to pay dividends in the future, which could additionally negatively impact the price of the security. In times of economic stress, large amounts of issuers could reduce or eliminate dividends, impacting the ability of VIM to execute its desired strategy. Recommendation of Particular Types of Securities As disclosed under the "Advisory Business" section in this Brochure, we generally recommend equities with a history of dividend growth. We consider each client's goals and risk tolerance in constructing their portfolio. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it. Item 9 Disciplinary Information Neither our firm nor any of our Associated Persons has any reportable disciplinary information. Item 10 Other Financial Industry Activities and Affiliations We are not related, through control or ownership, with any type of the following entities: • broker-dealer, municipal securities dealer, or government securities dealer or broker • investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) • other investment adviser or financial planner • futures commission merchant, commodity pool operator, or commodity trading advisor • banking or thrift institution • accountant or accounting firm • lawyer or law firm • pension consultant • real estate broker or dealer • sponsor or syndicator of limited partnerships We may provide model portfolios to unaffiliated registered investment advisers (third party) for their use in managing their underlying clients’ accounts. The unaffiliated registered investment adviser is exclusively responsible for determining the suitability of the model portfolio for their underlying client(s) and whether to implement any of the model portfolios. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties Verity & Verity, LLC 10  of honesty, good faith, and fair dealing with you. All of our Associated Persons are expected to adhere strictly to these guidelines. Our Code of Ethics also requires that certain persons associated with our firm submit reports of their personal account holdings and transactions to a qualified representative of our firm who will review these reports on a periodic basis. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this brochure. Participation or Interest in Client Transactions Neither our firm nor any of our Associated Persons has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in which you are already invested. We may also combine our orders to purchase securities with your orders to purchase securities ("block trading"). Please refer to the "Brokerage Practices" section in this brochure for information on our block trading practices. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that neither our Associated Persons nor we shall have priority over your account in the purchase or sale of securities. Item 12 Brokerage Practices We recommend the brokerage and custodial services of Schwab Institutional, a division of Charles Schwab & Co., Inc. ("Schwab Institutional"), a securities broker-dealer and a member of NYSE/SIPC. Clients are advised that there may be transaction charges involved when purchasing or selling securities. Our firm does not share in any portion of the brokerage fees/transaction charges imposed by Schwab Institutional. Additionally, the commission/transaction fees charged by Schwab Institutional may be higher or lower than those charged by other broker-dealer/custodians. Schwab Institutional provides our firm with access to its institutional trading and operations services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers at no charge to them so long as a total of at least $10 million of the adviser's clients account assets are maintained at Schwab Institutional. Schwab Institutional services may include research, brokerage, custody, access to mutual funds and other investments that are otherwise available only to institutional investors or would require significantly higher minimum initial investments. Schwab Institutional also makes available to our firm other products and services that benefit our firm but may not benefit its clients' accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution, provide research, pricing information and other market data, and provide custodial services which facilitate payment of our firm's fees from its clients' accounts and clients reports. The availability to our firm of the foregoing products and services is not contingent upon our firm committing to Schwab Institutional any specific amount of business (assets in custody or trading). We believe that Schwab Institutional provides quality execution services at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by Schwab Institutional, including the value of research provided, the firm's reputation, execution capabilities, commission rates, and responsiveness to our clients and our Verity & Verity, LLC 11  firm. In recognition of the value of research services and additional brokerage products and services Schwab Institutional provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Non-Soft Dollar Research and Additional Benefits Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, Verity Investment Partners may receive from Schwab (or another broker-dealer/custodian, investment manager, platform or fund sponsor, or vendor) without cost (and/or at a discount) support services and/or products, certain of which assist Verity Investment Partners to better monitor and service client accounts maintained at such institutions. Included within the support services that may be obtained by Verity Investment Partners may be investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support-including client events, computer hardware and/or software and/or other products used by Verity Investment Partners in furtherance of its investment advisory business operations. As indicated above, certain of the support services and/or products that may be received may assist Verity Investment Partners in managing and administering client accounts. Others do not directly provide such assistance, but rather assist Verity Investment Partners to manage and further develop its business enterprise. Verity Investment Partners’ clients do not pay more for investment transactions effected and/or assets maintained at Schwab because of this arrangement. There is no corresponding commitment made by Verity Investment Partners to Schwab or any other any entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as result of the above arrangement. Directed Brokerage Verity Investment Partners recommends that its clients utilize the brokerage and custodial services provided by Schwab. Verity Investment Partners generally does not accept directed brokerage arrangements (when a client requires that account transactions be affected through a specific broker- dealer). In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and Verity will not seek better execution services or prices from other broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers with orders for other accounts managed by Verity As a result, a client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Please Note: In the event that the client directs Verity Investment Partners to effect securities transactions for the client’s accounts through a specific broker- dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative clearing arrangements that may be available through Verity. Higher transaction costs adversely impact account performance. Please Also Note: Transactions for directed accounts will generally be executed following the execution of portfolio transactions for non-directed accounts. Trade Away/Prime Broker Fees Verity & Verity, LLC 12  Relative our discretionary investment management services (and sub-advisors), when beneficial to the client, Verity Investment Partners or sub-advisors, may purchase individual fixed income securities through broker-dealers other than the account custodian, in which event, the client generally will incur the fee (commission, mark-up, mark-down) charged by the executing broker-dealer and potentially, a separate "trade away" and/or prime broker fee charged by the account custodian. Internal Cross Transactions From time to time, we may affect a transaction between two or more of our managed accounts. In such transactions, one client account may purchase or sell a security to another client account. As a general rule, we will only facilitate cross transactions when we believe the trade is in the best interest of both parties. In order to approximate an arms-length transaction and as is directed by FINRA regulations, we will receive bids from the custodian on the open market who in turn will offer a buy and sell at the mid-point of the bids. The custodian retains all documentation for such transactions and is subject to periodic auditing of cross trades. In our effort to implement cross transactions, we will not receive any additional compensation other than our normal advisory fees, as disclosed in Item 5. Order Aggregation/Block trades Transactions for each client account generally will be affected independently unless we decide to purchase or sell the same securities for several clients at approximately the same time. Verity Investment Partners may (but is not obligated to) combine or “bundle" (aka block trades) such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among Verity Investment Partners clients’ differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. These allocations are made at the custodian level. Verity Investment Partners shall not receive any additional compensation or remuneration as a result of such aggregation. Verity Investment Partners’ Chief Compliance Officer, Tanya Olvera, remains available to address any questions that a client or prospective client may have regarding the above arrangements and any corresponding perceived conflict of interest such arrangements may create. Item 13 Review of Accounts The firm’s Investment Adviser Representatives monitor your account(s) on an ongoing basis to ensure that the portfolio management services provided to you are consistent with your stated investment needs and objectives. The level of review will vary depending upon the complexity of the individual client portfolio. Additional reviews may be conducted based on various circumstances, including, but not limited to: • contributions and withdrawals, • year-end tax planning, • market moving events, • security specific events, and/or, • changes in your risk/return objectives. We will provide you with written reports at least quarterly and on an interim basis if requested. Reports we provide to you include the following: asset allocation, portfolio summary, account performance and billing statement. In addition, you will receive trade confirmations and monthly or quarterly statements from your account custodian(s). Verity & Verity, LLC 13  Item 14 Client Referrals and Other Compensation Client Referrals Verity Investment Partners participates in referral arrangements with affiliated and unaffiliated third parties, which are made in accordance with Rule 206(4)-1. Before we compensate a third party for referrals, clear and prominent disclosures are provided on the material terms of the compensation arrangement between the referral source and Verity, whether there is any affiliation between the referral source and Verity, and whether the client bears any costs with respect to the referral. Additionally, we disclose that fees paid by a referred client may differ from fees paid by other similarly situated clients who are not introduced to Verity through a referral. We strongly recommend prospective clients review the disclosures carefully to help address any potential conflicts of interest. Other Compensation As referenced in Item 12 above, Verity Investment Partners may receive from Schwab, without cost (and/or at a discount), support services and/or products. Verity Investment Partners’ clients do not pay more for investment transactions effected and/or assets maintained at Schwab as result of this arrangement. There is no corresponding commitment made by Verity Investment Partners to Schwab or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of the above arrangements. Verity Investment Partners’ Chief Compliance Officer, Tanya Olvera, remains available to address any questions that a client or prospective client may have regarding the above arrangements and any corresponding conflicts of interest such arrangements may create. Item 15 Custody As paying agent for our firm, your independent 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 independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian (s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. We also provide a billing statement with our quarterly statements, so you understand how our fees are calculated. Asset Transfer Authority Our firm or persons associated with our firm may complete third party asset transfers on behalf of client accounts by having a client sign and establish a standing letter of authorization (SLOA) with the custodian. Because we do not seek client written authorization each time the SLOA is used to transfer assets, we are deemed to have access to the client’s assets and therefore we are required to claim custody of the assets associated with the accounts. If you have a question regarding your account statement or if you did not receive a statement from your custodian, please contact us directly at the telephone number on the cover page of this brochure. Item 16 Investment Discretion Before we can buy or sell securities on your behalf on a discretionary basis, you must first sign our management agreement and discretionary trading authorization forms with the custodian. You may Verity & Verity, LLC 14  specify investment objectives, guidelines, and/or impose certain conditions or investment parameters for your account(s). For example, you may specify that the investment in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions in the securities of a specific industry or security. Please refer to the "Advisory Business" section in this brochure for more information on our discretionary management services. Item 17 Voting Client Securities Proxy Voting As a matter of policy and practice, we generally do not vote proxies on behalf of advisory clients. However, we reserve the right to make a case-by-case assessment of a client’s specific needs, and, if necessary, we will vote proxies if the client requests it. Unless we have agreed to vote proxies for you specifically, if you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. If we inadvertently receive any written or electronic proxy materials, we will forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we will forward any electronic solicitation to vote proxies. 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. Verity Investment Partners has identified an unaffiliated service provider (Chicago Clearing Corporation) to assist the client with class action matters. The Client is under no obligation to engage the service provider. If you wish to engage the service provider, we will share your transaction data with Chicago Clearing Corporation who in turn reviews class action lawsuits in which you may be eligible to participate. Chicago Clearing Corporation will charge only for those cases where it recovers monies and charges 20% of the proceeds for its services. You may opt-out of this service by contacting us at the number on the cover page of this brochure or by signing the Opt-Out Agreement provided with your Investment Management Agreement. Item 18 Financial Information We are not required to provide financial information to our clients because we do not: • require the prepayment of more than $1,200 in fees and six or more months in advance, or • take custody of client funds or securities, or • have a financial condition that is reasonably likely to impair our ability to meet our commitments to you. Item 19 Requirement for State-Registered Advisers Our firm is SEC registered therefore this section is not applicable. Item 20 Additional Information Verity & Verity, LLC 15  Information Security Information We view protecting your private information as a top priority. Pursuant to applicable information security requirements, we have instituted policies and procedures to ensure that we reduce the risk regarding your personal and confidential information being breached. Your Privacy We do not disclose any nonpublic personal information about you to any non-affiliated third parties, except as permitted by law or requested by you. In the course of servicing your account, we may share some information with our service providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys. We restrict internal access to nonpublic personal information about you to employees, who need that information to provide products or services to you. We maintain physical and procedural safeguards that comply with regulatory standards to guard your nonpublic personal information and to ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone. We do not share your information unless it is required to process a transaction, at your request, or required by law. You will receive a copy of our privacy notice prior to or at the time you sign an Agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Please contact our main office at the telephone number on the cover page of this brochure if you have any questions regarding this policy. 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. If a trade error results in a profit, the custodian firm will donate the profit to charity. Verity & Verity, LLC 16