CLARITY FINANCIAL PLANNERS, LLC

Disclosure Brochure – Form ADV Part 2A Clarity Financial Planners, LLC 168 N. Meramec Avenue, Suite #150 Clayton, MO 63105, Phone: 314.548.2260 www.clarityfinancialplanners.com March 26, 2025 This Brochure provides information about the qualifications and business practices of Clarity Financial Planners, LLC (“Clarity”). If you have any questions about the contents of this Brochure, please contact us at 314.548.2260. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Clarity Financial Planners, LLC is a registered investment advisor. Registration of an Investment Advisor does not imply any level of skill or training. The oral and written communications of an Advisor provide you with information about which you determine to hire or retain an Advisor.Additional information about Clarity is also available on our website www.clarityfinancialplanners.com or on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 – Material Changes This Item of the Brochure will discuss only specific material changes that are made to the Brochure since our last update and provide clients with a summary of such changes. Since the last update of our brochure on 04/03/24, there has been no material changes made. 2  Item 3 - Table of Contents Item 1 – Cover Page ................................................................................................................................................ 1 Item 2 – Material Changes ....................................................................................................................................... 2 Item 3 - Table of Contents ....................................................................................................................................... 3 Item 4 – Advisory Business ..................................................................................................................................... 4 Item 5 – Fees and Compensation ............................................................................................................................ 6 Item 6 – Performance-Based Fees and Side-By-Side Management ..................................................................... 10 Item 7 – Types of Clients ...................................................................................................................................... 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Our Methods of Analysis and Investment Strategies ............................................................................................................................................ 10 Item 9 – Disciplinary Information ........................................................................................................................... 13 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................. 13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 13 Item 12 – Brokerage Practices .............................................................................................................................. 14 Item 13 – Review of Accounts Reviews ................................................................................................................. 16 Item 14 – Client Referrals and Other Compensation ............................................................................................. 17 Item 15 – Custody .................................................................................................................................................. 18 Item 16 – Investment Discretion ............................................................................................................................ 19 Item 17 – Voting Client Securities ......................................................................................................................... 18 Item 18 – Financial Information ............................................................................................................................ 19 3  Item 4 – Advisory Business Clarity initially filed for registration with the SEC in March of 2024. Clarity is owned by Shannon F. Moenkhaus (as of November 1, 2016) and has been providing comprehensive financial planning services since July 2015. As of December 31, 2024, Clarity managed $117,685,250 on a discretionary basis and $921,1333 on a non-discretionary basis. Comprehensive Financial Planning and Portfolio Management Clarity manages investment portfolios for individuals including high-net-worth individuals, trusts and businesses. Clarity works with clients to determine the client's investment objective which may be set forth in a written Investment Policy Statement that describes an asset allocation model that confirms a client’s risk tolerance. The determination of an appropriate portfolio for each client is a function of current and future cash flow needs, risk tolerance, time horizon, goals, and modeled returns. Investment and portfolio allocation software may be used to evaluate alternative portfolio designs. Clarity evaluates the client's existing investments with respect to the client's investment policy statement. Clarity works with new client families to develop a plan to transition from the client's existing portfolio to the desired portfolio. Clarity typically designs a portfolio of evidence-based no-load mutual funds or ETF’s and may use model portfolios if the models match the client's investment policy. Clarity allocates the client's assets among various investments taking into consideration the overall management style selected by the client. Clarity often recommends mutual funds and ETFs offered by Dimensional Fund Advisors (DFA), Vanguard, and other similar mutual funds and exchange traded funds. These sponsored mutual funds follow an evidence-based investment philosophy with low holdings turnover. Clarity prefers evidence-based mutual funds and ETF’s investments that offer low expense ratios, low security turnover, high transparency, and support a broadly diversified portfolio. Client portfolios may also include some individual equity securities and highly appreciated mutual funds in situations where disposition of these securities would present an overriding tax implication or the client specifically requests, they be retained for a personal reason. These situations are specifically identified in the client’s Investment Policy Statement (IPS). Clarity manages mutual fund and equity portfolios on a discretionary basis according to the investment policy selected by the client. A client may impose any reasonable restrictions on Clarity’s discretionary authority, including restrictions on the types of securities in which Clarity may invest client’s assets and on specific securities, the client 4  may believe to be appropriate. These situations are identified in the client’s Investment Policy Statement (IPS). Clarity may also recommend fixed income portfolios, which consist of managed accounts of laddered individual bond portfolios. Clarity will request discretionary authority from advisory clients to manage fixed income portfolio portfolios, including the discretion to retain a third- party fixed income manager. Clarity will periodically review each client’s investment policy, risk profile, and discuss the re-balancing of each client’s accounts to the extent appropriate. In addition to managing the client’s investment portfolio and as part of the Comprehensive Financial Planning service offering, Clarity consults with clients on various financial areas including income and estate tax planning, capital needs analysis, business sale structures, college financial planning, retirement planning, personal cash flow analysis, philanthropy establishment and design of retirement plans and trust designs, among other things. Clarity gathers required information through in-depth personal interviews. Information gathering includes a client’s current financial status, future goals, and attitudes toward risk. related documents supplied by the client are carefully reviewed and various types of written reports may be prepared by Clarity. Implementation of the financial plan recommendations is entirely at the client’s discretion although Clarity works with clients to implement the planning recommendations. Referrals to other professionals may happen based on the client’s needs. Please note: comprehensive financial planning is included with portfolio management services at no additional cost. 5  Wrap Fee Programs We do not participate in wrap fee programs. Item 5 – Fees and Compensation Comprehensive Financial Planning and Portfolio Management Services Note: similar advisory services can be obtained for less. The annual fee for advisory services will be charged as a percentage of assets under advisement or supervision according to the schedule below: Assets Under Advisement First $5,000,000 Next $5,000,000 Next $5,000,000 Next $5,000,000 Annual Fee 1.00% 0.80% 0.60% 0.40% *Minimum annual fee of $24,000 For example, an account valued at $13,000,000 would pay an effective fee of .83% with the annual fee of $108,000. The quarterly fee is determined by the following calculation: (($5,000,000 x 1.00%) + ($5,000,000 x 0.80%) + ($3,000,000 x 0.60%) ÷ 4 = $27,000. The fee schedule may be amended from time to time by Clarity upon at least forty-five (45) days advance written notice to client, subject to client’s right to terminate the investment advisory agreement before an increased fee schedule takes effect upon at least (30) days written notice to Clarity. Clarity generally requires a minimum annual fee of $24,000 for Comprehensive Financial planning and Portfolio Management Services. The specific manner in which fees are charged by Clarity is established in a client’s written agreement with Clarity. Generally financial advisory fees are billed and payable quarterly in advance based on the value of the client’s account on the last day of the previous quarter. If the client 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 in proportion to the number of days in the quarter for which you are a client. 6  In certain circumstances, 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 fee schedule stated above. Please note: comprehensive financial planning is included with portfolio management services at no additional cost. We may pay a portion of our advisory fee to the sub-advisor(s) we use; however, clients will not pay our firm a higher advisory fee as a result of any sub-advisory relationships. 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 clients at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. A client agreement may be canceled at any time, by either party, for any reason upon 30 days written notice. Upon termination of any account at any time after the required 30-day notice, any prepaid, or unearned fees will be promptly refunded. Clarity collects fees in advance, the fee refunded clients may terminate the advisory relationship upon 30-days' written notice to our firm. If the client’s advisory relationship is terminated, any fees for service not yet provided will be refunded to the client either by check or as a deposit back into their investment account. As a fee only advisor, Clarity does not receive any other form of compensation. We believe this policy helps mitigate the conflict of interest inherent when a firm receives compensation based on the sale of specific securities or investment products. In 2018 and prior years, Clarity followed a separate fee schedule, which remains in effect with clients who signed agreements with us during that period and who have not agreed to an amended advisory fee schedule. 7  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 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, refer to the Brokerage Practices section of this brochure. 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 while current employees may choose to 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 all costs and benefits of the rollover. 8  An employee will typically have four options: Leave the funds in your employer's (former employer's) plan. • • Move the funds to a new employer's retirement plan. • Cash out by taking a taxable distribution from the plan. • Rollover the funds into an IRA rollover account. Each option has advantages and disadvantages, before making a change, we encourage you to speak with your CPA and/or tax attorney. Rolling over your retirement funds to an IRA for Clarity to manage: • Determine whether the investment options in your employer’s retirement plan address your needs or whether you may want to consider other types of investments. o Employer retirement plans generally have a more limited investment menu than IRAs. o Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. • Your current plan may have lower fees than our fees. o 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. o 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. • Our strategy may have higher risk than the option(s) provided to you in your plan. • Your current plan may also offer financial advice. • If you keep your assets titled in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. • Your 401k may offer more liability protection than a rollover IRA; each state may vary. o 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 exceptions to the general rules, so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. 9  • You may be able to take out a loan on your 401k, but not from an IRA. • IRA assets can be accessed at 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 first time purchase of a home. • If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. • 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, contact your investment advisor representative with questions, or call our main number as listed on the cover page of this brochure. Item 6 – Performance-Based Fees and Side-By-Side Management Clarity does not receive any performance-based fees. Item 7 – Types of Clients Clarity provides services to Individuals, high-net-worth individuals, and businesses. In general, we charge a minimum fee of $24,000 to open and maintain an advisory account; however, we have the right to terminate your Account if it falls below a minimum size which, in our sole opinion, is too small to manage effectively. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Our Methods of Analysis and Investment Strategies Clarity may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully diversifying the proportions of various assets. 10  Risk: Market risk is that part of a security's risk that is common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. 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. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long-term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost by "locking-up" assets that may be better utilized in the short-term in other investments. We may use short-term purchases, short-term trading, margin transactions, option writing, and/or short sales as investment strategies when managing your account(s). None of these strategies are a fundamental part of our overall investment strategy, but we may use one or more occasionally if we determine they are suitable given your stated investment objectives and tolerance for risk. 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 information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is important that you notify us immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or employment status. We will not perform quantitative or qualitative analysis of individual securities. Instead, we will advise you on how to allocate your assets among various classes of securities or third-party money managers. We primarily rely on investment model portfolios and strategies developed by third-party money managers and their portfolio managers. We may replace/recommend replacing a third-party money manager if there is a significant deviation in characteristics or performance from the stated strategy and/or benchmark. Tax Considerations 11  Our strategies and investments may have unique and significant tax implications. Tax efficiency is a primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you consult with a tax professional regarding the investing of your assets. Moreover, custodians and broker-dealers must report the cost basis of equities acquired in client accounts on or after January 1, 2011. We will provide instructions to your custodian allowing us to choose "optimal tax method" for calculating the cost basis of your investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm Immediately, and we will alert your account custodian of your individually selected accounting method. 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. Recommendation of Particular Types of Securities We primarily recommend no-load institutional mutual funds and ETFs. However, we may advise on other types of investments as appropriate for your unique needs, goals, and tolerance for risk. Each type of security has its own unique set of risks, which are impossible to list her in their entirely. Even within the same type of investment, risks can vary widely. Generally, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. Mutual Funds and Exchange Traded Funds Mutual funds and exchange traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short- term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks 12  can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock which means their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees, which may reduce returns. Mutual funds may also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas "closed end" funds have a fixed number of shares to sell, which limits their availability to new investors. Item 9 – Disciplinary Information We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our advisory business or the integrity of our management. We do not have any required disclosures under this item. Item 10 – Other Financial Industry Activities and Affiliations Clarity has no other financial industry activities or affiliations. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Clarity has adopted a Code of Ethics expressing the firm’s commitment to ethical conduct. Clarity’s Code of Ethics describes the firm’s fiduciary duties and responsibility to clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at Clarity must acknowledge the terms of the Code of Ethics annually, or as amended. Individuals associated with Clarity may buy or sell securities for their personal accounts identical to, and/or different from those recommended to clients. It is the expressed policy of Clarity that no person employed by the firm shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on investment decisions of advisory clients. 13  Clarity’s employees and persons associated with Clarity are required to follow Clarity’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of Clarity and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for Clarity’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Clarity will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Clarity’s clients. In addition, the Code requires pre-clearance of certain transactions. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Clarity and its clients. It is Clarity’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts. Clarity will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an advisor, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment advisor in relation to a transaction in which the investment advisor, or any person controlled by or under common control with the investment advisor, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise when an advisor is dually registered as a broker-dealer or has an affiliated broker-dealer. Clarity will provide a complete copy of its Code of Ethics to any client or prospective client family upon request. Item 12 – Brokerage Practices Clarity recommends the brokerage and custodial services of Charles Schwab & Company, Inc. The recommended Custodian is a securities broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. We believe that the recommended Custodian provides quality execution services for you 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 the Custodian, including the value of the Custodian's 14  reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In recognition of the value of the services the Custodian provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Clarity participates in the Schwab Advisor Services (SAS) program offered to independent investment advisors by Charles Schwab and Company, INC. (“Schwab”). Through Schwab Advisor services, Schwab provides us and our clients with institutional brokerage services, trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab is a FINRA member broker dealer. Research and Other Soft Dollar Benefits We do not have any soft dollar arrangements. Economic Benefits As a registered investment advisor, Clarity has access to the institutional platform of your account custodian. As such, we also have access to research products and services from your account custodian and/or other brokerage firm. These products may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Such research products and services are provided to all investment advisors that utilize the institutional services platforms of these firms and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. Brokerage for Client Referrals Clarity does not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Directed Brokerage Clarity routinely requires that clients direct our firm to execute transactions through Charles Schwab & Company, Inc. As such, we may be unable to achieve the most favorable execution 15  of your transactions and you may pay higher brokerage commissions than you might otherwise pay through another broker-dealer that offers the same types of services. Not all advisors require their clients to direct brokerage. Block Trades We do not combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as "block trading") because we invest solely in mutual funds, which do not trade in blocks. Clarity generally does not aggregate any client transactions in mutual funds or other securities. Client accounts are individually reviewed and managed, and, transactions costs are not saved by aggregating orders in which Clarity arranges transactions. Item 13 – Review of Accounts Reviews All client accounts are review at least annually. Additional client account reviews will occur upon client request, changes in market conditions, new information about an investment, change in tax laws, or other pertinent events. Account assets are supervised continuously, and formally reviewed at least annually, by members of Clarity. The review process contains each of the following elements: assessing client goals and objectives; • evaluating the employed strategy(ies); • • monitoring the portfolio(s); and addressing the need to rebalance. • Additional account reviews may be triggered by any of the following events: a specific client request; • tax loss harvesting opportunities; • updating of client goals and objectives; changes in risk/return objectives; • • contributions and withdrawals; and • • market/economic conditions. For fixed income portfolios, certain account review responsibilities may be delegated to a third- party fixed income sub-advisor as described earlier in this document. 16  Employee Benefit Retirement Plan Services - plan assets are reviewed annually according to the standards and situations described above for portfolio management accounts. Reports All clients receive quarterly performance reports. The reports summarize the client’s account an asset allocation, portfolio performance, current positions, and current market value. Clients also receive monthly or quarterly statements from account custodian, which will outline the client’s current position and current market value. Employee Benefit Retirement Plan Services - Plan sponsors are provided with quarterly information and annual performance reviews from their custodian. In addition, plan participant education information may also be provided to the Plan Sponsor or Administrator for distribution to the participants of the plan. Item 14 – Client Referrals and Other Compensation As indicated under the discourse for (Item 12) above for disclosures on research and other benefits we may receive resulting from custodian and mutual fund companies in connection with utilizing their services that may not be available to retail clients. These services are generally available to independent investment advisors on an unsolicited basis at no charge to them. Mutual fund companies and custodians; including DFA, Vanguard and Schwab; provide continued education for Clarity personnel. They may also provide other services intended to help Clarity manage and further develop its business. These may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. These services are designed to assist Clarity in planning and designing its services for business and professional growth. Beyond the disclosures provided in this Brochure, Clarity does not receive any compensation from any third party in connection with providing investment advice to clients. Clarity does not enter into any commitments with brokers for transaction levels in changes for any services or products from brokers. DFA, NAPFA, and XYPN, through their web-based service, may provide referrals of clients to Clarity. 17  Clarity and our advisory personnel refer Clarity clients to a variety of non-affiliated service providers. Neither Clarity nor its advisory personal receive payments directly for referrals. Clarity does not engage third parties to solicit referral business and does not receive compensation for providing referrals to third parties. Item 15 – Custody As paying agent for Clarity, your independent custodian will directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from client accounts causes our firm to exercise limited custody over your funds or securities. Clarity does not have physical custody of any client funds and/or securities. Client 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 your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. Clients are encouraged to carefully review such official custodial records to the statements provided by Clarity. Our statements may vary from custodial statements based on accounting procedures, reporting dates or valuation methodologies of certain securities. Item 16 – Investment Discretion Clarity requires that it be provided with written authority to determine which securities, and in what amounts, are bought or sold. For fixed income securities, this authority will include the discretion to retain a third-party money manager for fixed income accounts. Any limitations on this discretionary authority shall be included in this written authority statement. Clients may change/amend these limitations as required. Such amendments shall be submitted in writing. When selecting securities and determining amounts, Clarity observes the investment policies, limitations and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to Clarity in writing. Item 17 – Voting Client Securities Proxy Voting: As a matter of firm policy and practice, Clarity does not have any authority to, and does not vote proxies on behalf of, advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients will receive 18  applicable proxies directly from the issuer of securities held in clients’ investment portfolios. Clarity, however, may provide advice to clients regarding the clients' voting of proxies. Class Actions, Bankruptcies and Other Legal Proceedings: Clients should note that Clarity will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held or previously were held in the client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct Clarity to transmit copies of class action notices to the client or a third party. Upon such direction, Clarity will make commercially reasonable efforts to forward such notices in a timely manner. Item 18 – Financial Information Clarity does not accept client fees of $1,200 or more in excess of six months in advance. There are no conditions reasonably likely to occur that would impair our ability to meet contractual commitments to clients. Clarity has never been the subject of a bankruptcy proceedings. 19