A. Firm Information
Clarity Asset Management, Inc. (“Clarity” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Corporation under the laws of the State of Iowa. Clarity was founded in 1998, and is owned and operated by Donald L. Erickson, ChFC® (President and Chief Executive Officer), Steven J. Larson (Vice President, Chief Investment Officer and Secretary), and Debra A. Conlon (Vice President, Chief Operating Officer, Treasurer and Chief Financial Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Clarity.
B. Advisory Services Offered
Clarity offers investment advisory services to individuals, high net worth individuals, families, trusts, estates, charitable organizations and corporations (each referred to as a “Client”).

The Advisor serves as a fiduciary to the Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Clarity’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.

Financial Planning Services Clarity provides a variety of financial planning and consulting services to Clients. Clients may elect to receive services in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s financial situation.

A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and charitable giving programs. Clarity may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly.

Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. In such instances, the Advisor will document and demonstrate the added value to the Client, based on historical data, for securing the management services and investment strategies recommended by the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction[s] through the Advisor. Investment Management Services Clarity may provide customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Clarity works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to select a strategy. Strategies consist of diversified mutual funds, exchange-traded funds (“ETFs”), and/or individual stocks to achieve the Client’s investment goals. The Advisor may use other types of investments to achieve the Client’s goals. The Advisor may retain certain legacy investments based on portfolio fit.
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Clarity’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Clarity will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. As described in Item 12 – Brokerage Practices, the Advisor may recommend that Client’s place their assets with a particular Custodian to custody its assets, for the Advisor to manage. If certain accounts are not placed with the recommended Custodian, the Advisor may also provide advisory services on those Client accounts.

Clarity evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Clarity may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.

At no time will Clarity accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 - Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the agreement, please see Item 12 – Brokerage Practices.
C. Client Account Management
Prior to engaging Clarity to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:


• Establishing an Investment Strategy – Clarity, in connection with the Client, will develop a strategy designed to achieve the Client’s stated investment goals and objectives.
• Asset Allocation – Clarity will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction– Clarity will select securities to fulfill the Asset Allocation plan for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Clarity will provide investment management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Clarity does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Clarity.
E. Assets Under Management
As of December 31, 2019, Clarity manages $182,746,954 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. please register to get more info

The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for investment management services described herein shall be required to enter into one or more agreements with the Advisor.
A. Fees for Advisory Services
Financial Planning Services Clarity offers financial planning services for up to $500. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total costs will be determined prior to engaging for these services. For Clients that engage with the Advisor to provide financial
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planning services, the Advisor may waive any fees related to the financial planning services if the Client engages the Advisor for investment management services.

Investment Management Services Investment advisory fees are paid quarterly, at the end of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the following schedule:
Assets Under Management ($) Annual Rate (%)
Up to $1,000,000 1.00% $1,000,001 to $2,000,000 0.65% Over $2,000,000 0.35%

The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees are negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Clarity will be independently valued by the Custodian. Clarity will not have the authority or responsibility to value portfolio securities.

The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client.. However, the Advisor shall not receive any portion of these commissions, fees, and costs.
B. Fee Billing
Financial Planning Services Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s].

Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor or its delegate shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective quarter-end date. Fees are calculated in arrears by multiplying the quarterly fee rate (annual fee rate divided the number of days in the year multiplied by the number of days in the quarter) by the total assets under management at the close of a calendar quarter (March 31, June 30, September 30, and December 31). Proration adjustments will be made to this calculation taking into account any contributions or withdrawals occurring during the quarter. Such calculation will be based on the lowest applicable tier rate (see fee schedule above) at the close of the calendar quarter and for only the days of the quarter during which the investment management services have been rendered. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by Clarity directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Clarity, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for most ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Clarity are separate and distinct from these custodial and execution fees. In addition, all fees paid to Clarity for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the
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funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Clarity, but may be required to purchase more expensive share classes where such purchases are made through retail account platforms. Clients would also not receive the services provided by Clarity which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Clarity to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Financial Planning Services Clarity is compensated for its services upon completion of the engagement deliverable[s]. Either party may terminate the financial planning engagement, at any time, by providing advance notice to the other party. The Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent.

Investment Management Services Clarity is compensated for its services at the end of the quarter after investment advisory services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Clarity does not buy or sell securities and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. please register to get more info

Clarity does not charge performance-based fees for its investment advisory services. The fees charged by Clarity are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client.

Clarity does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. please register to get more info

Clarity offers investment advisory services to individuals, high net worth individuals, families, trusts, estates, charitable organizations and corporations. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. Clarity generally requires a minimum relationship size of $250,000, which may be reduced or waived at the sole discretion of the Advisor. please register to get more info

A. Methods of Analysis
Clarity primarily employs fundamental analysis in developing investment strategies for its Clients. Research and analysis from Clarity are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others.
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Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts.

As noted above, Clarity generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Clarity will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Clarity may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Clarity will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals.

While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts.

Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis.

The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involves a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor. please register to get more info

There are no legal, regulatory or disciplinary events involving Clarity or any of its management persons.
Clarity values the trust Clients place in the Advisor. The Advisor encourages you to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 115699.
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The sole business of Clarity and its Supervised Persons is to provide advisory services to its Clients. Neither Clarity nor its advisory personnel are involved in other financial or investment related activities. Clarity does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. please register to get more info

A. Code of Ethics
Clarity has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code of Ethics applies to all persons associated with Clarity ( “Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. Clarity and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Clarity’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at 515-233-3152. In addition, Clarity abides to the Codes of Ethics of all professional designations of Supervised Persons.
B. Personal Trading with Material Interest
Clarity allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Clarity does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Clarity does not have a material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Clarity allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Clarity requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Clarity allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At
no time will Clarity, or any Supervised Person of Clarity, transact in any security to the detriment of any
Client. please register to get more info

A. Recommendation of Custodian[s]
Clarity does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Clarity to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Clarity does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis.
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Where Clarity does not exercise discretion over the selection of the Custodian, the Advisor will typically recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Clarity. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not utilized. Clarity may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client and its overall reputation. Clarity primarily recommends that Clients establish their account[s] with Fidelity Clearing & Custody Solutions and related entities of Fidelity Investments, Inc. (collectively “Fidelity”), where the Advisor maintains an institutional relationship. Please see Item 14 below.

Following are additional details regarding the brokerage practices of the Advisor:

1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Clarity does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please
see Item 14 below.

2. Brokerage Referrals - Clarity does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Clarity will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s] at the Custodian. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Clarity will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Clarity will execute its transactions through the Custodian as authorized by the Client. Clarity may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts. please register to get more info

A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by the Chief Investment Officer and Advisory Persons of Clarity. Formal reviews are generally conducted at least annually or more or less frequently depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A. above, each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Clarity if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events.
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C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. please register to get more info

A. Compensation Received by Clarity
Participation in Institutional Advisor Platform Clarity has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. Access to Fidelity’s Institutional platform is provided at no charge to the Advisor. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor’s recommendation of this custodian over one that does not furnish similar software, systems support, or services.

Additionally, the Advisor may receive the following benefits from Fidelity: receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information.
B. Client Referrals from Solicitors
Clarity does not engage paid solicitors for Client referrals. please register to get more info

All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct Clarity to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Clarity to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 - Brokerage Practices.

If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements in these cases, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. please register to get more info

Clarity generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Clarity. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Clarity will be in accordance with each Client's investment objectives and goals. please register to get more info

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Clarity does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. please register to get more info

Neither Clarity, nor its management, have any adverse financial situations that would reasonably impair the ability of Clarity to meet all obligations to its Clients. Neither Clarity, nor any of its advisory persons, have been subject to a bankruptcy or financial compromise. Clarity is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance.

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Privacy Policy
Effective: March 19, 2020

Our Commitment to You
Clarity Asset Management, Inc. (“Clarity” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”).

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Clarity (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.

Clarity does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information.
What information do we collect from you?

Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals


What Information do we collect from other sources?

Custody, brokerage and advisory agreements Account applications and forms Other advisory agreements and legal documents Investment questionnaires and suitability documents Transactional information with us or others Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us.
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How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information.
Basis For Sharing Do we share? Can you limit?
Servicing our Clients
We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Yes No
Marketing Purposes
Clarity does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Clarity or the client has a formal agreement with the financial institution. We will only
share information for purposes of servicing your accounts, not for
marketing purposes.
No Not Shared
Authorized Users
Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s). Yes Yes
Information About Former Clients
Clarity does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. No Not Shared


Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at 515-233-3152. please register to get more info