Services
The firm became an independent registered investment adviser in 2017 in order to directly offer
asset management and financial planning services. Investment Adviser Representatives of the firm
are also registered representatives of LPL Financial, a FINRA/SIPC member broker/dealer, to offer
brokerage services under the Doing Business Name of Clearview Financial Partners, founded in
2017. Clearview Financial Partners is a separate, independent entity that is legally unaffiliated with
LPL Financial. Investment advisor representatives are also insurance agents appointed with various
insurance carriers to offer insurance products.
• The firm offers discretionary asset management services for a wrap or non-wrap fee basis as
further described below.
• The firm does not directly hold securities or have direct access to client assets. The firm has
a custodial relationship with the below qualified custodians for the safekeeping of client
assets.
§ LPL Financial LLC (LPL)
§ Charles Schwab & Co., Inc (Schwab)
Firm Management
David L. Fitzgerald (CRD No. 1927550) is the principal owner with a 100% ownership interest. He
also serves as the President and Chief Compliance Officer (CCO). In addition to offering advisory
services, Mr. Fitzgerald is a registered representative of LPL Financial to offer securities transaction in
a separate and unaffiliated capacity as well as an insurance agent of various unaffiliated insurance
carriers. Mr. Fitzgerald has worked in the financial services field since 1989 after graduating from
Drexel University with dual degrees in Finance and Marketing.
Fees
In the Clearview Financial Partners Wrap program, clients pay Clearview Financial Partners a
single annual advisory fee for advisory services and execution of transactions. Clients do not pay
brokerage commissions, markups or transaction charges for execution of transactions in addition to
the advisory fee. The advisory fee is negotiable between the client and Clearview Financial Partners
and is set out in the advisory agreement.
The advisory fee is a percentage based on the value of all assets in the account, including cash
holdings. The maximum advisory fee is generally 1.6% subject to the below fee schedule.
Asset Under Management Annual Fee
$0 - $1,000,000 1.60%
$1,000,001 to $3,000,000 1.35%
$3,000,001 - $4,000,000 1.00%
$4,000,001 - $5,000,000 0.90%
Over $5,000,000 Negotiable
• The advisory fee is paid to Clearview Financial Partners and is shared between
Clearview Financial Partners and its associated persons.
• The advisory fee may be higher than the fee charged by other investment advisors for
similar services.
• Participation in the program may cost more or less than purchasing such services
separately.
• Clearview Financial Partners does not accept performance-based fees for program
accounts.
The advisory fees will be calculated and deducted on a quarterly basis in advance or in arrears based
on a written authorization from the client. If the advisory agreement is terminated before the end of
the quarterly period, client is entitled to a pro-rated refund of any pre-paid quarterly advisory fee
based on the number of days remaining in the quarter after the termination date, which will be
processed by the custodian.
Although clients do not pay a transaction charge for transactions in a program account, clients
should be aware that Clearview Financial Partners pays the custodian transaction charges for the
transactions. The transaction charges paid by Clearview Financial Partners vary based on the type
of transaction (e.g., mutual fund, equity or fixed income security) and range from $0 to $50.
Because Clearview Financial Partners pays the transaction charges in program accounts, there is a
conflict of interest. Clients should understand that the cost to Clearview Financial Partners of
transaction charges may be a factor that Clearview Financial Partners considers when deciding
which securities to select and how frequently to place transactions in a program account. This
conflict is mitigated by the investment advisor representative’s fiduciary duty to act in the client’s
best interest an acting accordingly.
Mutual Fund Share Class Disclosure and Fiduciary Duty (12b-1 Fees)
Section 206 of the Investment Advisers Act of 1940 (“Advisers Act”) imposes a fiduciary duty to
act in a client’s best interests and specifically prohibits investment advisers, directly or indirectly,
from engaging in any transaction, practice, or course of business which operates as a fraud or deceit
upon any client or prospective client.
However, the fiduciary duty to which advisers are subject is not specifically defined in the Advisers
Act or the Commission rules, but reflects a Congressional recognition “of the delicate fiduciary
nature of an investment advisory relationship” as well as a Congressional intent to eliminate, or at
least expose, all conflicts of interest which might incline an investment adviser, consciously or
unconsciously, to render advice which was not disinterested.
When selecting a mutual fund for a client’s advisory account, the investment advisor representative
has a fiduciary duty to select the share class that helps manage the overall fee structure of the
account. The overall fee structure includes such fees as:
• Asset Management Fee (Not to exceed 2%)
• Expense ratio, which includes 12b-1 fees, generally .25% for A shares.
• Trade Ticket Charges
o Equities and ETFs are $0 to $9.
o Mutual Funds, range from $0 to $26.50.
A Shares include 12b-1 fees but there are no ticket charges.
I Shares do not include 12b-1 fees there are ticket charges.
Ticket charges for A shares held in a wrap fee program require special consideration because the
ticket charges are included as part of the wrap fee program and paid by the adviser. Consequently,
A share do not offer the same level of benefit to a client that they do in a non-wrap fee account.
However, a different conflict of interet is introduced because the advisor now has an incentive to not
trade as frequently to aviod the ticket charges which can compromise the activie management of an
advisory account. This conflict is mitigated by an investment adviser representative’s fiduciary
duty to act in a clients best interest while also considering the higher asset management fee charged
for wrap fee accounts.
• Mutual funds normally offer multiple share classes, including lower-cost share
classes that do not charge 12b-1 fees and herefore less expensive.
• Investment adviser representatives will invest client funds in 12b-1 fee paying share
classes even when a lower-cost share class is available as appropriate to account for
the overall fee structure of the account.
• IARs benefit from investing clients in 12b-1 fee paying share classes because they
avoid paying LPL’s transaction charges.
• A Share mutual funds do not always have an otherwise equivalent I Share
alternative.
• Not all investors will qualify for I Shares, which can have a higher minimum
investment amount.
• 12b-1 fees are not retained by Clearview Financial Partners, LLC or an investment
advisor representative.
• 12b-1 fees are retained by LPL Financial, an unaffiliated member FINRA/SIPC
broker/dealer.
• LPL Financial does not share 12b-1 fees with individual investment adviser
representatives of Clearview Financial Partners, LLC in their capacity as
registered representatives of LPL Finacial.
Depending on the anticipated trading volume, and the asset management fee that that is determined
based on account size, complexity and time requirements, investment advisor representatives have a
fiduciary duty to determine the mutual fund share class that is in the best interest of each client as
part of the overall fee analysis.
Other Types of Fees and Charges
Program accounts will incur additional fees and charges from parties other than Clearview Financial
Partners as noted below. These fees and charges are in addition to the advisory fee paid to
Clearview Financial Partners. Clearview Financial Partners does not share in any portion of these
third-party fees.
The custodian and executing broker-dealer will impose certain fees and charges. Clients are
notified of these charges at account opening. The custodian will deduct these fees and charges
directly from the client’s program account.
There are other fees and charges that are imposed by other third parties that apply to investments in
program accounts. Some of these fees and charges are described below.
• If a client’s assets are invested in mutual funds or other pooled investment products, clients
should be aware that there will be two layers of advisory fees and expenses for those assets.
Client will pay an advisory fee to the fund manager and other expenses as a shareholder of
the fund. Client will also pay Clearview Financial Partners the advisory fee with respect to
those assets. Most of the mutual funds available in the program may be purchased directly.
Therefore, clients could generally avoid the second layer of fees by not using the
management services of Clearview Financial Partners and by making their own investment
decisions.
• Certain mutual funds impose fees and charges such as contingent deferred sales charges,
early redemption fees and charges for frequent trading. These charges may apply if client
transfers into or purchases such a fund with the applicable charges in a program account.
• If client holds a variable annuity as part of an account, there are mortality, expense and
administrative charges, fees for additional riders on the contract and charges for excessive
transfers within a calendar year imposed by the variable annuity sponsor.
Further information regarding fees assessed by a mutual fund, or variable annuity is available in the
appropriate prospectus, which is available upon request from Clearview Financial Partners or from
the product sponsor directly.
Other Important Considerations
• The advisory fee is an ongoing wrap fee for investment advisory services, the execution of
transactions and other administrative and custodial services. The advisory fee may cost the
client more than purchasing the program services separately, for example, paying an
advisory fee plus commissions for each transaction in the account. Factors that bear upon
the cost of the account in relation to the cost of the same services purchased separately
include the type and size of the account, historical and or expected size or number of trades
for the account, and number and range of supplementary advisory and client-related services
provided to the client.
• The advisory fee also may cost the client more than if assets were held in a traditional
brokerage account. In a brokerage account, a client is charged a commission for each
transaction, and the representative has no duty to provide ongoing advice with respect to the
account. If the client plans to follow a buy and hold strategy for the account or does not wish
to purchase ongoing investment advice or management services, the client should consider
opening a brokerage account rather than a program account.
• Clearview Financial Partners by recommending the program to the client receives
compensation as a result of the client’s participation in the program. This compensation
includes the advisory fee and also may include other compensation, such financial assistance
or the sponsorship of conferences and educational sessions, marketing support, incentive
awards, payment of travel expenses, and tools to assist with providing various services to
clients. The amount of this compensation may be more or less than what Clearview
Financial Partners would receive if the client participated in other LPL programs, programs
of other investment advisors or paid separately for investment advice, brokerage and other
client services. Therefore, Clearview Financial Partners may have a financial incentive to
recommend a program account over other programs and services.
• The investment products available to be purchased in the program can be purchased by
clients outside of a program account, through broker-dealers or other investment firms not
affiliated with Clearview Financial Partners.
• Investment advisor representatives may also be licensed insurance agents. In the capacity of
an insurance agent, they may recommend the purchase of certain insurance-related products
on a commission basis in addition to advisory fees.
• The purchase of securities and/or insurance commission product presents a conflict of
interest, as the receipt of commissions provides an incentive to recommend investment
products based on commissions received, rather than on a particular client’s need. No client
is under any obligation to purchase any commission products from Investment advisor
representatives of the firm. Clients may purchase investment products recommended by
investment advisor representatives through other, non-affiliated broker/dealers or insurance
agents. Such conflicts are subject to review by the Chief Compliance Officer for consistency
with the firm’s Code of Ethics.
• Clearview Financial Partners may establish agreements with a third-party adviser where that
third-party adviser offers various types of directly sponsored programs. Clearview Financial
Partners will ensure that any third-party adviser is properly registered and/or notice-filed
with the Department.
• Clearview Financial Partners has a conflict of interest and an incentive to recommend one
third-party advisers over
another; however, the firm has a fiduciary duty to act in the best
interests of the client.
Retirement Plan Consulting
Investment advisor representatives of Clearview Financial Partners may assist clients that are
trustees or other fiduciaries to retirement plans (“Plans”) by providing fee-based consulting and/or
advisory services. Investment advisor representatives may perform one or more of the following
services, as selected by the client in the client agreement:
• Assistance in the preparation or review of an investment policy statement (“IPS”) for the Plan
based upon consultation with client to ascertain Plan’s investment objectives and constraints.
• Acting as a liaison between the Plan and service providers, product sponsors or vendors.
• Ongoing monitoring of investment manager(s) or investments in relation to the criteria
specified in the Plan’s IPS or other written guidelines provided by the client.
• Preparation of reports describing the performance of Plan investment manager(s) or
investments, as well as comparing the performance to benchmarks.
• Ongoing recommendations, for consideration and selection by client, about specific
investments to be held by the Plan or, in the case of a participant-directed defined contribution
plan, to be made available as investment options under the Plan.
• Education or training for the members of the Plan investment committee with regard to various
matters, including plan features, retirement readiness matters, service on the committee, and
fiduciary responsibilities.
• Assistance in enrolling Plan participants in the Plan, including conducting an agreed upon
number of enrollment meetings. As part of such meetings, IARs may provide participants with
information about the Plan, which may include information on the benefits of Plan
participation, the benefits of increasing Plan contributions, the impact of pre-retirement
withdrawals on retirement income, the terms of the Plan and the operation of the Plan.
If the Plan makes available publicly traded employer stock (“company stock”) as an investment
option under the Plan, investment advisor representatives do not provide investment advice regarding
company stock and are not responsible for the decision to offer company stock as an investment
option. In addition, if participants in the Plan may invest the assets in their accounts through
individual brokerage accounts, a mutual fund window, or other similar arrangement, or may obtain
participant loans, investment advisor representatives do not provide any individualized advice or
recommendations to the participants regarding these decisions. Furthermore, investment advisor
representatives do not provide individualized investment advice to Plan participants regarding their
Plan assets.
Retirement Plan Rollovers
An employee generally has four (4) options for their retirement plan when they leave an employer:
1. Leave the money in his/her former employer’s plan, if permitted
2. Rollover the assets to his/her new employer’s plan, if one is available and permitted
3. Rollover to an Individual Retirement Account (IRA), or
4. Cash out the account value, which has significant tax considerations
Clearview Financial Partners may recommend that retirement plan assets be rolled-over into an IRA
managed by Clearview Financial Partners based on a particular client’s financial circumstances.
Clearview Financial Partners has an incentive to recommend such a rollover based on the
compensation received, which is mitigated by the fiduciary duty to act in a client’s best interest and
acting accordingly.
ERISA Fiduciary
Such services provided as an investment advisor are subject to the Investment Advisers Act of
1940 (“Advisers Act”), and the advisor is a fiduciary under the Advisers Act with respect to such
services. In addition, if client elects to engage an investment advisor representative to perform
ongoing investment monitoring and ongoing investment recommendation services to a Plan subject
to ERISA in the client agreement, such services will constitute “investment advice” under Section
3(21)(A)(ii) of ERISA. Therefore, the investment advisor representatives will be deemed a
“fiduciary” as such term is defined under Section 3(21)(A)(ii) of ERISA in connection with those
services. Clients should understand that to the extent the investment advisor representative is engaged
to perform services other than ongoing investment monitoring and recommendations, those services
are not “investment advice” under ERISA and therefore, the investment advisor representative will
not be a “fiduciary” under ERISA with respect to those other services.
From time to time the investment advisor representative may make the Plan or Plan participants
aware of and may offer services available from IAR that are separate and apart from the services
provided under Retirement Plan Consulting. Such other services may be services to the Plan, to a
client with respect to client's responsibilities to the Plan and/or to one or more Plan participants. In
offering any such services, the investment advisor representative is not acting as a fiduciary under
ERISA with respect to such offering of services. If any such separate services are offered to a client,
the client will make an independent assessment of such services without reliance on the advice or
judgment of the IAR.
Third Party Investment Advisers
Clearview Financial Partners has entered into agreements with various third-party advisers. Under
these agreements, the Adviser offers clients various types of programs sponsored by these advisers.
All third-party investment advisers to whom the Adviser will refer clients will be licensed as
investment advisers by their resident state and any applicable jurisdictions or registered investment
advisers with the SEC.
After gathering information about a client's financial situation and investment objectives, the Adviser
will assist the client in selecting a particular third-party program. The Adviser receives compensation
pursuant to its agreements with these third-party advisers for introducing clients to these third-party
advisers and for certain ongoing services provided to clients. In such situations, the third-party
investment adviser shall have the day-to-day responsibility for the active management of the
allocated program assets.
This compensation is disclosed to the client in a separate disclosure document and is typically equal
to a percentage of the investment advisory fee charged by that third-party adviser or a fixed fee. The
disclosure document provided by the Adviser will clearly state the fees payable to the Adviser and
the impact to the overall fees due to these payments.
Since the compensation an adviser receives may differ depending on the agreement with each third-
party adviser, the adviser may have an incentive to recommend one third-party advisers over another,
if the compensation arrangements are more favorable. Since the independent third-party adviser may
pay the fee for the investment advisory services of the Adviser, the fee paid to the Adviser is not
negotiable, under most circumstances. Such a conflict is mitigated by Clearview Financial Partner’s
fiduciary duty to act in the best interest of their clients and acting accordingly.
Clients who are referred to third-party investment advisers will receive full disclosure, including
services rendered and fee schedules, at the time of the referral, by delivery of a copy of the relevant
third-party adviser's Form ADV 2A at the same time as the Form ADV 2A of the Adviser.
In addition, if the investment program recommended to a client is a wrap fee program the client will
also receive the wrap fee brochure provided by the sponsor of the program. The Adviser will provide
to each client all appropriate disclosure statements, including disclosure of solicitation fees to the
Adviser and its advisory associates.
Conflicts of Interest
Investment adviser representatives must fully disclose all material facts concerning any conflict,
and should avoid even the appearance of a conflict of interest and abide by honest and ethical
business practices.
• Investment advisor representatives of Clearview Financial Partners are also registered
representatives of LPL Financial to other securities transactions for a commission.
• Investment advisor representatives of Clearview Financial Partners are also insurance
agents appointed with multiple insurance carriers to sell insurance products for a
commission.
o The recommendation that a client purchase a commission product from an
investment advisor representative in their separate capacity as a registered
representative of LPL or as an agent of an insurance company presents a conflict of
interest, as the receipt of commissions provides an incentive that may not be in a
client’s best interests.
• Investment advisor representatives must not induce trading in a client's account that is
excessive in size or frequency in view of the financial resources and character of the
account.
• Investment advisor representatives must make recommendations with reasonable grounds
to believe that they are appropriate based on the information furnished by the client.
• Investment advisor representatives may not borrow money or securities from, or lend
money or securities to a client.
• Investment advisor representatives must not place an order for the purchase or sale of a
security if the security is not registered, or the security or transaction is not exempt from
registration in the specific state.
• Product sponsors may pay for, or reimburse Clearview Financial Partners for the costs
associated with, education or training events.
• The code of ethics permits employees and investment advisor representatives or related
persons to invest for their own personal accounts in the same or different securities that
an investment advisor representative may purchase for clients in program accounts.
Such conflicts and risk of misconduct are mitigated by an investment adviser representative’s
fiduciary duty to act in the best interests of its clients and acting accordingly. The firm’s Chief
Compliance Officer, David Fitzgerald, is available to address any questions regarding conflicts of
interest.
Third-Party Advisory Services
Clearview Financial Partners is paid by third party money managers when we refer you to them
and you decide to open a managed account. Third party money managers pay us a portion of the
investment advisory fee that they charge you for managing your account. Fees paid to us by third
party money manager are generally ongoing. All fees we receive from third party money managers
and the written separate disclosures made to you regarding these fees comply with applicable state
statutes and rules. The separate written disclosures you need to be provided include:
• a copy of the third-party money manager’s Form ADV 2A;
• all relevant Brochures;
• a Solicitation Disclosure Statement detailing the exact fees we are paid; and,
• a copy of the third-party money manager’s privacy policy.
The fees for such managers and their services are different to the fees described above. However,
the total advisory fee for an account utilizing these managers shall not exceed a 2.99% annual fee.
The third-party money managers we recommend will not charge you a higher fee than they would
have charged without our introduction.
Third party money managers establish and maintain their own separate billing processes over
which we have no control. In general, they will directly bill you and describe how this works in
their separate written disclosure documents.
eMoney Advisor Platform
Clearview Financial Partners may provide clients with access to an online platform hosted by
“eMoney Advisor” (“eMoney”). The eMoney platform allows a client to view his/her complete
asset allocation, including those assets not managed by Clearview Financial Partners, known as
“Excluded Assets”. The eMoney tool also has financial planning tools. That can be used directly
by a client.
Clearview Financial Partners is only able to exercise a fiduciary duty when engaged to manage
otherwise excluded assets or provide guidance and oversight when using the financial planning
tools provided with the eMoney platform.
Other Considerations
Neither the firm nor any investment advisor representative are registered or have an application
pending to register, as a futures commission merchant, commodity pool operator, a commodity trading
advisor, or a representative of the foregoing.
Clearview Financial Partners is not a law firm or an accounting firm and does not offer legal or
accounting services. Accordingly, Clearview Financial Partners does not prepare legal documents or
prepare tax returns. Clearview Financial Partners may introduce clients to other professionals for such
non-investment related services, which in some cases may be an investment adviser representative of
Clearview Financial Partners acting in an unaffiliated separate individual capacity. Clients are under
no obligation to use these professionals and should conduct their own due-diligence prior to engaging
their services. Clearview Financial Partners should not be considered a party to any disputes that may
arise.
Certain mutual funds recommended by investment adviser representatives of Clearview Financial
Partners are publicly available for purchase without engaging the services of Clearview Financial
Partners. However, if a client elects to make such direct purchases, they do so without the benefit of
the on-going advisory services offered by Clearview Financial Partners.