A. Ownership/Advisory History
Clarity Financial Advisors LLC (“Clarity Financial” or the “firm”) is a registered investment advisor
with the U.S. Securities and Exchange Commission (“SEC”). The firm is organized as a limited
liability company (“LLC”) under the laws of the State of Florida. Clarity Financial was founded in
September 2022 and is owned and operated by Trevor K. Shultz (Principal and Chief Compliance
Officer) and William A. Root (Principal). This disclosure brochure provides information regarding
the qualifications, business practices, and the advisory services provided by Clarity Financial.
B. Advisory Services Offered
Investment Management Services
Clarity Financial provides 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 Financial works
closely with each client to identify their investment goals and objectives as well as risk tolerance
and financial situation in order to create a portfolio strategy. For its discretionary asset
management services, Clarity Financial receives a limited power of attorney to effect securities
transactions on behalf of its clients that include securities and strategies described in Item 8 of
this brochure.
Clarity Financial’s investment strategies are primarily long-term focused, but the firm may buy,
sell, or re-allocate positions that have been held for less than one year to meet the objectives of
the client or due to market conditions. Clarity Financial 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 firm.
Clarity Financial evaluates and selects investments for inclusion in client portfolios only after
applying its internal due diligence process. Clarity Financial may recommend, on occasion,
redistributing investment allocations to diversify the portfolio. Clarity Financial may recommend
specific positions to increase sector or asset class weightings. Clarity Financial may recommend
employing cash positions as a possible hedge against market movement.
Clarity Financial 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 the client, generating cash to meet client needs, or any risk deemed
unacceptable for the client’s risk tolerance.
Clients have the right to provide the firm with any reasonable investment restrictions that should
be imposed on the management of their portfolio (must be in writing and sent to the firm), and
should promptly notify the firm in writing of any changes in such restrictions or in the client's
personal financial circumstances, investment objectives, goals and tolerance for risk. Clarity
Financial will remind clients of their obligation to inform the firm of any such changes or any
restrictions that should be imposed on the management of the client’s account. Clarity Financial
will also contact clients at least annually to determine whether there have been any changes in a
client's personal financial circumstances, investment objectives and tolerance for risk.
Retirement Plan Participant Account Management (Discretionary)
We use a third-party platform (Pontera Order Management System) to facilitate
management of held away assets such as defined contribution plan participant accounts, with
discretion. The platform allows us to avoid being considered to have custody of client funds
since we do not have direct access to client log-in credentials to effect trades. We are not
affiliated with the platform in any way and receive no compensation from them for using their
platform. A link will be provided to the client allowing them to connect an account(s) to the
platform. Once client account(s) is connected to the platform, we will review the current
account allocations. When deemed necessary, we will rebalance the account considering client
investment goals and risk tolerance, and any change in allocations will consider current
economic and market trends. The goal is to improve account performance over time, minimize
loss during difficult markets, and manage internal fees that harm account performance. Client
account(s) will be reviewed at least quarterly and allocation changes will be made as deemed
necessary.
We may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between our firm and the client.
Retirement Accounts
When Clarity Financial provides investment advice to clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the firm is a fiduciary within the meaning
of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal
Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When
deemed to be in the client’s best interest, Clarity Financial will provide investment advice to a
client regarding a distribution from an ERISA retirement account or to roll over the assets to
an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored plan
to another, one IRA to another IRA, or from one type of account to another account (e.g.,
commission-based account to fee-based account). Such a recommendation creates a conflict
of interest if the firm will earn a new (or increase its current) advisory fee as a result of the
transaction. No client is under any obligation to roll over a retirement account to an account
managed by Clarity Financial.
Use of Independent
Managers
Clarity Financial may recommend that a client utilize one or more unaffiliated investment
managers or investment platforms (collectively “independent manager(s)”) for all or a portion
of a client’s investment portfolio. In such instances, the client may be required to authorize
and enter into an advisory agreement with the independent manager(s) that defines the terms
in which the independent manager(s) will provide investment management and related
services. Clarity Financial may also assist in the development of the initial policy
recommendations and managing the ongoing client relationship. Clarity Financial will perform
initial and ongoing oversight and due diligence over the selected independent manager(s) to
ensure the independent manager(s)’ strategies and target allocations remain aligned with its
clients’ investment objectives and overall best interests. The client, prior to entering into an
agreement with unaffiliated investment manager(s) available on one or more platform(s) that
the firm has an agreement with, will be provided with the independent manager(s)’ Form ADV
2A (or a brochure that makes the appropriate disclosures).
Financial Planning and Consulting Services
Clarity Financial will typically provide a variety of financial planning and consulting services to
clients. Services may be included as part of an overall wealth management engagement or
separately billed pursuant to a written financial planning agreement.
Services are offered in several areas of a client’s financial situation, depending on their goals and
objectives. 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,
insurance needs, 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/or
charitable giving programs.
Clarity Financial may also refer clients to an accountant, attorney, or other specialists as
appropriate for their unique situation. For certain financial planning engagements, Clarity
Financial will provide a written summary of the client’s financial situation, observations, and
recommendations. For consulting or ad-hoc engagements, Clarity Financial may not provide a
written summary. Plans or consultations are typically completed within six (6) 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
Clarity Financial and the interests of the client. For example, Clarity Financial has an incentive to
recommend that clients engage the firm for investment management services or to increase the
level of investment assets with Clarity Financial, as it would increase the amount of advisory fees
paid to the firm. Clients are not obligated to implement any recommendations made by Clarity
Financial or maintain an ongoing relationship with the firm. If the client elects to act on any of
the recommendations made by Clarity Financial, the client is under no obligation to implement
the transaction through Clarity Financial.
Basic Financial Plan as Part of AUM Fee
Clients with a minimum of $100,000 in assets under management with Clarity Financial are
offered a basic financial plan at no additional charge. The basic financial plan will include (i) a
financial report overviewing their assets, liabilities, income, and relevant insurance; and (ii) a
two-page financial plan that lists their goals, account recommendations, contribution
recommendations, and several relevant notes about their overall financial picture.
C. Client-Tailored Services and Client-Imposed Restrictions
Prior to engaging Clarity Financial to provide investment advisory services, each client is
required to enter into one or more agreements with Clarity Financial that define the terms,
conditions, authority and responsibilities of Clarity Financial and the client. These services may
include:
Establishing an Investment Strategy – Clarity Financial, in connection with the client, will
develop a strategy that seeks to achieve the client’s goals and objectives.
Asset Allocation – Clarity Financial 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 Financial will develop a portfolio for the client that is
intended to meet the stated goals and objectives of the client.
Investment Management and Supervision – Clarity Financial will provide investment
management and ongoing oversight of the client’s investment portfolio.
Each client’s account will be managed on the basis of the client’s financial situation and
investment objectives and in accordance with any reasonable restrictions imposed by the client
on the management of the account—for example, restricting the type or amount of security to
be purchased in the portfolio.
D. Wrap Fee Programs
Clarity Financial does not participate in wrap fee programs, where brokerage commissions and
transaction costs are included in the asset-based fee charged to the client.
E. Client Assets Under Management
As of December 31, 2023, Clarity Financial manages $79,897,323 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.