A) Firm Information Todd Allen Rustman is the owner of Clarity Capital Partners (hereinafter “CCP”). CCP was founded in September 2000 and is organized in the State of Delaware. We have a growing number of Wealth Managers, Associate Wealth Managers and Associates working as a team within the firm. Todd Rustman, in particular, has been in the advisory/wealth management business for over 30 years. He has worked for Long Term Credit Bank of Japan (LTC B), PIMCO, Mellon Private Asset Management and Kayne Anderson Investment Management before starting CCP. B) Advisory Services Provided CCP performs investment advisory to individuals, high net worth individuals, trusts, estates, companies, a private fund, and pension/profit sharing plans. We use many wealth management techniques, allocations and income strategies to manage and grow our client's portfolios. By coordinating in a team approach with our clients’ other advisors, we achieve greater synergies in tax efficiency, asset protection and legacy planning. Investment Management CCP provides customized investment advisory solutions for its clients. CCP works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio allocation. CCP will then construct a portfolio, consisting of equity securities (exchange-listed securities, securities traded over the counter (OTC), and foreign issuers), debt securities (government treasuries, corporate, municipal and agency debt), and investment company securities (alternatives, variable life insurance, variable annuities, exchange-traded funds, and mutual fund shares). The Advisor may utilize other types of investments, as necessary, to meet the needs of its Clients. CCP’s investment strategy is 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. CCP 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 the acceptance by the Advisor. CCP evaluates and selects investments for inclusion in Client portfolios only after applying their internal due diligence process. CCP may recommend, on occasion, redistributing investment allocations to diversify the portfolio. CCP may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. CCP 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. Prior to rendering investment advisory services, CCP will ascertain, in conjunction with the Client, the Client’s financial situation, risk tolerance, and investment objective[s]. CCP will provide investment advisory services and portfolio management services and will not provide securities custodial or other administrative services. All Client assets will be managed within their designated brokerage account or pension account, pursuant to the Client Investment Advisory Agreement. Held Away Account Services We use a third-party platform to manage assets such as defined contribution plan participant accounts that are not directly accessible to us. 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 affect trades in these accounts. 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 a Client account(s) is connected to the platform,

we will review the current account allocations and, when we deem necessary, we will rebalance the account considering client investment goals and risk tolerance. Financial Planning and Consulting Services CCP will typically provide a variety of financial planning services to individuals and families, pursuant to a written Financial Planning or Consulting Agreement. Services are offered in several areas of a client’s financial situation, depending on their goals, objectives and financial situation. Fees for service in preparation for a Financial Plan range from $1500-$10,000/year depending upon complexity. 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. CCP may also refer Clients to an accountant, attorney or other Trusted Advisor, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. 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 may pose a potential conflict between the interests of the Advisor and the interests of the Client. 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 effect the transaction through the Advisor. Client Account Management Prior to engaging CCP to provide investment advisory services, each Client is required to enter into an Investment Advisory Agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Policy Statement – CCP, in connection with the Client, may develop a statement that summarizes the Client’s investment goals and objectives along with the broad strategy[ies] to be employed to meet the objectives. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to the acceptance by the Advisor.
• Asset Allocation – CCP 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 – CCP will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – CCP will provide investment management and ongoing oversight of the Client’s portfolio and overall account. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Assets Under Management As of the December 2023, the Advisor manages $371,419,409 in discretionary assets under management. Clients may request more current information at any time by contacting the Advisor.