Description of Services
Verity and Verity, LLC d/b/a Verity Investment Partners and Verity Investment Management is a
registered investment adviser based in Beaufort, South Carolina with offices in Bluffton, South
Carolina, Edwards, Colorado and San Antonio, Texas. We are organized as a limited liability company
under the laws of the State of South Carolina. We have been providing investment advisory services
since 2002. William W. Verity is our firm's principal owner.
The following paragraphs describe our services. Please refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we", "our" and "us" refer to Verity Investment Partners and
the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also,
you may see the term Associated Person throughout this brochure. As used in this brochure, our
Associated Persons are our firm's officers, employees, and all individuals providing investment advice
on behalf of our firm.
We offer discretionary investment management services. Our investment advice is tailored to meet our
clients' needs and investment objectives. If you retain our firm for portfolio management services, we
will meet with you to determine your investment objectives, risk tolerance, and other relevant
information (the "suitability information") at the beginning of our advisory relationship. We will use the
suitability information we gather to develop a strategy that enables our firm to give you ongoing and
focused investment advice and/or to make investments on your behalf. Once we construct an
investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis and will
rebalance the portfolio as required by changes in market conditions and in your financial
circumstances.
We request you grant our firm discretionary authority to manage your account. Discretionary
authorization will allow our firm to determine the specific securities, and the amount of securities, to be
purchased or sold for your account without your approval prior to each transaction. Discretionary
authority is typically granted by the investment advisory agreement you sign with our firm, a power of
attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting
the types of securities that can be purchased for your account) by providing our firm with your
restrictions and guidelines in writing.
Financial Planning
We offer financial planning services but do not charge separately for this service. Our financial
planning services may be general in nature or focused on particular areas of interest or request,
depending on each client's unique circumstances and goals. Financial planning advice is offered in the
areas of goal setting, cash flow and debt management, retirement planning, investment planning,
college education funding, tax planning and estate planning as applicable. We offer such services as
requested by the client and the client is responsible for implementing, accepting or rejecting any plans
we may present. We do not serve as an attorney, accountant, insurance agent and no portion of our
services should be construed as same.
Limitations of Financial Planning
To the extent requested by a client, we may recommend the services of other professionals for certain
non-investment implementation purposes. You are under no obligation to engage the services of any
such recommended professional. The client retains absolute discretion over all such implementation
decisions and is free to accept or reject any recommendation that we make. Please note: If the client
engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such
March 2024 5
engagement, the client agrees to resolve the dispute directly with the engaged professional.
Advisory Services to Retirement Plans and Plan Participants
As disclosed above, we offer investment advisory and financial planning services. For Plans that allow
participants to have self-directed accounts, we provide our services to employee benefit plan
participants (“Participants”) or pooled accounts. The services are designed to assist plan sponsors in
meeting their management and fiduciary obligations to Participants under the Employee Retirement
Income Securities Act (“ERISA”). Pursuant to adopted regulations of the U.S. Department of Labor, we
are required to provide the Plan's responsible plan fiduciary (the person who has the authority to
engage us as an investment adviser to the Plan) with a written statement of the services we provide to
the Plan, the compensation we receive for providing those services, and our status (which is described
below).
The services we provide to your Plan and the compensation we receive for these services are
described above, and in the service agreement that you have previously signed. We do not reasonably
expect to receive any other compensation, direct or indirect, for the services we provide to the Plan or
Participants, unless the plan sponsor directs us to deduct our fee from the plan or directs the plan
record-keeper to issue payment for our fee out of the plan. If we receive any other compensation for
such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly
disclose the amount of such compensation,
the services rendered for such compensation and the
payer of such compensation to you.
IRA Rollover Considerations and Recommendations
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. We comply with the Department of Labor (“DOL”) Prohibited
Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable. Our firm is providing the following
additional acknowledgment:
When we provide investment advice to individuals regarding a retirement plan account or individual
retirement account, the firm is deemed a fiduciary 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 potential conflicts with a client’s
interest. Therefore, we, operate under a special rule which requires the firm to act in a client’s best
interest and not put our interests ahead of the client. 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 a client when making recommendations (give
loyal advice);
• Avoid misleading statements about conflicts of interest, fees and investments;
• Follow policies and procedures designed to ensure advice given is in the client’s best
interest;
• Charge no more than is reasonable for services; and
• Provide basic information about conflicts of interest.
We benefit financially from the rollover of a client’s assets from a retirement account to an account
managed by the firm. This is a primary conflict of interest because when we provide investment advice,
the assets increase the firm assets under management and, in turn, advisory fees. To meet the
fiduciary responsibility we only recommend a rollover when it is deemed in the client’s best interest.
March 2024 6
Sub-Advisory Services to Registered Investment Advisers
We may also serve as a sub-adviser to unaffiliated registered investment advisers per the terms and
conditions of a written agreement. With respect to its sub-advisory services, the unaffiliated
investment advisers that engage our sub-advisory services maintain both the initial and ongoing day-
to-day relationship with the underlying client, including initial and ongoing determination of client
suitability for our designated investment strategies. If the custodian/broker-dealer is determined by the
unaffiliated investment adviser, we will be unable to negotiate commissions and/or transaction costs,
and/or seek better execution. As a result, underlying accounts may pay higher commissions or other
transaction costs or greater spreads, or receive less favorable net prices, on transactions for the
account than would otherwise be the case through alternative clearing arrangements recommended by
us. Higher transaction costs adversely impact account performance.
Investment Strategy and Research Services to Registered Investment Advisers
We may provide model portfolios to unaffiliated registered investment advisers (third party) for their
use in managing their underlying clients’ accounts. Per the terms of the written agreement, with the
unaffiliated registered investment adviser we do not have an advisory, fiduciary or other relationship
with any of the third party’s underlying client(s). The unaffiliated registered investment adviser is
exclusively responsible for determining the suitability of the model portfolio for their underlying client(s)
and whether to implement any of the model portfolios.
Status
In providing services to the Plan and Participants, our status is that of an investment adviser registered
under the Investment Advisers Act of 1940, and we are not subject to any disqualifications under
Section 411 of ERISA. In performing fiduciary services, we are acting as a discretionary fiduciary of the
plan as defined in Section 3(38) under ERISA.
Types of Investments
In general, we offer advice on equity securities, ETFs, corporate debt securities, commercial paper,
certificates of deposit, municipal securities, mutual funds, U.S. Government securities, interests in
partnerships investing in real estate and oil and gas interests and other investments. You may request
that we refrain from investing in particular securities or certain types of securities. You must provide
these restrictions to our firm in writing.
Client Obligation
In performing our services, Verity Investment Partners shall not be required to verify any information
received from the client or from the client's other professionals and is expressly authorized to rely
thereon. Each client is advised that it remains his/her responsibility to promptly notify us in writing if
there is ever any change in his/her financial situation or investment objectives for the purpose of
reviewing/evaluating/revising our previous recommendations and/or services. We also request that you
keep us advised of any changes of address, phone, email and the like.
Assets Under Management
As of December 31, 2023, we provide continuous management services for $930,833,366 in client
assets on a discretionary basis as well as $7,900,558 on a non-discretionary basis.
March 2024 7