Claris Advisors is owned by 41 individual Members (see www.adviserinfo.sec.gov for Claris Advisors’ Form ADV Part 1, Schedule A for a list of all individual’s names) and has been providing advisory services since 1999. As of December 31, 2023, Claris Advisors managed $677,649,175 on a discretionary basis and $0 on a non-discretionary basis and advised on $71,207,066 of participant-directed retirement plan assets. Investment Management Services: Claris Advisors manages investment portfolios for individuals, trusts, charitable organizations, businesses and qualified retirement plans. Claris Advisors will work with the client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. Claris Advisors uses investment and portfolio allocation software to evaluate alternative portfolio designs. Claris Advisors evaluates the client's existing investments with respect to the client's investment policy statement. Claris Advisors works with new clients to develop a plan to transition for moving from the client's existing portfolio to the desired portfolio. Claris Advisors will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold regular review meetings with the client regarding the account as necessary. Claris Advisors will typically create a portfolio of no-load mutual funds. And may use model portfolios if the models match the client's investment policy. Claris Advisors will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. Claris Advisors primarily recommends portfolios consisting of mutual funds offered by Dimensional Fund Advisors (DFA). DFA sponsored mutual funds follow a passive asset class investment philosophy with low holdings turnover. Consequently, the DFA fund fees are generally lower than other fees and expenses charged by other types of funds. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. These situations will be specifically identified in the client’s Investment Policy Statement (IPS). Claris Advisors manages mutual fund and equity portfolios on a discretionary basis. A client may impose any reasonable restrictions on Claris Advisors’ discretionary authority, including restrictions on the types of securities in which Claris Advisors may invest client’s assets and on specific securities, which the client may believe to be appropriate. Use of Third-Party Sub-Advisers: Claris Advisors has retained Buckingham Strategic Partners, LLC (“BSP)” to act as a sub- advisor for certain client accounts. BSP shall provide various model asset allocation portfolios (each a “Portfolio”, collectively “Portfolios”) for selection by Claris Advisors. Each Portfolio strives to achieve long-term risk and return objectives through diversification among multiple asset classes using investment options available to BSP, which may include, but not limited to, mutual funds and/or exchange traded funds from Dimensional Fund Advisors LP, Bridgeway Capital Management, Inc., AQR Capital Management, LLC, The Vanguard Group, Inc., Stoneridge Asset Management, LLC or other providers selected by BSP. Each Portfolio is designed to meet a particular investment goal which Claris Advisors has determined is suitable based on the client's circumstances. Once the appropriate Portfolio(s) has been determined, the Portfolio will continuously be managed based on the portfolio’s goal and BSP will have the discretionary authority to manage the Portfolio(s), including periodically rebalancing. However, Adviser, on behalf of its client, will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Should material life events occur, clients should immediately contact Claris Advisors to determine if changes to an account and the allocation of the assets held in the account are necessary. Claris Advisors may also recommend fixed income portfolios to advisory clients, which consist of managed accounts of individual bonds. Claris Advisors will request discretionary authority from advisory clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. Claris Advisors will prepare a separate Fixed Income Investment Policy Statement for any client qualifying for separate fixed income portfolio services. Pursuant to its discretionary authority, Claris Advisors will retain an independent separate account manager (“Independent Manager”) for the management of certain aspects of client portfolios. The Independent Manager will be provided with the discretionary authority to invest client assets in a manner consistent with the client's Investment Policy Statement. The Independent Manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). Claris Advisors has hired Buckingham Strategic Partners (“BSP”) as the Independent Manager for fixed income portfolios. In certain circumstances, as determined by Claris Advisors and the client, Claris Advisors may also engage DFA as an Independent Manager to manage portfolios of individual securities for clients. In these instances, DFA’s fees

are separate, distinct, and in addition to Claris Advisors advisory fees. On an ongoing basis, Claris Advisors will answer clients' inquiries regarding their accounts and review periodically with clients the performance of their accounts. Claris Advisors will periodically, and at least annually, review client's investment policy, risk profile and to discuss the re-balancing of each client's accounts to the extent appropriate. Claris Advisors will provide to the Independent Manager any updated client financial information or account restrictions necessary for investment manager to provide sub-advisory services. In addition to managing the client’s investment portfolio, Claris Advisors may consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. Employee Benefit Retirement Plan Services: Claris Advisors also provides advisory services to participant-directed employee retirement benefit plans through several qualified third-party administration companies. These TPA's are online bundled service providers offering passive investment vehicles and an opportunity for plan sponsors to provide diversified portfolios to their participants along with daily account access. Claris Advisors will analyze the plans current investment platforms, and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. Claris Advisors will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. Claris Advisors will recommend changes in the plan's investment vehicles as may be appropriate from time to time. Claris Advisors generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, Claris Advisors also works in coordination and support with Buckingham Strategic Partners, LLC. Retirement plan clients will engage both Claris Advisors and Buckingham Strategic Partners, LLC. Buckingham Strategic Partners, LLC will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintain the plans’ investments according to the goals and investment objectives of the plan. Claris Advisors will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Financial Planning Services: Claris Advisors also provides advice in the form of a Financial Plan. Clients purchasing this service may receive a written financial plan, providing the client with a detailed financial plan designed to achieve their stated financial goals and objectives. In general, the financial plan will address any or all of the following areas of concern:
• Personal: Family records, budgeting, personal liability, estate information and financial goals.
• Education: Education IRAs, financial aid, state savings plans, grants and general assistance in preparing to meet dependent’s continuing educational needs through development of an education plan.
• Tax & Cash Flow: Income tax and spending analysis and planning for past, current and future years. Claris Advisors may illustrate the impact of various investments on a client’s current income tax and future tax liability.
• Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis.
• Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals.
• Investments: Analysis of investment alternatives and their effect on a client’s portfolio. Claris Advisors gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed and a written report may be prepared. This service is conducted through several client meetings gathering necessary data and determining client goals and objectives. Consulting Services Claris Advisors may provide general consultancy services with respect to business exit plan strategies, business succession planning, insurance policy review, other wealth and estate management projects as well as general strategic business planning to clients of our affiliated CPA firm, Anders, Minkler Huber & Helm, LLP (“Anders”). Claris Advisors will work with Anders’ expert Team to provide analysis and guidance on strategic business planning. Claris Advisors does not bill the client directly for these services, rather is compensated from Anders for the hourly work performed in this capacity as part of the Exit Planning Team. Typically, these clients will be clients of Anders rather than of Claris Advisors. The clients will either enter into a Consulting Services Agreement or a Financial Planning Services Agreement with Claris Advisors based upon the individual client needs and will pay either a flat financial planning fee or an hourly rate. The flat financial planning fee will be shared with Anders as outlined in our ADV in Item 5.