CLEARSTEAD; HARTLAND & CO., LLC; CLEARSTEAD ADVISORY SOLUTIONS

Clearstead Advisors, LLC (“Clearstead”), is a SEC-registered investment adviser with its principal place of business located in Cleveland, Ohio. Clearstead has a wholly-owned subsidiary named Clearstead Trust, which is a Maine[1]chartered trust company that can provide trustee services to Clearstead clients. Clearstead also has a wholly-owned subsidiary named Avalon Trust, which is a New Mexico-chartered trust company that can provide trustee services to Clearstead clients.

Clearstead is an independent investment advisory firm founded as Hartland & Co in 1989. Clearstead is owned by Hartland Management Investors, LLC (“HMI”), which holds the shares of Clearstead’s employees with approximately 40% ownership and Flexpoint Ford, LLC, through the entity Moses Buyer Holdings, LLC (“Flexpoint Ford”) with approximately 60% ownership. Effective October 23rd, 2018, Hartland & Co., LLC changed its legal name to Clearstead Advisors, LLC (“Clearstead”). This was only a name change with no change in ownership or control. Clearstead does business under its new name; however, it is also able to conduct business under the name Hartland & Co., LLC (“Hartland”). Through the acquisition of CLS Consulting, LLC (“CLS”), Clearstead continues to maintain the website for CLS (www.clsconsultingllc.com).

Clearstead is structured to put client’s interests first. The firm makes every effort to remove or mitigate any conflicts of interest and is dedicated to serving client interests with the highest standards of fiduciary and professional conduct. Clearstead is independent and believes this is central to providing objective and high-quality advice to its clients. To back up its commitment to clients, the firm has adopted a Conflicts of Interest Policy and Standards of Conduct. 

Clearstead has worked successfully for many years with diverse clients, providing advice on investment policy, asset allocation, manager selection and other related financial issues. Its advisors have deep professional and personal experience in institutional consulting, investment research and wealth management. We have a strong leadership team supported by an outstanding Board of Directors, all of whom are leaders in their fields.

Clearstead serves its institutional clients with the Investment Metrics reporting system to ensure timely and accurate information and provide robust portfolio analysis and peer group benchmarking for Clearstead clients. Clearstead believes that the disciplines it has developed for the institutional marketplace - portfolio analytics, manager research, aggregation of information and clear reporting - are applicable and valuable to families and individuals as well. 

SERVICES PROVIDED 

This Part 2A of Form ADV describes services provided to Clearstead institutional clients. A separate Part 2A of Form ADV describes services provided to private clients.

Clearstead provides both traditional investment consulting services (non-discretionary) and discretionary services. Clearstead is capable of accepting fiduciary responsibility under Section 3(21) and as an investment manager under Section 3(38) of ERISA. The primary clients for these services will be institutions - pension, profit sharing and 401(k) plans, endowments, foundations and operating non-profits, such as healthcare organizations - as well as private clients; individuals, trusts and estates. 

Institutional Consulting (Traditional and OCIO Discretionary Services)

Clearstead Institutional Consulting Group delivers fiduciary oversight and advice under the following process. First, Clearstead assists in the development, implementation and monitoring of Investment Policy Statements (IPS) for all clients. An IPS is a set of standards that prescribes how client assets will be invested, monitored, and measured. These standards begin with articulation of investment objectives and what a client expects to achieve with its assets. The investment policy also establishes guidelines for the way funds are to be invested in various asset classes and how performance will be measured and compared. In working with clients on investment policy, Clearstead 5 addresses time horizons, spending needs, ability to accept volatility, and client-specific or cultural considerations. Clearstead then prepares a written IPS detailing those needs and goals, including an encompassing plan under which these goals are to be achieved.

Second, Clearstead assists clients in identifying strategic asset allocation aligned with the institution’s objectives. Portfolios are then constructed using the IPS and firm’s criteria for selection of investment vehicles. 

Third, Clearstead provides ongoing monitoring of client investments based on the procedures and timing intervals delineated in the Investment Policy Statement and Clearstead’s internal processes. Clearstead is able to engage a client in two ways: 1) in a traditional consulting capacity in which Clearstead supervises the client’s portfolio and seeks approval for recommendations in advance of implementing 2) under our PRISM OCIO discretionary service where Clearstead supervises client portfolios and is delegated discretionary authority for portfolio implementation. 

Lastly, Clearstead creates clear and accurate periodic reports, including Monthly "Flash" Reports, Quarterly Performance Reports and Special Reports on topics relevant to the client. 

For pension, profit sharing, and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), Clearstead provides general educational guidance for plan administrators and in limited circumstances plan participants. The nature of the topics covered will be determined by Clearstead and the client under the guidelines established in ERISA Section 404(c). The educational support will NOT provide plan participants with individualized, tailored investment advice or individualized or tailored asset allocation recommendations. 

Clearstead also acts as a “Qualified Professional Asset Manager” (QPAM) under the Employee Retirement Income Security Act of 1974 (ERISA), providing requested guidance to fiduciaries on specific transactions related to particular assets of employee benefit plan investors. 

ERISA Plan Services

When we provide investment advice to you regarding your retirement plan, we are fiduciaries 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. 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.

Sub-Advisor Investment Management 

Clearstead offers discretionary sub-advisory investment management services to the individual clients of unaffiliated advisors. Under this service, the unaffiliated advisor will act as the primary advisor and fiduciary with the option to provide investment management services to its individual clients directly or engage with Clearstead as a sub-advisor to provide discretionary investment management and trade execution services. When Clearstead acts as a sub-advisor with discretionary investment services, Clearstead will use model strategies with different purposes and risk levels. The unaffiliated advisor will be responsible for reviewing the model strategies with their individual clients and selecting the model strategy that is most appropriate. If the unaffiliated advisor selects Clearstead for sub-advisor investment management services, the unaffiliated advisor will sign a Clearstead sub-advisor client management agreement for each of their clients to document the engagement, model strategy, and any reasonable restrictions. The model strategies can be allocated on an account-by-account basis or across multiple accounts. 6 

Clearstead may also provide general economic information or due diligence for the investment managers that are used in its models, which can be used by the unaffiliated advisor with its clients.

The unaffiliated advisor is responsible for establishing its own custody relationship, whereas Clearstead will be an approved sub-advisor and have access to the unaffiliated advisor’s client’s accounts for trade execution purposes only. Furthermore, the unaffiliated advisor is responsible for negotiating all trading/transaction/custody fees that its clients will be responsible for paying while engaged with Clearstead for sub-advisor investment management services. 

Clearstead also acts as a sub-advisor to advisors and their funds, whereas the primary advisor may delegate some or all of its services to Clearstead. The delegated services could include maintaining models (or series), discretionary investment services, investment manager sourcing, and ongoing investment manager due-diligence. 

ClearAccess Platform and Private Investment Fund

ClearAccess is a platform created to simplify investing in illiquid alternatives by combining years of experience, access to high-quality managers, and a streamlined process to access private investments. Initial and future recommendations are covered by one set of subscription documents and ClearAccess also consolidates account[1]ing for capital calls, distributions, statements, performance, and tax information. In addition to the benefits above, ClearAccess provides a platform with typically lower costs to clients compared to investing in other hedge or private equity fund of funds directly. Clearstead accomplishes this by working with a third-party investment manager and administrator (GLASfunds, LLC) whose fees are negotiated by Clearstead. GLASfunds, LLC is an investment advisor registered with the SEC. Clearstead clients are able to invest through the ClearAccess platform in the following ways: 

• Directly with a third-party alternative investment manager 

• Through the ClearAccess Fund, LP dedicated Fund (“Fund”), in which GLASfunds, LLC is the General Partner and Clearstead, is the Investment Manager. 

• GLASfunds, LLC

While Clearstead owns a minority equity stake in GLASfunds, Clients are under no obligation to invest in alternative investments through GLASfunds. Clearstead does not receive any compensation from the underlying alternative managers that it recommends through ClearAccess. 

ClearAccess allows clients to invest in alternative managers on an a la carte basis, ClearAccess Balanced Hedge or ClearAccess Private Equity Series. ClearAccess Balanced Hedge is a select group of hedge fund managers and allocations chosen by Clearstead and designed to target an absolute return of cash plus 4-6% over a complete market cycle. ClearAccess Private Equity Series is a select group of private equity funds designed to diversify among stage, geography, size, and sector to generate competitive returns over a full market cycle. 

All assets held through ClearAccess Fund, LP are held at qualified custodians, which provide quarterly statements to the Fund investors. The Fund is subject to an annual audit performed by an independent public accountant. The Fund seeks to invest in other funds, direct, and co-investment opportunities in the range of $5 to $50 million per individual opportunity. The Fund offers securities to investors only through private placements of such securities. Please refer to the Funds’ offering documents for information related to the risks, suitability requirements, investment objectives, fee charges and expenses for the Fund. 

OTHER BUSINESS ACTIVITIES 

From time to time Clearstead may be retained on special projects. These may be searches for client service providers (i.e. custodians or 401(k) providers), fee benchmarking, or projects relating to client investment funds. In all cases, the only source of Clearstead’s revenue is from client advisory fees.

Private Client Advisory Services 

As indicated above, Clearstead provides services to private clients (families, individuals, and estates) that may include all or some of the following services: investment management, financial consulting, tax planning and compliance, and family office administration. 

A separate ADV Part 2A, under “Clearstead Advisors – Private Client” describing these services is available on the SEC’s website at (https://adviserinfo.sec.gov/). You can search this site by a unique identifying number, known as a CRD number. Clearstead's CRD number is 105674.

Investment Research and Due-Diligence 

Clearstead has engaged with unaffiliated firms to provide investment research and due diligence on investment managers. Under this type of Service Agreement Clearstead provides proprietary research on mutually agreeable investment managers that Clearstead may or may not recommend to its own clients. Furthermore, clients are provided the opportunity to white label the research reports under their own name.

Executive Financial Services 

Clearstead offers comprehensive and tailored financial wealth services to organization’s executive leadership. Our offering, which incorporates the rigor of our institutional investment consulting practice with the deep tax and planning resources of our private client advisory practice, is designed specifically around an organization’s benefits, retirement plans, and incentives. We work with an organization to design a benefit for the executive leadership to provide financial resources and incentives for them to engage with Clearstead and benefit from the fully integrated tax, planning and investment capabilities of our Private Client Group.

Clearstead Advisory Solutions (“CAS”) 

As indicated above, Clearstead provides investment advisory services to private and institutional clients under Clearstead Advisory Solutions, a Division of Clearstead Advisors, LLC (“Clearstead Advisory Solutions” or “CAS”). 

A separate ADV Part 2A, under “Clearstead Advisory Solutions – a Division of Clearstead Advisors, LLC” describing these services is available on the SEC’s website at (https://adviserinfo.sec.gov/). You can search this site by a unique identifying number, known as a CRD number. Clearstead's CRD number is 105674.

Wrap Fee Services 

Clearstead Advisory Solutions, a Division of Clearstead Advisors, LLC (“CAS”) has entered into a “wrap fee” arrangement sponsored by LPL Financial Group, which is unaffiliated with Clearstead. Also, some of our clients may be involved in other such arrangements with brokerage firms or other companies which sponsor such arrangements. Under a wrap fee arrangement, a brokerage firm or other company may recommend retention of CAS to manage all or a portion of your assets; pay us our fee for our services; monitor and evaluate our services in managing your assets; execute securities transactions which we implement on your behalf; and provide you with custodial services for your assets, or the brokerage firm or other company may provide any combination of these services, for a set fee to be paid by you to the brokerage firm or other company. Under a wrap fee arrangement, your assets would be managed by us in the same manner as assets managed by us for our clients NOT in a wrap fee arrangement, although this would be subject to your particular investment needs and objectives and we may have limited or minimal contact with you where the brokerage firm or other company maintains the direct and primary relationship with you. You should understand that, depending upon the amount of the wrap fee the brokerage firm or other company charges you, the number of securities transactions in your account, the value of custodial or other services you will receive under the arrangement, the amount of the wrap fee may not be less than the total cost for such services added together if obtained separately. As a result, such arrangements may not be suitable for all clients based on the client’s individual financial circumstances and investment goals. You can find more specific information on each wrap fee arrangement in the Wrap Fee Program Brochure, which should be available to you from the wrap fee arrangement sponsor. CAS does not act as a sponsor of any wrap fee arrangements.

Trust Administration Services 

Clearstead will work with high-net worth families and family offices to review estate planning documents and consider options for implementing a private family trust company. Clearstead will also provide ongoing trust administration services. 

Other 

Clearstead does not provide brokerage or custodial services, nor is it affiliated with any brokerage firm, bank, or have any proprietary funds. 

MISCELLANEOUS 

Non-Discretionary Service Limitations: Clients that engage with Clearstead for traditional consulting (i.e. non[1]discretionary) services must be willing to accept that Clearstead cannot effect the investment changes that it recommends. Therefore, there may be material market changes between the time a portfolio change is recommended and a trade is implanted by the client. In some cases, traditional consulting clients will grant Clearstead with operational trading authority which authorizes the client’s custodian to accept client approved trade instructions from Clearstead. If Clearstead is granted operational trading authority, clients must be willing to accept that Clearstead cannot instruct client’s custodian to process trades without obtaining prior consent from the client. Thus, in the event that Clearstead recommends a portfolio change (including in the event of an individual holding or general market correction), and the client not available, Clearstead will be unable to effect the account transaction(s) without first obtaining the client’s consent.

Unaffiliated Private Investment Funds: Clearstead may recommend that certain qualified clients consider an investment in private investment funds. Typically these investments are made through the ClearAccess platform. Clearstead’s clients are under absolutely no obligation to consider or make an investment in a private investment recommendation. 

Private investment funds generally involve risk, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a subscription agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. If a client engages with Clearstead under an assets under management based advisory fee, Clearstead typically includes the value of private fund investments that it recommends. The value for all private investment funds owned by the client will reflect the most recent valuation provided by the fund sponsor. The current value of any private investment fund could be significantly more or less than the original purchase price or the price reflected in any supplemental account report. 

Portfolio Activity: Clearstead has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Clearstead will review client portfolios on an ongoing basis to determine if any changes are necessary due to market or economic conditions, if investments have fallen outside of prescribed ranges, and/or a change in the client’s investment objectives. Based upon these factors, there may be extended periods of time when Clearstead determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Clearstead will be profitable or meet any performance expectations. 

Cash Positions: Clearstead may maintain cash and cash equivalent positions (such as money market funds) for defensive and liquidity purposes. Unless otherwise agreed in writing, all cash and cash equivalent positions will be included as part of assets under management-based advisory fees.

Client Obligations: In performing our services, Clearstead 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. Moreover, each client is advised that it remains their responsibility to promptly notify us if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or services.

Disclosure Statement: A copy of Clearstead’s written disclosure statement as set forth in this Form ADV Part 2A shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement. In addition, from time to time, Adviser may be required to deliver certain documents to the client. Client, to the extent that client has email capability and/or web access, hereby consents to the Adviser’s use of electronic means, such as email, to make delivery of required and other documents. This delivery may include notification of the availability of such document(s) on a website, and client agrees that such notification will constitute “delivery.” In conjunction with the investment advisory agreement, the client agrees to provide Clearstead with the client’s email address and to keep this information current at all times by promptly notifying Clearstead of any change in email address.

AMOUNT OF ASSETS UNDER ADVISEMENT & MANAGEMENT 

As of 12/31/2024, total institutional and private client assets under advisement were approximately $46.6 billion, which includes assets under management. Total institutional and private client assets under management were $24,294,182,322 ($18,595,623,030 discretionary and $5,698,559,292 non-discretionary). Of the $24.2 billion assets under management $9.5 billion were with institutional clients and $14.7 billion were with private clients.