The Firm
Clarity Capital KCPS Ltd., a limited company established under the laws of Israel (“KCPS Clarity,” “we,”
“us” or “our”), is a portfolio manager licensed with the Israeli Securities Authority and an investment
adviser registered with the SEC that began conducting business in October 2007.
KCPS Clarity is majority owned by its parent company, Sigma-Clarity Ltd. (formerly known as Clarity
Capital Matrat Mizug Ltd.), a limited company established under the laws of Israel (“Sigma-Clarity”),
which owns 91.8 % of the issued and outstanding equity interests of KCPS Clarity. Mr. Eran Peleg owns
8.2% of the issued and outstanding equity interests of KCPS Clarity. Sigma-Clarity is jointly owned and
managed by KCPS
Clarity Capital Group Ltd., a limited company established under the laws of Israel
(“KCPS Clarity Capital Group”), and Andorra Bank Agricol Reig, S.A., a banking institution based in
Andorra (“Andbank”).
In February 2024, Sigma-Clarity, Andbank and KCPS Clarity Capital Group entered into an agreement
with J.C.K. Consulting Ltd. (“J.C.K. Consulting”), a limited company established under the laws of Israel.
According to the terms of such agreement, Andbank and KCPS Clarity Capital Group will sell ordinary
shares of Sigma-Clarity to J.C.K. Consulting and, as a result of the transaction, J.C.K. Consulting will own
52.21% of the issued and paid-up capital of Sigma-Clarity on a fully diluted basis, Andbank will hold
22.34%, and KCPS Clarity Capital Group will hold 25.45%. The closing of this transaction remains subject
to satisfaction of a number of conditions, including regulatory approval both in Israel and in Andorra, which
is expected to take a couple of months. Other than changes in our indirect ownership, we do not expect any
changes with respect to our operations or the services we provide.
None of KCPS Clarity, Sigma-Clarity or Sigma-Clarity’s parent companies is publicly owned or traded.
Types of Investment Services
KCPS Clarity provides continuous investment management services on both a discretionary and non-
discretionary basis to a diverse array of separate account clients, including high net worth individuals and
institutions.
KCPS Clarity offers investment service
s1 to its clients in respect of a variety of asset classes, including
equities, fixed income investments, alternative
investments and cash equivalents. The scope of its
investment services and specific investment guidelines and limitations are tailored for each client on an
individual basis, as described below. From time to time, KCPS Clarity may contract with sub-advisers to
provide certain portfolio management services for clients. In the event we use a sub-adviser’s services, the
sub-adviser may have discretion over the assets that it sub-advises, and the relevant client will be notified
by KCPS Clarity.
Tailored Portfolio Management and Investment Restrictions
KCPS Clarity tailors individual strategic asset allocations to fit each client’s needs through the following
steps:
• Risk Assessment & Establishment of Objectives: KCPS Clarity gains a thorough understanding of
each client’s needs through an upfront Client-Assessment process and through extensive dialogue
with the client. A client’s risk tolerance is then assessed, and long-term wealth objectives are
determined.
• Mandate Definition & Implementation: A client’s strategic asset allocation is determined and
implemented by a KCPS Clarity portfolio manager. Asset classes included are: equities, fixed
income, alternative investments and cash equivalents. Because some types of investments involve
certain additional degrees of risk, such investments will only be recommended when consistent
with the client’s stated investment objectives, tolerance for risk, liquidity and suitability.
• Ongoing Client Interaction & Reporting: A client’s portfolio is managed on an ongoing basis and
monthly and quarterly reports are provided.
Clients may impose restrictions on investing in certain types of securities or investment products.
Wrap Fee Programs
KCPS Clarity does not offer or participate in any wrap fee programs.
1 The term “investment services” refers to “investment advice” as defined under the U.S. Investment Advisers Act
of 1940, as amended, and to “portfolio manage” and “investment marketing” as defined under the Israeli Regulation of
Investment Advice, Investment Marketing and Investment Portfolio Management Law, 1995 (the “Israeli Law”).
Client Assets under Management
As of December 31, 2023, KCPS Clarity’s regulatory assets under management totaled approximately $580
million. Of such amount, approximately $571 million was managed on a discretionary basis and
approximately $9 million was managed on a non-discretionary basis.