Altar Rock

Altar Rock LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Altar Rock LLC. If you have any questions about the contents of this brochure, please contact us at operations@altarrockwealth.com. The information in this brochure has NOT been approved nor verified by the United States Securities and Exchange Commission nor by any state securities authority. Additional information about Altar Rock LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Altar Rock LLC’s CRD number is: 326868. 34 Harding Road Lexington, MA 02420 407 East 70th Street, 5th Floor, New York, NY 10021 (917) 226-0565 operations@altarrockwealth.com https://www.altarrockwealth.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: June 22, 2026 1  2: Summary of Material Changes This section summarizes material changes to Altar Rock’s Disclosure Brochure since the amendment filing dated March 3, 2026. ● Andrew Harding Barnes became Managing Partner of Altar Rock. ● Altar Rock appointed Valerie Konstantinova as Chief Compliance Officer. ● Altar Rock put a promoter agreement framework in place and updated disclosures related to referral and conflicts of interest. ● Altar Rock has updated its address and phone number. ii  3: Table of Contents 1: Cover Page 2: Summary of Material Changes ........................................................................................................ ii 3: Table of Contents ............................................................................................................................. iii 4: Advisory Business ............................................................................................................................ 4 5: Fees and Compensation .................................................................................................................. 6 6: Performance-Based Fees and Side-by-Side Management ............................................................ 9 7: Types of Clients ................................................................................................................................ 9 8: Methods of Analysis, Investment Strategies, & Risks of Loss ...................................................... 9 9: Disciplinary Information ................................................................................................................. 11 10: Other Financial Industry Activities and Affiliations .................................................................... 11 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 12 12: Brokerage Practices ..................................................................................................................... 13 13: Review of Accounts ...................................................................................................................... 14 14: Client Referrals and Other Compensation .................................................................................. 15 15: Custody ......................................................................................................................................... 16 16: Investment Discretion .................................................................................................................. 16 17: Voting Client Securities (Proxy Voting) ....................................................................................... 16 18: Financial Information ................................................................................................................... 16 iii  4: Advisory Business Description of the Advisory Business Altar Rock LLC (“Altar Rock,” “we,” “us,” or “our”) is an investment adviser registered with the U.S. Securities and Exchange Commission as of November 18, 2025. Altar Rock is organized as a limited liability company in the State of Delaware and was formed in December 2020. The firm’s principal owners are Archan Kumar Basu, Andrew Harding Barnes, and Innova Capital Partners III. Types of Advisory Services Investment Advisory in the Form of Portfolio Management Services Altar Rock provides advisory services in the form of portfolio management services. These services provide clients with continuous and ongoing supervision over their accounts, which may include managing client accounts, reviewing the continued suitability of the portfolio at least quarterly based on information available to Altar Rock, and placing trades when Altar Rock determines it is appropriate. Where appropriate for qualified clients, Altar Rock may provide investment advice on a variety of investment types and structures and may consider investment vehicles, private funds, alternative investments, insurance- related structures such as Private Placement Life Insurance (“PPLI”) or Private Placement Variable Annuities (“PPVA”), and other structures that Altar Rock believes are appropriate for the client. Altar Rock may also provide investment advisory services with respect to assets held within PPLI, PPVA, or similar structures, including asset allocation, manager selection, portfolio management, and ongoing monitoring. As part of its portfolio management services, Altar Rock may also recommend or allocate client assets to third-party investment advisers, managers, or separately managed account strategies. These arrangements may be used to implement specific investment strategies that Altar Rock believes are appropriate for the client. In some cases, the third-party adviser or manager may have discretion to buy and sell securities within the separately managed account or strategy. In those cases, Altar Rock generally does not make the individual security selection decisions within that portion of the client’s portfolio, but may monitor the strategy, manager, and overall allocation as part of its portfolio management services. Altar Rock’s policy is to allocate investment opportunities and transactions among clients on a fair and equitable basis over time, consistent with each client’s objectives, restrictions, and circumstances. Altar Rock does not guarantee that any investment strategy, recommendation, portfolio, or investment product will achieve a particular result or avoid loss. Tailoring and Restrictions Altar Rock provides portfolio management services based on information provided by clients regarding their investment objectives, financial circumstances, risk tolerance, investment 4  restrictions, and other relevant information. As part of these services, Altar Rock may provide financial or wealth planning, asset allocation, and portfolio construction advice. Clients may impose reasonable written restrictions on the management of their accounts, including restrictions on investing in certain securities or types of securities. Altar Rock is authorized to rely on information provided by the client and the client’s other professionals. Clients are responsible for promptly notifying Altar Rock of any material change in their financial circumstances, investment objectives, restrictions, or other information relevant to the management of their accounts. Financial Planning Services As part of its portfolio management services, Altar Rock may provide financial planning services to help clients evaluate their overall financial situation and develop financial objectives. As part of this analysis, Altar Rock may consider the different purposes of a client’s assets, including assets intended for near-term spending, liquidity or preservation, long-term growth, family or estate planning, charitable objectives, or other client-specific goals. Altar Rock may provide recommendations outlining potential planning considerations or a suggested course of action based on the client’s specific situation. Clients are responsible for deciding whether to implement Altar Rock’s recommendations and are not obligated to do so. Clients are also responsible for notifying Altar Rock of material changes in their financial circumstances, objectives, risk tolerance, liquidity needs, or other relevant information so that Altar Rock can review, evaluate, or revise prior recommendations, if appropriate. Altar Rock may also offer stand-alone financial planning and wealth consulting services for clients seeking advice outside of an ongoing portfolio management relationship. These engagements may address similar planning topics described above and are provided under a separate agreement. When provided outside of Altar Rock’s portfolio management services, financial planning services generally do not include ongoing client account management or portfolio management unless separately agreed. Altar Rock, LLC, in its capacity as a registered investment adviser, does not provide legal, tax, accounting, or insurance advice or services. Clients should consult their own legal, tax, accounting, and insurance professionals regarding those matters. Certain insurance-related services may be provided separately by Altar Rock Insurance LLC or other licensed insurance professionals, as described in this Brochure. Wrap Fee Programs Altar Rock does not participate in wrap fee programs. Assets Under Management Altar Rock has the following assets under management: 5  Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 0 December 31, 2025 $ 158,692,083 5: Fees and Compensation Portfolio Management Fees Altar Rock charges an annual asset-based advisory fee for portfolio management services. The annual fee is based on the value of assets managed by Altar Rock within the applicable client relationship, as set forth in the client’s Investment Advisory Agreement and applicable fee schedule. Unless expressly excluded, all assets managed by Altar Rock for the client are generally included in the fee calculation. Advisory fees are generally negotiable. Altar Rock may agree to a different advisory fee schedule, prorate a fee, or waive a fee based on facts and circumstances, including the amount of assets under management, householding arrangements, the complexity of the services provided, negotiations with the client, special arrangements, or other relevant factors. The following is Altar Rock’s standard fee schedule: Total Assets Under Management $0 - $5,000,000 $5,000,001 - $30,000,000 $30,000,001 - $150,000,000 $150,000,001 - $500,000,000 $500,000,001 - $1,000,000,000 $1,000,000,001 – AND UP Annual Fees 1.00% 0.75% 0.50% 0.35% 0.25% 0.20% Valuation of Assets for Billing Certain assets may be excluded from billing where Altar Rock does not provide management services for those assets, where assets are included for reporting or supervision purposes only, or where otherwise agreed with the client in writing. Altar Rock calculates advisory fees using asset values maintained in its billing system as of the last calendar day of the prior quarter, based on information available to Altar Rock at the time of billing. Altar Rock relies on information obtained from custodians, fund sponsors, administrators, pricing vendors, and other third-party sources and generally does not independently verify such valuations. For accounts that use margin, Altar Rock currently calculates advisory fees based on net asset value rather than gross exposure. As a result, advisory fees are generally not charged on borrowed amounts. 6  Asset values used for billing may differ from values shown on custodian statements or other client report due to accrued interest, timing of data updates, excluded assets, or the use of the most recent valuation available from a fund sponsor, administrator, custodian, or other third- party source available to Altar Rock. Altar Rock does not independently appraise or value private, illiquid, or less frequently valued investments. Deduction of Advisory Fees Advisory fees are generally deducted directly from the client’s account by the applicable custodian, using fee information provided through Altar Rock’s billing process, unless otherwise agreed. In some cases, fees for multiple accounts within a client relationship may be deducted from one designated account, as reflected in the account setup or other applicable documentation. Clients authorize the deduction of advisory fees through the applicable client agreement, custodian paperwork, or other authorization. Custodians generally provide account statements, at least quarterly, showing account transactions, including advisory fees deducted from the account. Third-Party Fees and Expenses In addition to Altar Rock’s advisory fee, clients may incur third-party fees and expenses, including, as applicable, custodian charges, brokerage commissions or transaction costs, separately managed account or sub-adviser fees, private fund or private investment fees and expenses, margin or financing costs, insurance-related charges, policy charges, administrative fees, and other expenses. Where Altar Rock recommends or allocates client assets to a separately managed account or third-party manager strategy, the client may pay fees to that manager or sub-adviser in addition to Altar Rock’s advisory fee, unless otherwise agreed. The applicable fee schedule and method of calculation for any such manager or sub-adviser will be disclosed at or before the time of engagement. Billing Frequency and Adjustments Advisory fees are annual fees that are billed quarterly in advance, at the beginning of each calendar quarter, based on asset values as of the last calendar day of the prior quarter. The quarterly fee is calculated by applying the applicable annual fee schedule to the assets subject to billing. For new accounts, closed accounts, additions, withdrawals, transfers, terminations, or other relevant account activity during a billing period, Altar Rock may prorate or adjust the advisory fee based on the number of actual calendar days the applicable assets were under management during the period. Such adjustments may be reflected in the current billing cycle, as a refund, or in a subsequent billing cycle, as applicable. Termination and Refunds 7  If fees are paid in advance and the agreement is terminated before the end of the billing period, Altar Rock will retain the earned portion of the fee through the termination date and refund any unearned prepaid fees on a pro-rated basis. The refund is generally calculated based on the number of actual calendar days remaining in the billing period, unless otherwise provided in the applicable agreement. Financial Planning Fees Altar Rock generally provides financial planning services as part of its portfolio management services and does not separately charge for those services. In certain circumstances, Altar Rock may provide financial planning services under a separate engagement. Any fee for a separate financial planning engagement will be agreed with the client in advance and may be charged as a fixed fee, hourly fee, project-based fee, capped fee arrangement, or other agreed fee arrangement, depending on the scope and complexity of the services. Before commencing any separately charged financial planning services, the client must enter into an agreement or other written arrangement describing the services to be provided and the fees to be charged, the billing or payment terms, and any applicable termination or refund terms. Any termination or refund terms will be governed by that agreement. PPLI & PPVA Fees and Insurance-Related Compensation As discussed in the Types of Advisory Services section, Altar Rock may provide advisory or portfolio management services for assets held within PPLI or PPVA policies or contracts and may charge an advisory fee for those services. In addition to advisory fees, Altar Rock, its affiliates, and/or supervised persons may receive insurance-related or distribution compensation in connection with client purchases of PPLI or PPVA policies. This compensation may include: broker-dealer compensation paid to a registered representative; insurance agent compensation; compensation paid to Altar Rock Insurance LLC or another insurance brokerage entity in connection with the placement of a policy; and/or compensation or revenue-sharing paid in connection with a policy even where Altar Rock or its affiliate is not acting as the broker of record. This creates a conflict of interest because Altar Rock, its affiliates, and/or supervised persons have a financial incentive to recommend PPLI, PPVA, or other insurance-related products. Altar Rock addresses this conflict by recommending such products only when the firm believes they are suitable and in the client’s best interest, disclosing the compensation structure, and informing clients that they may purchase similar or equivalent policies through unaffiliated brokers, agents, or representatives. Altar Rock does not receive more than 50% of its total revenue from commissions or other compensation for the sale of investment products. Altar Rock may reduce or waive its advisory fees to offset insurance-related compensation received in connection with PPLI, PPVA, or other insurance-related arrangements. 8  6: Performance-Based Fees and Side-by-Side Management Altar Rock does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of your assets. 7: Types of Clients The majority of Altar Rock’s clients are high-net-worth individuals, families, or trusts. 8: Methods of Analysis, Investment Strategies, & Risks of Loss Methods of Analysis Altar Rock uses a combination of qualitative and quantitative analysis in developing investment advice and managing client portfolios. This may include review of client objectives, asset allocation, market conditions, investment fundamentals, risk/return characteristics, tax considerations, liquidity needs, portfolio exposures, and manager or fund due diligence. Altar Rock’s investment process is generally centered on aligning client objectives, risk tolerance, liquidity needs, and tax considerations with portfolio construction and asset allocation decisions. Altar Rock generally selects investments, managers, funds, and other investment vehicles that have been reviewed and approved through its internal investment process. Altar Rock’s Investment Committee meets regularly to review market conditions, portfolio positioning, asset allocation views, investment opportunities, approved investments, and client portfolio considerations. Investment recommendations may be updated over time based on changes in market conditions, client circumstances, risk considerations, or the firm’s investment outlook. Investment Strategies Altar Rock’s investment strategies may include long-term investing, portfolio rebalancing, asset allocation, tax-aware portfolio construction, ETFs and mutual funds, selection of third-party managers, separately managed accounts, private funds, alternative investments, real estate- related investments, municipal bonds and other fixed income investments, and non-U.S. investments where appropriate for a client. Altar Rock may recommend third-party managers or separately managed accounts that use long/short, quantitative, market-neutral, direct-indexing, tax-aware, or similar strategies. These strategies may rely on quantitative models, data inputs, algorithms, automated or systematic trading processes, tax-loss harvesting, short sales, margin, leverage, derivatives, and frequent trading. Material Risks 9  Investing in securities involves risk of loss, including the potential loss of principal, and clients should be prepared to bear that risk. Investment strategies may be affected by market risk, interest-rate risk, credit risk, liquidity risk, inflation risk, tax risk, concentration risk, manager risk, operational risk, and political or regulatory developments. Past performance is not indicative of future results. Certain investments involve additional risks. Private funds, private placements, venture capital, private equity, private credit, real estate funds, and similar alternative investments may be illiquid, difficult to value, subject to limited transparency, and available only to qualified investors. These investments may use leverage, have limited redemption rights, involve higher fees, and may result in substantial or complete loss of capital. Real estate-related investments, including REITs and private real estate funds, may be affected by local market conditions, interest rates, financing availability, property values, operating expenses, taxes, environmental matters, zoning rules, and broader economic conditions. ETFs and mutual funds are subject to the risks of their underlying investments, market fluctuations, expenses, tracking differences, and, in the case of ETFs, intraday trading and market-pricing risks. Municipal bonds and municipal bond strategies may be affected by interest-rate risk, credit risk, call risk, liquidity risk, tax risk, and risks related to the financial condition of the issuing state, municipality, or other governmental entity. The tax treatment of municipal bond income may vary based on a client’s circumstances and changes in applicable law. Non-U.S. investments may involve currency risk, political and economic risk, different accounting standards, less public information, and different regulatory protections. Long/short, quantitative, market-neutral, direct-indexing, tax-aware, or similar strategies are subject to market risk, model risk, data risk, coding and systems risk, implementation risk, financing and borrowing-cost risk, short-sale constraint risk, liquidity risk, tax risk, and manager risk. These strategies may underperform if model assumptions are incorrect, data is inaccurate or incomplete, market conditions change, short positions appreciate, borrowing costs increase, systems fail, or the strategy is not implemented as intended. Tax-aware strategies may not achieve the expected tax benefits and may create wash sale, straddle, constructive sale, tax-lot, or other tax-reporting issues. Clients should consult their own tax advisers regarding the tax consequences of these strategies. Options, short sales, margin, leverage, derivatives, or other similar strategies, if used, involve greater risk and may increase losses. Frequent trading may increase transaction costs and taxes and may negatively affect investment performance. Private Placement Life Insurance and Private Placement Variable Annuities: PPLI and PPVA are long-term insurance and investment structures that may provide access to alternative investments and potential tax-related benefits. PPLI and PPVA are not suitable for all investors and are subject to the risks of the underlying investments, including market risk, liquidity risk, 10  valuation risk, manager risk, and the possible loss of principal. In addition, PPLI and PPVA involve insurance-related risks, including insurance carrier risk, policy expenses, and the risk that changes in tax laws, regulations, or a client's circumstances could reduce or eliminate anticipated tax benefits. Because PPLI and PPVA are generally offered through private placement exemptions, they are not subject to the same regulatory requirements as registered investment products. Clients should carefully review all offering materials and consult their legal and tax advisers before investing. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 9: Disciplinary Information Altar Rock has no disciplinary information to report. Criminal or Civil Actions There are no criminal or civil actions to report. Administrative Proceedings There are no administrative proceedings to report. Self-Regulatory Organization Proceedings There are no self-regulatory organization proceedings to report. 10: Other Financial Industry Activities and Affiliations Futures and Commodities Registration Neither Altar Rock LLC nor any of our management persons are registered, or have an application pending, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Material Relationships and Affiliations Altar Rock has material relationships or arrangements with related persons in the following categories: • • Broker-Dealer. Certain supervised persons of Altar Rock are registered representatives of Simplicity Investments, Inc., a broker-dealer. In that capacity, they may receive broker- dealer compensation in connection with certain PPLI, PPVA, or other insurance-related arrangements. Insurance Agency. Altar Rock Insurance LLC is wholly owned by Altar Rock LLC. Altar Rock Insurance LLC and/or our supervised persons may receive insurance-related compensation in connection with client purchases of PPLI, PPVA, or other insurance products. 11  • Path Matters LLC. Path Matters LLC is wholly owned by Altar Rock LLC and owns or supports certain proprietary planning, forecasting, or modeling tools used in Altar Rock’s advisory process. Path Matters LLC currently does not receive separate compensation from clients, its affiliates or any other company. These relationships create material conflicts of interest because Altar Rock, its affiliates, and/or supervised persons may receive compensation or other economic benefits from insurance- related products or arrangements recommended to clients. Altar Rock addresses these conflicts through disclosure, suitability and best-interest reviews, supervision, and by informing clients that they may purchase comparable policies through unaffiliated brokers, agents, or representatives. Recommendation of Other Investment Advisers Altar Rock does not recommend or select other investment advisers for our clients in exchange for compensation, nor does the firm have other business relationships with other advisers that create a material conflict of interest. 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Summary Altar Rock has adopted a Code of Ethics that applies to its supervised persons and is designed to address the firm’s fiduciary duty to clients, personal securities trading, conflicts of interest, insider trading, confidentiality, gifts and entertainment, reporting obligations, and other standards of business conduct. The Code is based on the principle that Altar Rock and its supervised persons must place client interests ahead of their own and must avoid activities that create, or appear to create, conflicts of interest or misuse of their position of trust. This section is a summary of the Code of Ethics. Altar Rock will provide a complete copy of its Code of Ethics to any client or prospective client upon request. Participation or Interest in Client Transactions Altar Rock and its related persons may recommend to clients, or buy or sell for client accounts, securities or investment products in which Altar Rock or a related person has a financial interest, including where a related person receives compensation or has an affiliation relating to an investment product, insurance-related structure, fund, manager, or service provider. These arrangements create conflicts of interest because Altar Rock or its related persons may have an incentive to recommend investments, products, or structures based on compensation or other financial interests. 12  Altar Rock addresses these conflicts by disclosing material conflicts to clients, evaluating recommendations based on the client’s objectives and circumstances, and maintaining policies and procedures reasonably designed to address conflicts of interest. Personal Trading Altar Rock and its supervised persons may buy, sell, or hold securities for their own accounts that are the same as, similar to, or related to securities recommended to or purchased for client accounts. This creates a conflict of interest because supervised persons could have an incentive to trade before, after, or around the same time as client transactions. Altar Rock’s Code of Ethics requires supervised persons to report personal securities holdings and transactions and may require pre-clearance or impose restrictions for certain transactions. Altar Rock monitors personal trading for compliance with its Code of Ethics and seeks to prevent personal trading from disadvantageous clients. 12: Brokerage Practices Factors Used to Select Custodians or Broker-Dealers Altar Rock generally recommends that clients maintain accounts with qualified custodians such as Fidelity Brokerage Services LLC or Charles Schwab & Co., Inc. Advisor Services. Altar Rock considers factors such as execution quality, custody and trading capabilities, financial strength, platform reliability, reporting, service, technology, access to investment products, operational support, and overall cost. Best execution does not necessarily mean the lowest commission or transaction cost. Qualified custodians may provide Altar Rock with access to institutional trading, custody, reporting, technology, market data, research, pricing information, account data, fee billing tools, and other operational or administrative support. These services may benefit Altar Rock because Altar Rock may not have to obtain or pay separately for them. Some services may be used to support all or a substantial number of Altar Rock client accounts, including accounts not maintained at the custodian providing the benefit. The receipt of these services creates a conflict of interest because Altar Rock may have an incentive to recommend a custodian based, in part, on the products or services made available to Altar Rock rather than solely on a client’s interest in obtaining the lowest execution cost. Altar Rock addresses this conflict by considering best execution, overall custody and brokerage quality, and the reasonableness of compensation under the circumstances. Altar Rock does not receive commissions, mark-ups, or transaction-based compensation from client securities transactions. Clients may pay brokerage commissions, transaction fees, custody-related charges, or other fees imposed by custodians, broker-dealers, managers, funds, or product sponsors. 13  Altar Rock generally recommends or requires clients to use Fidelity Brokerage Services LLC, Charles Schwab & Co., Inc., or another custodian approved by Altar Rock. Not all advisers require clients to use specified custodians. Because Altar Rock generally directs clients to particular custodians, Altar Rock may be unable to obtain the most favorable execution or lowest transaction cost available from other broker-dealers. Altar Rock does not select or recommend broker-dealers based on receiving client referrals from broker-dealers. Altar Rock does not require clients to use Simplicity Investments as the registered broker-dealer for PPLI or PPVA arrangements. Where Simplicity Investments or another broker-dealer is involved in a PPLI or PPVA transaction, applicable compensation and conflicts are described in this Brochure. Research and Other Soft-Dollar Benefits Altar Rock does not have a formal soft dollar program and does not use client brokerage commissions to obtain third-party research or other products or services. Brokerage for Client Referrals Altar Rock receives no referrals from a broker-dealer nor third party in exchange for using that broker-dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use Altar Rock generally requires clients to use broker-dealers or custodians approved by Altar Rock, such as Fidelity Brokerage Services LLC or Charles Schwab & Co., Inc. Advisor Services. Not all advisers require clients to use a particular broker-dealer or custodian. Because Altar Rock generally directs clients to particular custodians, Altar Rock may be unable to obtain the most favorable execution or lowest transaction cost available from other broker-dealers. Altar Rock generally does not permit clients to direct brokerage to broker-dealers or custodians that are not approved by Altar Rock. If Altar Rock agrees to a client-directed brokerage arrangement, Altar Rock may be unable to obtain most favorable execution, and the client may pay higher costs or receive less favorable execution. Aggregation of Orders Altar Rock does not generally aggregate client orders for the purchase or sale of securities. To the extent Altar Rock has the opportunity to aggregate orders but does not do so, clients may not receive the potential benefits of aggregation, such as lower transaction costs or more favorable execution prices. 13: Review of Accounts Strategic Reviews 14  Client objectives are set at onboarding and formally reviewed at least annually. Strategy may be revisited after material changes in a client’s financial circumstances, investment objectives, liquidity needs, or other relevant factors. Financial planning services, where provided, are reviewed upon preparation and delivery by the appropriate advisory personnel. Altar Rock’s Investment Committee regularly reviews market conditions, economic developments, strategic asset allocation views, and model portfolios. Material changes in market conditions or investment outlook may prompt adjustments to strategic positioning or client portfolio recommendations. Clients must notify Altar Rock of any changes to their financial situation or investment objectives to enable review and revision of recommendations and services. The assigned investment adviser leads plan preparation and updates and is available by phone, e-mail, or in- person/virtual meetings as often as needed. Portfolio Reviews Client portfolios are reviewed at least quarterly by Altar Rock's portfolio management team, led by the Head of Investments. The team also conducts periodic rebalancing reviews to assess drift, cash balances, liquidity, risk exposures and other tactical adjustments to keep portfolios aligned with client objectives and target allocations. Client Reporting Portfolio management clients receive reports at least annually, including assets held, asset values, performance, and fees. Clients also receive account statements directly from the custodian at least quarterly. Financial planning clients receive a comprehensive plan concerning their financial situation, which is updated periodically by client request or as needed. 14: Client Referrals and Other Compensation Third-Party Compensation and Benefits Altar Rock may receive compensation from third-party advisers to which it directs clients as disclosed in Item 4, Item 5 and Item 10. Compensation for Client Referrals Altar Rock may compensate persons or entities that refer prospective clients to the Firm, subject to applicable federal and state requirements. When a prospective client is introduced to Altar Rock by a promoter or referring party, the promoter is required, at or before the time of the referral, to disclose the nature of the referral relationship, any material conflicts of interest, and the material terms of the compensation arrangement, including the compensation the promoter may receive from Altar Rock if the prospective client becomes a client. Altar Rock provides required disclosure materials to promoters, enters into written promoter agreements where 15  required, conducts due diligence and oversight, and maintains records relating to promoter activity. Promoters are not authorized to provide investment advice, make performance claims, or determine suitability on behalf of Altar Rock unless separately registered or otherwise permitted under applicable law. 15: Custody Altar Rock LLC is deemed to have custody of client funds and securities because it has authority to deduct our advisory fees directly from client accounts. Clients receive quarterly, or more frequent, account statements directly from the qualified custodian. Clients should carefully review these custodian statements. To the extent the firm also provides account statements or reports, clients are urged to compare them with the statements received directly from the custodian. Client assets are held at qualified custodians in separate accounts under each client’s name. The custodian does not verify the accuracy of our advisory fee calculations. Altar Rock does not have other forms of custody, such as trustee services, bill-paying authority, or third-party disbursement powers. 16: Investment Discretion Altar Rock LLC generally provides discretionary investment advisory services. Upon receiving written authorization from the client in Altar Rock’s standard advisory agreement, Altar Rock has authority to determine the type, quantity, and timing of securities bought or sold in client accounts without obtaining the client’s prior consent for each transaction. All clients may place reasonable restrictions on the types of investments that may be purchased in an account. Clients may also provide specific instructions or place reasonable limitations on the discretionary authority granted to Altar Rock, provided such restrictions, instructions, or limitations are specifically set forth in or included as an attachment to the client agreement, or otherwise agreed to by Altar Rock in writing. Altar Rock reserves the right not to accept any proposed restriction, limitation, or instruction. 17: Voting Client Securities (Proxy Voting) Altar Rock will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. 18: Financial Information Balance Sheet 16  Altar Rock neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Altar Rock nor its management has any financial condition that is likely to reasonably impair Altar Rock’s ability to meet contractual commitments to clients. Bankruptcy Petitions in Previous Ten Years Altar Rock has not been the subject of a bankruptcy petition in the last ten years. 17  18