ATLANTIC EDGE PRIVATE WEALTH MANAGEMENT, LLC

Item 1: Cover Page Atlantic Edge Private Wealth Management, LLC 200 W. Forsyth St. Suite 1020 Jacksonville, FL 32202 Phone: (904)719-1360 Website: www.atlanticedgewealth.com Form ADV Part 2A – Firm Brochure January 2025 This Form ADV Part 2A – Firm Brochure (“Brochure”) provides information about the qualifications and business practices of Atlantic Edge Private Wealth Management, LLC (“Atlantic Edge”). If you have any questions about the contents of this Brochure, please contact Matthew Cochran at (904) 719-1360 or by email at Matt@AtlanticEdgeWealth.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training. information about Atlantic Edge Using the SEC’s website at www.adviserinfo.sec.gov, additional is available. This website will allow you to search for additional information about any registered firm by a unique identifying number, known as a CRD number. Atlantic Edge’s CRD number is 327354.  Item 2 Material Changes This section is used to provide our clients with a summary of any “Material Changes” with Atlantic Edge. These types of “Material Changes” would include changes of ownership or control; location; disciplinary proceedings; significant changes to our advisory services or advisory affiliates – any information that is critical to a client’s full understanding of who we are, how to find us, and how we do business. A material change will require us to send you a summary of the changes or we will provide you with our revised Brochure that will include a summary of these changes in this section. At times, we may perform routine checks for grammar, punctuation, etc., and make necessary updates to this Brochure. Additionally, we may make updates within certain sections of this brochure for better clarity. Although the revision date on this Brochure may change due to these types of changes, these changes would not be considered a material change. There are no material changes for this release. 2 | P a g e  Item 3 Table of Contents Item 1: Cover Page .............................................................................................................................. 1 Item 2 Material Changes ..................................................................................................................... 2 Item 3 Table of Contents ..................................................................................................................... 3 Item 4 Advisory Business .................................................................................................................... 3 Item 5 Fees and Compensation ........................................................................................................... 5 Item 6 Performance Based Fees and Side-By-Side Management ........................................................ 7 Item 7 Types of Clients ........................................................................................................................ 7 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 8 Item 9 Disciplinary Information ........................................................................................................... 11 Item 10 Other Financial Industry Activities and Affiliations .................................................................... 11 Item 11 Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 11 Item 12 Brokerage Practices ............................................................................................................... 12 Item 13 Review of Accounts ................................................................................................................. 13 Item 14 Client Referrals and Other Compensation ............................................................................... 14 Item 15 Custody .................................................................................................................................. 14 Item 16 Investment Discretion.............................................................................................................. 14 Item 17 Voting Client Securities ........................................................................................................... 14 Item 18 Financial Information .............................................................................................................. 15 Item 4 Advisory Business Atlantic Edge Private Wealth Management, LLC (“Atlantic Edge or Firm”) is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) engaged in providing advisory services to clients. It was organized as a Limited Liability Company (“LLC”) under the laws of the State of Florida on July 25, 2023. Atlantic Edge began conducting business in September 2023 after registration approval was granted by the SEC and after approval from Charles Schwab and Company, Inc as a registered investment advisor on their platform. Please note, registration with the SEC does not imply a certain level of skill or training. The principal place of business is located in Jacksonville, Florida. The managing members with equal control are Matthew B. Cochran, Kaitlyn P. Weatherly, and Jeffery T. Albaneze. Discretionary Investment Management Services Our Firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Primarily, discretionary asset management services are provided by our one Florida-based office. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal target asset allocation and create and manage a portfolio based on that target. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. While we principally manage these advisory accounts on a discretionary basis, we retain the unrestricted authority to accept select accounts on a non-discretionary basis as a concession to certain advisory clients, friends, and family relationships. Account supervision is guided by the client's stated investment objectives (i.e., aggressive growth, enhanced growth, growth, growth and income, 3 | P a g e  enhanced income or income), as well as tax considerations. Atlantic Edge creates and manages a diversified portfolio, allocating the client's assets among various investments taking into consideration the investment objective selected by the client. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities: listed securities the-counter ‐ ‐ • Securities traded over • Commercial paper • Exchange-Traded funds • U. S. governmental securities • Options contracts on securities • Variable annuities • Corporate debt securities (other than commercial paper) • Exchange • Warrants • Mutual fund shares • Municipal securities • Certificates of deposit • Variable life insurance • Structured Notes • Private Funds (alternative investments) Although recommendations for new investments will typically be limited to these items, we may render investment advice on other types of investments held by a client at the start of the advisory relationship. Furthermore, clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors, or markets. traded funds and/or no ‐ ‐ Exchange load mutual funds are selected on the basis of any or all of the following criteria: the fund's performance history, the industry sector in which the fund invests, the track record of the fund's manager, the fund's investment objectives, the fund's management style and philosophy, and the fund's management fee structure. Portfolio weighting between funds and market sectors are determined on a per account basis pursuant to each client's individual needs and circumstances. Clients retain individual ownership of all securities. Because some types of investments involve certain additional degrees of risk, they will only be implemented when consistent with the client's stated investment objectives. In addition to managing the client’s investment portfolio, Atlantic Edge may provide certain financial planning services to clients on various financial areas including income and estate tax planning, college financial planning, retirement planning, insurance analysis and personal cash flow analysis, among other things. This office, however, will not charge a separate fee for this service. IRA Rollover Recommendations For the purpose of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, we are providing the following acknowledgment to clients. When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are 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 conflicts with clients’ interests. We operate under an exemption that requires us to act in the clients’ best interest and not put our or our employees’ interests ahead of the clients. Under this exemption, we must: • meet a professional standard of care when making investment recommendations (give prudent advice), • never put our or our employees’ financial interests ahead of the clients when making recommendations (give loyal advice), • avoid making misleading statements about conflict of interests, fees, and investments, • follow policies and procedures designed to ensure that we and our employees give advice that is in the clients’ best interest, • charge no more than is reasonable for our services, and 4 | P a g e  • give the clients basic information about conflict of interests. We benefit financially from the rollover of the clients’ assets from a retirement account to an account that we manage because the clients’ assets increase the assets we manage and, consequently, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in the client’s best interest. Consulting Services Portfolio Overview Service. Atlantic Edge offers a Portfolio Overview Service providing perspective on the full portfolio assets held by a client, encompassing all investment assets including brokerage, banking, private banking, insurance/annuity, 401(k), stock options, and alternative assets (online access to transactions and balances required). Portfolio Aggregation and Reporting. Atlantic Edge will prepare and provide to you consolidated reports, which shall include (i) consolidated portfolio accounting to provide oversight for adherence to an Investment Policy Statement, (ii) consolidated asset allocation for high level exposure (stock, bond, cash, alternative) as well as granular exposure (sub-asset class, sector and stock concentration) and (iii) via a personalized online portal for Client, consolidated portfolio assets and up-to-date consolidated performance updated daily. Consolidated reporting covers multiple investment vehicles, including both marketable and non-marketable securities in both retirement and non-retirement accounts, regardless of custodian, broker, or bank. Portfolio Overview includes accounting, reconciliation, and reporting of all accounts and assets available through online sources, asset allocation evaluation for the entire portfolio of holdings, independent verification of performance by manager, overall comparative performance measurement, customized portfolio benchmarking, combined tax reporting, and an annual review. Investment Management Services are NOT included in Portfolio Overview Services. Clients can also receive financial advice on a more focused basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Additionally, we may provide advice on non-securities matters. Generally, this is in connection with the rendering of estate planning, insurance, and/or annuity advice. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. Wrap Fee Program We do not sponsor or act as a portfolio manager in a wrap fee program. Assets Under Management As of 01/01/2025 with its updated ADV Part 2a, Atlantic Edge manages $535,092,705 of which $529,681,955 is on a discretionary basis and $5,410,750 is non-discretionary. Item 5 Fees and Compensation Portfolio Management Fees The annualized fee for discretionary investment management services is charged as a percentage of managed assets, according to the following schedule: Assets Under Management Annual Fee Up to Up to $1,000,000 1.00% per annum Plus, the next $4 million 0.75% per annum Plus, the next $5 million 0.50% per annum Over $10 million 0.30% per annum Atlantic Edge requires a minimum annual fee of $5,000 for portfolio management services. Consequently, 5 | P a g e  accounts with less than $500,000 in assets may pay advisory fees that are higher than one percent per year and therefore this minimum fee may prevent this branch of Atlantic Edge from providing investment management services to smaller client accounts. You may request that related accounts be combined in order to meet fee break points and reduce the advisory fee charged. Clients are invoiced, in advance, at the beginning of each calendar quarter based upon the value (market value or fair market value in the absence of market value) of the client's account, including accrued interest, at the end of the previous quarter. Fees will be debited from the client’s account in accordance with the client authorization in the Client Services Agreement. Atlantic Edge will send to Client a quarterly statement showing the amount of the advisory fee due, the Account value on which the fee is based and how the fee was calculated. The Custodian will send Client a quarterly statement showing all amounts paid from the Account, including all advisory fees paid by Custodian to Atlantic Edge. Fee adjustments are not made for contributions and withdrawals to accounts within a calendar quarter, however, in the event a client terminates his or her Investment Management Agreement with Atlantic Edge, the advisory fee for the calendar quarter in which the termination occurs will be pro-rated based on the number of days that the Account was open during the quarter, and client will be refunded the difference. We encourage you to reconcile our invoices and statements with the statement(s) you receive from the qualified custodian. If you find any inconsistent information between our invoice and the statement(s) you receive from the qualified custodian, please call our offices at (904) 719-1360. Limited Negotiability of Advisory Fees: Although Atlantic Edge has established the aforementioned fee schedules, we retain the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets, related accounts, portfolio style, account composition, and reports, among other factors. The specific annual fee schedule is identified in the contract between the adviser and each client. Furthermore, minimum account requirements and fees charged to pre-existing clients that have transitioned their accounts to Atlantic Edge from the predecessor registered investment adviser (e.g., BDO WM or LBA WM) may differ from the aforementioned fee schedule(s). Consulting Services Fees Portfolio Overview. The annual fee for Portfolio Overview will be charged on a quarterly basis, as a percentage of assets under advisement calculated at the annual rate of 0.25% or 25 bps, with an initial setup fee of $1,000 per account. The negotiable minimum annual fee for this service is $10,000. Atlantic Edge consulting fees are determined based on the nature of the services being provided (e.g., the number, size and composition of the client's accounts) and the overall complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. General consulting fees not detailed above will be calculated and charged on an hourly basis, ranging from $100 to $350 per hour (for administrative staff time and for professional time, respectively) depending upon the client's circumstances and the nature of the engagement. Although the length of time it will take to fulfill the consulting commitment will depend on each client's personal situation and the nature of the services as contracted for, we will provide an estimate for the total hours at the start of the advisory relationship. The fee will be due and payable upon completion of the consulting engagement. We may request a retainer upon completion of our initial fact-finding session with the client. Consulting Services Fee Offset. Atlantic Edge reserves the discretion to reduce or waive the hourly fee and/or the minimum fixed fee if a consulting services client chooses to engage us for our Investment Management Services. 6 | P a g e  General Information In performing our services, Atlantic Edge shall not be required to verify any financial information received from the client or from the client’s other professionals and is expressly authorized to rely on the information provided. Moreover, clients are advised that it remains their responsibility to promptly notify their respective Atlantic Edge account manager if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating and revising our previous recommendations and/or services. Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason, upon written notice. As disclosed above, certain fees are paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement of fees, we will pro rate the reimbursement according to the number of days remaining in the billing period. Mutual Fund/ETF Fees: All fees paid to Atlantic Edge for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or exchange-traded funds (ETFs) to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. Our recommendations are typically limited to no- load or load- waived mutual funds. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review the fees charged by the funds and our fees to fully understand the total amount of fees to be paid. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction charges imposed by a broker dealer with which an independent investment manager effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Brochure for additional information. Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. Note: Atlantic Edge does not receive fees from any mutual fund, custodian or broker dealer in connection with our advisory services (i.e., 12b-1 fees or commissions). Item 6 Performance Based Fees and Side-By-Side Management Atlantic Edge does not charge performance-based fees or participate in side-by-side management. Item 7 Types of Clients Atlantic Edge provides advisory services to the following types of clients: • Individuals (other than high net worth individuals) • High net worth individuals and families • Family offices • Charitable organizations • Corporations or other businesses not listed above As previously disclosed in Item 5, our firm has established certain initial minimum account requirements, based on the nature of the service(s) being provided. For a more detailed understanding of those requirements, please review the previous disclosures in Items 4 and 5. 7 | P a g e  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods Of Analysis We use the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy or add to an already established position) or overpriced (indicating it may be time to sell or trim from an already established position). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of equities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. The methodology we use is based on Modern Portfolio Theory. In Modern Portfolio Theory, certain mathematical principles are applied to the historical or forecasted performance of asset classes, and combinations of classes to identify asset allocations that attempt to maximize the client's rate of return within the constraints imposed by the client's circumstances. We then recommend mutual funds, exchange traded securities (equities or ETFs) and/or independent money managers deemed to correlate with certain asset classes to the client for investment. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest successfully over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Funds (mutual funds or ETFs) we recommend to clients are reviewed against a number of quantitative criteria, including manager tenure and track records, amounts invested or assets under management and other measurement statistics. In addition, mutual fund managers must meet qualitative criteria, including consistency of investment style, employee turnover, efficiency, and capacity. Mutual funds are reviewed against these quantitative and qualitative criteria to determine whether a fund will be recommended. Recommended funds (mutual funds or ETFs) are also reviewed each quarter to determine whether they continue to meet the quantitative and qualitative maintenance criteria. Any approved funds that fail to meet maintenance criteria may be placed on watch or removed from the recommended list. Advisory clients investing through removed funds will be informed of the removal and provided with new recommendations. Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical 8 | P a g e  analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly- managed or financially unsound company may underperform regardless of market movement. Charting. In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict how long the trend may last and when that trend might reverse. Risks for all Forms of Analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly- available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. System Failures and Reliance on Technology Risks. Our investment strategies, operations, research, communications, risk management, and back-office systems rely on technology, including hardware, software, telecommunications, internet-based platforms, and other electronic systems. Additionally, parts of the technology used are provided by third parties and are, therefore, beyond our direct control. We seek to ensure adequate backups of hardware, software, telecommunications, internet-based platforms, and other electronic systems, when possible, but there is no guarantee that our efforts will be successful. In addition, natural disasters, power interruptions and other events may cause system failures, which will require the use of backup systems (both on- and off-site). Backup systems may not operate as well as the systems that they back up and may fail to properly operate, especially when used for an extended period. To reduce the impact a system failure may have, we continually evaluate our backup and disaster recovery systems and perform periodic checks on the backup systems’ conditions and operations. Despite our monitoring, hardware, telecommunications, or other electronic systems malfunctions may be unavoidable, and result in consequences such as the inability to trade for or monitor client accounts and portfolios. If such circumstances arise, the Investment Committee will consider appropriate measures for clients. Cybersecurity Risk. A portfolio is susceptible to operational and information security risks due to the increased use of the internet. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include, but are not limited to, infection by computer viruses or other malicious software code, gaining unauthorized access to systems, networks, or devices through “hacking” or other means for the purpose of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches by third-party service providers may cause disruptions and impact the service providers’ and our business operations, potentially resulting in financial losses, the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement, or other compensation costs, and/or additional compliance costs. While we have established business continuity plans and risk management systems designed prevent or reduce the impact of such cyberattacks, there are inherent limitations in such plans and systems due in part to the everchanging nature of technology and cyberattack tactics. Investment Strategies We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Tactical Asset Allocation. Our investment philosophy and tactical decision making processes have been formulated and continue to be refined pursuant to years of financial industry experience, empirical research, and proven methodologies. We manage clients' money by adjusting allocations to asset classes based off of macro and microeconomic forecasts. We are not “buy and hold” managers nor are we “market timers”. Strategic Asset Allocation. A cornerstone of our philosophy is to rebalance clients' portfolios back to their long term asset allocation after major market moves up or down. Disciplined Rebalancing. Portfolio rebalancing is judiciously implemented to maintain proper alignment of investments; we seek to ensure the degree of risk such holdings represent is consistent with each particular 9 | P a g e  client's stated risk tolerance and investment objectives. We believe equities (owning companies) are the optimal asset class for growing wealth over the long term. We also believe that fixed income is the best way to hedge risk and improve cash flow. We analyze and select investments that best represent the asset classes and global strategies we are implementing utilizing individual stocks, Exchange Traded Funds (ETFs), index funds and/or actively managed funds. We pride ourselves in having complete independence allowing us to freely choose how and where to invest your money. Long-term purchases (buy-and-hold) - Securities are purchased with the idea of holding them in the client's account for one year or longer. Typically, this strategy is employed because we want exposure to a particular asset class over time, regardless of the current projection for the asset class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, a security may decline sharply in value before a decision to sell is made. Short-term purchases - Securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations. We may, at times, use short- term trading (in general, selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Short-term trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given stated investment objectives and tolerance for risk for our clients. Margin Transactions. We do not typically engage in margin transactions as a strategy. However, in some cases margin transactions may occur based on cash withdrawals and/or securities trading in your account or to purchase securities in advance of a bond maturity. A risk in margin trading is that, in volatile markets, securities prices can fall very quickly. If the value of the securities in your account minus what you owe the broker falls below a certain level, the broker will issue a "margin call," and you will be required to sell your position in the security purchased on margin or add more cash to the account. In some circumstances, you may lose more money than you originally invested. Option writing. On a more limited basis, we may use options as an investment strategy when consistent with a client’s investment objectives and risk threshold. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative, because it derives its value from an underlying asset. The two types of options are calls and puts: • A call gives the holder the right to buy an asset at a certain price within a specific period of time. We will buy a call if we have determined that the stock will increase substantially before the option expires. • A put gives the holder the right to sell an asset at a certain price within a specific period of time. We will buy a put if we have determined that the price of the stock will fall before the option expires. We will use options to speculate on the possibility of a sharp price swing. We will also use options to "hedge" a purchase of the underlying security; in other words, we will use an option purchase to limit the potential upside and downside of a security we have purchased for your portfolio. We use "covered calls," in which we sell an option on a security you own. In this strategy, you receive a fee for making the option available, and the person purchasing the option has the right to buy the security from you at an agreed-upon price. A risk of covered calls is that the option buyer does not have to exercise the option, so that if we want to sell the security prior to the end of the option agreement, we have to buy the option back from the option buyer, for a possible loss. Generally, options trading/writing and margin transactions are not a fundamental part of overall investment strategy, but may be used at the request of the client (for short-term cash needs) or to transition an existing portfolio to our recommended portfolio. 10 | P a g e  Risk of Loss. Clients should understand that all of Atlantic Edge's investment strategies and the investments purchased, sold and/or traded pursuant to such strategies involve risk of loss, including the potential loss of the entire investment in their account, which clients should be prepared to bear. The investment performance and the success of any investment strategy or particular investment can never be predicted or guaranteed, and the value of a client’s investments will fluctuate due to market conditions and other factors. The investment decisions made and the actions taken for any investment strategies as well as for any client account will be subject to various markets, liquidity, currency, economic, political and other risks. The value of investments and the income derived from investments can go down as well as up. Past performance is not indicative of future results and future returns are not guaranteed. There is a risk that a client could lose all or a portion of his or her money. We ask that you work with us to help us understand your tolerance for risk. Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose. Item 10 Other Financial Industry Activities and Affiliations Currently, Atlantic Edge does not have any other financial industry activities or affiliations to disclose. Item 11 Code of Ethics, Participation in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Atlantic Edge and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement and recordkeeping provisions. Atlantic Edge's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to Matt@AtlanticEdgeWealth.com, or by calling us at (904) 719-1360. Atlantic Edge and individuals associated with our firm are prohibited from engaging in principal transactions. Atlantic Edge and individuals associated with our firm are also prohibited from engaging in agency cross transactions. Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm buy or sell securities for their personal accounts that are identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in a certain security(ies) (which may also be recommended to a client). We may aggregate our employee trades with client transactions where possible and when compliant with our duty to seek the best execution for our clients. In these instances, participating clients will receive an average share price and transaction costs will be shared equally and on a pro-rata basis. In the instances where there is a partial fill of a particular batched order, we will allocate all purchases pro-rata, with each account paying 11 | P a g e  the average price. Our employee accounts will be included in the pro-rata allocation. As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing the Code of Ethics, to ensure compliance with our regulatory obligations and provide our clients and potential clients with full and fair disclosure of such conflicts of interest. 1. No principal or employee of our firm may put his or her own interest above the interest of an advisory client. 2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received as a result of his or her employment unless the information is also available to the investing public. 3. We maintain a list of recommended securities (current mutual funds and exchange- traded securities used in client portfolios.) 4. We have established procedures for the maintenance of all required books and records. 5. Clients can decline to implement any advice rendered, except in situations where our firm is granted discretionary authority. 6. All of our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 7. We require delivery and acknowledgement of the Code of Ethics by each supervised person of our firm. 8. We have established policies requiring the reporting of Code of Ethics violations. 9. Any individual who violates any of the above restrictions may be subject to disciplinary sanctions, up to and including termination. Item 12 Brokerage Practices Atlantic Edge and individuals associated with our firm are prohibited from engaging in principal transactions and/or agency cross transactions. dealer to be used or the commission As our firm does not have the discretionary authority to determine the broker rates to be paid, clients must direct Atlantic Edge as to the broker-dealer to be used. ‐ Atlantic Edge routinely recommends the brokerage and custodial services of either Schwab Institutional (Schwab Advisor Services) division of Charles Schwab & Co., Inc. ("Schwab"), a FINRA registered broker-dealer, member SIPC. We have an arrangement with Schwab through which such firm provides Atlantic Edge with its platform services. The platform services include, among other items, brokerage, custodial, administrative support, record keeping and related services that are intended to provide support to our firm in conducting business and in serving the best interests of our clients. Atlantic Edge is independently owned and operated and not affiliated with Schwab. Regardless, you may utilize the broker/dealer of your choice and have no obligation to purchase or sell securities through the brokers we recommend. SCHWAB Atlantic Edge may effect trades for client accounts at Schwab, or may in some instances, consistent with Atlantic Edge's duty of best execution and specific agreement with each client, elect to execute trades elsewhere. Although Atlantic Edge may recommend that clients establish accounts at Schwab, it is ultimately the client’s decision to custody assets with Schwab. Atlantic Edge is independently owned and operated and is not affiliated with Schwab. Schwab provides Atlantic Edge with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser's clients' assets are maintained in accounts at Schwab Institutional. These services are not contingent upon our firm committing to Schwab any specific amount of business (assets in custody or trading commissions). Schwab's brokerage services include the execution of securities transactions, custody, research, and access to 12 | P a g e  mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset- based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab Institutional also makes available to our firm other products and services that benefit Atlantic Edge but may not directly benefit our clients’ accounts. Many of these products and services may be used to service all or some substantial number of our client accounts, including accounts not maintained at Schwab. Schwab's products and services that assist us in managing and administering our clients' accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution (iii) provide research, pricing and other market data; (iv) facilitate payment of our fees from clients' accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Schwab Institutional also offers other services intended to help us manage and further develop our business enterprise. These services may include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. Schwab may make available, arrange and/or pay third-party vendors for the types of services rendered to Atlantic Edge. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to our firm. Schwab Institutional may also provide other benefits such as educational events or occasional business entertainment of our personnel. In evaluating whether to recommend or require that clients custody their assets at Schwab, we may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors we consider and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Trade Errors -Schwab In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade and/or reimbursing the account. If a trade error results in a profit, the profit goes the client’s account in which the error occurred. Item 13 Review of Accounts Investment Management Services the underlying securities within Investment Management Services accounts are Reviews. While continually monitored, these accounts are reviewed at least quarterly. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. Furthermore, Atlantic Edge offers to conduct an annual review of the client's investment policy statement (IPS) and makes any necessary revisions. These accounts are reviewed by Matthew B. Cochran, a Managing member and Chief Compliance Officer (CCO), and/or the other Managing Members, Kaitlyn P. Weatherly or Jeffery T. Albaneze. Reports. In addition to the monthly statements and confirmations of transactions that clients receive from their broker dealer, we provide written quarterly reports summarizing account performance, balances and holdings. ‐ 13 | P a g e  Item 14 Client Referrals and Other Compensation Client Referrals It is Atlantic Edge’s policy not to engage solicitors or to pay related or non-related persons for referring potential clients to our firm. Other Compensation It is Atlantic Edge's policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. Item 15 Custody Atlantic Edge does not maintain physical custody of the investments under our management. We use a third- party custodian, Charles Schwab, to hold and safeguard stocks, mutual funds, and other assets. These custodians then independently maintain actual physical custody of client securities. We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm directly debits advisory fees from client accounts. As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to review carefully their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe there may be an error in their statement. Item 16 Investment Discretion Clients generally hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: • Determine the security to buy or sell, and/or • Determine the amount of the security to buy and/or sell. Clients give us discretionary authority when they sign a discretionary agreement with our firm and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by once again providing us with written instructions. ‐ Discretionary Clients. An advisory client electing not to grant investment discretionary authority to Atlantic Non Edge is advised that trades in his/her account may be executed subsequent to trades effected in discretionary accounts due to the additional time involved in obtaining the required client approval prior to executing any trade in such client's account. Furthermore, these clients may be excluded from participation in block trading and thus there may be a difference in the price per share of a given security and the commission rates paid between client accounts. Item 17 Voting Client Securities We offer to vote proxies for all client accounts; however, you always have the right to vote proxies yourself. You can exercise this right by instructing us in writing to not vote some or all proxies in your account. We vote proxies in the best interests of our clients and in accordance with our established policies and procedures. Our firm retains all proxy voting books and records for the requisite period of time, including a copy of each proxy statement received, a record of each vote cast, a copy of any document created by us that was material to making a decision how to vote proxies, and a copy of each written client request for information on how specific proxies were voted. If our firm has a conflict of interest in voting a particular action, we advise the client of the conflict and request that the client instruct Atlantic Edge on the vote to cast on the client's behalf. 14 | P a g e  ‐ Under certain circumstances, we may retain an independent third party to cast a vote. In certain instances, Atlantic Edge and its client may agree that Atlantic Edge will abstain from voting any proxies at all, regardless of whether the client undertakes to vote the proxies itself. With respect to ERISA accounts, we will vote proxies unless the plan documents specifically reserve the plan sponsor's right to vote proxies. You can instruct us to vote proxies according to particular criteria (for example, to always vote with management, or to vote for or against a proposal to allow a so-called "poison pill" defense against a possible takeover). You can also instruct us on how to cast your vote in a particular proxy contest. These directives must be provided to Atlantic Edge in writing. Clients may request a copy of our complete proxy voting policies and procedures. If any client requests a copy of our complete proxy policies and procedures and/or how we voted specific proxies for his/her account(s), we will promptly provide the requested information. Clients should direct proxy-related communications to Matthew B. Cochran, partner of Atlantic Edge. Email communications should be addressed to Matt@AtlanticEdgeWealth.com; other written communications should be addressed to the firm and mailed to his attention (see the cover page of this brochure for our address information). Class Actions, Bankruptcies, and Other Legal Proceedings. We will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s), including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, clients may direct us to transmit copies of class action notices to the client or a third party or to relate requested claim form information to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. Item 18 Financial Information Under no circumstances do we require or solicit payment of fees more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. Atlantic Edge has never been the subject of bankruptcy proceedings. 15 | P a g e