ATLAS

ATFS Advisers LLC Form ADV Part 2A 15603 Valerian Trail Frisco, TX 75033 (805) 557-8713 www.atlasfinancial.com March 26, 2026 This Form ADV Part 2A (“Firm Brochure”) provides information about the qualifications and business practices of ATFS Advisers LLC (“Atlas”, “ATFS”, the “Adviser”, “we”, “us”, or “our”). If you have any questions about the content of this Firm Brochure, please contact us at (805) 557-8713. Atlas is a registered investment Adviser with U.S. Securities and Exchange Commission (“SEC”). The information in this Firm Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment adviser does not imply any specific level of skill or training. This Firm Brochure provides information about ATFS to assist you in determining whether to retain us as your adviser. Additional information about ATFS Advisers LLC (CRD# 324191) and its advisory persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Adviser’s firm name or CRD number.  Item 2: Material Changes Registered investment advisers are required to amend their Firm Brochure when information becomes materially inaccurate. If there are any material changes to an adviser's Firm Brochure, the adviser is required to notify you and provide you with a description of the material changes. This summary of material changes does not describe all modifications, such as updates to dates and numbers, stylistic changes, corrections or clarifications. Summary of Material Changes since our most recent Firm Brochure filing on September 3, 2025: • No material changes to report. We are pleased to offer, upon request, a complimentary copy of our full Firm Brochure, which provides detailed information about our services, investment philosophy, and business practices. To receive your copy, please contact us using the information provided on the cover page, and we will promptly deliver the brochure to you at no cost. Form ADV Part 2A – Firm Brochure 2 ATFS Advisers LLC  Item 3: Table of Contents 2 Item 2: Material Changes Item 3: Table of Contents 3 Item 4: Advisory Services 4 Item 5: Fees and Compensation 10 Item 6: Performance-Based Fees and Side-By-Side Management 13 Item 7: Types of Clients 14 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 15 Item 9: Disciplinary Information 27 Item 10: Other Financial Industry Activities and Affiliations 28 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 29 Item 12: Brokerage Practices 30 Item 13: Review of Accounts 34 Item 14: Client Referrals and Other Compensation 35 Item 15: Custody 36 Item 16: Investment Discretion 37 Item 17: Voting Client Securities 38 Item 18: Financial Information 39 Form ADV Part 2A – Firm Brochure 3 ATFS Advisers LLC  Item 4: Advisory Services ATFS Advisers LLC (hereinafter referred to as “Atlas”, “ATFS,” the “Adviser,” “Firm,” “we,” “us,” or “our”) is a Delaware limited liability company with its principal office located in Texas and is registered with the Securities and Exchange Commission (the “SEC”) as an investment adviser. ATFS was formed in October 2022 and is wholly-owned by Atlas Financial Services, Inc. (“Atlas Financial”). Atlas Financial is a privately held financial technology company that provides a wealth management platform and investment tools to ATFS. Often times, Atlas Financial and ATFS are collectively referred to as Atlas. Information about the Firm’s organizational and ownership structure is provided on Part 1 of the Firm’s Form ADV, which is available online at www.adviserinfo.sec.gov. This Firm Brochure provides information regarding the qualifications, business practices, and the advisory services provided by ATFS. For information regarding this Firm Brochure, please contact Tara Horne (Chief Compliance Officer) by emailing tara@atlasfinancial.com. Advisory Services Offered ATFS offers advisory services to individuals, high net worth individuals, families, trusts, estates, businesses, and retirement plans (each referred to as a “Client”) designed to help Clients accomplish their financial goals. ATFS serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, ATFS upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate conflicts of interest. ATFS’s fiduciary commitment is further described in ATFS’s Code of Ethics. For more information regarding the Code of Ethics, please see “Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”. Atlas Private Client ATFS is an adviser to Client investment accounts through a service called Atlas Private Client. Through Atlas Private Client, the Firm provides customized discretionary and non- discretionary investment and wealth management services to high-net-worth individuals and associated trusts, estates, pension and profit-sharing plans, and other legal entities. ATFS generally invests client discretionary assets in domestic and international stocks, bonds, options, mutual funds, exchange traded funds (“ETFs”), private funds, and real estate. ATFS works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to design a portfolio strategy. ATFS considers the Client’s specific goals and risk tolerance and its capital markets outlook when directing assets to specific investments. ATFS may retain certain legacy investments based on portfolio fit and/or tax considerations for each Client. Atlas Private Client maintains an online presence through the Firm’s website, www.atlasfinancial.com, primarily for informational purposes. Through Atlas Private Client, ATFS may also provide investment advice to its Clients with Form ADV Part 2A – Firm Brochure 4 ATFS Advisers LLC  held away assets such as 401ks and shares in private companies. In providing these services, ATFS may or may not have the ability to transact in the Client’s account, depending on the platform where such assets are held. Provision of these services is subject to the Client’s investment advisory agreement with ATFS. With respect to each Client account and the investment portfolio held in each Client account, ATFS will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by ATFS. ATFS evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. ATFS may recommend, on occasion, redistributing investment allocations to diversify the portfolio. ATFS may recommend specific positions to increase sector or asset class weightings. ATFS may recommend employing cash positions as a possible hedge against the market movement. ATFS may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Financial Planning ATFS provides financial planning services. Financial planning is a comprehensive evaluation of a Client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients receiving this service from ATFS receive a written report that provides the Client with a detailed financial plan designed to assist the Client achieve his or her financial goals and objectives. In general, a financial plan from ATFS can address any or all of the following areas: • Personal: ATFS reviews family records, budgeting, personal liability, estate information and financial goals. • Tax & Cash Flow: ATFS analyzes the Client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability. • Investments: ATFS analyzes investment alternatives and their effect on the Client's portfolio. • Insurance: ATFS reviews existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. Form ADV Part 2A – Firm Brochure 5 ATFS Advisers LLC  • Retirement: ATFS analyzes current strategies and investment plans to help the Client achieve his or her retirement goals. • Death & Disability: ATFS reviews the Client’s cash needs at death, income needs of surviving dependents, estate planning and disability income. • Estate: ATFS assists the Client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder care. ATFS gathers required information through in-depth personal interviews and ongoing Client conversations. Information gathered includes the Client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. ATFS carefully reviews documents supplied by the Client. Should the Client choose to implement the recommendations contained in the financial plan, we suggest the Client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the Client's discretion, except to the extent that ATFS is providing discretionary investment advisory services to the Client’s portfolios included in such financial plan. ATFS also provides general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial planning 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. Wealth.com ATFS may also utilize third-party resources and tools such as to help with certain elements of the financial planning process (i.e., trust and estate planning). When third-party resources and/or tools are used, it may cause additional ancillary fees to be incurred to cover the costs associated with subscriptions to these services. ATFS is not affiliated with these third-party resources, so it is important to consult with your financial professional regarding all fees associated with your planning services when you engage ATFS. Spreadwise Borrowing Spreadwise Borrowing (“Spreadwise”) is a borrowing strategy available to Atlas Clients, which deploys the implementation of synthetic loan strategies utilizing listed index options. This service is considered an “add on” strategy to ATFS’ wealth management. Please defer to the “Item 5: Fees and Compensation” for more information about the costs associated. Form ADV Part 2A – Firm Brochure 6 ATFS Advisers LLC  Private Fund Management ATFS also provides portfolio management services to a pooled investment vehicle, called the Atlas Evergreen Private Credit Fund I, (referred to herein as “APC” or the “Fund”). These services are detailed in the offering documents for the Fund, which include as applicable, operating agreements, private placement memoranda and/or term sheets, limited partnership agreements, separate disclosure documents, and all amendments thereto (“Offering Documents”). ATFS and its related persons serve as General Partner (“GP”) over the Fund. ATFS manages the Fund based on the investment objectives, policies and guidelines as set forth in the respective Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein. Each prospective investor interested in investing in the Fund is required to complete a subscription agreement in which the prospective investor attests as to whether or not they meet the minimum qualifications to invest in the Fund and further acknowledges and accepts various risk factors associated with such an investment. The Fund is only offered to certain sophisticated investors, who meet certain requirements under applicable state and/or federal securities laws. Persons affiliated with ATFS may have made an investment in the Fund and therefore have an incentive to recommend the Fund to over other investments available. Clients of ATFS are under no obligation to invest in APC. For more information on investment objectives, policies, guidelines and risks, please refer to the Fund’s Offering Documents. Selection of Sub-Advisors ATFS may engage one or more third-party sub-advisors to manage a portion of assets if deemed appropriate and in the best interest of the Client. ATFS will generally execute a sub- advisory agreement with the third-party advisor. ATFS will provide the Client with the sub- advisor’s Form ADV Part 2A, Part 2B, Form CRS and Privacy Policy, as applicable. In some cases, ATFS may require the Client to execute a separate written agreement directly with the third-party sub-advisor instead of ATFS doing so on the Client’s behalf. Sub-advisors shall have limited power-of-attorney and shall have only trading authority over those assets ATFS directs to them for management. Sub-advisors shall be authorized to buy, sell and trade (in accordance with applicable law and consistent with the Client’s objectives) and to give instructions, related to their authority, to the broker-dealer and custodian. Unless otherwise disclosed to Clients prior to the engagement of a third-party sub-advisor, ATFS will be responsible for compensating the sub-advisor for any investment management fees due for advisory services performed on ATFS’ Client accounts by sub-advisors subject to the agreement(s) executed. Generally, the Client will not incur additional management fees by ATFS for the investment advisory services rendered by the sub-advisor. In the event fees to a sub-advisor shall result in increased fees to Clients, the Clients shall be notified in writing and such increased fees shall become effective no earlier than 30 days after written notice is sent to the Client, unless a written objection is sent to back to ATFS prior to the expiration of that time. The Client may incur transaction fees and custodial fees Form ADV Part 2A – Firm Brochure 7 ATFS Advisers LLC  on assets managed by the sub-advisor, which are separate and distinct from the advisory fees. ATFS reasonably monitors and reviews the performance of all Client account activity managed by the third-party sub-advisor. ATFS Acting as Sub-Advisor ATFS may act as a sub-advisor to other non-affiliated investment advisors who hire ATFS to manage a portion of, or all of their clients’ portfolio(s). The non-affiliated investment advisors must have discretionary authority over the account and the ability to delegate that discretionary authority to ATFS. ATFS will manage the assets according to the agreed upon strategies between the non-affiliated investment advisor and ATFS. Client Account Management Prior to engaging ATFS to provide advisory services each Client is required to enter into a written advisory agreement with the Adviser that define the fees, terms, conditions, authority, and responsibilities of the relationship between ATFS and the Client. These services may include: • Establishing an Investment Strategy – ATFS, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – ATFS will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client or unique client goal. • Portfolio Construction – ATFS will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Wealth Management and Supervision – ATFS will provide wealth management and ongoing oversight of the Client’s investment portfolio. ERISA Fiduciary Statement When we provide investment advice to you regarding whether to rollover your retirement plan account or individual retirement account, we are fiduciaries 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 some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Form ADV Part 2A – Firm Brochure 8 ATFS Advisers LLC  Assets Under Management As of February 28, 2026, ATFS has a total of $153,858,461 in assets under management, of which $40,331,938 is managed on a discretionary basis, and $113,526,523 is managed on a non-discretionary basis. Form ADV Part 2A – Firm Brochure 9 ATFS Advisers LLC  Item 5: Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Adviser. Each Client engaging the Firm for services described herein shall be required to enter into a written investment advisory agreement with the Firm containing the applicable fee for the services each Client seeks to obtain. Fees for Advisory Services Asset-Based Fees Fees will be based on a percentage of the Client’s total managed assets and are paid in advance on a monthly basis and based on the previous month’s ending account value (or initial account balance prorated for the initial billing cycle in the case of new Clients) as agreed upon by ATFS and the Client. Fees are negotiable and typically range between 0.50%- 1.5% per year, depending on the size and complexity of the Client account, among other factors. Accounts initiated or terminated during a calendar month will be charged a prorated fee based on the number of days that the account(s) was managed. ATFS typically imposes a minimum account size of $250,000 before executing an investment management agreement, however, this minimum may be waived on a case-by-case basis. The market value of assets includes accrued interest and dividends, as well as margin balances (if applicable). Most Clients authorize ATFS to deduct fees automatically from their brokerage accounts, but Clients may request that the Firm send monthly invoices to be paid by check or ACH. The custodian of the Client’s brokerage account is responsible for sending statements at least quarterly indicating, among other things, management fees disbursed from the account. ATFS may agree to aggregate the assets of multiple separate accounts of a client and other affiliated clients for fee calculation purposes. Fixed Fees Clients can be charged an annual fixed fee for investment management services. Annual fixed fees are negotiated based on the size and complexity of the relationship and charged based on the frequency stated in the agreement with the client. Private Fund Management Fees The Fund is billed quarterly for management fees, not to exceed 1% annually. The fee is calculated on a quarterly basis on the investor’s capital contributed. Investors should refer to the Offering Documents for specifics on all fees charged to and/or expensed to the Fund. Spreadwise Borrowing Fees For Spreadwise Borrowing, an annual advisory fee of .60% will be calculated and billed monthly in arrears based on the end-of-month market value of active synthetic loans. Fees Form ADV Part 2A – Firm Brochure 10 ATFS Advisers LLC  for Spreadwise Borrowing are identified in each Client’s investment management agreement if they are enrolled in the program. Fees may be negotiable and/or waived at ATFS’ discretion. Sub-Advisory Fees (when ATFS acts as Sub-Advisor) Fees will be charged by ATFS on the total assets under management that the third-party investment advisor brings to ATFS. ATFS is compensated directly by the third-party investment advisor with a portion of their investment management fees collected by them on their clients’ accounts. Third-party investment advisors who engage ATFS as a sub- advisor shall be responsible for billing their clients and collecting all fees then remitting a portion of those fees to ATFS per an executed agreement between ATFS and the third-party investment advisor. Custodial Fees and Other Fees Fees paid to ATFS for investment advisory services provided via Atlas Private Client are separate and distinct from the fees and expenses charged by underlying pooled investments such as mutual funds and exchange traded funds. In the case of mutual funds, these fees and expenses are described in each fund’s prospectus. These fees will generally include a management fee, other fund expenses, and possible distribution fee. As a general rule, ATFS does not use mutual funds that charge sales charges or distribution fees. Expenses of a fund, including management fees payable to the mutual fund manager and other expenses, will not appear as transaction fees on a client’s ATFS statement, as they are deducted from the value of the fund shares by the mutual fund service provider. Clients will incur certain charges imposed by financial institutions and other third parties such as custodial fees, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Additionally, clients may incur brokerage commissions and transaction fees. Such charges, fees and commissions are exclusive of and in addition to the ATFS asset-based fee. For information relating to custodial fees and expenses, please refer to the applicable custodial agreement or contact the applicable custodian. Clients may make additions to and withdrawals from their account[s] at any time, subject to ATFS’ right to terminate an account. Additions may be in cash or securities provided that ATFS reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw account assets on notice to ATFS, subject to the usual and customary securities settlement procedures. However, the withdrawal of assets may impair the achievement of a Client’s investment objectives. ATFS may consult with its Clients about the options and ramifications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. Form ADV Part 2A – Firm Brochure 11 ATFS Advisers LLC  Fee Billing Investment advisory fees for Atlas Private Client are calculated by ATFS and deducted from the Client’s account[s] at the applicable custodian. ATFS shall send an invoice to the applicable custodian indicating the amount of the fees to be deducted from the Client’s account[s] held at the applicable custodian at the end of each month. If fees are paid in advance of the month, the amount due is calculated by applying the monthly rate (annual rate divided by 12) to the market value of assets under management as of the end of the prior month. Clients will be provided with a statement, generally quarterly, from the applicable custodian reflecting the deduction of the wealth management fee. Clients provide written authorization permitting advisory fees to be deducted by ATFS to be paid directly from their account[s] held by the applicable custodian as part of their investment advisory agreement and separate account forms provided by the applicable custodian. Advance Payment of Fees and Termination Either party may terminate the investment advisory agreement on wealth management services, at any time, by providing advance written notice to the other party. Any fees paid in advance but deemed to be unearned due to termination during the billing cycle, will be returned to the client as soon as reasonably possible. Compensation for Sales of Securities ATFS does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account. Form ADV Part 2A – Firm Brochure 12 ATFS Advisers LLC  Item 6: Performance-Based Fees and Side-By-Side Management The GP of the Atlas Evergreen Private Credit Fund I is entitled to a performance-based fee (“Performance Allocation”) for each fiscal quarter made on net profits that exceed a return of 3% for the quarter (12% annualized). The Performance Allocation is based on a breakpoint fee schedule ranging from 20% - 50% based on subscriptions. Performance-based fee arrangements are only offered to clients who meet applicable regulatory requirements, such as “qualified clients,” as defined under the Rule 205-3 under the Investment Advisers Act of 1940. Performance-based fee arrangements create inherent conflicts of interest as it may create an incentive for the firm to make investments that are riskier or more volatile than those that would be recommended under a different fee structure, as higher risk investments may increase the potential for higher returns (and therefore higher fees), even though they also increase the potential for losses. The Firm’s fiduciary duty requires that it act in the best interests of all clients, regardless of the fee arrangement. Clients should be aware of these conflicts and are encouraged to discuss any questions with their investment adviser representative. Please refer to the Offering Documents for complete details. Form ADV Part 2A – Firm Brochure 13 ATFS Advisers LLC  Item 7: Types of Clients ATFS primarily provides wealth management services to pooled investment vehicles and to high-net-worth individuals, associated trusts, estates, pension and profit-sharing plans, and other legal entities. The minimum Client size for Atlas Private Client is generally $250,000, but this amount is negotiable at the Firm’s discretion. Form ADV Part 2A – Firm Brochure 14 ATFS Advisers LLC  Methods of Analysis Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ATFS primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from ATFS are derived from numerous sources, including financial media companies, third-party research materials, professional data subscriptions, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. ATFS develops customized investment recommendations for each Client based on a variety of factors including the Client’s investment objectives and risk tolerance among other factors. The Firm typically meets with the new individual Client at least once before developing an investment plan and recommended asset allocation strategy. The Firm works carefully to understand each individual Client’s risk tolerance and investment goals, but Clients should understand that all investing involves the risk of loss. The Firm primarily invests for relatively long-term periods (more than 3 years) using primarily an index-based approach to investing in a broad range of diversified exchange- traded funds (ETFs) in addition to direct ownership of individual equities. The Firm may also provide advice on mutual funds, exchange traded notes (ETNs), bonds, stocks, hedge funds, private equity funds, real estate, restricted stock, private stock, and structured notes. In managing Client assets, the Firm seeks to limit risk through diversification among asset classes and, as appropriate for certain Clients, will recommend third party sponsored alternative investments or sub advisors. Fundamental Proprietary Research Process for Portfolio Strategies Offered to Clients: ATFS has developed a fundamental research process, which includes both qualitative and quantitative factors, that it employs to construct and manage a concentrated basket of equities while providing hedging (each, an “ATFS Strategy"). Clients have the option to include these ATFS Strategies in their managed portfolios. The research process aims to select equities who align with the subject matter of a particular ATFS Strategy and whose underlying assets meet certain characteristics such as the following: durable competitive advantages, high returns on capital, strong management teams, and attractive valuations. These criteria, among others, are used to monitor and manage each ATFS Strategy. As part of the analysis and review process for its portfolio strategies, ATFS may add, remove, re-categorize or replace ATFS Strategies or assets within a given ATFS Strategy offered to Clients. In the event an asset is removed from a ATFS Strategy and replaced with another substantially similar asset, ATFS will liquidate Client positions to cash and directly initiate a reinvestment in the replacement investment. As noted above, ATFS generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. ATFS will typically hold all or a portion of a security for Form ADV Part 2A – Firm Brochure 15 ATFS Advisers LLC  more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, ATFS may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. Risk of Loss No guarantee or representation is made that Client accounts will achieve their investment objective. Investing involves risks. The risks set out below do not purport to be exhaustive. Additional risks and uncertainties that are currently unknown or currently deemed immaterial may become material factors that affect Clients. Prospective Clients should carefully consider the risks involved in an investment with ATFS. ATFS does not guarantee the future performance of any Client’s account. Clients must understand that investments involve substantial risk and are subject to various market, currency, economic, political and business risks, and that those investment decisions and actions will not always be profitable. Clients may lose some or all of the amount invested. Subject to the Advisers Act, ATFS shall have no liability for any losses in a Client’s account. The price of any security can decline for a variety of reasons outside of ATFS’s control, including, but not limited to, changes in the macroeconomic environment, unpredictable market sentiment, forecasted or unforeseen economic developments, interest rates, regulatory changes, and domestic or foreign political, demographic, or social events. There is no guarantee that ATFS’s judgment or investment decisions about particular securities will necessarily produce the intended results. ATFS’s judgment may prove to be incorrect, and a Client might not achieve his or her investment objectives. High volatility and/or the lack of deep and active liquid markets may prevent the sale of a Client’s securities at all, or at an advantageous time or price because ATFS and the applicable custodian may have difficulty finding a buyer and may be forced to sell at a significant discount to market value. ATFS cannot guarantee any level of performance or that any Client will avoid a loss of account assets. Any investment in securities involves the possibility of financial loss that Clients should be prepared to bear. When evaluating risk, financial loss may be viewed differently by each Client and may depend on many different risk items, each of which may affect the probability of adverse consequences and the magnitude of any potential losses. The following risks may not be all- inclusive but should be considered carefully by a prospective Client before obtaining ATFS’s services through Atlas Private Client. These risks should be considered as possibilities, with additional regard to their actual probability of occurring and the effect on a Client if there is, in fact, an occurrence. Market Risk The price of a security and/or exchange-traded fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent Form ADV Part 2A – Firm Brochure 16 ATFS Advisers LLC  of a security’s particular underlying circumstances. For example, macroeconomic environment, unpredictable market sentiment, forecasted or unforeseen economic developments, interest rates, regulatory changes, and domestic or foreign political, demographic, or social events. If a Client has a high allocation in a particular asset/class, it may negatively affect overall performance to the extent that the asset/class underperforms relative to other market assets. Conversely, a low allocation to a particular asset class that outperforms other asset/classes in a particular period may cause that Client account to underperform relative to the overall market. Investment Risk There is no guarantee that ATFS’s judgment, recommendations, or investment decisions about particular portfolio strategies, securities, or asset classes will necessarily produce the intended results. ATFS’s judgment may prove to be incorrect, and a Client might not achieve his or her investment objectives by investing in the portfolio strategies. ATFS may also make future changes to the investing algorithms and services that it provides. In addition, it is possible that Clients or ATFS itself may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to ATFS’s software-based financial service. Volatility and Correlation Risk Clients should be aware that ATFS’s asset selection process for the portfolio strategies is based in part on a careful evaluation of past price performance and volatility in order to evaluate future probabilities. However, it is possible that different or unrelated asset/classes may exhibit similar price changes in similar directions which may adversely affect a Client and may become more acute in times of market upheaval or high volatility. Past performance is no guarantee of future results, and any historical returns, expected returns, or probability projections may not reflect actual future performance. Equity-Related Risk Investing in individual companies involves investments in common stocks and is subject to the volatility and individual risks associated with those stocks. These price movements may result from factors affecting individual companies, industries, or the securities market as a whole. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments. The prices of securities issued by such companies may suffer a decline in response. In addition, the equity market tends to move in cycles, which may cause stock prices to fall over short or extended periods of time. Concentration of Investments The portfolios will typically hold a relatively small number of security positions, which will expose the portfolio to the particular industry or market sector the security represents and the value of the specific company. Losses in one or more positions, or a downturn in an industry or market sector in which the company participates, could adversely affect the Form ADV Part 2A – Firm Brochure 17 ATFS Advisers LLC  portfolio’s performance in a particular period. Such limited diversification may heighten the concentration of risk, which, in turn, could expose the Client to losses disproportionate to market movements in general if there are disproportionately greater adverse price movements with respect to investments. Hedging Risk Although hedging strategies in general are usually intended to limit or reduce investment risk, they may not achieve the anticipated effect. In fact, they may result in poorer overall performance for the portfolio than it could have achieved had it not engaged in such hedging transactions. Furthermore, the portfolio will always be exposed to risks that cannot be hedged. ETF Risks, including Net Asset Valuations and Tracking Error ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depository Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. Clients should be aware that to the extent ATFS invests in ETF securities, they will pay two levels of compensation – the fee charged by ATFS plus any management fees charged by the issuer of the ETF. This scenario may cause a higher cost (and potentially lower investment returns) than if a Client purchased the ETF directly. ETFs typically include embedded expenses that may reduce the fund’s net asset value, and therefore directly affect the fund’s performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Expenses of the fund may include investment adviser management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Shareholders are also liable for taxes on any fund-level capital gains, as ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss Fundamental Investment Strategy Risks ATFS’s portfolio management and trading decisions are based on fundamental and technical research conducted by its professionals. The research process incorporates various operating and financial factors aimed at exploiting market trends, anomalies and pricing Form ADV Part 2A – Firm Brochure 18 ATFS Advisers LLC  discrepancies with a view to selecting investments in pursuit of the portfolio’s investment objectives. The process of designing and perfecting the research, portfolio construction, and management model is highly complex. ATFS cannot guarantee that the model will indeed function as intended or that it will produce profits on investments as implemented. The fundamental and quantitative strategies utilized by ATFS have inherent limitations, including the possibility of human error in the design, data input or implementation process, imperfections of a model to keep up with changes in the markets and the behavior of market participants over time. The risk of errors, malfunctions and anomalies is inherent in each component of the programming process, how those components function together, and how the program absorbs market data interpreted by ATFS. In addition, any portfolio manager judgment during the approval or override of model results is based on human skills and abilities similar to non-quantitative investing, with all the risks, potential errors or miscalculations that any asset or portfolio manager faces. Liquidity and Valuation Risk High volatility and/or the lack of deep and active liquid markets for a security may prevent the sale of a Client’s securities at all, or at an advantageous time or price because ATFS and The applicable clearing broker-dealer and custodian for your account may have difficulty finding a buyer and may be forced to sell at a significant discount to market value. Some securities (including ETFs) that hold or trade financial instruments may be adversely affected by liquidity issues as they manage their portfolios. While ATFS values the securities held in Client accounts based on reasonably available exchange-traded security data, ATFS may from time to time receive or use inaccurate data, which could adversely affect security valuations, transaction size for purchases or sales, and/or the resulting fees paid to ATFS. Credit Risk ATFS cannot control and Clients are exposed to the risk that financial intermediaries or issuers may experience adverse economic consequences that may include impaired credit ratings, default, bankruptcy or insolvency, any of which may affect portfolio values or management. This risk applies to assets on deposit with any broker utilized by a Client, notwithstanding asset segregation and insurance requirements that are beneficial to Clients generally. In addition, exchange trading venues or trade settlement and clearing intermediaries could experience adverse events that may temporarily or permanently limit trading or adversely affect the value of securities held by Clients. Finally, any issuer of securities may experience a credit event that could impair or erase the value of the issuer’s securities held by a Client. ATFS seeks to limit credit risk through ETFs, which are subject to regulatory limits and leverage such that fund shareholders are given liquidation priority versus the fund issuer; however, certain funds and products may involve higher issuer credit risk because they are not structured as a registered fund. Legislative and Tax Risk Performance may directly or indirectly be affected by government legislation or regulation, Form ADV Part 2A – Firm Brochure 19 ATFS Advisers LLC  which may include, but is not limited to: changes in investment adviser, securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities and changes in the tax code that could affect interest income, income characterization, and/or tax reporting obligations. Inflation, Currency, and Interest Rate Risks Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. The liquidity and trading value of foreign currencies could be affected by global economic factors, such as inflation, interest rate levels, and trade balances among countries, as well as the actions of sovereign governments and central banks. In addition, the relative value of the U.S. dollar-denominated assets managed by ATFS may be affected by the risk that currency devaluations affect ATFS’s purchasing power. Client Information Collection ATFS gathers required information through in-depth personal interviews and ongoing Client conversations. Information gathered includes the Client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. ATFS carefully reviews documents supplied by the Client. ATFS considers all of this collected information for the basis for its investment recommendations. However, this collected information may not, or may not accurately, capture an individual Client’s needs. Operational Risk Operational risk is the exposure to the chance of loss arising from shortcomings or failures in internal processes or systems of ATFS or Schwab external events impacting those systems, and human error. A Client account may suffer a loss arising from shortcomings or failures in internal processes, people or systems, or from external events. Operational risk can arise from many factors ranging from routine processing errors to potentially costly incidents related to, for example, major systems failures. Trade errors and other operational mistakes (“Operating Events”) occasionally may occur in connection with ATFS’s management of Client accounts. ATFS has policies and procedures that address identification and correction of Operating Events. An Operating Event generally is compensable by ATFS to a Client when it is a mistake (whether an action or inaction) in which ATFS has, in ATFS’s reasonable view, deviated from the applicable investment guidelines or the applicable standard of care in managing a Client account, subject to the considerations set forth below. Operating Events may include, but are not limited to, the following: (i) the placement of orders (either purchases or sales) in excess of the amount intended to trade for a Client account; (ii) the purchase (or sale) of when it should have been sold (or purchased); (iii) a Form ADV Part 2A – Firm Brochure 20 ATFS Advisers LLC  purchase or sale not intended for the Client account; and (iv) incorrect allocations of trades. Operating Events can also occur in connection with other activities that are undertaken by ATFS, such as fee calculations, and other matters that are non-advisory in nature. ATFS makes its determinations regarding Operating Events pursuant to its policies on a case- by-case basis, in its discretion, based on factors it considers reasonable, including regulatory requirements, contractual obligations, and business practices. Not all Operating Events will be considered compensable mistakes. Relevant factors ATFS considers when evaluating whether an Operating Event is compensable include, among others, the nature of the service being provided at the time of the event, specific applicable contractual and legal requirements and standards of care, whether an applicable investment guideline was contravened, and the nature of the relevant circumstances. Operating Events may result in gains or losses or could have no financial impact. Clients are entitled to retain any gain resulting from an Operating Event. Operating Events involving erroneous transactions in Client accounts generally are corrected in accordance with the procedures established by ATFS and/or the applicable clearing broker-dealer and custodian for a Client account. When ATFS determines that reimbursement by ATFS is appropriate, the Client will be compensated as determined in good faith by ATFS. ATFS will determine the amount to be reimbursed, if any, based on what it considers reasonable guidelines regarding these matters in light of all of the facts and circumstances related to the Operating Event. In general, compensation is expected to be limited to direct and actual losses, which may be calculated relative to comparable conforming investments, market factors and benchmarks and with reference to related transactions, and/or other factors ATFS considers relevant. Compensation generally will not include any amounts or measures that ATFS determines are speculative or uncertain. Cybersecurity Risks ATFS and its service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data from cyber-attacks and hacking by other computer users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate, but unintentional events may have similar effects. Cyber-attacks may cause losses to ATFS’s Clients by interfering with the processing of transactions, affecting ATFS’s ability to calculate net asset value or impeding or sabotaging trading. Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary information. Any such breach could expose ATFS to civil liability as well as regulatory inquiry Form ADV Part 2A – Firm Brochure 21 ATFS Advisers LLC  and/or action. In addition, Clients could be exposed to additional losses as a result of unauthorized use of their personal information. While we have established business continuity plans, incident responses plans and systems designed to prevent cyber-attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified. Similar types of cybersecurity risks also are present for issuers of securities in which we invest, which could result in material adverse consequences for such issuers and may cause a Client’s investment in such securities to lose value. Reliance on Management and Other Third Parties ETF investments will rely on third-party management and advisers. ATFS will not have an active role in the day-to-day management of fund investments. Carried interest and other incentive distributions to fund management may create an incentive towards more speculative investments than would otherwise have been made. Market Volatility General economic conditions have an impact on the success of ATFS’s investment strategies. Changing external economic conditions in the U.S. and global economics could have a significant impact on the success of the Clients’ investments. The stability and sustainability of growth in global economies may be impacted by terrorism or acts of war. There can be no assurance that such markets and economic systems will be available for issuers of securities available to Clients. Changing economic conditions, thus, could potentially adversely impact the valuation of Clients’ investments in securities. Large Investment Risks Clients may collectively account for a large portion of the assets in certain investments. A decision by many investors to buy or sell some or all of a particular investment where Clients hold a significant portion of that investment may negatively impact the value of that the investment. Leveraged and Inverse ETFs, ETNs and Mutual Funds Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index’s return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged Form ADV Part 2A – Firm Brochure 22 ATFS Advisers LLC  products. In highly volatile markets with large positive and negative swings, return distortions may be magnified over time. Some deviations from the stated objectives, to the positive or negative, are possible and may or may not correct themselves over time. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. Margin Risk When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your brokerage firm. If you choose to borrow funds through a margin account, securities purchased are the firm's collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the firm can act, such as issue a margin call and/or sell securities or other assets in any of your accounts held with the member, in order to maintain the required equity in the account. Investing with margin is characterized by unique risks including amplified losses due to increased leverage; margin calls; forced liquidations; and additional fees including margin interest charges and increased advisory fees (See Item 5 for more information). In order to manage margin risk, ATFS recommends leveraging responsibly (borrowing less than the amount available); keeping a diversified portfolio; and monitoring the account and evaluating risk regularly. Before investing on margin, be sure to read the Margin Disclosure Statement provided by your broker-dealer or custodian. Other Catastrophic Risks Clients, ATFS, and their respective affiliates, may be subject to the risk of loss arising from direct or indirect exposure to a number of types of other catastrophic events, including without limitation (i) other public health crises, including any outbreak of COVID-19, SARS, H1N1/09 influenza, avian influenza, other coronavirus, Ebola or other existing or new epidemic diseases, or the threat thereof; or (ii) other major events or disruptions, such as hurricanes, earthquakes, tornadoes, fires, flooding and other natural disasters; acts of war or terrorism, including cyberterrorism; or major or prolonged power outages or network interruptions. The extent of the impact of any such catastrophe or other emergency on ATFS’s and/or a Client’s operational and financial performance and each Client’s investments will depend on many factors, including the duration and scope of such emergency, the extent of any related travel advisories and restrictions, the impact on overall supply and demand, goods and services, investor liquidity, consumer confidence and levels of economic activity, and the extent of its disruption to important global, regional and local supply chains and economic markets, all of which are highly uncertain and cannot be predicted. In particular, to the extent that any such event occurs and has a material effect on global financial markets or specific markets in which a Client participates (or has a material effect on any locations in which ATFS operates or on any of its personnel) the risks of loss could be substantial and could have a material adverse effect on Clients or the ability of ATFS to fulfill its investment objectives on behalf of its Clients. Form ADV Part 2A – Firm Brochure 23 ATFS Advisers LLC  Limitations of Disclosure The foregoing list of risks does not purport to be a complete enumeration or explanation of the risks involved in investing in investments. As investment strategies develop and change over time, Clients may be subject to additional and different risk factors. No assurance can be made that profits will be achieved or that substantial losses will not be incurred. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Atlas Evergreen Private Credit Fund I (“APC”) The APCFI is an open-ended fund that invests in structured merchant private credit opportunities. The following is a summary of the material risks associated with investment strategies for the Fund. The information contained in this Brochure cannot disclose every potential risk associated with the Fund, rather, it is a general description of the nature and risks associated. Investors should understand that an investment in the Fund involves risk of loss, including the potential loss of their entire investment. No guarantee is made that the Fund’s investment objectives will be achieved. Prospective investors should carefully review the Offering Documents for additional information regarding the risks. Merchant Related Risks in The Fund intends to raise capital through sales of passive membership interests and to use said capital for investments in short duration merchant private credit deals (MPC). Due to this methodology, risks to merchants may impact investors as well. Merchants are spread across sectors of the economy and general economic fluctuations may impact the ability of merchants in repayment under the terms of each MPC. Regional and national economic weakness could adversely affect the performance and viability of Merchants, regardless of sector. MPC deals and the merchants associated with them are subject both directly and indirectly to federal regulation. It is possible that new regulations or new interpretations of existing regulations could adversely affect the fund. Included in some MPC deals will be Merchant Cash Advances (MCA). MCAs are regulated by the Uniform Commercial Code which jurisdictional comes with the risks of uncertainty resulting from differences interpretations across parties. The Fund and the Management Company rely on MPC Firms to underwrite potential MPC deals, which presents the risk of inaccurate assessments ultimately impacting Fund returns. MPC Firms have fees associated with them including Platform Fee, Cash Management Fee, and ISO Fee. Fund Capitalization Risks The Fund has limited capitalization and as a result, may be dependent on raising funds. The Fund may seek additional working capital through debt or equity financing. Debt financing Form ADV Part 2A – Firm Brochure 24 ATFS Advisers LLC  comes with a number of additional risks. The Fund may be required to mortgage, pledge, or hypothecate its assets. Additionally, interest rates fixed or variable, collateral agreements, balloon payment on maturity date, or a lender exercising control over The Fund adverse to Investor interests are all risks potentially impacting Fund business. Internal Operation Risks The Fund should be considered in the developmental stage as it has a limited operating history and has not produced any revenue. The absence of prior operating history and the need for working capital present risks to funds such as this. There may not be any current income to distribute to members. Furthermore, there is no assurance that the amount of cash reserves will be adequate to cover fund operating expenses. Problems, expenses, and delays frequently encountered by new businesses as well as a competitive environment may also impact The Funds operation. Risks of Private Offerings As this offering is nonpublic, it is not registered under federal or state securities laws and thus Prospective Investors will not have the benefit of review by the SEC or any state securities regulatory authority. Rescission of purchased units by Prospective Investors may result in severe financial demands that could adversely affect The Fund as a whole. The Fund does not intend at this time to register under the Investment Company Act of 1940, as amended, in reliance upon one or more exemptions from its registration provisions. To the Sponsor’s knowledge, the intended business of the Fund does not subject the Sponsor to the Investment Advisors Act of 1940, or equivalent state laws. The Management Company is an SEC registered investment adviser and will be advising the Fund. Units of the Fund will be considered restricted securities, and any resale will subject them to state and federal securities laws as well as additional restrictions imposed by the Fund Operating Agreement. Tax Related Risks Because the tax aspects of the Fund are complex and may differ depending on individual tax circumstances, each prospective investor must consult with and rely on his/her own, independent tax advisor concerning the tax aspects of the Fund offering and his/her individual situation. No representation or warranty of any kind is made with respect to the acceptance by the IRS of the treatment of any item by the Fund or by any investor. The Fund may generate unrelated business taxable income (UBTI) from its assets or debt financing, although Qualified Plans may be eligible for an exemption therefrom. Due to the likely presence of UBTIs, an investment in the Units is not appropriate for a Charitable Remainder Trust. An investor’s share of the Fund’s taxable income and loss will likely be considered to be derived from a passive activity. Limitations exist on losses and credits from passive activities. In order for allocations of income, gains, deductions, losses and credits under the Fund Operating Agreement to be recognized for tax purposes, such allocations must possess substantial economic effect. The Fund cannot assure that the IRS will not claim that such allocations lack substantial economic effect. An investor may have taxable income Form ADV Part 2A – Firm Brochure 25 ATFS Advisers LLC  that exceeds the amount of cash distributions received potentially resulting in an investor’s tax liability exceeding his/her share of cash distributions from the Fund. Investors may also be liable for Alternative Minimum Tax. Changes in federal income tax law could also adversely affect an investment in the Fund. Form ADV Part 2A – Firm Brochure 26 ATFS Advisers LLC  Item 9: Disciplinary Information There are no legal, regulatory, or disciplinary events involving ATFS or its management persons. ATFS values the trust Clients place in the Adviser. The Adviser encourages Clients to perform the requisite due diligence on any Adviser or service provider that the Client engages. The backgrounds of the Adviser and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Adviser’s firm name. Form ADV Part 2A – Firm Brochure 27 ATFS Advisers LLC  Item 10: Other Financial Industry Activities and Affiliations Third-Party Broker-Dealers Certain supervised persons of ATFS are also registered representatives (“RRs”) of an unaffiliated broker-dealer. In their capacity as RRs, these individuals are permitted to effect securities transactions for clients through the broker-dealer and may receive transaction- based compensation, such as commissions or other sales-related incentives. This arrangement presents a conflict of interest because RRs may have a financial incentive to recommend that clients implement securities transactions through the broker-dealer in order to receive such compensation. In addition, the broker-dealer may offer products, services, or investment opportunities that are not available through ATFS. This creates an incentive for RRs to recommend products or services offered through the broker-dealer, even where similar or lower-cost alternatives may be available through the investment adviser. Clients should be aware that they are under no obligation to purchase securities or insurance products through any supervised person in their capacity as a registered representative or through the unaffiliated broker-dealer. Clients are encouraged to discuss any questions regarding these conflicts with their investment adviser representative. Third-Party Investment Advisers Some persons providing investment advice on behalf of ATFS are separately registered as investment adviser representatives of other outside investment advisory firms and/or may be deemed supervised persons of outside third-party investment advisory firms. These outside advisory firms are not under common ownership or control with ATFS. This creates a conflict of interest because separate compensation arrangements typically exist that creates a financial incentive for some of our investment advisor representatives to recommend products or services outside of ATFS. Our Clients are under no obligation to purchase products, engage in transactions and/or accept services being made available or recommended via outside third-party advisory firms. Please review the separate ADV Part 2B provided to you about the persons at ATFS who are providing investment advice so you can better understand their specific arrangements and conflicts of interest. Outside Licensed Insurance Agents Some of our investment adviser representatives are licensed insurance agents outside of ATFS. ATFS is not an insurance broker. This creates a conflict of interest because separate compensation arrangements typically exist that creates a financial incentive for some of our investment advisor representatives to recommend insurance products to you for which they receive a commission. Please review the separate ADV Part 2B provided to you about the persons at ATFS who are providing investment advice so you can better understand their specific arrangements and conflicts of interest. Form ADV Part 2A – Firm Brochure 28 ATFS Advisers LLC  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ATFS’s ethical and legal duty is to act at all times as a fiduciary to its clients. This means that ATFS puts the interests of its clients ahead of its own and seeks to manage any perceived or actual conflict of interest that may arise in relation to our advisory services. ATFS has adopted a Code of Ethics (“COE”), which is designed to ensure that it meets its fiduciary obligation to clients, enhances its culture of compliance within the firm, and detects and prevents any violations of securities laws. ATFS’s COE establishes standards of conduct for ATFS’s officers and employees (“Supervised Persons”) and is consistent with the Code of Ethics requirements of Rule 204A-1 under the Investment Advisers Act of 1940, as amended. The COE includes general requirements that all Supervised Persons comply with their fiduciary obligations to clients and applicable securities laws, and also contains specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest, and confidentiality of client information. ATFS’s COE will be provided to any client or prospective client upon request. ATFS and its employees may purchase, sell, or otherwise enter into transactions for their own accounts in securities and other instruments. Prior to, or simultaneously with, or after such transactions, ATFS may, for its Clients provide suggestions for purchasing stock involving any of these same securities or other instruments and any related securities or instruments (including securities issued by the same issuer, options on such securities or instruments, and instruments convertible into such securities or instruments). ATFS has adopted the Code of Ethics discussed above to address potential conflicts. Subject to certain restrictions, ATFS and each of their employees personally may at any time hold, acquire, increase, decrease, dispose of or otherwise deal with positions in investments in which a Client may have an interest from time to time. ATFS has no obligation to recommend or acquire for a Client account a position in any security which it acquires or recommends on behalf of another Client, or which an employee acquires for his or her own account. Transactions effected for all Client accounts are not aggregated or combined with employee’s personal orders. In all instances, ATFS will act in the best interests of its Clients. Form ADV Part 2A – Firm Brochure 29 ATFS Advisers LLC  Item 12: Brokerage Practices Each Client is required to enter into an investment advisory agreement with the Firm, which discusses the services the Client will receive, the fees charged to the Client, and the conditions of the Client’s relationship with the Firm. Our advisory relationship begins upon the effective date of the investment advisory agreement with a Client. Any preliminary information provided to a Client before we accept the investment advisory agreement does not constitute investment advice under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and should not be relied on as such. The Firm does not provide brokerage or custodial services. The Firm seeks to use a custodian/clearing broker that will hold Client assets on terms that are most advantageous when compared with other available providers and their services. We consider a wide range of factors, including the ability to clear and settle trades, capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), availability of investment research and tools that assist us in making investment decisions, quality of services, competitiveness of the price of those services, reputation, financial strength, and stability of the provider. ATFS generally recommends that clients arrange for their assets to be held with Charles Schwab (“Schwab”). The Firm generally executes securities transactions through the institution where Client accounts are held. The Firm believes that Schwab provides reliable, quick, responsive, and efficient brokerage services. Schwab provides the Firm with access to their institutional trading and operational services, which are typically not available to retail individual investors. Their services also include custody and access to mutual funds and other investments that are otherwise generally available only to institutional investors or that would require a significantly higher minimum initial investment. Additionally, Schwab generally does not charge clients separately for custody of their investment accounts but is compensated by account holders through commissions, transaction-related fees or asset-based fees. Non-Soft Dollar Research and Additional Benefits Although not a material consideration when determining whether to recommend that a Client utilize the services of a particular custodian, ATFS receives from Schwab (or another custodian, investment platform, unaffiliated investment manager, vendor, unaffiliated product/fund sponsor, or vendor) support services and/or products, certain of which assist ATFS to better monitor and service Client accounts maintained at Schwab. Included within the support services that may be obtained by ATFS may be investment-related research, pricing information and market data, software and other technology that provide access to Client account data, compliance and/or practice management-related publications, discounted or gratis services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by ATFS in furtherance of its investment advisory Form ADV Part 2A – Firm Brochure 30 ATFS Advisers LLC  business operations. As indicated above, certain of the support services and/or products that may be received may assist ATFS in managing and administering Client accounts. Others do not directly provide such assistance but rather assist ATFS to manage and further develop its business operations. ATFS’s Clients do not pay more for investment transactions effected and/or assets maintained at Schwab as a result of this arrangement. There is no corresponding commitment made by ATFS to Schwab or any other entity to invest any specific amount or percentage of Client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. ATFS’ team remains available to address any questions that a Client or prospective Client may have regarding the above arrangement and any corresponding conflict of interest such arrangement may create. ATFS does not engage in any formal soft dollar practices. Best Execution Considerations Subject to the Clients’ investment advisory agreements that govern their participation in Atlas Private Client, the Firm has discretionary authority to determine the type, amount, and price of securities and investments to be bought and sold on behalf of each Client, including the selection of, and commissions paid to, brokers. The Firm considers a variety of factors in its selection of trading counterparties. The Firm seeks to trade with reputable counterparties. In addition to trading costs and listed prices, the Company periodically and systematically evaluates approved counterparties based on factors such as: • • • • • • • • • • • • The ability to execute large or difficult transactions; The ability to execute quickly when necessary; The ability to work orders when necessary; The ability to obtain locates for short sales; Special execution capabilities; Efficiency of execution and error resolution; Willingness to execute related or unrelated difficult transactions in the future; Custody, recordkeeping, and similar services The protection of proprietary trading information; Financial responsibility, regulation, and integrity; The frequency of trade errors; and The responsiveness to ATFS during trading and settlement. ATFS has not acquired any products or services with client brokerage commissions. Services Form ADV Part 2A – Firm Brochure 31 ATFS Advisers LLC  constituting “research” under Section 28(e) that ATFS may receive may include, but are not limited to: research reports; financial newsletters and trade journals; attendance at certain seminars and conferences; economic and market information; industry and company comments; technical data; recommendations; information on industries, groups of securities, individual companies, political developments, legal developments affecting portfolio securities and technical market action; statistical information; accounting and legal interpretations relating Client account transactions; credit analysis; risk measurement analysis, and performance analysis. These research services are received primarily in the form of written reports, calls, and meetings with research analysts. In addition, such research services may be provided in the form of access to computer-generated data and meetings arranged with corporate and industry spokespersons, economists, academicians and/or government representatives. Products and services constituting “brokerage” under Section 28(e) that the Company may receive may include, but are not limited to: services related to the execution, clearing and settlement of securities transactions and functions incidental thereto, such as connectivity services between ATFS and a broker-dealer and other relevant parties such as custodians; trading software operated by a broker-dealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; trade clearance and settlement; electronic communication of allocation instructions; routing of settlement instructions; post-trade matching of trade information; and services required by the SEC or a self-regulatory organization, such as comparison services, electronic confirms or trade affirmations. Directed Brokerage Clients generally do not direct the Firm to trade through any particular counterparty. A Client’s insistence on the use of one or more particular counterparties in connection with the trading of its account can have a materially adverse effect on the quality of execution that is available to the client. Among other things, Clients that direct the use of trading counterparties may pay higher transaction costs as a result of being excluded from aggregated orders, and trade after other Clients have traded. Trade Aggregation and Allocation Trading activities of Client accounts will occasionally overlap. While Client accounts invest in the same issuers, the purchase and sale of such investments may be at different times and upon different terms, based on each Client’s overall investment objectives and strategy, legal or regulatory concerns, and/or other relevant considerations. When ATFS purchases or sells securities of the same issuer at the same time for the Clients, ATFS may submit an aggregated trade for execution if ATFS believes that the use of an aggregated trade reasonably furthers its efforts to seek best execution. Participants in aggregated trades receive the average execution price and incur their pro rata share of the trading costs. Form ADV Part 2A – Firm Brochure 32 ATFS Advisers LLC  To the extent that partial fills occur, ATFS will allocate the results of the partially completed trade pro rata between participating Clients based on the initial allocation instructions submitted for execution. Impacted accounts receive the average execution price and incur their pro rata share of the trading costs with respect to the partially completed trade. Instances in which Client orders may not be aggregated include, but are not limited to, the following: (1) ATFS determines that the aggregation is not appropriate because of market conditions; (2) situations where ATFS must effect the transactions at different times or prices, making aggregation unfeasible; and (3) a determination is made by ATFS not to aggregate orders because of tax, legal, regulatory or administrative reasons such as typical trading increments or quantities. Trade Errors While ATFS takes the utmost care in making and implementing investment decisions on behalf of Clients, it may make an error while placing a trade for Clients. ATFS attempts to minimize trade errors by promptly reconciling confirmations with trade tickets, and by reviewing past trade errors to understand the internal control breakdown that caused the errors. If ATFS makes an error while placing a trade, it will seek to correct the error promptly in a way that mitigates any losses. The cost of errors will be borne by ATFS. for any error that is the result of bad faith, gross negligence, or willful misconduct by ATFS. ATFS will generally bear any costs associated with correcting any error in a Client’s account subject to the terms of the relevant investment management agreement. Valuation of Client Assets ATFS relies on the custodians of Client accounts to provide accurate valuations of Client investments. The Firm does not value investments separately from the values received from the custodians of the Client accounts. However, ATFS's periodic Client investment performance reports may vary slightly from custodial statements received by its Clients due to the Firm’s reliance on third party portfolio management systems to aggregate Client account information. Clients should contact ATFS if any significant discrepancies or errors are discovered. Form ADV Part 2A – Firm Brochure 33 ATFS Advisers LLC  Item 13: Review of Accounts ATFS strives to review managed Client accounts regularly with Clients, but there is no rigid schedule for doing so. However, Clients are offered a review on at least an annual basis. Each Client works with a dedicated advisor who is responsible for helping them determine an investment plan, establishing a target allocation percentage and answering any questions the client may have about their specific financial situation. ATFS reviews Client accounts periodically to ensure allocation thresholds are being met, and to invest money or withdraw it as necessary given the Client’s guidelines. Additional or focused reviews can be triggered by factors such as political and economic developments, corporate announcements, and changes in market conditions. Client Reports ATFS may provide quarterly and/or monthly reports on managed Client accounts and balances. Clients may also receive regular monthly statements from their applicable custodian(s) for the same accounts which show account transactions and month-end holdings. Custodian(s) are not responsible for verifying the calculation of our advisory fees. Clients should review their custodial statements and contact ATFS if any significant discrepancies or errors are discovered. Form ADV Part 2A – Firm Brochure 34 ATFS Advisers LLC  Item 14: Client Referrals and Other Compensation Client Referrals from Solicitors ATFS and/or some of its supervised persons have entered into agreements with individuals who are paid to refer potential clients to us (“Solicitors”). If a Solicitor refers prospective clients to ATFS, those Solicitors are entitled to receive a portion of the advisory fees those prospects pay us when they successfully become a Client of ATFS. Each Solicitor is engaged by ATFS pursuant to a “Referral Agreement” between ATFS and the Solicitor. Under the terms of that agreement, the Solicitor holds an obligation to inform you that there is a compensation arrangement in place which is the basis of their referral. This arrangement creates a conflict of interest because it provides the solicitor with a financial incentive to recommend ATFS. The fees paid to the Solicitor are not in addition to the fees Clients pay to us. There is no additional financial burden on the Client for this referral arrangement. Form ADV Part 2A – Firm Brochure 35 ATFS Advisers LLC  Item 15: Custody All Clients must place their assets with a “qualified custodian.” Clients are required to engage the applicable custodian (in most cases, Schwab) to retain their funds and securities and direct ATFS to utilize that custodian for the Client’s security transactions. Clients should review statements provided by the applicable custodian and compare to any reports provided by ATFS to ensure accuracy, as the custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Under government regulations, we are deemed to have custody of your assets if, for example, you authorize us to instruct your custodian to deduct our advisory fees directly from your account or if you grant us authority to move your money to another person’s account. Your custodian (in most cases, Schwab) maintains actual custody of your assets. You will receive account statements directly from your custodian at least quarterly. They will be sent to the email or postal mailing address you provided to the custodian. You should carefully review those statements promptly when you receive them. ATFS also urges you to compare the custodian’s account statements with the periodic account statements/portfolio reports you will receive from us. ATFS is also deemed to have custody of certain client assets due to our authority to effect disbursements from client accounts pursuant to clients’ standing letter of authorization (“SLOA”). An SLOA permits ATFS as authorized by the client, to direct the qualified custodian to transfer funds from the client’s account to one or more designated third parties. This authority is limited to transfers made in accordance with the client’s written instructions and does not allow ATFS to take physical possession of client assets. Client assets are maintained with a qualified custodian. The SEC has issued guidance in the form of a No-Action Letter (February 21, 2017), which provides that an investment adviser with custody solely as a result of SLOAs is not required to undergo an annual surprise examination by an independent public accountant, provided that specific conditions are satisfied, for which ATFS is complying with. Lastly, ATFS’ related persons serve as the GP to one or more private pooled investment vehicle(s). In our capacity as the GP, we will have access to pooled investment vehicles’ funds and securities, and therefore we are deemed to have custody over such funds and securities. We provide each investor in the pooled investment vehicle(s) with audited annual financial statements within 120 days (of 180 days for "fund of funds") of the fund's fiscal year end. Form ADV Part 2A – Firm Brochure 36 ATFS Advisers LLC  Item 16: Investment Discretion ATFS generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by ATFS. The discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by ATFS will be in accordance with each Client's investment objectives and goals. Form ADV Part 2A – Firm Brochure 37 ATFS Advisers LLC  Item 17: Voting Client Securities ATFS does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Adviser will assist in answering questions relating to proxies. However, the Client retains the sole responsibility for proxy decisions and voting. Form ADV Part 2A – Firm Brochure 38 ATFS Advisers LLC  Item 18: Financial Information Neither ATFS, nor its management, have any adverse financial situations that would reasonably impair the ability of ATFS to meet all obligations to its Clients. Neither ATFS, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. ATFS is not required to deliver a balance sheet along with this Firm Brochure as the Adviser does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Form ADV Part 2A – Firm Brochure 39 ATFS Advisers LLC