ATON Financial LLC is a registered investment advisor firm registered with the U. S. Securities 
and Exchange Commission (“SEC”) since April 2018.  Prior to that, the firm was registered with 
the Puerto Rico securities regulators since February 2015. 
The principal owners of ATON Financial LLC are Marko Rendic, CFA, Managing Member and 
Dionisio Trigo, Investor. 
Advisory Services 
ATON  Financial  LLC’s  (“ATON”  or  “Advisor”)  principal  service  is  providing  fee-based 
investment  advisory  services  and  financial  planning  services.    The  Advisor  practices  custom 
management of portfolios, on either a discretionary or non-discretionary basis, according to the 
client’s objectives.   The Advisor’s primary approach is to use a tactical allocation strategy aimed 
at reducing risk and increasing performance.  The Advisor may use any of the following: exchange 
listed  securities,  over-the-counter  securities,  foreign  securities,  corporate  debt  securities, 
commercial paper, CDs, variable annuities, municipal securities, mutual funds, and United States 
government  securities  to  accomplish  this  objective.    The  Advisor  measures  and  selects  mutual 
funds  by  using  various  criteria,  such  as  the  fund  manager’s  tenure,  and/or  overall  career 
performance.  The Advisor may recommend, on occasion, redistributing investment allocations to 
diversify the portfolio in an effort to reduce risk and increase performance.  The Advisor may 
recommend specific stocks to increase sector weighting and/or dividend potential.  The Advisor 
may recommend employing cash positions as a possible hedge against market movement which 
may adversely affect the portfolio.  The Advisor may recommend selling positions for reasons that 
include, but are not limited to, harvesting capital gains or losses, business or 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 client, or any risk deemed unacceptable for the client’s risk 
tolerance.   
Selection of Other Money Managers 
ATON may recommend and refer clients to unaffiliated money managers or investment advisors 
through Managed Account programs sponsored by a third-party provider. In these arrangements, 
the  client  will  then  enter  into  a  program  and  investment  advisory  agreement  with  the  program 
sponsor and third-party money managers. ATON will assist and advise the client in establishing 
investment objectives for the third-party money managers and continue to provide oversight of the 
client account and ongoing monitoring of the activities of the third-party money managers. The 
third-party  money  managers  will  develop  an  investment  strategy  to  meet  those  objectives  by 
identifying appropriate investments and monitoring such investments. In consideration for such 
services, the program sponsor will charge a program fee that includes the investment advisory fee 
of the third-party money managers, the administration of the program and trading, clearance and 
settlement costs. The program sponsor will add ATON 's investment advisory fee (described below 
in Item 5) and will deduct the overall fee from the client account quarterly in arrears based on the 
fair market value at the end of the preceding quarter.  The asset-based program fee will depend on 
factors such as the size of the account, the asset class of the underlying securities and the third-
party money managers selected.   
ATON will ensure that all third-party money managers recommended to clients will be either an 
investment advisor registered with the Puerto Rico Securities Commission, the Securities and 
Exchange Commission, or exempt from such registrations.  The client, prior to entering into an 
agreement with a third-party money manager selected by ATON, will be provided with that 
manager’s Brochure.  In addition, ATON and its client will agree
                                        
                                        
                                             in writing that the client’s 
account will be managed by that selected third party money manager on a discretionary basis. 
Financial Planning 
In addition to investment supervisory services, ATON may provide Financial Planning Services 
to some of its clients.  The Advisor’s Financial Planning services may include recommendations 
for  portfolio  customization  based  on  their  client’s  investment  objectives,  goals  and  financial 
situation.  Financial Planning Services may also include recommendations relating to investment 
strategies as well as tailored investment advice, and estate planning services.   
 
Qualified Retirement Plan Consulting Services 
ATON will evaluate the Plan and its operation including its:  Trustee, custodial and recordkeeping 
arrangement; design; fiduciary compliance program; costs and fees associated with investments 
and  service  providers;  required  and  elective  contributions;  employee  communication  and 
education program, and; investment selection and monitoring process, including its investment 
policy statement, hereinafter referred to as the “IPS”.  With regard to the IPS, the Advisor will 
assist the Plan Sponsor in adopting a suitable IPS, amending it from time to time, and will provide 
information and recommendations, consistent with the IPS, to aid the Plan Sponsor in selecting 
and monitoring investments offered to Participants in the Plan.  Information and recommendations 
will be based on data as of the end of each calendar quarter.  Within a reasonable period of time 
following each calendar quarter, the Advisor will provide the Plan Sponsor with a written report 
detailing, at a minimum, all costs and fees associated with investments and operation of the Plan, 
and information and recommendations, consistent with the IPS, for the Plan Sponsor's selection, 
removal and replacement of investments offered to Participants in the Plan.  The Advisor’s asset 
management fee (described below in Item 5) will be calculated based on assets in the Plan at the 
end of the quarter, added to the Plan Administrator’s fee, and charged to the Plan by the Plan 
Administrator in accordance with the agreement between the Plan Sponsor and the Administrator.  
The Administrator will remit the Advisor’s portion of the fee to the Advisor. 
The Advisor's roles and actions in fulfilling all responsibilities pertaining to this Agreement shall 
not include those of the Plan's Trustee, and will be performed solely at the direction of the Plan 
Sponsor, its authorized officers, employees and/or agents.  At no time will the Advisor accept, 
maintain possession of, or have custodial responsibility for, the Plan's assets.  The Advisor will 
not conduct or effect the purchase or sale of any assets of the Plan on behalf of the Plan Sponsor 
or Plan Participants.  The Advisor will not advise, in any manner, any Participant, person or entity 
related to the Plan other than the Plan Sponsor.  Communicational and educational activities in 
which the Advisor engages related to Participants in the Plan shall be solely at the direction of the 
Plan Sponsor, and shall not be represented by the Advisor or Plan Sponsor as investment, tax or 
legal advice.  The Advisor is not licensed to provide, shall not provide, nor be construed to provide, 
the services of an attorney or accountant. 
ATON  will  tailor  its  advisory  services  to  its  client’s  individual  needs  based  on  meetings  and 
conversations with the client.  If clients wish to impose certain restrictions on investing in certain 
securities or types of securities, the Advisor will address those restrictions with the client to have 
a clear understanding of the client’s requirements.    
ATON does not provide portfolio management services to wrap fee programs.   
As of February 15, 2023, ATON had the following client assets under management: 
Discretionary   $296,668,000 
Non-discretionary     132,212,000 
Total $428,880,000