ATLAS PRIVATE WEALTH MANAGEMENT, LLC Atlas Private Wealth Management, LLC (“Atlas”), previously known as Dion Money Management Inc., was founded in 1995. Atlas provides wealth management services, as well as investment management, and retirement planning services. Additionally, Atlas provides financial counseling services to employees of organizations including independent schools, offers 3(21) fiduciary and non-fiduciary services to participant-directed employee retirement benefit plans, and provides business consulting services. We offer investment management services primarily with respect to mutual fund and ETF portfolios, which generally invest in mutual funds and exchange-traded funds (“ETFs”) (or other investments such as equity or debt securities or cryptocurrency related investments when appropriate), and individually managed accounts, which generally invest in a broader range of securities. Where appropriate, we engage unaffiliated third-party managers to provide portfolio management services to clients via separately managed accounts. Further information about this service is available in Item 5. Previously, Atlas offered a mutual fund asset allocation service, Investment RE-Allocation Service (“REAL”), for smaller, tax-deferred accounts (e.g., IRAs and 403(b)s) and accounts holding annuities. Atlas no longer offers this service option to new accounts, but continues to manage legacy accounts that were established prior to discontinuation of Atlas’ offering the REAL service. FOCUS FINANCIAL PARTNERS, LLC Atlas is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Atlas is a wholly-owned subsidiary of Connectus Group, LLC, which is a wholly-owned subsidiary of Focus Operating, LLC (“Focus Operating”), which is, directly and indirectly, a wholly-owned subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because Atlas is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Atlas. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers, and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting, and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. INVESTMENT ADVISORY SERVICES Atlas provides investment advisory and wealth management services based on the individual needs of the client as well as the client’s financial profile. Atlas meets with the client to review the client’s financial situation, which may include a review of assets and liabilities, cash flow, taxes, anticipated short-term events, risk management, and estate structures. Through these personal discussions, Atlas documents the client’s investment goals and objectives, develops the client's personal profile, and manages the portfolio based on that profile. Atlas manages advisory accounts on a discretionary, fee-only basis. A client may impose reasonable restrictions on securities held in their accounts. If a client informs Atlas that they do not want to purchase or sell specific securities, Atlas will generally restrict trading in the client’s account so that the restricted securities are not purchased or sold. See Item 16 - Investment Discretion for additional information. Atlas implements investment advice on behalf of clients in certain held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). The order management system that we use for held-away accounts is provided by Pontera Solutions, Inc. We review, monitor, and manage these held-away accounts in an integrated way with client accounts held at our primary custodians. Further information about this service is available in Item 5. Atlas serves as the investment adviser with respect to certain donor-advised funds described in Internal Revenue Code Section 4966(d)(2), giving vehicles whereby donors make tax deductible, irrevocable charitable contributions of assets to a donor-advised fund sponsoring organization (“DAF Sponsor”), and the donor has certain input with respect to distributions from and investments within the donor-advised fund. FIDUCIARY SERVICES Atlas also offers fiduciary and non-discretionary advisory services (“3(21) Fiduciary Services”) to certain participant-directed employee retirement benefit plans. Atlas acts as a 3(21) fiduciary as defined in the Employee Retirement Income Security Act (“ERISA”). As such, Atlas assists the plan sponsor in selecting, reviewing, and evaluating the performance of an investment manager, and meets with the plan sponsor periodically to discuss that investment manager’s performance and retention. Atlas will also meet with the plan sponsor periodically to review and discuss investment reports. Additionally, Atlas also provides non-fiduciary services to the plan sponsor, including educating the plan sponsor on its fiduciary responsibilities; assisting the plan sponsor in monitoring, selecting, and supervising service vendors (and coordinating the transition process should the plan sponsor determine to replace a vendor); and assisting

in the group enrollment meetings for the purpose of increasing both plan participation by the plan sponsor’s employees and investment and financial understanding by the plan sponsor’s employees. Atlas will also assist in the education of plan participants and provide guidance about general investment principles and the investment alternatives under the plan. Plan sponsors who engage us for services to participant-directed retirement plans will enter into an investment advisory and management agreement among the plan sponsor, Atlas, and Buckingham Strategic Partners, LLC (“BSP”), an Atlas affiliate. Atlas, like BSP, is an indirect wholly-owned subsidiary of Focus LLC and is therefore under common control with BSP. Under this arrangement, BSP will provide services as the 3(38) investment manager, including discretionary investment management services. BSP will exercise discretionary authority to select in accordance with the plan’s goals and objectives those plan investments to be made available to plan participants. Atlas is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plans and ERISA plan participants. Atlas is also a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, Atlas is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a “PTE”). As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. FINANCIAL COUNSELING SERVICES Atlas offers financial counsel for organizations including independent schools, whereby the organizations engage Atlas to provide financial counseling to those of its employees who elect to participate. Depending on the employee, financial counseling sessions may not involve a review of a financial plan or a discussion of investments. A review will typically consist of a written report presented to the participating employee within a short period of time after the consultation session has concluded. Those participants who are interested in more substantial reviews may enter into individual financial planning agreements with Connectus at any time. The client is under no obligation to act upon any of Atlas’ financial counseling recommendations. Should the client determine to adopt any or all of Atlas’ recommendations, the client will be responsible for their implementation. Atlas does not serve as an attorney, accountant, or insurance agency, and no portion of Atlas’ services should be construed as legal or accounting services. Accordingly, Atlas neither prepares trust or estate planning documents, nor sells insurance products. To the extent requested by a client, Atlas may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, or insurance agents, etc.). Clients are under no obligation to engage the services of any recommended professional. If the client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged professional(s) (i.e., attorney, accountant, or insurance agent, etc.), and not Atlas, shall be responsible for the quality and competence of those services provided. OTHER SERVICES We help our clients obtain financial planning and/or tax planning and preparation services by introducing clients to our affiliate, Connectus Wealth, LLC (“Connectus”) d/b/a Connectus Financial Counseling and Connectus Accountants, respectively. Connectus, like Atlas, is a wholly-owned subsidiary of Connectus Group, LLC, which is a wholly-owned subsidiary of Focus Operating, LLC (“Focus Operating”), which is, directly and indirectly, a wholly-owned subsidiary of Focus LLC. Please see Items 5 and 10 for a fuller discussion of these services and other important information. We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. We help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly- owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of this service and other important information. AMOUNT OF CLIENT ASSETS MANAGED As of December 31, 2023, Atlas managed $1,284,409,128 of client assets on a discretionary basis. Of these assets, $28,386,552 are REAL account assets. While REAL accounts are managed on a discretionary basis, they are not categorized as “regulatory assets under management” as they are reviewed and adjusted on a periodic basis.