Item 4A Atlantis Asset Management is a Fee-Based Investment Advisor. This means that we provide equity, fixed income, risk management and many other investment advisory and portfolio management services for a fee. This fee is an agreed upon percentage of assets under management. Our advisory business was formed in the State of New York in 2009 under the name MDC Capital, LLC and has been legally changed to Atlantis Asset Management, LLC as of May, 2012. The majority owner of Atlantis Asset Management is MDC Wealth Management LLC and the ownership and officers of the firm is outlined in the following table: FULL LEGAL NAME Title or Status Date of Title Ownership Control CRD No. / SS No. MDC WEALTH MANAGEMENT, LLC MEMBER 4/2009 100% Y 45-4597765 MICHAEL DAVIS COHN MANAGING MEMBER / CHIEF COMPLIANCE OFFICER 04/2009 N/A Y 1743568 Item 4B We provide continuous and regular account supervision to clients. Clients may request advice on all of their portfolios and investments. Each account is being held as a separate account in the investor’s (client) name at a third party custodian. As part of our portfolio management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned types of securities. Each portfolio is initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least monthly and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Atlantis Asset Management LLC – Form ADV Part 2 Page 5 Specialized investment

services a) Portfolios are team managed. The investment interacts weekly to discuss strategy, portfolio holdings and buy/sell candidates. Each team member is responsible for implementing investment policy in their respective client accounts and contributing to general investment policy by staying abreast of the dynamics impacting their designated sectors, industries and companies. b) Frequently we employ portfolio risk management techniques using derivatives. No leverage is used in the management of portfolios unless specifically requested by a client. A simple month-to-month covered call writing strategy is periodically employed in equity portfolios. Additionally, from time to time, market exposure has been reduced by purchasing puts on a broad large cap index such as the S&P 500 or the Russell 1000 indexes. At no time is the derivative strategy employed with more than 1:1 leverage unless specifically requested by the client. The strategy is employed to reduce the volatility (standard deviation) of returns. Item 4C All clients may choose whether to participate in the team managed portfolios and (or) the risk management strategy. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Item 4D Participation in wrap fee programs. We do not offer wrap fee programs. Item 4E Disclosure of the amount of client assets we manage on a discretionary basis as of December 31, 2026 We manage sixteen million two hundred thousand ($16,200,000) on a discretionary basis. Atlantis Asset Management LLC – Form ADV Part 2 Page 6 Disclosure of the amount of client assets we manage on a non-discretionary basis as of March 30, 2024 We manage no assets ($0.00) on a non-discretionary basis. Our Total Assets under Management (AUM) are sixteen million two hundred thousand ($16,200,000)