A. Firm Information Atrato Asset Management LLC (“AAM” or the “Advisor”) is a registered investment advisor with the State of Washington. AAM is organized as a Limited Liability Company (“LLC”) under the laws of the State of Delaware. AAM was founded in August 2009 and is primarily owned and operated by James M. Tallent (“Manager and Chief Compliance Officer”). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by AAM. B. Advisory Services Offered AAM offers discretionary and non-discretionary investment advisory services to wealth family groups, individuals and high net worth individuals (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. AAM’s fiduciary commitment is further described in the Advisor’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. General Information on Advisory Services AAM does not represent, warrant or imply that the services it provides or the methods of analysis it uses can or will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses due to market corrections. The agreement that AAM enters into with its Clients states that AAM is not liable to the Client for: (a) any loss that the client may suffer by reason of any investment decision made or other action taken or omitted by AAM, except in the case of AAM's negligence, intentional misconduct or bad faith; (b) any loss arising from AAM's adherence to the Client's instructions; or (c) any act or failure to act by any Custodian or broker. However, nothing in the agreements with Clients constitutes a waiver by the Clients of any legal right under applicable federal or state securities laws or any other law whose applicability is not permitted to be contractually waived. In the event of any discrepancy or conflict between the information in this brochure and a Client's agreement with AAM, the Client agreement will control. As part of AAM's advisory services, AAM assists its Clients in developing appropriate asset allocation objectives. However, due to volatile market conditions, and the resulting changes in asset values, the values of Client assets may become inconsistent with the Client's desired asset allocation objectives. When AAM considers it appropriate, AAM will rebalance the Client's portfolio, or recommend changes to rebalance the portfolio. This is likely to result in additional trading costs for Clients. Investment Management Services AAM provides investment supervisory and investment management services to its Clients, sometimes on a discretionary basis or for most Clients on a non-discretionary basis. In the non-discretionary role, AAM makes recommendations to its Clients that require Client approval for implementation. AAM does not have discretion over these Client assets, and all investment decisions must be approved by the Client before execution. When retained on a discretionary basis, AAM makes investment decisions, including retaining and dismissing investment managers, on behalf of a Client consistent with the Client’s objectives and suitability, without the Client’s prior approval of specific transactions. Whether serving in a discretionary or non-discretionary capacity, AAM assists its Clients in reviewing, developing and implementing investment policies and strategies, determining appropriate asset allocations (both strategic and tactical), structuring portfolios, making investments to implement each Client's investment policies and allocations, and measuring the performance of the client's investments. AAM's investment decisions on behalf of a discretionary Client, and AAM's investment recommendations to a non-discretionary Client, relate to:
• The retention and termination of investment managers
• Investments in limited partnerships and limited liability company investment funds and other investment vehicles (such as, real estate funds, venture capital funds and private equity funds)
• Investments in other specific securities AAM will provide investment advisory services and related services. At no time will AAM accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. For additional information, please see Item 12 – Brokerage Practices and 15 - Custody. AAM clients invest in virtually all types of securities, including but not limited to:
• Certificates of Deposit
• Commercial paper
• Corporate debt securities
• Exchange-traded funds
• Exchange-listed securities
• Foreign issuers
• Future contracts on tangibles and intangibles
• Municipal securities
• Mutual fund shares
• Options contracts on securities and commodities
• Private placements of securities (limited partnerships and limited liability company investment funds)
• Real estate investments
• Securities traded over-the counter
• U.S. Government securities
• Variable life insurance Warrants When Client assets are invested with unaffiliated investment manager[s], the unaffiliated investment manager[s] (and not AAM) recommend and effect investment decisions

for the Client with respect to individual equity and fixed-income securities and other investments. AAM provide investment oversight of the overall account[s], but not the individual security selection and trading. AAM is the non-discretionary investment adviser to two limited liability companies (the "LLCs") that were each created to manage the personal funds of a specific individual. A trust formed by that individual, AAM and Mr. Tallent are the only members of each LLC. The LLCs make real estate, securities and other investments. Each LLC has an independent Manager who determines whether or not to retain AAM as the LLC's investment adviser. AAM receives a management fee and performance allocation for its advisory services provided by the LLCs. Neither of the LLCs is open to other investors. See Item 6 for a discussion of the performance allocation AAM receives from these LLCs. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers AAM will recommend to Clients that all or a portion of their portfolio be implemented by utilizing one or more unaffiliated money managers participating in a managed accounts program at the Client's selected custodian (the “Program Sponsor”). The Client will then enter into a program and investment advisory agreement with the Program Sponsor and the participating money manager[s]. The Advisor will assist and advise the Client in establishing investment objectives for the account[s], the selection of the money manager[s], and defining any restrictions on the account[s]. AAM will continue to provide oversight of the Client account and ongoing monitoring of the activities of the unaffiliated money managers. These 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 money managers, the administration of the program and trading, clearance and settlement costs. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A – Disclosure Brochure (or a brochure that makes the appropriate disclosures). AAM does not receive any compensation from these unaffiliated money managers or the Program Sponsor, other than AAM’s investment advisory fee (described in Item 5). The Client, prior to entering into an agreement with a Program Sponsor, will be provided with the Program Sponsor's Form ADV Part 2 (or a brochure that makes the appropriate disclosures). In addition, AAM and its Client will agree in writing that that selected Program Sponsor will manage the Client's account[s] on a discretionary basis. Family Office Services AAM also provides its Clients of wealthy families a range of services that address their complex financial needs. Some of the services they provide but not limited to are; planning for retirement, education planning, personal insurance analysis, estate planning review, business succession planning, balance sheet preparation, tax planning, charitable planning and private business management consulting. C. Client Account Management Prior to engaging AAM to provide investment advisory services, each Client is required to enter into an advisory agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Policy Statement – AAM, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – AAM 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.
• Portfolio Construction – AAM will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client that may include allocations to third-party managers.
• Investment Management and Supervision – AAM will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs AAM does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by AAM. E. Assets Under Management As of December 31, 2023, AAM manages $82,956,198 in Client assets, all of which are managed on a non- discretionary basis. Clients may request more current information at any time by contacting the Advisor.