SERVICES, FEES, AND COMPENSATION DESCRIPTION OF SERVICES In 2016, Atlas Private Wealth Advisors, LLC (“Atlas PWA”) became an SEC registered investment advisor to directly offer asset management and financial planning services, while using LPL Financial as the qualified custodian for advisory assets. Atlas PWA is equally owned by Juan (Tony) Mayo, Managing Member and Vladislav Krubich, Managing Member and Chief Compliance Officer. The Atlas Private Wealth Advisors Wrap Program (the “Program”) is an investment advisory program sponsored by Atlas PWA. The Program provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. As of December 31, 2023, the firm has 548,357,443 in discretionary assets under management and $9,322,888 in non-discretionary assets under management. To join the Program a person must:
• Complete an investor profile that describes the client’s financial needs, investment objectives, time horizon, and risk tolerance, as well as any other factors relevant to the client’s specific financial situation (the “Investor Profile”) and any other supporting documentation required for the Program;
• Complete the investment advisory wrap fee agreement (the “Program Agreement”) with the Atlas PWA and become a client of the Program;
• Complete a new account agreement with LPL Financial (“LPL”) or another broker dealer approved by Atlas PWA for participation in the Program (“Broker-Dealer”); and
• Open a securities brokerage account with LPL or the Broker-Dealer (an “Account”) and deposit those client assets designated for participation in the Program (“Program Assets”) into the Account. After an analysis of any information provided by the client to Atlas PWA, Atlas PWA shall assist the client in developing an appropriate investment strategy for the Program Assets in their Account(s) (the “Investment Strategy”). Thereafter, all clients are encouraged to discuss their needs, goals, and objectives with Atlas PWA and to keep Atlas PWA informed of any changes thereto. Atlas PWA shall contact clients at least annually to review its previous services and/or recommendations and to determine whether changes should be made to their Investment Strategy. MANAGEMENT OF YOUR PORTFOLIO All clients in the Program shall grant Atlas PWA discretionary authority to buy, sell, and otherwise trade in the type of securities described in Item 6 (below) for their Account(s) and to liquidate previously purchased securities that the client has transferred to their Account(s). Program Assets in the client’s Account(s) shall be managed by one of Atlas PWA’s investment adviser representatives. Neither Atlas PWA nor the client may assign the Program Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of Atlas PWA shall not be considered an assignment. FEES FOR PARTICIPATION IN THE PROGRAM o Clients in the Program pay a single annualized fee for participation in the Program (the “Program Fee”). Atlas PWA shall charge an annual fee based upon a percentage of the market value of the assets being managed by Atlas PWA. Atlas PWA’s annual fee shall be prorated and charged quarterly, in advance, based upon the market value of the assets being managed by Atlas PWA on the last day of the previous quarter. The annual fee shall vary and will

be described in the executed advisory agreement. The maximum advisory fee Atlas charges for this service is 2%. Atlas PWA, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, pro bono activities, etc.). At its discretion, Atlas PWA may also waive investment advisory fees for accounts including those of employees and their relatives. As the portfolio manager and Sponsor to the Program, Atlas PWA receives the annual fee less transaction charges which are paid to LPL Financial. This arrangement creates an incentive for the Atlas PWA to limit trading in the client account to reduce costs to Atlas PWA. Atlas PWA has policies and procedures to ensure that all accounts are monitored on an ongoing basis and rebalanced as needed. Under the Program, clients receive both investment advisory services and the execution of transactions in securities for a single, combined annualized fee, the Program Fee. Participation in the Program may cost the client more or less than purchasing such services separately. The number of transactions made in the client’s Account(s), as well as the commissions charged for each transaction, will determine the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. The Program Fee may be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Clients may incur certain charges imposed by third parties in addition to the Program Fee such charges imposed directly by a mutual fund or exchange traded fund in the account, which shall be disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions FEES FOR MANAGEMENT DURING PARTIAL QUARTERS OF SERVICE For the initial period of participation in the Program, the Program Fee shall be calculated on a pro rata basis. The Program Agreement between Atlas PWA and the client will continue in effect until terminated by either party pursuant to the terms of the Program Agreement. The Program Fee shall be prorated through the date of termination and any remaining balance shall be refunded to the client in a timely manner. If assets are deposited into or withdrawn from an account after the inception of a quarter, the Program Fee with respect to such assets will be prorated based on the number of days remaining in the quarter. Atlas PWA and its investment advisory representative receive compensation as a result of clients’ participation in the Program. Atlas PWA also engages third party solicitors who receive compensation for recommending the Program to clients. The amount of compensation received may be more than what the person would receive if the client participated in Atlas PWA’s other programs. Therefore, the person recommending the Program may have a financial incentive to recommend the wrap fee program over other programs. Atlas PWA and its investment advisory representatives have a fiduciary duty to all clients and review the suitability of the Program based on the client’s investment objectives.