Atomic Invest LLC (“Atomic” or the “Adviser”) is a limited liability company based on New York, NY,
incorporated under the laws of the state of Delaware on February 9, 2021, and is a registered investment
adviser with the SEC. AtomicVest Inc. and Atomic Group LLC each own 50% of Atomic.
Types of Advisory Services and Investments
Atomic uses proprietary algorithmic-based technology to provide discretionary asset management
services to its clients utilizing the internet, through an online platform and mobile phone application. In
certain cases, Atomic may act as a sub-adviser to a third-party investment adviser. Atomic also provides
non-discretionary investment advisory services to certain clients, as described below.
Atomic provides Discretionary Portfolio Management over the internet through an online platform and
mobile application. Atomic tailors its Discretionary Portfolio Management to clients by generating a
recommended portfolio based on client responses to a suitability questionnaire ranging from conservative to
aggressive investment strategies. Atomic manages portfolios based on its algorithmic analysis of the
information provided by clients unless a client elects to override Atomic’s recommendation or otherwise
customizes the portfolio.
Atomic’s Discretionary Portfolio Management service includes the discretion to buy and sell securities on
behalf of its clients. There is no minimum account balance required, and Atomic will monitor your
portfolios on a periodic basis using its proprietary algorithms. Atomic may trade on behalf of clients in
accordance with a client’s risk tolerance or other information provided in the Questionnaire (as defined
below), and Atomic will periodically rebalance account positions to align with a client’s targeted allocations
and risk levels. Clients may choose to impose certain restrictions on their account, such as
environmental, social or governance related restrictions, or individual security restrictions, which may
be provided at account opening or at any time thereafter at no additional cost. These restrictions
may be accepted or rejected as reasonably determined by Atomic in its sole discretion. However,
you should be aware that accounts with restrictions imposed may perform differently, sometimes
materially, than other accounts using the same or a similar strategy.
The Adviser utilizes its online interface to collect client investment criteria and other information
through a questionnaire (the “Questionnaire”), including but not limited to information regarding a client’s
financial situation, goals, objectives, and risk tolerance, to determine a suitable investment strategy
within the Adviser’s model portfolio offerings. The Adviser’s algorithmic-based technology analyzes
a client’s responses to the Questionnaire to recommend a portfolio of equities, bonds and/or
mutual funds/exchange traded funds (collectively, “Funds”) that are determined to be suitable based on
the client’s targeted risk profile and other financial objectives. The model portfolio recommendation is
solely based on client responses to the Questionnaire.
The client has the option to override the Adviser’s model portfolio recommendation and choose one of
the other model portfolios offered by the Adviser. In addition, at any time, a client may also choose
between the model portfolios recommended by Atomic, or, within reasonable limitations, customize the
recommended portfolio by increasing or decreasing exposure to a particular industry. These actions may
initiate an adjustment in the client’s holdings. For more information on the types of model portfolios
offered by Atomic, please see Item 8, Investment Strategies.
Clients may update their risk profile at any time by updating the responses to the Questionnaire, which
can be accessed through Atomic’s online platform or through the mobile phone application. At a
minimum, a client will be prompted to review and/or update the responses to the Questionnaire, including
new or existing client-imposed investment restrictions, annually. Client assets are used to purchase the
securities that align to the client’s corresponding target asset allocation within the recommended
portfolio or client-selected portfolio. As a client deposits or withdraws funds from his or her account,
purchases and/or sales of securities are initiated to rebalance the account in line with its target allocation.
Atomic’s algorithms will also rebalance a client’s Account if the investment allocations deviate from the
model portfolio in excess of certain thresholds established by Atomic or as otherwise specified by the
client. The Adviser will seek to execute any rebalancing transactions promptly, however each
account is managed in accordance with the proprietary algorithmic-based technology, which analyzes
the trading markets to optimize the timing of trades. Atomic will utilize its discretion in determining the
timing of any purchases, sales, or reallocations.
In addition, Atomic reserves the right, at any time and without notice, to delay or manage trading in
response to market instability. Atomic delays or manages trading when it determines it is appropriate to
respond to extraordinary circumstances of market instability, as evidenced by extreme instances of
elevated localized volatility (i.e., minute-to-minute spikes in implied volatility), insufficient or unstable
market depth, price dislocation, incomplete execution, fast markets, and rapidly widening bid-ask
spreads. In the event that Atomic delays placing orders in response to extraordinary market volatility for
greater than sixty consecutive minutes during Atomic's typical trading hours, Atomic will seek to provide
clients with notice of such delay. For the avoidance of doubt, Atomic does not delay or manage trading
based on any view about whether markets are likely to rise or fall.
Subject to each client’s agreement with the Adviser (the “Investment Advisory Agreement”), client assets will
be invested in equities and fixed income securities and unaffiliated exchange traded funds (“ETFs”), as
applicable to the selected model portfolio or client customized portfolio. After the initial client
investment, a client may choose to participate in the Smart Contributions Services. As a participant in
Smart Contributions Services, a client will authorize the Adviser, through its proprietary algorithmic-based
technology, to analyze the client’s bank account transactions for excess cash and the Adviser will make
recommendations to the client for amounts to be invested initially and periodically, subject to the client’s
approval. A client may disable the Smart Contribution Service at any time upon one (1) business day
notice to Atomic through the online platform or the mobile phone application, however any transactions
in progress will be completed and cannot be revoked. Atomic will rely on information from the client’s
third-party banking institution. If inaccurate information is provided to Atomic by a third-party banking
institution, such as an incorrect bank account balance amount, this could cause Atomic to over or under
withdraw amounts from a client’s bank account. If Atomic overdraws from a client’s bank account, the
client may incur overdraft fees from the third-party banking institution. This also could result in market
exposure that is greater or less than the client’s desired investment exposure in the account. Moreover,
the timing of such transactions will also depend on the speed in which such third-party banking
institutions process such transfers.
Clients are given the opportunity to modify their recommended or individually-selected portfolio in a
number of different ways. First, a client may customize his or her portfolio as described above. Second,
clients can choose to have the Adviser apply Environmental, Social or Governance (“ESG”) considerations
when building their portfolio. The Adviser will implement the ESG overlay while maintaining the client’s
target risk profile and will seek to
substitute or increase allocations to companies that have certain
environmental and social characteristics while avoiding investments in other businesses based on the
stated ESG criteria. The strategies will provide clients with the ability to select certain ESG screens that
will be applied to the client’s portfolio. ESG screens may be selected upon account opening or any time
thereafter for no additional charge by providing an election to Atomic through the online platform
and selecting the desired ESG screens. Clients who choose to apply any ESG screens to their portfolio may
perform differently than portfolios within the same risk profile that have not applied the ESG screens. Once
the portfolio of stocks, bonds and/or Funds is determined based on the Questionnaire and client
preferences, and modifications, the Adviser’s algorithms will manage each client’s portfolio seeking
to track their target risk allocation.
Although the client will be contacted at least annually to do so, it is the client’s responsibility to
update the Questionnaire through the online platform or the mobile phone application when a
change is desired and/or the restriction(s) is (are) no longer wanted by the client.
Atomic also offers investment management services for corporate treasury management. Atomic may
provide this service to its corporate clients on a discretionary or non-discretionary basis. For any non-
discretionary arrangements, Atomic will need to obtain the client’s approval prior to executing any
transactions on behalf of your account. The client may decline to implement any advice provided by
Atomic on a non-discretionary basis. The minimum account balance for this service is negotiable, as are
the aggregate asset-based fees.
Atomic also provides tax-loss harvesting services to clients. Tax-loss harvesting is a technique designed to
help lower a client’s taxes while maintaining the expected risk and return profile of the client’s portfolio.
It harvests unrecognized investment losses to offset taxes due on the account’s other gains and income
by selling a security at a loss to accelerate the realization of capital loss and investing the proceeds in a
security with closely correlated risk and return characteristics. The realized loss can be applied to lower
your tax liability and the tax savings can be reinvested to grow the value of your portfolio. Tax-loss
harvesting is available to all clients who choose our recommended portfolios. It is also available to clients
who customize our recommended portfolios.
Clients should understand that Atomic has discretion to limit or postpone tax-loss harvesting to prioritize
other trading activity on any given day, including days where extreme market conditions may produce
higher price volatility or higher trading volumes. The tax-loss harvesting algorithm is designed to reduce
the potential for wash sales but does not constitute or provide comprehensive tax advice to clients.
Clients are solely responsible for the determination of whether, and when, to enable these features in
their accounts, as well as any tax consequences arising from any transaction associated with these
features. In providing the tax loss harvesting service, Atomic will use information on your income if
provided or a default tax rate, which will be 22% for short-term and 15% for long-term capital gains.
This tax rate may or may not correspond to a client’s individual tax rate. Clients are encouraged to consult
with their own tax advisors prior to enabling this feature, and for ongoing tax-related advice.
Atomic does not provide: (i) comprehensive financial planning services, and its services are not a complete
investment program as they do not take all of a client’s financial and other considerations into account
when recommending a model portfolio; rather Atomic’s recommendations are limited based on the
information provided by the client through the Questionnaire and algorithmic analysis of any cash flows
in linked bank accounts, where applicable; (ii) tax, accounting or legal advice; or (iii) custody of your
account assets. You are encouraged to consider additional asset classes, strategies, and investments to
supplement the investments maintained in your account and to consult with your tax advisor regarding
any tax consequences related to your account.
Wrap Fee Program
The discretionary investment management services are offered through a wrap fee program (the “Atomic
Wrap Fee Program”) described herein and the Adviser’s wrap fee program brochure (the “Wrap Fee
Program Brochure”). The Adviser is the sponsor and portfolio manager for the Atomic Wrap Fee Program.
As described above, Atomic uses its proprietary algorithms to evaluate a client’s risk profile to recommend
a model portfolio that is designed to meet the client’s investment objectives and risk tolerance. Client
accounts will be managed in accordance with that client’s selected model portfolio or customized
portfolio. Atomic will use its algorithms to monitor client account performance on an ongoing basis and
periodically rebalance each portfolio as required by changes in market conditions, additions, or
withdrawals in a client’s account and/or a change in a client’s financial circumstances.
In general, wrap fee programs allow clients to pay a single fee (the “Wrap Fee”) which covers advisory
fees, trading commissions, fees for brokerage and other administrative and advisory services provided by
an investment adviser or the custodian. Atomic retains a portion of the Wrap Fee for its investment
advisory services. Clients are generally not charged separate fees for each component of the total
services. Clients will be responsible for certain transaction execution fees and costs in addition to the
Wrap Fee. See Item 12: Brokerage Practices and the Wrap Fee Brochure for more information.
Because wrap fee program advisers typically absorb client transaction fees, an incentive exists to limit
trading activities in the wrap fee account. Depending on the Wrap Fee Program account, clients may pay
more or less for using a wrap fee program than they would for using non- wrap fee program services.
Clients will be required to open a custody account with Pershing LLC ( “Pershing” or the “Custodian”) who
will serve as the “qualified custodian” for all Atomic client advisory accounts. Through the Investment
Advisory Agreement, clients will authorize Atomic to open an account with Pershing. Pershing, an SEC-
registered broker-dealer and a member of the Financial Industry Regulatory Authority (“FINRA”) and
the Securities Investor Protection Corporation (“SIPC”), provides custody, clearing, and settlement
services for clients, as well as other support services for the Atomic Wrap Fee Program. The Investment
Advisory Agreement will set forth the terms and conditions of the services provided and the inclusion of
the client’s account in the Atomic Wrap Fee Program. When clients enter into an Investment Advisory
Agreement with Atomic, the client grants Atomic discretionary authority to manage his or her
account under the Atomic Wrap Fee Program. Discretionary authorization allows Atomic to
determine the specific securities and the amount of securities to be purchased or sold for the account
without a client’s approval prior to each transaction. Pershing will exercise no discretion in determining if
and when trades are placed. Discretionary authority is granted by the Investment Advisory Agreement
and the appropriate trading authorization forms. Clients may limit Atomic’s discretionary authority (for
example, limiting the types of securities that can be purchased or sold for their account) by updating their
profile by accessing their account online or through the mobile phone application.
Assets Under Management
As of December 31, 2023, the Adviser managed approximately $1,528,450,936 in Regulatory
Assets Under Management (“RAUM”) on a discretionary basis and approximately $7,890,000 in RAUM
on a non- discretionary basis.