A. Firm Information
Atlas Fiduciary Services, Inc. (“AFS” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission. The Advisor is organized as a Corporation under the laws of the State of New Hampshire.
AFS was founded in March 2022 and is owned and operated by John R. Heise (President and Chief Compliance
Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by AFS.
B. Advisory Services Offered
AFS offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and
retirement plans (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. AFS'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.
Investment Management Services
AFS provides customized investment advisory solutions for its Clients. This is achieved through continuous personal
Client contact and interaction while providing discretionary investment management and related advisory services.
AFS works closely with each Client to identify their investment goals, objectives, risk tolerance and financial situation
in order to create a portfolio strategy. AFS will then construct an investment portfolio, consisting of low-cost, diversified
mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also
utilize individual stocks or bonds to meet the needs of its Clients. The Advisor may retain certain types of investments
based on portfolio fit and/or tax considerations.
AFS’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client, due to market conditions, or trade
signals provided by third party providers. AFS will construct, implement and monitor the portfolio to ensure it meets
the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity
to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
AFS evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process primarily utilizing third party research and trade signal providers. AFS may recommend, on occasion,
redistributing investment allocations to diversify the portfolio. AFS may recommend specific positions to increase
sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against
market movement.
AFS may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or
losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting
of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
At no time will AFS accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
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
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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.
Financial Planning Services
AFS will typically provide a variety of financial planning and
consulting services to Clients, pursuant to a written
financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on
their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or
rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or
consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations
may be made that the Client start or revise their investment programs, commence or alter retirement savings,
establish education savings and/or charitable giving programs.
AFS may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation.
For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial
situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide
a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming
all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would increase
the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made
by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the
Advisor.
Retirement Plan Advisory Services
AFS provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company
(the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in
meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs
of the Plan and Plan Sponsor. Services generally include:
● Vendor Analysis
● RFP Consulting
● Board Governance Consulting
● Fiduciary Education
● Plan Design Consulting
● Plan Participant Enrollment and Education Tracking
● Investment Policy Statement (“IPS”) Design and Monitoring
● Investment Oversight Services (ERISA 3(21))
● Investment Management Services (ERISA 3(38))
● Performance Reporting
● Ongoing Investment Recommendation and Assistance
These services are provided by the Advisor serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
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Sponsor is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered
and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging AFS to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
● Establishing an Investment Strategy – AFS, in connection with the Client, will develop a strategy that seeks
to achieve the Client’s goals and objectives.
● Asset Allocation – AFS 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 – AFS will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
● Investment Management and Supervision – AFS will provide investment management and ongoing oversight
of the Client’s investment portfolio.
D. Wrap Fee Programs
AFS does not manage or place Client assets into a wrap fee program. Investment management services are provided
directly by AFS.
E. Assets Under Management
As of December 31, 2023 Atlas Fiduciary Services manages $253,644,953 in Client assets, $116,489,847 on a
discretionary basis and $137,155,106 on a non-discretionary basis. Clients may request more current information at
any time by contacting the Advisor.