A. Description of the Advisory Firm Atlas Wealth LLC, doing business as Gearhart & Associates (“Gearhart & Associates” or the “Firm”) is a limited liability company organized in the State of Ohio. Gearhart & Associates is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). Gearhart & Associates is majority owned by Kyle Gearhart. B. Types of Advisory Services Gearhart & Associates provides personalized discretionary and non-discretionary investment management services to individuals, including high net worth individuals, and entities, including, but not limited to, family offices, trusts, estates, private foundations, and qualified retirement plans. In addition, the Firm may provide financial planning services on a stand alone basis or as part of the investment management services provided to clients. Investment Management Services Gearhart & Associates offers investment management services on a discretionary basis and non- discretionary basis. All investment advice provided is customized to each client’s investment objectives and financial needs. The information provided by the client, together with any other information relating to the client’s overall financial circumstances, will be used by Gearhart & Associates to determine the appropriate portfolio asset allocation and investment strategy for the client. The securities utilized by Gearhart & Associates for investment in client accounts mainly consist of registered mutual funds, including closed-end funds, and exchange traded funds (ETFs), but we will also invest in equity securities, corporate bonds, REITS, Private Funds, and other illiquids, among others, if we determine such investments fit within a client’s objectives and are in the best interest of our clients. Gearhart & Associates may further recommend to clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“External Managers”). The client may be required to enter into a separate agreement with the External Manager(s), which will set forth the terms and conditions of the client’s engagement of the External Manager. Gearhart & Associates generally renders services to the client relative to the discretionary selection of External Managers. Gearhart & Associates also assists in establishing the client’s investment objectives for the assets managed by External Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated External Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are exclusive of, and in addition to, the annual advisory fee charged by Gearhart & Associates. Investment Management Services to Retirement Plans Gearhart & Associates offers discretionary and non-discretionary advisory services to qualified plans, including 401k plans. These services include, depending upon the needs of the plan client, recommending, or for discretionary clients selecting, investment options for plans to offer to participants, ongoing monitoring of a plan’s investment options, assisting plan fiduciaries in creating and/or updating the plan’s written investment

policy statements, working with plan service providers, and providing general investment education to plan participants. Financial Planning and Consulting Services Gearhart & Associates offers personal financial planning services to set forth goals, objectives and implementation strategies for clients over the long-term. Our recommendations for retirement planning, educational planning, estate planning, cash flow planning, tax planning and insurance needs and analysis will depend upon individual client requirements. Clients should notify us promptly anytime there is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the financial information initially provided to us Clients are under no obligation to implement any of the recommendations provided. However, should a client decide to proceed with the implementation of the investment recommendations then the client can either have Gearhart & Associates implement those recommendations or utilize the services of any investment adviser or broker-dealer of their choice. Gearhart & Associates cannot provide any guarantees or promises that a client’s financial goals and objectives will be met. Fiduciary Status for Retirement Plan Accounts Gearhart & Associates is a fiduciary under the Employment Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including ERISA plan participants. Gearhart & Associates is also a fiduciary under the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to ERISA plans, ERISA plan participants, individual retirement accounts and individual retirement account owners (collectively “Retirement Account Clients”). As such, Gearhart & Associates is subject to specific duties and obligations under ERISA and the IRC, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”). C. Client-Tailored Advisory Services Clients may impose reasonable restrictions on the management of their accounts if Gearhart & Associates determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Gearhart & Associates’s management efforts. D. Information Received From Clients Gearhart & Associates will not assume any responsibility for the accuracy of the information provided by clients. Gearhart & Associates is not obligated to verify any information received from a client or other professionals (e.g., attorney, accountant) designated by a client, and Gearhart & Associates is expressly authorized by the client to rely on such information provided. Under all circumstances, clients are responsible for promptly notifying Gearhart & Associates in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. E. Assets Under Management Gearhart & Associates currently has $638,216,495 in assets under management, of which $633,626,823 are discretionary, and $4,589,672 are non-discretionary.