Atlas Brown, Inc. (“Atlas Brown” or the “Firm”) was formed in December 2004 by a group of Louisville, Kentucky investment professionals and is an investment adviser providing Family Wealth Management. Our investment management solutions combined with our suite of Family Office Services are offered primarily to individuals and their families, including high net-worth individuals, retirement plans, trusts, estates, charitable organizations, and corporations. Our mission is to provide individuals and families with thoughtful, independent, and comprehensive advice combined with exceptional services. Our client relationships are grounded in a complete and thorough understanding of each family’s complex needs, desires, and objectives. This focus on all aspects of a family’s needs, both financial and otherwise, is what sets us apart from other wealth management firms. As of December 31, 2023: Discretionary Assets under Management: $ 441,729,959 Non-Discretionary Assets under Management: $ 13,483,230 Total: $ 455,213,189 Investment Management Services Atlas Brown’s primary investment management services consist of allocating its clients’ investment management assets, on a discretionary basis, among individual debt and equity securities, options, mutual funds, and/or exchange traded funds in accordance with clients’ investment objectives. Atlas Brown may also recommend that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities, which may include debt, equity, and/or pooled investment vehicles when consistent with such client’s investment objectives. The majority of Atlas Brown’s clients have authorized the Firm to determine, without specific consent, the broker-dealer to be utilized for client trading activity. However, Atlas Brown also emphasizes the unrestricted right of the client to direct all transactions to any broker-dealer he or she wishes. Atlas Brown also renders non-discretionary investment advisory services on a limited basis. Atlas Brown does not place trades in a non-discretionary account without first obtaining and documenting specific client consent to the transaction. There are no exceptions to this policy. As of December 31, 2023, Fidelity serves as Atlas Brown’s primary custodian and US Bank serves as its primary trust custodian. Other custodians may be used in limited circumstances at the specific direction of our clients. Prior to engaging Atlas Brown to provide investment management services, new clients are required to enter into a Discretionary Investment Management Agreement or a Non-Discretionary Investment Advisory Agreement with Atlas Brown setting forth the terms and conditions under which the Firm shall provide its services to such clients. Clients are advised to promptly notify Atlas Brown in writing if there are any changes in their financial situation or investment objectives or if they wish to impose any restrictions upon the management services being provided. Atlas Brown allows clients to place restrictions or prohibitions on the activities and holdings in their portfolios; however, the Firm reserves the right to refuse to accept any client account if the restrictions are too restrictive for the account to be managed properly. Additions may be in cash or securities provided that Atlas Brown reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Atlas Brown will consult with its clients about the options and ramifications of transferring securities but will not provide any tax advice with respect thereto. Clients should keep in mind at all times that when transferred securities are liquidated, they are typically subject to transaction fees, fees assessed at the mutual fund level if applicable (e.g., contingent deferred sales charges) and/or tax consequences. Atlas Brown would not be responsible for any gains or losses incurred by clients as a result of any restrictions and/or trades directed by them. With respect to mutual fund/ETF investing, Atlas Brown engages in discussions with clients regarding their anticipated account balances and distribution needs and a good faith selection is made regarding the most cost-effective investment for them. Atlas Brown uses its best efforts to select the share class that is most appropriate for each client at the time of investment and will use its discretionary authority to exchange client shares to less expensive investment options if such products become available. Rollover to IRA Clients considering rolling over assets from a qualified employer-sponsored retirement plan (“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the advantages and disadvantages of an IRA rollover

from their Employer Plan. A plan participant leaving an employer typically has four options (and may engage in a combination of these options): (1) Leave the money in the former employer’s plan, if permitted; (2) Rollover the assets to a new employer’s plan (if available and rollovers are permitted); (3) Rollover Employer Plan assets to an IRA; or, (4) Cash out the Employer Plan assets and pay the required taxes on the distribution. At a minimum, clients should consider fees and expenses, investment options, services, penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and employer stock. Atlas Brown encourages you to discuss your options and review the above listed considerations with an accountant, third-party administrator, investment advisor to your Employer Plan (if available), or legal counsel, to the extent you consider necessary. By recommending that you rollover your Employer Plan assets to an IRA, Atlas Brown and your financial advisor may earn fees based on the terms of your management agreement. In contrast, leaving assets in your Employer Plan or rolling the assets to a plan sponsored by your new employer likely results in little or no compensation to Atlas Brown. Atlas Brown has an economic incentive to encourage investors to rollover Employer Plan assets into an IRA managed by the Firm. Clients face increased fees when they move retirement assets from an Employer Plan to a Rollover IRA account. Even if there are no costs associated with the IRA rollover itself, there will be costs associated with account administration, investment management, or both. In addition to the fees charged by Atlas Brown, the underlying investment (mutual fund, ETF, annuity, or other investment) charges a management fee. Custodial and trading fees also apply. Investing in an IRA with Atlas Brown will typically be more expensive than an Employer Plan. IRA Rollover Recommendations For purposes of complying with the US Department of Labor (DOL)’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Additional resources about IRA Rollovers are available to investors through FINRA’s web site at www.finra.org. Family Office Services Finally, Atlas Brown provides certain clients with a broad range of comprehensive advice and services (which may include non-investment related matters) commonly referred to as “Family Office Services” based on each client’s individual needs. This suite of services includes, without limitation, one or more of the following: preparing financial plans and/or evaluations based on a client's current and anticipated financial situation, investment objectives and needs; consulting services regarding the need to establish trusts and/or annual gifting programs, and the adequacy and appropriateness of insurance coverages; coordination of pre-legal estate planning involving trusts and wills to be drafted by clients’ attorneys; retirement and estate planning; personal financial reporting; bill paying including, in very limited cases, the custody of clients funds (i.e., checking accounts); private foundation management; debt negation (which involves the irrevocable setting aside of assets for repayment of debt without the actual corresponding retirement of the debt); cash management; consulting on real property and tangible personal property identification, acquisition and management; consulting of negotiation of business transactions; and consulting on business succession oversight and coordination. This suite of Family Office Services are included in the Investment Management Services fee as described in Item 5 below.