Atlas is an independent, privately owned investment advisory firm that provides investment advice to individuals and institutions. Atlas has been in business since 2003 and its principal owners are Jonathan Tunney, CFA and Albert Gutierrez, CFA As part of its wealth management business, Atlas provides tax efficient, systematic investment advice to its clients under a discretionary arrangement wherein a client grants Atlas the discretion and authority to supervise, invest and trade client assets Form ADV Part 2AB: Uniform Application for Investment Adviser Registration March 2024 Page 2 placed under its management in a manner consistent with established client objectives and guidelines. All client assets are held in their own separately managed accounts and portfolio strategies are specifically tailored to each client’s needs. Each client may impose restrictions on investing in certain securities or types of securities. Such restrictions would be disclosed in the client’s Investment Policy Statement. When Atlas Capital provides investment advice to you regarding your investment accounts, including your retirement plan account or individual retirement account, we are fiduciaries within the meaning of certain state and federal laws such as the Employee Retirement Income Security Act and/or the Internal Revenue Code and the regulations of the U.S. Securities and Exchange Commission, as applicable. These regulations require us to act in your best interest and not put our interests ahead of yours. We do not manage any commingled fund vehicles or mutual funds. We do not participate in wrap-fee programs. Atlas Capital has executed a Portfolio Manager Licensing Agreement with Covestor Limited. Covestor Limited (doing business as Interactive Advisors) is an SEC-registered

investment adviser affiliated with Interactive Brokers LLC, the broker and custodian for some of our client accounts. Pursuant to that agreement, Atlas Capital provides Covestor with information regarding the trading in an IB brokerage account owned by Atlas Capital. Atlas Capital trades that account in accordance with a specific investment strategy. Based on this trading data, Covestor creates a portfolio discussed on its website, which Covestor clients may invest in, if Covestor deems it appropriate based on the client’s suitability profile. Covestor mirrors (subject to certain limits) the trading activity in Atlas Capital’s brokerage account into the accounts of investing clients using Covestor’s proprietary replication logic. Atlas Capital does not offer any investment advice to Covestor clients, have discretionary trading authority over Covestor clients’ accounts, or know the identity or suitability profile of those clients. In certain instances, at the request of clients, Atlas may agree to monitor assets held in an account (such as a trust) for which the firm has no discretionary authority. Atlas provides investment advice for the following types of investments:
• Public equities
• Fixed Income securities
• Commodities
• Currencies
• Futures
• REITS
• Exchange Traded Funds (ETFs)
• Mutual Funds (MFs)
• Private Alternative Investments Form ADV Part 2AB: Uniform Application for Investment Adviser Registration March 2024 Page 3 As of December 31st, 2023, Atlas had $904,991,000 worth of regulatory assets under management (RAUM) in its wealth management business. We offer advice to our clients on an additional $69,415,000 of assets, but these assets do not meet the test for inclusion in RAUM.