Atlas Asset Management LLC

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Atlas Asset Management LLC
CRD #173561
SEC #801-119872
CIK #
AUM 700.6 M (2025-12-18)
Employees 3 (67% Investors, 0% Brokers)
Fees
Minimum
Phone787-781-1301
AddressBuchanan Office Center 40 Carr 165
Guaynabo, PR 00968-8022
Source [IAPD] [Website]
Total AUM ($M)
80064048032016002010201520212027
Fees and Compensation — Form ADV Part 2A (12/18/2025) [Brochure]
Item 5 – Fees and Compensation

Billing Practices

Separate Managed Accounts

The fees charged for managing separate accounts will be a function of the strategy and the size
of a specific client’s account. Atlas’ annualized fees for managing a separate account will typically
range between 0.05% and 1.50% of the net assets of the account.

Atlas’ investment advisory fees are subject to negotiation with clients and are established based
on a number of factors including, but not limited to, account size and the investment strategy
employed. Fees may differ between products and in some instances in the same strategy. As an
example, Atlas may implement the same strategy to a discretionary and a non-discretionary
client, but with varying fee structures given the different costs incurred by Atlas on each client.

Atlas does not charge investment advisory fees in advance. The invoicing process for each client
is based on the fee and payment schedule outlined in the client’s investment management
agreement or contract. Depending on the negotiated schedule, it may be on a monthly or
quarterly basis. Generally, Clients may negotiate the method and mode of payment of the
advisory fee to Atlas.

The investment advisory fee is generally calculated using the average of the beginning and ending
market value statements of the client’s account for the most recent period of calculation,
monthly or quarterly. In circumstances where a client’s account with Atlas is opened less than a
full fee calculation period, Atlas’s standard investment advisory agreements state that the
advisory fee will be pro-rated for the days the account is opened.

General fee information, which is subject to negotiation, for Atlas’s current investment
strategies, are listed below. Atlas reserves the right to negotiate fees and minimum account sizes
where unique circumstances occur, and fee schedules with clients may vary from the fees listed.

Atlas’ annual fee schedule for managed accounts, when it functions as adviser, is as follows:

On amounts up to $1 Million it may range from 1.25% to 0.05% for amounts greater than $25
Million.

Mutual Fund

Atlas is the investment adviser for the Atlas U.S. Tactical Income Fund Inc., an open-end
investment company registered as of June 17, 2021, under the Investment Company Act 1940.
The fees and expenses charged to shareholders are outlined in the Fund’s prospectus. Atlas is the
investment adviser for the Atlas U.S. Government Money Market Fund Inc., an open-end
investment company registered as of August 18, 2025, under the Investment Company Act 1940.
The fees and expenses charged to shareholders are outlined in the Fund’s prospectus.

During the first two years of operations, Atlas has agreed to reduce its investment advisory fee,
and if necessary, reimburse the Fund’s expenses, in the event that total annual operating
expenses (including the investment advisory fees but excluding interest, taxes, brokerage
commissions and extraordinary expenses) for the said fiscal years of operations, exceed an
established percentage the Fund’s average weekly assets (including assets purchased with the
proceeds of leverage). Atlas may voluntarily waive or reimburse advisory fees. Reductions in the
investment advisory fee as a result of fee waivers may be recovered by Atlas within the two fiscal
years following such fee waiver, as long as Fund expenses fall below the percentage limitation.

Shareholders may pay other expenses besides investment advisory fees. Other charges indirectly
paid by shareholders include custodial, transfer agent, account maintenance and distribution
fees. Mutual funds and exchange traded funds also charge management fees. These and other
expenses are detailed in the Fund’s prospectus.

Atlas is also the interim investment adviser for the Puerto Rico Residents Tax Free Fund, Inc.,
Puerto Rico Residents Tax Free Fund VI, Inc., Tax Free Fund for Puerto Rico Residents, Inc. and
Tax-Free Fund for Puerto Rico Residents IV, Inc., non-diversified closed-end management
investment companies registered as investment companies under the Investment Company Act
1940. Pursuant to an interim investment advisory contract (the “Interim Advisory Agreement”)
and subject to the oversight of the Board, the Fund receives investment advisory services in
exchange for a fee. The investment advisory fee will not exceed 0.25% of the Fund’s average
weekly net assets (including assets purchased with the proceeds of leverage).

Additional Compensation

Atlas and its employees do not accept compensation, including sales charges or service fees, for
the sale of securities or other investment products.

Atlas provides financial advice for a fixed fee determined prior to starting the relationship.
Fees may be negotiable based on the nature and complexity of the services to be provided and
the overall relationship with the Advisor.
Account Minimums and Types of Clients — Form ADV Part 2A (12/18/2025) [Brochure]
Item 7 – Types of Clients

Atlas provides, or may provide, investment advisory services to the following types of clients:

   o   High net worth individuals
   o   Investment companies, including funds
   o   Corporations and Partnerships
   o   Pension and profit-sharing plans
   o   Charitable and Educational organizations
   o   State and municipal government entities
   o   Insurance companies
   o   Financial Intermediary

Atlas typically does not accept separate account mandates smaller than $1 million and accounts
for certain investment strategies may have a higher or lower minimum account size requirement.
Atlas reserves the right, subject to the negotiated terms of the investment advisory agreement
between Atlas and a client, to waive any minimum size requirements.
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 0 0.0
(b) Individuals (high net worth individuals) 1 13.8
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 6 387.6
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 0 0.0
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 0 0.0
(j) Other investment advisers 0 0.0
(k) Insurance companies 0 0.0
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 12 299.2
(n) Other 0 0.0
Total 19 700.6
By Discretionary
Discretionary 12 393.0
Non-Discretionary 7 307.7
Total 19 700.6
By Non-United States Persons
Non-United States Persons 0.0
United States Persons 700.6
Total 19 700.6
Firm Profile (Form ADV)
ServesInstitutional, Retail
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