Atlas Capital Management Corp

Item 5 Fees and Compensation
Description
Atlas Capitals' compensation is solely from fees paid directly by clients. The firm does not receive
commission based on the clients' purchase of any financial product, including insurance. No
commissions in any form are accepted. No benefits are received by Atlas Capital from
custodians/broker-dealers based on client securities transactions ("soft dollar benefits") Assets under
the direct management of Atlas Capital are held by independent custodians, including Axos Advisor
Services, various insurance carriers, or others, in the client's name. Atlas offers proprietary strategies
built with its trade signals and strategies created using trade signals from independent signal providers.
This creates a financial incentive to recommend its own strategies because it does not share a portion of
its fee when recommending a proprietary strategy. Our owner and certain of our investment adviser
representatives are incentivized to select a proprietary strategy over non-proprietary strategies. Please
see their Form ADV Part 2B for more information.
Atlas Capital does not act as custodian of client assets. Since custodians do not verify the accuracy of the
advisory and custody fee calculations, clients should review each custodial statement and promptly
contact Atlas if any questions should arise. Atlas Capitals' basic fee structure is as follows:

                                 First $250,000 ............... 2.00%
                                 Next $250,000 .............. 1.75%
                                 Next $500,000 .............. 1.50%
                                 Thereafter. ................... 1.00%

Atlas Capital may enter into a consulting arrangement with selected clients where Atlas Capital will
provide non-discretionary recommendations. The client may accept, reject, or modify these
recommendations. The fee for this consulting agreement may be either a fixed annual fee, or a
negotiated percentage of the clients' account (prorated for additions and withdrawals). These fees are
charged monthly in arrears and are based on the requirement of the client and are negotiated at the
time the agreement is signed. Atlas Capital does not act as custodian of consulting assets. The
Registrant’s Chief Compliance Officer, Jerry Jacobs, or his designee, remains available to address any
questions that a client or prospective may have regarding the above consulting arrangements.

Fee Billing
For custodians that accommodate average daily balance, investment advisory fees will be calculated and
billed monthly, using average daily balances. At all other custodians where average daily balance
calculations are unavailable, fee calculations will use end of month/quarter values multiplied by the
appropriate fee structure, with deposits and withdrawals prorated accordingly.
Fees are negotiable at the sole discretion of the President of Atlas Capital. Atlas believes that the annual
fee is reasonable in relation to 1) the Management services provided and 2) the fees charged by other
investment adviser's offering similar services/programs. However, Atlas Capital's annual investment
management fee may be higher than that charged by other investment advisers offering similar
services/programs. Clients utilizing Atlas Capital as asset manager may choose to have fees deducted
quarterly/monthly in arrears from the account being managed, deducted from another designated
account at their qualified custodian, or to be invoiced quarterly/monthly. The client must consent in
Atlas Capital Management Corp.                       Page 8                   ADV Part 2A – 12.31.2025

advance to direct debiting of their investment account for management fees. Investment Management
fees for non-qualified accounts may not be deducted from qualified accounts. Accounts in the same
household may be aggregated for the purposes of determining the applicable program fee rate.

Other Fees
Atlas Capital’s management fee for assets in Mutual Fund shares, Exchange Traded Funds, Variable
Annuity, or Variable Life accounts is for active management with respect to these accounts. Atlas
Capital’s management fees for active management with respect to said accounts are separate and
distinct from and in addition to the fees and expenses charged by the Mutual Funds, Exchange Traded
Funds, Variable Annuities, or Variable Life accounts in which client’s assets are invested. A description of
such fees and expenses is available in each Mutual Fund, Variable Annuity’s, or Variable Life’s
prospectus. Clients that select the basic fee schedule are billed quarterly in arrears. The investment fee
will be a percentage of the market value of the investment account.

Custodians may charge transaction fees on the purchase or sales of certain investments. These
transaction charges are usually relatively small and are incidental to the purchase of the security. In
some cases, custodians also charge monthly, quarterly, or annual custody fees. Mutual funds and
exchange traded funds are managed by other advisers, who charge a management fee for their services
as investment managers. The management fee is included in the expense ratio. Mutual fund fees also
include transaction charges for the purchase or sale of securities within the fund and may charge other
fees as disclosed in the fund prospectus. These fees are in addition to the fees paid by the client to Atlas
Capital. Please see the section entitled "Brokerage Practices" for more information.

It should be noted that all investments incur expenses, which are paid from fund assets. Such expenses
include, without limitation, investment advisory fees and charges by certain Investments of 12b-1,
revenue sharing, administrative or shareholder servicing fees, or certain other fees, all of which reduce
the Net Asset Value of the Investments on a continuing basis. In addition, variable annuities charge
...

Item 7 Types of Clients
Description
Atlas Capital generally provides investment advice to individuals, families, pensions, profit sharing plans,
trusts and estates. Advice may extend to entities related to the client such as small businesses and
charitable organizations, including foundations and endowments. Client relationships vary in scope and
length of service. Atlas Capital does not impose a minimum dollar value of assets or other conditions for
opening or maintaining an account.