SmartAsset Atlas PWM Disclosure

We pay a fee to participate in an online matching program, SmartAsset, which seeks to match prospective advisory clients who have expressed an interest in finding an investment adviser with investment advisory firms such as Atlas Private Wealth Management, LLC (“Atlas”).  The adviser matching program provides the name and contact information of such persons to the advisory firms as potential leads.  For our participation in the program, we pay a flat fee of $212 per lead (“lead fee”) for prospective clients with investible assets of more than $1 million.  The lead fee we have agreed to pay gives SmartAsset a financial incentive to match prospective clients to our firm.  The lead fee is payable regardless of whether the prospect becomes our advisory client. Atlas does not increase the fees of advisory clients matched through the SmartAsset program to cover the lead fee. SmartAsset is not a current investment client or investor of Atlas.

Focus Financial Partners, LLC (“Focus”), Atlas’ parent company, is one of several minority investors in SmartAsset.  Focus has one director on SmartAsset’s board as well as a board observer. Atlas’ payment of a fee to SmartAsset benefits SmartAsset’s investors, including Focus, Atlas’ parent company.