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Atmos Advisory, LLC
CRD # 160087
Brochure
Dated March 24, 2025
Contact: Richard I. Lerach, Chief Compliance Officer
1001 Liberty Avenue, Suite 500
Pittsburgh, PA 15222
(412) 497-1766
This brochure provides information about the qualifications and business practices of Atmos
Advisory, LLC. If you have any questions about the contents of this brochure, please contact us at
(412) 497-1766. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission (“SEC”) or by any state securities authority.
Additional information about Atmos Advisory, LLC also is available on the SEC’s website at
www.adviserinfo.sec.gov. References herein to Atmos Advisory, LLC as a “registered investment
adviser” or any reference to being “registered” does not imply a certain level of skill or training.
DISCURE
PRIVATE WEALTH MANAGEMENT
ITEM 2. MATERIAL CHANGES
In this Item, Atmos Advisory, LLC (formerly named GPWM LLC) is required to discuss any
material changes which have been made to the brochure since our last annual amendment filed on
March 14, 2024.
As previously reported on June 20, 2024, effective June 1, 2024:
• GPWM, LLC changed its legal name to Atmos Advisory, LLC, although our Tax ID has
not changed.
• We relocated our office to 1001 Liberty Avenue, Suite 500, Pittsburgh, PA 15222.
• Our telephone numbers did not change however our email addresses changed as we
communicated to our clients.
• Certain employees of Atmos Advisory, LLC are now Registered Representatives of The
Leaders Group, Inc., and are no longer serving as Registered Representatives of M
Holdings Securities, Inc.
• Certain employees of Atmos Advisory, LLC are now licensed Insurance Agents of The
LRM Group, LLC, and are no longer serving as licensed Insurance Agents of Gateway
Financial Group, Inc.
We routinely make changes throughout the brochure to improve and clarify the descriptions of our
business practices and compliance policies and procedures or in response to evolving industry and
Firm practices. We believe that these changes are not material changes and therefore do not
describe them in this Item 2. Upon request, we will provide clients (“you”, “your”) with a
comparison of this brochure against the one previously filed indicating these changes.
We will provide you with a new brochure as necessary based on regulatory requirements, in the
event of material changes or new information, without charge. Should you require a copy of our
most current brochure at any time, please contact us at 412-497-1766. Please read this Form ADV
Part 2A in its entirety. Additional information about Atmos Advisory, LLC is available on the
IAPD website at www.adviserinfo.sec.gov, by searching for our CRD #160087.
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DISCURE
PRIVATE WEALTH MANAGEMENT
ITEM 3. TABLE OF CONTENTS
Brochure:
Item 1. Cover Page ...........................................................................................................................i
Item 2. Material Changes ........................................................................................................... ii
Item 3. Table of Contents ........................................................................................................... ii
Item 4. Advisory Business ......................................................................................................... 1
Item 5. Fees and Compensation ................................................................................................. 4
Item 6. Performance-Based Fees and Side-by-Side Management............................................... 7
Item 7. Types of Clients ............................................................................................................ 7
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ....................................... 7
Item 9. Disciplinary Information ..............................................................................................11
Item 10. Other Financial Industry Activities and Affiliations ....................................................11
Item 11. Code of Ethics ............................................................................................................12
Item 12. Brokerage Practices ....................................................................................................13
Item 13. Review of Accounts ...................................................................................................16
Item 14. Client Referrals and Other Compensation ...................................................................17
Item 15. Custody ......................................................................................................................17
Item 16. Investment Discretion ................................................................................................18
Item 17. Voting Client Securities .............................................................................................18
Item 18. Financial Information .................................................................................................18
Table 1. Risk Considerations……………………………………………………………………18
Brochure Supplements:
Richard I. Lerach………………………………………………………………………………...22
Kevin P. Siebert……………………………………………………….........................................26
Nicole Cosnotti…………………………………………………………………………………..30
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ITEM 4. ADVISORY BUSINESS
Atmos Advisory, LLC, previously named GPWM LLC (hereafter referred to as “Atmos
Advisory”, the “Firm”, “we”, “our”) has been in business as a registered investment adviser since
January 2012 and is principally owned by Richard I. Lerach. The Firm provides financial planning,
consulting, and wealth management services. Prior to engaging Atmos Advisory to provide any of
the foregoing investment advisory services, the client is required to enter into one or more written
agreements with the Firm setting forth the terms and conditions under which Atmos Advisory
renders its services (collectively the “Agreement”).
As of December 31, 2024, Atmos Advisory had approximately $149 million in assets under
management, all of which were managed on a discretionary basis.
While this brochure generally describes the business practices of Atmos Advisory, certain sections
also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners,
directors (or other persons occupying a similar status or performing similar functions), or
employees, or any other person who provides investment advice on Atmos Advisory’s behalf and
is subject to the Firm’s supervision or control.
Investment Management Services
Atmos Advisory manages client investment portfolios on a discretionary basis, by allocating assets
among various Exchange-Traded Funds (“ETFs”) and, to a lesser extent, mutual funds and
independent investment managers (“Independent Managers”).
Atmos Advisory tailors its advisory services to the individual needs of clients. Atmos Advisory
consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon
and other factors that may impact the clients’ investment needs. Atmos Advisory seeks to ensure
that clients’ investments are suitable for their investment needs, goals, objectives, and risk
tolerance.
Clients are advised to promptly notify Atmos Advisory if there are changes in their financial
situation or investment objectives or if they wish to impose any reasonable restrictions upon Atmos
Advisory’s management services. Clients are permitted to impose reasonable restrictions or
mandates on the management of their account if, in Atmos Advisory’s sole discretion, we
determine that such conditions will not materially impact the performance or risk of a portfolio
strategy or prove overly burdensome to its management efforts.
Atmos Advisory does not participate in wrap fee programs.
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Use of Independent Managers
As mentioned above, Atmos Advisory recommends that certain clients authorize the active
discretionary management of a portion of their assets by and/or among certain Independent
Managers. The terms and conditions under which a client engages an Independent Manager are
set forth in a separate written agreement between the Client and the Independent Manager or in
place of an agreement, a separate disclosure document is provided by Atmos Advisory. In addition
to this brochure, clients also receive the written disclosure brochure of the designated Independent
Manager engaged to manage their assets.
Atmos Advisory evaluates various information about the Independent Managers in which it
recommends or selects to manage client portfolios under the Program. The Firm generally reviews
a variety of different resources, which generally include the Independent Managers’ public
disclosure documents, materials supplied by the Independent Managers themselves, and other
third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the
Independent Managers’ investment strategies, past performance, and risk results in relation to its
clients’ individual portfolio allocations and risk exposures. Atmos Advisory also takes into
consideration each Independent Manager’s management style, returns, reputation, financial
strength, reporting, pricing, and research capabilities, among other related factors.
Atmos Advisory continues to provide services related to the discretionary or non-discretionary
selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance
of those accounts being managed by Independent Managers. Atmos Advisory has discretion to
appoint, terminate and/or replace any Independent Manager. Atmos Advisory does not, however,
actively supervise the trading activities of the Investment Managers, nor is it liable for any losses
in the value of assets as a result of their trading activities. Clients should be aware that in most
cases, they have the opportunity to invest directly with Independent Managers without the
involvement of Atmos Advisory.
ERISA (Other than Individual Retirement Accounts)
If the client is: (i) a retirement plan (“Plan”) organized under the Employee Retirement Income
Security Act of 1974 (“ERISA”); (ii) a participant or beneficiary of a Plan subject to Title I of
ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code, with authority to direct
the investment of assets in his or her Plan account or to take a distribution; (iii) the beneficial
owner of an Individual Retirement Account (“IRA”) acting on behalf of the IRA; or (iv) a Retail
Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A)
of the Internal Revenue Code: then Atmos Advisory represents that it and its representatives are
fiduciaries under ERISA or the Internal Revenue Code, or both, with respect to any investment
advice provided by Atmos Advisory or its representatives or with respect to any investment
recommendations regarding an ERISA Plan or participant or beneficiary account.
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Retirement Plan Rollovers
A client or prospective client leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money in the
former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”),
or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse
tax consequences). If Atmos Advisory provides a recommendation as to whether a client should
engage in a rollover or not, Atmos Advisory is acting as a fiduciary within the meaning of Title I
of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. Furthermore, if Atmos Advisory recommends that a client roll over their retirement plan
assets into an account to be managed by Atmos Advisory, such a recommendation creates a conflict
of interest if Atmos Advisory will earn new (or increase its current) compensation as a result of
the rollover. To mitigate this conflict, Atmos Advisory will in good faith assist the client in
understanding the tradeoffs and options related to the rollover through written analysis and
discussion. No client is under any obligation to roll over retirement plan assets to an account
managed by Atmos Advisory.
Financial Planning and Consulting Services
As part of our investment management process, Atmos Advisory provides its clients with a broad
range of comprehensive financial planning and consulting services at no additional expense. These
services vary, but generally includes matters such as retirement planning, educational funding,
basic estate planning, insurance planning, basic tax planning and cash flow analysis.
In performing its services, Atmos Advisory is not required to verify any information received from
the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly
authorized to rely on such information. Atmos Advisory recommends the services of itself, its
Supervised Persons in their individual capacities as registered representatives of a broker-dealer,
and/or other professionals to implement its recommendations. Clients are advised that a conflict
of interest exists if Atmos Advisory recommends its own services. The client is under no
obligation to act upon any of the recommendations made by Atmos Advisory under a financial
planning or consulting engagement or to engage the services of any such recommended
professional, including Atmos Advisory itself. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any of Atmos Advisory’s
recommendations. Clients are advised that it remains their responsibility to promptly notify Atmos
Advisory if there is ever any change in their financial situation or investment objectives for the
purpose of reviewing, evaluating, or revising Atmos Advisory’s previous recommendations and/or
services.
Clients have the option to also engage Atmos Advisory to advise on certain investment products
that are not maintained at their primary custodian, such as variable life insurance and annuity
contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e.
529 plans). In these situations, Atmos Advisory directs or recommends the allocation of client
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assets among the various investment options available with the product. Each situation is handled
differently. Client assets are generally maintained at the underwriting insurance company, or the
custodian designated by the product’s provider.
ITEM 5. FEES AND COMPENSATION
Atmos Advisory’s annual investment management fee is based upon a percentage (%) of the
market value of assets placed under the Firm’s management, including cash. Atmos Advisory, in
its sole discretion, is authorized to reduce its investment management fee based upon certain
criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount
of assets to be managed, related accounts, account composition, negotiations with client, etc.). Fees
are generally waived for employee accounts. Additionally, certain of our Supervised Persons, in
their individual capacities, offer securities brokerage services and insurance products under a
commission fee arrangement.
Investment Management Fees
Atmos Advisory provides investment management services for an annual fee depending upon the
market value of the assets under management, as follows:
PORTFOLIO VALUE
ANNUAL FEE
From $0 to $4,999,999
$5,000,000 – $9,999,999
$10,000,000 – $19,999,999
$20,000,000 – $49,999,999
$50,000,000 +
1.00%
0.75%
0.50%
0.35%
0.20%
Effective July 1, 2022, Atmos Advisory changed its fee billing protocol from charging quarterly
fees in advance to charging quarterly fees in arrears. Our annual fee is based upon the market value
of the assets being managed by us on the last day of the previous quarter. The quarterly fee in any
given quarter will be adjusted for each deposit or withdrawal of $50,000 or more in that quarter.
The fee for the initial or final billing period will be prorated to charge the client only for the period
in which Atmos Advisory managed the account. Our annual fee is exclusive of, and in addition to
brokerage commissions, transaction fees and other related costs and expenses which are incurred
by the client.
Independent Manager Fees
When Atmos Advisory recommends, or client requests exposure to, an Independent Manager, the
investment management fee charged by Independent Manager(s) is separate from, and in addition
to, Atmos Advisory’s investment management fee. Fees for Independent Managers are detailed
separately in their Form ADV. Clients should be aware that in many cases, access to Independent
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Managers is available directly without the involvement of Atmos Advisory, which would alleviate
the layering of fees.
ERISA (Other than Individual Retirement Accounts)
For discretionary 3(38) plans, the management fee for each billing period will be paid in arrears,
based upon the market value of the assets on the last day of the previous billing period, in
accordance with the fee schedule contained in the Agreement. The management fee for the initial
billing period will be prorated for such billing period and shall be based upon the initial market
value of the assets invested.
For non-discretionary 3(21) plans, the amount of the management fee is detailed in the Agreement.
The management fee for the initial billing period will be prorated for such billing period. The
policies and procedures of the third-party retirement or employee benefits plan platform provider
the plan uses will determine if the management fee is taken in arears or in advance, how the fee is
calculated (e.g., the value of the account at the end of the quarter, average value for the month,
etc.), and how the fee is handled in the case of a termination. Please see the Section 408(b)(2)
Letter applicable to your plan for additional information.
Fees Charged by Financial Institutions
As further discussed in response to Item 12 (below), Atmos Advisory generally recommends that
clients utilize the brokerage and clearing services of Charles Schwab & Co., Inc. (“Schwab”) for
investment management accounts.
Atmos Advisory will only implement its investment management recommendations after the client
has arranged for and furnished Atmos Advisory with all information and authorization regarding
accounts with appropriate financial institutions. Financial institutions include, but are not limited
to, Schwab, any other broker-dealer recommended by Atmos Advisory, broker-dealer directed by
the client, trust companies, banks etc. (collectively referred to herein as the “Financial
Institutions”).
Clients will incur certain charges imposed by the Financial Institutions and other third parties,
such as fees charged by Independent Managers, custodial fees, charges imposed directly by a
mutual fund or ETF in the Account, which are disclosed in the fund’s prospectus (e.g., fund
management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions.
Fee Debit Arrangements
Atmos Advisory’s Agreement and the separate agreement with any Financial Institutions authorize
Atmos Advisory or Independent Managers to debit the client’s account for the amount of Atmos
Advisory’s fee and to directly remit that management fee to Atmos Advisory or the Independent
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Managers. Any Financial Institutions recommended by Atmos Advisory have agreed to send a
statement to the client, at least quarterly, indicating all amounts disbursed from the account,
including the amount of management fees paid directly to Atmos Advisory. In accordance with
applicable rules and regulations, the Firm also sends invoices to clients detailing the amount
debited for payment of the quarterly management fee.
For non-discretionary ERISA 3(21) plans, fees are not subject to fee debit arrangements but are
instead directed by the designated third-party platform.
Fees for Management During Partial Quarters of Service
For the initial period of investment management services, the fees are calculated on a pro rata
basis to charge only for the period the account is managed by Atmos Advisory. The Agreement
between Atmos Advisory and the client will continue in effect until terminated by either party
pursuant to the terms of the Agreement. Atmos Advisory’s fees are prorated through the date of
termination and a final invoice is sent to the client, as appropriate. Clients may make additions to
and withdrawals from an account at any time. If assets are deposited or withdrawn after the
beginning of a billing period, the management fee will be prorated if the amount of a particular
deposit or withdrawal exceeds $50,000. For smaller deposits and withdrawals, the management
fee will not be prorated. All withdrawals are subject to customary securities settlement procedures.
A termination of this Agreement will not automatically result in a termination of the custody
agreement with the Financial Institution (“Custody Agreement”), which will continue in effect
between you and the Financial Institution. Upon termination of the Custody Agreement, we will
not have the ability to take any further action with respect to your Account, including the ability
to credit any unearned fees to your Account.
Clients are permitted to make additions to and withdrawals from their account at any time, subject
to Atmos Advisory’s right to terminate an account. Clients have the option to deposit cash or
securities into the account, provided that Atmos Advisory reserves the right to liquidate any
transferred securities or decline to accept particular securities into a client’s account. Clients are
permitted to withdraw account assets on notice to Atmos Advisory, subject to the usual and
customary securities settlement procedures. However, Atmos Advisory designs its portfolios as
long-term investments and the withdrawal of assets in certain cases will impair the achievement
of a client’s investment objectives. When appropriate, Atmos Advisory is available to consult with
its clients about the options and ramifications of transferring securities. However, clients are
advised that when transferred securities are liquidated, they are subject to transaction fees, fees
assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications.
Commissions or Sales Charges for Recommendations of Securities
Clients can engage certain persons associated with Atmos Advisory (but not Atmos Advisory) to
render securities and insurance brokerage services under a commission arrangement. Clients are
under no obligation to engage such persons and are free to choose brokers or agents not affiliated
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with Atmos Advisory. Under this arrangement, clients have the choice to implement securities
transactions through certain of Atmos Advisory’s Supervised Persons in their respective individual
capacities as registered representatives of The Leaders Group, Inc. (“Leaders Group”), an
unaffiliated SEC registered broker-dealer and member of FINRA. Leaders Group charges
brokerage commissions to effect these securities transactions and thereafter, wherein a portion of
these commissions are often paid by Leaders Group to such Supervised Persons. Prior to effecting
any transactions, clients are required to enter into a new account agreement with Leaders Group.
The brokerage commissions charged by Leaders Group may be higher or lower than those charged
by other broker dealers. In addition, certain of Atmos Advisory’s Supervised Persons at times also
receive ongoing 12b-1 fees for mutual fund purchases from the mutual fund company during the
period that the client maintains the mutual fund investment. These fees are not collected by Atmos
Advisory but are collected from Leaders Group on client assets held away from the client’s Atmos
Advisory investment advisory account, a portion of which are distributed to the registered
representative.
A conflict of interest exists to the extent that Atmos Advisory recommends the purchase of
securities or insurance where Atmos Advisory’s Supervised Persons receive commissions or other
additional compensation as a result of Atmos Advisory’s recommendations. Supervised Persons
are bound by the Atmos Advisory compliance program which is designed to facilitate compliance
with applicable rules and regulations and seek to treat all clients fairly.
ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Atmos Advisory does not provide any services for a performance-based fee (i.e., a fee based on a
share of capital gains or capital appreciation of a client’s assets).
ITEM 7. TYPES OF CLIENTS
Atmos Advisory provides its services to individuals, pension and profit-sharing plans, trusts,
estates, charitable organizations, corporations, and business entities.
Atmos Advisory does not impose a minimum portfolio size or minimum annual fee. Certain
Independent Managers have the authority to, however, impose more restrictive account
requirements and varying billing practices than Atmos Advisory. In such instances, Atmos
Advisory will at times alter its corresponding account requirements and/or billing practices to
accommodate those of the Independent Managers.
ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES, RISK OF LOSS
Methods of Analysis
Atmos Advisory employs an analytical method based on modern portfolio theory (“MPT”). MPT
is a mathematical based investment discipline that seeks to quantify expected portfolio returns in
relation to corresponding portfolio risk. The basic premise of MPT is that the risk of a particular
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holding is to be assessed by comparing its price variations against those of the market portfolio.
However, MPT disregards certain investment considerations and is based on a series of
assumptions that do not always reflect actual market conditions. As such, the factors for which
MPT does not account (e.g., tax implications, regulatory constraints, and brokerage costs) can at
times negate the upside or add to the actual risk of a particular allocation. Nonetheless, Atmos
Advisory’s investment process is structured in such a way to integrate those assumptions and real-
life considerations for which MPT analytics do not account.
Investment Strategies
The Firm offers diversified portfolio choices that serve a wide range of investor risk profiles and
are aligned with clients’ unique needs and circumstances. Atmos Advisory primarily manages
clients’ accounts through ETF-based asset allocated risk models. The ETFs underlying the Firm’s
proprietary models are primarily comprised of domestic and international fixed income and equity
securities but also include exposure to real estate holdings and commodities. In certain
circumstances, the Firm utilizes Independent Managers in accordance with a client’s specific
investment objective (e.g. increasing cash flow and liquidity or minimizing taxes).
Risks of Loss
General Risk of Loss
Investing in securities involves the risk of loss. Clients should be prepared to bear such loss.
Market Risks
The profitability of a significant portion of Atmos Advisory’s recommendations depend to a great
extent upon correctly assessing the future course of price movements of stocks and bonds. There
can be no assurance that Atmos Advisory will be able to predict those price movements accurately.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund
and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of
the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-
level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the
event they sell securities for a profit that cannot be offset by a corresponding loss. Additionally,
ETFs and mutual funds incur fees that are separate from those fees charged by Atmos Advisory.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund
itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a
fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads,
purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of
each business day, although the actual NAV fluctuates with intraday changes to the market value
of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from
the NAV during periods of market volatility, which will, among other factors, lead to the mutual
fund’s shares trading at a premium or discount to NAV.
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Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the
secondary market. Generally, ETF shares trade at or near their most recent NAV, which is
generally calculated at least once daily for indexed-based ETFs and more frequently for actively
managed ETFs. However, certain inefficiencies cause the shares to trade at a premium or discount
to their pro rata NAV. There is also no guarantee that an active secondary market for such shares
will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as
creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to
exist for shares of a particular ETF, a shareholder could have no way to dispose of such shares.
Use of Independent Managers
Atmos Advisory recommends the use of Independent Managers for certain clients. Atmos
Advisory will continue to do ongoing due diligence of such managers, but such recommendations
rely, to a great extent, on the Independent Managers ability to successfully implement their
investment strategy. In addition, Atmos Advisory does not have the ability to supervise the
Independent Managers on a day-to-day basis other than as previously described in response to
Item 4 above.
Management Through Similarly Managed “Model” Accounts
Atmos Advisory manages certain accounts through the use of similarly managed “model”
portfolios, whereby the Firm allocates all or a portion of its clients’ assets among various mutual
funds and/or securities on a discretionary basis using one or more of its proprietary investment
strategies. In managing assets through the use of models, the Firm remains in compliance with the
safe harbor provisions of Rule 3a-4 of the Investment Company Act of 1940.
Atmos Advisory portfolio turnover is relatively low, with tax efficiency an important objective.
The Firm seeks to ensure that clients’ assets are managed in a manner consistent with their
individual financial situations and investment objectives. Clients should contact Atmos Advisory
if they experience a change in their financial situation or to impose reasonable restrictions on the
management of their accounts.
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laws, and national and
General Economic, Geopolitical, and Market Disruption Risks
The success of Atmos Advisory’s investment strategies, processes, and methods of analysis, as
well as any client portfolio activities, will likely be affected by general economic, geopolitical, and
market conditions, such as changes in interest rates, availability of credit, inflation rates, market
liquidity, global demand for particular products or resources, natural disasters, supply chain
disruptions, tariffs, cybersecurity events, economic uncertainty, pandemics, epidemics, terrorism,
social and political discord, war, debt crises and downgrades, regulatory events, governmental or
quasi-governmental actions, changes
international political
circumstances. These factors create uncertainty, and can adversely impact the volatility, value and
performance of the securities held in client accounts.
Cash Balances in Client Accounts
Atmos Advisory considers its models to be fully invested but will hold some minimum amount of
cash resulting from dividend and interest income and to facilitate the payment of client fees. Cash
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held in the client’s investment accounts are typically swept into the money market fund accounts
or money market bank accounts at the client’s custodian. Generally, the rate a client will earn on
cash sweep investments will be lower than the rate on other available cash alternatives, although
cash sweep rates do vary by custodian. During periodic portfolio reviews, Atmos Advisory will
generally discuss upcoming cash flow needs with each client and seeks to plan accordingly to meet
those needs. Atmos Advisory includes cash and cash equivalents in the calculation of assets under
management and fees, unless the client has negotiated another arrangement, such as an asset carve-
out agreement. During periods of exceedingly low short-term interest rates, client fees paid on cash
balances will exceed money market yields.
Cybersecurity
Atmos Advisory is dependent on the effectiveness of the information and cybersecurity policies,
procedures and capabilities it maintains to protect the confidentiality, integrity, and availability of
its computer and telecommunications systems and the data that resides on or is transmitted through
them. An externally caused information security incident, such as a cyber-attack including a
phishing scam, malware, or denial-of-service attack, or an internally caused incident, such as
failure to control access to sensitive systems, could materially interrupt business operations or
cause disclosure or modification of sensitive or confidential client or competitive information.
Moreover, Atmos Advisory’s increased use of mobile and cloud technologies could heighten these
and other operational risks, as certain aspects of the security of such technologies may be complex,
unpredictable or beyond Atmos Advisory’s control. Atmos Advisory’s exposure to the public
Internet, as well as any reliance on mobile or cloud technology or any failure by third-party service
providers to adequately safeguard their systems and prevent cyber-attacks, could disrupt its
operations and result in misappropriation, corruption or loss of personal, confidential or proprietary
information.
In addition, there is a risk that encryption and other protective measures may be circumvented,
particularly to the extent that new computing technologies increase the speed and computing power
available. Moreover, due to the complexity and interconnectedness of Atmos Advisory’s systems,
the process of upgrading existing capabilities, developing new functionalities and expanding
coverage into new markets and geographies, including to address client or regulatory requirements,
may expose Atmos Advisory to additional cyber- and information-security risks or system
disruptions, for Atmos Advisory, as well as for clients who rely upon, or have exposure to, Atmos
Advisory’s systems. Although Atmos Advisory has implemented policies and controls, and takes
protective measures, to strengthen its computer systems, processes, software, technology assets
and networks to prevent and address potential data breaches, inadvertent disclosures, cyber-attacks
and cyber-related fraud, there can be no assurance that any of these measures prove effective. In
addition, due to Atmos Advisory’s interconnectivity with third-party vendors, advisers, custodians,
exchanges, clearing houses and other financial institutions, Atmos Advisory may be adversely
affected if any of them are subject to a successful cyber-attack or other information security event,
including those arising due to the use of mobile technology or a third-party cloud environment.
Atmos Advisory also transmits and receives personal, confidential or proprietary information by
email and other electronic means. Atmos Advisory collaborates with clients, vendors and other
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third parties to develop secure transmission capabilities and protect against cyber-attacks.
However, Atmos Advisory cannot ensure that it or such third parties have all appropriate controls
in place to protect the confidentiality of such information. Any information security incident or
cyber-attack against Atmos Advisory or third parties with whom it is connected, or issuers of
securities or instruments in which client portfolios invest, including any interception, mishandling
or misuse of personal, confidential or proprietary information, has the ability to cause disruptions
and impact business operations, potentially resulting in financial losses, the inability to transact
business, violations of applicable privacy and other laws, loss of competitive position, regulatory
fines and/or sanctions, breach of client contracts, reputational harm or legal liability. Furthermore,
many jurisdictions in which Atmos Advisory operates have laws and regulations relating to data
privacy, cybersecurity and protection of personal information. Any determination of a failure to
comply with any such laws or regulations could result in fines and/or sanctions against Atmos
Advisory.
Other Risk Considerations
While Atmos Advisory strives to construct portfolios that are diversified, there is no guarantee that
market forces will not overwhelm diversification efforts, subjecting clients to correlation risk.
Recognizing that assuming some type of risk is unavoidable, the Firm takes a risk-based approach
to minimize the probability and magnitude of losses. Such risk management steps include proper
asset allocation, portfolio rebalancing, in-depth and independent research, financial planning,
client education, and regular portfolio monitoring and client reviews.
Finally, regular communication with clients plays a critical role in maintaining a prudent and
successful long-term investment program. Please see Table 1 at the end of this disclosure for an
important summary of the primary investment risks and the steps taken by Atmos Advisory to
minimize these risks. Please note this list is intended to highlight primary risks of investing assets
with the Firm but does not capture all such risks.
ITEM 9. DISCIPLINARY INFORMATION
Atmos Advisory has not been involved in any legal or disciplinary events that are material to a
client’s evaluation of its advisory business or the integrity of management.
ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Atmos Advisory is required to disclose any relationship or arrangement that is material to its
advisory business or to its clients with certain related persons.
Registered Representatives of Broker Dealer
As discussed in Item 5, certain of the Firm’s Supervised Persons are registered representatives of
Leaders Group and from time to time provide clients with securities brokerage services under a
separate commission-based arrangement. A conflict of interest exists to the extent Atmos Advisory
recommends the purchase of a security and one of its Supervised Persons receives a portion of the
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commissions paid to Leaders Group. Supervised Persons are bound by the Atmos Advisory and
Leaders Group compliance programs which are designed to facilitate compliance with applicable
rules and regulations and seek to treat all clients fairly.
Receipt of Insurance Commission
Certain of Atmos Advisory’s Supervised Persons, in their individual capacities, are also licensed
insurance agents with The LRM Group, and in such capacity, are authorized to recommend, on a
fully disclosed commission basis, the purchase of certain insurance products. While Atmos
Advisory (the adviser) does not sell such insurance products to its investment advisory clients,
Atmos Advisory does permit its Supervised Persons, in their individual capacities as licensed
insurance agents, to sell insurance products to its investment advisory clients. A conflict of interest
exists to the extent that Atmos Advisory recommends the purchase of insurance products where
Atmos Advisory’s Supervised Persons receive insurance commissions or other additional
compensation. Supervised Persons are bound by the compliance programs of both Atmos
Advisory and LRM Group which are designed to facilitate compliance with applicable rules and
regulations.
Recommending Other Independent Managers
When appropriate Atmos Advisory recommends an Independent Manager to provide the client
with exposure to certain asset classes and related expertise. Atmos Advisory does not receive any
compensation from Independent Managers for such recommendations. Please refer to Items 4, 5,
and 8 for more information about these arrangements.
ITEM 11. CODE OF ETHICS
Atmos Advisory has adopted a code of ethics in compliance with applicable securities laws (“Code
of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Atmos
Advisory’s Code of Ethics contains written policies reasonably designed to prevent certain
unlawful practices such as the misuse of material non-public information by the Firm or any of its
Supervised Persons and the trading by the same of securities ahead of clients in order to take
advantage of pending orders.
The Code of Ethics also requires certain of Atmos Advisory’s personnel (called “Access Persons”)
to report their personal securities holdings and transactions and obtain pre-approval of certain
investments (e.g., initial public offerings, private placements, SPACs, and limited offerings).
However, Atmos Advisory’s Supervised Persons are permitted to buy or sell securities that the
Firm also recommends to clients if done in a manner consistent with the Firm’s policies and
procedures. This Code of Ethics has been established recognizing that some securities trade in
sufficiently broad markets to permit transactions by Access Persons to be completed without any
appreciable impact on the markets of such securities. Therefore, under certain limited
circumstances, exceptions will be made to the policies stated below.
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When the Firm is engaging in or considering a transaction in any security on behalf of a client
where there is a potential for conflict, no Access Person is permitted to knowingly effect for
themselves or for their immediate family (i.e., spouse, minor children and adults living in the same
household as the Access Person) a transaction in that security unless:
♦ the transaction has been completed.
♦ the transaction for the Access Person is completed as part of a batch trade (as defined below
in Item 12) with clients; or
♦ a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United
States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit,
commercial paper, repurchase agreements and other high quality short-term debt instruments,
including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and
(iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual
funds.
Clients and prospective clients may contact Atmos Advisory at (412) 497-1766 to request a copy
of its Code of Ethics.
ITEM 12. BROKERAGE PRACTICES
Custodian Selection
As discussed above, in Item 5, Atmos Advisory generally recommends that clients utilize the
brokerage and clearing services of Schwab. Factors which Atmos Advisory considers in
recommending Schwab, or any other Financial Institution, to clients include their respective
financial strength, reputation, execution, pricing, research, and service. Schwab generally enables
Atmos Advisory to obtain many mutual funds without transaction charges and other securities at
nominal transaction charges. The commissions and/or transaction fees charged by Schwab may be
higher or lower than those charged by other Financial Institutions.
The commissions paid by Atmos Advisory’s clients comply with Atmos Advisory’s duty to obtain
“best execution.” Clients may pay commissions that are higher than another qualified Financial
Institution might charge to effect the same transaction where Atmos Advisory determines that the
commissions are reasonable in relation to the value of the brokerage and research services
received. In seeking best execution, the determinative factor is not the lowest possible cost, but
whether the transaction represents the best qualitative execution, taking into consideration the full
range of a Financial Institution’s services, including among others, the value of research provided,
execution capability, commission rates, and responsiveness. Atmos Advisory seeks competitive
rates but does not necessarily obtain the lowest possible commission rates for client transactions
in all cases.
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Atmos Advisory is cognizant of its duty to obtain best execution and has implemented policies and
procedures reasonably designed in such pursuit. Atmos Advisory periodically and systematically
reviews these policies and procedures consistent with its duty to obtain best execution.
Directed Brokerage
The client is permitted to direct Atmos Advisory in writing to use a particular Financial Institution
to execute some or all transactions for the client. In that case, the client will negotiate terms and
arrangements for the account with that Financial Institution, and Atmos Advisory will not seek
better execution services or prices from other Financial Institutions or be able to “batch” client
transactions for execution through other Financial Institutions with orders for other accounts
managed by Atmos Advisory (as described below). As a result, the client will at times pay higher
commissions or other transaction costs or greater spreads, or receive less favorable net prices, on
transactions for the account than would otherwise be the case. Subject to its duty of best execution,
Atmos Advisory will decline a client’s request to direct brokerage if, in Atmos Advisory’s sole
discretion, such directed brokerage arrangements would result in additional operational difficulties
or violate restrictions imposed by other broker-dealers (as further discussed below).
Trade Management and Allocation
Transactions for each client generally will be effected independently, unless Atmos Advisory
decides to purchase or sell the same securities for several clients at approximately the same time.
Atmos Advisory generally (but is not obligated to) combines or “batches” such orders to obtain
best execution, to negotiate more favorable commission rates, or to allocate equitably among
Atmos Advisory’s clients, differences in prices and commissions or other transaction costs that
might have been obtained had such orders been placed independently. Under this procedure,
transactions will generally be averaged as to price and allocated among Atmos Advisory’s clients
pro rata to the purchase and sale orders placed for each client on any given day. To the extent that
Atmos Advisory determines to aggregate client orders for the purchase or sale of securities,
including securities in which Atmos Advisory’s Supervised Persons invest, Atmos Advisory
generally does so in accordance with applicable law. Atmos Advisory does not receive any
additional compensation or remuneration as a result of the aggregation.
In the event that Atmos Advisory determines that a prorated allocation is not appropriate under the
particular circumstances, the allocation will be made based upon other relevant factors, which
include: (i) when only a small percentage of the order is executed, shares may be allocated to the
account with the smallest order or the smallest position or to an account that is out of line with
respect to security or sector weightings relative to other portfolios, with similar mandates; (ii)
allocations may be given to one account when one account has limitations in its investment
guidelines which prohibit it from purchasing other securities which are expected to produce similar
investment results and can be purchased by other accounts; (iii) if an account reaches an investment
guideline limit and cannot participate in an allocation, shares will be reallocated to other accounts
(this could be due to unforeseen changes in an account’s assets after an order is placed); (iv) with
respect to sale allocations, allocations will when appropriate be given to accounts low in cash; (v)
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in cases when a pro rata allocation of a potential execution would result in a de minimis allocation
in one or more accounts, Atmos Advisory may exclude the account(s) from the allocation; the
transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases
where a small proportion of an order is executed in all accounts, shares may be allocated to one or
more accounts on a random basis.
Access to Research
Atmos Advisory has access to research from Schwab. The receipt of investment research poses a
conflict of interest because Atmos Advisory does not have to produce or pay for the products or
services. To mitigate this conflict, Atmos Advisory evaluates the services and fees/expenses of
Schwab periodically to reaffirm that fees and expenses are fair and reasonable relative to industry
standards and relative to the value of the services received.
Commissions or Sales Charges for Recommendations of Securities
As discussed above, certain Supervised Persons in their respective individual capacities are
registered representatives of Leaders Group. These Supervised Persons are subject to FINRA Rule
3040 which restricts registered representatives from conducting securities transactions away from
their broker-dealer unless Leaders Group provides written consent. Therefore, clients are advised
that certain Supervised Persons will at times be restricted from conducting securities transactions
through Leaders Group unless they first secure written consent from Leaders Group to execute
securities transactions though a different Financial Institution. Absent such written consent or
separation from Leaders Group, these Supervised Persons are prohibited from executing securities
transactions through any Financial Institution other than Leaders Group. Further, when such
Supervised Persons execute transactions through Leaders Group, they generally receive a portion
of the brokerage commissions and/or transaction fees charged to the client by Leaders Group. Any
such brokerage commissions and/or transaction fees are separate from and in addition to the
management fee paid by the client to Atmos Advisory.
As noted in Item 5, a conflict of interest exists to the extent that Atmos Advisory recommends the
purchase of securities where Atmos Advisory’s Supervised Persons receive commissions or other
additional compensation as a result of Atmos Advisory’s recommendations. Supervised Persons
are bound by the Atmos Advisory compliance program which is designed to facilitate compliance
with applicable rules and regulations and seek to treat all clients fairly.
Software and Support Provided by Financial Institutions
Atmos Advisory generally receives from Schwab, without cost to Atmos Advisory, computer
software and related systems support, which allow Atmos Advisory to better monitor client
accounts maintained at Schwab. Atmos Advisory receives the software and related support without
cost because Atmos Advisory renders investment management services to clients that maintain
assets at Schwab. The software and related systems support may benefit Atmos Advisory, but not
its clients directly. In fulfilling its duties to its clients, Atmos Advisory endeavors at all times to
15
put the interests of its clients first. Clients should be aware, however, that Atmos Advisory’s receipt
of economic benefits from a Financial Institution creates a conflict of interest since these benefits
could influence Atmos Advisory’s choice of one Financial Institution over another that does not
furnish similar software, systems support or services.
Additionally, Atmos Advisory receives the following benefits from Schwab through its
institutional division: receipt of duplicate client confirmations and bundled duplicate statements;
access to a trading desk that exclusively services the institutional participants; access to block
trading which provides the ability to aggregate securities transactions and then allocate the
appropriate shares to client accounts; and access to an electronic communication network for client
order entry and account information. Although Atmos Advisory benefits from these services, the
Firm believes the services benefit clients as well.
ITEM 13. REVIEW OF ACCOUNTS
Account Reviews
Richard I. Lerach monitors model investment portfolios as part of a continuous and ongoing
process. This entails ongoing evaluation of asset allocation, rebalancing requirements, and
underlying investment holdings. Client communications are ongoing, while Atmos Advisory
undertakes a formal client review generally, with some exceptions, on an annual basis. Atmos
Advisory further conducts account reviews upon the occurrence of a triggering event, such as a
change in client investment objectives and/or financial situation, cash flows, market corrections
and client request.
For those clients to whom Atmos Advisory provides financial planning and/or consulting services,
reviews are conducted on an “as needed” basis. Such reviews are conducted by one of Atmos
Advisory’s investment adviser representatives. All investment advisory clients are encouraged to
discuss their needs, goals, and objectives with Atmos Advisory and to keep Atmos Advisory
informed of any changes thereto. Atmos Advisory contacts ongoing investment advisory clients
at least annually to review its previous services and/or recommendations, and to discuss the impact
resulting from any changes in the client’s financial situation and/or investment objectives.
Account Statements and Confirmations
Unless otherwise agreed upon, clients are provided with transaction confirmation notices and
regular summary account statements directly from the Financial Institution for the client Account.
Those clients to whom Atmos Advisory provides investment advisory services will also receive a
report from Atmos Advisory that sets forth a summary overview of the Account and Account
performance, as clients request from time to time. Clients should compare the account statements
they receive from their custodian with those reports they receive from Atmos Advisory. Custodial
statements at times vary from Atmos Advisory reports based on differences between accounting
procedures, reporting dates, or valuation methods for certain securities.
16
ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION
Client Referrals
Atmos Advisory has arrangements in place whereby the Firm compensates its employees for client
referrals. All referral fees are paid solely from Atmos Advisory’s management fee and do not result
in any additional charges to the Firm’s clients.
Other Economic Benefits
As discussed in Item 12, Atmos Advisory and its Supervised Persons at times receive economic
benefits from certain Financial Institutions for recommendations and investments made through
such Financial Institutions. A conflict of interest exists to the extent that Atmos Advisory and its
Supervised Persons receive these benefits. Supervised Persons are bound by the Atmos Advisory
compliance program which is designed to facilitate compliance with applicable rules and
regulations and seek to treat all clients fairly.
ITEM 15. CUSTODY
Under applicable law, Atmos Advisory is deemed to have custody over a client’s assets when it
has the ability to dispose of client funds or securities for any purpose other than authorized trading.
Thus, for example, Atmos Advisory is deemed to have custody when it is authorized to directly
debit a client’s account for payment of the Firm’s quarterly management fee. In this instance,
however, Atmos Advisory is not subject to a surprise custody audit because the Financial
Institutions recommended by Atmos Advisory have agreed to send statements to clients, not less
than quarterly, indicating all amounts paid to Atmos Advisory and/or the Independent Managers
engaged to manage their accounts.
Similarly, Atmos Advisory is deemed to have constructive custody over client assets as a result of
any arrangement under which Atmos Advisory is authorized to withdraw client funds or securities
pursuant to a standing letter of instruction or other similar asset transfer authorization established
by a client with a Financial Institution. In this instance, however, Atmos Advisory would be
excused from the requirement of an annual surprise examination because it complies with certain
processes and procedures mandated by applicable law.
Except for these two limited situations, Atmos Advisory does not have custody over any other
client assets.
As discussed in Item 13, Atmos Advisory from time to time also sends periodic reports to clients.
Clients are advised to carefully review the statements and confirmations sent directly by the
Financial Institutions and to compare them with any reports received from Atmos Advisory.
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ITEM 16. INVESTMENT DISCRETION
Atmos Advisory is given the authority to exercise discretion on behalf of clients. Atmos Advisory
is considered to exercise investment discretion over a client’s account if it can effect transactions
for the client without first having to seek the client’s consent. Atmos Advisory is given this
authority through a power-of-attorney included in the Agreement. Clients are permitted to request
reasonable limitations on this authority (such as certain securities not to be bought or sold). Atmos
Advisory takes discretion over the following activities:
♦ the securities to be purchased or sold;
♦ the amount of securities to be purchased or sold;
♦ when transactions are made; and
♦ the selection or replacement of the Independent Managers.
Atmos Advisory does not, however, exercise day-to-day discretion over any assets managed by
the Independent Managers. Atmos Advisory manages one or more ERISA accounts which are
deemed non-discretionary per the terms of the Agreement.
ITEM 17. VOTING CLIENT SECURITIES
Atmos Advisory does not accept the authority to vote any proxies and/or other solicitations on
behalf of clients. Thus, unless an Independent Manager[s] assumes proxy voting responsibility
for client assets, clients maintain exclusive responsibility for: (1) directing how proxies solicited
by issuers of securities owned by the client shall be voted, and (2) making all elections related to
any mergers, acquisitions, tender offers, bankruptcy proceedings or other event types pertaining to
the client’s investment assets.
Clients will receive proxies directly from the relevant Financial Institution and should contact the
Firm at (412) 497-1766 with questions about proxies and/or other such solicitations.
ITEM 18. FINANCIAL INFORMATION
Atmos Advisory does not solicit client fees six months or more in advance. The Firm is unaware
of any financial condition that is reasonably likely to impair its ability to meet its contractual
commitments relating to its discretionary authority over client accounts. Atmos Advisory has not
been the subject of a bankruptcy petition.
TABLE 1. RISK CONSIDERATIONS
As disclosed in Item 8 above, please read this important summary of primary investment risks and
the steps taken by Atmos Advisory to minimize these risks. Please note this list is intended to
highlight primary risks of investing assets with the Firm but does not capture all such risks.
18
Risk
Risk of Loss -
General
Disclosure Statement
Investing in securities involves risk of loss
that clients should be prepared to bear.
Mitigation
Diversification, asset
allocation, rebalancing
Market Fluctuation
Investment plan suited to
client objectives, liquidity
needs, and time horizon
Asset Class
Correlations
Constant monitoring,
rebalancing,
communication, and
disclosure
Mutual Funds
Portfolio construction and
diversification, and
ongoing due diligence on
holdings
Exchange-Traded
Funds (ETFs)
Portfolio construction,
diversification, and
ongoing due diligence on
holdings
Financial markets and the value of
investments fluctuate substantially over
time, which may lead to losses in the value
of client portfolios, especially in the short
run.
During times of market turmoil,
correlations between asset classes may
break down, which may result in higher-
than-expected losses for diversified
portfolios.
Mutual fund investing involves risk;
principal loss is possible. Investors will pay
fees and expenses, even when investment
returns are flat or negative. Investors cannot
influence the securities bought and sold, nor
the timing of transactions which may result
in undesirable tax consequences.
Additionally, mutual funds incur fees that
are separate from those fees charged by the
adviser.
ETFs are subject to risks similar to those of
stocks and are not suitable for all investors.
Shares can be bought and sold through a
broker, and the selling shareholder may
have to pay brokerage commissions in
connection with the sale. Investment returns
and principal value will fluctuate so that
when shares are redeemed, they may be
worth more or less than original cost.
Shares are only redeemable directly from
the fund. There can be no assurance that an
active trading market for the shares will
develop or be maintained, and shares may
trade at, above or below their NAV.
Additionally, the value of the investment
will fluctuate in response to the
performance of the underlying benchmark.
ETFs incur fees that are separate from those
fees charged by the adviser. Accordingly,
19
Risk
Mitigation
Fixed Income
Vary maturities, careful
selection of securities to
match client risk tolerance
and time horizon
Foreign Securities
Diversification and
limitations on exposure
Inflation Risk
Security selection
Currency Risk
Diversification and limit
investment in international
securities
Liquidity Risk
Portfolio construction
concentrated in mutual
funds and ETFs, and
longer-term time horizon
Income Risk
Disclosure Statement
our investments in ETFs will result in the
layering of fees and expenses.
Prices of fixed income (debt) securities
typically decrease in value when interest
rates rise. This risk is usually greater for
longer-maturity debt securities. Investments
in debt with lower credit ratings (and non-
rated credits) are subject to a greater risk of
loss to principal and interest than those with
higher credit ratings.
Investments in foreign securities often
introduce greater volatility to client
portfolios. Additional risks include political
risk, currency translation risk, and lack of
transparency (accounting methods,
regulatory reporting requirements,
shareholder protection rules, etc.). These
factors at times result in large price swings
of foreign security investments, and greater
risk of loss.
Risk that increases in the prices of goods
and services, and therefore the cost of
living, reduce consumer purchasing power.
Currency risk is evident due to the free-
floating mechanism present in global
foreign exchange markets. With a few
notable exceptions, the value of most global
currencies freely floats against one another.
U.S. companies and portfolios with non-
dollar exposure directly assume foreign
exchange risk.
Risk evident when investors do not have
full access to their funds and/or when assets
cannot be converted into cash according to
normal market settlement standards.
Liquidity risk is generally higher for small
capitalization stocks, alternative assets, and
private placement securities.
Risk that an investment strategy designed to
generate a sufficient income, resulting in
the inability to sustain a desired lifestyle
Portfolio construction and
financial planning to avoid
asset depletion
20
Risk
Mitigation
Independent
Manager Selection
Ongoing monitoring and
replacement of
independent managers as
necessary
Disclosure Statement
and/or the need to sell other assets to
generate desired income.
When client assets are invested by outside
professional asset managers, the adviser
does not directly control the investment
decisions of outside managers. An
independent manager may stray from its
stated investment strategy (known as "style
drift") or make poor investment decisions
which place client assets at greater risk of
loss.
21
RICHARD I. LERACH
CRD # 4555209
Atmos Advisory, LLC
1001 Liberty Avenue, Suite 500
Pittsburgh, PA 15222
(412) 497-1766
Brochure Supplement
Dated March 24, 2025
This Brochure Supplement provides information about Richard I. Lerach that supplements the
Disclosure Brochure of Atmos Advisory, LLC (hereinafter “Atmos Advisory”), a copy of which
you should have received. Please contact Atmos Advisory’s Chief Compliance Officer at (412)
497-1766 if you have not received the Disclosure Brochure or if you have any questions about
the contents of this Brochure Supplement. Additional information about Richard I. Lerach is
available on the SEC’s website at www.adviserinfo.sec.gov.
22
Item 2. Educational Background and Business Experience
Born 1975
Post-Secondary Education
♦ Pennsylvania State University, B.S., Business Administration, 1998
Recent Business Background
♦ Atmos Advisory, LLC, Principal & Managing Partner, 01/12 – Present
♦ The LRM Group, LLC, Insurance Agent, 06/24 - Present
♦ The Leaders Group, Inc., Registered Representative,06/24 -Present
♦ M Holdings Securities, Inc., Registered Representative, 01/12 – 6/24
♦ Gateway Financial Group, Inc., Insurance Agent, 01/12 – 6/24
♦ Morgan Stanley Smith Barney, Financial Advisor, 06/09 – 01/12
♦ Citigroup Global Markets Inc., Financial Advisor, 05/02 – 06/09
Professional Designations
Richard I. Lerach is certified for financial planning services in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, he may refer to himself as
a CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional and may use these
and CFP Board’s other certification marks (the “CFP Board Certification Marks”). The CFP®
certification is voluntary. No federal or state law or regulation requires financial planners to hold
the CFP® certification. You may find more information about the CFP® certification at
www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience,
and ethics. To become a CFP® professional, an individual must fulfill the following requirements:
♦ Education – Earn a bachelor’s degree or higher from an accredited college or university
and complete CFP Board-approved coursework at a college or university through a CFP
Board Registered Program. The coursework covers the financial planning subject areas
CFP Board has determined are necessary for the competent and professional delivery of
financial planning services, as well as a comprehensive financial plan development
capstone course. A candidate may satisfy some of the coursework requirement through
other qualifying credentials.
♦ Examination – Pass the comprehensive CFP® Certification Examination. The examination
is designed to assess an individual’s ability to integrate and apply a broad base of financial
planning knowledge in the context of real-life financial planning situations.
♦ Experience – Complete 6,000 hours of professional experience related to the personal
financial planning process, or 4,000 hours of apprenticeship experience that meets
additional requirements.
23
♦ Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former
CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code
of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical
and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board
Certification Marks:
♦ Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a
commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore,
act in the best interests of the client, at all times when providing financial advice and
financial planning. CFP Board may sanction a CFP® professional who does not abide by
this commitment, but CFP Board does not guarantee a CFP® professional's services. A
client who seeks a similar commitment should obtain a written engagement that includes a
fiduciary obligation to the client.
♦ Continuing Education – Complete 30 hours of continuing education every two years to
maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and
keep up with developments in financial planning. Two of the hours must address the Code
and Standards.
Richard I. Lerach holds the professional designations of Accredited Investment Fiduciary
(“AIF®”). The AIF® designation is a credential awarded by the Center for Fiduciary Studies,
LLC, a division of Fiduciary360, to individuals who meet its professional, educational, and ethical
requirements, and demonstrate a commitment to fiduciary principles. The AIF® training
curriculum culminates in a 60- question exam on the fiduciary practices, which requires a passing
score of at least 75 percent. AIF® designees must agree to abide by the applicable code of ethics
and complete six hours of continuing education each year on an ongoing basis. For more
information about this credential, go to https://www.fi360.com/.
Item 3. Disciplinary Information
Atmos Advisory is required to disclose information regarding any legal or disciplinary events
material to a client’s evaluation of Richard I. Lerach. Atmos Advisory has no information to
disclose in relation to this Item.
Item 4. Other Business Activities
Registered Representative of a Broker-Dealer
Richard I. Lerach is a registered representative of The Leaders Group, Inc., an SEC registered
broker-dealer and member of FINRA. In this capacity, Richard I. Lerach provides securities
brokerage services and implements securities transactions under a commission-based arrangement
in certain situations. Richard I. Lerach is entitled to a portion of the brokerage commissions paid
to The Leaders Group, Inc. as well as a share of any ongoing distribution or service (“trail”) fees
from the sale of mutual funds, which are held outside client advisory accounts.
24
A conflict of interest exists when Richard I. Lerach recommends the purchase of securities where
he receives commissions or other additional compensation as a result. This practice gives him an
incentive to recommend investment products based on compensation received rather than on the
client’s needs. Supervised Persons are bound by the Atmos Advisory compliance program which
is designed to facilitate compliance with applicable rules and regulations and seek to treat all
clients fairly.
Licensed Insurance Agent
Richard I. Lerach is a licensed insurance agent with. The LRM Group, LLC and in such capacity,
recommends, on a fully disclosed commission basis, the purchase of certain insurance products.
A conflict of interest exists to the extent that The LRM Group, LLC. recommends the purchase of
insurance products where Richard I. Lerach receives insurance commissions or other additional
compensation. The LRM Group, LLC and Atmos Advisory seek to ensure that all
recommendations are made in the best interests of clients regardless of any additional
compensation earned.
Member of the Board of Directors
Richard I. Lerach acts as a general board member and serves on the investment committees for
The Children’s Museum of Pittsburgh, The Mt. Lebanon Community Foundation, St. Paul's
Episcopal Church and The Pittsburgh Foundation. Richard I. Lerach does not receive any
compensation for his participation on the boards. The amount of time devoted to these entities is
not material relative to his Atmos Advisory duties.
Item 5. Additional Compensation
As a licensed insurance agent, Mr. Lerach refers clients where appropriate to other insurance firms
for the purchase of certain insurance product and receives a portion of the commission earned by
such insurance firms. We do not believe there is any conflict of interest resulting from such
referrals, as these insurance products are different from the investment and securities products
provided by Atmos Advisory or Mr. Lerach. Moreover, neither the amount of time devoted to
these referrals, not the compensation from such referral, is material to the business of Atmos
Advisory or Mr. Lerach.
Item 6. Supervision
Richard I. Lerach is the Principal and Managing Partner of Atmos Advisory and is generally
responsible for his own supervision. Richard I. Lerach seeks to ensure that investments are suitable
for his individual clients and consistent with their individual needs, goals, objectives, and risk
tolerance, as well as any restrictions requested by Atmos Advisory’s clients. He is subject to the
compliance policies and procedures of Atmos Advisory, The Leaders Group, Inc., and The LRM
Group, LLC.
25
KEVIN P. SIEBERT
CRD # 4946233
Atmos Advisory, LLC
1001 Liberty Avenue, Suite 500
Pittsburgh, PA 15222
(412) 497-1766
Brochure Supplement
Dated March 24, 2025
This Brochure Supplement provides information about Kevin P. Siebert that supplements the
Disclosure Brochure of Atmos Advisory, LLC (hereinafter “Atmos Advisory”), a copy of which
you should have received. Please contact Atmos Advisory’s Chief Compliance Officer at (412)
497-1766 if you have not received the Disclosure Brochure or if you have any questions about
the contents of this Brochure Supplement. Additional information about Kevin P. Siebert is
available on the SEC’s website at www.adviserinfo.sec.gov.
26
Item 2. Educational Background and Business Experience
Born 1984
Post-Secondary Education
♦ University of Pittsburgh, B.S., Finance, 2006
Recent Business Background
♦ Atmos Advisory, LLC, Associate, 01/12 – Present
♦ The LRM Group, LLC, Insurance Agent, 06/24 - Present
♦ The Leaders Group, Inc., Associate, 06/24 - Present
♦ M Holdings Securities, Inc., Registered Representative, 01/12 – 06/24
♦ Gateway Financial Group, Inc., Insurance Agent, 01/12 – 06/24
♦ Morgan Stanley Smith Barney, Portfolio Management Associate, 04/07 – 01/12
Professional Designations
Kevin P. Siebert is certified for financial planning services in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, he may refer to himself as
a CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional and may use these
and CFP Board’s other certification marks (the “CFP Board Certification Marks”). The CFP®
certification is voluntary. No federal or state law or regulation requires financial planners to hold
the CFP® certification. You may find more information about the CFP® certification at
www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience,
and ethics. To become a CFP® professional, an individual must fulfill the following requirements:
♦ Education – Earn a bachelor’s degree or higher from an accredited college or university
and complete CFP Board-approved coursework at a college or university through a CFP
Board Registered Program. The coursework covers the financial planning subject areas
CFP Board has determined are necessary for the competent and professional delivery of
financial planning services, as well as a comprehensive financial plan development
capstone course. A candidate may satisfy some of the coursework requirement through
other qualifying credentials.
♦ Examination – Pass the comprehensive CFP® Certification Examination. The examination
is designed to assess an individual’s ability to integrate and apply a broad base of financial
planning knowledge in the context of real-life financial planning situations.
♦ Experience – Complete 6,000 hours of professional experience related to the personal
financial planning process, or 4,000 hours of apprenticeship experience that meets
additional requirements.
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♦ Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former
CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code
of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical
and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board
Certification Marks:
♦ Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a
commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore,
act in the best interests of the client, at all times when providing financial advice and
financial planning. CFP Board may sanction a CFP® professional who does not abide by
this commitment, but CFP Board does not guarantee a CFP® professional's services. A
client who seeks a similar commitment should obtain a written engagement that includes a
fiduciary obligation to the client.
♦ Continuing Education – Complete 30 hours of continuing education every two years to
maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and
keep up with developments in financial planning. Two of the hours must address the Code
and Standards.
Item 3. Disciplinary Information
Atmos Advisory is required to disclose information regarding any legal or disciplinary events
material to a client’s evaluation of Kevin P. Siebert. Atmos Advisory has no information to
disclose in relation to this Item.
Item 4. Other Business Activities
Registered Representative of a Broker-Dealer
Kevin P. Siebert is a registered representative of The Leaders Group, Inc., an SEC registered
broker-dealer and member of FINRA. In this capacity, Kevin P. Siebert provides securities
brokerage services and implements securities transactions under a commission-based arrangement
in certain situations. Kevin P. Siebert is entitled to a portion of the brokerage commissions paid to
The Leaders Group, Inc. as well as a share of any ongoing distribution or service (“trail”) fees
from the sale of mutual funds, which are held outside client advisory accounts.
A conflict of interest exists when Kevin P. Siebert recommends the purchase of securities where
he receives commissions or other additional compensation as a result. This practice gives him an
incentive to recommend investment products based on compensation received rather than on the
client’s needs. Supervised Persons are bound by the Atmos Advisory compliance program which
is designed to facilitate compliance with applicable rules and regulations and seek to treat all
clients fairly.
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Licensed Insurance Agent
Kevin P. Siebert is a licensed insurance agent with The LRM Group, LLC, and in such capacity,
recommends, on a fully- disclosed commission basis, the purchase of certain insurance products.
A conflict of interest exists to the extent that The LRM Group, LLC, Inc. recommends the purchase
of insurance products where Kevin P. Siebert receives insurance commissions or other additional
compensation. The LRM Group, LLC and Atmos Advisory seek to ensure that all
recommendations are made in the best interests of clients regardless of any additional
compensation earned.
Item 5. Additional Compensation
Atmos Advisory is required to disclose information regarding any arrangement under which Kevin
P. Siebert receives an economic benefit from someone other than a client for providing investment
advisory services. Atmos Advisory has no information to disclose in relation to this Item.
Item 6. Supervision
Richard I. Lerach, the Firm’s Managing Member, is generally responsible for supervising Kevin
P. Siebert’s advisory activities on behalf of Atmos Advisory. Mr. Lerach can be reached at the
firm’s main telephone number listed on the cover page of this Brochure Supplement.
Atmos Advisory supervises its personnel and the investments made in client accounts. Atmos
Advisory monitors the investments recommended by Kevin P. Siebert to ensure they are suitable
for the particular client and consistent with their investment needs, goals, objectives, and risk
tolerance, as well as any restrictions previously requested by the client. Atmos Advisory
periodically reviews the advisory activities of Kevin P. Siebert, which may include reviewing
individual client accounts and correspondence (including e-mails) sent and received by Kevin P.
Siebert. He is subject to the compliance policies and procedures of Atmos Advisory, The Leaders
Group, Inc, and The LRM Group, LLC.
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NICOLE COSNOTTI
CRD # 4147773
Atmos Advisory, LLC
1001 Liberty Avenue, Suite 500
Pittsburgh, PA 15222
(412) 497-1766
Brochure Supplement
Dated March 24, 2025
This Brochure Supplement provides information about Nicole Cosnotti that supplements the
Disclosure Brochure of Atmos Advisory, LLC (hereinafter “Atmos Advisory”), a copy of which
you should have received. Please contact Atmos Advisory’s Chief Compliance Officer at (412)
497-1766 if you have not received the Disclosure Brochure or if you have any questions about
the contents of this Brochure Supplement. Additional information about Nicole Cosnotti is
available on the SEC’s website at www.adviserinfo.sec.gov.
30
Item 2. Educational Background and Business Experience
Born 1971
Post-Secondary Education
♦ Indiana University of Pennsylvania, B.S., Food and Nutrition, 1993
Recent Business Background
♦ Atmos Advisory, LLC, Associate, 07/15 – Present
♦ The Leaders Group, Inc., Registered Representative, 06/01/2024 to Present
♦ Gateway Financial Group, Inc., Staff, 07/15 – 06/24
♦ M Holdings Securities, Inc., Registered Representative, 07/15 – 06/24
♦ LPL Financial, Director of Operations, 09/13 – 05/15
♦ LPL Financial, Manager of Operations, 11/03 – 09/13
Item 3. Disciplinary Information
Atmos Advisory is required to disclose information regarding any legal or disciplinary events
material to a client’s evaluation of Nicole Cosnotti. Atmos Advisory has no information to
disclose in relation to this Item.
Item 4. Other Business Activities
Nicole Cosnotti is a registered representative of The Leaders Group. Inc., an SEC registered
broker-dealer and member of FINRA. In this capacity, Nicole Cosnotti provides securities
brokerage services and implements securities transactions under a commission-based arrangement
in certain situations. Nicole Cosnotti is entitled to a portion of the brokerage commissions paid to
The Leaders Group, Inc., as well as a share of any ongoing distribution or service (“trail”) fees
from the sale of mutual funds, which are held outside client advisory accounts.
A conflict of interest exists when Nicole Cosnotti recommends the purchase of securities where
he receives commissions or other additional compensation as a result. This practice gives her an
incentive to recommend investment products based on compensation received rather than on the
client’s needs. Supervised Persons are bound by the Atmos Advisory compliance program which
is designed to facilitate compliance with applicable rules and regulations and seek to treat all
clients fairly.
Item 5. Additional Compensation
Atmos Advisory is required to disclose information regarding any arrangement under which
Nicole Cosnotti receives an economic benefit from someone other than a client for providing
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investment advisory services. Atmos Advisory has no information to disclose in relation to this
Item.
Item 6. Supervision
Richard I. Lerach, the Firm’s Managing Member, is generally responsible for supervising Nicole
Cosnotti’s advisory activities on behalf of Atmos Advisory. Mr. Lerach can be reached at the
firm’s main telephone number listed on the cover page of this Brochure Supplement.
Atmos Advisory supervises its personnel and the investments made in client accounts. Atmos
Advisory monitors the investments recommended by Nicole Cosnotti to ensure they are suitable
for the particular client and consistent with their investment needs, goals, objectives, and risk
tolerance, as well as any restrictions previously requested by the client. Atmos Advisory
periodically reviews the advisory activities of Nicole Cosnotti, which may include reviewing
individual client accounts and correspondence (including e-mails) sent and received by Nicole
Cosnotti. She is subject to the compliance policies and procedures of Atmos Advisory, and The
Leaders Group, Inc.
32