Atlas Capital Management Corp

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SECURITIES EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE, CEASE AND DESIST
3.
Date Initiated (MM/DD/YYYY): 
09/01/2014
 Exact
 Explanation
If not exact, provide explanation:
EXAMINATION WHICH LED TO FINAL ACTION BEGAN IN SEPT. 2014
4.
Docket/Case Number:
3-18319
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
NONE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ALLEGATIONS AGAINST FIRM WERE RELATED TO NOT DIRECTING AN UNAFFILIATED THIRD PARTY FIRM TO OPEN CUSTODIAL ACCOUNTS FOR CLIENTS
WHICH COULD ACCEPT A LESS EXPENSIVE MUTUAL FUND SHARE CLASS AND LACK OF ADEQUATE POLICIES AND PROCEDURES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
10/16/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?

 Monetary/Fine Amount: $ 80,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NONE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
NONE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON OCTOBER 16, 2017, ATLAS EXECUTED A CONSENT ORDER WITH THE SECURITIES AND EXCHANGE COMMISSION ("SEC"), WHICH INCLUDED THE
FIRM'S CONSENT TO ENTRY OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING
REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. FROM 2012-2016, ATLAS RECEIVED NUMEROUS CLIENT REFERRALS FROM AN UNAFFILIATED
FIRM. THE UNAFFILIATED FIRM WOULD TYPICALLY RECOMMEND AND OPEN SERVICE CLASS CUSTODIAL ACCOUNTS FOR CLIENTS, WHICH ACCOUNTS
COULD ONLY ACCEPT SERVICE CLASS MUTUAL FUND SHARE CLASSES THAT PAID 12B-1 COMPENSATION AND SHAREHOLDER SERVICE FEES TO THE
REGISTERED REPRESENTATIVES OF THE UNAFFILIATED REFERRING FIRM. BECAUSE THE TYPE OF ACCOUNT OPENED WITH THE MUTUAL FUND
DISTRIBUTOR DICTATED THE TYPE OF SHARE CLASS THAT COULD BE PURCHASED, THE SELECTION AND OPENING OF A PARTICULAR ACCOUNT TYPE BY
THE REFERRING FIRM WAS TANTAMOUNT TO THE SELECTION OF A PARTICULAR SHARE CLASS. ATLAS HAD NO AUTHORITY OR ABILITY WHATSOEVER TO
SELECT OR CHANGE THE TYPE OF CUSTODIAL ACCOUNT MAINTAINED BY THE CLIENT AND, AS A RESULT, ONCE A SERVICE CLASS ACCOUNT WAS
OPENED, ATLAS HAD NO AUTHORITY OR ABILITY TO SELECT LESS EXPENSIVE MUTUAL FUND SHARE CLASS OPTIONS. AS SUCH, AFTER A SERVICE CLASS
ACCOUNT WAS OPENED, ATLAS INVESTED THE REFERRED CLIENTS IN THE ONLY SHARE CLASS AVAILABLE FOR SUCH ACCOUNTS: THE SERVICE CLASS
MUTUAL FUND SHARE CLASS. MUTUAL FUND SHARE CLASSES WHICH PAY 12B-1 AND/OR SERVICE FEE COMPENSATION TYPICALLY ARE SUBJECT TO
HIGHER EXPENSE RATIOS THAN THOSE WHICH DO NOT PAY SUCH COMPENSATION. THEREFORE, EVEN THOUGH ATLAS DID NOT RECEIVE ANY PORTION
OF THE 12B-1 COMPENSATION OR SERVICE FEES, AND DID NOT SELECT THE INITIAL OR ONGOING SERVICE CLASS ACCOUNT TYPE, BY INVESTING THE
REFERRED CLIENTS IN SUCH SERVICE CLASS SHARES, ATLAS DID NOT INFORM CLIENTS OR THE UNAFFILIATED FIRM OF THE ADVISABILITY OF
UTILIZING A LESS EXPENSIVE SHARE CLASS. AS A RESULT, THE TERMS OF THE CONSENT ORDER INCLUDE REPRESENTATIONS THAT ATLAS WILLFULLY
VIOLATED SECTION 206(2) OF THE ADVISERS ACT OF 1940, WHICH PROHIBITS "ANY TRANSACTION, PRACTICE, OR COURSE OF BUSINESS WHICH
OPERATES AS A FRAUD OR DECEIT UPON ANY CLIENT OR PROSPECTIVE CLIENT," AS WELL AS SECTION 206(4) OF THE ACT AND RULE 206(4)(7)
THEREUNDER, WHICH REQUIRES ADVISORY FIRMS TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO
PREVENT VIOLATIONS OF THE ACT AND ITS RULES, DUE TO: (1) ATLAS'S FAILURE TO INFORM CLIENTS AND THE REFERRING FIRM THAT THE IMPACTED
CLIENTS WERE NOT INVESTED IN THE LEAST EXPENSIVE MUTUAL FUND SHARE CLASSES, SINCE THE CLIENT AND REFERRING FIRM WERE THE ONLY
PARTIES WHO COULD SELECT THE CUSTODIAL ACCOUNT TYPE; AND (2) THE FIRM'S FAILURE TO HAVE COMPLIANCE PROCEDURES WHICH ADDRESSED
THE EVALUATION OF ANNUAL FEES OR EXPENSES ASSOCIATED WITH MUTUAL FUND SHARE CLASSES. NOTE THAT A "WILLFUL" VIOLATION DOES NOT
REQUIRE THAT ATLAS BE AWARE THAT IT IS IN VIOLATION OF THE ADVISERS ACT OF 1940 OR THE RULES PROMULGATED THEREUNDER. PURSUANT TO
THE CONSENT ORDER, ATLAS AGREED TO CEASE AND DESIST FROM COMMITTING OR CAUSING VIOLATIONS OF THE ABOVE REFERENCED SECTIONS OF
THE ADVISERS ACT AND THE RULES PROMULGATED THEREUNDER, WAS CENSURED, AND WAS SUBJECT TO A CIVIL MONEY PENALTY IN THE AMOUNT OF
$80,000. ON NOTIFICATION BY THE SEC, ATLAS TOOK IMMEDIATE CORRECTIVE ACTION BY CEASING TO INVEST CLIENTS IN THE SERVICE CLASS
SHARES AND BY DIRECTING THE UNAFFILIATED FIRM TO CONVERT ALL SERVICE CLASS ACCOUNTS TO ACCOUNT TYPES THAT COULD SUPPORT LOWER
COST MUTUAL FUND SHARE CLASSES. ATLAS HAS NOT INVESTED ANY CLIENTS IN SERVICE CLASS SHARES SINCE THIS TIME.