Atlantic Capital Management of Florida, Inc., with offices in West Palm Beach, was incorporated on June 28^th, 1995.

Atlantic Capital furnishes investment supervisory services that involve the continuous management of client portfolios with the goal of meeting client objectives within well-defined risk/reward parameters.  Before a client is accepted, we explain that a risk free, positive return can be achieved without using our service or without employing agents of any kind.  A simple Treasury bill rollover program at the Federal Reserve Bank will assure consistent positive results.  We then demonstrate that a program that conservative has provided the lowest return among investment alternatives and outline the merits of a portfolio allocated among equities and fixed income securities.  After all the risk factors are presented and understood, we establish an asset allocation and security suitability profile that is specific to that client.  These do not change with market conditions but can be reset if the client's financial situation or comfort level with risk changes.  We then implement the strategy using a broker/custodian arrangement determined by the client and report quarterly on the progress toward meeting the specific objectives established.

Fees are billed quarterly and are calculated based on an account's market value at the time of the billing.  The first fee is due within thirty (30) days of the execution of the investment advisory agreement.  Termination of services is upon written notice at any time, effective when received by the other party. 

Our work is centered on listed and over the counter equity securities, convertible securities, corporate debt securities, U.S. Government securities, municipal bonds, and short term instruments.  We focus on domestic issues but we may utilize foreign securities if they meet our standards and are suitable for a client.  We do not select mutual funds for a client and, if a client chooses to have such funds in a portfolio we manage, we do not include those funds in our fee calculation.

We rely on fundamental analysis for investment selection although some technical analysis is used in timing the purchase and sale of securities.  Common stocks are evaluated first on a company's business model and its ability to execute that model given the strength of current management.  We estimate the health of each industry and a company's strategic place in that industry.  For relative strength we use a proprietary model, the Nolan Quotient, which revises standard price earnings multiples by rewarding companies with excessive cash and short term holdings and penalizes those with excessive debt.  The Quotient also places a premium on a consistently high rate of earnings growth.

We require portfolio managers to have a minimum of five (5) years experience in the investment industry.  No specific formal education is required, but a Bachelor of Science degree or extensive industry experience is necessary.

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We use the Internet as an investment research tool, accessing independent information sources and obtaining company filings.  With respect to our brokerage relationships, we look for standard industry discounts for our clients and will block trades if that practice lowers the unit cost for a security.

We do not hold client assets, leaving that task to brokers and bank custodians.  The selection of a broker/custodian is a client decision although we will provide a list of the banks and brokers that currently house client assets.  Atlantic Capital personnel are prohibited from receiving commissions, gifts, or remuneration of any kind from brokerage firms or bank custodians.

Accounts are reviewed at least monthly as to consistency of asset allocation and adherence to client goals and objectives.  A portfolio summary and detailed portfolio appraisal is forwarded to the client on a quarterly basis with a letter detailing transactions and reviewing current economic and market conditions.  The frequency of client meetings each year varies with individual client requirements.

Rev. Oct. 2006