Compliance & Disclosures: Transparency First

Access our regulatory documents, privacy policy, and required disclosures in compliance with SEC and New York State regulations for investment advisers.

Regulatory Disclosures

As a New York state-registered investment adviser, we provide the following required disclosures:

✓ Registration Status

Aturan Capital Management, LLC (CRD# 338443) is registered as an investment adviser with the New York State Attorney General's Office. Registration does not imply a certain level of skill or training.

✓ No Custody or Discretion

We do not take custody of client assets or accept discretionary trading authority. Clients maintain full control over their accounts and execute trades themselves.

✓ Fee-Only Structure

Our standard advisory fee is $350/hour. For workshops or seminars with three or more participants, the fee is $200/hour. We receive no commissions, referral fees, or other incentives that could create conflicts of interest.

✓ Disciplinary History

The firm and its personnel have no disciplinary history. For more details, view our Form ADV on the SEC's Investment Adviser Public Disclosure website.

✓ Client Delivery Requirements

We deliver Form ADV Part 2A and 2B to clients and prospective clients, along with annual privacy notices as required under Regulation S-P.

✓ Recordkeeping & Examinations

We maintain required books and records and are subject to examinations by New York state regulators.

Download Regulatory Documents

Access our Form ADV brochures and related documents. These are provided in compliance with SEC and New York State requirements for investment advisers.

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Form ADV (Full Registration)

View our complete Form ADV filing, including Parts 1 and 2, on the SEC's public database.

View on IAPD
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Form ADV Part 2A (Firm Brochure)

Detailed information about our services, fees, practices, and potential conflicts of interest.

Download PDF
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Form ADV Part 2B (Brochure Supplement)

Information about our supervised persons, including education, experience, and disciplinary history.

Download PDF

Documents are current as of October 31, 2025. Contact us for the most recent versions.

Privacy Policy

At Aturan Capital Management, LLC, we are committed to protecting your nonpublic personal information and ensuring transparency in how we collect and use data. This notice describes our privacy practices in compliance with SEC Regulation S-P and New York State requirements.

1

Information We Collect

We collect nonpublic personal information that you provide voluntarily, such as your name, address, phone number, email, Social Security number, assets, income, investment objectives, and information provided during consultations, forms, or account openings.

2

How We Use Information

Your information is used solely to provide investment advisory services, develop investment plans and strategies, and comply with regulatory requirements. We do not sell or share your personal information with non-affiliated third parties for marketing purposes.

3

Sharing Practices

We may share information only as required by law or regulation (e.g., with regulators), or with your consent (e.g., with your custodian or other service providers). Otherwise, nonpublic personal information is not disclosed to non-affiliated third parties.

4

Website Analytics and Cookies

Our website uses Google Analytics to understand visitor interactions and improve user experience. Google Analytics may collect IP addresses (anonymized where possible), pages visited, time spent on pages, and general browser or device behavior. This data is collected via cookies and is used solely for analytics and reporting purposes. It does not include nonpublic personal information you provide directly to us. You may opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-on.

5

Safeguards

We maintain physical, electronic, and procedural safeguards to protect your information, including secure storage of records, access controls, authentication, regular review of security procedures, and incident response protocols for potential breaches.

6

Your Rights

You may request access to personal information we maintain, opt out of optional data sharing, and contact us with questions regarding your privacy. Contact us at matthew.engel@aturancapital.com for access requests or privacy inquiries.

This notice is provided annually to clients and is updated whenever we implement changes to our privacy practices.

Questions About Compliance?

Contact us for more information or to request printed copies of documents.