ADV Part 2 / Disclosures

1 
 
Part 2A of Form ADV:  Firm Brochure 
 
 
 
Form ADV, Part 2A, Item 1 
Cover Page 
 
 
 
 
 
 
 
2015 Grand Avenue, Suite 100 
Des Moines, Iowa 50312 
 
 
Tel: (515) 207-3310 
 
 
 
 
 
 
March 19, 2025 
 
 
 
FORM ADV PART 2 
FIRM BROCHURE 
 
This brochure provides information about the qualifications and business practices of Altitude 
Capital Management LLC. If you have any questions about the contents of this brochure, please 
contact us at (515) 207-3310. The information in this brochure has not been approved or verified 
by the United States Securities and Exchange Commission or by any state securities authority.  
 
Additional information about Altitude Capital Management LLC is also available on the SEC’s 
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Altitude Capital 
Management LLC is 329366. 
 
Altitude Capital Management LLC is a Registered Investment Adviser. Registration with the United 
States Securities and Exchange Commission or any state securities authority does not imply a 
certain level of skill or training.

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Form ADV, Part 2A, Item 2  
Material Changes 
Annual Update 
 
The Material Changes section of this brochure will be updated annually or when material 
changes occur since the previous release of the Firm Brochure.  Each year, we will ensure that 
you receive a summary of any material changes to this and subsequent brochures by April 30th.  
We will further provide you with our most recent brochure at any time at your request, without 
charge.  You may request a brochure by contacting us at (515) 207-3310. 
 
Material Changes since the Last Update 
 
Altitude Capital Management LLC was established as a new Registered Investment Advisor in 
January 2024 with the Securities and Exchange Commission (“SEC”), under the rules and 
regulations of the US Investment Advisers Act of 1940, as amended (the "Advisers Act").  The 
following material changes were made since the last annual filing on March 18, 2024: 
 
• None

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Form ADV, Part 2A, Item 3    
Table of Contents 
 
Advisory Business…………………………………………………………… 4 
Fees and Compensation…………………………………………………….. 5 
Performance-Based Fees and Side-By-Side Management……………. 7 
Types of Clients………………………………………………………………. 7 
Methods of Analysis, Investment Strategies, and Risk of Loss……… 7 
Disciplinary Information…………………………………………………….. 9 
Other Financial Industry Activities and Affiliations……………………. 10 
Code of Ethics, Participation or Interest in Client Transactions and Personal 
Trading……………………………………………………………… 10 
Brokerage Practices………………………………………………………….. 11 
Review of Accounts………………………………………………………….. 12 
Client Referrals and Other Compensation……………………………….. 13 
Custody………………………………………………………………………… 13 
Investment Discretion……………………………………………………….. 13 
Voting Client Securities……………………………………………………… 13 
Financial Information………………………………………………………… 14 
Requirements for State-Registered Advisers…………………………… 14

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Form ADV Part 2A, Item 4    
Advisory Business 
Altitude Capital Management LLC (hereinafter called “ACM”) is a Registered Investment 
Adviser based in Des Moines, Iowa, and incorporated under the laws of the State of Iowa.  ACM 
is owned by Charles Johnson and Mitchell Whitney.  ACM is registered with the SEC and 
subject to the rules and regulations of the US Advisers Act.  Founded in January 2024, ACM 
provides investment advisory services, which may include, but are not limited to, the review of 
client investment objectives and goals, recommending asset allocation strategies of managed 
assets among investment products such as cash, stocks, mutual funds and bonds, annuities, 
and/or preparing written investment strategies. Our investment advice is tailored to meet our 
clients’ needs and investment objectives.  Clients may impose restrictions on investing in certain 
securities or types of securities (such as a product type, specific companies, specific sectors, etc.) 
by providing a signed and dated written notification, of which an e-mail is also an acceptable 
form of notification.  ACM also provides financial planning consulting services including, but 
not limited to, risk assessment/management, investment planning, estate planning, financial 
organization, or financial decision making/negotiation.   
 
ACM provides investment advisory and other financial services through its Investment Advisory 
Representatives ("IAR") to accounts opened with ACM.  Managed Accounts are available to 
individuals and high net worth individuals.     
 
ACM provides discretionary and non-discretionary investment advisory services to some of its 
clients through various managed account programs.  ACM will assist clients in determining the 
suitability of the Managed Account Programs for the client. The IAR is compensated through a 
comprehensive single fee and the account may be assessed other charges associated with 
conducting a brokerage business. ACM and its IAR, as appropriate, will be responsible for the 
following: 
• Performing due diligence 
• Recommending strategic asset and style allocations 
• Providing research on investment product options, as needed 
• Providing client risk profile questionnaire 
• Obtaining investment advisory contract from client with required financial, risk tolerance, 
suitability and investment vehicle selection information for each new account 
• Performing client suitability check on account documentation, review the investment 
    objectives and evaluate the investment vehicle selections 
• Providing Firm Brochure (this document) 
 
As of March 12, 2025, the firm has assets under management of Discretionary:  $49,400,000 
AUM and Non-Discretionary:  $0 AUM.

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Form ADV, Part 2A, Item 5 
Fees and Compensation 
The following types of fees will be assessed: 
 
Asset Management – Fees are charged monthly in arrears and are based primarily on asset size 
and the level of complexity of the services provided.  In individual cases, ACM has the sole 
discretion to negotiate fees that are lower than the standard fee shown or to waive fees.  Fees are 
not based on the share of capital gains or capital appreciation of the funds or any portion of the 
funds.  Comparable services for lower fees may be available from other sources.  Fees for the 
initial month will be prorated based upon the number of calendar days in the calendar month that 
the advisory agreement is in effect.  Fees are based on the market value of the assets on the last 
business day of the month.  Annual fees are a maximum of 2.0%.  Consulting services are 
included in these fees for asset management services with the exception of unique circumstances 
that may require a separate agreement for financial planning services (description and fees are 
discussed below).  If the situation warrants separate financial planning fees, it will be discussed 
upfront and a separate agreement will be negotiated. 
 
As authorized in the client agreement, the account custodian withdraws Altitude Capital 
Management LLC’s advisory fees directly from the clients’ accounts according to the 
custodian’s policies, practices, and procedures.  The custodial statement includes the amount of 
any fees paid to ACM for advisory services.  You should carefully review the statement from 
your custodian/broker-dealer’s statement and verify the calculation of fees.  Your 
custodian/broker-dealer does not verify the accuracy of fee calculations.     
 
Fees are charged in arrears on a monthly basis, meaning that advisory fees for a month are 
charged on the first day of the following month.  Clients may terminate investment advisory 
services obtained from ACM, without penalty, upon written notice within five (5) business days 
after entering into the advisory agreement with ACM.  The client is responsible for any fees and 
charges incurred by the client from third parties as a result of maintaining the account such as 
transaction fees for any securities transactions executed and account maintenance or custodial 
fees.  Thereafter, the client may terminate advisory services upon written notice delivered to and 
received by ACM.  Clients who terminate investment advisory services during a month are 
charged a prorated advisory fee based on the date of ACM’s receipt of client’s written notice to 
terminate.  Any earned but unpaid fees are immediately due and payable, and any prepaid and 
unearned fees will be immediately refunded.   
 
Financial Planning – Financial planning services are charged in arrears through a fixed fee or 
hourly arrangement as agreed upon between the client and Altitude Capital Management LLC.  
There will never be an instance where $1,200 or more in fees is charged six or more months in 
advance.  Hourly fees are generally charged when the scope of services cannot be determined or 
if the services are limited to one meeting.  Fixed fees are generally quoted to the client for longer 
term consulting projects.  Fees are negotiable and vary depending upon the complexity of the 
client situation and services to be provided.  Hourly fees range from $200 - $500 per hour, 
depending on what is negotiated between ACM and the client.  Similar financial planning 
services may be available elsewhere for a lower cost to the client.  Fixed fees for longer-term

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consulting projects range from $500 to $2,500 per project.  An estimate for total hours and 
charges is determined at the start of the advisory relationship.   
 
Typically, clients will be invoiced monthly for all time spent by ACM as agreed upon by client 
or upon completion of the services if less than a month.  Clients who wish to terminate the 
planning process prior to completion may do so with written notice.  The client may obtain a 
refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period 
by contacting Charles Johnson at (515) 207-3310.  Upon receipt of written notification, any 
earned fee will immediately become due and payable, and any prepaid and unearned fees will be 
immediately refunded.  A client may terminate an advisory agreement without being assessed 
any fees or expenses within five (5) days of its signing.   
 
Additional Fees and Expenses 
In addition to advisory fees paid to ACM as explained above, clients may pay custodial service, 
account maintenance, transaction, and other fees associated with maintaining the account.  These 
fees vary by broker and/or custodian.  Clients should ask ACM for details on transaction fees or 
other custodial fees specific to their account, as these fees are not included in the annual advisory 
fee.  ACM does not share any portion of such fees.  Additionally, for any mutual funds 
purchased, the client may pay their proportionate share of the funds’ distribution, internal 
management, investment advisory and administrative fees.  Such fees are not shared with ACM 
and are compensation to the fund manager.  Clients are urged to read the mutual fund prospectus 
prior to investing. 
 
Mutual fund companies impose internal fees and expenses on clients.  These fees are in addition 
to the costs associated with the investment advisory services as described above.  Complete 
details of such internal expenses are specified and disclosed in each mutual fund company’s 
prospectus.  Clients are strongly advised to review the prospectus(es) prior to investing in such 
securities.     
 
Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that 
would not exist if the purchase or sale were made directly with the mutual fund company.  
Mutual funds held in broker-dealer accounts also charge management fees.  These mutual fund 
management fees may be more or less than the mutual fund management fees charged if the 
client held the mutual fund directly with the mutual fund company.   
Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal 
underwriter, or a distributor without purchasing the services of ACM or paying the advisory fee 
on such shares (but subject to any applicable sales charges).  Certain mutual funds are offered to 
the public without a sales charge.  In the case of mutual funds offered with a sales charge, the 
prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the 
applicable advisory fee.  However, clients would not receive ACM’s assistance in developing an 
investment strategy, selecting securities, monitoring performance of the account, and making 
changes as necessary. 
 
Please refer to Item 12 “Brokerage Practices” of this brochure for additional information.

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Form ADV, Part 2A, Item 6 
Performance-Based Fees and Side-By-Side Management 
Altitude Capital Management LLC does not charge performance-based fees or participate in 
side-by-side management.  Side-by-side management refers to the practice of managing accounts 
that are charged performance-based fees while at the same time managing accounts that are not 
charged performance-based fees.  Performance-based fees are fees that are based on a share of 
capital gains or appreciation of the assets of a client.  Our fees are calculated as described in Fees 
and Compensation section above and are not charged on the basis of performance of your 
advisory account.   
 
 
Form ADV, Part 2A, Item 7 
Types of Clients 
ACM offers investment advisory services to individuals and high net worth individuals.  There is 
no minimum account size to open and maintain an advisory account. 
 
 
Form ADV, Part 2A, Item 8 
Methods of Analysis, Investment Strategies, and Risk of Loss 
ACM’s methods of analysis and investment strategies incorporate the client’s needs and 
investment objectives, time horizon, and risk tolerance.  ACM is not bound to a specific 
investment strategy for the management of investment portfolios, but rather consider the risk 
tolerance levels pre-determined gathered at the account opening, as well as on an on-going basis.  
Examples of methodologies that our investment strategies may incorporate include: 
 
Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix 
of asset classes and the efficient allocation of capital to those assets by matching rates of return 
to a specified and quantifiable tolerance for risk. 
 
Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount 
of securities at regularly scheduled intervals, regardless of the price per share.  This will 
gradually, over time, decrease the average share price of the security.  Dollar-cost averaging 
lessens the risk of investing a large amount in a single investment at the wrong time. 
 
Technical Analysis – involves studying past price patterns and trends in the financial markets to 
predict the direction of both the overall market and specific stocks. 
 
Long-Term Purchases – securities purchased with the expectation that the value of those 
securities will grow over a relatively long period of time, generally greater than one year.

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Short-Term Purchases – securities purchased with the expectation that they will be sold within a 
relatively short period of time, generally less than one year, to take advantage of the securities’ 
short term price fluctuations. 
 
Our strategies and investments may have unique and significant tax implications.  Regardless of 
your account size or other factors, we strongly recommend that you continuously consult with a 
tax professional prior to and throughout the investing of your assets.   
 
Investing in securities involves risk of loss that clients should be prepared to bear.  Although we 
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there 
can be no guarantee that our efforts will be successful.  You should be prepared to bear the risk 
of loss. 
 
All investments involve the risk of loss, including (among other things) loss of principal, a 
reduction in earnings (including interest, dividends, and other distributions), and the loss of 
future earnings.  These risks include market risk, interest rate risk, issuer risk, and general 
economic risk. Regardless of the methods of analysis or strategies suggested for your particular 
investment goals, you should carefully consider these risks, as they all bear risks.   
 
ACM’s primary goal for investing is to help the client maintain purchasing power over the long 
term.  This may result in short term variability and loss of principal.  Time horizon and risk 
tolerance are key determinates of the proper asset allocation.  ACM’s approach focuses on taking 
appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or 
eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or 
lack of portfolio risk). 
 
Below are some more specific risks of investing: 
 
Market Risk.  The prices of securities in which clients invest may decline in response to certain 
events taking place around the world, including those directly involving the companies whose 
securities are owned by the client or an underlying fund; conditions affecting the general 
economy; overall market changes; local, regional or global political, social or economic 
instability; and currency, interest rate and commodity price fluctuations.  Investors should have a 
long-term perspective and be able to tolerate potentially sharp declines in market value. 
 
Management Risk.  ACM’s investment approach may fail to produce the intended results. If our 
perception of the performance of a specific asset class or underlying fund is not realized in the 
expected time frame, the overall performance of client’s portfolio may suffer. 
 
Equity Risk. Equity securities tend to be more volatile than other investment choices. The value 
of an individual mutual fund or ETF can be more volatile than the market as a whole. This 
volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are 
subject to additional risks. Smaller companies may experience greater volatility, higher failure 
rates, more limited markets, product lines, financial resources, and less management experience 
than larger companies.  Smaller companies may also have a lower trading volume, which may 
disproportionately affect their market price, tending to make them fall more in response to 
selling pressure than is the case with larger companies.

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Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and 
principal payments when due. Generally, the lower the credit rating of a security, the greater the 
risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower 
rating, the value of the debt security will decline because investors will demand a higher rate of 
return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A 
nominal interest rate is the sum of a real interest rate and an expected inflation rate.   
 
Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may 
be affected by adverse political, legislative and tax changes, as well as by financial developments 
that affect the municipal issuers.  Because many municipal obligations are issued to finance 
similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.), 
conditions in the sector related to the project can affect the overall municipal market.  Payment 
of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue 
generated by a specific project, the operator of the project, or government appropriation or aid. 
There is a greater risk if investors can look only to the revenue generated by the project. In 
addition, municipal bonds generally are traded in the “over-the-counter” market among dealers 
and other large institutional investors. From time to time, liquidity in the municipal bond market 
(the ability to buy and sell bonds readily) may be reduced in response to overall economic 
conditions and credit tightening. 
 
Investment Companies Risk.  When a client invests in open end mutual funds or ETFs, the 
client indirectly bears its proportionate share of any fees and expenses payable directly by those 
funds.  Therefore, the client will incur higher expenses, many of which may be duplicative.  In 
addition, the client’s overall portfolio may be affected by losses of an underlying fund and the 
level of risk arising from the investment practices of an underlying fund (such as the use of 
derivatives).  ETFs are also subject to the following risks:  (i) an ETF’s shares may trade at a 
market price that is above or below their net asset value; (ii) the ETF may employ an investment 
strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the 
listing exchange’s officials deem such action appropriate, the shares are de-listed from the 
exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases 
in stock prices) halts stock trading generally.  ACM has no control over the risks taken by the 
underlying funds. 
 
 
Form ADV, Part 2A, Item 9 
Disciplinary Information 
Altitude Capital Management LLC or its Principal Executive Officers have not had any 
reportable disclosable events in the past ten years.

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Form ADV, Part 2A, Item 10 
Other Financial Industry Activities and Affiliations 
Charles Johnson and Mitchell Whitney, owners of ACM, are not currently registered with any 
broker dealer. 
 
Neither ACM nor its representatives are registered as a Futures Commission Merchant, 
Commodity Pool Operator, or a Commodity Trading Advisor.   
 
Representatives of ACM may also be licensed insurance agents. From time to time, they will 
offer clients advice or products from those activities. Clients should be aware that these services 
pay a commission and involve a possible conflict of interest, as commissionable products can 
conflict with the fiduciary duties of a registered investment adviser. ACM always acts in the best 
interest of the client; including the sale of commissionable products to advisory clients. Clients 
are in no way required to implement the plan through any representative of ACM in their 
capacity as an insurance agent.  Not more than 30% of representatives’ time is spent on these 
activities. 
 
 
Form ADV, Part 2A, Item 11 
Code of Ethics, Participation or Interest in Client Transactions and 
Personal Trading 
ACM’s Code of Ethics includes guidelines for professional standards of conduct for our 
Associated Persons.  Our goal is to protect client interests at all times and to demonstrate our 
commitment to fiduciary duties of honesty, good faith, and fair dealing.  All of ACM’s 
Associated Persons are expected to strictly adhere to these guidelines.  Persons associated with 
Altitude Capital Management LLC are also required to report any violations to the Code of 
Ethics.  Additionally, the firm maintains and enforces written policies reasonably designed to 
prevent the misuse or dissemination of material, non-public information about our clients or 
client accounts by persons associated with our firm. 
 
ACM and its employees may buy or sell securities that are also held by clients.  It is the expressed 
policy of the advisor that no person employed by our firm purchase or sell any security prior to the 
transaction being implemented for an advisory account; therefore, preventing such employees 
from benefiting from transactions placed on behalf of the advisory clients.  
 
The advisor may have an interest or position in a certain security, which may also be recommended 
to the client.  As these situations may present a conflict of interest, the advisor has established the 
following restrictions in order to ensure its fiduciary responsibilities should this issue ever arise:  
 
1. A director, officer or employee of the advisor shall not buy or sell a security for their 
personal portfolio(s) where their decision is substantially derived, in whole or part, by 
reason of his or her employment, unless the information is also available to  the investing 
public.  No owner/employee of ACM shall prefer their own interest to that of the client.

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2. The advisor maintains a list of all securities held by the company and all directors, officers, 
and employees.  These holdings are reviewed on a quarterly basis by the principal of the 
firm. 
3. The advisor requires that all employees must act in accordance with all applicable Federal 
and State regulations governing registered investment advisors. 
4. The advisor may block personal trades with those of clients but will ensure that clients are 
not at a disadvantage. 
 
ACM’s Code of Ethics is available to you upon request.  You may obtain a copy of our Code of 
Ethics by contacting Charles Johnson at (515) 207-3310. 
 
 
Form ADV, Part 2A, Item 12 
Brokerage Practices 
In order for ACM to provide asset management services, we request you utilize the brokerage 
and custodial services of Charles Schwab & Co., Inc. (“Schwab”) and/or Altruist Financial 
(“Altruist”), for which we have existing relationships.  ACM and Schwab and Altruist are not 
affiliated companies.  In considering which independent qualified custodian will be the best fit 
for ACM’s business model, we are evaluating the following factors, which is not an all-inclusive 
list: 
 
➢ Financial strength 
➢ Reputation 
➢ Reporting capabilities 
➢ Execution capabilities 
➢ Pricing, and 
➢ Types and quality of research 
 
While you are free to choose any broker-dealer or other service provider, we recommend that 
you establish an account with a brokerage firm with which we have an existing relationship.  
Such relationships may include benefits provided to our firm, including, but not limited to 
research, market information, and administrative services that help our firm manage your 
account(s).  We believe that recommended broker-dealers provide quality execution services for 
our clients at competitive prices.  Price is not the sole factor we consider in evaluating best 
execution.   We also consider the quality of the brokerage services provided by the recommended 
broker-dealers, including the value of research provided, the firm’s reputation, execution 
capabilities, commission rates, and responsiveness to our clients and our firm.      
 
You may direct us in writing to use a particular broker-dealer to execute some or all of the 
transactions for your account.  If you do so, you are responsible for negotiating the terms and 
arrangements for the account with that broker-dealer.  We may not be able to negotiate 
commissions, obtain volume discounts, or best execution.  In addition, under these circumstances 
a difference in commission charges may exist between the commissions charged to clients who 
direct us to use a particular broker or dealer and other clients who do not direct us to use a 
particular broker or dealer.

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ACM does not receive client referrals from broker-dealers in exchange for cash or other 
compensation, such as brokerage services or research. 
 
ACM does not have any formal soft dollar arrangements. 
 
When ACM buys or sells the same security for two or more clients (including our personal 
accounts), we may place concurrent orders to be executed together as a single “block” in order to 
facilitate orderly and efficient execution.  Each client account will be charged or credited with 
the average price per unit.  We receive no additional compensation or remuneration of any kind 
because we aggregate client transactions.  No client is favored over any other client.  If an order 
is not completely filled, it is allocated pro-rata based on an allocation statement prepared by 
ACM prior to placing the order.  Because of an order’s aggregation, some clients may pay higher 
transaction costs, or greater spreads, or receive less favorable net prices on transactions than 
would otherwise be the case if the order had not been aggregated.  
 
 
Form ADV, Part 2A, Item 13 
Review of Accounts 
Client accounts are reviewed at least quarterly by Charles Johnson, Chief Compliance Officer of 
the firm. Charles Johnson reviews clients’ accounts with regards to their investment policies and 
risk tolerance levels.  All accounts at ACM are assigned to this reviewer.    
 
All financial planning accounts are reviewed upon financial plan creation and plan delivery by 
Charles Johnson, Chief Compliance Officer of the firm. There is only one level of review and 
that is the total review conducted to create the financial plan. 
 
Reviews may be triggered by material market, economic or political events, or by changes in 
client's financial situations (such as retirement, termination of employment, physical move, or 
inheritance). 
 
Each client will receive at least quarterly a written report that details the clients’ account which 
may come from the custodian. Clients are encouraged to review these statements to verify 
accuracy and calculation correctness. 
 
Clients are provided a one-time financial plan concerning their financial situation. After the 
presentation of the plan, there are no further reports. Clients may request additional plans or 
reports for a fee.

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Form ADV, Part 2A, Item 14 
Client Referrals and Other Compensation 
ACM does not compensate any individual or firm for client referrals.  In addition, ACM does not 
receive compensation for referring clients to other professional service providers.  
 
 
Form ADV, Part 2A, Item 15 
Custody 
ACM does not have physical custody of any client funds and/or securities, and does not take 
custody of client accounts at any time.  Client funds and securities will be held with a bank, 
broker dealer, or other independent qualified custodian.  However, by granting ACM written 
authorization to automatically deduct fees from client accounts, ACM is deemed to have limited 
custody.  You will receive account statements from the independent, qualified custodian holding 
your funds at least quarterly.  The account statement from your custodian will indicate the 
amount of advisory fees deducted from your account(s) each billing cycle.  Clients should 
carefully review statements received from the custodian. 
 
 
Form ADV, Part 2A, Item 16 
Investment Discretion 
Before ACM can buy or sell securities on your behalf, you must first sign our discretionary 
management agreement, a limited power of attorney, and/or trading authorization forms.  By 
choosing to do so, you may grant the firm discretion over the selection and amount of securities 
to be purchased or sold for your account(s) without obtaining your consent or approval prior to 
each transaction.  Clients may impose limitations on discretionary authority for investing in 
certain securities or types of securities (such as a product type, specific companies, specific 
sectors, etc.), as well as other limitations as expressed by the client.  Limitations on discretionary 
authority are required to be provided to the IAR in writing.  Please refer to the “Advisory 
Business” section of this Brochure for more information on our discretionary management 
services.   
 
 
Form ADV, Part 2A, Item 17 
Voting Client Securities 
We do not vote proxies on behalf of your advisory accounts. At your request, we may offer you 
advice regarding corporate actions and the exercise of your proxy voting rights. If you own 
shares of common stock or mutual funds, you are responsible for exercising your right to vote as 
a shareholder.

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In most cases, you will receive proxy materials directly from the account custodian. However, in 
the event we were to receive any written or electronic proxy materials, we would forward them 
directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in 
which case, we would forward any electronic solicitation to vote proxies. 
 
 
Form ADV, Part 2A, Item 18 
Financial Information 
ACM is not required to provide financial information to our clients because we do not require or 
solicit the prepayment of more than $1,200 six or more months in advance.   
 
 
Form ADV, Part 2A, Item 19 
Requirements for State-Registered Advisers 
This section is not applicable as ACM is SEC registered and not state registered.

1 
 
 
Form ADV, Part 2B, Item 1 
Cover Page 
 
 
 
 
 
 
 
 
 
MICHAEL COOLEY  
 
2015 Grand Avenue, Suite 100 
Des Moines, Iowa 50312 
 
 
Phone: (865) 407-7357 
 
 
 
 
 
 
 
 
 
 
October 7, 2025 
 
 
 
 
 
 
FORM ADV PART 2 
BROCHURE SUPPLEMENT 
 
 
This brochure supplement provides information about Michael Cooley that supplements the 
Altitude Capital Management LLC brochure.  You should have received a copy of that brochure.  
Please contact Michael Cooley if you did not receive Altitude Capital Management LLC’s brochure 
or if you have questions about this supplement.  Mr. Cooley ’s CRD number is 7078892. 
 
Additional information about Michael Cooley  is also available on the SEC’s website at 
www.adviserinfo.sec.gov.

2 
 
 
Form ADV, Part 2B, Item 2  
Educational Background and Business Experience 
Michael Cooley  
Investment Advisor Representative 
Year of Birth:  1975 
 
 
Business Background: 
Altitude Capital Management LLC, Investment Advisor Representative, October 2025 - Present 
 
Whitney & Associates, Agent, September 2025 – Present  
 
Forthright Capital Partners, LLC, Insurance Agent, June 2025 – August 2025  
 
Forthright Capital Advisory, LLC, Investment Advisor Representative, June 2025 – August 2025 
 
RidgeBrook Capital Management, LLC, Investment Advisor Representative, July 2024 – June 
2025 
 
RidgeBrook Retirement Planning, LLC, Insurance Agent, July 2024 – June 2025 
 
Sole Proprietor, Independent Insurance Agent / Market Technician, April 2021 – May 2024 
 
Knoxville Appraisal Company, Appraiser, March 2020 – September 2022 
 
    
Educational Background: 
University of Memphis, Bachelor of Science in Business Administration – Business Finance, 
Graduated: 2018 
 
 
Form ADV, Part 2B, Item 3 
Disciplinary Information 
Mr. Cooley does not have a reportable disciplinary disclosure. Further information is available at 
the SEC’s website at www.adviserinfo.sec.gov.

3 
 
Form ADV, Part 2B, Item 4 
Other Business Activities 
Michael Cooley  has a financial industry affiliated business as an insurance agent. Mr. Cooley 
spends no more 30% of his time per month on these activities. From time to time, he offers 
clients advice or products from those activities. He may receive separate yet typical 
compensation in the form of commissions for the sale of insurance products. 
 
These practices represent a conflict of interest because it gives Mr. Cooley an incentive to 
recommend products based on the commission amount received. This conflict is mitigated by the 
fact that Mr. Cooley has a fiduciary responsibility to place the best interest of the client first and 
the clients are not required to purchase any products. Clients have the option to purchase these 
products through another insurance agent of their choosing. 
 
 
Form ADV, Part 2B, Item 5 
Additional Compensation 
Michael Cooley does not receive any economic benefit from anyone, who is not a client, for 
providing advisory services. 
 
 
Form ADV, Part 2B, Item 6 
Supervision 
Altitude Capital Management LLC has written supervisory procedures in place that are 
reasonably designed to detect and prevent violations of the securities laws, rules, and regulations 
of the US Investment Advisers Act of 1940, as amended (the "Advisers Act").  Mr. Cooley is 
supervised by Altitude Capital Management LLC’s Chief Compliance Officer, Charles Johnson.  
Mr. Johnson can be reached at (207) 576-0822. 
 
 
Form ADV, Part 2B, Item 7 
Requirements for State-Registered Advisers 
Michael Cooley  does not have any reportable disciplinary events required to be disclosed in this 
section.