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Item 1
Cover Page
Lutz Financial
SEC File Number: 801 – 62093
ADV Part 2A, Firm Brochure
Dated: March 30, 2025
Contact: James P. Boulay, Chief Compliance Officer
13616 California Street, Suite 300
Omaha, Nebraska 68154
www.lutzfinancial.com
This brochure provides information about the qualifications and business practices of Lutz Financial.
If you have any questions about the contents of this brochure, please contact us at (402) 827-2300 or
jboulay@lutzfinancial.com. 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 Lutz Financial also is available on the SEC’s website at
www.adviserinfo.sec.gov.
References herein to Lutz Financial as a “registered investment adviser” or any reference to being
“registered” does not imply a certain level of skill or training.
Material Changes
Item 2
Since its last annual amendment filing on March 28, 2024, Lutz Financial has materially updated its Form
ADV 2A Disclosure Brochure at:
•
Item 4
o Lutz Financial has included Altruist as a custodian, in addition to Schwab, as part of the
Automated Investment Program (the “Program”).
•
Item 5
o Lutz Financial has amended its fees for financial planning services to $5,000 on a fixed fee
basis and $200-$500 on an hourly basis.
Item 3
Table of Contents
Item 1 Cover Page .................................................................................................................................... 1
Item 2 Material Changes .......................................................................................................................... 2
Table of Contents .......................................................................................................................... 2
Item 3
Item 4 Advisory Business ........................................................................................................................ 3
Fees and Compensation .............................................................................................................. 11
Item 5
Item 6
Performance-Based Fees and Side-by-Side Management .......................................................... 14
Types of Clients .......................................................................................................................... 15
Item 7
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 15
Item 9 Disciplinary Information ............................................................................................................ 18
Item 10 Other Financial Industry Activities and Affiliations .................................................................. 18
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.............. 19
Item 12 Brokerage Practices .................................................................................................................... 20
Item 13 Review of Accounts .................................................................................................................... 22
Item 14 Client Referrals and Other Compensation .................................................................................. 22
Item 15 Custody ....................................................................................................................................... 22
Item 16
Investment Discretion ................................................................................................................. 23
Item 17 Voting Client Securities .............................................................................................................. 23
Item 18 Financial Information ................................................................................................................. 23
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Item 4
Advisory Business
A. Lutz Financial is a limited liability company formed on February 2, 2000, in the State of
Nebraska. Lutz Financial first registered as an investment adviser with the SEC in June
2003. Lutz Financial is principally owned by Ectart, LLC. James P. Boulay is Lutz
Financial’s Managing Member and Chief Compliance Officer.
B. As discussed below, Lutz Financial offers to its clients (generally, individuals, high net
worth individuals, retirement plans, charitable organizations, and business entities),
pension consulting and investment advisory services, and to the extent specifically
requested by a client, financial planning and related consulting services.
INVESTMENT ADVISORY SERVICES
The client can engage Lutz Financial to provide discretionary or non-discretionary
investment advisory services on a fee basis. Lutz Financial’s annual investment advisory
fee is based upon a percentage (%) of the market value of the assets placed under Lutz
Financial’s management. Prior to engaging Lutz Financial to provide investment advisory
services, clients are required to enter into an Investment Advisory Agreement with Lutz
Financial setting forth the terms and conditions of the engagement (including termination),
describing the scope of the services to be provided, and the fee that is due from the client.
Lutz Financial provides investment advisory services specific to the needs of each client.
Prior to providing investment advisory services, an investment adviser representative will
ascertain each client’s investment objectives. Thereafter, Lutz Financial will allocate or
recommend that the client allocate investment assets consistent with their designated
investment objectives. Once allocated, Lutz Financial provides ongoing monitoring and a
review of account performance and asset allocation as compared to client investment
objectives, and may rebalance the account as necessary based on such reviews. Lutz
Financial primarily recommends or uses various mutual funds (including the mutual funds
sponsored by Dimensional Fund Advisors (“DFA”)), individual bonds, exchange-traded
funds (“ETFs”), in managing client accounts, based on the investment objectives of each
client.
Lutz Financial’s annual investment advisory fee includes investment advisory services,
and, to the extent specifically requested by the client, financial planning and consulting
services. In the event that the client requires extraordinary planning or consultation services
(to be determined in the sole discretion of Lutz Financial), Lutz Financial reserves the right
to charge for these additional services, pursuant to a stand-alone Financial Planning and
Consulting Agreement (see below).
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
Lutz Financial may provide financial planning or consulting services (including on
investment and non-investment related matters, such as estate planning and insurance
planning) on a stand-alone separate fee basis as described in Item 5 below. Prior to
engaging Lutz Financial to provide planning or consulting services, clients are generally
required to enter into a Financial Planning and Consulting Agreement with Lutz Financial
setting forth the terms and conditions of the engagement (including termination),
describing the scope of the services to be provided, and the portion of the fee that is due
from the client prior to Lutz Financial commencing services.
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If requested by the client, Lutz Financial may recommend the services of other
professionals for implementation purposes, including the accounting services of Lutz
Financial’s affiliate, Lutz & Company, P.C. and related entities (“Lutz & Company”). (See
additional information about this affiliation at Item 10.C.). The client is under no obligation
to engage the services of any recommended professional. The client retains absolute
discretion over all implementation decisions and is free to accept or reject any
recommendation from Lutz Financial.
If the client engages any recommended professional, and a dispute arises thereafter relative
to such engagement, the client agrees to seek recourse exclusively from and against the
engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney,
accountant, insurance agent, etc.), and not Lutz Financial, shall be responsible for the
quality and competency of the services provided.
It remains the client’s responsibility to promptly notify Lutz Financial if there is ever any
change in their financial situation or investment objectives so that Lutz Financial can
review, and if applicable, revise its previous recommendations or services.
RETIREMENT PLAN CONSULTING SERVICES
Lutz Financial offers fiduciary and non-fiduciary retirement plan consulting services, on a
discretionary or non-discretionary fee basis, to defined contribution, defined benefit and
non-qualified plans. All qualified plan client accounts are regulated under the Employee
Retirement Income Securities Act (“ERISA”). Lutz Financial will provide discretionary,
non-discretionary, fiduciary and non-fiduciary advisory services to the sponsors of the
defined contribution, defined benefit, and nonqualified deferred compensation plans,
considering each plan’s stated objective, liquidity needs, and stated policies and guidelines.
Lutz Financial employs an initial and ongoing screening process based upon various
quantitative and qualitative factors, including performance and costs.
Lutz Financial may be engaged to provide the following services (collectively, “Services”)
to a company, plan or plan participant during the term of an engagement.
Pooled Qualified Retirement Plan Fiduciary Services: Lutz Financial may be engaged to
provide discretionary 3(38) investment management to clients regarding the investment
management of pooled qualified retirement plans. Under this arrangement, Lutz Financial
will serve as an investment fiduciary as that term is defined under The Employee
Retirement Income Security Act of 1974 (“ERISA”) and accepts discretion over plan
assets, while assuming full responsibility and liability for the fiduciary functions
concerning decisions related to the plan assets. Lutz Financial’s services shall include the
following, to the extent requested and agreed upon, in writing:
i. Making discretionary investment decisions for Plan assets
ii. Developing an investment policy statement
iii. Creating periodic investment reports to aid in monitoring investments
iv. Attending periodic meetings with the client to discuss reports
v. Analyzing and recommending service providers
vi. Reviewing and conducting due diligence relating to manager and fund selections
vii. Attending meetings with custodian or record-keeper on matters pertaining to the
plan investments
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viii. Participating in periodic committee meetings (or as often as the committee deems
necessary)
ix. Participating in additional sub-committee meetings as requested with members and
outside advisors
Defined Contribution Plan and Defined Benefit Plan Fiduciary Services: Lutz Financial
may be engaged to provide non-discretionary 3(21)(a)(ii) investment advice to clients
regarding asset classes and investment alternatives available to the client in accordance
with its investment policies and objectives and to the extent written policies and objectives
have been brought to the attention of Lutz Financial. When Lutz Financial is engaged in
this capacity, the client shall have final decision-making authority regarding the selection,
retention, removal and addition of investment options. Lutz Financial will not maintain
discretionary authority or control, whatsoever, with respect to the plan or the plan
participant accounts maintained by the plan. Lutz Financial will provide services only to
the extent it receives necessary and timely cooperation from the company, including but
not limited to meetings, telephone calls, production of documents, coordination of services
and company decision-making assistance. Lutz Financial’s services shall include the
following, to the extent requested and agreed upon, in writing:
i. Assisting in selecting investment options
ii. Assisting in the development of an investment policy statement
iii. Providing periodic investment reports to aid in monitoring investment options
iv. Attending periodic meetings with the client to discuss reports
v. Assisting with the selection of qualified default investment alternatives
vi. Analyzing and recommending service providers
vii. Assisting with review and due diligence relating to manager and fund selections
viii. Attending meetings with custodian or record-keeper on matters pertaining to the
plan investments
ix. Participating in periodic committee meetings (or as often as the committee deems
necessary)
x. Participating in additional sub-committee meetings as requested with members and
outside advisors
xi. Assisting with investment fund mapping and analytical support as requested
Clients must acknowledge that Lutz Financial has no responsibility to provide any services
related to the following types of assets: employer securities; ESOP Plans, real estate
(except for real estate funds and publicly traded REITs); voting proxies, stock brokerage
accounts or mutual fund windows; participant loans; non-publicly traded partnership
interests; other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or other hard-to-value or illiquid securities or property (collectively,
“Unmanaged Assets”).
Defined Contribution, Defined Benefit Plan Non-Fiduciary Services: Lutz Financial may
be engaged to provide non-discretionary, non-fiduciary services. When Lutz Financial is
engaged in this capacity, the client shall have final decision-making authority regarding the
selection, retention, removal, modification or addition of all advisor non-fiduciary
recommendations. Lutz Financial’s services shall also include the following, to the extent
requested and agreed upon, in writing:
i. Monitoring and supporting governances
ii. Assisting with plan administration and vendor management
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iii. Supporting participant communication and education program
iv. Providing benchmark studies and searches
v. Assisting with implementation and conversions
vi. Analyzing client’s service provider reports
AUTOMATED INVESTMENT PROGRAM
Lutz Financial offers an Automated Investment Program (the “Program”) for certain clients
who do not want ongoing planning and consulting services. This Program features asset
management services delivered digitally, with access to online financial planning software
for the client’s use. However, this program shall not include financial planning services.
Clients who are members of the Program are invested in a range of investment strategies
Lutz Financial has constructed and manages, each consisting of a portfolio of exchange-
traded funds and mutual funds, and a cash allocation. The client may instruct us to exclude
up to three Funds from their portfolio. The Client’s portfolio is held in a brokerage account
opened by the client at Charles Schwab & Co., Inc. (“Schwab”) and Altruist.
Lutz Financial, and not Schwab or Altruist, is the Client’s investment adviser and act as
the Client’s primary contact for the Program. Duties of implementation under this Program
fall solely on the client. Lutz Financial is not responsible for implementation of advice
provided under this Program. Additional details regarding the fee for the Program can
be found at Item 5 below.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, Lutz Financial may provide financial planning and related
consulting services regarding non-investment related matters, such as estate planning, tax
planning, insurance planning, etc. Lutz Financial does not serve as a law firm or accounting
firm, and no portion of its services should be construed as legal or accounting services.
Accordingly, Lutz Financial does not prepare estate planning documents or tax returns.
To the extent requested by a client, Lutz Financial may recommend the services of other
professionals for certain non-investment implementation purposes (i.e., attorneys,
accountants, insurance agents, etc.), including Lutz Financial’s affiliate, Lutz & Company
(See additional information about these affiliations at Item 10.C). The client is under no
obligation to engage the services of any recommended professional. The client retains
absolute discretion over all implementation decisions and is free to accept or reject any
recommendation from Lutz Financial and/or its representatives.
If the client engages any recommended professional, and a dispute arises thereafter relative
to that engagement, the client agrees to seek recourse exclusively from and against the
engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney,
accountant, insurance agent, etc.), and not Lutz Financial, shall be responsible for the
quality and competency of the services provided. Please Further Note-Conflict of
Interest: The recommendation by Lutz Financial representative that a client purchase an
insurance product from a Lutz Financial representative in his/her individual capacity as a
representative of an insurance agent, presents a conflict of interest. The receipt of
commissions may provide an incentive to recommend insurance products based on
commissions to be received, rather than on a particular client’s need. No client is under any
insurance commission products from a Lutz Financial
obligation
to purchase
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representative. Clients may purchase insurance products through other insurance agents.
Additionally, Lutz Financial and its IARs may receive additional compensation for
recommending clients to Lutz Financial’s affiliate, Lutz & Co. Neither Lutz Financial nor
any of its investment professionals are agent of record for insurance product referrals.
Lutz Financial’s Chief Compliance Officer, James P. Boulay, remains available to
address any questions that a client or prospective client may have regarding the above
conflict of interest.
Use of Mutual Funds and ETFs. Lutz Financial utilizes mutual funds and exchange
traded funds for its client portfolios. In addition to Lutz Financial’s investment advisory
fee described below, and transaction and/or custodial fees discussed below, clients will also
incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at
the fund level (e.g., management fees and other fund expenses). The mutual funds and
exchange traded funds utilized by Lutz Financial are generally available directly to the
public. Thus, a client can generally obtain the funds recommended and/or utilized by Lutz
Financial independent of engaging Lutz Financial as an investment advisor. However, if a
prospective client does so, then they will not receive Lutz Financial’s initial and ongoing
investment advisory services.
Use of DFA Mutual Funds. Lutz Financial utilizes the mutual funds issued by
Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through
registered investment advisers approved by DFA. Thus, if the client was to terminate Lutz
Financial’s services, and transition to another adviser who has not been approved by DFA
to utilize DFA funds, restrictions regarding additional purchases of, or reallocation among
other DFA funds, will generally apply. Lutz Financial’s Chief Compliance Officer,
James P. Boulay, remains available to address any questions that a client or
prospective client may have regarding the above.
Custodian Charges-Additional Fees. As discussed below at Item 12 below, when
requested to recommend a broker-dealer/custodian for client accounts, Lutz Financial
generally recommends that Charles Schwab and Co., Inc. (“Schwab”), and Nationwide
Advisory (“Nationwide”) serve as the broker-dealer/custodian for client investment
management assets. Broker-dealers such as Schwab and Nationwide charge brokerage
commissions, transaction, and/or other type fees for effecting certain types of securities
transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and
mark-downs charged for fixed income transactions, etc.). The types of securities for which
transaction fees, commissions, and/or other type fees (as well as the amount of those fees)
shall differ depending upon the broker-dealer/custodian (while certain custodians,
including Schwab and Nationwide, do not currently charge fees on individual equity
transactions, others do). When beneficial to the client, individual fixed‐income and/or
equity transactions may be effected through broker‐dealers with whom Lutz Financial
and/or the client have entered into arrangements for prime brokerage clearing services,
including effecting certain client transactions through other SEC registered and FINRA
member broker‐dealers (in which event, the client generally will incur both the transaction
fee charged by the executing broker‐dealer and a “trade-away” fee charged by Schwab
and/or Nationwide). These fees/charges are in addition to Lutz Financial’s investment
advisory fee at Item 5 below. Lutz Financial does not receive any portion of these
fees/charges.
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Retirement Plan Rollovers- No Obligation/Conflict of Interest. 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 Lutz Financial recommends that a client roll over
their retirement plan assets into an account to be managed by Lutz Financial, such a
recommendation creates a conflict of interest if Lutz Financial will earn new (or increase
its current) compensation as a result of the rollover. If Lutz Financial provides a
recommendation as to whether a client should engage in a rollover or not (whether it is
from an employer’s plan or an existing IRA), Lutz Financial is acting as a fiduciary within
the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal
Revenue Code, as applicable, which are laws governing retirement accounts. No client is
under any obligation to roll over retirement plan assets to an account managed by Lutz
Financial. Lutz Financial’s Chief Compliance Officer, James P. Boulay, remains
available to address any questions that a client or prospective client may have
regarding the conflict of interest presented by such a rollover recommendation.
Non-Discretionary Service Limitations. Clients that determine to engage Lutz Financial
on a non-discretionary investment advisory basis must be willing to accept that Lutz
Financial cannot effect any account transactions without obtaining prior consent to such
transaction(s) from the client. In the event that Lutz Financial would like to make a
transaction for a client’s account (including in the event of an individual holding or general
market correction), and the client is unavailable, Lutz Financial will be unable to effect the
account transaction(s) (as it would for its discretionary clients) without first obtaining the
client’s consent.
Variable Annuities (1035 exchanges). In limited circumstances, Lutz Financial may
invest client assets in the investment sub-divisions of a variable annuity issued by
Nationwide. Lutz Financial does not purchase variable annuities for its clients on a
commission basis. Rather, Lutz Financial recommends that clients owning variable
annuities consider a 1035 exchange to Nationwide, one of the nation's lowest cost, fee-
only, variable annuity providers. By so doing, we seek to reduce the fees and expenses
associated with commission-based annuities. The client retains absolute discretion over the
decision to engage Nationwide and is free to accept or reject any recommendation from
Lutz Financial and/or its representatives.
Reporting Services. Lutz Financial may provide its clients with access to an online
platform hosted by Orion. The Orion platform allows a client to view their complete asset
allocation, including those assets that Lutz Financial does not manage (the “Unmanaged
Assets”). Lutz Financial does not provide investment management, monitoring, or
implementation services for the Unmanaged Assets. Therefore, Lutz Financial shall not
be responsible for the investment performance of the Unmanaged Assets. Rather, the client
and/or their advisor(s) that maintain management authority for the Unmanaged Assets, and
not Lutz Financial, shall be exclusively responsible for such investment performance. The
client may choose to engage Lutz Financial to manage some or all of the Unmanaged
Assets pursuant to the terms and conditions of an Investment Advisory Agreement between
Lutz Financial and the client. The Orion platform also provides access to other types of
information, including financial planning concepts, which should not be viewed as
services, advice, or recommendations provided by Lutz Financial. Finally, Lutz Financial
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shall not be held responsible for any adverse results a client may experience if the client
engages in financial planning or other functions available on the Orion platform without
Lutz Financial’s assistance or oversight.
Portfolio Activity. Lutz Financial has a fiduciary duty to provide services consistent with
the client’s best interest. Lutz Financial will review client portfolios on an ongoing basis
to determine if any changes are necessary based upon various factors, including, but not
limited to, investment performance, market conditions, fund manager tenure, style drift,
account additions/withdrawals, and/or a change in the client’s investment objective. Based
upon these factors, there may be extended periods of time when Lutz Financial determines
that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees
described in Item 5 below during periods of portfolio inactivity. Of course, as indicated
below, there can be no assurance that investment decisions made by Lutz Financial will be
profitable or equal any specific performance level(s).
Other Assets. A client may:
client’s
• Hold securities that were purchased at the request of the client or acquired prior to
the
engagement of Lutz Financial. Generally, with potential
exceptions, Lutz Financial does not/would not recommend nor follow such
securities, and absent mitigating tax consequences or client direction to the
contrary, would prefer to liquidate such securities. If/when liquidated, it should not
be assumed that the replacement securities purchased by the Lutz Financial will
outperform the liquidated positions. To the contrary, different types of investments
involve varying degrees of risk, and there can be no assurance that future
performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by Lutz
Financial) will be profitable or equal any specific performance level(s). In addition,
there may be other securities and/or accounts owned by the client for which Lutz
Financial does not maintain custodian access and/or trading authority; and,
Corresponding Services/Fees. When agreed
to by Lutz Financial, Lutz
Financial shall: (1) remain available to discuss these securities/accounts on an
ongoing basis at the request of the client; (2) monitor these securities/accounts on a
regular basis, including, where applicable, rebalancing with client consent; (3) shall
generally consider these securities as part of the client’s overall asset allocation; (4)
report on such securities/accounts as part of regular reports that may be provided by
Lutz Financial; and, (5) include the market value of all such securities for purposes of
calculating advisory fee.
Cash Positions. Lutz Financial continues to treat cash as an asset class. As such, unless
determined to the contrary by Lutz Financial, all cash positions (money markets, etc.) shall
continue to be included as part of assets under management for purposes of calculating
Lutz Financial’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated
market conditions/events will occur), Lutz Financial may maintain cash positions for
defensive purposes. In addition, while assets are maintained in cash, such amounts could
miss market advances. Depending upon current yields, at any point in time, Lutz
Financial’s advisory fee could exceed the interest paid by the client’s money market fund.
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Cross Transactions. In limited circumstances, when determined to be in the best interest
of its clients, Lutz Financial may arrange for cross-transactions pursuant to which Lutz
Financial may cross transactions between two of its managed client accounts (i.e.,
arranging for the clients’ securities trades by “crossing” these trades when Lutz Financial
believes that such transactions are beneficial to its clients). This may present a conflict of
interest. For all such transactions, neither Lutz Financial nor any affiliate will be acting as
a broker. Lutz Financial will not receive any commission or transaction-based
compensation, although Lutz Financial has an interest in the price at which the cross trades
are conducted since Lutz Financial’s asset-based fees will be negatively impacted by lower
bond values. These transactions will be generally effected through Schwab, the account
custodian. The client may revoke Lutz Financial’s cross-transaction authority at any time
upon written notice to Lutz Financial.
Cybersecurity Risk. The information technology systems and networks that Lutz
Financial and its third-party service providers use to provide services to Lutz Financial’s
clients employ various controls that are designed to prevent cybersecurity incidents
stemming from intentional or unintentional actions that could cause significant
interruptions in Lutz Financial’s operations and/or result in the unauthorized acquisition or
use of clients’ confidential or non-public personal information. In accordance with
Regulation S-P, Lutz Financial is committed to protecting the privacy and security of its
clients' non-public personal information by implementing appropriate administrative,
technical, and physical safeguards. Lutz Financial has established processes to mitigate the
risks of cybersecurity incidents, including the requirement to restrict access to such
sensitive data and to monitor its systems for potential breaches. Clients and Lutz Financial
are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause
them to incur financial losses and/or other adverse consequences. Although Lutz Financial
has established processes to reduce the risk of cybersecurity incidents, there is no guarantee
that these efforts will always be successful, especially considering that Lutz Financial does
not control the cybersecurity measures and policies employed by third-party service
providers, issuers of securities, broker-dealers, qualified custodians, governmental and
other regulatory authorities, exchanges, and other financial market operators and providers.
In compliance with Regulation S-P, Lutz Financial will notify clients in the event of a data
breach involving their non-public personal information as required by applicable state and
federal laws.
Socially Responsible Investing Limitations. Socially Responsible Investing involves the
incorporation of certain considerations into the investment due diligence process. Socially
responsible investing incorporates a set of socially responsible criteria/factors used in
evaluating potential investments, including environmental, social, and governance
considerations. The number of companies that meet an acceptable socially responsible
mandate can be limited when compared to those that do not, and could underperform broad
market indices. Investors must accept these limitations, including potential for
underperformance. Correspondingly, the number of socially responsible mutual funds and
exchange-traded funds are limited when compared to those that do not maintain such a
mandate. As with any type of investment (including any investment and/or investment
strategies recommended and/or undertaken by Lutz Financial), there can be no assurance
that investment in socially responsible securities or funds will be profitable or prove
successful. Lutz Financial does not maintain or advocate a socially responsible investment
strategy, but will seek to employ socially responsible investments if directed by a client to
do so. If implemented, Lutz Financial shall rely upon the assessments undertaken by the
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unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to
determine that the fund’s or portfolio’s underlying company securities meet a socially
responsible mandate.
Client Obligations. In performing its services, Lutz Financial shall not be required to
verify any information received from the client or from the client’s other designated
professionals, and is expressly authorized to rely thereon. It remains the client’s
responsibility to promptly notify Lutz Financial if there is ever any change in their financial
situation or investment objectives so that Lutz Financial can review, and if applicable,
revise its previous recommendations or services.
Disclosure Brochure. A copy of Lutz Financial’s written Privacy Notice, written
disclosure statement as set forth on Part 2A and 2B of Form ADV and Form CRS (Client
Relationship Summary) shall be provided to each client or prospective client prior to, or
contemporaneously with, the execution of the Investment Advisory Agreement or Financial
Planning and Consulting Agreement. Any client who has not received a copy of Adviser’s
written Brochure at least 48 hours prior to executing such agreement shall have five
business days subsequent to executing the agreement to terminate the Adviser’s services
without penalty.
C. Lutz Financial provides investment advisory services specific to the needs of each client.
Prior to providing investment advisory services, an investment adviser representative will
ascertain each client’s investment objectives. Thereafter, Lutz Financial will allocate or
recommend that the client allocate investment assets consistent with their designated
investment objectives. The client may impose reasonable restrictions, in writing, on Lutz
Financial’s services.
D. Lutz Financial does not participate in a wrap fee program.
E. As of December 31, 2024, Lutz Financial had $2,314,263,752 in assets under management
on a discretionary basis and $295,882,427 in assets under management on a non-
discretionary basis for a total of $2,610,146,179 in assets under management.
Item 5
Fees and Compensation
A. Clients can engage Lutz Financial to provide discretionary or non-discretionary investment
advisory services in accordance with the fee schedules and descriptions of fees described
below.
Although the schedules and description of fees set forth below are Lutz Financial’s
standard fees, its fees remain negotiable. In addition, Lutz Financial reserves the right to
charge different fees to clients based upon various objective and subjective factors. These
factors include, but are not limited to, the amount of the assets placed under Lutz
Financial’s management or supervision, the level and scope of the overall investment
services to be rendered, anticipated future earning capacity, anticipated future additional
assets, dollar amount of assets to be managed, related accounts, account composition,
anticipated services to be rendered, grandfathered fee schedules, employees and family
members, courtesy accounts, competition, negotiations with client, and the complexity of
the engagement. As a result, Lutz Financial’s clients could pay diverse fees based upon the
market value of their assets, the complexity of the engagement, and the level and scope of
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the overall financial planning and/or consulting services to be rendered. The services to be
provided by Lutz Financial to any particular client could be available from other advisers
at a higher or lower fee. Additionally, similarly situated clients could pay different fees.
ANY QUESTIONS: Lutz Financial’s Chief Compliance Officer, James P. Boulay,
remains available to address any questions that a client or prospective client may have
regarding advisory fees.
INVESTMENT ADVISORY SERVICES
Lutz Financial’s annual investment advisory fee for discretionary or non-discretionary
investment advisory services shall be based upon a percentage (%) of the market value
(including accrued interest) and type of assets placed under Lutz Financial’s management
based on the following fee schedule:
Market Value of Portfolio % of Assets
$500,000 - $1,000,000
$1,000,000 - $2,000,000
$2,000,000 - $5,000,000
$5,000,000 - $10,000,000
$10,000,000 - $25,000,000
Over $25,000,000
1.00%
0.75%
0.60%
0.45%
0.40%
0.30%
Lutz Financial’s annual investment advisory fee shall be prorated and paid quarterly, in
advance, based upon the market value of the assets on the last business day of the previous
quarter. Lutz Financials fees are negotiable. Lutz Financial’s policy is to treat intra-quarter
account additions and withdrawals equally unless indicated to the contrary on the Firm’s
Investment Advisory Agreement executed by the client. Lutz Financial may partially bill
increases in the client’s account after the account was billed. Lutz Financial may, in its sole
discretion, adjust fees based upon certain criteria including, but not limited to, the client’s
relationship, timing of the additional investment and a materiality analysis.
Existing clients will be grandfathered under their current fee schedules. The above fee
schedule shall apply to new clients as of the date of filing of this Brochure.
Minimum Asset and Minimum Fee Levels. Lutz Financial maintains a minimum fee of
the lesser of 1.50% annually or $1,250 per quarter, recalculated on a quarterly basis, for
clients who fall below Lutz Financial’s minimum assets under management. This minimum
will apply to new clients as of the date of this filing and some existing clients. Further, Lutz
Financial generally maintains a minimum asset level of $500,000. In the event that the
client is subject to an annual minimum fee, the client could pay a higher percentage fee
than referenced above.
Fee Dispersion. Lutz Financial, in its discretion, may charge a lesser or higher investment
advisory fee, charge a flat fee, waive appliable minimum asset or minimum fee levels,
waive its fee entirely, or charge fee on a different interval, 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, complexity of the
engagement, anticipated services to be rendered, grandfathered fee schedules, employees
and family members, courtesy accounts, competition, negotiations with client, etc.). As
result of the above, similarly situated clients could pay different fees. In addition, similar
advisory services may be available from other investment advisers for similar or lower
12
fees. ANY QUESTIONS: Lutz Financial’s Chief Compliance Officer, James P. Boulay,
remains available to address any questions that a client or prospective client may have
regarding advisory fees.
AUTOMATED INVESTMENT PROGRAM
Lutz Financial offers an Automated Investment Program for certain clients who do not
want ongoing planning and consulting services. This Program features asset management
services delivered digitally, with access to online financial planning software for the
client’s use. However, this program shall not include financial planning services. Members
of the Program are subject to a flat 1.00% annual advisory fee. Clients do not pay brokerage
commissions or any other fees to Schwab or Altruist as part of the Program. Schwab does
receive other revenues, including (i) the profit earned by Charles Schwab Bank, SSB, a
Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program
described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii)
investment advisory and/or administrative service fees (or unitary fees) received by Charles
Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab
Funds® and Laudus Funds® that Lutz Financial selects to buy and hold in the client’s
brokerage account; (iii) fees received by Schwab from mutual funds in the Schwab Mutual
Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s
brokerage account for services Schwab provides; and (iv) remuneration Schwab receives
from the market centers where it routes ETF trade orders for execution. Brokerage
arrangements are further described below in Item 12.
Additional features of this Program are further described in Item 4 above.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
Lutz Financial may provide financial planning and/or consulting services (including
investment and non-investment related matters, including estate planning, insurance
planning, etc.) on a stand-alone fee basis. Lutz Financial’s planning and consulting fees are
negotiable, but is generally $5,000 on a fixed fee basis, and between $200 to $500 on an
hourly rate basis, depending upon the level and scope of the service(s) required and the
professional(s) rendering the service(s).
RETIREMENT PLAN CONSULTING
Lutz Financial offers retirement plan consulting services, on a discretionary or
non-discretionary fee basis, to defined contribution, defined benefit and non-qualified
plans. Generally, the fees for retirement plan consulting are between 0.10% and 1.00% or,
the client may be charged on a flat dollar basis which will depend on the size of the plan.
Lutz advisory fees are payable according to the terms and conditions stated in the
Retirement Plan Consulting Agreement between Lutz and the client. Lutz Financial may
charge fees according to an agreed upon method with each retirement plan client. Lutz
Financial’s fee for advisory services may be based on a percentage of assets under
advisement, an agreed upon fixed fee or determined on an hourly rate basis, subject to a
written agreement between the parties.
B. Clients may elect to have Lutz Financial’s advisory fees deducted from their custodial
account. Both Lutz Financial’s Investment Advisory Agreement and the custodial/clearing
agreement may authorize the custodian to debit the account for Lutz Financial’s investment
advisory fee and pay the fee to Lutz Financial in compliance with regulatory procedures.
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In the limited event that Lutz Financial bills the client directly, payment is due upon receipt
of Lutz Financial’s invoice. Lutz Financial will generally deduct fees or bill clients
quarterly in arrears, based upon the market value of the assets on the last business day of
the previous quarter.
C. As discussed below, unless the client directs otherwise or an individual client’s
circumstances require, Lutz Financial shall generally recommend that Schwab and
Nationwide (collectively, the “Custodians”), as applicable, to serve as the broker-
dealer/custodian for client investment advisory assets. The Custodians charge brokerage
commissions and transaction fees for effecting securities transactions. In addition to Lutz
Financial’s investment advisory fee, brokerage commissions and transaction fees, clients
will incur, relative to all mutual fund and exchange traded fund purchases, and charges
imposed at the fund level (e.g., management fees and other fund expenses). The fees
charged by the applicable broker-dealer/custodian, and the charges imposed at the fund
level, are in addition to Adviser’s investment advisory fees referenced in this Item 5.
If Lutz Financial determines that it would be beneficial to the client, individual transactions
may be effected through broker-dealers with whom Lutz Financial and/or the client have
entered into arrangements for prime brokerage clearing services, including effecting certain
client transactions through the Custodians (in which event, the client shall incur both the
transaction fee charged by the executing broker-dealer and a “tradeaway” fee charged by
the Custodians).
D. Lutz Financial generally requires an annual minimum fee or asset level for investment
advisory services. However, Lutz Financial, in its sole discretion, may charge a lesser
investment advisory fee or charge a flat 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.). As result
of the above, similarly situated clients could pay different fees. In addition, similar advisory
services may be available from other investment advisers for similar or lower fees.
The Investment Advisory Agreement between Lutz Financial and the client will continue in
effect until terminated by either party by written notice in accordance with the terms of the
Investment Advisory Agreement. Upon termination, Lutz Financial shall refund the pro-
rated portion of the advanced advisory fee paid based upon the number of days remaining
in the billing quarter.
E. As further described in Item 10.C. below, some of Lutz Financial representatives in their
separate and individual capacities as insurance agents, may receive compensation for the
sale of insurance products. Neither Lutz Financial nor any of its investment professionals
are agent of record for insurance product referrals.
Neither Lutz Financial, nor its representatives accept compensation from the sale of
securities.
Item 6
Performance-Based Fees and Side-by-Side Management
Lutz Financial is not a party to any performance or incentive-related compensation
arrangements with its clients.
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Item 7
Types of Clients
Lutz Financial’s clients shall generally include individuals, high net worth individuals,
retirement plans, charitable organizations, and business entities. Lutz Financial generally
requires an annual minimum fee or asset level for investment advisory services.
Lutz, in its discretion, may charge a lesser investment advisory fee, charge a flat fee, waive
its fee entirely, or charge fee on a different interval, 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, complexity of the
engagement, anticipated services to be rendered, grandfathered fee schedules, employees
and family members, courtesy accounts, competition, negotiations with client, etc.). As
result of the above, similarly situated clients could pay different fees. In addition, similar
advisory services may be available from other investment advisers for similar or lower
fees. ANY QUESTIONS: Lutz Financial’s Chief Compliance Officer, James P. Boulay,
remains available to address any questions that a client or prospective client may have
regarding advisory fees.
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
A. Lutz Financial may utilize the following methods of security analysis:
• Fundamental - (analysis performed on historical and present data, with the goal of
making financial forecasts)
Lutz Financial may utilize the following investment strategies when implementing
investment advice given to clients:
• Long Term Purchases (securities held at least a year)
• Short Term Purchases (securities sold within a year)
Investment Risk. Investing in securities involves risk of loss that clients should be
prepared to bear. Different types of investments involve varying degrees of risk, and it
should not be assumed that future performance of any specific investment or investment
strategy (including the investments and/or investment strategies recommended or
undertaken by Lutz Financial) will be profitable or equal any specific performance level(s).
Investment strategies such as asset allocation, diversification, or rebalancing do not assure
or guarantee better performance and cannot eliminate the risk of investment losses. There
is no guarantee that a portfolio employing these or any other strategy will outperform a
portfolio that does not engage in such strategies. While asset values may increase and client
account values could benefit as a result, it is also possible that asset values may decrease
and client account values could suffer a loss.
B. Lutz Financial’s methods of analysis and investment strategies do not present any
significant or unusual risks. However, every method of analysis has its own inherent risks.
To perform an accurate market analysis Lutz Financial must have access to current/new
market information. Lutz Financial has no control over the dissemination rate of market
information; therefore, unbeknownst to Lutz Financial, certain analyses may be compiled
with outdated market information, severely limiting the value of Lutz Financial’s analysis.
Lutz Financial’s primary investment strategies - Long Term Purchases and Short-Term
Purchases - are fundamental investment strategies. However, every investment strategy has
15
its own inherent risks and limitations. For example, longer term investment strategies
require a longer investment time period to allow for the strategy to potentially develop.
Shorter term investment strategies require a shorter investment time period to potentially
develop but, as a result of more frequent trading, may incur higher transactional costs when
compared to a longer-term investment strategy.
Margin Strategies
Lutz Financial does not recommend the use of margin as an investment strategy, in which
the client would borrow money leveraged against securities it holds to purchase additional
securities. However, if a client determines to use margin to purchase assets that Lutz
Financial will manage, Lutz Financial would include the entire market value of the
margined assets when computing its advisory fee, which would present a conflict of interest
to the extent it increases Lutz Financial’s advisory fee. Another conflict of interest would
arise if Lutz Financial has an economic disincentive to recommend that the client terminate
the use of margin. The terms and conditions of each margin loan are contained in a separate
agreement between the client and the margin lender selected by the client, which terms and
conditions may vary from client to client.
Borrowing funds on margin is not suitable for all clients and is subject to certain risks,
including but not limited to: increased market risk, increased risk of loss, especially in the
event of a significant downturn; liquidity risk; the potential obligation to post collateral or
repay the margin if the margin Lender determines that the value of collateralized securities
is no longer sufficient to support the value of the margin; and the risk that the margin lender
may liquidate the client’s securities to satisfy its demand for additional collateral or
repayment / the risk that the margin lender may terminate the margin at any time. Before
agreeing to participate in a margin program, clients should carefully review the applicable
margin agreement and all risk disclosures provided by the margin lender including the
initial margin and maintenance requirements for the specific program in which the client
enrolls, and the procedures for issuing “margin calls” and liquidating securities and other
assets in the client’s accounts. ANY QUESTIONS: Lutz Financial’s Chief Compliance
Officer, James P. Boulay, remains available to address any questions that a client or
prospective client may have regarding investment strategies.
C. Currently, Lutz Financial primarily recommends or uses various mutual funds (including
the mutual funds sponsored by DFA), individual bonds, ETFs, in managing client accounts,
based on the investment objectives of each client. Each type of security has its own unique
set of risks associated with it. The following provides a short description of some of the
underlying risks associated with investing in these types of securities:
Market Risk. The price of a security may drop in reaction to tangible and intangible events
and conditions. This type of risk may be caused by external factors (such as economic or
political factors), but may also be incurred because of a security’s specific underlying
investments. Additionally, each security’s price can fluctuate based on market movement,
which may or may not be due to the security’s operations or changes in its true value. For
example, political, economic and social conditions may trigger market events which are
temporarily negative, or temporarily positive.
Unsystematic Risk. Unsystematic risk is the company-specific or industry-specific risk in
a portfolio that the investor bears. Unsystematic risk is typically addressed through
diversification. However, as indicated above, diversification does not guarantee better
performance and cannot eliminate the risk of investment losses.
16
Interest Rate Risk. Fixed income securities and fixed income-based securities are subject
to interest rate risk because the prices of fixed income securities tend to move in the
opposite direction of interest rates. When interest rates rise, fixed income security prices
tend to fall. When interest rates fall, fixed income security prices tend to rise. In general,
fixed income securities with longer maturities are more sensitive to these price changes.
Inflation Risk. When any type of inflation is present, a dollar at present value will not carry
the same purchasing power as a dollar in the future, because that purchasing power erodes
at the rate of inflation.
Reinvestment Risk. Future proceeds from investments may have to be reinvested at a
potentially lower rate of return (i.e., interest rate), which primarily relates to fixed income
securities.
Credit Risk. The issuer of a security may be unable to make interest payments and/or repay
principal when due. A downgrade to an issuer’s credit rating or a perceived change in an
issuer’s financial strength may affect a security’s value and impact performance. Credit
risk is considered greater for fixed income securities with ratings below investment grade.
Fixed income securities that are below investment grade involve higher credit risk and are
considered speculative.
Call Risk. During periods of falling interest rates, a bond issuer will call or repay a higher-
yielding bond before its maturity date, forcing the investment to reinvest in bonds with
lower interest rates than the original obligations.
Regulatory Risk. Changes in laws and regulations from any government can change the
market value of companies subject to such regulations. Certain industries are more
susceptible to government regulation. For example, changes in zoning, tax structure or laws
may impact the return on investments.
Mutual Fund Risk. Mutual funds are operated by investment companies that raise money
from shareholders and invests it in stocks, bonds, and/or other types of securities. Each
fund will have a manager that trades the fund’s investments in accordance with the fund’s
investment objective. Mutual funds charge a separate management fee for their services,
so the returns on mutual funds are reduced by the costs to manage the funds. While mutual
funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market. Mutual funds that are sold through brokers
are called load funds, and those sold to investors directly from the fund companies are
called no-load funds. Mutual funds come in many varieties. Some invest aggressively for
capital appreciation, while others are conservative and are designed to generate income for
shareholders. 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).
Exchange Traded Fund Risk. ETFs are marketable securities that are designed to track,
before fees and expenses, the performance or returns of a relevant index, commodity, bonds
or basket of assets, like an index fund. Unlike mutual funds, ETFs trade like common stock
on a stock exchange. ETFs experience price changes throughout the day as they are bought
and sold. In addition to the general risks of investing, there are specific risks to consider
with respect to an investment in ETFs, including, but not limited to: (i) an ETF’s shares
17
may trade at a market price that is above or below its 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.
Item 9
Disciplinary Information
Lutz Financial has not been the subject of any disciplinary actions.
Item 10
Other Financial Industry Activities and Affiliations
A. Neither Lutz Financial, nor its representatives, are registered or have an application
pending to register, as a broker-dealer or a registered representative of a broker-dealer.
B. Neither Lutz Financial, nor its representatives, are registered or have an application
pending to register, as a futures commission merchant, commodity pool operator, a
commodity trading advisor, or a representative of the foregoing
C. Licensed Insurance Agent. Certain investment adviser representatives, in their separate
and individual capacity, are licensed insurance agents and may recommend the purchase
of insurance-related products where compensation may be received. These representatives
may also assist with educating clients on insurance coverage options. Neither Lutz
Financial nor any of its investment professionals are agent of record for insurance product
referrals.
Conflict of Interest: The recommendation by a Lutz Financial representative that a client
purchase an insurance product presents a conflict of interest, as the receipt of commissions
may provide an incentive to recommend investment products based on commissions to be
received, rather than on a particular client’s need. No client is under any obligation to
purchase any commission products from representatives of Lutz Financial. Clients may
purchase insurance products recommended by Lutz Financial through other, insurance
agents. Lutz Financial’s Chief Compliance Officer, James P. Boulay, remains
available to address any questions that a client or prospective client may have
regarding the above conflict of interest.
Certified Public Accounting Firm. Lutz Financial’s majority member (66%) is Ectart,
LLC (“Ectart”). Ectart is owned by the individual shareholders of Lutz & Company, PC
(“Lutz”), a certified public accounting firm principally located in Omaha, Nebraska. The
individual shareholders of Lutz are certified public accountants and devote the substantial
majority of their professional time to accounting-related services. Lutz Financial and Lutz
share the same principal place of business. To the extent that Lutz provides accounting
and/or tax preparation services to any clients, including clients of Lutz Financial, all such
services shall be performed by Lutz, in its individual professional capacity, independent of
Lutz Financial, for which services Lutz Financial may receive a portion of the fees charged
by Lutz.
It is expected that the members of Lutz, solely incidental to their respective practices as
Certified Public Accountants with Lutz, shall recommend Lutz Financial’s services to
certain of Lutz’s clients. Although Lutz shall not receive referral fees from Lutz Financial,
18
Lutz shall be entitled to receive distributions relative to its ownership interest in Ectart, the
majority member of Lutz Financial. Neither Lutz, nor any shareholder of Lutz, is involved
in providing investment advice on behalf of Lutz Financial, nor does Lutz or any other
shareholder of Lutz, hold itself/himself/herself out as providing advisory services on behalf
of Lutz Financial.
Lutz Financial’s Chief Compliance Officer, James P. Boulay, remains available to
address any questions that a client or prospective client may have regarding the above
arrangements and any corresponding conflict of interest such arrangement may
create. No client of Lutz Financial is required to engage Lutz’s services.
D. Lutz Financial does not receive, directly or indirectly, compensation from investment
advisors that it recommends or selects for its clients.
Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. Lutz Financial maintains an investment policy relative to personal securities transactions.
This investment policy is part of Lutz Financial’s overall Code of Ethics, which serves to
establish a standard of business conduct for all of Lutz Financial’s Representatives that is
based upon fundamental principles of openness, integrity, honesty and trust, a copy of
which is available upon request.
In accordance with Section 204A of the Investment Advisers Act of 1940, Lutz Financial
also maintains and enforces written policies reasonably designed to prevent the misuse of
material non-public information by Lutz Financial or any person associated with Lutz
Financial.
B. Neither Lutz Financial nor any related person of Lutz Financial recommends, buys, or sells
for client accounts, securities in which Lutz Financial or any related person of Lutz
Financial has a material financial interest.
C. Lutz Financial and/or representatives of Lutz Financial may buy or sell securities that are
also recommended to clients. This practice may create a situation where Lutz Financial
and/or representatives of Lutz Financial are in a position to materially benefit from the sale
or purchase of those securities. Therefore, this situation creates a conflict of interest.
Practices such as “scalping” (i.e., a practice whereby the owner of shares of a security
recommends that security for investment and then immediately sells it at a profit upon the
rise in the market price which follows the recommendation) could take place if Lutz
Financial did not have adequate policies in place to detect such activities. In addition, this
requirement can help detect insider trading, “front-running” (i.e., personal trades executed
prior to those of Lutz Financial’s clients) and other potentially abusive practices.
Lutz Financial has a personal securities transaction policy in place to monitor the personal
securities transactions and securities holdings of each of Lutz Financial’s “Access
Persons”. Lutz Financial’s securities transaction policy requires that an Access Person of
Lutz Financial must provide the Chief Compliance Officer or his/her designee with a
written report of their current securities holdings within ten (10) days after becoming an
Access Person. Additionally, each Access Person must provide the Chief Compliance
Officer or his/her designee with a written report of the Access Person’s current securities
19
holdings at least once each twelve (12) month period thereafter on a date Lutz Financial
selects.
D. Lutz Financial and/or representatives of Lutz Financial may buy or sell securities, at or
around the same time as those securities are recommended to clients. This practice creates
a situation where Lutz Financial and/or representatives of Lutz Financial are in a position
to materially benefit from the sale or purchase of those securities. Therefore, this situation
creates a conflict of interest. As indicated above in Item 11.C, Lutz Financial has a personal
securities transaction policy in place to monitor the personal securities transaction and
securities holdings of each of Lutz Financial’s Access Persons.
Item 12
Brokerage Practices
A. In the event that the client requests that Lutz Financial recommend a broker-
dealer/custodian for execution and/or custodial services (exclusive of those clients that may
direct Lutz Financial to use a specific broker-dealer/custodian), Lutz Financial generally
recommends that investment advisory accounts be maintained at Schwab. Prior to engaging
Lutz Financial to provide investment advisory services, the client will be required to enter
into a formal Investment Advisory Agreement with Lutz Financial setting forth the terms
and conditions under which Lutz Financial shall manage the client’s assets, and a separate
custodial/clearing agreement with each designated broker-dealer/custodian.
Factors that Lutz Financial considers in recommending the Custodians (or any other
broker-dealer/custodian to clients) include historical relationship with Lutz Financial,
financial strength, reputation, execution capabilities, pricing, research, and service. Broker-
dealers such as Schwab can charge transaction fees for effecting certain securities
transactions (See Item 4 above). To the extent that a transaction fee will be payable by the
client to Schwab, the transaction fee shall be in addition to Lutz Financial’s investment
advisory fee referenced in Item 5 above.
transaction
rates, and
To the extent that a transaction fee is payable, Lutz Financial shall have a duty to obtain
best execution for such transaction. However, that does not mean that the client will not
pay a transaction fee that is higher than another qualified broker-dealer might charge to
effect the same transaction where Lutz Financial determines, in good faith, that the
transaction fee is reasonable. 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 broker-dealer’s services, including the value of
research provided, execution capability,
responsiveness.
Accordingly, although Lutz Financial will seek competitive rates, it may not necessarily
obtain the lowest possible rates for client account transactions.
1. Research and Additional Benefits
Lutz Financial receives from the Custodians (and potentially other broker-dealers,
custodians, investment platforms, unaffiliated investment managers, vendors, or fund
sponsors, including DFA) free or discounted support services and products. Certain of
these products and services assist Lutz Financial to better monitor and service client
accounts associated with these institutions. The support services that Lutz Financial
obtains can include investment-related research; pricing information and market data;
compliance or practice management-related publications; discounted or free
attendance at conferences, educational or social events; or other products used by Lutz
Financial to further its investment management business operations.
20
Certain of the support services or products received may assist Lutz Financial in
managing and administering client accounts. Others do not directly provide this
assistance, but rather assist Lutz Financial to manage and further develop its business
enterprise.
Lutz Financial’s clients do not pay more for investment transactions effected or assets
maintained at the Custodians because of these arrangements. There is no corresponding
commitment made by Lutz Financial to any broker-dealer or custodian or any other
entity to invest any specific amount or percentage of client assets in any specific mutual
funds, securities or other investment products because of the above arrangements.
Lutz Financial’s Chief Compliance Officer, James P. Boulay, remains available
to address any questions that a client or prospective client may have regarding
the above arrangement and any corresponding perceived conflict of interest such
arrangement may create.
2. Lutz Financial does not receive referrals from broker-dealers.
3. Lutz Financial recommends that its clients utilize the brokerage and custodial services
provided by the Custodians. Lutz Financial does not generally accept directed
brokerage arrangements (when a client requires that account transactions be effected
through a specific broker-dealer). In such client directed arrangements, the client will
negotiate terms and arrangements for their account with that broker-dealer, and Lutz
Financial will not seek better execution services or prices from other broker-dealers or
be able to "batch" the client’s transactions for execution through other broker-dealers
with orders for other accounts managed by Lutz Financial. As a result, client may 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.
In the event that the client directs Lutz Financial to effect securities transactions for the
client’s accounts through a specific broker-dealer, the client correspondingly
acknowledges that such direction may cause the accounts to incur higher commissions
or transaction costs than the accounts would otherwise incur had the client determined
to effect account transactions through alternative clearing arrangements that may be
available through Lutz Financial. Higher transaction costs adversely impact account
performance.
Transactions for directed accounts will generally be executed following the execution
of portfolio transactions for non-directed accounts.
Lutz Financial’s Chief Compliance Officer, James P. Boulay, remains available
to address any questions that a client or prospective client may have regarding
the above arrangement.
B. Transactions for each client account generally will be effected independently, unless Firm
decides to purchase or sell the same securities for several clients at approximately the same
time. The Firm may (but is not obligated to) combine or “batch” such orders for individual
equity transactions (including ETFs) with the intention to obtain better price execution, to
negotiate more favorable commission rates, or to allocate more equitably among the
Firm’s clients differences in prices and commissions or other transaction costs that might
21
have occurred had such orders been placed independently. Under this procedure,
transactions will be averaged as to price and will be allocated among clients in proportion
to the purchase and sale orders placed for each client account on any given day. Lutz
Financial shall not receive any additional compensation or remuneration as a result of such
aggregation.
Item 13
Review of Accounts
A. For those clients to whom Lutz Financial provides investment supervisory services,
account reviews are conducted on an ongoing basis by Lutz Financial’s Managing Member,
James P. Boulay and/or representatives, Justin B. Vossen, Nick Hall, Joe Hefflinger, Austin
Wells, Chris Wagner, Joe Carlson, Tom Hodgson and Josh Jenkins. All investment
supervisory and financial planning clients are advised that it remains their responsibility to
advise Lutz Financial of any changes in their investment objectives and/or financial
situation. All clients (in person or telephonically) are encouraged to review financial
planning issues, investment objectives and account performance with Lutz Financial on an
annual basis, as applicable.
There will likely be extended periods of time when Lutz Financial determines that changes
to a client’s portfolio are not necessary. However, clients remain responsible for payment
of their advisory fees and for determining whether the services of Lutz Financial are still
warranted.
B. Lutz Financial may conduct account reviews on an other than periodic basis upon the
occurrence of a triggering event, such as a change in client investment objectives and/or
financial situation, market corrections and client request.
C. Clients are provided, at least quarterly, with written transaction confirmation notices and
regular written summary account statements directly from the broker-dealer/custodian
and/or program sponsor for the client accounts. In most instances, Lutz Financial also
provides written quarterly reports summarizing account activity and performance.
Item 14
Client Referrals and Other Compensation
A. As referenced in Item 12.A.1 above, Lutz Financial receives economic benefits from
certain custodians including support services, without cost (and/or at a discount). Lutz
Financial’s clients do not pay more for investment transactions effected and/or assets
maintained at the custodians as a result of this arrangement. There is no corresponding
commitment made by Lutz Financial to the custodian or any other entity to invest any
specific amount or percentage of client assets in any specific mutual funds, securities or
other investment products as a result of the above arrangement.
B. Lutz Financial does not compensate, directly or indirectly, any person, other than its
representatives, for client referrals.
Item 15
Custody
Lutz Financial shall have the ability to have its advisory fee for each client debited by the
custodian. Clients are provided with transaction confirmation notices and regular summary
22
account statements directly from the broker-dealer/custodian for the client accounts. Those
clients to whom Lutz Financial provides investment supervisory services will also receive
a quarterly report from Lutz Financial summarizing account activity and performance.
To the extent that Lutz Financial provides clients with periodic account statements or
reports, the client is urged to compare any statement or report provided by Lutz Financial
with the account statements received from the account custodian. The account custodian
does not verify the accuracy of Lutz Financial’s advisory fee calculation.
In addition, certain clients have established asset transfer authorizations that permit the
qualified custodian to rely upon instructions from Lutz Financial to transfer client funds or
securities to third parties. These arrangements are disclosed at Item 9 of Part 1 of Form
ADV. However, in accordance with the guidance provided in the SEC’s February 21, 2017
Investment Adviser Association No-Action Letter, the affected accounts are not subject to
an annual surprise CPA examination. ANY QUESTIONS: Lutz Financial’s Chief
Compliance Officer, James P. Boulay, remains available to address any questions
that a client or prospective client may have regarding custody-related issues.
Item 16
Investment Discretion
The client can determine to engage Lutz Financial to provide investment advisory services
on a discretionary basis. Prior to Lutz Financial assuming discretionary authority over a
client’s account, the client shall be required to execute Investment Advisory Agreement,
naming Lutz Financial as the client’s attorney and agent in fact, granting Lutz Financial
full authority to buy, sell, or otherwise effect investment transactions involving the assets
in the client’s name found in the discretionary account.
Clients who engage Lutz Financial on a discretionary basis may, at any time, impose
restrictions, in writing, on Lutz Financial’s discretionary authority (i.e., limit the
types/amounts of particular securities purchased for their account, exclude the ability to
purchase securities with an inverse relationship to the market, limit or proscribe Lutz
Financial’s use of margin, etc.).
Item 17
Voting Client Securities
A. Lutz Financial does not vote client proxies. Clients maintain exclusive responsibility for:
(1) directing the manner in which proxies solicited by issuers of securities beneficially
owned by the client shall be voted, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the
client’s investment assets.
B. Clients will receive their proxies or other solicitations directly from their custodian. Clients
may contact Lutz Financial to discuss any questions they may have with a particular
solicitation.
Item 18
Financial Information
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A. Lutz Financial does not solicit fees of more than $1,200, per client, six months or more in
advance.
B. Lutz Financial 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
certain client accounts.
C. Lutz Financial has not been the subject of a bankruptcy petition.
ANY QUESTIONS: Lutz Financial’s Chief Compliance Officer, James P. Boulay, remains
available to address any questions that a client or prospective client may have regarding the
above disclosures and arrangements.
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