Overview

Assets Under Management: $2.3 billion
Headquarters: OMAHA, NE
High-Net-Worth Clients: 369
Average Client Assets: $5 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Portfolio Management for Institutional Clients, Pension Consulting

Fee Structure

Primary Fee Schedule (ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.00%
$1,000,001 $2,000,000 0.75%
$2,000,001 $5,000,000 0.60%
$5,000,001 $10,000,000 0.45%
$10,000,001 $25,000,000 0.40%
$25,000,001 and above 0.30%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $35,500 0.71%
$10 million $58,000 0.58%
$50 million $193,000 0.39%
$100 million $343,000 0.34%

Clients

Number of High-Net-Worth Clients: 369
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 73.59
Average High-Net-Worth Client Assets: $5 million
Total Client Accounts: 2,186
Discretionary Accounts: 2,014
Non-Discretionary Accounts: 172

Regulatory Filings

CRD Number: 117273
Last Filing Date: 2024-06-13 00:00:00
Website: HTTPS://WWW.LINKEDIN.COM/IN/SAM-BONEBRAKE-70002219B

Form ADV Documents

Primary Brochure: ADV PART 2A (2025-03-30)

View Document Text
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 2 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. 3 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 4 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 5 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 6 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. 7 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 8 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. 9 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 10 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 11 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. 13 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. 14 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 23 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. 24