Luedtke & Associates LLC

Item 5 – Fees and Compensation
Fee Calculations & Clarifications
Luedtke began operating in earnest as an independent registered investment advisor on
October 1, 2025. Some clients have executed an advisory agreement with the Firm with
an effective date of October 1, 2025 (“Luedtke Advisory Agreement”). These agreements
were signed as we continue migrating client accounts from Commonwealth Financial
Network and its affiliated broker-dealer, National Financial Services (“NFS”), to our
preferred broker-dealer and custodial partner, Charles Schwab & Company, Inc.
(“Schwab”).
As part of the transition, transfers of client accounts from NFS to Schwab have been
completed on a rolling basis, with our team working diligently with both firms to expedite
the process. Despite these efforts, some client accounts have transitioned to Schwab
sooner than others, with certain client accounts remaining at NFS beyond the October 1,
2025, effective date set forth in the Luedtke Advisory Agreement. In light of these
circumstances, we want to outline how our advisory fees have been applied to your
accounts during this transition period.
Accordingly, please be advised as follows:
   1. Fee Billing While Your Account Remained at NFS. To the extent any of your
      account(s) remained at NFS beyond the October 1, 2025 effective date set forth in

       our Luedtke Advisory Agreement, such accounts have continued to be billed in
       accordance with the Commonwealth branded “PPS Custom Client Agreement,”
       “PPS Select Client Agreement,” and/or “Master Services Agreement” through the
       date of their transfer to Schwab.
   2. Fee Billing Post-Transfer of Your Account to Schwab. The fee schedule and other
      policies and terms described in the Luedtke Advisory Agreement has been applied
      effective as of the date your accounts became available for our management at
      Schwab.
Portfolio Management Fees
Fees for advisory services are generally calculated as a percentage of the total market value
of your managed assets. The total fee is comprised of two components: (a) the Advisory Fee
charged by Luedtke, and (b) if applicable, any fees associated with the use of a TPAM.

Fees are billed monthly in arrears and calculated based upon the average daily balance of the
Account during the applicable billing period. The maximum fee charged will not exceed 1.15%.
The average daily balance is calculated by summing the market value (or fair value, in the
absence of market value) of the Account for each day in the applicable billing period and
dividing by the number of days in the billing period. The monthly fee is then determined by
applying the applicable annual fee rate to the average daily balance of the Account and dividing
by twelve.

Certain TPAMs and fee-based insurance product vendors may impose billing practices that vary
from the Advisor’s billing practices set forth herein. In such instances, Client agrees that Advisor
is authorized to adjust its billing practices to accommodate those of the subject TPAMs and
fee-based insurance product vendors.

Luedtke is entitled to rely upon the Custodian’s calculation of the market value of assets held
in the Account for purposes of calculating the advisory fees due hereunder. In computing the
market value of any investment held in the Account, each security listed on any national
securities exchange or otherwise subject to current last-sale reporting shall be valued at the
last sale price on the valuation date. However, for assets such as alternative investments where
a fee is charged and the Custodian does not price the security, the asset may be priced (i) by
the provider of the asset according to their pricing policy; (ii) by an independent pricing service;
and/or (iii) by Advisor using a fair valuation method which complies with generally accepted
accounting practices (“GAAP”) in the United States.

Because fees are calculated based on the Account’s average daily balance for the billing period,
fees are inherently prorated for any period during which the Account is opened, closed, or
otherwise not managed for the full billing cycle, and no separate proration calculation is
applied. In the event Advisor’s services are terminated during a billing period, Advisor shall be
entitled to bill Client for all fees accrued through the effective date of termination, calculated
in accordance with the foregoing methodology, and no fees shall be charged for any period
thereafter.

You authorize fees to be deducted from your account, or from any other account in the
custodian’s custody as directed by you. The fees deducted, including the dates and amounts,

are reflected in the account statements sent by the custodian. You should review those
statements, and the fees deducted. Any questions on the fees deducted from your account
should be directed to your IAR, or you may contact us at the number on the cover page of this
Brochure.

Fees are negotiated on an individual basis at the time of engagement for such services. Factors
considered in determining the fees charged generally include, without limitation, the
complexity of the portfolio, amount of assets to be placed under management, related
accounts, or other special requirements. This practice creates a conflict of interest because
some clients will pay more than other clients for the same Advisory Services.

Since Luedtke started providing Advisory Services, some IARs may have clients under legacy
advisory fee schedules in effect at the time of the client’s engagement. As new advisory fee
schedules are implemented, they are made applicable to only new clients and fees for existing
clients are not affected. Therefore, some existing clients pay different advisory fees than are
being charged currently and not all clients will have the same or similar fee structures (e.g.,
flat percentage rate or tiered) and can be subject to a minimum advisory fee. Your specific fee
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Item 7 – Types of Clients
Luedtke generally provides advisory services to the following types of clients:

   •   Individuals (other than high net worth individuals)
   •   High net worth individuals
   •   Corporations or other businesses not listed above
   •   Other: For an asset-based fee, Luedtke may contract directly with third-party broker-
       dealers and insurance carriers to maintain current client financial profiles and to
       provide ongoing account suitability and best interest analysis for client accounts held
       at those third parties.

Luedtke does not have a minimum account size requirement.

However, our managed account programs generally require clients to meet certain account
minimums. In some cases, account balances may be combined at the household level to
satisfy the account minimum. Refer to the third-party program disclosure document for
information on minimum account size requirements or any other conditions for managing an
account.