Luken Investment Analytics LLC

Item 5: Fees and Compensation

A. Fee Schedule

Financial Planning Fees
Fees for the Financial Planning Program are a flat fee based upon the complexity
of the consulting arrangement and services to be rendered. The fees for this
program are negotiable and generally range from $500 to $5,000.

Discretionary Wrap Program Fees
Client Advisory Programs fees are billed monthly in advance and are debited
directly from the Client account. The annual advisory fee is negotiable between the
Client and the Representative. It can be a specific fee percentage; however, the
fee is most often based on a sliding schedule that ranges from 30 to 160 basis
points. This results in different fees for similar accounts. Based on your investment
portfolio and investment strategy, the costs associated with an advisory account
can exceed the commissions you would pay for brokerage services only.

Pontera retirement plan participants are billed quarterly in arrears and are debited
directly from their designated Schwab account. The annual advisory fee is
negotiable between the Client and the Adviser, however the fee is most often
0.75%.

Bloomwell 529 account participants do not pay a fee for this
service.

Model Subscription Fees
LWM offers a monthly subscription newsletter and quarterly allocation updates to
other Registered Investment Advisers and Investment Adviser Representatives.
Subscribers choose between varying subscription levels that include services
ranging from newsletters and allocation updates to access to client tools,
communications and investment models and strategies. The subscription dues
are generally charged monthly in advance; however, subscribers have the option
to pay annually in advance at a discounted rate. For current subscription levels
and rates, please email greg@lukenanalytics.com or call 615-550-5570.

Subscription fees are not refundable and generally not negotiable.

Employee Accounts and Pro Bono Accounts
With regard to employee and/or employee-related accounts and certain other
accounts, the quarterly fees are generally less, depending upon a number of
factors, including portfolio size, length of employment and relationship to the
employee. Advisory fees for accounts may be waived at the discretion of the
Adviser for reasons which may include but not be limited to familial relationships
and accounts within a household.

Termination of Agreement
The standard advisory contract has an initial term of one year and automatically
renews for unlimited one-year terms. Clients and Subscribers can terminate their
agreement without penalty, for a full refund of LWM’s fees, within five business
days of signing the Investment Advisory Contract or Subscription Agreement.
Thereafter, Clients and Subscribers can terminate their Agreement with written
notice. Any unearned portion of advisory fees paid by Clients in advance will be
refunded. LWM reserves the right to charge a $100 termination fee if the advisory

account is terminated by Client within the first year. LWM does not refund
subscription fees.

B. Payment of Fees

Payment of Financial Planning Fees
Financial Planning Services Program fees are negotiated before the plan is
created. A deposit is requested and full payment is due when the financial plan is
delivered.

Payment of Discretionary WRAP Program Fees
Advisory fees are paid monthly in advance and are debited directly from the
Client account, or other client account as the client may direct. Fees are
calculated by multiplying the account value on the last day of the previous month
by the annual fee percentage, then multiplying by the number of days in the
upcoming month divided by the number of days in the year.

Pontera Retirement Plan Participant fees are billed quarterly in arrears and are
debited directly from their designated Schwab account. The annual advisory fee is
negotiable between the Client and the Adviser, however the fee is most often
0.75%.

Bloomwell investment advisory services to 529 plan participants not billed a fee for
this service.

Payment of Model Subscription Fees
Subscription fees are generally paid monthly or annually via credit card.

C. Clients Are Responsible For Third Party Fees

For individual Clients who pay LWM advisory fees, in addition to our advisory fee,
you will incur certain charges imposed by third parties which are not assessed or
received by LWM or your Representative. Such charges include, but are not limited
to, custodial fees, clearing firm fees, charges imposed by a mutual fund, index
fund, or exchange traded fund purchased for the account which shall be disclosed
in the fund’s prospectus (e.g., fund management fees and other fund expenses),
certain deferred sales charges, odd-lot differentials, transfer taxes, wire transfer
and electronic fund fees, brokerage account termination fees, annual account
maintenance fees, SEC fees, Reg Fees, Trading Activity Fees, exchange and floor
fees, and other fees and taxes on brokerage accounts and securities transactions.

D. Prepayment of Fees

      As described above, LWM collects certain program fees in advance. Upon
      termination, any unearned portion of fees paid in advance will be refunded.

       E. Outside Compensation

       Gregory L. Luken is President of Luken Wealth Management and a licensed
       insurance agent. From time to time, he will offer clients advice or products in his
       capacity as an insurance agent.

      1. Conflict of Interest
       The insurance business presents a conflict of interest and provides an incentive
       to recommend products based on the compensation received rather than on the
       client’s needs. When recommending the sale of insurance products for which any
       supervised person receives compensation, LWM will document the conflict of
       interest in the Insurance Log and confirm the client received the ADV as
       disclosure of the conflict of interest. Clients should be aware that these services
...

Item 7: Types of Clients
LWM provides investment advisory services to individual investors, families, high net
worth investors, trusts, charitable organizations, estates, retirement plan participants and
private business owners.

LWM provides investment subscription services to Registered Investment Advisers and
Investment Adviser Representatives.

       Minimum Account Size

There is no account minimum imposed by LWM for any of LWM’s services.