A. Description of the Advisory Firm Luken Investment Analytics, LLC (hereinafter “LIA”) is a Limited Liability Company organized in the State of Tennessee. LIA is a registered investment adviser registered with the Securities and Exchange Commission (SEC). The firm was formed in May 2013, and the principal owner is Gregory Lee Luken. B. Types of Advisory Services LIA provides investment advisory services to individual investors (“Clients”) and to other registered investment advisers ("Advisers"). These services are described below. As a registered investment adviser, we are held to the highest standard of client care - a fiduciary standard. As a fiduciary we always put our client's interests first and must fully disclose any potential conflict of interest. We do not directly hold customer funds or securities. It is the Firm’s policy to always seek the best possible executions. The firm does not act as principal, but rather as agent on customer transactions. LIA offers the following advisory programs: Financial Planning Services Program LIA provides financial planning services to individual retail Clients. Clients pay a one-time fee for this program. Clients pay a deposit and the remainder of the fee for this program is due when the financial plan is delivered. Services include some or all of the following: general investment education, retirement planning, estate planning, college planning, debt and cash flow analysis, broader assessments of the Clients’ overall financial situation, income needs and goals, analysis with regard to investment of distributions from employer retirement plans and profit-sharing plans. Clients will receive a written financial plan designed to assist Clients in identifying specific financial objectives and goals. Discretionary WRAP Program LIA provides discretionary investment advisory services to individual retail Clients. Clients pay the fee for this program monthly in advance. LIA receives no additional payments or commissions for accounts in this program. These services include some or all of the following: trading, explanation of investment concepts and strategies, asset allocation modeling, assistance with interpreting investment performance reports, broader assessments of the Clients’ overall financial situation, income needs and goals. The Clients’ goals, objectives and risk tolerance are matched with the model or models that are most suitable. Model allocations are reviewed quarterly, and adjustments are made as necessary to realign with the model allocation. LIA also provides discretionary investment advisory services to retail clients for their 401(k) plan accounts via the Pontera platform. Target allocations for these accounts are reviewed quarterly and adjustments are made as necessary, and as allowed by the plan, to realign with target allocations. Clients can cancel the advisory services by giving 30 days prior written notice. Model Subscription Program LIA provides newsletter subscription services for a fee to Investment Advisor Representatives, “Subscribers”. These services include a newsletter and security ratings service that will offer recommendations on purchasing and selling specific securities, sectors, asset classes, or other specific groupings of securities at a stated time. This newsletter will be provided via electronic mail and via a website and can be cancelled by giving written notice. Transaction recommendations are sent to our Subscribers for them to communicate to their qualified custodians who execute, compare, allocate, clear, and settle the transactions. We neither handle nor execute trades for Subscribers. Services Limited to Specific Types of Investments LIA will assign each advisory account to a model based on the clients’ investment needs. The investments will primarily consist of Mutual Funds, Equity Securities, and Exchange Traded Funds. Advisory Representatives In addition to LIA, the Representative who recommends the advisory program to the Client receives compensation as a result of the Client’s participation in the program. Our advisory personnel are expected to have education and business backgrounds that enable them to perform their respective responsibilities effectively. No formal standards have been set, but appropriate education and experience

are required. See your Representative’s Form ADV Part 2B Brochure Supplement for additional information on their background and experience. C. Client Tailored Services and Client Imposed Restrictions Advisory Client investment strategies and their implementation are dependent upon our consulting with the Client and reviewing each client’s current situation (objectives, goals, income, tax levels, and risk tolerance levels). LIA makes recommendations and suitability determinations as to which asset allocation models are best for its Clients based upon information provided by the Client. It is important that each Client provide accurate and complete responses to the questions asked by the Representative and that the Client promptly inform the Representative of any subsequent changes to the information provided. Clients cannot impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. For our Investment Adviser Representative Subscribers, specific client investment strategies and their implementation are dependent upon the Subscriber consulting with their client and reviewing their Investment Policy Statement, or similar documents, which outlines their client’s current situation (income, tax levels, and risk tolerance levels). LIA does not make recommendations or suitability determinations as to which strategies are best for its Subscribers or their clients. The Subscriber determines if their clients can impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. You should be aware that all investment programs involve risk and there is no guarantee that using our Services will produce favorable results. Please carefully review the information and statements contained in any investment-related materials provided to you and be sure to ask for assistance in clarifying any questions you have regarding the materials you receive. LIA suggests that each Client works closely with their Representative, attorney, accountant and insurance agent. D. WRAP Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and other administrative fees. LIA sponsors one wrap fee program, The Discretionary Wrap Program. Benefits of a wrap fee program depend, in part, on the size of the account, the costs associated with managing the account, and the frequency and types of securities transactions executed and held in the account. A Wrap fee program may not be suitable for all accounts, including cash or cash equivalent investments, fixed income securities, no-transaction-fee mutual funds or other securities that can be traded without commissions or other transaction fees. You should compare the agreed upon costs associated with participating in a Wrap Fee Program with amounts that would be charged by others who charge for investment advice, brokerage, transaction, execution and custodial services individually. Conflict of Interest We receive as compensation for advisory services the balance of the Wrap fee you pay after custodial and other management costs (including execution and transaction fees) have been deducted. This creates a conflict of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred by your accounts. Schwab and other custodians have eliminated commissions for online trades of U.S. equities, ETF’s and options (subject to a per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay commissions to Schwab. When you choose a wrap fee arrangement, your total cost could exceed the cost of paying for brokerage and advisory services separately. Further details relating to this program are available in Appendix 1: Wrap Program Brochure. E. Assets Under Management As of December 31, 2023, LIA has a total of $200,869,616 assets under management. LIA manages $200,838,076 on a discretionary basis and $31,540 on a non-discretionary basis.