Private Wealth Services (PWS) Disclosure

Howard Capital Management, Inc. (“HCM”) is an SEC-registered investment advisor with its principal place of business in the State of Georgia. SEC registration does not constitute an endorsement of HCM by the SEC, nor does it indicate that HCM has arraigned a particular level of skill or ability. HCM only transacts business where it is properly registered or is otherwise exempt from registration. For information pertaining to the registration status of HCM, please contact HCM or refer to the Investment Advisor Public Disclosure web site (www.adviserinfo.sec.gov). For additional information about HCM, including fees and services, send for our disclosure statement as set forth on Form ADV from us using the contact information herein. Please read the disclosure statement carefully before you invest or send money. Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment or strategy will either be suitable or profitable for a client’s investment portfolio. Investment returns will fluctuate and are subject to market volatility due to general market and economic conditions and perceptions, so that an investor’s shares when redeemed may be worth more or less than their original costs. Please work with your financial professional to determine which investment program is consistent with your financial objectives and risk tolerance. HCM offers its investment methodology through multiple programs that may invest in exchange traded funds, individual equities, and mutual funds. There is no certainty that any investment or strategy (including the investments and/or investment strategies recommended by your advisor), will be profitable or successful in achieving investment objectives. This presentation includes a comparison of the client’s actual account performance since inception against the hypothetical performance of the client’s account if allocated in a manner consistent with the Proposed Holdings described herein. While performance information related to each HCM model contained herein is based on actual historical performance of that model, the specific allocation amongst HCM models presented is hypothetical in nature. Back-tested returns such as these are purely hypothetical, do not reflect actual allocations amongst HCM models in clients’ accounts, should not be viewed as indicative of the manager’s skill, and do not reflect actual returns achieved by any particular client. Back-tested performance results have inherent limitations, particularly the fact that these results do not represent actual historical allocations amongst HCM models and may not reflect the impact that material economic and market factors might have placed on the adviser’s decision-making if the adviser were actually managing the client’s money. These results should not be viewed as indicative of the adviser’s skill and do not reflect the performance results that were achieved by any particular client. During this period, the manager was not using this combination of models and client’s results were materially different. The models that gave rise to these back-tested performance results are now used by the manager to manage actual client accounts. From inception to present, the results of these HCM strategies reflect the historical model performance of client accounts held at FOLIOfn using these HCM strategies. These returns represent actual trading using client assets at FOLIOfn only. Cash is not factored into the results except when dictated by the HCM-BuyLine®. Results of accounts invested in this (these) model(s) at custodians other than FOLIOfn may vary due to restrictions at the custodian, the amount of cash in the account, and fund availability. HCM performance results: 1) are calculated monthly, 2) are net management fees, deducted monthly, and 3) reflect the reinvestment of all income, and 4) do not consider taxes and custodian fees. All performance results are audited and have been independently verified. The actual performance of an individual client’s portfolio may be lower or higher than the performance of the HCM model portfolio strategies due to differences in timing of contributions and withdrawals, account start date, actual fees paid, and other factors. No current or prospective client should assume that the future performance of any specific investment, investment strategy (including the investments and/or investment strategies recommended by the advisor), will be profitable or equal to past performance levels. Economic factors, market conditions, and investment strategies will affect the performance of any portfolio and there are no assurances that it will match or outperform any particular benchmark for measuring the performance of a portfolio. One or more of the following HCM strategies/models may be used in the management of client accounts:
  • Index Plus- The Index Plus model is designed for investors seeking to maximize growth through broad-based index exposure, while striving to outpace the S&P 500® Total Return Index. Utilizing the HCM-BuyLine®, the Index Plus model is fully liquid and can go to 100% cash or cash equivalents within its equity position to attempt to minimize loss in a market downturn.
  • Low Volatility- The Low Volatility model is designed for investors seeking to maximize growth through investments in Large Capitalization companies that exhibit low volatility respective to their peers, while striving to outpace the S&P 500® Total Return Index. Utilizing the HCM-BuyLine®, the Low Volatility model is fully liquid and can go to 100% cash or cash equivalents within its equity position to attempt to minimize loss in a market downturn.
  • Sector Plus- The Sector Plus model is designed for investors seeking to maximize growth through concentrated investments in any combination of GICS® sectors and sub-sectors, while striving to outpace the S&P 500® Total Return Index. Utilizing the HCM-BuyLine®, the Sector Plus model is fully liquid and can go to 100% cash or cash equivalents within its equity position to attempt to minimize loss in a market downturn.
  • Short-term Bond- The Short-Term Bond model is designed for investors seeking conservative growth and income, while striving to outpace the Bloomberg Barclays US Aggregate Bond Index. This model typically contains holding in one or two sectors of the multi income market at any given time, utilizing our Proactive Sector Rotation methodology to rotate sectors on a periodic basis based on perceived opportunities for better returns indicated. Investments rotate among various multi income asset classes including, but not limited to short-term bonds, high-yield bonds, corporate bonds, convertible bonds, treasuries, and occasionally international bonds and preferred securities. Holdings generally remain invested 100% of the time but can get defensive during market downturns and allocate into defensive areas of the market through application of the HCM-BuyLine®.
  • Long Term Bond- The Long-Term Bond model is designed for investors seeking moderate growth and income, while striving to outpace the Bloomberg Barclays US Aggregate Bond Index. This model typically contains holding in one or two sectors of the multi income market at any given time, utilizing our Proactive Sector Rotation methodology to rotate sectors on a periodic basis based on perceived opportunities for better returns indicated. Investments rotate among various multi income asset classes including, but not limited to medium-, and long-term bonds, high-yield bonds, corporate bonds, convertible bonds, treasuries, and occasionally international bonds and preferred securities. Holdings generally remain invested 100% of the time but can get defensive during market downturns and allocate into defensive areas of the market through application of the HCM-BuyLine®.
  • Muni Bond ETF- The Muni Bond model is designed for investors seeking conservative growth and federally- exempt, tax-free income, while striving to outpace the S&P National AMT-Free Municipal Bond Index. The model typically contains holdings in the municipal bond market at any given time utilizing our proprietary methodology to rotate among various investments on a periodic basis based on perceived opportunities for better returns indicated. These investments include, but are not limited to, short-, medium-, and long-term municipal bond securities and high-yield municipal bond securities. Holdings generally remain invested 100% of the time but can get defensive during market downturns and allocate into defensive areas of the market through application of the HCM-BuyLine®.
  • Nasdaq 100- The Nasdaq 100 model is designed for investors seeking growth through concentrated exposure in the largest domestic and international non-financial companies listed on the Nasdaq Stock Market, while striving to outpace the S&P 500® Total Return Index. The model typically contains constituents of the Nasdaq-100® Index at any given time utilizing our proprietary methodology to rotate among various investments on a periodic basis based on perceived opportunities for better returns indicated. Utilizing the HCM-BuyLine®, the Nasdaq-100 model is fully liquid and can go to 100% cash or cash equivalents within its equity position to attempt to minimize loss in a market downturn.
  • Ultra Aggressive- The Ultra Aggressive model is designed for investors seeking to maximize returns and capital gains through an aggressive investment approach, while striving to outpace the S&P 500® Total Return Index. This portfolio uses HCM’s Proactive Sector Rotation methodology, rotating holdings among various asset classes based on perceived opportunities for better returns. This portfolio is unconstrained by the market and it sectors, investing primarily in various Exchange Traded Funds (ETFs), relying on high-risk, high-reward asset classes. The portfolio will rotate sectors periodically and rebalance periodically based on market movement. Fully liquid, this portfolio can go up to 100% in cash or cash equivalents with the HCM-BuyLine® to potentially minimize loss in a market downturn.
Comparative Index: S&P 500® Total Return. The S&P 500® is widely regarded as the best single gauge of large-cap U.S. equities. There is over USD 11.2 trillion indexed or benchmarked to the index, with indexed assets comprising approximately USD 4.6 trillion of this total. The index includes 500 leading companies and covers approximately 80% of available market capitalization. Historical performance results for investment indices and/or categories have been provided for general comparison purposes only. Indexes are unmanaged investment measures and are not available for investment purposes. The returns of any HCM model or strategy, or any combination thereof, in certain years may be higher than the returns of its comparative benchmark index as a result of certain market factors and events that may not be replicated in the future. In addition, the strategy’s holdings may differ significantly from the securities that comprise the benchmark. Historical performance results for investment indexes and/or categories generally do not reflect the deduction of transaction and/or custodial charges or the deduction of an investment-management fee, the incurrence of which would have the effect of decreasing historical performance results. HCM-BuyLine®. The HCM-BuyLine® is a strategic proprietary indicator used to assist in determining when and how much to invest in equities, including the potential for the equity portion of an HCM strategy to become fully invested in cash, cash equivalents, or bond funds. When the HCM-BuyLine® indicates a bull market, HCM then identifies the particular mutual funds, ETFs or individual stocks that we believe have the best return potentials in the current market from the universe of assets available in each given program and invests in them. When the HCM-BuyLine® indicates a bear market, HCM moves clients’ investments to less risky alternatives. Not every HCM-BuyLine® buy and sell will result in a profitable trade. There will be times when following the indicator results in a loss. However, there have been situations in the past in which HCM reduced clients’ exposure to equities during market downturns by following an HCM-BuyLine® signal, thereby preserving capital. An important goal of the HCM-BuyLine® is to outperform the market on a long-term basis. The reason is the mathematics of gains and losses. A portfolio which suffers a 30% loss takes a 43% gain to return to the previous portfolio value. The HCM-BuyLine® is a reactive indicator, not a proactive one. It will not catch the first 5–10% of a bull or bear market. Ideally, it will avoid most of the downtrends and catch the bulk of the uptrends. There may be times when the use of the indicator will result in a loss when we re-enter the market. Other times there may be a modest positive impact. When severe downtrends occur, however, such as in 2000-2002 and 2007-2008, it has the potential to make a significant difference in portfolio performance. Naturally, there can be no guarantee that the HCM-BuyLine® indicator will perform as anticipated. The HCM-BuyLine® is not a stoploss order that automatically sells securities in the portfolio at a certain price. As a result, it will not necessarily limit your losses to the desired amounts due to the limitations of the HCM-BuyLine®, market conditions, and delays in executing orders. The HCM Private Wealth Services division is designed for high net worth business owners seeking a personalized approach to investing, tax reduction strategies, business planning solutions, legacy strategies, and retirement opportunities. Through a tailored investment strategy, we aim to help business owners reduce their taxes, protect their savings, and optimize their returns.  HCM has established a relationship with an unaffiliated provider of tax savings advice. There is a possibility that the third party entity may refer clients to HCM for investment advisory services, creating a conflict of interest, as recommendations to utilize the services of such third party may be made in the interest of receiving future advisory referrals, rather than basing such recommendation on a particular client’s needs. HCM does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. The client is under no obligation to engage the services of any third-party service provider recommended by HCM. Please Note: If a client engages any recommended unaffiliated professional and/or entity, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional and/or entity. Please remember to contact your adviser, in writing, if there are any changes in your personal/financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services, or if you want to impose, add, to modify any reasonable restrictions to our investment advisory services, or if you wish to direct any specific transactions for your account. A copy of HCM’s current written disclosure Brochure discussing our advisory services and fees continues to remain available upon request. LASS.PWS.PROP.0921