Disclosures

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The 401(k) Optimizer® is offered through Howard Capital Management (HCM), an SEC-registered investment adviser which only does business where it is properly registered or is otherwise exempt from registration. SEC registration does not constitute an endorsement of the firm by the Commission nor does it indicate that the adviser has attained a particular level of skill or ability. The firm may make investment decisions that are inconsistent with the information provided herein. Stop loss protection will not necessarily contain your losses in the desired amounts due to the tool’s limitations, market conditions, and delays in executing orders. It is not an actual stop loss order that automatically sells securities in the portfolio at a certain price. All investment strategies have the potential for profit or loss. Asset allocation and diversification do not assure or guarantee better performance and cannot eliminate the risk of investment losses. The 401(k) Optimizer® is a web-based tool intended to help clients invest in their employer’s 401(k) or similar defined contribution plan. Clients receive professional recommendations from The 401(k) Optimizer® and maintain total control over their personal accounts. The goal is to reduce risk by taking proactive measures with company-sponsored retirement plans.

Changes in investment strategies, contributions or withdrawals may materially alter the performance,strategy and results of your portfolio. Different types of investments involve varying degrees of risk, andthere can be no assurance that any specific investment (including the investments and/or investmentstrategies recommended by the advisors), will either be suitable or profitable for client’s investmentportfolio. Past performance does not guarantee future results. All investment strategies have thepotential for profit or loss. Economic factors, market conditions, and investment strategies will affect theperformance of any portfolio and there are no assurances that it will match or outperform any particularbenchmark for measuring the performance of a portfolio.

The subscriber acknowledges and understands that the OTI is an opinion only, based upon HCM’s judgment as of a particular date. That opinion could be wrong. No current or prospective subscriber to the HCM 401(k) Optimizer® should assume that investment in, or purchase and sale of, his/her company stock based upon the OTI will be profitable for his/her retirement portfolio. Unlike the mutual funds that are available for investment in the subscriber’s retirement portfolio, individual equities such as the subscriber’s company stock are not diversified positions, and may be subject to greater volatility and principal risk.

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 down trends and catch the vast bulk of the up trends. 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.  
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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. Stop loss protection 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. It is not an actual stop loss order that automatically sells securities in the portfolio at a certain price.
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