Howard Capital Management Disclosures

Unless otherwise noted, performance results are presented net of advisory fees of 2.2% and reflect the reinvestment of dividends and capital gains. Past performance may not be indicative of future results. Therefore, 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. Performance results represent the results of our model portfolios. The actual current performance of the portfolio may be lower or higher than the performance of the strategy. The returns for the strategy in certain years were significantly higher than the returns of its comparative benchmark index. These returns were the result of certain market factors and events that may not be replicated in the future. Style allocation in all portfolios will vary over time and may be changed at Howard Capital Management, Inc.'s discretion. It is important to remember that there are risks inherent in any investment and that there is no assurance that any money manager, asset class, style, or index will provide positive performance over time.

All investment strategies have the potential for profit or loss. 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, and there can be no assurance that any specific investment will either be suitable or profitable for a client's investment portfolio.

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. 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. Depending upon the holdings in your portfolio, your investment objectives, and your risk temperament, it may be more appropriate to measure performance against a different benchmark.

The S&P 500 Index is a market capitalization- weighted index of 500 widely held stocks often used as a proxy for the stock market. It measures the movement of the largest issues. Standard and Poor's chooses the member companies for the 500 based on market size, liquidity, and industry group representation. Included are the stocks of industrial, financial, utility, and transportation companies. All performance results are unaudited and have not been independently verified. Information pertaining to Howard Capital Management, Inc.'s advisory operations, services, and fee's is set forth to Howard Capital Management, Inc.'s current disclosure statement, a copy of which is available from Howard Capital Management, Inc. upon request.

For reasons including variances in program account holdings, transactions and custodial fee variances, market fluctuation, the date on which a client became a participant in the program, and an account contributions or withdrawals, the performance of a specific client's account may vary substantially from the indicated performance results. For more complete information, including fees and expenses on mutual fund, call or write for a prospectus. Read the prospectus carefully before you invest. You should consider the portfolio's investment objectives, risks, and charges and expenses carefully before investing. An investment in a portfolio containing small-cap companies is subject to additional risks, as the share prices of small-cap companies are often more volatile than those of larger companies due to several factors, including limited trading volumes, products, financial resources, management inexperience and less publicly available information.

Howard Capital Management, Inc. may involve an above-average turnover, which could have a negative impact upon the net-after tax gain experienced by an individual client in a taxable account. To the extent that there has been a change in a client's investment objectives or financial situation, he/she/it is encouraged to advise Howard Capital Management, Inc. immediately. Different types of investment and/or investment strategies involve varying levels of risk, and there can be no assurance that any specific investment or investment strategy (including the investments purchased and/or investment strategies devised by Howard Capital Management, Inc.) will be either suitable or profitable for a client's or prospective client's portfolio.

This communication is issued by Howard Capital Management, Inc. It is for informational purposes and is not an official confirmation of terms. It is not guaranteed as to accuracy, nor is it a complete statement of the financial products or markets referred to. Opinions expressed are subject to change without notice. Howard Capital Management, Inc. may maintain long or short positions in the financial instruments referred to and may transact in them as principal or agent. Unless stated specifically otherwise, this is not a recommendation, offer or solicitation to buy or sell and any prices or quotations contained herein are indicative only. To the extent permitted by law, Howard Capital Management, Inc. does not accept any liability arising from the use of this communication. Moreover, you should not assume that any discussion or information contained in the communications of Howard Capital Management, Inc. serves as the receipt of, or a substitute for, personalized investment advice from Howard Capital Management, Inc. or from any other investment professional. Howard Capital Management is an SEC-registered investment adviser which only does business where it is properly registered or is otherwise exempt from registration. Past performance is no guarantee of future results.