OVER A 21 YEAR PERIOD SCOTT EARNED 54% MORE MONEY FOR RETIREMENT THAN SAM.

Active Lifestyle Portfolio
Model Overview Disclosure

Active Lifestyle Portfolio (ALP) strategy typically seeks to participate in all markets and sectors by investing the portfolio in sectors which HCM’s Proactive
Section Rotation (PSR) methodology indicates have potential to meet performance objectives. PSR is a tactical asset allocation methodology, which
attempts to identify the best performing sectors at a given point in time. The ALP strategy utilizes the HCM-BuyLine® proprietary indicator to monitor
market conditions and assist in determining whether or not assets should be invested in equity products or moved to cash, cash equivalents, or bond
funds. Multiple indicators are monitored in an effort to identify such trends in the equity markets. The strategy is rebalanced periodically, and it is possible
for the allocation to be adjusted, including when the HCM-BuyLine® indicates a strengthening or weakening of the equity markets. Because this Howard
Capital Management, Inc. (HCM) strategy is actively managed, it may experience above-average turnover, which could have a negative impact on
account performance. To discourage short-term investing and excessive trading, mutual funds, including those utilized in the ALP strategy, may impose
short-term redemption fees that range from 0.50% to 2.00%. HCM seeks to avoid these fees, but they may occasionally be incurred.

Comparative Benchmark. Aggressive – S&P 500 Monthly Reinvested Index (10%), HFRX Equity Hedge Index (90%). Growth- S&P 500 Monthly
Reinvested Index (5%), HFRX Equity Hedge Index (75%), Barclays Capital US Aggregate Bond TR Index (20%). Balanced- S&P 500 Monthly Reinvested
Index (5%), HFRX Equity Hedge Index (60%), Barclays Capital US Aggregate Bond TR Index (35%). Conservative- S&P 500 Monthly Reinvested Index (5%),
HFRX Equity Hedge Index (40%), Barclays Capital US Aggregate Bond TR Index (55%). S&P 500 Reinvested is a gauge of the large cap U.S. equities
market. The index includes 500 leading companies in leading industries of the U.S. economy, capturing 75% coverage of U.S. equities. S&P 500
Reinvested assumes dividends are reinvested. Visit http://www.standardandpoors.com/indices for more information regarding Standard & Poor’s indices.
HFRX Equity Hedge Index is constructed using a UCITSIII compliant methodology, which is based on defined and predetermined rules and objective
criteria to select and rebalance components to maximize representation of the Hedge Fund Universe. HFRX Indices utilize quantitative techniques and
analysis, multi-level screening, cluster analysis, Monte-Carlo simulations and optimization techniques to ensure that each Index is a pure representation of
its corresponding investment focus. Full strategy and regional descriptions (multi-language), as well as the full “HFRX Hedge Fund Indices Defined
Formulaic Methodology” may be downloaded at www.hfrx.com. Barclays Capital US Aggregate Bond TR Index is a broad-based benchmark that
measures the investment grade, US dollar-denominated, fixed-rate taxable bond market, including Treasuries, government-related and corporate
securities, MBS (agency fixed-rate and hybrid ARM passthroughs), ABS, and CMBS. The US Aggregate rolls up into other Barclays Capital flagship indices
such as the multi-currency Global Aggregate Index and the US Universal Index, which includes high yield and emerging markets debt. The US Aggregate
Index was created in 1986, with index history backfilled to January 1, 1976. Total Return (TR) assumes yield is reinvested. Visit https://
ecommerce.barcap.com/indices for more information regarding Barclays Capital indices. Indices are unmanaged investment measures and are not
available for investment purposes.

Active Lifestyle Portfolio (ALP) strategy data in this report has been distributed for informational purposes only and should not be considered as
investment advice or a recommendation of any particular security, strategy or investment product. No part of this material may be reproduced in any
form, or referred to in any other publication, without express written permission of Howard Capital Management, Inc. 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. This presentation is limited to the dissemination of general information pertaining to its
investment advisory/management services. Any subsequent, direct communication by HCM with a prospective client shall be conducted by a
representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. 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.
The information contained herein: (1) is proprietary to Morningstar and/or its content providers; (2) may not be copied or distributed; and (3) is not
warranted to be accurate, complete or timely.

All investment approaches have the potential for loss as well as gain. There is no certainty that any investment or strategy (including the investments
and/or investment strategies recommended by the advisor), will be profitable or successful in achieving investment objectives. Please work with your
financial professional to determine which investment program is consistent with your financial objectives and risk tolerance.LASS.ALPO.MS.0920
Source: Morningstar

Howard Capital Management Model Overview Disclosure

Howard capital management, inc. (“hcm”) is registered with the sec and only transacts 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 advisor has attained a particular level of skill or ability. changes in investment strategies, contributions or withdrawals, and economic conditions may materially alter the performance of your portfolio. Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment or strategy may be suitable or profitable for an investor’s portfolio. past performance may not be indicative of future results. hcm indicator. the hcm-buyline® (indicator) our proprietary indicator is used to assist in determining when to buy and sell securities. when the indicator identifies signs of a rising market, hcm then identifies the particular security(ies) that hcm believes have the top return potentials in the current market from the universe of assets available in each given model and signals to invest in them. When the indicator identifies signs of a declining market, the indicator signals to move clients’ investments to less risky alternatives. not every signal generated by the indicator can result in a profitable trade. there may be times when following the indicators results in a loss. an important goal of the indicator 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 indicator is a reactive in nature, not proactive. They are not designed to catch the first 5–10% of a bull or bear market. ideally, they can avoid almost all of the downtrends and catch the bulk of the uptrends. there may be times when the use of the indicator may result in a loss when hcm re-enters the market. other times there may be a modest positive impact. When severe downtrends occur, however, such as in 2000-2002 and 2007-2008, the indicator has the potential to make a significant difference in portfolio performance. naturally, there can be no assurance that the indicator can perform as anticipated. the indicator does not generate stop-loss orders that automatically sell securities in the portfolio at a certain price. as a result, use of the indicator may not necessarily limit your losses to the desired amounts due to the limitations of the indicator, market conditions, and delays in executing orders. ease remember to contact hcm, in writing, if there are any changes in your personal/financial situation or investment goals for the purpose of reviewing/evaluating/revising our previous recommendations and/or services, or if you want to impose, add, or modify any reasonable restrictions to our investment advisory services. please note: unless you advise, in writing, to the contrary, we can assume that there are no restrictions on our services, other than to manage the account in accordance with your designated investment goals. a copy of our current written disclosure brochure discussing our advisory services and fees continues to remain available upon request. lass.vsg.bl.1120 hcm-111620-6 securities and investment advisory services are offered through brokers international financial services, llc. member sipc. brokers international financial services, llc is not an affiliated company