All American Conservative Disclosures

All American Conservative (Holdings: Equity and Multi-Income) 45/55 but may vary at manager’s discretion. The All American Conservative 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 to have the 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 All American Conservative 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, funds, including those utilized in the All American Conservative, 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.

Performance Results. Returns reflect the aggregate of all directly managed client accounts using the All American Conservative strategy.  Returns 1) are calculated monthly, 2) are net of advisory fees (Advisory 2.20%, Custodian 0.21%), deducted monthly in advance, 3) reflect the reinvestment of all income, and 4) are calculated and reported in U.S. dollars. All performance results are audited and have been independently verified.

Mutual Fund and Exchange-Traded Fund Advisory Services. We provide investment advisory services to the HCM Tactical Growth Fund, HCM Dividend Sector Plus Fund, HCM Income Plus Fund, and HCM Dynamic Income Fund (“the Funds”), mutual funds registered under the Investment Company Act of 1940. We also provide investment advisory services to the HCM Defender 100 and HCM Defender 500 exchange-traded funds (“ETFs”). The HCM Tactical Growth Fund seeks long-term capital appreciation through investments in (i) domestic equity securities of any market capitalization, (ii) investment companies (including mutual funds that use leverage), closed-end funds and ETFs (including ETFs that use leverage), and (iii) cash and cash equivalents. The HCM Dividend Sector Plus Fund seeks to achieve its investment objective through investment in (i) dividend paying equity securities of companies included in the S&P 500 and (ii) cash and cash equivalents. The HCM Income Plus Fund seeks income and capital appreciation through investments in ETFs including but not limited to utilities, convertible bonds, real estate, fixed income of any maturity, duration, and credit quality including “junk bonds.” The HCM Dynamic Income Fund seeks total returns through investments in long and/or short positions in fixed income securities, including (i) bills, (ii) notes, (iii) structured notes, (iv) bonds, (v) convertible bonds, or (vi) any other debt or debt-related securities. The HCM Defender 100 ETF seeks to achieve its investment objective through a combination of investments in large and liquid companies classified in the Technology sector as defined by the TRBC Sector Classification and U.S. dollar denominated T – Bills with a time to maturity of 1 to 3 months. The HCM Defender 500 ETF seeks to achieve its investment objective through a combination of investments in large cap equity securities contained in the Solactive US Large Cap Index and U.S. dollar denominated T – Bills with a time to maturity of 1 to 3 months. We will be entitled to an annual advisory fee equal to 1.25% (0.95% for the HCM Income Plus Fund) of each of the Fund’s and ETF’s respective average daily net assets paid on a monthly basis. We may recommend investments in the Funds and/or ETFs for other advisory client accounts, including accounts for owners, officers, and investment adviser representatives associated with our firm. If you have engaged us for discretionary management services, we may invest a percentage of your assets in the Funds and/or ETFs without further approval from you. Because we receive compensation from the Funds and ETFs, we have a financial incentive to invest client assets in the Funds or ETFs or to recommend that clients invest in the Funds or ETFs. However, we will only make such investments and/or recommendations where we believe it is consistent with our fiduciary duty and your investment objectives. We will earn fees from the Funds and ETFs, as well as fees from you for investments made in the Funds and ETFs. For ERISA assets invested in the Funds or ETFs, the advisory fee on such assets will be offset by the amount of the management fee paid to us by the Funds or ETFs. At our discretion, we may offset a portion of your advisory fee against the fees and expenses you may otherwise pay to the Funds or ETFs. You should refer to each Fund and ETF prospectus for a complete description of the fees, investment objectives, risks and other relevant information associated with investing in the Funds and ETFs. Refer to the Investment Discretion section below for additional disclosures on our discretionary authority to manage your investment account. Securities held in separate accounts, including accounts for owners, officers, and other individuals associated with our firm, may also be the same securities as those purchased by the Funds and/or ETFs.

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.

Comparative Benchmark. S&P 500 Monthly Reinvested Index (5%), HFRX Equity Hedge Index (40%), Bloomberg US Aggregate Bond TR Index 55%).  No investments within benchmarks and benchmarks do not incur management fees or taxes. 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 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. Bloomberg 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 Bloomberg 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 ecommerce.barcap.com/indices for more information regarding Bloomberg indices. Indices are unmanaged investment measures and are not available for investment purposes.

Historical performance results for investment indices and/or categories have been provided for general comparison purposes only. Indices are unmanaged investment measures and are not available for investment purposes. The returns of the strategy 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. 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. The actual performance of an individual client’s portfolio may be lower or higher than the performance of the HCM portfolio strategy due to differences in timing of contributions and withdrawals, account start date, actual fees paid, and other factors. 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. Historical performance results for investment indices 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. The ability of the program to position assets in cash and/or bond funds results in its returns exhibiting a considerable variation from, and lower volatility than, its benchmark returns during periods when the HCM BuyLine® indicates higher risk for equities. During other periods, the program’s returns may exhibit higher volatility than those of the benchmark. All investment strategies have the potential for profit or loss. There can be no assurances that any investment or strategy will match or outperform any particular benchmark. Past performance is not a guarantee of future investment success.

All American Conservative 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. is registered as an investment adviser 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 adviser has attained a particular level of skill or ability. LARL.AM.C.FS.PERF.022624 | HCM-022624-050