Viper 2 Conservative Growth (Holdings: Equity and Multi-Income): 45/55 but may vary at manager’s discretion.) The Viper 2 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 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 Viper 2 Conservative Growth 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. The net asset value per share of this HCM program will fluctuate as the value of the securities within the portfolio change. 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 Viper 2 Conservative Growth 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. 

Performance Results. Returns reflect the aggregate of FOLIOfn client accounts using the Viper 2 Conservative Growth strategy. Prior to 1/1/2013, as they became available, the first five accounts using this strategy at FOLIOfn are used in the performance calculation. After 1/1/2013 all accounts trading this strategy at FOLIOfn are used for performance tracking. Returns 1) are calculated monthly, 2) are net of advisory fees, 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 Advisory Services. We provide investment advisory services to the HCM Tactical Growth Fund, HCM Dividend Sector Plus Fund, and the HCM Income Plus Fund (“the Funds”), mutual funds registered under the Investment Company Act of 1940. 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 exchange traded funds (“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.” We will be entitled to an annual advisory fee equal to 1.25% of each of the Fund’s average daily net assets paid on a monthly basis. We may recommend investments in the Funds 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 without further approval from you. Because we receive compensation from the Funds, we have a financial incentive to invest client assets in the Funds or to recommend that clients invest in the Funds. 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 fees from you for investments made in the Funds. For ERISA assets invested in the Funds, the advisory fee on such assets will be offset by the amount of the management fee paid to us by the Funds. At our discretion, we may offset a portion of your advisory fee against the fees and expenses you may otherwise pay to the Funds. You should refer to the prospectus for a complete description of the fees, investment objectives, risks and other relevant information associated with investing in the Funds. 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. 

Comparative Benchmark. Conservative Growth- S&P 500 Monthly Reinvested Index (5%), HFRX Equity Hedge Index (40%), Barclays Capital US Aggregate Bond TR Index (55%)

Viper 2 Conservative Growth 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. LASS.V2CG.0921