IMPORTANT NOTES:  Halbert Wealth Management, Inc. (HWM) and Howard Capital Management, Inc. (“HCM”) are Investment Advisors registered with the SEC and/or their respective states.  Information in this report is taken from sources believed reliable but its accuracy cannot be guaranteed. Any opinions stated are intended as general observations, not specific or personal investment advice.  Please consult a competent professional and the appropriate disclosure documents before making any investment decisions. Investments mentioned involve risk, and not all investments mentioned herein are appropriate for all investors.  HWM receives compensation from HCM in exchange for introducing client accounts.  For more information on HWM or HCM, please consult Form ADV Part II, available at no charge upon request. Officers, employees, and affiliates of HWM may have investments managed by the Advisors discussed herein or others.

As benchmarks for comparison, the Standard & Poor’s 500 Stock Index (which includes dividends) and the NASDAQ Composite Index represent an unmanaged, passive buy-and-hold approach.  The volatility and investment characteristics of these benchmarks cited may differ materially (more or less) from that of Howard’s Rydex Proactive Sector Rotation Strategy (“RYX-PSR”) since they are unmanaged Indexes which cannot be invested in directly. The performance of the S & P 500 Stock Index and the NASDAQ Composite is not meant to imply that investors should consider an investment in the RYX-PSR trading program, which is actively managed, as comparable to an investment in the “blue chip” stocks that comprise the S & P 500 Stock Index or the stocks listed on The NASDAQ Stock Market that comprise the NASDAQ Composite Index.

Historical performance data represent actual implementation of the strategy calculated monthly.  From October 1, 2002, to July 31, 2005, HCM managed one account trading at Rydex and AIM Funds using the RYX-PSR strategy.  Following the imposition of trading restrictions by AIM, performance is presented using one account trading only Rydex Funds from 8/1/2005 to 5/13/2008.  From 5/14/2008 to present, returns are calculated using representative client accounts held at FOLIOfn.  Representative accounts are accounts managed solely with the RYX-PSR strategy that have no additional deposits, withdrawals or other transactions during the month.   The results are net of advisory fees of 2.2%, paid quarterly in advance, are not net of custodial fees and reflect the reinvestment of dividends and capital gains. Statistics for “Worst Drawdown” are calculated as of month-end.  Drawdowns within a month may have been greater. PAST RESULTS ARE NOT NECESSARILY INDICATIVE OF FUTURE RESULTS.  Mutual funds carry their own expenses which are outlined in the fund’s prospectus.  An account with any Advisor is not a bank account and is not guaranteed by FDIC or any other governmental agency.

When reviewing past performance records, it is important to note that different accounts, even though they are traded pursuant to the same strategy, can have varying results.  The reasons for this include: i) the period of time in which the accounts are active; ii) the timing of contributions and withdrawals; iii) the account size; iv) the minimum investment requirements and/or withdrawal restrictions; and v) the rate of brokerage commissions and transaction fees charged to an account. There can be no assurance that an account opened by any person will achieve performance returns similar to those provided herein for accounts traded pursuant to the RYX-PSR trading program.

In addition, you should be aware that (i) the RYX-PSR program is speculative and involves the risk of loss; (ii) the RYX-PSR trading program’s performance may be volatile; (iii) an investor could lose a substantial amount of his or her investment in the program; (iv) Howard Capital will have trading authority over an investor’s account and the use of a single advisor could mean lack of diversification and consequently higher risk; and (v) the RYX-PSR program’s fees and expenses (if any) will reduce an investor’s trading profits, or increase any trading losses.

Returns illustrated are net of the management fees, underlying mutual fund management fees, and other fund expenses such as 12b-1 fees.  Results do not include the effect of annual IRA fees or mutual fund sales charges, if applicable. No adjustment has been made for income tax liability. Consult your tax advisor. “Annualized” returns take into account compounding of earnings over the course of an investment’s actual track record.  Money market funds are not bank accounts, do not carry deposit insurance, and do involve risk of loss.  The results shown are for a limited time period and may not be representative of the results that would be achieved over a full market cycle or in different economic and market environments.