IMPORTANT NOTES: Halbert Wealth Management, Inc. (HWM) and Metropolitan Capital Strategies, LLC. (MCS) 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. HWM receives compensation from MCS in exchange for introducing client accounts.  For more information on HWM or MCS, please consult the respective Form ADV Part 2, available at no charge upon request. Officers, employees, and affiliates of HWM may have investments managed by the Advisors discussed herein or others.

The Tactical Moderate Composite and the Tactical Growth composite were created on May 1, 2007.  Prior to January 1, 2011, the composites were named Fact Funds Tactical Moderate Composite and Fact Funds Tactical Growth Composite, respectively.  Prior to May 2007, the composites consisted of a single account in each program related to one of the firm’s principals whose investment objective and philosophy were similar.  The composites do not unfairly inflate performance returns.  Prior to January 1, 2009, the Tactical Moderate composite contained a minimal amount of uncovered options that were immaterial to the performance of that composite.  

MCS claims compliance with the Global Investment Performance Standards (GIPS) and performance numbers have been prepared and presented in compliance with the GIPS standards and verified by Cohen Fund Audit Services for the period from May 1, 2007 through May 31, 2008, and by Ashland Partners & Co., LLP from the period June 1, 2008 through December 31, 2010.  Verification assesses whether (1) the firm has complied with all the composite construction requirements of GIPS standards on a firm-wide basis and (2) the firm’s policies and procedures are designed to calculate and present performance in compliance with GIPS standards.  The composites have been examined for the periods May 1, 2007 through March 31, 2011.  To receive a complete list and description of MCS investment composites and/or presentation that adheres to GIPS standards, contact Cheryl Parish at 571-379-8586 or email info@mcsmgr.com.   Prior to May 1, 2007, the performance numbers are not independently verified to be in compliance with GIPS.

These performance numbers have not been verified by HWM, and therefore HWM is not responsible for their accuracy. Since all accounts in the program are managed similarly, the results shown are representative of the majority of participants in the Metropolitan Tactical Growth and Moderate Strategies.  The signals are generated by the use of  proprietary models developed by Metropolitan Capital with the objective of participating in stock markets gains while keeping the level of risk moderate to aggressive.  PAST RESULTS ARE NOT NECESSARILY INDICATIVE OF FUTURE RESULTS.  ETFs carry their own expenses which are outlined in the ETFs’ prospectus.

When reviewing past performance records, it is important to note that different accounts, even though they are traded pursuant to the same strategies, 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 Metropolitan Tactical Moderate and Growth Strategies.

In addition, you should be aware that (i) in these programs, your principal is not guaranteed and there are risks involved; (ii) the performance of these programs may be volatile; (iii) an investor could lose all or a substantial amount of his or her investment in these programs; (iv) Metropolitan 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) these programs fees and expenses (if any) will reduce an investor’s trading profits, or increase any trading losses.

As a benchmark for comparison, the Standard & Poor’s 500 Stock Index (which includes dividends), represents an unmanaged, passive buy-and-hold approach.  The volatility and investment characteristics of this benchmark may differ materially (more or less) from that of the Metropolitan Tactical Moderate and Growth Strategies since it is an unmanaged Index which cannot be invested in directly. The performance of the S & P 500 Stock Index is not meant to imply that investors should consider an investment in the Metropolitan Tactical Moderate or Growth Strategies, which are actively managed, as comparable to an investment in the “blue chip” stocks that comprise the S&P 500 Stock Index. 

All accounts in the composites are charged the rate of fees corresponding to the assets placed under management with MCS.  Bundled, tiered fee accounts make up 100% of the composites for all periods beginning May 1, 2007.  Wrap fee schedules are provided by independent wrap sponsors and are available upon request from the respective wrap sponsor.  The bundled fees include custody, trading expenses, and other expenses associated with the management of the accounts.  HWM accounts pay actual transaction costs rather than a wrap fee.  Prior to May 1, 2007, the composites consisted of single non-wrap fee portfolios and these returns have been reduced by transaction costs but not by a management fee.  However, the transaction costs during this period were higher and thus comparable to the management fee plus transaction cost/wrap fee charged on accounts after May 1, 2007.

The Tactical Growth program writes covered and uncovered put and call options, coupled with risk management techniques.  There are special risks associated with uncovered option writing which may expose an investor to a potentially significant loss, and the strategy may not be suitable for all customers.  The potential loss in uncovered call writing is unlimited, and the risks of writing uncovered put options can be substantial.  Investors should understand the risks and have sufficient liquid assets to meet margin calls.  (Note:  The Tactical Moderate Strategy does not use options.)

Returns illustrated are net of the Advisor management fees, custodial fees, underlying ETF fees, and other expenses.  Management fees are deducted quarterly, and are not accrued on a month-by-month basis.  Returns do not include the effect of annual IRA fees, 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. Dividends and capital gains have been reinvested. Money market funds and other low risk asset classes are not bank accounts, do not carry deposit insurance, and do involve risk of loss.  These programs buy and sell on a short-term basis and clients are expected to incur short-term capital gains and losses.  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.