Scotia Programs, Halbert Wealth Management, Gary D. Halbert, President

Growth S&P Plus Strategy

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S&P Moderate Growth Strategy

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The Scotia Partners, Ltd. Growth S&P Plus and S&P Moderate Growth Strategies provide a somewhat unique way to participate in a leveraged, long/short S&P 500 Index strategy. Scotia’s founder, Cliff Montgomery, CFA, seeks to identify only those trading days with the highest probability of success, either long or short. He does so by applying his proprietary system to a variety of market data to determine which days appear to be most likely to offer potential gains.

Cliff describes his trading model as being trend following in the long term, but contrarian in the short term. Because of the highly selective nature of the model, Scotia's programs have historically been in the safety of a money market fund about two-thirds of the time, and only invested in the market about one-third of the time.

This is a very interesting strategy, especially considering that Scotia's investment strategies found a way to navigate the high market volatility in 2007 and 2008, while many other formerly successful money managers struggled. As you will see in our Advisor Profile, Scotia is one of the most exciting money managers we have seen in several years.

The S&P Moderate Growth Strategy differs from the more aggressive Growth S&P Plus Strategy in two ways. First, the Moderate Strategy trades using only Scotia’s core trading model, while the S&P Plus Strategy also uses an overbought/oversold signal. This means the S&P Plus Strategy is likely to have more trades per year than the Moderate Strategy.

A second difference is that the Moderate Strategy will make partial allocations on the initial trading signal while the S&P Plus always commits 100% of the account on all trades. Thus, the S&P Plus Strategy will either be 100% long, 100% short or 100% neutral (cash) while the Moderate Strategy can have 50% allocations to each of these positions.

The model is 100% mechanical and Scotia has indicated it will not override its signal under any circumstances. When in cash, the model moves to the Rydex US Government Money Market Fund. The Scotia Growth S&P Plus Strategy trades frequently, and is not expected to be tax efficient.

The minimum account size for the Growth S&P Plus program is $25,000 and it is available to both individual and IRA investors. All accounts are held at Rydex Funds in the name of the investor. Scotia Partners has outsourced its back-office administration and trading operations to Purcell Advisory Services, LLC, a Registered Investment Advisor and third-party back-office administration firm. Past performance is not necessarily indicative of future results. Be sure to read Important Notes below.

	Scotia Partners Growth S&P Plus Strategy	Scotia Partners S&P Moderate Growth Strategy	S&P 500	Nasdaq Composite Index
1-year	(5.19)	(8.32)	53.25	62.45
2-year	31.17	9.73	(6.80)	(0.73)
3-year	46.81	13.70	(5.75)	(2.52)

Actual performance record (annualized) as of February 28, 2010.

IMPORTANT NOTES: Halbert Wealth Management, Inc. (HWM), Scotia Partners, Ltd. (SPL), and Purcell Advisory Services, LLC (PAS) 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 PAS in exchange for introducing client accounts. For more information on HWM or PAS, 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 unmanaged, passive buy-and-hold approaches. The volatility and investment characteristics of these benchmarks may differ materially (more or less) from that of the Scotia Partners programs, since they are unmanaged Indexes which cannot be invested in directly. The performance of the S & P 500 Stock Index and the NASDAQ Composite Index is not meant to imply that investors should consider an investment in the Scotia Partners trading programs 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 represents actual accounts in a program named Scotia Partners Growth S&P Plus and Scotia Partners S&P Moderate Growth custodied at Rydex Series Trust, and verified by Theta Investment Research, LLC. These results reflect actual trades in proprietary accounts of the Advisor, managed to mimic the Advisor’s trading signals. The results may not reflect the performance of actual client accounts due to contributions and withdrawals from client accounts, tax loss sales, client-imposed investment restrictions and other factors. 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 these Scotia programs. The signals are generated by the use of proprietary models developed by Scotia Partners with the objective of participating, on a leveraged basis, in trading days with the highest probability of success in the S&P 500 Index. 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 Scotia Partners trading programs.

In addition, you should be aware that (i) the Scotia Partners program are speculative and involve a high degree of risk; (ii) the Scotia Partners trading programs’ performance may be volatile; (iii) an investor could lose all or a substantial amount of his or her investment in the program; (iv) Purcell Advisory Services 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 Purcell Advisory Services trading 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 maximum management fees, custodial fees, underlying mutual fund management fees, and other fund expenses such as 12b-1 fees. Management fees are deducted quarterly, and are not accrued on a month-by-month basis. They 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. Dividends and capital gains have been reinvested. 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.