Howard Capital Management, Inc. (“HCM”) is registered 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 advisor has attained a particular level of skill or ability. The HCM Guided Retirement Solution is a web-based Risk Assessment Tool intended to help clients invest in their employer’s 401(k) or similar defined contribution plan. Clients receive discretionary investment management from the HCM Guided Retirement Solution while maintaining total control over their personal accounts. The goal is to reduce risk by taking proactive measures with company-sponsored retirement plans. Changes in investment strategies, contributions or withdrawals may materially alter the performance, strategy, and results of your portfolio. 

The HCM Guided Retirement Program is an optional service. Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment (including the investments and/or investment strategies recommended through the HCM Guided Retirement Solution), will be equal to past performance level, equal any corresponding indicated historical performance level(s), be suitable for your portfolio or individual situation, or be profitable for a client’s portfolio. Past performance does not guarantee future results. All investment strategies have the potential for profit or loss. 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 benchmark for measuring the performance of a portfolio. 

When HCM provides investment advisory services to a retirement plan qualified under the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, it does so in its capacity as a “fiduciary,” as that term is defined under Section 3(21) of ERISA. When HCM provides these services on a discretionary basis, it does so as an “investment manager,” as that term is defined under Section 3(38) of ERISA.

Qualified Default Investment Alternative (“QDIA”) General Information

You have the right to select how the assets in your retirement plan account will be invested. You may need to make investment elections upon initial enrollment under the plan, upon a change of investment options under the plan, or upon receipt of a rollover or transfer contribution into your account. If you do not follow the plan’s procedures for making investment elections timely, any contributions made to your account will be invested in the plan’s qualified default investment alternative (“QDIA”) as described below. The allocation of your account will continue in this manner until you advise the Plan Administrator otherwise. The Plan Administrator will provide you with information on the plan’s procedures for making investment elections, including other investment alternatives available under the plan. Participants retain the right to change or alter their investment elections at any time, and will not incur any additional restrictions, fees, or expenses as a result of doing so.

Plan Default Process

In the event no affirmative election on how your money is to be invested is received, your plan assets will be mapped to the Conservative Growth custom model as the QDIA. Without an affirmative investment election, subsequent elective contributions will also be defaulted into the QDIA. All participants will be given the option during conversion process to opt out of the QDIA and select their own investments and will remain free to change or update their investment elections after the conversion is completed. 

In the event of the death of the participant, and after the account has been turned over to the account beneficiary(ies), such beneficiary(ies) will have the option to direct the investments and move the assets from the QDIA into any investment they select. 

HCM Buy-Line® Indicator. The HCM-BuyLine® (the “Indicator”) is a proprietary indicator used to assist in determining when to buy and sell securities. When the Indicator identifies signs of a rising market, HCM then identifies the particular security(ies) that HCM believes have the best return potentials in the current market from the universe of assets available in each given model and signals to invest in them. When the Indicator identifies signs of a declining market, the indicator signals to move clients’ investments to less risky alternatives. Not every signal generated by the indicator will result in a profitable trade. There will be times when following the indicator results in a loss. An important goal of the indicator is to outperform the market on a long-term basis. The reason is the mathematics of gains and losses. A portfolio which suffers a 30% loss takes a 43% gain to return to the previous portfolio value. The indicator is reactive in nature, not proactive. It is not designed to catch the first 5–10% of a bull or bear market. Ideally, it will avoid most of the downtrends and catch the bulk of the uptrends. There may be times when the use of the indicator will result in a loss when HCM re-enters the market. Other times there may be a modest positive impact. When severe downtrends occur, however, such as in 2000-2002 and 2007-2008, the indicator has the potential to make a significant difference in portfolio performance. Naturally, there can be no guarantee that the indicator will perform as anticipated. The indicator does not generate stop-loss orders that automatically sell securities in the portfolio at a certain price. As a result, use of the indicator will not necessarily limit your losses to the desired amounts due to the limitations of the indicator, market conditions, and delays in executing orders.

Please remember to update your personal information if there are any changes in your personal/financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services, or if you want to impose, add, or modify any reasonable restrictions to our services. Please Note: Unless you advise, in writing, to the contrary, we will assume that there are no restrictions on our services, other than to manage the account in accordance with your designated investment objective. A copy of our current written Disclosure Brochure discussing our advisory services and fees continues to remain available upon request.

Please Note:

Past performance may not be indicative of future results.  Moreover, no current or prospective Plan participant should assume that future performance of any specific investment, investment strategy, or product made reference to directly or indirectly in any general informational materials or educational sessions (including the plan investment alternatives), will be profitable or equal any corresponding indicated historical performance level(s).  Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment will either be suitable or profitable for a participant’s retirement portfolio.

You have the right to transfer the assets invested in the default investments to any other investment alternative available under the plan. You may transfer assets from default investments on a daily basis. You may obtain additional information on all available plan investments by logging into your account on the plan website. Also, if you want additional investment information, regarding risk and return characteristics, and fees and expenses , to ask any questions about how the plan works or your rights and obligations under the plan, or if you want a copy of the plan’s Summary Plan Description (SPD) or other plan documents, please contact the Plan Administrator.

Please refer to your plan sponsor’s annual fee disclosures or contact us for more information.  Termination of this service does not reverse actions taken in the past by the HCM Guided Retirement Program. LARL.GR.WEB.0522



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