IMPORTANT DISCLOSURES REGARDING WEBSITE

Adviser has developed the Investment Program (the “Program”) through which it manages each client accounts according to one of the model investment portfolios (the “Portfolios”) shown in the Website. Adviser has developed and will continue to develop investment strategies (collectively, the “Strategies”) to manage each Portfolio to achieve a specific investment objective.
Clients and prospective clients should take care to consider the information provided below regarding the Strategies, the methodology and assumptions used by Adviser in creating the Portfolios and calculating the Portfolios’ performance, and the limitations of using the information provided in the Website in evaluating Adviser’s ability to manage actual client assets.
Additional important information regarding Adviser, its investment management services, compensation, conflicts of interest, and other matters are contained in its Form ADV, Part II or substitute disclosure document, available from Adviser upon request of Adviser’s Chief Compliance Officer.

LIMITATIONS OF USING HYPOTHETICAL PERFROMANCE INFORMATION; POSSIBILITY OF LOSSES

Past performance, particularly hypothetical, backtested performance information, as presented in the Website, does not guarantee future results or success in achieving the objectives of any account. Clients and prospective clients should not assume that future performance of their account will be profitable or will reflect the performance shown in the Web Pages.
Participation in the Program carries the potential for profit as well as the possibility of loss. Performance of actual client accounts has been materially lower than the performance shown in the Website.

HYPOTHETICAL, BACKTESTED PERFORMANCE

The performance information presented in the Website under the heading “Hypothetical Performance” reflects hypothetical, backtested performance calculated by applying the Strategies to each of the Portfolios, using historic financial data received from third-party data providers for the time periods shown.
Backtested performance represents theoretical performance calculated by applying a particular investment Strategy to historic financial data to show what performance might have been achieved if the Strategy had been used. Backtested performance does not represent actual account performance and should not be interpreted as an indication of such performance. Backtested performance does not reflect the impact that material economic or market factors might have had on Adviser’s decision-making process if Adviser had been actually managing clients’ accounts according to such Strategy. Further, backtested performance differs from actual performance because Adviser has the ability to adjust the model or Strategy at any time, for any reason and can continue to adjust the model or Strategy until desired or better performance results are achieved.
It is unlikely the results shown in the Website as Hypothetical, Backtested Performance could have been achieved without the benefit of hindsight.

MODEL PERFORMANCE

The performance information presented in the Website under the heading “Model Performance” reflects the theoretical returns for a Portfolio managed by Adviser according to the strategy without the benefit of hindsight. However, such performance does not reflect the actual performance of accounts, if any, managed by Adviser in any Portfolio.
The actual performance of accounts managed in each Portfolio was materially less than the performance shown in the Website as Model Performance.

PERFORMANCE IS NET OF FEES AND TRADING EXPENSES; DIVIDENDS AND INTEREST REINVESTED

For periods for which Hypothetical Performance is shown, Adviser has deducted a model advisory fee and model trading expenses equal to the highest management fee Adviser would have charged each Portfolio, and a model trading cost, which represents Adviser’s reasonable estimate of the trading costs the Portfolio would have incurred during such periods for a total annual portfolio cost.
For periods for which Model Performance is shown, such performance reflects the deduction of a model advisory fee and model trading expenses equal to the highest fee rate and expense ratio paid by accounts actually participating in such Portfolio; excluding, however, non-discretionary accounts and accounts which were subject to investment restrictions or extraordinary inflows or outflows of funds, accounts managed for less than one full calendar quarter, or other accounts whose fees or expenses were not reasonably representative for such period of the fees and expenses charged other accounts participating in such Portfolio. Hypothetical Performance and Model Performance assume the reinvestment of dividends and interest for each Portfolio.
Actual fees charged to clients will vary depending upon, among other things, the applicable fee schedule and portfolio size. Adviser’s general fee schedule is available on request and also may be found in Part II of its Form ADV.

RELIANCE ON THIRD-PARTY DATA PROVIDERS

Adviser’s investment decisions for the Program and the construction of the Portfolios are guided by model portfolios, and investment buy and sell signals Adviser purchases from one or more third-party data providers. Adviser may select or change data providers at any time, and may accept or reject such signals or model portfolios, as it deems appropriate. The third-party data providers used to calculate the Portfolios, the Hypothetical Performance, and the Model Performance have not changed over the periods reported.

OTHER FEES AND EXPENSES; IMPACT OF TAXES

The investment management fee paid to Adviser is separate and distinct from the internal fees and expenses charged by ETFs and mutual funds to their shareholders. These fees and expenses are described in each ETF’s and mutual fund's prospectus, and will generally include a management fee, internal investment, custodial, and other expenses, and a possible distribution fee. If Adviser is engaged as a subadviser to an account’s primary investment adviser, the account may also be required to pay the advisory fees charged by the primary adviser, as provided in the account’s agreement with the primary adviser.
Prospective clients should consider all of these fees and charges when deciding whether to invest in the Program. Performance results for the Program do not reflect the impact of taxes. Program accounts may engage in a significant amount of trading. Gains or losses will generally be short-term in nature; consequently, this program will likely not be suitable for clients seeking tax efficiency.

OTHER CONSIDERATIONS

Program accounts will invest in so-called “leveraged” and “inverse” ETFs. Such ETFs may seek to enhance returns through the use of financial instruments, such as derivatives, swaps, and options, as well short sales. Although such instruments may improve fund returns, they will also increase the ETFs’ risks of loss and magnify the ETFs’ potential volatility. A common misconception is that the total return of an inverse ETF will be the exact opposite of the total return of the index to which it is benchmarked. This will not be the case for any time period beyond one day. Due to the nature of compounding, it would be virtually impossible to produce a total return that is exactly opposite the total return of an inverse fund’s benchmark index over any time frame beyond one day. Due to the increased risks of leveraged ETFs and inverse ETFs, the Program is suitable only for investors who are able to withstand significant volatility in the value of their Program investment, and who do not foresee the need to liquidate their investment for at least 3 years.

SEPARATE DISCALIMER

The information presented above is qualified in its entirety by the following Important Information:  The performance of the Model Portfolio(s) shown on this page is hypothetical and does not represent the performance or trading of any actual client account or actual client assets.  There are certain limitations inherent in the presentation of hypothetical performance data. The proprietary investment strategy that the hypothetical results are based upon can be changed at any time in order to show better model performance, and the strategy can continue to be tested and adjusted until the desired results are achieved.  As you review this hypothetical performance information, please keep the following points in mind:  All information on this page, other than index data, is the result of the retroactive application of the investment strategies being recommended and uses historical data with the benefit of hindsight.  Past hypothetical performance is no guarantee of future performance and is for illustrative purposes only and the possibility of realizing a loss does exist. 

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