Howard Capital Management, INC.

HCM primarily manages accounts introduced to it by unaffiliated broker-dealers and investment adviser, and shares a portion of the total advisory fee with the client’s primary investment professional. The portion of the advisory fee that HCM retains will range up to, but will not exceed, 1.1% of assets under management. The advisory fee will be based upon the total asset value of the securities under management in the account. Fees will be charged according to the Advisory Agreement. The annual advisory fee is generally billed monthly in advance, calculated as a percent of the value of your account at the close of the last business day of the previous month. For individual clients using 401(k) Optimizer® or TSP OptimizerTM, the annual subscription fee is $108, payable monthly in advance. HCM’s annual fee assessed to the plan for HCM Guided Retirement service is 0.06% of plan assets, assessed on a quarterly basis, in arrears. For Custom models, a participant-level annual fee for this offering is assessed at a rate of 0.40% of assets placed within the models.