Howard Capital Management Group LLC

Item 5 – Fees and Compensation
The annual fees for the above services will be calculated from the following fee schedules:
        Equity (incl. Alternative Investments) & Balanced Investment Advisory Services
           Annual Fee Rate     Assets Under Management
           1.25%               on assets up to         $ 999,999 plus
           1.00%               on assets from          $ 1,000,000 to $ 2,999,999 plus
           0.90%               on assets from          $ 3,000,000 to $ 4,999,999 plus
           0.80%               on assets from          $ 5,000,000 to $ 9,999,999 plus
           0.75%               on assets from          $ 10,000,000 and above
          Subject to a minimum annual fee of $10,000
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                           Fixed Income Investment Advisory Services
           Annual Fee Rate      Assets Under Management
           0.60%                on assets up to        $ 2,499,999 plus
           0.50%                on assets from         $ 2,500,000 to $ 4,999,999 plus
           0.40%                on assets from         $ 5,000,000 to $ 9,999,999 plus
           0.35%                on assets from         $ 10,000,000 and above
          Subject to a minimum annual fee of $6,000

For certain clients, we charge an advisory fee for services provided to held-away accounts
mentioned above in Item 4, just as we do with client accounts held at our primary custodians.
The specific fee schedule charged by HCM is provided in the client’s investment advisory
agreement with us.
In certain circumstances fees may be negotiated. Negotiated fees may be higher or lower than
those delineated above. The above fee schedule is effective August 27, 2010. Fees for
preexisting clients may be higher or lower than those delineated above.
Generally, fees are payable on a quarterly basis in advance, based upon the market value of the
client's investments as of the beginning of the quarter. Alternative investments will be fairly
valued by the fund manager(s) and reviewed by HCM’s valuation committee, which may include
third-party independent valuation services. Managed accounts will be automatically debited on a
quarterly basis in accordance with the fee calculations described above unless other
arrangements are made. The specific manner in which fees are calculated by HCM and paid by
client will be established in a client’s written Investment Advisory Agreement.
The Investment Advisory Agreement may be terminated by either party with 7 days written
notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded,
and any earned, unpaid fees will be due and payable.
HCM may purchase for clients certain NASDAQ securities where HCM does not have direct
access to market makers. As a result, such orders may be placed with other financial institutions
thus causing a client to pay an agency commission. This cost may be in addition to the mark-up
or mark-down assessed by the market maker.
HCM’s fees are exclusive of brokerage commissions, transaction fees, and other related costs
and expenses which may be incurred by the client. Clients may incur certain charges imposed by
custodians, brokers and other third parties such as fees charged by other managers, custodial
fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund
fees, and other fees and taxes on brokerage accounts and securities transactions. Money market
funds and exchange traded funds also charge internal management fees, which are disclosed in a
fund’s prospectus. HCM and its advisor representatives do not accept any compensation for the
purchase or sale of securities or other investment products, including asset-based sales charges or
service fees from the sale of funds or securities, and do not share or otherwise participate in any
of the transaction fees, commissions, or charges described in this paragraph. Item 12 further
describes the factors that HCM considers in selecting or recommending broker-dealers for client
asset custody and execution of transactions and determining the reasonableness of their
compensation (e.g., commissions).
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For alternative investments, HCM pays an annual fee to a third-party model portfolio advisor for
access and creation of customized alternative investment model portfolios, with HCM oversight
and discretion. The third-party model portfolio advisor is our sole source for alternative
investment fund recommendations and is compensated by those funds. The annual fee paid by
HCM for such services is exclusive of any fund-level management fees, including any carried
interest. The fees charged by fund managers for alternative investments are separate and distinct
from the advisory fees charged by HCM. Alternative investment fees at the fund level are
typically outlined in the offering documents. Client assets recommended by HCM for investment
in an alternative investments fund, whether or not as part of a model portfolio, are included as
part of the client’s managed account for purposes of calculating HCM’s advisory fee above. The
addition of HCM’s advisory fee to the fund level fees will adversely affect net returns as
compared with a direct investment in the fund.

Item 7 – Types of Clients
HCM generally provides discretionary portfolio management services to high net worth
individuals, trusts, estates, foundations, endowments, charitable organizations, corporations, and
other business entities as well as non-discretionary advisory services to certain clients.
Clients must generally reside in the United States, its territories or be U.S. Citizens.
Minimum account size is $1,000,000. Generally, HCM combines family accounts to meet the
minimum account size threshold. HCM reserves the right to accept lesser amounts depending
upon the circumstances.