2. Strategy Overview: ICM employs a top down multi-cap growth strategy, seeking to capitalize on the fastest growing companies in any market environment, while hedging market volatility and maintaining a long bias in uptrends and shorting in bear market cycles.

3. Strategy Philosophy: We use a proprietary Trend Directional Model (TDM) to identify market direction. The manager invests in companies exhibiting fundamental and technical characteristics which are similar to the fastest growing leading stocks of the past century. Typically, these companies possess a fundamental catalyst, driving the rapid EPS growth, often having a new product or service and are the leaders in their respective industry. Purchases are made at lower risk buy points or logical areas of support. The portfolio is dynamically managed with the ability to be nimble - taking advantage of short/intermediate term fluctuations. However, holding periods elongate materially in core positions during confirmed uptrends. While we cannot achieve perfection, we expect to be in phase with intermediate term trends and identify most worthwhile investment areas.

4. Portfolio Construction: Once the fund’s Trend Directional Model confirms an uptrend, stocks are purchased out of consolidation patterns and logical areas of support, where a risk reward can be established. New commitments have a predetermined stop loss. The portfolio will typically hold between 8-20 stocks possessing strong current EPS and/or revenues representing a variety of industry groups. Initial exposure will range from 3-10%. Once a position is established and working and we are in a position of strength, we will typically expand the exposure. Conversely, once the model turns negative, we implement protective stop losses in our best positions and weaker performers are eliminated, as we will use cash as a hedge until downward pressure resolves and new buy candidates emerge.

5. Risk Management: New positions are restricted to domestic and international companies that trade domestically. Typically, we employ a stop loss that is within 5-10% of our purchase price. All stocks are grouped into 197 industries and we will not commit more than 25% into a single group. However, we believe over diversification is a hedge for ignorance and instead choose to use a rigid stop loss philosophy while investing in the strongest possible areas. Exposure typically will range between 10%-100% long and 10%-50% short during bear phases.

6. Winning Trade Example: Purchased as it emerges from well-formed base at $37.50 Advances 36.8%. Forms a new base, breaks out, and is purchased again at $51.50 before advancing to$65.71 EPS and sales growth of 79% and 57% New product with big demand in the wake of 2008 RE. Correction.

7. Losing Trade Example: Purchased out of a well formed base at $78.39 Advances 20% but unable to hold gains due to an impending market correction. Firms Trend Direction Model turns negative so position is reduced Stock breaks below the78.39 buy point on heavy volume Stop losses are employed

8. Company Overview: Innovative Capital Management, LLC has been a registered investment advisor since 2001. We are growth stock managers that specialize in finding the highest quality growth companies in the marketplace, while utilizing our proprietary Trend Directional Model (TDM) to adjust our market exposure in order to hedge the inherent risks in growth stock investing. We specialize in attempting to give investors the best of both worlds: strong gains in market uptrends and protecting principal in downtrends. The management team has 40+ years of collective management experience, with a proven track record of outperforming the indices over the long term, with less volatility. We pride ourselves on being nimble, active managers that seek to avoid large draw downs and always keep our investors in phase with the market’s intermediate and long term trends.

9. Management Bios: Scott Parent, CFA Managing Member & Portfolio Manager Scott Parent, CFA is a founding partner of Innovative Capital Management and its proprietary equity hedge fund. He has continuously served as the fund’s Chief Portfolio Manager since its inception in 2001. In addition, he has been an equity analyst and portfolio manager with F500 Advisory Services since 1995, where his current responsibilities include managing equity portfolios for the F500 Advisory clientele. He also serves as the Portfolio Manager for F500’s proprietary equity hedge fund. He earned his CFA designation in 1999.