DISCLOSURE FOR BACKTESTED MODEL

PERFORMANCE

Backtested performance is NOT an indicator of future actual results. Results are Gross of investment management fees. The results reflect performance of a strategy’s signals and not historically offered to investors and do NOT represent returns that any investor actually attained. Results are calculated by the retroactive application of a model signals constructed on the basis of historical data and based on assumptions integral to the model which may or may not be testable and are subject to losses.

General assumptions include: Ace Capital would have been able to purchase the securities recommended by the model and the markets were sufficiently liquid to permit all trading. Tactical Equity Strategy, Tactical Alternatives Strategy and Tactical Bond Strategy hypothetical performance assumes that a 5% cash position was kept at all times. Changes in these assumptions may have a material impact on the backtested returns presented. Certain assumptions have been made for modeling purposes and are unlikely to be realized. No representations and warranties are made as to the reasonableness of the assumptions. This information is provided for illustrative purposes only.

The S&P 500 is used as a comparison because it is a broad based market barometer of highly capitalized stocks in our opinion. Ace Capital holdings may or may not resemble the holdings of the S&P 500. Ace Capital may be long, short and/or in cash as well as invested in ETFs, Mutual Funds, Stocks, Inverse Securities, Leveraged Securities and/or Fixed Income which may or may not be included in the S&P 500.

Backtested performance is developed with the benefit of hindsight and has inherent limitations. Specifically, backtested results do not reflect actual trading or the effect of material economic and market factors on the decision-making process. Since trades have not actually been executed, results may have under- or over-compensated for the impact, if any, of certain market factors, such as lack of liquidity, and may not reflect the impact that certain economic or market factors may have had on the decision-making process. Further, backtesting allows the security selection methodology to be adjusted until past returns are maximized. Actual performance may differ significantly from backtested performance.

Backtested results are adjusted to reflect the reinvestment of dividends and other income and, except where otherwise indicated, are presented gross of the maximum fee and do not include the effect of backtested transaction costs, investment advisory fees, or expenses, if applicable. Please note all regulatory considerations regarding the presentation of fees must be taken into account. A 5% cash balance or cash flow is included in the calculation.

PERFORMANCE DISCLOSURES

Performance information is presented gross of all management fees and expenses unless marked otherwise. Commissions are not considered since Clients on the Ace Capital platform are not charged trading commissions. For all periods the performance information includes the reinvestment of dividends and interest unless otherwise noted. Any comparison to traditional financial advisors is based on an evaluation of average fees and returns. Actual results may be different for each investor and there can be no guarantee of enhanced returns due to additional diversification, ETF selection, mutual funds or the use of Ace Capital’s investment management service.

Projected and/or hypothetical performance is intended to show only an expected range of possible investment outcomes based on historical average returns and standard deviation of each investment type contained in the investment mix recommended by Ace Capital, but does not take into consideration the effect of taxes, changing risk profiles, or future investment decisions. Projected and/or hypothetical performance does not represent actual Client accounts or actual trades and may not reflect the effect of material economic and market factors. The actual transaction costs in Client accounts may be different.

Actual investors on Ace Capital may experience different results from any hypothetical results shown. There is a potential for loss, as well as gain, that is not reflected in the hypothetical information portrayed. The hypothetical performance results shown do not represent the results of actual trading using client assets but were achieved by means of the retroactive application of a model designed with the benefit of hindsight. Investors should carefully review the additional information presented by Ace Capital as part of any hypothetical comparison.

ANY COMPARISONS TO INDICES ARE PROVIDED FOR ILLUSTRATIVE PURPOSES ONLY. AN INDEX IS A BROADLY DIVERSIFIED, UNMANAGED GROUP OF SECURITIES, WHICH MAY INCLUDE ONLY LARGE CAPITALIZATION COMPANIES OR COMPANIES OF A CERTAIN SIZE. BROADLY BASED INDICES MAY BE SHOWN ONLY AS AN INDICATION OF THE GENERAL PERFORMANCE OF THE FINANCIAL MARKETS DURING THE PERIODS INDICATED. BECAUSE OF THE DIFFERENCES BETWEEN THE CLIENT ALLOCATIONS AND ANY INDICES SHOWN, ACE CAPITAL CAUTIONS INVESTORS THAT NO INDEX IS DIRECTLY COMPARABLE TO THE PERFORMANCE SHOWN SINCE EACH INDEX HAS ITS OWN UNIQUE RESULTS AND VOLATILITY, AND SUCH INDICES, IF SHOWN, SHOULD NOT BE RELIED UPON AS AN ACCURATE COMPARISON.

The S&P 500 Index is an unmanaged group of securities considered to be representative of the stock market in general, and its performance is not reflective of the performance of any specific investment. Investments cannot be made directly into an index. Historical returns data are calculated using data provided by sources deemed to be reliable, but no representation or warranty, expressed or implied, is made as to their accuracy, completeness or correctness. This information is provided "AS IS" without any warranty of any kind. All historical returns data should be considered hypothetical. The return, composite and performance information shown on the Site uses or includes information compiled from third-party sources, including independent market quotations and index information. Ace Capital believes the third-party information comes from reliable sources, but Ace Capital does not guarantee the accuracy of the Site information and may receive incorrect information from third-party providers. Unless otherwise indicated, the information on the Site has been prepared by Ace Capital and has not been reviewed, compiled or audited by any independent third-party or public accountant.

GENERAL DISCLOSURES

Ace Capital Inc. ("Ace Capital") operates an online financial advisor at www.AceCapital.com (the "Site") and is registered with the Securities and Exchange Commission under the Investment Advisers Act of 1940, as amended. Ace Capital does not provide personalized financial planning to investors, such as estate, tax, or retirement planning. Nothing on this Site should be construed as a solicitation or offer, or recommendation, to buy or sell any security. Financial advisory services are only provided to investors who become Ace Capital Clients ("Clients") pursuant to a written Client Account Agreement, which investors are urged to read and carefully consider in determining whether such agreement is suitable for their individual facts and circumstances. (Part 2 of Ace Capital’s Form ADV is available by emailing info@AceCapital.com

PAST PERFORMANCE IS NO GUARANTEE OF FUTURE RESULTS, AND ANY EXPECTED RETURNS OR HYPOTHETICAL PROJECTIONS MAY NOT REFLECT ACTUAL FUTURE PERFORMANCE. FURTHERMORE, PAST RETURNS MAY REFLECT THE PERFORMANCE OF ASSETS FOR A FINITE TIME, OR DURING A PERIOD OF EXTREME MARKET ACTIVITY. ALL INVESTMENTS INVOLVE RISK AND MAY LOSE MONEY. There can be no assurance that an investment mix or any projected or actual performance shown on the Site will lead to the expected results shown or perform in any predictable manner. It should not be assumed that investors will experience returns in the future, if any, comparable to those shown or that any or all of Ace Capital’s Clients experienced such returns.

SECURITIES SELECTION DISCLOSURES

Although Ace Capital believes its selection process identifies securities with liquidity, low expenses, and low tracking error, Ace Capital’s selection process does not guarantee the quality of a particular security or that it will 1) be profitable, 2) properly track any comparable index, 3) trade in a liquid fashion, or 4) trade at or above its publicly-posted value.

Ace Capital reserves the right to change at any time the selection of securities that it recommends if, in Ace Capital’s sole discretion, any security does not meet requirements for continued listing on the platform. Clients should be aware that changes in the selection of securities employed by Ace Capital‘s investment management service may result in the sale of their existing holdings and may subject them to additional tax liability.

FEE AND ACCOUNT DISCLOSURES

Recommendations and fees may vary for each Client. Advisory fees are calculated based upon the amount of assets being managed and/or monthly fixed charges(as detailed further in Ace Capital’s Form ADV Part 2).

Ace Capital does not make any representations regarding the execution quality of orders placed with our brokerage partner. However, Ace Capital does monitor the execution quality of transactions to ensure that Clients receive the best overall trade execution pursuant to regulatory requirements.