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Overview

VIEWS: 18 PAGES: 4

									                                                                 IMPORTANT DISCLOSURES
                                                                  Kades-Margolis Capital, LLC
                                                       Money-by-Design IRA/Roth IRA/ SEP IRA/Simple IRA


 Overview
                                                                                         How Can I Receive A Copy Of The Prospectus?


The Kades-Margolis Capital Money-by-Design IRA/Roth IRA/SEP
                                                                                         You may view and print a copy of the prospectus on each mutual
IRA/Simple IRA Program provides you the opportunity to participate
                                                                                         fund offered in the Program from the Money-by-Design internet site
in a retirement income program to supplement your pension and
                                                                                         at www.moneybydesign.biz, or you may have a prospectus on each
Social Security retirement benefits. To participate in this program,
                                                                                         fund mailed to your address of record by selecting the option on
you must complete a Participant Enrollment Form that will be
                                                                                         the Participant Enrollment Form. If no election is made, the default
provided by your Kades-Margolis financial advisor. By signing this
                                                                                         will be the internet option. Your election may be changed at any
form you are bound to the Kades-Margolis Capital IRA/Roth IRA/SEP
                                                                                         time by directing written instructions to the Sponsor Kades-Margolis
IRA/Simple IRA Custodial Agreement, as it may be amended from time
                                                                                         Capital, LLC.
to time (“Custodial Agreement”). In addition to contributions, you
will have the opportunity to transfer or rollover funds from other
qualifying programs. This Program offers the features and benefits
that may not be available through other IRA/Roth IRA/SEP IRA/Simple                       How Will My Money Be Invested?
IRA programs.

                                                                                         When you complete your Money-by-Design Participant Enrollment
 How Do I Receive A Copy Of The Custodial Agreement?                                     Form, you will select from a list of mutual funds offered in the
                                                                                         Program. As funds are deposited to your account the monies will be
                                                                                         allocated in the funds as you directed on the enrollment form. You
                                                                                         may modify these instructions by accessing your account through the
You may view and print a copy of the Custodial Agreement
                                                                                         Program’s internet site at www.moneybydesign.biz, or by calling the
incorporating the latest amendments from the Money-by-Design
                                                                                         toll-free client service number. The new investment instructions will
Internet site at www.moneybydesign.biz, or you may have a copy of
                                                                                         determine the allocation of future additions or existing allocations to
the Agreement mailed to your address of record by selecting the
                                                                                         your account. The Program currently limits ongoing contributions to
option on the Participant Enrollment Form. If no election is made, the
                                                                                         20 allocations.
default will be the internet version.
                                                                                         If for any reason money can not be allocated to a fund(s) that you
                                                                                         selected, your money will be temporarily allocated to a Sponsor
How Do I Become A Participant?                                                           selected Money Market or Cash Reserve Fund. The Fund selected may
                                                                                         be changed from time to time, please see Important Disclosure
                                                                                         document on our website for details. A prospectus of the Fund is
A Kades-Margolis financial advisor will assist you in completing the                     available at the www.moneybydesign.biz web site or by contacting
forms necessary to join the Program. To become a participant, a                          your Kades-Margolis financial advisor.
Money-by-Design Participant Enrollment Form should be completed
and returned to your Kades-Margolis financial advisor. This will                         Your fund(s) will be transferred out of the selected Money Market
establish an account in your name that will receive contributions and                    Fund to the fund(s) of your choosing as soon as possible upon the
any lump sums or transfers that you may direct. If applicable, you                       Sponsor receiving proper investment instructions.
also must complete a salary reduction agreement which directs your
employer to withhold your contributions pre-tax from each paycheck
and send your deferrals to be credited to your account.                                   Can I Change My Investments?

 How Much May I Contribute To My IRA/Roth IRA/ SEP IRA/
Simple IRA?                                                                              You may reallocate your monies into new investments by selecting
                                                                                         new funds from the list of funds offered on the internet site. Any
                                                                                         trade entered to your account by 2:00 pm EST on normal business
You may contribute up to the maximum amount that may be                                  days will be placed with the mutual fund on that day. On the
contributed under the law.                                                               following day, you will be able view changes to your account.

You may also be eligible for Special IRA catch-up contributions if you                   Please note that your reallocation privileges may be limited by
meet certain requirements. As long as the plan permits, you can elect                    policies implemented by the Sponsor, Kades-Margolis Capital, LLC in
to have a portion of your contributions designated as pre-tax (IRA)                      accordance with the mutual fund trading restrictions pertaining to
and a portion post-tax (Roth IRA). The sum of these contributions                        market timing.
cannot exceed the overall contribution limits. Your Kades-Margolis
financial advisor can assist you in making this determination.
                                                                                         Can I Directly Transfer-in-kind Mutual Fund Shares Between
                                                                                         Money-by-Design Program Accounts?
Can I Transfer/Exchange/Rollover Funds Into My Account?
                                                                                         No. Mutual Fund shares in one program account may not be directly
                                                                                         transferred-in-kind to a different program account. To affect a
Your Money-by-Design account will accept transfers, exchanges and
                                                                                         transfer-in-kind, you must contact your Kades-Margolis financial
rollovers from other retirement accounts. You may request a transfer
                                                                                         advisor to seek a redemption of shares in the first program account
into your account by completing the Incoming Exchange/Rollover
                                                                                         and a purchase of the same or similar shares for the second program
Request Form and returning it to your Kades-Margolis financial
                                                                                         account. Please note that there may be differences in fund share
advisor. The form will be submitted and funds requested from the
                                                                                         classes offered through different programs. In this regard, different
custodian or trustee. You will be able to direct the investment of
                                                                                         share classes normally have different expense characteristics.
your transfer or rollover separately or in the same manner as your
                                                                                         Additionally, please be aware that there may be a two or more
regular contributions.
                                                                                         business day delay between a redemption and purchase of shares.
                                                                                         Please contact your Kades-Margolis financial advisor regarding any
                                                                                         questions relating to this process.




            “Money-By-Design” is a trademark of Kades-Margolis Corporation that has been licensed to Kades-Margolis Capital, LLC for the latter’s use in the
                                  Kades-Margolis Capital, LLC IRA/Roth IRA/SEP IRA/ Simple IRA Program (Revision Date 9/08)
                                                                                                                                                   1
                                                                                         deposited to your account. These Transaction Fees are authorized
                                                                                         under the Custodial Agreement.
How Are Distributions Made From My Account?
                                                                                                  Your ITD Contributions            Your Transaction Fee
                                                                                                       $0 - $23,499.99                       4.90%
You can withdraw assets from your IRA/Roth IRA/SEP IRA/Simple IRA
at any time. However, penalties and unfavorable tax consequences                                  $23,500.00 - $49,999.99                    4.65%
may result from premature distributions. You may request a single
sum payment or a series of systematic withdrawals from your                                       $50,000.00 - $99,999.99                    3.80%
account. Since these transactions involve income tax consequences,                               $100,000.00 - $249,999.99                   3.25%
you should consult a tax advisor before electing a distribution from
your account. (Please see other sections of this disclosure document                             $250,000.00 - $499,999.99                   2.25%
for fees).
                                                                                                 $500,000.00 - $999,999.99                   1.65%
                                                                                                  $1,000,000.00 and over                       0%
What Happens To My Account If I Die?

                                                                                          Are There Any Transaction Fee Exceptions And Reductions?
Your Participant Enrollment Form permits you to name a beneficiary
of your account. If you do not name a beneficiary, your account will
be distributed to your estate. Whenever you wish, you may modify                         Yes. You may qualify for a reduction in the Transaction Fee if you
your beneficiary by completing in writing a new beneficiary                              intend to make sizeable contributions to your account within the next
designation form and sending it to the Sponsor or its designated                         13-month period. To qualify, you must execute a Letter of Intent
recordkeeper, GWN Marketing, Inc.                                                        (LOI) specifying the total contributions you believe will be applied to
                                                                                         your account in the 13-month period that begins on the date of your
                                                                                         LOI. For a LOI executed with an incoming rollover from the Public
Will I Receive An Account Statement?                                                     School Employees’ Retirement System (PSERS), the LOI period is 18
                                                                                         months to allow all of the participant’s contributions and interest
                                                                                         from the PSERS system to rollover. If at the end of the 13-month or
Yes. An account statement will be mailed to your address of record                       18-month period your contributions are not sufficient to meet the
within 15 business days after the end of each quarter. Statements are                    program requirements, fees will be applied retroactively to your
generated for lump sum or rollover contributions. However,                               account based on the ITD contributions made through the last day of
transaction confirmations for salary deferral contributions will not be                  the 13-month or 18-month period. Fees will collected through
generated. These will show on your quarterly statements. You will                        redemptions that will be applied on a pro-rata basis to your accounts
also be able to view and print a copy of your account statement from                     with account balances on that date.
the internet site at anytime at www.moneybydesign.biz.
                                                                                         If your spouse participates in the Program, contributions made by
You will have 30 days to review your statement for any discrepancies.                    either you or your spouse may be counted as your ITD contributions
At the end of the 30 day grace period, it will be assumed that you                       for determining your Transaction Fee.
agree with the information provided in your statement.
                                                                                         All accounts, including those owned by a spouse, within the
                                                                                         Money-by-Design 403(b)(7)/Roth 403(b)(7)/457(b)/IRA/Roth IRA/SEP
Are There Fees To Participate In The Program?                                            IRA/Simple IRA and or Money-by-Design Platinum Advisory Service
                                                                                         Programs, may be aggregated to reduce Transaction Fees.

The Program charges or passes along various fees as disclosed herein,                    The Money-by-Design 403(b)(7)/Roth 403(b)(7)/457(b) Program will
including a Transaction Fee that is based on your total account                          allow rollovers, transfers and exchanges to the Money By Design IRA/
contributions from inception.                                                            Roth IRA/SEP IRA/Simple IRA Program and Money-by-Design Platinum
                                                                                         Advisory Service Program without a new Transaction Fee.

How Are Transaction Fees Calculated?                                                     If you provide a copy of a mutual fund statement at the time that you
                                                                                         initiate a qualifying transfer/exchange or rollover from a mutual fund
                                                                                         family included in this Program, you will not be subject to a
When a contribution is received for your account, that amount is                         Transaction Fee on these monies. These transfer/exchange or
added to your prior contributions. This is known as your                                 rollover dollars will be included in the ITD contribution and therefore
Inception-To-Date (ITD) Contribution. The total is compared to the                       may reduce future Transaction Fees.
breakpoints in the Fee Schedule below and the appropriate charge is
                                                                                         If you are a relative of a Kades-Margolis financial advisor, the
deducted from the current contribution. The remaining amount is
then applied to the investments in your account. All fees you pay will                   Transaction Fees may be waived. If you add new
be reflected in the quarterly statement you receive from the                             contributions/transfers/rollovers or exchanges to the Money-by-
recordkeeper. You may also view the fees on the internet site at                         Design Platinum Advisory Service Program and elect the Asset Based
www.moneybydesign.biz.                                                                   Fee Structure, you will not be subject to any Transaction Fees.
                                                                                         However, you will be subject to an Asset Fee structure imposed by
                                                                                         that Program.
What Is The Transaction Fee Schedule?


The Transaction Fee Schedule shown below is based on
Inception-To-Date (ITD) contributions to your account:

(Example): On May 30th the ITD contributions to your account totaled
$22,500. On June 15th an additional $1,000 deferral is received. The
ITD contributions now equal $23,500 and the fee applied to your
$1,000 would now be 4.65%, rather than 4.90%. Transaction Fees are
deducted from ITD contributions before such contributions are

            “Money-By-Design” is a trademark of Kades-Margolis Corporation that has been licensed to Kades-Margolis Capital, LLC for the latter’s use in the
                                  Kades-Margolis Capital, LLC IRA/Roth IRA/SEP IRA/ Simple IRA Program (Revision Date 9/08)
                                                                                                                                                    2
                                                                                            Pertinent Parties
Will I Incur Any Other Fees?


Yes. An annual recordkeeping fee of $15 ($3.75 per quarter) will be
applied to your account.                                                                 Exclusive Marketer: Kades-Margolis Corporation
                                                                                         Sponsor: Kades-Margolis Capital, LLC
This fee is waived when ITD contributions reach $50,000. This and                        Recordkeeper- GWN Marketing, Inc.
other fees are authorized under the Custodial Agreement. In this                         Custodian- AST Trust Company
regard, other fees that may be applied when taking distributions from                    Securities offered though: GWN Securities, Inc.,
your account are:                                                                        11440 N. Jog Road, Palm Beach Gardens, FL 33418, (561) 472-2700,
                                                                                         Member FINRA & SIPC.
    •    For Systematic Distributions using ACH you may make
         one free election per calendar year. ACH is available                           Kades-Margolis Corporation, Kades-Margolis Capital, LLC and or GWN
                                                                                         Securities, Inc. (“Organizations”) may be reimbursed by funds or their
         monthly, quarterly, semi-annually or annually. After
                                                                                         affiliates or other service providers (“Service Providers”) for the
         your first election, a $25 Fee will be assessed against
                                                                                         expenses the Organizations incur for various sales meetings,
         your account for each additional election made during                           seminars, and conferences held in the normal course of business, or
         the year. This Fee will be deducted from your account                           the Service Providers may directly sponsor the latter events.
         evenly over the remaining number of systematic ACH                              Although Service Providers independently decide what they will
         withdrawals that year.                                                          spend on these activities, some Service Providers may allocate their
                                                                                         promotional budgets based upon prior sales and asset levels and may
    •    For Systematic Distributions with a physical check sent to                      work with our Organizations to plan promotional and educational
         participant’s address a $10 per check fee will be deducted                      activities on the basis of such budgets. Our Organizations do not
         from your account.                                                              control Service Providers' determinations of how to allocate their
                                                                                         promotional budgets or their spending decisions in this regard. Our
    •    $25 Distribution Fee for any and all partial lump sum                           Organizations also may receive recurring distribution and service fees
         distributions by check or ACH out of the Program.                               (referred to as"12b-1 fees") from Service Providers. Our financial
                                                                                         advisors receive no additional compensation as a result of the
    •    $70 Distribution Fee (ACH or Check) for a 100% lump sum                         aforementioned reimbursements and payments.
         distribution out of the Program.
                                                                                         For additional information on a particular fund’s payment and
                                                                                         reimbursement practices, please refer to the fund's prospectus. We
                                                                                         also note that certain individuals simultaneously serve in key policy
Is There A Cost Applied By The Mutual Fund?                                              and decision making roles at Kades-Margolis Corporation, Kades-
                                                                                         Margolis Capital, LLC and or GWN Securities, Inc.
Yes. Mutual Fund Companies apply certain expenses and
management fees to the earnings of the mutual funds, which may                           Kades-Margolis and GWN Securities, Inc. are non-affiliated companies.
vary by fund share class. Generally, A, Advisor, R3 and R4 share                         Kades-Margolis has no sponsorship, affiliation or endorsement
classes are being offered through the Program. These share classes                       relationship with PSERS.
generally impose 12b-1 fees that may be shared with Kades-Margolis
Capital to offset recordkeeping and other service related costs of
operating the Program. For an explanation of the expenses and fees                          Who Can I Contact With Questions?
associated with a particular fund class, participants should read the
specific fund prospectus. Mutual Fund Companies also may charge
redemption fees, particularly to participants who do not hold fund                       If you have any questions regarding the Money-by-Design Program,
investments for a certain minimum time. These expenses vary by                           you may contact your local Kades-Margolis financial advisor by
fund and are also disclosed in the fund’s prospectus.                                    calling the main office.

                                                                                         Kades-Margolis Corporation
                                                                                         998 Old Eagle School Road, Suite 1220, Wayne PA, 19087
                                                                                         Toll-Free (800) 433-1828 ext. 4 or Email: info@4kmc.com
                                                                                         Client Account Services: Kades-Margolis Capital, LLC
                                                                                         Toll-Free (800) 940-5524
                                                                                         (8:30 am to 5:00 pm EST) or visit www.moneybydesign.biz




            “Money-By-Design” is a trademark of Kades-Margolis Corporation that has been licensed to Kades-Margolis Capital, LLC for the latter’s use in the
                                  Kades-Margolis Capital, LLC IRA/Roth IRA/SEP IRA/ Simple IRA Program (Revision Date 9/08)
                                                                                                                                                   3
  Platinum Advisory Service- General Information
 (AN OPTIONAL, ELECTIVE SERVICE)

                                                                                                  Your Asset Value              Your Annual Asset
Clients with a minimum of $50,000 in assets can elect to choose a                                                                    Based Fee
managed advisory model portfolio option offered through the
federally registered investment advisor of GWN Securities, Inc.
(“Platinum Advisory Service”). This Service offers clients a choice of                               $50,000.00 –                       1.30%
actively managed model portfolios. These portfolios include                                          $249,999.99
aggressive growth; moderately aggressive growth; moderate growth;
balanced; moderately conservative income and conservative income.                                   $250,000.00 –                       1.05%
Additional funds apart from those available in the basic Money-by-                                   $749,999.99
Design Program may be available through the Platinum Advisory
Service. Service portfolios are reviewed at least every 90 days and                                  $750,000.00                         .80%
investment decisions are automatically implemented across all                                          & over
participants in each model.

Accordingly, this option may not be suitable for all clients,                            A client not meeting the 13- month minimum of $50,000 will receive
particularly those with smaller amounts of Program assets. This                          notification 90 days prior to the expiration date. This notice will
disclosure document does not constitute an offer to engage in this                       state that the client will have 90 days to satisfy the minimum
option nor should be construed as investment advice. To engage in                        requirement. If the requirement can not be met, then alternate
the Platinum Advisory Service, clients must receive the option’s                         investment options (non Advisory funds) must be received for the
disclosure documents and sign the advisory agreement. Please see                         Advisory account to be placed in a Money-by-Design (Non Advisory)
your Kades-Margolis financial advisor or call for additional                             program account no later than the end of the 13-month period. If the
information. The Advisory Account Agreement and GWN Securities,                          alternate investment options are not received within the specified
Inc.’s Form ADV Part II specifically describe the service. The                           timeframe, then the Sponsor will open a Money-by-Design
Pennsylvania State Education Association (PSEA) and Delaware State                       (Non Advisory) account for the client using the Program’s default
Education Association (DSEA) is not a sponsor of the service, but has                    Money Market.
endorsed the Flat Rate Fee Structure program. As a newer fee
structure, the Asset Based Fee Structure has not been reviewed by                        The Money-by-Design Platinum Advisory account will be
PSEA & DSEA, and consequently has not been endorsed by PSEA &                            automatically de-unitized and shares liquidated. The proceeds from
DSEA.                                                                                    the liquidation will then be invested into either the default Money
                                                                                         Market or client elected options of the Money-by-Design (Non
  Platinum Advisory Service- Asset Based Fee Structure                                   Advisory) program. These are not unitized. The client is then subject
 (AN OPTIONAL, ELECTIVE SERVICE)                                                         to transaction and recordkeeping fees as noted within this Important
                                                                                         Disclosure document.

Clients can elect the Platinum Advisory Service managed advisory
portfolio model with the Asset Based Fee structure (see schedule
below). The minimum requirement of $50,000 in assets must be
received within 13-months of the account open date. The Asset Based
Fee program will accept initial reduction contributions as well as
transfers/rollovers/exchanges and lump sum investments. For
purposes of calculating Custodial Account assets, the Custodian will
not will not count accounts owned by a spouse and it is not
relevant whether you will intend to make sizeable contributions to
your account under a LOI or otherwise. Based upon your
instructions, however, the Custodian will count all of your
Money-by-Design Platinum Advisory 403(b)(7)/Roth 403(b)(7)/457(b)
accounts and IRA/Roth IRA/SEP IRA/Simple IRA accounts within the
Platinum Advisory Money-by-Design Program.

All contributions received will be invested directly into the models.

The Custodian shall collect a quarterly fee equal to a percentage of
the market value of all assets held within the Custodial Account on
the last business day of the quarter or upon withdrawal from the
Custodial Account prior to quarter end. There are no Transaction
Fees applied to purchases within this Asset Based Fee Structure.
See the 403(b) Custodial Account Agreement for a complete schedule
of fees and charges. Such fee shall be collected by the Custodian, and
the Advisor may direct the Custodian to pay all or a portion of the fee
to an agent performing duties on behalf of the Advisor. The
Custodian may pay all or a portion of the Custodial fee to an agent
performing administrative duties on behalf of the Custodian.




            “Money-By-Design” is a trademark of Kades-Margolis Corporation that has been licensed to Kades-Margolis Capital, LLC for the latter’s use in the
                                  Kades-Margolis Capital, LLC IRA/Roth IRA/SEP IRA/ Simple IRA Program (Revision Date 9/08)
                                                                                                                                                   4

								
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