Hughes Investment Management

Private Account Management An Individualized Approach to Your Portfolio The Highest Level of Attention

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1-888-814-7575

Performance: we are the top performing money manager in our respective peer group as rated by Nelson!

Do you want the opportunity to have a direct impact on what stocks we buy and sell in your portfolio? If the answer is yes, then private account management may be your best way to benefit from the expertise of Hughes Investment Management.

With our Private Account Management Service, your individual investment picture is reviewed in detail by Douglas Hughes. After consultations that help to identify specified goals for your portfolio, an account is set up in your name at Wedbush Morgan or a firm of your choice. We are signed onto the account as your adviser and are authorized to make buy and sell decisions. You receive, from Tucker, immediate confirmations on all trades and regular monthly statements.

You continue to have direct one-on-one access to Douglas Hughes, who is generally available to answer and handle any questions you may have.

Maximum flexibility. Maximum personalization. Maximum support from our staff. To open an account, a balance of $100,000 is required. This can consist of several individual accounts such as your IRA, your spouse's IRA, and/or a joint account.

Learn more about our Our Services.

To determine if Private Account Management is right for you, answer these questions:

1. Are you managing substantial sums of money?

2. Do you need a high degree of personalization and customization in your portfolio?

3. Do you like close contact with all activity in your portfolio?

4. Do you like to see every trade confirmation for every change?

5. Do you have tax-management concerns?

6. Are you trying to invest in only one or two specific sectors?

How Do We Work?

• In-House Research
• Portfolio Structure
• Brokerage Practices
• Net Asset Value
• Portfolio Turnover

In-House Research

Hughes Management is a research-oriented investment firm. As such, the Manager intends to invest only in those companies of which it has in-depth knowledge. This includes a thorough understanding of a company’s business lines, its future earnings prospects, management, liquidation value, and its plans for growing its deposit base. Book value many times is understated, not reflecting the true value of all company assets. Even if all of the Manager’s requirements for investment are met from a purely financial perspective, the Manager does not invest in companies whose management is not capable, reliable, knowledgeable, and shareholder-oriented.

By concentrating on a small number (30-50 stocks) of particularly attractive investment opportunities at any one time, the Manager believes that it can provide much higher returns than would be provided in most other investment vehicles, and it believes that it can do so with a relatively low risk of permanent loss of capital.

The Manager’s approach to valuing stocks is no different than that which should be applied in valuing a whole company. The Manager will search for companies it believes are undervalued and will be conservative in future assumptions, in order to minimize the potential for permanent loss of capital.

Once the security approaches what the Manager believes to be its fair value, the Manager will consider selling all or part of the position and reinvesting the proceeds in another company that it feels is undervalued.

The Manager does not intend to employ technical analy sis, nor does it intend to use a "momentum" style of investing, under which a stock would be purchased, or sold short, just because of recent price trends. Realizing that there are better times to purchase stocks than others, the Manager will always take into account current overall economic and market conditions. However, the Manager strongly believes that for long-term investors, the greatest returns can be generated from a strategy that involves buying a good business at a large discount to the present value.

Hughes Management will generally be invested in equity securities of smaller companies that are not widely followed by the major investment banking firms. The Manager believes that by spending time and effort, first, to find and analyze the fundamentals of promising companies, and second, to understand the market in which the company operates, it will be able to generate returns well in excess of those found in the market as a whole.

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Portfolio Structure

The portfolios will, on average, have 10-50 issues in them, depending on the size of the assets. As a result, there is risk that an adverse event affecting a single company could result in significant losses to the portfolio’s value. In addition, some of these companies’ stocks may have relatively low trading volume. This illiquidity may increase the risk of loss if circumstances dictate the necessity of liquidating these positions.

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Brokerage Practices

Portfolio transactions will be allocated to brokers on the basis of best execution, special execution capabilities, block trading, efficiency and error resolution, availability of stocks to borrow for short trades, record keeping and similar services, as well as commissions charged.

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Net Asset Value

In connection with the determination of the net asset value of the portfolio, securities shall be valued as follows.

1. Listed portfolio securities are valued at the last reported sales price on the date of determination on the composite tape or on the principal exchange on which such securities are traded or, if not available, at the exchange mean price.
2. Over-the-counter securities are valued at the last reported sales price on the date of determination if available through the facilities of a recognized inter-dealer quotation system (NASDAQ). If the last reported sales price is not readily available, over-the-counter securities are valued at the mean between the closing "bid" and "asked" prices on the date of determination.

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Portfolio Turnover

The portfolio annual turnover rate may vary, depending on market conditions, and at times the portfolio may engage in short-term trading. However, most investing is done for the long term. A high rate of portfolio turnover involves correspondingly greater expenses than a lower rate. Douglas Hughes, the portfolio Manager, will have direct and primary responsibility for all investment decisions.

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Please feel free to contact us with any questions you may have.

As always, you may call me, Douglas Hughes of Hughes Investment Management, with any questions on any stock. This is a free service to our subscribers.

To subscribe, contact Douglas Hughes via phone at 1-888-814-7575 or by email at dhughes33@charter.net

Douglas Hughes of Hughes Investment Management can and does take positions in stocks it recommends.

All material Copyright© 1995-2008 by Douglas Hughes. Reproduction of this publication in whole or in part is strictly forbidden.