Hilton Capital ManagementFOCUSED. DILIGENT. DRIVEN.

Hilton Capital Management is a boutique asset manager founded in 2001. With over $635 million in assets under management, the firm’s mission is to seek consistent yield and preservation of capital, all while seeking attractive risk-adjusted growth.

Based in Garden City, NY, the firm has thirteen employees, including five investment professionals. Hilton Capital is a subsidiary of Rafferty Holdings, LLC, and a sister company of Direxion. Our clients include high net-worth individuals, institutions, advisors and family offices.

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FocusedAt Hilton Capital, we want our clients to eat well and sleep well. We strive to deliver a consistently high level of income while seeking preservation of capital and risk-adjusted total returns.

DiligentThere’s no substitute for hard work. Many managers focus on a specific style or type of security – we focus on our clients’ objectives. To achieve our clients’ goals, we seek to take advantage of opportunities across domestic and international markets throughout the capital structure and in all market capitalizations.

At Hilton Capital, we incorporate a systematic, disciplined investment process, while constantly considering the state of world economies and markets.

Driven We go all out in search of income.There’s income out there if you know where to look, and we are skilled at pinpointing opportunities and focused on mitigating losses.

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“We’re not interested in hugging benchmarks. We actively seek out opportunities and capture them.”– Bill Garvey

Chief Investment Officer

Hilton Capital Management

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William J. Garvey, Founder & Chief Investment Officer

Mr. Garvey founded the firm in 2001. In his role as Chief Investment Officer, Mr. Garvey is responsible for overseeing the entire investment process and asset allocation decisions for Hilton Capital.

During his 30 years on Wall Street, Mr. Garvey has developed a distinctive investment process that serves as the core of the firm’s investment philosophy.

Prior to founding Hilton Capital, Mr. Garvey established a fixed-income investment advisory business at Ashland Management, where he served as Head of Portfolio Management.

Mr. Garvey was also affiliated with Lehman Brothers, where he concentrated primarily on fixed-income markets.

Earlier in his career, Mr. Garvey worked with Bache and Co., Dean Witter, and was a founding partner of William J. Garvey and Co. (a member firm of the COMEX).

“Our clients don’t pay us to wait for opportunities.

We seek them out and look to seize them every day.”

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Craig O’Neill, CEO & President

Mr. O’Neill is responsible for overseeing and executing overall Hilton Capital business activity, is a member of the investment committee, and acts as a co-portfolio manager.

Prior to joining Hilton Capital, Mr. O’Neill was a Managing Director at Rafferty Capital Markets, where he oversaw their Institutional Equity Sales and Trading, as well as the Prime Brokerage Group.

Prior to Rafferty Capital, Mr. O’Neill was a partner at CDM LLC, an option specialist firm on the American Stock Exchange, where he served as a Senior Market Maker and Risk Manager.

“Our clients trust us.

We honor that trust with consistency.”

Alexander D. Oxenham, CFA Partner & Portfolio Manager

In his role as Partner and Portfolio Manager, Mr. Oxenham participates in the active management of the Hilton Capital investment strategy and is responsible for investment decisions and asset allocation, with a particular focus on overall portfolio risk management.

Prior to joining Hilton Capital, Mr. Oxenham served at HSBC Private Bank in New York as a Senior Portfolio Manager. Mr. Oxenham was a voting member on the HSBC Private Bank Investment Policy Committee for the Americas region.

Prior to HSBC, Mr. Oxenham worked in portfolio management for Mercantile Bankshares, Bankers Trust Alex Brown / Brown Advisory and Bank of America.

Mr. Oxenham is a CFA charterholder and is also a standing member of the CFA Institute and the New York Society of Security Analysts.

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“We have high standards for ourselves,

driven by the trust our clients place in us.”

At Hilton Capital, managing risk is at the heart of our investment approach.

Minimize risk.Managing risk in dynamic markets requires a tactical and flexible approach that takes into consideration diversified asset classes and geography.

We seek to maintain a nimble portfolio that allows for necessary tactical adjustments to avoid undue risks while remaining flexible enough to take advantage of opportunities.

As the market changes, we adapt to strive to achieve the right outcomes for our clients.

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Maximize income.Providing income for our clients is among our primary goals. We take a disciplined approach in seeking to uncover the best opportunities for our clients.

We analyze and invest in a broad range of income-producing securities, whether in traditional fixed income, dividend-paying common stocks, or more esoteric yield- producing vehicles.

These securities include, but are not limited to:

Fixed Income

• Preferred Stock• Single-issuer Bonds• Closed-end Funds• Exchange Traded Funds• Convertible Bonds

Equity

• Multi-cap Equities• Master Limited

Partnerships• Real Estate

Investment Trusts• BDCs• Royalty Trusts

HILTON TACTICAL INCOME STRATEGY ALLOCATIONS SINCE INCEPTION (2001):Allocations adapt as markets change.

Percentage

15.8%

33.1%

38.9% 36.6%40.2%

33.8%

23.7%

28.5%

49.0%

40.4%

53.1%

57.9%59.7%

37.9%33.4%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Dec 2002 Dec 2003 Dec 2004 Dec 2005 Dec 2006 Dec 2007 Dec 2008 Dec 2009 Dec 2010 Dec 2011 Dec 2012 Dec 2013 Dec 2014 Dec 2015 Jun 2016

Equities Fixed Income Cash

Hilton Capital routinely conducts a top-down macroeconomic evaluation of world economies and markets including:

- Global Economic Forecasts

- Interest Rates

- Commodity Markets

- Government Policies

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The Investment Process

Disciplined » Flexible » Tactical » Outcome-driven.

Needs-based.First, the top-down macroeconomic evaluation determines the asset allocation of the portfolio. Then Hilton Capital focuses on companies that provide services or products which are viewed as “needs-based” – including, but not limited to, companies focused on energy, financials, consumer staples and healthcare.

Needs-based companies typically pay higher dividends and dampen the cyclicality of the portfolio. This increases the likelihood of performing well in both rising and falling markets.

Security Universe Defined by Focusing on

“Needs-based” Securities

Weekly Review

Income/Yield Filter• Sensitivity to interest rate changes

• Above market dividend/yield

• Sustainability of income stream

• Capital appreciation potential

Fundamental Factors• Sector analysis

• Below market beta

• Ability to increase dividend

• Dominant market share orhigh barrier to entry

• Margin expansion

• Liquidity

Portfolio Compatibility Optimization

• Adds value to overall portfolio capital appreciation

• Correlation and weighting analysis

• Contributes to desired portfolio standard deviation

Capital StructureRisk/Reward Analysis

• Bonds

• Preferred stock

• Common stock

• Convertibles

Bottom-up Security Analysis and Selection Process

All securities “try out” each week to make the portfolio

Portfolio Compatibility.In addition to its individual investment

characteristics, each is considered for

its compatibility in conjunction

with all other holdings in

the portfolio.

- Exchange Rates

- Fiscal/Monetary Policies

- Inflation

- Geopolitical Risks

FINDING YIELD.There’s yield out there, but in the evolving global arena, it takes sustained attention to detail and skilled management to find it.

Our proprietary methodology seeks to uncover opportunities where others may not have looked.

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Yield, risk management, total return.We focus on the income.

Then, we calculate and confirm that the risk metrics are acceptable. Our final step is to assess the ability to produce capital appreciation.

Efficient, tactical management.We are tactical managers. We understand that opportunities come and go, and strategies are only as good as their execution.

Markets are dynamic, so we look to take advantage of pricing anomalies where we can. And we assume an agile position – preferring securities that are liquid.

Please call 1.877.437.9363, or go to direxioninvestments.com to find out more.

1.877.437.9363info@direxioninvestments.comwww.direxioninvestments.com

Disclosures

Separately Managed AccountsThere is no guarantee that the investment objectives described herein will be achieved. You should not make an investment unless you have a long-term investment objective. Investing through our strategies involves risk and there is no guarantee that the strategies described herein will be successful. The prior performance of Hilton Capital in managing separately managed accounts does not ensure that such performance will be achieved for any account in the future. Prior to opening a managed account with Hilton Capital, you will be required to review and execute an investment management agreement which will contain a full description of the fees, liquidity and investment guidelines to which your managed account will be subjected.

This material is for informational purposes only. Any opinions expressed herein represent current opinions only.

Certain information contained in this material constitutes forward-looking statements, which can be identified by the use of forward-looking terminology such as “may,” “will,” “should,” “expect,” “anticipate,” “target,” “project,” “projections,” “estimate,” “intend,” “continue,” or “believe,” or the negatives thereof or other variations thereon or comparable terminology. Such statements are not guarantees of future performance or activities. Due to various risks and uncertainties, the actual performance of your managed account may differ materially from those reflected or contemplated in such forward-looking statements.

Mutual FundsAn investor should consider the investment objectives, risks, charges, and expenses of the Direxion Funds carefully before investing. The prospectus and summary prospectus contain this and other information about Direxion Funds. To obtain a prospectus or summary prospectus, please contact Direxion Investments at 877-437-9363 or visit www.direxioninvestments.com. The prospectus or summary prospectus should be read carefully before investing.

Mutual fund investing involves risk. Principal loss is possible. The Fund’s strategy of investing in dividend-paying stocks involves the risk that such stocks may fall out of favor with investors and underperform the market. In addition, there is the possibility that such companies could reduce or eliminate the payment of dividends in the future or the anticipated acceleration of dividends could not occur. The Fund may invest in foreign securities and ADRs which involve political, economic and currency risks, greater volatility and differences in accounting methods. Medium- and small-capitalization companies tend to have limited liquidity and greater price volatility than large-capitalization companies. Investments in REIT securities involve risks such as declines in the value of real estate and increased susceptibility to adverse economic regulatory expenses. The Fund may invest in MLPs which can be negatively influenced when interest rates rise. These investments also entail many of the general tax risks of investing in a partnership. There is always the risk that an MLP will fail to qualify for favorable tax treatments. Investments in debt securities typically decrease in value when interest rates rise. This risk is usually greater for longer-term debt securities. Investment by the Fund in lower-rated and nonrated securities presents a greater risk of loss to principal and interest than higher-rated securities. Income from municipal securities may be subject to state and local taxes and a portion of income may be subject to the federal alternative minimum tax for certain investors. Federal income tax rules will apply to any capital gains distributions. Because the funds invest in ETFs and ETNs, they are subject to additional risks that do not apply to conventional mutual funds. ETF risk includes the risks that the market price of the shares may trade at a discount to its net asset value (“NAV”), an active secondary trading market may not develop or be maintained, or trading may be halted by the exchange in which they trade, which may impact a Fund’s ability to sell its shares. ETN risk includes the risk that the value of an ETN may be influenced by time to maturity, level of supply and demand for the ETN, volatility and lack of liquidity in the underlying securities markets, changes in the applicable interest rates, changes in the issuer’s credit rating and economic, legal, political or geographic events that affect the referenced index. In addition, ETNs are unsecured debt of the issuer and would lose value if the issuer goes bankrupt.

Distributor: Rafferty Capital Markets, LLC.

Hilton Capital Management and Direxion are subsidiaries of Rafferty Holdings, LLC.

Rev: 06/30/2016