A. The Company Hudson Capital Advisory, Inc. (“Hudson Capital” or the “firm”), a Delaware corporation, was registered with the State of New York from 2019 to 2022 and has been registered with the U.S. Securities and Exchange Commission since May 2021. The principal owner of Hudson Capital is William N. Hudson III. B. Advisory Services Hudson Capital offers the following services to advisory clients: Investment Management Services Hudson Capital offers ongoing Investment Management Services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Investment Management Services include, but are not limited to, the following:
• Financial planning
• Investment strategy
• Asset allocation
• Risk tolerance
• Personal investment policy
• Asset selection
• Regular portfolio monitoring Hudson Capital will create and manage a customized portfolio based on the client’s risk profile and investment guidelines. Hudson Capital will allocate the client's assets among various asset classes based on the client’s risk tolerance. Each portfolio will be designed with the goal of meeting each client's individual needs. Investment Management Services will be provided on both a discretionary and non- discretionary basis. For those accounts to be managed on a discretionary basis, the client will give Hudson Capital full authority to manage the client's assets in accordance with what Hudson Capital deems to be in the client's best interest based on the client’s investment objectives and guidelines. Clients will retain individual ownership of all securities in their account. Hudson Capital Portfolio Strategies Hudson Capital manages two proprietary portfolio strategies:
• The HCA Healthcare Opportunities Portfolio
• The HCA Earnings Growth Portfolio
• The HCA Balanced Portfolio Hudson Capital may recommend to clients that a portion of their assets be invested in either one or both of these portfolio strategies. Please see the fee disclosures in Item 5 (Fees and Compensation) below for an explanation of any potential conflicts of interest and for disclosures regarding Hudson Capital’s fee-sharing arrangement with Monetary Management Corporation, Inc., an investment adviser registered with the State of California that provides research to support the construction of the Hudson Capital proprietary portfolio strategies. Financial Planning Services If a client desires to obtain financial planning apart from the basic planning services provided as part of Investment Management Services, Hudson Capital also provides financial planning as a stand-alone service. Financial plans and/or financial planning recommendations (in the absence of a financial plan) may include, but are not limited to, investment planning, life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Information gathered includes a client's current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed, and a written report may be prepared. Financial planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All financial planning recommendations are of a generic nature. In performing its services, Hudson Capital is not required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely on such information. Should a client choose to implement the financial planning recommendations contained in the plan, Hudson Capital may recommend its own services or that of other professionals (i.e., attorney, accountant, insurance agent, and/or stockbroker). Clients are advised that a conflict of interest exists if Hudson Capital recommends its own services. The client is under no obligation to act upon any of the recommendations made by Hudson Capital under a financial planning engagement and/or engage the services of any such recommended professional, including Hudson Capital or any of its related persons. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Hudson Capital’s recommendations. Consulting Services Clients can also receive investment advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, reviewing a client's existing portfolio, or any other specific topic. Hudson Capital also provides specific consultation and administrative services regarding investment and financial concerns of the client. Additionally, Hudson Capital provides advice on non- securities matters. Generally, this is in connection with the rendering of estate planning, tax planning insurance, and/or annuity advice. Consulting recommendations are not limited to any specific product or service

offered by a broker-dealer or insurance company. All recommendations are of a generic nature. Sub-Advisory Services Hudson Capital offers investment advisory services to other registered investment advisers on a sub-advisory basis. Such sub-advisory services may include providing proprietary research and investment ideas. Hudson Capital provides sub-advisory services on both a discretionary and a non-discretionary basis. Co-Advisory Services Hudson Capital also provides investment consulting services to clients through a co-advisory arrangement (the “Co-Advisory Services”) with Shield Wealth Advisors, LLC, an investment adviser registered with the SEC (“Shield”). Shield and Hudson Capital have entered into a Co-Advisory Agreement that sets forth their respective responsibilities and obligations to the client (“Joint Client”). Joint Clients will enter into a discretionary co-investment advisory agreement (the “Co-Investment Advisory Agreement”) with Hudson Capital and Shield. Pursuant to the Co-Investment Advisory Agreement, Hudson Capital and Shield will have the following respective responsibilities:
• Hudson Capital will be responsible for providing the Joint Client with the following investment management services: (i) preparing the Joint Client’s investment policy statement; (ii) recommending investment strategies for the Joint Client’s account(s); (iii) providing discretionary investment management services to the Joint Client’s account(s); (iv) providing advice on asset allocation within the Joint Client’s account(s); (v) conducting periodic reviews of the Joint Client’s account(s); and (vi) updating the Joint Client’s investment objectives and profiles as warranted but on no less than an annual basis. Hudson Capital will make and implement investment decisions without prior consultation with the Joint Client or Shield, except for such restrictions as the Joint Client provides to Hudson or Shield in writing.
• Shield will be responsible for providing the Joint Client with the following investment consulting services: (i) recommending to the Joint Client the qualified custodian/broker-dealer (the “Custodian”) that will be used to provide custody of Joint Client assets and execute trades in the Joint Client’s account(s); (ii) providing the Joint Client with administrative assistance to (a) enter into the Co-Investment Advisory Agreement and (b) supply the Joint Client with all custodial documentation required for opening and maintaining an account with the Custodian; (iii) being responsible for executing trades in the Joint Client’s account(s); and (iv) charging, collecting and distributing investment advisory fees collected pursuant to the Co- Investment Advisory Agreement. Bookkeeping Services If requested by a client, Hudson Capital will provided customized bookkeeping services which consists of serving as either your bookkeeper or assistant bookkeeper and/or providing tax preparation. C. Client Tailored Services and Client Imposed Restrictions Hudson Capital’s investment management services are tailored to meet the specific needs of each client. In order to provide appropriately individualized services, Hudson Capital will work with the client to obtain information regarding the client’s financial circumstances, investment objectives, overall financial condition, income and tax status, personal and business assets, risk profile and other information regarding the client’s financial and investment needs. At least annually, Hudson Capital will review with clients their financial circumstances, investment objectives and risk profile. In order for Hudson Capital to provide effective investment management services, it is critical that clients provide accurate and complete information to Hudson Capital and inform Hudson Capital anytime such information needs to be updated or anytime there is a change in their financial circumstances, investment objectives and/or risk profile. Generally, clients are permitted to impose reasonable restrictions on investing in certain securities or types of securities in their advisory accounts, provided, however, that some restrictions may not be accommodated when utilizing Exchange Traded Funds, mutual funds or with respect to certain third-party investment managers. In addition, a restriction request may not be honored if it is fundamentally inconsistent with Hudson Capital’s investment philosophy, runs counter to the client’s stated investment objectives, or would prevent Hudson Capital from properly servicing client accounts. D. Wrap Fee Programs Hudson Capital does not participate in wrap fee programs (i.e., programs that offer services for one, all-inclusive fee). E. Assets Under Management As of March 28, 2023, Hudson Capital has approximately $119,147,000 in assets under management, of which $107,434,000 are managed on a discretionary basis and $11,713,000 on a non-discretionary basis.