Description of Advisory Services
Hudson Valley Investment Advisors, Inc. (and its predecessor, Hudson Valley Investment Advisors, LLC) is a
United States Securities and Exchange Commission Registered Investment Advisor, that has been serving
clients with the same consistent investment strategy and discipline since 1995. In 2012, our firm went through a
change involving the sale of the principal assets of Hudson Valley Investment Advisors, LLC (“HVIA, LLC”),
a subsidiary of Provident New York Bancorp, to Orange County Bancorp, Inc., (“OCBI” or “Holding
Company”). HV Capital Management, the management company for HVIA, LLC and an investment advisor
owned by Thomas Guarino was similarly purchased by OCBI. OCBI has kept HV Capital Management, Inc.’s
SEC registration, has transferred the assets of HVIA, LLC into HV Capital Management, Inc.., and has changed
the name back to Hudson Valley Investment Advisors, Inc. The firm will continue to provide the same proven
investment strategy and discipline that has been utilized since 1995.
We provide investment services to a diverse client list. In every case, we give continuous advice to you based
on your stated needs. Among the clients served by us are individuals, trusts, estates, corporations, pension, and
profit-sharing plans, charitable institutions, and investment companies. Your account can be managed on both a
discretionary and nondiscretionary basis. Where we have discretion, we have discretionary authority regarding
the securities to be bought and sold and the timing of transactions. Discretion may extend to the selection of
broker-dealers to execute trades for your account. Account supervision is guided by your stated objectives.
Assets may be allocated to equity and fixed income securities, and, where appropriate, to alternative
investments such as privately-offered securities, with recommendations, selections, and asset allocations
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Where appropriate, we may recommend to clients investments in alternative securities such as private equity funds,
private real estate funds, private debt funds, hedge funds, and/or venture capital funds. When we utilize a third-party
investment platform, investment recommendations may be limited to alternative securities offered via such a platform.
Interests in alternative securities are typically offered in reliance upon various exemptions available under the
securities laws for transactions in securities not involving a public offering. These investments are managed by
unaffiliated third-party managers on a discretionary basis in accordance with the terms and conditions of the
relevant offering and organizational documents.
Prospective investors in alternative securities should be aware of additional risks, restrictions on withdrawals
and redemptions, and other important information associated with investment in such instruments. This
information is outlined in relevant offering and subscription documents. Prospective investors should refer to
these documents for information regarding important additional considerations and risks.
We provide a service for client held-away accounts that are maintained at independent third-party custodians
where we utilize their order management system (currently Pontera) to implement asset allocation or
rebalancing strategies on behalf of the client for those held-away accounts.
These are primarily 401(k) accounts, 529 plans, and other assets we do not directly manage and are maintained
by the client. We regularly review the current holdings and available investment options in these held-away
accounts, monitor the held-away accounts, and rebalance and implement the client’s investment strategy as
necessary.
Investment advisory services provided to accounts are based on your needs and objectives. These may be
established at an initial meeting with us, or through written investment objectives submitted by the Client. At
any time, you may impose restrictions on investing in certain securities or types of securities.
The relevant facts relating to the management of the account are examined and appropriate investment
strategies are developed to obtain your desired goals. We will provide, at least annually, a performance analysis
of each account. We will meet with you periodically and encourage regular telephone contact and in-person
meetings to review objectives and investment strategies.
Investment Company Management
We provide investment advisory services to a mutual fund (“Fund”) that is part of Ultimus Managers Trust
(“UMT”) and is registered under the Investment Company Act of 1940, as amended. We serve as the
investment manager to the Fund and continuously manage the Fund’s assets based on the investment goals and
objectives as outlined in the Fund's prospectus.
Interested investors should refer to the Fund's prospectus and Statement of Additional Information ("SAI") for
important information regarding objectives, investments, time horizon, risks, fees, and additional disclosures.
These documents are also available by calling 1-888-209-8710.
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Prior to making any investment in the fund, investors and prospective investors should carefully review these
documents for a comprehensive understanding of the terms and conditions applicable for investment in the
Fund.
Financial Planning Services
We also provide Financial Planning advice. Financial Planning is only provided for existing clients. We gather
the required information through in-depth personal interviews. We may ask you about your current financial
status, future goals, and attitudes toward risk. We carefully review any appropriate documentation that you
provide.
In general, financial planning discussions may address any or all of the following areas that may be of concern
to you:
Personal: Family records, budgeting, personal liability, estate information, and financial goals.
Education: Education IRAs, financial aid, state savings plans, grants, and general assistance in preparing to
meet your dependent's continuing educational needs through the development of an education plan.
Tax & Cash Flow: Income tax planning and spending analysis. For example, we may illustrate the impact of
various investments on your current income tax and future tax liability.
Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning, and disability
income analysis.
Retirement:
Analysis of current strategies and investment plans to help you achieve your retirement goals. At
its sole discretion, we will compensate unaffiliated third parties for various professional services rendered to our
clients, including, but not limited to, estate planning, social security planning, and Medicare planning.
Investments: Analysis of investment alternatives and their effect on your portfolio.
If you choose to implement the recommendations discussed in the financial planning consultation, we suggest
that you work closely with your attorney, accountant, insurance agent, and/or stockbroker. Implementation of
financial planning recommendations is entirely at your discretion. Our financial planning 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. We do not charge fees for financial planning consultations for
existing clients who have assets under management with us of at least $250,000.
Investment Consulting Services
HVIA provides a model portfolio, economic Diffusion Index, economic overview, and manager selection to
third-party manager(s) who may utilize such a model and information for client investments. We provide three
levels of services for our investment consulting services.
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Level 1 is access to the model portfolio. Level 2 encompasses Level 1 with additional access to the Diffusion
Index and economic overview. Level 3 includes the services in both Levels 1 and 2, and includes access to
economic overview conference calls, and manager selection.
HVIA does enter into an advisory relationship with the clients of the third-party manager(s) and does not
execute transactions associated with the model provided. The third-party manager may accept or reject any or
all recommendations contained within our Investment Consulting relationship.
401K Consulting Services
We provide several advisory services separately or in combination. 401K Consulting Services is comprised of
four distinct services. Clients may choose to use any or all of these services.
A. Investment Policy Statement Preparation (Hereinafter Referred To As ''IPS'')
We will meet with the client (in person or over the telephone) to determine the client's investment needs and
goals. We will then prepare a written IPS stating those needs and goals and encompassing a policy under which
these goals are to be achieved. The IPS will also list the criteria for the selection of investment vehicles and the
procedures and timing intervals for monitoring of investment performance.
B. Selection of Investment Vehicles
We will review various investments, consisting exclusively of mutual funds (both index and managed) to
determine which of these investments are appropriate to implement the client's IPS. The number of investments
to be recommended will be determined by the client, based on the Investment Policy Statement.
C. Monitoring of Investment Performance
Client investments will be monitored continuously based on the procedures and timing intervals delineated in
the Investment Policy Statement. Although for most of our plans, we will not be involved in any way in the
purchase or sale of these investments, we will supervise the client's portfolio and will make recommendations to
the client as market factors and the client's needs dictate.
D. Employee Communications
Since our clients will have individual accounts with participants exercising control over assets in their own
account (''self-directed plans''), we also provide quarterly educational support designed for the Plan participants.
The nature of the topics to be covered will be determined by us and the client under the guidelines established in
ERISA Section 404(c). The educational support will NOT provide Plan participants with individualized,
tailored investment advice or individualized tailored asset allocation recommendations.
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1031 Exchange Consulting Services
We provide 1031 consulting services to clients who are interested in the implementation of a 1031 Exchange
plan for their real property. Section 1031 of the United States Internal Revenue Code allows investors to defer
capital gains taxes on any exchange of like-kind properties for business or investment purposes. We work with
the clients to provide information assistance, and due diligence on 1031 Exchange plans.
We can recommend one or more non-affiliated private real estate funds to implement the 1031 Exchange
depending on client qualifications and suitability. Private real estate funds come with risk, such as lack of
liquidity and substantial holding periods. Clients are urged to read the fund Offering Memorandum prior to
investing in any private real estate fund.
We do not provide accounting or legal advice nor prepare any accounting or legal documents for the
implementation of a 1031 Exchange Plan. The investor is urged to work closely with his/her attorney and/or
accountant in implementing our recommendation to invest in a particular 1031 Exchange Plan.
Miscellaneous Terms
Prior to engaging us to provide any services, you will generally be required to enter into an advisory agreement
that sets forth the terms and conditions of our relationship, describes the scope of the services to be provided,
and additional details with respect to the compensation arrangement.
In performing our services, we shall not be required to verify any information received from the client or the
client’s other professionals. We are authorized to rely on the information that is given to us.
It is your responsibility to promptly notify us if there is ever any change in your financial situation or
investment objectives to review, evaluate, and/or revise our previous recommendations and/or services. No one
may assign the Advisory Agreement without the prior consent of the other party. Transactions that do not result
in or involve a change of actual control or management are not considered an assignment.
A copy of our written disclosure statement, Part 2 of Form ADV (or an equivalent brochure), will be provided
to you prior to or at the time of signing our Advisory Agreement.
Assets Under Management: 12/29/2023
ACCOUNT TYPE U.S. DOLLAR AMOUNT TOTAL # OF ACCOUNTS
DISCRETIONARY $1,222,252,618 1974
NON-DISCRETIONARY $182,603,871 73
TOTAL: $1,404,856,489 2,047
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