A. The Company Hudson Advisor Services, Inc. is a privately-held New York corporation that has been providing investment advisory services as an SEC-registered investment adviser since 1997 (from 1994 to 1997, William N. Hudson, the founder of Hudson Advisor Services, Inc., conducted the business as a sole proprietorship). Throughout this disclosure brochure, Hudson Advisor Services, Inc. is referred to as “Hudson Advisor Services”. The principal owners of Hudson Advisor Services are William N. Hudson, Jr. and Frances Miley. B. Advisory Services Hudson Advisor Services provides comprehensive investment management services. Through personal discussions, during which goals and objectives based on a client's particular circumstances are established, Hudson Advisor Services and the client agree on guidelines that quantify the client’s risk profile and investment objectives. If requested by the client, Hudson Advisor Services will include outside investments (e.g., investments not directly managed by Hudson Advisor Services) for allocation and planning purposes. Thereafter, Hudson Advisor Services creates and manages a customized portfolio based on that profile, allocating the client's assets among various investments while taking into consideration the client’s risk tolerance. Investment management services may include some or all of the following components (as applicable): Record Keeping Services This service includes maintaining asset, liability, income and expense ledgers. Tax Services This service includes ongoing tax planning and preparation of client tax returns (with the assistance of a Certified Public Accounting firm). Asset Management Services This service includes monitoring the status and valuation of a client’s personal and real property in order to recommend changes when, in the opinion of Hudson Advisor Services’ principals, conditions indicate it is necessary or desirable. Sub-Advisory Services This service includes selecting one or more independent money managers to serve as investment manager(s) of all or a portion of a client’s assets. These independent money managers may either be registered investment advisers or firms that are not required to register with federal or state securities authorities. If the independent money manager is registered as an investment adviser, a complete description of the manager’s services and fees will be disclosed in the manager’s Form ADV Part 2A that will be provided to client. The selection of a specific independent money manager for a client is based on the client's goals, objectives and asset allocation decisions. Each investment manager selected will implement a specific investment strategy and philosophy that individually, or combined with other independent money managers or the assets managed by Hudson Advisor Services, will serve to meet the client's asset allocation decisions and advance the client's objectives. Each independent money manager will have discretion to manage client assets by investing in various equity and fixed income securities. Hudson Advisor Services will monitor the organization, investment philosophy and performance of each independent money manager as well as the economy, investment climate and competitive market conditions for the securities being managed. As a result, Hudson Advisor Services will provide ongoing management services with respect to the client's investment assets. Over time, Hudson Advisor Services may make recommendations to a client regarding proposed changes in the selection of an independent money manager. Hudson Advisor Services may recommend the use of Hudson Capital Advisory, Inc., an affiliated entity and investment adviser registered with the State of New York “HCA”). HCA provides clients of Hudson

Advisor Services with access to two specialized investment strategies - HCA Earnings Growth Portfolio and HCA Healthcare Opportunities Portfolio. As the recommendation of an affiliated entity may present a conflict of interest, any client that will be placed in one or both of the HCA portfolios will be required to sign a waiver document acknowledging the conflict before Hudson Advisor Services will use Hudson Capital Advisory, Inc. as a sub-advisor. Special Services This service includes managing tax-deferred plans, assisting in insurance programming and/or responding to the specialized needs or objectives of a client. When required, either upon Hudson Advisor Services’ recommendation, or at the request of the client, Hudson Advisor Services will engage counsel, accountants, real estate agents or other professionals to render services in connection with a particular matter for a client. Hudson Advisor Services will manage advisory accounts on either a discretionary or non- discretionary basis. C. Client Tailored Services and Client Imposed Restrictions Hudson Advisor Services offers a full range of investment advisory services which can be tailored to meet the specific needs of each client. In order to provide appropriately individualized services, Hudson Advisor Services 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. Hudson Advisor Services will periodically review with clients their financial circumstances, investment objectives and risk profile. In order for Hudson Advisor Services to provide effective advisory services, it is critical that clients provide accurate and complete information to Hudson Advisor Services and inform the firm 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 products or services made available through Hudson Advisor Services. In addition, a restriction request may not be honored if it is fundamentally inconsistent with Hudson Advisor Service’s investment philosophy, runs counter to the client’s stated investment objectives, or would prevent the firm from properly servicing client accounts. Whether clients using an independent money manager will be able to place reasonable restrictions on the types of investments which will be made on the client's behalf is at the discretion of the independent money manager. D. Wrap Fee Programs Hudson Advisor Services does not provide portfolio management services to a wrap fee program(s). Under a wrap fee program, advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and transaction services (e.g., execution of trades) are provided for one fee. This is different than traditional investment management programs whereby services are provided for a fee, but transaction services are billed separately on a per-transaction basis. E. Assets Under Management As of December 31, 2023, the total amount of client assets managed by Hudson Advisor Services is approximately $255,720,000. Of this total amount, approximately $240,158,000 of client assets are managed on a discretionary basis and approximately $15,561,000 of client assets are managed on a non-discretionary basis.