The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," "HPM" and "us" refer to Hudson Portfolio Management LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Description of Firm Hudson Portfolio Management LLC is a fee-only registered investment advisor based in Garrison, NY. We are organized as a limited liability company ("LLC") under the laws of the State of New York. We have been providing investment advisory services since the beginning of 2004. We manage client portfolios and provide related investment advice. The principal owner and managing member is Byron S. Stinson. ToyKen Yee is a Partner of our firm.
The sole business of Hudson Portfolio Management LLC (HPM) is the management of client portfolios and the provision of related investment advice. HPM does not sell products or services other than portfolio management and related investment advice to clients.
Portfolio Management Services Specifically, we offer discretionary portfolio management services to private individuals – including couples and families – and to related trusts, estates, family or small businesses, and charitable funds. We also provide such services to unrelated public non-profit or charitable organizations.
We try to structure portfolios to respond to specific client needs and objectives, and to reflect specific client circumstances such as risk tolerance, and liquidity and cash needs. We do not use target portfolios though it is possible that clients' portfolios may hold similar investment holdings.
If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities and the amount of securities to be purchased or sold for your account, without seeking your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate brokerage account application and trading authorization forms.
In providing discretionary portfolio management services, we rarely accept client restrictions on the specific securities or the types of securities that may be held in your account. But in a very few cases, clients have requested that certain securities not be purchased or that certain holdings not be sold. If you wish to limit HPM's discretionary authority, you must provide us with a written list of securities not to be traded.
For certain clients, e.g., top executive of listed companies, investment bankers and certain attorneys, we may need to obtain "clearance" from the employer's compliance department before we can make certain purchases or sales.
Investment Advisory and Consulting Services We

may also furnish investment advice through consultations that are not a part of the portfolio management services described above. These consulting services primarily involve advising clients on specific investments or investment-related topics outside of the portfolios we manage. HPM does not provide tax or any other non- investment financial advice.
4 Types of Investments We offer advice on equity securities, warrants, corporate debt securities (including commercial paper), certificates of deposit, municipal securities, mutual fund shares, United States government securities, options contracts on securities or commodities, money market funds, REITs, PIPEs, derivatives, structured notes, ETFs, interests in private partnerships and interests in publicly traded partnerships (PTP).
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. IRA Rollover Recommendations For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest, which may occur because there are far greater investment opportunities in an unrestricted investment account compared with retirement plans in which the investment opportunities are restricted to a limited menus of mutual funds.
Wrap Fee Programs We are not the sponsor or manager of a wrap fee program.
Assets Under Management As of December 31, 2023, we provide continuous management services for $145,766,400 in client assets on a discretionary basis.