Hudson has been in business since October 2008 and is principally owned by Christopher J. Conover. The Firm was formed to provide individual and high-net-worth clients access to institutional caliber wealth management services, which include investment management, financial planning and consulting. Prior to Hudson rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Hudson setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). As of December 2023, Hudson had approximately $112,059,230 in assets under management, $88,500,383 of which was managed on a discretionary basis and $23,558,847 of which was managed on a non- discretionary basis. While this brochure describes the business of Hudson, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Hudson’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services Hudson offers clients a broad range of financial planning and consulting services, which may include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Manager Due Diligence These services are typically rendered as part of a standard investment management relationship; however, the Firm may also negotiate to provide these services under a standalone, project-based engagement. In addition, the Firm may provide investment consulting services with respect to certain assets under an on- going engagement. In performing these services, Hudson is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. Hudson may recommend clients engage the Firm for additional related services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage Hudson to provide additional fee-based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any Page | 5 © MarketCounsel 2021 of the recommendations made by Hudson under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Hudson’s recommendations and/or services. Investment Management Services Hudson manages client investment portfolios on a discretionary or non-discretionary basis. Hudson employs a passive management approach and primarily allocates client assets among various mutual funds and exchange-traded funds (“ETFs”) in accordance with their stated investment objectives. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, however, clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. In addition, Hudson recommends that certain eligible clients invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds) and direct investments in film and television production programs. Hudson tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Hudson consults with clients on an initial and ongoing

basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Hudson if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Hudson determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. The Firm also does not provide tax advice. The Firm’s investment advisory services do not include securities brokerage services as the Firm does not serve as the sponsor or manager to a wrap fee program (i.e., an arrangement where brokerage commissions and transaction costs are absorbed by the Firm). Management of Collective Investment Vehicles Hudson and its affiliates serve as the general partner and investment manager to affiliated private investment funds, Hudson Private LP and ProudLiving New Jersey Real Estate Fund LP, (the “Private Funds”). Interests in the Private Funds are privately offered pursuant to Regulation D under the Securities Act of 1933, as amended. The Private Funds currently rely on an exemption from registration under the Investment Company Act of 1940, as amended. Participation as an investor in the Private Funds is restricted to investors that are qualified clients pursuant to the requirements under Rule 205-3 under the Advisers Act, as well as are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended. Page | 6 © MarketCounsel 2021 To the extent certain of Hudson’s individual advisory clients qualify, they will be eligible to participate as limited partners of the Private Funds. Investment in the Private Funds involves a significant degree of risk. All relevant information, terms and conditions relative to the Private Funds, including the compensation received by Hudson or its affiliate as general partner, suitability, risk factors, and potential conflicts of interest, are set forth in a Confidential Private Offering Memorandum (the “Memorandum”), Limited Partnership Agreement (the “Agreement”), and/or Subscription Agreement (together, the “Offering Documents”), which each investor is required to receive and/or execute prior to being accepted as an investor in a Private Fund. Hudson and/or its affiliates are the general partners of the Private Funds and, as compensation for managing the fund, receive a management fee equal to two percent of the Private Funds’ net asset value and a performance allocation equal to twenty percent of the net capital appreciation of each investor's capital account balance. As a result, a conflict of interest exists because Hudson has an incentive to recommend that its clients invest in the Private Funds because the Firm or its affiliates collects not only the investment management fee (described in Item 5 below) for managing the client's assets as a whole, but also the management fee and performance allocation for managing the client's investment in a Private Fund. Nonetheless, Hudson will only recommend that its clients invest in a Private Fund if such investment is in their best interest. While a Private Fund is considered to be a client of Hudson, “client(s)” may also refer to the investors in a Private Fund. Hudson will devote its best efforts with respect to its management of both the Private Funds and its individual client accounts. Given the above discussion relative to the objectives, suitability, risk factors, and qualifications for participation in the Private Funds, Hudson may give advice or take action with respect to a Private Fund that differs from that for individual client accounts. To the extent that a particular investment is suitable for both a Private Fund and certain individual client accounts, such investments will be allocated between a Private Fund and the individual client accounts in a manner which Hudson determines is fair and equitable under the circumstances to all of its clients.