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Hudson
Heritage Capital Management, Inc.
Form ADV
Part 3, Form CRS
Client
Relationship Summary
June 1, 2022
Item 1.
{Introduction}
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Hudson
Heritage Capital Management, Inc. is registered with the Securities and
Exchange Commission (SEC) as both a broker-dealer and an investment adviser
[and is a member of the Financial Industry Regulatory Authority (FINRA) and
the Securities Investor Protection Corporation (SIPC)]. Brokerage and
investment advisory services and fees differ and it is important for you to
understand these differences. Free and simple tools are available to research
firms and financial professionals at https://www.investor.gov/CRS which also
provides
educational materials about broker-dealers, investment advisers, and
investing.
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Item
2.
{What
investment services and advice can you provide me?}
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BROKERAGE
SERVICES
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ADVISORY
SERVICES
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Our brokerage services
include buying and selling mutual funds, variable annuities, variable Life
products and 529 College Saving Plans. Investment recommendations are made on
a nondiscretionary basis to compliment investments made through our advisory
business. You make the ultimate decision regarding the purchase or sale of
investments with the assistance of a Hudson Heritage professional.
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Our advisory services include
investing in Equity, ETF and Fixed Income Investments. Many investments are
made by utilizing our Proprietary Portfolios or custom designed Fixed Income
Portfolios. Hudson Heritage offers nondiscretionary services, whereby the retail investor makes the
ultimate decision regarding the purchase
and/or sale of investments. Investment monitoring is conducted on
an ongoing basis for not only our proprietary recommendations but customized
portfolios also.
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For additional information, please see Form ADV, Part 2A
brochure (Methods of Analysis, Investment Strategies and Risk of Loss) and
other applicable documents. See http://adviserinfo.sec.gov/
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Conversation Starters. Ask your financial professional—
·
{Given my financial situation, should I choose an investment advisory
service? Should I choose a brokerage service? Should I choose both types of services? Why or why not?
·
How will you
choose investments to recommend to me?
·
What is your
relevant experience, including your licenses, education and other qualifications? What do these
qualifications mean?}
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BROKERAGE SERVICES
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ADVISORY SERVICES
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Item 3.
{What
fees will I pay?}
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For
investments in certain products like mutual funds, annuities, and alternative
investments, we receive transaction-based fees from the investment product
sponsor
in
the form of asset-based sales charges (e.g., sales loads). These fees are
based
on
the amount invested in a product and,
depending
on the product, may be based
on
how long you hold the investment. Our receipt of asset-based sales loads
creates
an
incentive to recommend products or sponsors that include such charges.
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Investment management
fees are billed quarterly, in arrears,
meaning that we invoice you after
the three-month billing period has ended. Payment in full is expected upon invoice
presentation. Fees are usually
deducted from a designated client account to facilitate billing. The client must consent in advance to
direct debiting of their investment account.
Custodians may charge
transaction fees on purchases or sales of certain mutual funds and
exchange-traded funds. These
transaction charges are usually small and incidental to the purchase or sale
of a security. The selection of the
security is more important than the nominal fee that the custodian charges to
buy or sell the security.
HHCM, in its sole
discretion, may waive its minimum fee and/or charge a lesser investment
advisory fee based upon certain criteria (e.g., historical relationship, type
of assets, anticipated future earning capacity, anticipated future additional
assets, dollar amounts of assets to be managed, related accounts, account
composition, negotiations with clients, etc.).
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"You will pay fees and costs
whether you make or lose money on your investments. Fees and costs will
reduce any amount of money you make on your investments over time. Please
make sure you understand what fees and costs you are paying.";
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Conversation
Starters. Ask
your financial professional—
·
{Help me understand how these fees and costs might
affect my investments. If I give you $10,000 to invest, how much will go to
fees and costs, and how much will be invested for me? }
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{"What are your legal obligations to me when providing
recommendations as my broker-dealer or when acting as my investment adviser?
How else does your firm make money and what conflicts of interest do you
have?"; }
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"When
we provide you with a recommendation at your broker-dealer or act as your
investment adviser, we have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates
some conflicts with your interests. You should understand and ask us about
these conflicts because they can affect the recommendations and investment
advice, we provide you." Here are some examples to help you understand
what this means."
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See - Disclosures, Fees and
Commissions – www.hhcminc.com (disclosures)
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Conversation Starters. Ask
your financial professional—
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{How might
your conflicts of interest affect me, and how will you address them?” }
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{How
do your financial professionals make money?}
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Hudson
Heritage Capital Management, Inc. bases its fees on a percentage of assets
under management, hourly charges, fixed fees (not including subscription
fees), subscription fees, and commissions.
Some Retainer
Agreements may be priced based on the complexity of work, especially when
asset management is not the most significant part of the relationship.
Financial plans are
priced according to the degree of complexity associated with the client’s
situation.
Fees are not negotiable.
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Item 4.
{Do
you or your financial professionals have legal or disciplinary history?} NO
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Hudson
Heritage Capital Management, Inc. and its employees have not been subject to
any disciplinary events brought by the SEC, FINRA or a court of Law. Hudson
Heritage Capital Management, Inc. and an advisory was subject to a court case
regarding the issuances of a Term Life Insurance Policy. The courts have
found no guilt are the part of Hudson Heritage Capital Management, Inc. or
its advisor.
Conversation
Starter. Ask your financial
professional—
·
{As a
financial professional, do you have any disciplinary history? For what type of conduct?}
See https://www.investor.gov/CRS
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Item 5.
{Additional
Information}
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For additional information about our services, If you would like additional,
up-to-date information or a copy of this disclosure, please call 914-271-8102.
Conversation
Starters. Ask
your financial professional—
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{Who is my
primary contact person? Is he or she a representative of an investment adviser
or a broker-dealer? Who can I talk to if I
have concerns about how this person is treating me?}
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