Hudson Canyon Capital Management LLC

Item 5 – Fees and Compensation

In addition to the information provided in Item 4 – Advisory Business, this section provides additional
details regarding our firm’s services along with descriptions of each service’s fees and compensation
arrangements.

Hudson Canyon Capital Management, LLC believes that its annual fee is reasonable in relation to: (1)
services provided and (2) the fees charged by other investment advisers offering similar
services/programs. However, our annual investment advisory fee may be higher than that charged by
other investment advisers offering similar services/programs.

The exact fees and other terms will be outlined in the agreement between each client and Hudson
Canyon Capital Management, LLC.

Asset Management Services

Fees for our asset management services are charged based on a percentage of assets under
management, billed in advance (at the start of the billing period) on a quarterly calendar basis and
calculated based on the fair market value of your account as of the last business day of the previous
billing period.

Fees are prorated (based on the number of days service is provided during the initial billing period) for
your account opened at any time other than the beginning of the billing period. If asset management
services are commenced in the middle of the billing period, then the prorated fee for that billing period is
based on the value of the Account when services commence and is due immediately and will be charged
when services commence.

Fees charged for our asset management services are negotiable based on the type of client, the
complexity of the client's situation, the composition of the client's account (i.e., equities versus fixed
income portfolios), and the total amount of assets under management for the client. The following
represents our standard or typical fee schedule. Some clients may receive a lower annual fee than what
is listed below. The minimum annual fee we charge is .25% annually.

                                             All Equity Accounts

                                First $20,000,000                        .75%
                                $20,000,001 to $30,000,000               .65%
                                Above $30,000,001                        .55%

                                              Balanced Accounts

                                First $20,000,000                        .60%
                                $20,000,001 to $30,000,000               .55%
                                Above $30,000,001                        .45%

Our services continue in effect until terminated. You may terminate services by providing Hudson
Canyon Capital Management, LLC with notice. Hudson Canyon Capital Management, LLC may terminate
the services by providing you with written notice effective 30 days after you receive the written notice.
Any prepaid, unearned fees will be promptly refunded by Hudson Canyon Capital Management, LLC to

Hudson Canyon Capital Management, LLC               Page 6                       Form ADV Part 2A Firm Brochure

you. Fee refunds will be determined on a pro rata basis using the number of days services are actually
provided during the final period.

You will pay our firm upon receipt of a billing notice sent directly to you. The billing notice will detail the
formula used to calculate the fee, the assets under management and the time period covered. Fees for
our services will be due immediately upon receipt of the billing notice.

Brokerage commissions, transaction ticket fees, and other expenses charged by the qualified custodian
are billed directly to you by the qualified custodian. Hudson Canyon Capital Management, LLC does not
receive any portion of such commissions or fees from you or the qualified custodian. The only form of
compensation we receive is the management fee as detailed above.

Item 7 – Types of Clients

Hudson Canyon Capital Management, LLC generally provides investment advice to the following types of
clients:

    •   Labor Unions including Taft-Hartley Plans
    •   Union Retirement Plans
    •   Corporations
    •   Corporate Pension and Profit Sharing Plans

You are required to execute a written agreement with Hudson Canyon Capital Management, LLC
specifying the particular advisory services in order to establish a client arrangement with Hudson Canyon
Capital Management, LLC.

Minimum Investment Amounts Required

There are no minimum investment amounts or conditions required for establishing an account managed
by Hudson Canyon Capital Management, LLC.