Hudson Trading Group LLC

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Fees

        Total Assets Under Management          Annual Fees
        All Assets                             Up to 2.00%

The advisory fee is calculated using the value of the assets in the Account on the last
business day of the prior billing period.

These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of HTGL's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract generally
with 30 days' written notice.

Performance-Based Fees for Portfolio Management

Qualified clients will pay an annual fee of 1.00% of assets under management along with
a 20.00% performance fee based on capital appreciation. If the client's portfolio rises in
value, the client will pay 20.00% on that increase in value, but if the portfolio drops in
value, the client will not incur a new performance fee until the portfolio reaches the last
highest value, adjusted for withdrawals and deposits, which is generally known as a “high
water mark.”

The high-water mark will be the highest value of the client’s account on the last day of
any previous year, after accounting for the client’s deposits or withdrawals for each billing
period.

These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. This service may be canceled with 30 days’ notice. Clients
must pay the prorated performance-based fees for the billing period in which they
terminate the Investment Advisory Contract up to and including the day of termination.

B. Payment of Fees

Payment of Portfolio Management Fees

Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a quarterly basis. Fees are paid in advance.

Payment of Performance-Based Portfolio Management Fees

Performance-based portfolio management fees are withdrawn directly from the client's
accounts with client's written authorization on a quarterly basis. Fees are paid in arrears.

C. Client Responsibility For Third Party Fees

Clients are responsible for the payment of all third party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by HTGL. Please see Item 12 of this brochure
regarding broker-dealer/custodian.

D. Prepayment of Fees

HTGL collects certain fees in advance and certain fees in arrears, as indicated above.
Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis
and returned within fourteen days to the client via check, or return deposit back into the
client’s account.

       For all asset-based fees paid in advance, the fee refunded will be equal to the balance of
       the fees collected in advance minus the daily rate* times the number of days elapsed in
       the billing period up to and including the day of termination. (*The daily rate is calculated
       by dividing the annual asset-based fee rate by 365.)

       E. Outside Compensation For the Sale of Securities to Clients

       Neither HTGL nor its supervised persons accept any compensation for the sale of
       investment products, including asset-based sales charges or service fees from the sale of
       mutual funds.

Item 7: Types of Clients

HTGL generally provides advisory services to the following types of clients:

           ❖   Individuals
           ❖   High-Net-Worth Individuals
           ❖   Corporations or Business Entities
           ❖   Pooled Investment Vehicles

There is no account minimum for any of HTGL’s services.