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F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U R E
Hudson Financial Services, Inc.
DBA
Vantage Financial Group
Office Address:
164 Maple St
Suite 1
Auburn, CA 95603
Tel: 530-906-1948
Email:
jess@vantageauburn.com
A P R I L 1 , 2 0 2 6
This brochure provides information about the qualifications and business practices of Vantage
Financial Group. Being registered as a registered investment adviser does not imply a certain level
of skill or training. If you have any questions about the contents of this brochure, please contact us
at 530-906-1948. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission, or by any state securities authority.
Additional information about Vantage Financial Group (CRD #309675) is available on the SEC’s
website at www.adviserinfo.sec.gov
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
This brochure will be amended anytime there is a material change and this section will
include a summary of material changes. Since the last filing of this brochure on March 11,
2026, the following has been updated:
• Brochure updated for SEC Registration.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm.
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Full Brochure Available .................................................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 5
Wrap Fee Programs ......................................................................................................................................................... 5
Client Assets under Management .............................................................................................................................. 5
Item 5: Fees and Compensation ....................................................................................................... 5
Method of Compensation and Fee Schedule .......................................................................................................... 5
Client Payment of Fees ................................................................................................................................................... 7
Additional Client Fees Charged ................................................................................................................................... 7
Prepayment of Client Fees ............................................................................................................................................ 8
External Compensation for the Sale of Securities to Clients ........................................................................... 8
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 8
Sharing of Capital Gains ................................................................................................................................................. 8
Item 7: Types of Clients ....................................................................................................................... 8
Description .......................................................................................................................................................................... 8
Account Minimums .......................................................................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 8
Methods of Analysis ......................................................................................................................................................... 8
Investment Strategy ........................................................................................................................................................ 9
Security Specific Material Risks .................................................................................................................................. 9
Item 9: Disciplinary Information ................................................................................................... 11
Criminal or Civil Actions ............................................................................................................................................. 11
Administrative Enforcement Proceedings .......................................................................................................... 12
Self- Regulatory Organization Enforcement Proceedings ............................................................................ 12
Item 10: Other Financial Industry Activities and Affiliations ............................................. 12
Broker-Dealer or Representative Registration ................................................................................................. 12
Futures or Commodity Registration ...................................................................................................................... 12
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 12
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 12
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ................................................................................................................................................... 12
Code of Ethics Description ......................................................................................................................................... 12
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 13
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 13
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest .................................................................................................................. 13
Item 12: Brokerage Practices ......................................................................................................... 14
Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 14
Aggregating Securities Transactions for Client Accounts ............................................................................. 15
Item 13: Review of Accounts ........................................................................................................... 15
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 15
Review of Client Accounts on Non-Periodic Basis ........................................................................................... 15
Content of Client Provided Reports and Frequency ........................................................................................ 15
Item 14: Client Referrals and Other Compensation ................................................................ 15
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 15
Advisory Firm Payments for Client Referrals .................................................................................................... 15
Item 15: Custody .................................................................................................................................. 16
Account Statements ...................................................................................................................................................... 16
Item 16: Investment Discretion ..................................................................................................... 16
Discretionary Authority for Trading...................................................................................................................... 16
Item 17: Voting Client Securities ................................................................................................... 16
Proxy Votes ...................................................................................................................................................................... 16
Item 18: Financial Information ...................................................................................................... 17
Balance Sheet .................................................................................................................................................................. 17
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 17
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 17
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 19
Principal Executive Officer – Jess Hudson ........................................................................................................... 19
Item 2 - Educational Background and Business Experience ....................................................................... 19
Item 3 - Disciplinary Information ........................................................................................................................... 19
Item 4 - Other Business Activities ........................................................................................................................... 20
Item 5 - Additional Compensation .......................................................................................................................... 20
Item 6 - Supervision ..................................................................................................................................................... 20
Item 4: Advisory Business
Firm Description
Vantage Financial Group (“Vantage”) was founded in 2019 and became registered in 2020.
Jess Hudson is 100% owner.
Types of Advisory Services
ASSET MANAGEMENT
Vantage offers discretionary asset management services to advisory Clients. Vantage will
offer Clients ongoing asset management services through determining
individual
investment goals, time horizons, objectives, and risk tolerance. Investment strategies,
investment selection, asset allocation, portfolio monitoring and the overall investment
program will be based on the above factors. The Client will authorize Vantage discretionary
authority to execute selected investment program transactions as stated within the
Investment Advisory Agreement. Vantage will put the Client’s interest first which includes,
but is not limited to, a duty of care, loyalty, obedience and good faith.
FINANCIAL PLANNING AND CONSULTING
If financial planning services are applicable, a comprehensive evaluation of an investor's
current and future financial state will be provided by using currently known variables to
predict future cash flows, asset values and withdrawal plans. Vantage will use current net
worth, tax liabilities, asset allocation, and future retirement and estate plans in developing
financial plans.
Single Consultation
Typical topics reviewed in a financial plan may include but are not limited to:
• Financial goals: Based on an individual's or a family's clearly defined financial
goals, including funding a college education for the children, buying a larger home,
starting a business, retiring on time or leaving a legacy. Financial goals should be
quantified and set to milestones for tracking.
• Personal net worth statement: A snapshot of assets and liabilities serves as a
benchmark for measuring progress towards financial goals.
• Cash flow analysis: An income and spending plan determines how much can be set
aside for debt repayment, savings and investing each month.
• Retirement strategy: A strategy for achieving retirement independent of other
financial priorities. Including a strategy for accumulating the required retirement
capital and its planned lifetime distribution.
• Comprehensive risk management plan: Identify all risk exposures and provide
the necessary coverage to protect the family and its assets against financial loss. The
risk management plan includes a full review of life and disability insurance,
personal liability coverage, property and casualty coverage, and catastrophic
coverage.
for selecting, buying and selling
• Long-term investment plan: Include a customized asset allocation strategy based
on specific investment objectives and a risk profile. This investment plan sets
guidelines
investments and establishing
benchmarks for performance review.
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• Tax reduction strategy: Identify ways to minimize taxes on personal income to the
extent permissible by the tax code. The strategy should include identification of tax-
favored investment vehicles that can reduce taxation of investment income.
• Estate preservation: Help update accounts, review beneficiaries for retirement
accounts and life insurance, provide a second look at your current estate planning
documents, and prompt you to update your plan when the legal environment
changes or you have major life events such as a marriage, death, or births.
Ongoing Consultations (Services not offered to clients residing in Washington State)
Ongoing consultations are different than the planning offered above in that the clients are
looking for ongoing support and services as opposed to creating a one-time plan. Ongoing
consultations consist of one or more of the items as described below:
• Retirement and insurance analysis: a review of retirement accounts and plans
including recommendations; a review of insurance policies and recommendations
for changes. With active monitoring of both.
• Budgeting/debt management: Provide budgeting and cash flow advice, to help
you understand the difference between good and bad debt, make sure you have
enough set aside for emergencies and special opportunities, and, if needed, help you
gain control over your spending.
When engaging in ongoing consultations a client can expect the following:
• Meet every quarter - in person or telephone. Includes but is not limited to the
following:
o coaching on budgeting and accountability
o review situation, ongoing coaching
o employee benefits review
o tax strategy review, review of assets held outside of RIA
If a conflict of interest exists between the interests of Vantage and the interests of the
Client, the Client is under no obligation to act upon Vantage’s recommendation. If the Client
elects to act on any of the recommendations, the Client is under no obligation to affect the
transaction through Vantage. Financial plans will be completed and delivered inside of
ninety (90) days contingent upon timely delivery of all required documentation.
ERISA PLAN SERVICES
Vantage provides service to qualified retirement plans including 401(k) plans, 403(b)
plans, pension and profit-sharing plans, cash balance plans, and deferred compensation
plans as either a 3(21) or 3(38) advisor:
Limited Scope ERISA 3(21) Fiduciary. Vantage may serve as a limited scope ERISA 3(21)
fiduciary that can advise, help and assist plan sponsors with their investment decisions. As
an investment advisor Vantage has a fiduciary duty to act in the best interest of the Client.
The plan sponsor is still ultimately responsible for the decisions made in their plan, though
using Vantage can help the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
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• Provide investment advice to the Client about asset classes and investment options
available for the Plan in accordance with the Plan’s investment policies and
objectives. Client will make the final decision regarding the initial selection,
retention, removal and addition of investment options. Vantage acknowledges that
it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan. Client shall have
the ultimate responsibility and authority to establish such policies and objectives
and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a
qualified default investment option for participants who are automatically enrolled
in the Plan or who have otherwise failed to make investment elections. The Client
retains the sole responsibility to provide all notices to the Plan participants required
under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the IPS and make recommendations to
maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information
and the investment options available to them under the Plan. Client understands
Vantage’s assistance in education of the Plan participants shall be consistent with
and within the scope of the Department of Labor’s definition of investment
education (Department of Labor Interpretive Bulletin 96-1). As such, Vantage is not
providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants.
Vantage will not provide investment advice concerning the prudence of any
investment option or combination of investment options for a particular participant
or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
Vantage may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Vantage and Client.
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3. Vantage has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to Vantage on the ERISA
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2
disclosure.
ERISA 3(38) Investment Manager. Vantage can also act as an ERISA 3(38) Investment
Manager in which it has discretionary management and control of a given retirement plan’s
assets. Vantage would then become solely responsible and liable for the selection,
monitoring and replacement of the plan’s investment options.
1. Fiduciary Services are:
• Vantage has discretionary authority and will make the final decision regarding the
initial selection, retention, removal and addition of investment options in
accordance with the Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent
with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment option for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5).
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information
and the investment options available to them under the Plan. Client understands the
Vantage’s assistance in education of the Plan participants shall be consistent with
and within the scope of the Department of Labor’s definition of investment
education (Department of Labor Interpretive Bulletin 96-1). As such, the Vantage is
not providing fiduciary advice as defined by ERISA to the Plan participants. Vantage
will not provide investment advice concerning the prudence of any investment
option or combination of investment options for a particular participant or
beneficiary under the Plan.
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• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
Vantage may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Vantage and Client.
3. Vantage has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2
disclosure.
SEMINARS AND WORKSHOPS
Vantage holds seminars and workshops to educate the public on different types of
investments and the different services they offer. The seminars are educational in nature
and no specific investment or tax advice is given.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities. Agreements may not be
assigned without written Client consent.
Wrap Fee Programs
Vantage does not sponsor any wrap fee programs.
Client Assets under Management
Vantage has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$118,000,000
$0
Date Calculated:
December 31, 2025
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
Vantage offers discretionary direct asset management services to advisory Clients. Lower
fees for comparable services may be available from other sources. Total fees to Client will
never exceed 2%. For California clients, that is below the California safe harbor threshold of
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3% of assets under management per year. Vantage charges an annual investment advisory
fee based on the total assets under management as follows:
Assets Under Management
All Assets
Maximum Annual Fee
2.00%
Monthly Fee
.166%
The annual fee is negotiable 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.). Fees are billed monthly in advance based on the amount of assets managed as
of the close of business on the last business day of the previous month. Lower fees for
comparable services may be available from other sources. Clients may terminate their
account within five (5) business days of signing the Investment Advisory Agreement with
no obligation and without penalty. After the initial five (5) business days, the agreement
may be terminated by Vantage with thirty (30) days written notice to Client and by the
Client at any time with written notice to Vantage. For accounts opened or closed mid-billing
period, fees will be prorated based on the days services are provided during the given
period. All unpaid earned fees will be due to Vantage. Additionally, all unearned fees will be
refunded to the Client. Client shall be given thirty (30) days prior written notice of any
increase in fees. Any increase in fees will be acknowledged in writing by both parties before
any increase in said fees occurs.
FINANCIAL PLANNING AND CONSULTING
Vantage charges either a one-time hourly fee or ongoing fixed fee for financial planning.
Prior to the planning process the Client will be provided an estimated plan fee. One-time
Services are completed and delivered inside of ninety (90) days contingent upon timely
delivery of all required documentation. Ongoing services will remain in effect year over
year unless cancelled in writing by either party by giving the other party thirty (30) days
written notice.
Client may cancel within five (5) business days of signing Agreement with no obligation
and without penalty. If the Client cancels after five (5) business days, any unearned fees
will be refunded to the Client, or any unpaid earned fees will be due to Vantage. If Client
cancels before the financial plan is completed, the Client will receive all completed portions
of the plan along with the prorated refund/invoice. Vantage reserves the right to waive the
fee should the Client implement the plan through Vantage. Fees for financial planning will
be offset for related advisory services of the assets being managed by Vantage.
ONE-TIME HOURLY FEES
Services are offered based on a non-negotiable hourly fee of $250 per hour. Fees are
due upon delivery of the completed plan.
ONGOING FIXED FEES (Service not offered to clients residing in Washington State)
Services are offered based on an annual flat fee charged quarterly and in arrears,
based on an annual rate of up to $10,000.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed
0.50%. The annual fee is negotiable and may be charged as a percentage of the Included
Assets or as a flat fee. Fees may be charged quarterly or monthly in arrears or in advance
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based on the assets as calculated by the custodian or record keeper of the Included Assets
(without adjustments for anticipated withdrawals by Plan participants or other anticipated
or scheduled transfers or distribution of assets). If the services to be provided start any
time other than the first day of a quarter or month, the fee will be prorated based on the
number of days remaining in the quarter or month. If this Agreement is terminated prior to
the end of the billing cycle, Vantage shall be entitled to a prorated fee based on the number
of days during the fee period services were provided or Client will be due a prorated refund
of fees for days services were not provided in the billing cycle.
The fee schedule, which includes compensation of Vantage for the services is described in
detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees,
however the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or
have fees deducted from Plan Assets. Vantage does not reasonably expect to receive any
additional compensation, directly or indirectly, for its services under this Agreement. If
additional compensation is received, Vantage will disclose this compensation, the services
rendered, and the payer of compensation. Vantage will offset the compensation against the
fees agreed upon under the Agreement
SEMINARS AND WORKSHOPS
Vantage holds seminars and workshops to educate the public on different types of
investments and the different services they offer. The seminars are educational in nature
and no specific investment or tax advice is given. Vantage does not charge a fee for
attendance to these seminars.
Client Payment of Fees
Fees for asset management services are:
• Deducted from a designated Client account. The Client must consent in advance to
direct debiting of their investment account.
• Check – to be remitted by Client to Vantage
• Deducted from a non-qualified account managed by Vantage
Fees for all financial planning will be billed:
• Check – to be remitted by Client to Vantage. Fees are due upon delivery of the
completed plan for the one-time service. Fees for ongoing financial planning are
charged quarterly in arrears.
• Electronic Payment via Venmo or Zelle (fees will be paid via a third party payment
processor in which the client will securely input payment information and pay the
advisory fee through a secure portal. Vantage will not have access to the Client’s
banking information.)
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds. These charges may include mutual fund transaction
fees, postage and handling and miscellaneous fees. For more details on the brokerage
practices, see Item 12 of this brochure.
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Prepayment of Client Fees
Vantage does not require any prepayment of fees of more than $1,200 per Client and six
months or more in advance.
Investment management fees are billed monthly in advance.
Fees for ERISA 3(21) and/or 3(38) services may be billed in advance.
If the Client cancels after five (5) business days, any unearned fees will be refunded to the
Client, or any unpaid earned fees will be due to Vantage.
External Compensation for the Sale of Securities to Clients
Investment Advisor Representatives of Vantage receive external compensation from sales
of investment related products such as insurance as licensed insurance agents (Insurance
services will not be solicited in the state of Oregon). This represents a conflict of interest
because it gives an incentive to recommend products based on the commission received.
This conflict is mitigated by disclosures, procedures, and Vantage’s fiduciary obligation to
place the best interest of the Client first and Clients are not required to purchase any
products or services. Vantage will put the client’s interests first which includes, but is not
limited to, a duty of care, loyalty, obedience and good faith. Clients have the option to
purchase these products through another insurance agent of their choosing.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
Vantage does not use a performance-based fee structure because of the conflict of interest.
Performance based compensation may create an incentive for Vantage to recommend an
investment that may carry a higher degree of risk to the Client.
Item 7: Types of Clients
Description
Vantage generally provides investment advice to individuals, high net worth individuals,
corporations and business entities. Client relationships vary in scope and length of service.
Account Minimums
Vantage does not require a minimum to open an account.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include fundamental analysis and technical analysis.
Investing in securities involves risk of loss that Clients should be prepared to bear. Past
performance is not a guarantee of future returns. Investing in securities involves risk of
loss that clients should be prepared to bear.
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Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is that
the market will fail to reach expectations of perceived value.
Technical analysis attempts to predict a future stock price or direction based on market
trends. The assumption is that the market follows discernible patterns and if these patterns
can be identified then a prediction can be made. The risk is that markets do not always
follow patterns and relying solely on this method may not take into account new patterns
that emerge over time.
In developing a financial plan for a Client, Vantage’s analysis may include cash flow
analysis, investment planning, risk management, tax planning and estate planning. Based
on the information gathered, a detailed strategy is tailored to the Client’s specific situation.
The main sources of information include financial newspapers and magazines, annual
reports, prospectuses, and filings with the Securities and Exchange Commission.
Investment Strategy
The investment strategy for a specific Client is based upon the objectives stated by the
Client during consultations. The Client may change these objectives at any time by
providing written notice to Vantage. Each Client executes a Client profile form or similar
form that documents their objectives and their desired investment strategy.
Other strategies may include long-term purchases, short-term purchases, trading, and
option writing (including covered options, uncovered options or spreading strategies).
Security Specific Material Risks
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following investment
risks and should discuss these risks with Vantage:
• Market Risk: The prices of securities in which Clients invest may decline in response
to certain events taking place around the world, including those directly involving
the companies whose securities are owned by a fund; conditions affecting the
general economy; overall market changes; local, regional or global political, social or
economic instability; and currency, interest rate and commodity price fluctuations.
Investors should have a long-term perspective and be able to tolerate potentially
sharp declines in market value.
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become
less attractive, causing their market values to decline.
•
Inflation Risk: When any type of inflation is present, a dollar today will buy more
than a dollar next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also
referred to as exchange rate risk.
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• Reinvestment Risk: This is the risk that future proceeds from investments may have
to be reinvested at a potentially lower rate of return (i.e. interest rate). This
primarily relates to fixed income securities.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties
are not.
• Management Risk: The advisor’s investment approach may fail to produce the
intended results. If the advisor’s assumptions regarding the performance of a
specific asset class or fund are not realized in the expected time frame, the overall
performance of the Client’s portfolio may suffer.
• Equity Risk: Equity securities tend to be more volatile than other investment choices.
The value of an individual mutual fund or ETF can be more volatile than the market
as a whole. This volatility affects the value of the Client’s overall portfolio. Small-
and mid-cap companies are subject to additional risks. Smaller companies may
experience greater volatility, higher failure rates, more limited markets, product
lines, financial resources, and less management experience than larger companies.
Smaller companies may also have a
lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in
response to selling pressure than is the case with larger companies.
• Fixed Income Risk: The issuer of a fixed income security may not be able to make
interest and principal payments when due. Generally, the lower the credit rating of a
security, the greater the risk that the issuer will default on its obligation. If a rating
agency gives a debt security a lower rating, the value of the debt security will
decline because investors will demand a higher rate of return. As nominal interest
rates rise, the value of fixed income securities held by a fund is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
•
Investment Companies Risk: When a Client invests in open end mutual funds or ETFs,
the Client indirectly bears their proportionate share of any fees and expenses
payable directly by those funds. Therefore, the Client will incur higher expenses,
which may be duplicative. In addition, the Client’s overall portfolio may be affected
by losses of an underlying fund and the level of risk arising from the investment
practices of an underlying fund (such as the use of derivatives). ETFs are also
subject to the following risks: (i) an ETF’s shares may trade at a market price that is
above or below their net asset value or (ii) trading of an ETF’s shares may be halted
if the listing exchange’s officials deem such action appropriate, the shares are de-
listed from the exchange, or the activation of market-wide “circuit breakers” (which
are tied to large decreases in stock prices) halts stock trading generally. Adviser has
no control over the risks taken by the underlying funds in which Client invests.
• REIT Risk: To the extent that a Client invests in REITs, it is subject to risks generally
associated with investing in real estate, such as (i) possible declines in the value of
real estate, (ii) adverse general and local economic conditions, (iii) possible lack of
availability of mortgage funds, (iv) changes in interest rates, and (v) environmental
- 10 -
problems. In addition, REITs are subject to certain other risks related specifically to
their structure and focus such as: dependency upon management skills; limited
diversification; the risks of locating and managing financing for projects; heavy cash
flow dependency; possible default by borrowers; the costs and potential losses of
self-liquidation of one or more holdings; the possibility of failing to maintain
exemptions from securities registration; and, in many cases, relatively small market
capitalization, which may result in less market liquidity and greater price volatility.
• Derivatives Risk: Funds in a Client’s portfolio may use derivative instruments. The
value of these derivative instruments derives from the value of an underlying asset,
currency or index. Investments by a fund in such underlying funds may involve the
risk that the value of the underlying fund’s derivatives may rise or fall more rapidly
than other investments, and the risk that an underlying fund may lose more than the
amount that it invested in the derivative instrument in the first place. Derivative
instruments also involve the risk that other parties to the derivative contract may
fail to meet their obligations, which could cause losses.
• Long-term purchases: Long-term investments are those vehicles purchased with the
intension of being held for more than one year. Typically, the expectation of the
investment is to increase in value so that it can eventually be sold for a profit. In
addition, there may be an expectation for the investment to provide income. One of
the biggest risks associated with long-term investments is volatility, the fluctuations
in the financial markets that can cause investments to lose value.
• Short-term purchases: Short-term investments are typically held for one year or less.
Generally, there is not a high expectation for a return or an increase in value.
Typically, short-term investments are purchased for the relatively greater degree of
principal protection they are designed to provide. Short-term investment vehicles
may be subject to purchasing power risk — the risk that your investment’s return
will not keep up with inflation.
• Trading risk: Investing involves risk, including possible loss of principal. There is no
assurance that the investment objective of any fund or investment will be achieved.
• Options Trading: The risks involved with trading options are that they are very time
sensitive investments. An options contract is generally a few months. The buyer of
an option could lose his or her entire investment even with a correct prediction
about the direction and magnitude of a particular price change if the price change
does not occur in the relevant time period (i.e., before the option expires).
Additionally, options are less tangible than some other investments. An option is a
“book-entry” only investment without a paper certificate of ownership.
Item 9: Disciplinary Information
Criminal or Civil Actions
Vantage and its management have not been involved in any criminal or civil action.
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Administrative Enforcement Proceedings
Vantage and its management have not been involved in administrative enforcement
proceedings.
Self- Regulatory Organization Enforcement Proceedings
Vantage and its management have not been involved in legal or disciplinary events that are
material to a Client’s or prospective Client’s evaluation of Vantage or the integrity of its
management.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Vantage is not registered as a broker-dealer and no affiliated representatives of Vantage
are registered representatives of a broker-dealer.
Futures or Commodity Registration
Neither Vantage nor its affiliated representatives are registered or have an application
pending to register as a futures commission merchant, commodity pool operator, or a
commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Investment Advisor Representatives of Vantage receive external compensation from sales
of investment related products such as insurance as licensed insurance agents (Insurance
services will not be solicited in the state of Oregon). This represents a conflict of interest
because it gives an incentive to recommend products based on the commission received.
This conflict is mitigated by disclosures, procedures, and Vantage’s fiduciary obligation to
place the best interest of the Client first and Clients are not required to purchase any
products or services. Clients have the option to purchase these products through another
insurance agent of their choosing.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
Vantage does not select or recommend other investment advisors.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
include employees and/or
independent
The affiliated persons (affiliated persons
contractors) of Vantage have committed to a Code of Ethics (“Code”). The purpose of our
Code is to set forth standards of conduct expected of Vantage affiliated persons and
addresses conflicts that may arise. The Code defines acceptable behavior for affiliated
persons of Vantage. The Code reflects Vantage and its supervised persons’ responsibility to
act in the best interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for
their personal accounts and how to mitigate any conflict of interest with our Clients. We do
not allow any affiliated persons to use non-public material information for their personal
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profit or to use internal research for their personal benefit in conflict with the benefit to
our Clients.
Vantage’s policy prohibits any person from acting upon or otherwise misusing non-public
or inside information. No advisory representative or other affiliated person, officer or
director of Vantage may recommend any transaction in a security or its derivative to
advisory Clients or engage in personal securities transactions for a security or its
derivatives if the advisory representative possesses material, non-public information
regarding the security.
Vantage’s Code is based on the guiding principle that the interests of the Client are our top
priority. Vantage’s officers, directors, advisors, and other affiliated persons have a fiduciary
duty to our Clients and must diligently perform that duty to maintain the complete trust
and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s
interests over the interests of either affiliated persons or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have
access to non-public information regarding any Clients' purchase or sale of securities, or
non-public information regarding the portfolio holdings of any reportable fund, who are
involved in making securities recommendations to Clients, or who have access to such
recommendations that are non-public.
Vantage will provide a copy of the Code of Ethics to any Client or prospective Client upon
request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
Vantage and its affiliated persons do not recommend to Clients securities in which we have
a material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
Vantage and its affiliated persons may buy or sell securities that are also held by Clients. In
order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated
persons are required to disclose all reportable securities transactions as well as provide
Vantage with copies of their brokerage statements.
The Chief Compliance Officer of Vantage is Jess Hudson. He reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over associated persons’ transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
Vantage does not maintain a firm proprietary trading account and does not have a material
financial interest in any securities being recommended and therefore no conflicts of
interest exist. However, affiliated persons may buy or sell securities at the same time they
buy or sell securities for Clients. In order to mitigate conflicts of interest such as front
running, affiliated persons are required to disclose all reportable securities transactions as
well as provide Vantage with copies of their brokerage statements.
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The Chief Compliance Officer of Vantage is Jess Hudson. He reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over associated persons’ transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
Vantage will recommend the use of a particular broker-dealer based on their duty to seek
best execution for the client, meaning they have an obligation to obtain the most favorable
terms for a client under the circumstances. The determination of what may constitute best
execution and price in the execution of a securities transaction by a broker involves a
number of considerations and is subjective. Factors affecting brokerage selection include
the overall direct net economic result to the portfolios, the efficiency with which the
transaction is affected, the ability to effect the transaction where a large block is involved,
the operational facilities of the broker-dealer, the value of an ongoing relationship with
such broker and the financial strength and stability of the broker. Vantage will select
appropriate brokers based on a number of factors including but not limited to their
relatively low transaction fees and reporting ability. Vantage relies on its broker to provide
its execution services at the best prices available. Lower fees for comparable services may
be available from other sources. Clients pay for any and all custodial fees in addition to the
advisory fee charged by Vantage. Vantage does not receive any portion of the trading fees.
Vantage will recommend the use of Charles Schwab & Co., Inc.
Directed Brokerage
In circumstances where a Client directs Vantage to use a certain broker-dealer,
Vantage still has a fiduciary duty to its Clients. The following may apply with
Directed Brokerage: Vantage's inability to negotiate commissions, to obtain volume
discounts, there may be a disparity in commission charges among Clients and
conflicts of interest arising from brokerage firm referrals. The firm may be unable to
achieve most favorable execution of client transactions, and this practice may cost
clients more money.
• Brokerage for Client Referrals
Vantage does not receive client referrals from any custodian or third party in
exchange for using that broker-dealer or third party.
• Best Execution
Investment advisors who manage or supervise Client portfolios have a fiduciary
obligation of best execution. The determination of what may constitute best
execution and price in the execution of a securities transaction by a broker involves
a number of considerations and is subjective. Factors affecting brokerage selection
include the overall direct net economic result to the portfolios, the efficiency with
which the transaction is effected, the ability to affect the transaction where a large
block is involved, the operational facilities of the broker-dealer, the value of an
ongoing relationship with such broker and the financial strength and stability of the
broker. Vantage does not receive any portion of the trading fees.
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• Soft Dollar Arrangements
Vantage does not receive soft dollar benefits.
• Brokerage for Client Referrals
Vantage does not receive client referrals from any custodian or third party in
exchange for using that broker-dealer or third party.
Aggregating Securities Transactions for Client Accounts
Vantage manages each account separately, and therefore, does not aggregate purchases
and sales and other transactions. If orders are not aggregated, some clients purchasing
securities around the same time may receive a less favorable price than other clients which
may cost clients more money.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed quarterly by the Chief Compliance Officer of Vantage, Jess
Hudson. Account reviews are performed more frequently when market conditions dictate.
Reviews of Client accounts include, but are not limited to, a review of Client documented
risk tolerance, adherence to account objectives, investment time horizon, and suitability
criteria, reviewing target bans of each asset class to identify if there is an opportunity for
rebalancing, and reviewing accounts for tax loss harvesting opportunities.
Financial plans generated are updated as requested by the Client and pursuant to a new or
amended agreement, Vantage suggests updating at least annually.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation.
Content of Client Provided Reports and Frequency
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by Vantage’s custodian. Client receives confirmations of
each transaction in account from Custodian and an additional quarterly statement for the
quarter in which a transaction occurs.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest
Vantage does not receive any economic benefits from external sources.
Advisory Firm Payments for Client Referrals
Vantage does not compensate for Client referrals.
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Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to Clients at their address of record at least quarterly. Clients are urged
to compare the account statements received directly from their custodians to any
documentation or reports prepared by Vantage.
Vantage is deemed to have limited custody solely because advisory fees are directly
deducted from Client’s accounts by the custodian on behalf of Vantage.
If Vantage is authorized or permitted to deduct fees directly from the accounts by the
custodian:
• Vantage will provide the Client with an invoice concurrent to instructing the
custodian to deduct the fee stating the amount of the fee, the formula used to
calculate the fee, the amount of assets under management the fee is based on and
the time period covered by the fee;
• Vantage will obtain written authorization signed by the Client allowing the fees to
be deducted; and
• The Client will receive quarterly statements directly from the custodian which
disclose the fees deducted.
Item 16: Investment Discretion
Discretionary Authority for Trading
Vantage requires discretionary authority to manage securities accounts on behalf of
Clients. Vantage has the authority to determine, without obtaining specific Client consent,
the securities to be bought or sold, and the amount of the securities to be bought or sold.
Vantage allows Client’s to place certain restrictions, as outlined in the Client’s Investment
Policy Statement or similar document. Such restrictions could include only allowing
purchases of socially conscious investments. These restrictions must be provided to
Vantage in writing.
The Client approves the custodian to be used and the commission rates paid to the
custodian. Vantage does not receive any portion of the transaction fees or commissions
paid by the Client to the custodian.
Item 17: Voting Client Securities
Proxy Votes
Vantage does not vote proxies on securities. Clients are expected to vote their own proxies.
The Client will receive their proxies directly from the custodian of their account or from a
transfer agent.
When assistance on voting proxies is requested, Vantage will provide recommendations to
the Client. If a conflict of interest exists, it will be disclosed to the Client.
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Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because Vantage does not serve as a
custodian for Client funds or securities and Vantage does not require prepayment of fees of
more than $1,200 per Client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
Vantage has no condition that is reasonably likely to impair our ability to meet contractual
commitments to our Clients.
Bankruptcy Petitions during the Past Ten Years
Vantage has not had any bankruptcy petitions in the last ten years.
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Item 1 Cover Page
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Jess Hudson
Hudson Financial Services, Inc.
DBA
Vantage Financial Group
Office Address:
164 Maple St
Suite 1
Auburn, CA 95603
Tel: 530-906-1948
Email:
jess@vantageauburn.com
This brochure supplement provides information about Jess Hudson and supplements the Vantage
Financial Group brochure. You should have received a copy of that brochure. Please contact Jess
Hudson if you did not receive the brochure or if you have any questions about the contents of this
supplement.
A P R I L 1 , 2 0 2 6
Additional information about Jess Hudson (CRD# 5676030) is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer – Jess Hudson
• Year of birth: 1979
Item 2 - Educational Background and Business Experience
Educational Background:
• California State University Sacramento; BS Business; 2003
Business Experience:
• Hudson Financial Services, Inc. DBA Vantage Financial Group; Managing
Member/Investment Advisor Representative; 06/2020 – Present
• Cambridge Investment Research Advisors, Inc.; Investment Advisor Representative;
07/2017 – 06/2020
• MKB Financial Services; Office Manager; 03/2009 – 12/2017
Item 3 - Disciplinary Information
A. Mr. Hudson has never been involved in a criminal or civil action in a domestic,
foreign or military court of competent jurisdiction for which he:
1. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any
felony; (b) misdemeanor that involved investments or an investment-related
business, fraud, false statement or omissions, wrongful taking of property,
bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any
of these offenses;
2. Is the named subject of a pending criminal proceeding that involves an
investment-related business, fraud, false statements or omissions, wrongful
taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a
conspiracy to commit any of these offenses;
3. Was found to have been involved in a violation of an investment-related statute
or regulation; or
4. Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order.
B. Mr. Hudson never had an administrative proceeding before the SEC, any other
federal regulatory agency, any state regulatory agency, or any foreign financial
regulatory authority in which he:
1. Was found to have caused an investment-related business to
lose its
authorization to do business; or the subject of an order by the agency or
authority;
2. Was found to have been involved in a violation of an investment-related statute
or regulation or was the subject of an order by the agency or authority
(a)denying, suspending or revoking the authorization of the supervised person
to act in an investment-related business; (b) barring or suspending his
association with an investment-related business; (c) otherwise significantly
limiting his investment-related activities; or (d) imposing a civil money penalty
of more than $2,500 on him.
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C. Mr. Hudson has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
1. Was found to have caused an investment-related business to
lose its
authorization to do business; or
2. Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members
or was expelled from membership; (b) otherwise significantly limited from
investment-related activities; or (c) fined more than $2,500.
D. Mr. Hudson has not been involved in any other hearing or formal adjudication in
which a professional attainment, designation, or license of the supervised person
was revoked or suspended because of a violation of rules relating to professional
conduct.
Item 4 - Other Business Activities
Mr. Hudson has no other business activities besides Vantage Financial Group.
Item 5 - Additional Compensation
Mr. Hudson does not receive any additional compensation for performing advisory services
other than what is disclosed in Item 5 of Part 2A.
Item 6 - Supervision
Since Mr. Hudson is the sole owner and Chief Compliance Officer of Vantage, he is solely
responsible for all supervision and formulation and monitoring of investment advice
offered to Clients. He will adhere to the policies and procedures as described in the firm’s
Compliance Manual. He can be reached at jess@vantageauburn.com or 530-906-1948.
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