A. Describe your advisory firm, including how long it has been in business. Identify your principal owner(s). Gilman Hill Asset Management, LLC is a registered investment advisory firm, registered with the SEC securities regulators as of June 5, 2007. The Principal Owner of Gilman Hill Asset Management, LLC is: Jenny Van Leeuwen Harrington, Chief Executive Officer Gilman Hill Asset Management, LLC Page 5 B. Describe the types of advisory services the firm offers. If the firm holds itself out as specializing in a particular type of advisory service, explain the nature of that service in detail. If the firm provides investment advice only with respect to limited types of investments, explain the type of investment advice firm offers and disclose that the advice is limited to those types of investments. Gilman Hill Asset Management, LLC ("GHAM, LLC") provides fee-based, separate account and model- based investment advisory services, primarily within the Equity Income, International Income, Disciplined Growth, Real Estate Equity and Balanced account disciplines. At no time will GHAM, LLC accept or maintain custody of a client’s funds or securities, except as relates to GHAM, LLC’s contractual ability to authorize the deduction of investment management fees from certain accounts or by virtue of certain authorizations that allow GHAM, LLC to facilitate the movement of funds on behalf of clients. When GHAM, LLC provides investment advice to you regarding your retirement plan account or individual retirement account, GHAM, LLC are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way GHAM, LLC makes money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. As a fiduciary, GHAM, LLC must provide advice in the “Best Interest” of the Retirement Investor; charge “reasonable” compensation for the services provided to you; and, not make misleading statements about investment transactions, compensation, and conflicts of interest. Pursuant to an Investment Management Agreement contract signed by each client, the client pays GHAM, LLC a monthly or quarterly Investment Management Fee, payable in advance or in arrears, as negotiated with each client, based on the amount of the assets managed on behalf of the client by GHAM, LLC, and computed based on the valuation of these assets as of the close of the most recent month or quarter. The asset value upon which the Investment Management Fee is based is taken from GHAM, LLC’s accounting system, other than in instances where the client requires it to be based on account value data from its custodian. The following Management Fees are the maximum that can be charged by GHAM, LLC, and are negotiable downward at the discretion of GHAM, LLC: For all assets in a separate account, the maximum annual charge, payable quarterly, is 1% of all assets. In most cases, and where allowed by contract, Investment Management Fees will be automatically deducted from the client

account on a quarterly basis by the custodian. In addition, the client is responsible for all custodial and securities execution fees charged by the custodian and executing broker- dealer. The Investment Management Fee is separate and distinct from the custodian and execution fees. Clients may request to terminate their advisory contract with GHAM, LLC, in whole or in part, by providing written notice. Upon termination, any fees paid in advance will be prorated to the date of termination and any excess will be refunded to client. Any fees due in arrears will be similarly prorated to the date of termination, and will be billed to the client. The client’s Investment Management Agreement with GHAM, LLC is non-transferable without the client’s written approval. Gilman Hill Asset Management, LLC Page 6 C. Explain whether (and, if so, how) the firm tailors advisory services to the individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. GHAM, LLC tailors its advisory services to its clients’ individual needs, guidelines and objectives based on a written client profile, and information gleaned in conversations and meetings with the prospect or client. If clients wish to impose restrictions on investing in certain securities or types of securities, GHAM, LLC will make a determination as to whether the investment strategy remains suitable for the client in light of the potential impact of the proposed restrictions. Gilman Hill Asset Management, LLC Page 7 D. If the firm participates in wrap fee programs by providing portfolio management services, (1) describe the differences, if any, between how the firm manages wrap fee accounts and how it manages other accounts, and (2) explain that the firm receives a portion of the wrap fee for its services. GHAM, LLC does currently provide portfolio management services to wrap fee programs on a dual- contract basis. GHAM, LLC applies the same investment philosophy, process and discipline to the management of both wrap fee accounts and accounts that do not participate in a wrap fee program within a given investment strategy. GHAM, LLC receives compensation for providing portfolio management services. Additionally, GHAM, LLC provides model portfolios to Janney Montgomery Scott LLC (“JMS”) and Vestmark Advisory Solutions, Inc. (“VAS”) the Sponsor of wrap fee programs available through JMS. As a result, GHAM, LLC receives model fees from JMS and VAS. GHAM, LLC does not have discretionary authority to trade these models nor is GHAM, LLC compensated directly from the underlying accounts invested in the models. E. If the firm manages client assets, disclose the amount of client assets it manages on a discretionary basis and the amount of client assets on a non-discretionary basis. Disclose the date “as of” which it calculated the amounts. GHAM, LLC manages client assets, and as of December 31, 2022, has the following assets under management: Discretionary assets: $622,826,298 Non-discretionary assets: $ 230,929