Gilman Hill Asset Management, LLC

Item 1 Cover Page GILMAN HILL ASSET MANAGEMENT, LLC 220 Elm Street New Canaan, CT 06840 (203) 571-0225 www.gilmanhill.com February 12, 2026 This brochure provides information about the qualifications and business practices of Gilman Hill Asset Management, LLC. If you have any questions about the contents of this brochure, please contact us at (203) 571-0225 or john.harrington@gilmanhill.com. 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 Gilman Hill Asset Management, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site using our firm name or CRD number to obtain information about our registration and filings.  Item 2 Material Changes The changes from Gilman Hill Asset Management, LLC’s (GHAM) prior submission include updating the firm’s regulatory assets under management as of December 31, 2025 in Item 4. In addition, GHAM has revised certain disclosures relating to wrap fee programs, model portfolio arrangements, brokerage practices, custody (including standing letters of authorization), and related compensation and conflict of interest language. No material changes have been made to the firm’s ownership, management, or core investment strategy. The material changes discussed above are only those changes that have been made to this brochure since the firm’s last annual update of the brochure. The date of the last annual update of the brochure was February 5, 2025. Gilman Hill Asset Management, LLC Page 2  Item 3 Table of Contents Brochure Item 3 Table of Contents ..................................................................................................................... 3 Item 4 Advisory Business ................................................................................................................... 4 Item 5 Fees and Compensation ........................................................................................................... 6 Item 6 Performance-Based Fees and Side-by-Side Management ....................................................... 8 Item 7 Types of Clients ....................................................................................................................... 9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 9 Item 9 Disciplinary Information ....................................................................................................... 11 Item 10 Other Financial Industry Activities and Affiliations ............................................................. 11 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading......... 12 Item 12 Brokerage Practices ............................................................................................................... 14 Item 13 Review of Accounts ............................................................................................................... 16 Item 14 Client Referrals and Other Compensation ............................................................................. 17 Item 15 Custody .................................................................................................................................. 17 Item 16 Investment Discretion ............................................................................................................ 18 Item 17 Voting Client Securities ......................................................................................................... 18 Item 18 Financial Information ............................................................................................................ 19 Item 19 Requirements for State-Registered Advisers ......................................................................... 19 Gilman Hill Asset Management, LLC Page 3  Item 4 Advisory Business A. Describe your advisory firm, including how long it has been in business. Identify your principal owner(s). Gilman Hill Asset Management, LLC is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) since June 5, 2007. The Principal Owner of Gilman Hill Asset Management, LLC is: Jenny Van Leeuwen Harrington, Chief Executive Officer 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") provides investment advisory services, primarily on a discretionary basis, for asset-based fees to individuals, high net worth individuals, trusts, estates, charitable organizations, retirement plans (including governmental pension plans), corporations, and other business entities. As a registered investment adviser, GHAM is a fiduciary to its clients. In this capacity, the firm has a duty of care and a duty of loyalty and is obligated to act in the best interest of its clients at all times. GHAM provides ongoing portfolio management services tailored to each client’s investment objectives, risk tolerance, time horizon, liquidity needs, tax considerations, and overall financial circumstances. Services include: • Asset allocation design • Security selection • Ongoing monitoring and review of portfolios • Rebalancing as appropriate • Coordination with a client’s other professional advisers when requested GHAM primarily employs fundamental, research-driven equity investment strategies focused on publicly traded securities. Portfolios are generally constructed using long-only equity and fixed income securities and may also include exchange-traded funds (“ETFs”), mutual funds, and cash equivalents where appropriate. The use of short sales or other complex instruments is not a core component of GHAM’s strategy and, if utilized, would be used only in a manner consistent with a client’s objectives and risk tolerance. Certain clients may independently elect to utilize margin accounts with their custodian. Gilman Hill Asset Management, LLC Page 4  Although GHAM primarily focuses on publicly traded equity and fixed income securities, its advice is not limited to a predefined list of securities or product sponsors. investment advisers. Under GHAM also participates in third-party wrap fee programs sponsored by broker-dealers or other these arrangements, GHAM provides portfolio management services pursuant to either a dual-contract arrangement with the client and sponsor, or as a sub-adviser to the program sponsor. GHAM may also provide model portfolios to certain sponsors or platforms. In such cases, GHAM licenses model strategies to the sponsor or platform, and the sponsor or another adviser may retain trading discretion and implementation authority. GHAM receives compensation from the sponsor, platform, or directly from client accounts pursuant to applicable advisory agreements, as further described in Item 5. 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 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 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. 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 does currently provide portfolio management services to wrap fee programs. GHAM 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 receives compensation for providing portfolio management services. Additionally, GHAM provides model portfolios to Janney Montgomery Scott LLC (“JMS”) and Vestmark Advisory Solutions, Inc. (“VAS”), for wrap fee programs available through JMS. As a result, GHAM receives model fees from JMS and VAS. GHAM does not have discretionary authority to trade these models nor is GHAM compensated directly from the underlying accounts invested in the models. Gilman Hill Asset Management, LLC Page 5  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 manages client assets, and as of December 31, 2025, has the following assets under management: Discretionary assets: $1,244,139,379 Non-discretionary assets: $ 0 Item 5 Fees and Compensation A. Describe how the firm is compensated for its advisory services. Provide the fee schedule. Disclose whether the fees are negotiable. Describe whether the firm deducts fees from clients’ assets or bills client for fees incurred. Explain how often firm bills clients or deducts its fee. Standard Advisory Fees GHAM is compensated for its advisory services through asset-based fees calculated as a percentage of assets under management. For separately managed accounts, GHAM’s maximum annual investment management fee does not exceed 1% of assets under management. Wrap fee program and model portfolio compensation arrangements are described separately below. Advisory fees are calculated based on the value of assets under management as reflected in GHAM’s accounting records. For certain clients, as specified in the applicable investment management agreement, fees may instead be calculated based on account valuation data provided by the client’s custodian. Valuations are determined in accordance with the terms of the client’s investment management agreement and are generally based on market values for publicly traded securities. Fees are generally billed quarterly, either in advance or in arrears as specified in the client’s investment management agreement, and in most cases are deducted from client accounts pursuant to written authorization. In addition, clients are 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 such custodial and transaction- related charges. Fee schedules are negotiable and may vary based on account size, complexity, and scope of services. Clients may terminate their investment management agreement with GHAM, in whole or in part, upon written notice. Upon termination, any investment management fees paid in advance will be prorated through the date of termination and any unearned portion will be Gilman Hill Asset Management, LLC Page 6  refunded to the client. Fees billed in arrears will be similarly prorated through the termination date and either deducted from the account or billed to the client, as applicable. Wrap Fee Programs In wrap fee programs, clients pay a single fee to the program sponsor, which generally covers advisory services, custody, and transaction costs. The sponsor pays GHAM a portion of the wrap fee for providing advisory services. In certain wrap arrangements, GHAM may be compensated directly from client accounts pursuant to applicable advisory agreements. Because transaction costs are included in the wrap fee, clients may pay more or less than they would in a non-wrap arrangement depending on trading activity. GHAM does not recommend wrap programs to clients based on the compensation it receives. However, GHAM has a financial incentive to maintain relationships with sponsors that compensate it for advisory services. GHAM addresses this potential conflict through disclosure and by managing client accounts in a manner it believes is consistent with its fiduciary duty. Model Portfolio Compensation GHAM may license model portfolios to third-party sponsors or platforms and receive compensation from the sponsor or platform in connection with such arrangements. In these cases, GHAM does not typically retain trading discretion over the underlying accounts unless separately engaged, and GHAM does not direct client assets to such platforms. These arrangements create a financial incentive for GHAM to maintain or expand relationships with sponsors or platforms that compensate it for access to its investment models. GHAM addresses this potential conflict through disclosure and by structuring such arrangements independently from its direct client advisory relationships. B. Describe any other types of fees or expenses clients may pay in connection with firm’s advisory services, such as custodian fees or mutual fund expenses. Disclose that clients will incur brokerage and other transaction costs, and direct clients to the section(s) of your brochure that discuss brokerage. GHAM provides investment advisory services and portfolio management services, but does not provide custodial or other administrative services, except as relates to GHAM’s contractual ability to authorize the deduction of investment management fees from certain accounts, or by virtue of certain authorizations that allow GHAM to submit transfer instructions pursuant to standing letters of authorization established by the client with the qualified custodian. Clients are responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer. The investment management fee paid to GHAM is separate and distinct from the custodian and execution fees. Gilman Hill Asset Management, LLC Page 7  Clients whose portfolios hold American Depository Receipts, foreign securities or currencies, or mutual funds, exchange traded funds, or other such pooled investment vehicles may also incur expenses associated with these investments, and such fees or expenses are the sole responsibility of the client, and are not included in the investment management fee. Also, see the response to Item 12A, below, for additional information on brokerage. C. If the firm’s clients either may or must pay your fees in advance, disclose this fact. Explain how a client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period. Explain how you will determine the amount of the refund. In the instances where GHAM’s management fee is payable in advance, upon termination, any fees paid in advance will be prorated to the date of termination and any excess will be refunded to client. D. If the firm or any of its supervised persons accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds, disclose this fact. Neither GHAM nor any of its supervised persons accepts compensation for the sale of securities or other investment products, or asset-based sales charges or service fees from the sale of mutual funds. Item 6 Performance-Based Fees and Side-by-Side Management A. If the firm or any of its supervised persons accepts performance-based fees, that is, fees based on a share of capital gains on or capital appreciation of the assets of a client, disclose this fact. If the firm or any of its supervised persons manages both accounts that are charged a performance-based fee and accounts that are charged another type of fee, such as an hourly or flat fee or asset-based fee, disclose this fact. At present, GHAM does not manage any accounts that are charged a performance-based fee. Gilman Hill Asset Management, LLC Page 8  Item 7 Types of Clients A. Describe the types of clients to whom the firm generally provides investment advice, such as individuals, trusts, investment companies or pension plans. If the firm has any requirements for opening or maintaining an account, such as a minimum account size, disclose the requirements. GHAM provides advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations, retirement plans (including governmental pension plans), corporations, and other business entities. The firm has a stated minimum initial investment of $2,000,000 for each client relationship, although this minimum may be waived at the discretion of GHAM. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss A. Describe the methods of analysis and investment strategies you use in formulating investment advice or managing assets. For all investment strategies, GHAM’s investment professionals conduct ongoing analysis of both current and potential holdings. From a top-down perspective, the team monitors and acts upon macro changes that have repercussions for the portfolio. From the bottom-up, they assess and respond to changes that impact the valuation, growth potential or dividend yield of the companies that are held or are being actively researched. While the majority of the security level research is conducted internally, as a boutique firm, GHAM also reviews third- party research in forming its investment views. As such, the firm maintains relationships with various research providers and incorporates publicly available and third-party research into its investment decision-making process. To implement its investment strategies, GHAM most frequently effects long term purchases of securities, and, where appropriate, shorter-term purchases consistent with client objectives. Infrequently, and only where permitted by the client, the firm may engage in shorter-term trading or short sales. Certain clients may independently elect to utilize margin accounts with their custodian. Investing in securities involves risk, including the risk of loss of principal. Equity securities are subject to market risk, company-specific risk, and sector or concentration risk. Fixed income securities are subject to interest rate risk, credit risk, and liquidity risk. Gilman Hill Asset Management, LLC Page 9  B. For each significant investment strategy or method of analysis the firm uses, explain the material risks involved. If the method of analysis or strategy involves significant or unusual risks, discuss the risks in detail. If the firm’s primary strategy involves frequent trading of securities, explain how frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. The methods of analysis and the investment strategies described in Item 8A, above, are utilized, to varying degrees, across all of GHAM’s client accounts. The client should be aware that with any trading that occurs in the client account, the client may incur transaction and administrative costs which would have an impact on investment performance. Investments with GHAM are subject to all risks generally associated with investing in equities, fixed income and currency. Prices for securities held may move up and down, sometimes rapidly, and investing in these asset classes carries the risk that some or all of the principal investment may be lost. Market volatility, political issues, taxation issues and liquidity represent only a few of the risks to which the client’s investment may be exposed. In addition, there are unique risks associated with investing in small capitalization securities, as well as securities and currencies of foreign issuers. In light of these various risks, it is generally advisable that a client diversify their investments across a range of asset classes and strategies as a means of controlling risk. Clients are encouraged by GHAM to consult with a financial advisor or planner to determine an appropriate asset allocation plan to best reflect their individual objectives, needs and risk tolerances. For certain client relationships in which GHAM manages more than one strategy for a client, GHAM may provide such asset allocation services as a component of its investment management responsibilities. Certain clients may independently elect to establish margin accounts with their custodian. GHAM does not require or routinely recommend the use of margin as part of its investment strategy. The use of margin increases investment risk because it magnifies both gains and losses. Clients who utilize margin may lose more than the amount invested in securities purchased on margin, and custodians may require the liquidation of securities if account equity falls below required levels. The use of short sales, options, or other complex instruments is not a core component of GHAM’s strategy and, if utilized, would be limited and consistent with a client’s objectives and risk tolerance. Past performance is not indicative of future results, and there can be no assurance that any investment strategy will achieve its objectives. C. If the firm recommends primarily a particular type of security, explain the material risks involved. If the type of security involves significant or unusual risks, discuss these risks in detail. GHAM primarily recommends publicly traded equity and fixed income securities. The material risks associated with these investments are described in Item 8B above and include, Gilman Hill Asset Management, LLC Page 10  among others, market risk, company-specific risk, sector and concentration risk, interest rate risk, credit risk, liquidity risk, and risks associated with small capitalization and foreign securities. Equity securities are subject to fluctuations in value based on general market conditions, economic developments, and factors affecting specific issuers. Fixed income securities are subject to risks associated with changes in interest rates, issuer creditworthiness, and market liquidity. Clients should understand that investments in these securities may result in the loss of some or all of the principal invested. Item 9 Disciplinary Information A. If there are legal or disciplinary events that are material to a client’s or prospective client’s evaluation of the firm’s advisory business or the integrity of the firm’s management, disclose all material facts regarding those events. GHAM has no legal or disciplinary events to disclose. Item 10 Other Financial Industry Activities and Affiliations A. If the firm or any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer, disclose this fact. Neither GHAM nor any of its management persons are registered as a representative of a broker-dealer or have an application pending to register as a broker-dealer. B. If the firm or any of its management persons are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities, disclose this fact. Neither GHAM nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Gilman Hill Asset Management, LLC Page 11  C. Describe any relationship or arrangement that is material to the firm’s advisory business or to your clients that the firm or any of its management persons have with any related person listed below. Identify the related person and if the relationship or arrangement creates a material conflict of interest with clients, describe the nature of the conflict and how you address it. GHAM manages accounts on behalf of other investment advisers on a dual contract and sub- advisory basis, and participates in certain wrap fee program and model portfolio arrangements as described in Items 4 and 5. GHAM receives compensation from program sponsors or platforms in connection with such arrangements. These relationships create a financial incentive for GHAM to maintain or expand such relationships. GHAM addresses this potential conflict through disclosure and by managing client accounts in a manner consistent with its fiduciary duty. At present, GHAM maintains relationships with AGW Capital Advisors, &Wealth Partners, Charney Investment Group, Dakota Wealth, The Dowling Group, Essex Financial Services, Janney Montgomery Scott, LLC, MAI Capital Management LLC, Morgan Stanley, Principle Wealth Partners, Raymond James, RBC, Tred Avon Family Wealth, Uhlmann Price Securities, Wells Fargo, WMS Partners, and Xponance, Inc. whereby GHAM has been retained to manage client accounts or investment models either as a sub-advisor or on a dual- contract basis. All such agreements are disclosed by GHAM at the time that the Investment Management Agreement is entered into by delivery to the client of GHAM’s Brochure. GHAM may receive a portion of the advisory or wrap fee paid by clients to such firms. D. If firm recommends or selects other investment advisers for its clients and receives compensation directly or indirectly from those advisers that creates a material conflict of interest, or if the firm has other business relationships with those advisers that create a material conflict of interest, describe these practices and discuss the material conflicts of interest these practices create and how you address them. GHAM does not recommend or select other investment advisors for clients, nor does it have other business relationships with advisors that could represent a conflict of interests. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. If the firm is an SEC-registered advisor, briefly describe your code of ethics adopted pursuant to SEC rule 204A-1 or similar state rules. Explain that you will provide a copy of your code of ethics to any client or prospective client upon request. GHAM has adopted and rigorously enforces a Code of Ethics that sets forth the basic policies of ethical conduct for all employees of the advisor. In addition, the Code of Ethics governs personal trading by each employee of GHAM and is intended to ensure that securities transactions effected by employees of GHAM are conducted in a manner that avoids any actual or potential conflict of interest between such persons and clients of the advisor. In Gilman Hill Asset Management, LLC Page 12  addition to requiring pre-approval of all personal trading of reportable securities, GHAM collects and maintains records of securities holdings and securities transactions effected by all employees and conducts thorough post-trade reviews to ensure that no intended or unintended breach of the employee trading policy or conflict of interest has occurred. A copy of GHAM’s Code of Ethics is available to clients and prospects upon request. B. If firm or its related persons recommends to clients, or buys or sells for client accounts, securities in which the firm or a related person has a material financial interest, describe the firm’s practice and discuss the conflicts of interest it presents. Describe generally how you address conflicts that arise. As an independent investment advisor with no proprietary firm trading, GHAM has no material financial interests in securities in which clients might invest. With respect to its employees, GHAM requires that all employees disclose to the firm any involvement or material financial interest that might represent a potential conflict of interest between the individual and the firm’s clients. If the activities or financial interests of any employee should be deemed to pose a conflict of interest by virtue of GHAM’s desire to invest in a security in which an employee is involved or has a material financial interest, the employee would be instructed to eliminate their involvement or financial interest, or the affected clients would be informed of the potential conflict prior to GHAM’s purchase of the security on behalf of a client. C. If the firm or a related person invests in the same securities (or related securities, e.g., warrants, options or futures) that the firm or a related person recommends to clients, describe the firm’s practice and discuss the conflicts of interest this presents and generally how the firm addresses the conflicts that arise in connection with personal trading. GHAM members can be expected, in many cases, to buy for themselves those securities that they are buying on behalf of their clients. The firm and its employees acknowledge that they have a fiduciary duty to put the interests of their clients ahead of their own, and to fulfill this responsibility, GHAM has adopted and rigorously enforces a Code of Ethics that establishes basic policies and ethical standards for all employees. Among other things, the Code of Ethics governs personal trading by each employee of GHAM. The objective of the firm’s policies on personal trading is to ensure that securities transactions effected by employees of GHAM are conducted in a manner that mitigates any conflict of interest between such persons and clients of the advisor. Specifically, employees are required to submit personal trades to certain designated individuals for approval in advance of effecting a transaction in their personal accounts. In most cases, the trading of a security in a personal account is prohibited on the day in which a transaction is effected in the security on behalf of a client. In addition, GHAM collects and maintains records of securities holdings and securities transactions effected by employees of the firm. These records are reviewed by the Chief Compliance Officer on a quarterly basis to ensure that there have been no conflicts, either Gilman Hill Asset Management, LLC Page 13  intended or unintended, between employee and client trading. GHAM’s Code of Ethics is available upon request. D. If the firm or related person recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that the firm or related person buys or sells the same securities for your own account, describe the firm’s practice and discuss the conflicts of interest it presents. Describe generally how you address conflicts that arise. See the response to Item 11C, above. Item 12 Brokerage Practices A. Describe the factors the firm considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g. commissions). As a registered investment advisor, GHAM has a fiduciary duty to seek best execution for client transactions. While GHAM seeks competitive commission rates, the lowest possible commission cost may not always represent the best qualitative execution. In selecting broker- dealers to execute transactions, GHAM considers a variety of factors, including, but not limited to, the ability of the broker to execute the transaction at hand quickly and efficiently with minimal market impact, the commission rate charged, the quality, the clearance and settlement capabilities of the broker selected, the broker’s transaction confirmation and account statement practices, and the research services provided. Other factors that may be considered include the financial strength of the broker, the broker’s responsiveness and ability to service GHAM and its clients, and the frequency of trading errors. GHAM LLC’s Investment Committee reviews brokers on at least an annual basis to ensure that transactions are directed in a manner that will provide the most benefit to the firm’s clients and makes changes to the firm’s broker roster as necessary with this objective in mind. B. Research and Other Soft Dollar Benefits. If the firm receives research or other products or services other than execution from a broker-dealer or a third party in connection with client securities transactions (“soft dollar benefits”), disclose the firm’s practices and discuss the conflicts of interest they create. GHAM may receive research products and services from broker-dealers in connection with client transactions. Such research may include investment research reports, market data, analytical tools, and other information that assists GHAM in managing client accounts. Research products and services are generally made available to brokerage clients and are not provided pursuant to contractual soft dollar arrangements. Gilman Hill Asset Management, LLC Page 14  GHAM does not enter into agreements that require the direction of a specified amount of brokerage commissions in exchange for research products or services. To the extent research is received in connection with brokerage activity, it may qualify under the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934. The receipt of research products or services creates a potential conflict of interest because GHAM has an incentive to select broker-dealers that provide such benefits. GHAM addresses this potential conflict by seeking best execution for client transactions and by evaluating broker- dealers based on the overall quality of execution and services provided. C. Brokerage for Client Referrals. If the firm considers, in selecting or recommending broker-dealers, whether the firm or a related person receives client referrals from a broker-dealer or third party, disclose this practice and discuss the conflicts of interest it creates. Neither GHAM nor any related person receives client referrals from any broker-dealer or third party as a result of the firm selecting or recommending that broker-dealer to clients. D. Directed Brokerage. If the firm routinely recommends, requests or requires that a client direct you to execute transactions through a specified broker-dealer, describe the firm’s practice or policy. Although GHAM uses a range of brokers to execute transactions on behalf of its clients, the firm typically recommends that its clients select a specific broker for primary execution and custodial services, unless otherwise directed by the client. The broker-dealer is recommended based on criteria such as, but not limited to, reasonableness of commissions charged to the client, tools and services made available to the client and GHAM, and convenience of access to the account for trading and reporting. It is disclosed that, from time to time, and when not prohibited by the client, GHAM may determine that it is beneficial to the client for GHAM to place trades with a broker other than that which the client has selected for primary execution and custodial services. In such cases, the client may incur additional transaction charges associated with trading securities away from the primary broker. If GHAM is directed by a client to direct trades to a specific broker dealer, it is disclosed that the firm’s ability to negotiate commissions (where applicable), obtain volume discounts, or otherwise obtain best execution may not be maximized. Gilman Hill Asset Management, LLC Page 15  E. Discuss whether and under what conditions you aggregate the purchase and sale of securities for various client accounts. If you do not aggregate orders when you have the opportunity to do so, explain your practice and describe the costs to clients of not aggregating. GHAM seeks to aggregate orders when possible and allocates trades in a manner it believes to be fair and equitable. Accounts that are unable to participate in block trades due to specific client restrictions may receive separate executions. Item 13 Review of Accounts A. Indicate whether your firm periodically reviews client accounts or financial plans. If you do, describe the frequency and nature of the review and the titles of the supervised persons who conduct the review. All accounts are monitored and reviewed by a Portfolio Manager of GHAM on an ongoing basis. Reviews consider portfolio holdings, performance, and alignment with the client’s stated investment objectives. In addition, in instances where more than one account is managed on behalf of a client, a Portfolio Manager who has been designated as the primary relationship manager for the client will have additional ongoing oversight responsibility for the client’s overall relationship with GHAM. In addition, GHAM reviews clients’ accounts when the firm becomes aware of a change in a client’s investment objectives, investment guidelines, risk tolerance, employment status, marital status or other relevant information, when market conditions appear to be undergoing a significant change, when portfolios experience a significant cash flow, or when portfolios require rebalancing from an asset allocation standpoint. Portfolios are also reviewed annually to verify suitability of investment and adherence to guidelines, based, in part, on the information received from each client as part of the firm’s Client Information Form. B. If the firm reviews client accounts on other than a periodic basis, describe the factors that trigger a review. See the response to Item 13A, above. C. Describe the content and indicate the frequency of regular reports the firm provides to clients regarding their accounts. State whether these reports are written. All clients receive monthly or quarterly holdings and transaction statements from their qualified custodian. In addition, each discretionary client receives from GHAM a monthly or quarterly report or letter discussing the investment environment, investment activity, and investment performance of the strategy in which they are invested. Customized reporting is available as necessary. Gilman Hill Asset Management, LLC Page 16  Item 14 Client Referrals and Other Compensation A. If someone who is not a client provides an economic benefit to the firm for providing investment advice or other advisory services to your clients, generally describe the arrangement, explain the conflicts of interest, and describe how the firm addresses the conflicts of interest. For purposes of this Item, economic benefits include any sales awards or other prizes. GHAM does not compensate third parties for client referrals. B. If the firm or a related person directly or indirectly compensates any person who is not a supervised person for client referrals, describe the arrangement and the compensation. GHAM does not currently have any such arrangements in place. Item 15 Custody A. If the firm has custody of client funds or securities and a qualified custodian sends quarterly, or more frequent, account statements directly to clients, explain that clients will receive account statements from the broker-dealer, bank or other qualified custodian and that clients should carefully review those statements. Client assets are maintained at qualified custodians selected by the client. GHAM does not take physical possession of client funds or securities. GHAM is deemed to have custody of client assets solely as a result of (i) its authority to deduct advisory fees from client accounts pursuant to written authorization and (ii) in certain circumstances, its authority to transfer client funds to third parties pursuant to standing letters of authorization (“SLOAs”) established by the client with the qualified custodian. GHAM does not have the authority to designate or change third-party payees or addresses. Transfers pursuant to SLOAs are effected by the qualified custodian in accordance with client instructions and custodial procedures. GHAM complies with the conditions set forth in the SEC staff’s February 21, 2017 no-action letter regarding custody and standing letters of authorization. Accordingly, GHAM is not subject to the annual surprise examination requirement solely as a result of such SLOA authority. Clients receive account statements directly from their qualified custodians and are urged to carefully review such statements and compare them to any reports provided by GHAM. Gilman Hill Asset Management, LLC Page 17  Item 16 Investment Discretion A. If the firm accepts discretionary authority to manage securities accounts on behalf of clients, disclose this fact and describe any limitations clients may (or customarily do) place on this authority. Describe the procedures you follow before you assume this authority (e.g., execution of a power of attorney). GHAM typically manages client accounts on a discretionary basis pursuant to authority granted in the client’s investment management agreement. Discretionary authority permits GHAM to determine the securities to be purchased or sold, the amount of securities to be purchased or sold, and the timing of transactions. Item 17 Voting Client Securities A. If the firm has, or will accept authority to vote client securities, briefly describe the voting policies and procedures, including those adopted pursuant to SEC rule 206(4)-6 and the applicable state securities rules. GHAM has adopted written Proxy Voting Policies and Procedures designed to ensure that proxies are voted in the best interest of clients and in accordance with applicable fiduciary standards and SEC Rule 206(4)-6 under the Investment Advisers Act of 1940. Unless otherwise agreed in writing, GHAM has authority to vote proxies for client accounts over which it exercises discretionary investment authority. In certain instances, clients may retain proxy voting authority or provide specific instructions regarding proxy matters. In carrying out its proxy voting responsibilities, GHAM may utilize the services of Institutional Shareholder Services Inc. (“ISS”) to assist in research, administrative processing, and vote execution. ISS provides research reports and voting recommendations based on guidelines selected by GHAM. While GHAM may consider ISS recommendations, GHAM retains ultimate responsibility and authority for proxy voting decisions and oversight of the proxy voting process. GHAM’s Proxy Voting Policies and Procedures are designed to address potential conflicts of interest. If a material conflict of interest arises between GHAM and a client in connection with a proxy vote, GHAM will take appropriate steps to ensure the vote is cast in the client’s best interest, which may include following an independent third-party recommendation or other procedures described in its policies. Clients may obtain information regarding how GHAM voted proxies for their account by submitting a written request. A copy of GHAM’s Proxy Voting Policies and Procedures is also available upon request. Gilman Hill Asset Management, LLC Page 18  B. If the firm does not have authority to vote client securities, disclose this fact. Explain whether clients will receive their proxies or other solicitations directly from their custodian or a transfer agent or from you and discuss whether (and, if so, how) clients can contact you with questions about a particular solicitation. GHAM votes proxies on behalf of clients unless the client retains such authority or designates another party. Where clients prefer that proxies be voted by themselves or by another designated party, proxies will be issued to the designated individual by the client’s custodian or by a transfer agent, rather than by GHAM. For all clients who elect not to have GHAM vote proxies on their behalf, GHAM is available to discuss the firm’s voting stance on any portfolio holding. Item 18 Financial Information A. If the firm requires or solicits prepayment of more than $1,200 in fees per client, six months or more in advance, include a balance sheet for your most recent fiscal year. GHAM does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance and is not required to provide audited financial statements. B. If firm has discretionary authority or custody of client funds or securities, or firm requires or solicits prepayment of more than $1,200 in fees per client, six months or more in advance, disclose any financial condition that is reasonably likely to impair your ability to meet contractual commitments to clients. GHAM has discretionary authority over client accounts and is not aware of any financial condition that is likely to impair its ability to meet contractual commitments to clients. If GHAM does become aware of any such financial condition, this brochure will be updated and clients will be notified. C. If firm has been the subject of a bankruptcy petition at any time during the past ten years, disclose this fact, the date the petition was first brought and the current status. Not applicable to GHAM. Item 19 Requirements for State-Registered Advisers GHAM is registered with the Securities and Exchange Commission (SEC) and therefore is not subject to this Item. Gilman Hill Asset Management, LLC Page 19