Municipal Commentary by Tom Kozlik

Anonymous Reporting Hotline

Reporting of Policy Violations
You may become aware of a situation or be confronted with a transaction that raises a concern of whether it complies with proper business, accounting or compliance practices. If you witness theft, fraud, dishonesty, harassment, unethical behavior or improper accounting practices, we strongly encourage you to report any such activity to our General Counsel at the headquarters address. Complaints of policy violations will be promptly and carefully investigated.

If you are uncomfortable reporting to the General Counsel, HTS provides a third party, anonymous ethics and compliance hotline which provides a confidential channel for anyone to alert us to errors and wrongdoings, via online or by telephone.

The hotline is accessible 24 hours a day, 365 days a year.

To submit an anonymous report by telephone

Call the toll free hotline number, 1.800-461.9330
Provide the company name: Hilltop Holdings
A trained operator will guide you through a series of questions.
When responding to the operator, use as much factual detail as possible about the incident(s), including time(s), location(s) and the person or people involved.

To submit an anonymous report online

Go to www.MySafeWorkplace.com
Click on "Make a Report OnLine Now" button
Enter "Hilltop Holdings" in the Organization Search box and press the Search button
Select "Hilltop Holdings" from the dropdown menu and press the Next button
Follow the instructions to submit your report. Use as much factual detail as possible about the incident(s), including time(s), location(s) and the person or people involved.

Disclosures

Hilltop Securities Inc.