Municipal Commentary by Tom Kozlik

Hilltop Securities Inc. Privacy Policy

At Hilltop Securities Inc. (HTS), we are committed to pro-tecting your privacy and the confidentiality of your personal and financial information. The measures we take to keep your personal information private and secure are outlined below.

HTS has multiple affiliates, including Momentum Independent Network Inc., Southwest Insurance Agency, Inc., Hilltop Securities Asset Management, LLC, PrimeLending, Inc. and Plains Capital Bank. These companies, along with HTS Inc., are wholly owned subsidiaries of Hilltop Holdings Inc., a financial holding company whose stock is listed on the New York Stock Exchange under the ticker symbol HTH. Since the affiliates are all part of one corporate family, they work with one another and may work together to service your financial needs. The sharing of your information among our affiliates enables us to serve you more efficiently and makes it more convenient for you to do business with us. We are permitted by law to share information with our affiliates about your account history and your experiences with us. All of our affiliates follow similar privacy policies.

How We Protect Confidentiality

HTS uses procedural, physical and electronic system safe-guards to store and secure information about you in compli-ance with federal standards. Our systems protect your in-formation from unauthorized access, alteration, and destruc-tion. Access is permitted only to those individuals within our organization who need the information to perform their job responsibilities.

When we enter into agreements with other companies to provide services to us or to make products and services available to you, we include a confidentiality clause. Under such an agreement, these companies may receive infor-mation about you, but they may only use it for the intended purpose - to benefit you.

Persons Covered by the Privacy Policy

The HTS’ Privacy Policy applies to anyone who is a current or former HTS brokerage or investment advisory client or who registers with one of our services or promotional of-fers. We provide you with a copy of this policy when you open an account, and we send you annual notifications thereafter. If we change our policy regarding the sharing of information, we will notify you in advance and give you the opportunity to "opt out" of such disclosure.

How We Obtain Information About You

In the normal course of business, we collect, retain and use information about you to serve your financial needs, admin-ister your account(s) and inform you of products and ser-vices that may be of interest. This data, known as non-public personal information, may be collected from several sources, including: applications and other forms you file with us (e.g., name, assets, income), records of transactions with us, our affiliates, non-affiliated third parties and others (e.g., credit report). Because we strive to provide you with the best possible service, the accuracy and completeness of your personal information is important to us. We ask that you review your information regularly to ensure that it is correct. Please contact your financial professional or HTS directly if you need to correct or update your personal in-formation.

Sharing Information-With Whom and Why

HTS does not sell your personal information to anyone. We restrict the types of information we share and the types of entities with whom we share it. The primary reason for shar-ing information about you is to increase your convenience in transacting business with us and to give you more finan-cial service choices.

We do not disclose your personal information to non-affiliated third parties, unless one of the following excep-tions applies: (1) We disclose personal information to ser-vice providers that assist us in processing your transactions or servicing your account(s). An example would be the company that prints and mails your account statement. (2) We disclose or report personal information in limited cir-cumstances when we believe in good faith that disclosure is required or permitted under law. For example, we would provide information in cooperation with securities regula-tors or law enforcement authorities, to resolve consumer disputes, or to perform credit evaluations and authenticate checks.

Internet Security

We do not retrieve account or personal information from visitors who browse the public areas of our website. Clients who have the ability to access their accounts online are required to log on to our secure websites with their user name and individually selected password. Your password is known solely to you and should never be shared with any-one. Each time you access your account, please log off when you are finished. This will prevent someone else from accessing your account if you leave your computer unattended.

HTS employees use information about you to respond to your needs and to provide you with information about spe-cific products in which you may have an interest. We in-struct our employees to use strict standards of care in han-dling the personal, confidential information of customers and remind them on a regular basis of their obligations with regard to the confidentiality of customer information.

Option to Opt Out and Change Notices

If for any reason at any time in the future, we find it necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change and the opportunity to opt out of such disclosure. For your reference, this Privacy Policy has been posted at www.hilltopsecurities.com. If you have questions or concerns, please contact us via email at info@hilltopsecurities.com.

Revised 07/14/2020

Disclosures

Hilltop Securities Inc.