MA-A 0001614752 XXXXXXXX Michael Armstrong 813-280-1002 marmstrong@hamlinadvisors.com sioannidis@hamlinadvisors.com 12-31-2025 Y Hamlin Capital Advisors, LLC 45-4335680 866-01216-00 867-00279 5550 WEST EXECUTIVE DR. SUITE 235 TAMPA FL 33609 813-280-1000 N http://www.hamlinadvisors.com Michael Christopher Armstrong

5550 West Executive Dr. Suite 235 Tampa FL 33609

813-280-1000 marmstrong@hamlinadvisors.com Sharon McComas Ioannidis

5550 West Executive Dr. Suite 235 Tampa FL 33609

813-280-1000 sioannidis@hamlinadvisors.com Add Hamlin Capital Management, LLC 640 Fifth Avenue, 11th floor New York NY 10019 212-752-8777 212-752-5698 financial records, including checking account records, bank statements, and cash reconciliations Hamlin Capital Management, LLC Y U.S. SEC 801-60945 December DE 01-18-2012 N 3 3 0 0 0 20 Municipal Entities Non-profit organizations Corporations or other businesses 0 0 0 Not Applicable Fixed Fees Contingent Fees Not Applicable Advice Insurance Of MS Advice Use Of MD Advice On Selection Other Other activities may include, but are not limited to, financial aspects of strategic planning exercises, financial aspects of a new project plan, and debt capacity studies. N Investment Adviser 2 Add Investment Adviser Joseph J. Bridy Hamlin Capital Management LLC Y N N Add Investment Adviser Mark Stitzer Hamlin Capital Management, LLC Y N N N N N Y Y N Y Y Y N Y N N N N N N N N Y N Y Y N N N N N N N N N N N N N N N Y Y Hamlin Capital Advisors Holdings LLC N 46-2209603 Managing Member 02-01-2012 D Y DEBORAH, ANNE FINEGAN Member 02-01-2012 A Y 1737965 CHARLES STEDMAN GARLAND Member 02-01-2012 A Y 1587640 CHRISTOPHER MICHAEL DAGNES Member 02-01-2012 NA Y 3265978 Michael Christopher Armstrong Chief Compliance Officer / Principal 01-01-2015 B Y 000000000 Paul Towell Towell Principal 01-01-2015 B Y 000000000 Hamlin Capital Advisors Holdings LLC Mark NMN Stitzer Member 02-01-2012 C Y 1205027 Hamlin Capital Advisors Holdings LLC JOSEPH JOHN BRIDY Member 02-01-2012 C Y 4342660 Hamlin Capital Advisors Holdings LLC N 46-2209603 Managing Member 02-01-2012 D Y DEBORAH, ANNE FINEGAN Member 02-01-2012 A Y 1737965 CHARLES STEDMAN GARLAND Member 02-01-2012 A Y 1587640 CHRISTOPHER MICHAEL DAGNES Member 02-01-2012 NA Y 3265978 Michael Christopher Armstrong Chief Compliance Officer / Principal 01-01-2015 B Y 000000000 Paul Towell Towell Principal 01-01-2015 B Y 000000000 Hamlin Capital Advisors Holdings LLC Mark NMN Stitzer Member 02-01-2012 C Y 1205027 Hamlin Capital Advisors Holdings LLC JOSEPH JOHN BRIDY Member 02-01-2012 C Y 4342660 1 9-C2 9-C4 SECURITIES AND EXCHANGE COMMISSION ADMINISTRATIVE PROCEEDING 3-22274 100 F Street NE, Mail Stop 1090 Washington DC 20549 The Securities and Exchange Commission today charged that Hamlin Capital Advisors LLC and its associated person and Michael Braun failed to timely and fully disclose material conflicts of interest and engaged in related violations including violations of MSRB rules and that Hamlin Capital Advisors LLC breached its fiduciary duty with respect to its disclosure violations. Hamlin Capital Advisors LLC and Braun agreed to settle the charges without admitting or denying the SECs findings. 10-24-2024 Cease and Desist Censure CivilAdminPenaltyFine Debt - Municipal The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted against Hamlin Capital Advisors, LLC (Hamlin Advisors) and Michael Ferrell Braun (together, Respondents). In anticipation of the institution of these proceedings, Respondents have submitted Offers of Settlement which the Commission has determined to accept. The Commission finds that this matter concerns failures to timely and fully disclose material conflicts of interest and related violations by Hamlin Advisors, a registered municipal advisor, and its associated person and Managing Director, Braun, including violations of various Municipal Securities Rulemaking Board ("MSRB") rules by each Respondent, and related breaches of fiduciary duty by Hamlin Advisors with respect to its disclosure violations. From September 2017 to at least April 2022 (the "Relevant Period"), Hamlin Advisors and Braun provided advice to certain charter schools (directly or indirectly through related borrower entities) (collectively, the "Charter School Clients") on the issuance of municipal bond offerings totaling over $500 million in aggregate principal amount. In each of these issuances, Hamlin Advisors's affiliate, a registered investment adviser ("Hamlin Affiliate"), purchased either all or a substantial portion of the offered bonds. In most instances, Hamlin Affiliate also acted as compensated bondholder representative. This affiliate relationship created a material conflict of interest which was not timely disclosed to the Charter School Clients until several days or sometimes weeks after Hamlin Advisors began advising on the structure, timing, and terms of the particular offerings at issue. Braun provided the advice to the Charter School Clients and was responsible for providing the conflicts disclosure and the agreements for municipal advisory services. When Hamlin Advisors and Braun did disclose that a material conflict of interest existed because of Hamlin Advisors's affiliation with Hamlin Affiliate, the disclosure was inadequate because it only disclosed that the firms had certain common ownership and both firms could "receive fees." It did not disclose that Hamlin Advisors had a financial incentive that was opposed to the interests of the Charter School Clients, due to its affiliation with the Hamlin Affiliate. Further, Hamlin Advisors's disclosure was inadequate because it did not adequately describe the nature, implications, and potential consequences of the conflict, and did not disclose how it planned to manage and mitigate the conflict. In addition, in their advisory agreements with the Charter School Clients, Hamlin Advisors and Braun did not accurately describe the scope of Hamlin Advisors's municipal advisory services for the deals at issue. Finally, Hamlin Advisors's written supervisory procedures were not reasonably designed to achieve compliance with the applicable securities laws and regulations, including the applicable MSRB rules. As a result of the conduct described herein, Respondents violated Section 15B(c)(1) of the Exchange Act (prohibiting violations of MSRB Rules), and MSRB Rules G-17 and G-42 and Hamlin Advisors violated Section 15B(c)(1) of the Exchange Action (fiduciary duty) and MSRB Rule G-44. 10-24-2024 Order Y Y Cease and Desist Censure CivilAdminPenaltyFine 200000.00 200000.00 10-24-2024 200000.00 Michael Ferrell Braun Y 868-02086 SECURITIES AND EXCHANGE COMMISSION ADMINISTRATIVE PROCEEDING 3-22274 100 F Street NE Mail Stop 1090 Washington DC 20549 Braun willfully violated Section 15B(c)(1) of the Exchange Act, MSRB Rule G-17, MSRB Rule G42(b) and MSRB Rule G-42(c). Accordingly, it is hereby ordered that Braun cease and desist from committing or causing any violations and any future violations of Section 15B(c)(1) of the Exchange Act, MSRB Rule G-17, MSRB Rule G42(b) and MSRB Rule G-42(c), is censured, and shall pay a civil money penalty of $75,000 10-24-2024 Cease and Desist Censure CivilAdminPenaltyFine Debt - Municipal The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted against Hamlin Capital Advisors, LLC (Hamlin Advisors) and Michael Ferrell Braun (together, Respondents). In anticipation of the institution of these proceedings, Respondents have submitted Offers of Settlement which the Commission has determined to accept. The Commission finds that this matter concerns failures to timely and fully disclose material conflicts of interest and related violations by Hamlin Advisors, a registered municipal advisor, and its associated person and Managing Director, Braun, including violations of various Municipal Securities Rulemaking Board ("MSRB") rules by each Respondent, and related breaches of fiduciary duty by Hamlin Advisors with respect to its disclosure violations. From September 2017 to at least April 2022 (the "Relevant Period"), Hamlin Advisors and Braun provided advice to certain charter schools (directly or indirectly through related borrower entities) (collectively, the "Charter School Clients") on the issuance of municipal bond offerings totaling over $500 million in aggregate principal amount. In each of these issuances, Hamlin Advisors's affiliate, a registered investment adviser ("Hamlin Affiliate"), purchased either all or a substantial portion of the offered bonds. In most instances, Hamlin Affiliate also acted as compensated bondholder representative. This affiliate relationship created a material conflict of interest which was not timely disclosed to the Charter School Clients until several days or sometimes weeks after Hamlin Advisors began advising on the structure, timing, and terms of the particular offerings at issue. Braun provided the advice to the Charter School Clients and was responsible for providing the conflicts disclosure and the agreements for municipal advisory services. When Hamlin Advisors and Braun did disclose that a material conflict of interest existed because of Hamlin Advisors's affiliation with Hamlin Affiliate, the disclosure was inadequate because it only disclosed that the firms had certain common ownership and both firms could "receive fees." It did not disclose that Hamlin Advisors had a financial incentive that was opposed to the interests of the Charter School Clients, due to its affiliation with the Hamlin Affiliate. Further, Hamlin Advisors's disclosure was inadequate because it did not adequately describe the nature, implications, and potential consequences of the conflict, and did not disclose how it planned to manage and mitigate the conflict. In addition, in their advisory agreements with the Charter School Clients, Hamlin Advisors and Braun did not accurately describe the scope of Hamlin Advisors's municipal advisory services for the deals at issue. Finally, Hamlin Advisors's written supervisory procedures were not reasonably designed to achieve compliance with the applicable securities laws and regulations, including the applicable MSRB rules. As a result of the conduct described herein, Respondents violated Section 15B(c)(1) of the Exchange Act (prohibiting violations of MSRB Rules), and MSRB Rules G-17 and G-42 and Hamlin Advisors violated Section 15B(c)(1) of the Exchange Action (fiduciary duty) and MSRB Rule G-44. 10-24-2024 Order Y Y Cease and Desist Censure CivilAdminPenaltyFine 75000.00 75000.00 10-24-2024 75000.00 Michael Armstrong Michael Armstrong CCO 01-21-2026 N N N N N Y N N N N Y N Y N N N N N Y N N