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Sandra Brown

Independent Trustee at SOURCE CAPITAL /DE/
Board

About Sandra Brown

Sandra Brown (born 1955) is an Independent Trustee of Source Capital (SOR) and has served since 2016. She is currently a consultant (since 2009) and previously held senior leadership roles in financial services, including CEO and President of Transamerica Financial Advisers, President of Transamerica Securities Sales Corp., and Vice President of Bank of America Mutual Fund Administration; she also served as a Trustee of Bragg Capital Trust from 2020–2023 . Education is not disclosed in the proxy; tenure on SOR’s board: first elected in 2016 .

Past Roles

OrganizationRoleTenureCommittees/Impact
Transamerica Financial Advisers, Inc.CEO & President1999–2009 Not disclosed
Transamerica Securities Sales Corp.President1998–2009 Not disclosed
Bank of America Mutual Fund AdministrationVice President1990–1998 Not disclosed
Bragg Capital TrustTrustee2020–2023 Not disclosed

External Roles

OrganizationRoleStatusScope
Investment Managers Series Trust IIITrusteeCurrent Oversees 8 portfolios in the Fund Complex

Board Governance

  • Independence: Classified as an Independent Trustee under the 1940 Act and NYSE standards .
  • Chair/Committee Roles: Audit Committee Chair (2025); Audit Committee members: Brown, Goldrich, Zader . Nominating & Governance Committee members: Brown, Goldrich, Zader .
  • Committee Activity: Audit Committee met 4 times (FY 2024); Nominating & Governance Committee met 2 times (FY 2024) .
  • Attendance: FY 2024—each Trustee attended all Board and Committee meetings on which they served . FY 2023—Brown attended 75% or more of Board and Committee meetings .
  • Board leadership: Chairman is John Zader; Board meets at least quarterly and holds executive sessions; Independent Trustees meet quarterly in executive session with the CCO .
CommitteeRoleMembersFY 2024 Meetings
Audit CommitteeChairSandra Brown; Members: Robert F. Goldrich, John Zader 4
Nominating & GovernanceMemberSandra Brown; Members: Robert F. Goldrich, John Zader 2

Fixed Compensation

MetricFY 2023FY 2024
Aggregate Compensation from SOR ($)$15,920 $8,131
Total Compensation from Fund Complex ($)$202,618 $180,000
Pension/Retirement BenefitsNone None
Deferred Compensation Plan AvailabilityAvailable; non-qualified plan permitting deferral elections Available; non-qualified plan permitting deferral elections

Notes:

  • Independent Trustees receive an annual retainer plus Board/Committee meeting fees; Board/Committee chairs receive additional fees (specific rates not disclosed) .

Performance Compensation

ComponentFY 2023FY 2024
Equity awards (RSUs/PSUs)Not disclosed for Independent Trustees Not disclosed for Independent Trustees
Option awardsNot disclosed for Independent Trustees Not disclosed for Independent Trustees
Performance metrics tied to director compensationNot disclosed (director pay described as retainer/meeting fees) Not disclosed (director pay described as retainer/meeting fees)
Clawback provisions (director-specific)Not disclosed Not disclosed
PerquisitesNot disclosed Not disclosed

Other Directorships & Interlocks

Company/EntityRolePeriodNotes
Investment Managers Series Trust IIITrusteeCurrent IMST III includes multiple series; FPA advises certain series within the Fund Complex
Bragg Capital TrustTrustee2020–2023 Prior trustee role

Expertise & Qualifications

  • Senior leadership experience in investment management distribution and administration (Transamerica; Bank of America Mutual Fund Administration) and governance roles across registered investment companies .
  • Committee leadership as Audit Committee Chair; Board governance and nominating experience; familiarity with 1940 Act risk oversight processes .

Equity Ownership

MetricAs of Dec 31, 2023As of Dec 31, 2024
Dollar Range of SOR Shares Owned$10,000–$50,000 None
Aggregate Dollar Range in Fund Complex OverseenOver $100,000 None

Additional ownership context:

  • As of April 2, 2025, all officers and Trustees as a group owned less than 1% of SOR’s outstanding shares .

Governance Assessment

  • Strengths: Independence; service as Audit Committee Chair; fully attended Board and Committee meetings in FY 2024; robust committee charters and pre-approval policies; independent legal counsel retained by Independent Trustees; executive sessions and quarterly engagement with CCO support risk oversight .
  • Alignment Considerations: Brown reported “None” for SOR share ownership and Fund Complex holdings as of Dec 31, 2024, after reporting meaningful ownership in 2023—this reduction may be viewed as a potential alignment concern for some investors .
  • Conflicts/Related Parties: Independent Trustees do not hold interests in the Adviser or entities under common control; Audit Committee pre-approves auditor services; no material legal proceedings involving nominees; committee independence affirmed under NYSE standards .

RED FLAGS

  • No current SOR share ownership disclosed for Brown as of Dec 31, 2024 (previously $10k–$50k in 2023), potentially weakening ownership alignment signals .