Bmo Asset Management Corp.

Allegations: ON APRIL 19, 2024, THE FSS NOTIFIED BAMC THAT IT WAS INVESTIGATING BAMC PURSUANT TO ARTICLE 21(1) OF THE ADMINISTRATIVE PROCEDURES ACT AND ARTICLE 36(1) OF THE REGULATIONS ON INVESTIGATION OF CAPITAL MARKETS (THE "FSCMA"). THE FSS ALLEGED THAT BAMC VIOLATED THE KOREAN SHORT SALE REGULATIONS WHEN BAMC PLACED A SELL ORDER FOR 1,984 SHARES OF NHN KCP CORP. ("NHN KCP")'S COMMON STOCK ON JANUARY 20, 2021, WHICH BAMC ERRONEOUSLY BELIEVED INCLUDED 134 SHARES THAT WERE EXPECTED TO BE RECEIVED AS STOCK DIVIDENDS, WHEN BAMC HELD ONLY 1,928 SHARES. BAMC BECAME AWARE OF THE SHORTAGE OF 56 SHARES (ORDER AMOUNT OF KRW 3,724,000) THE NEXT DAY (THURSDAY, JANUARY 21, 2021; T+1). ON JANUARY 22, 2021 (T+2), BAMC RESOLVED THIS SHORTAGE BY PURCHASING THE 56 SHARES IT WAS SHORT TO SETTLE THE ORIGINAL TRADE. BAMC EXECUTED THE PURCHASE ORDER ON MONDAY, JANUARY 25, 2021 (T+3). THE ORIGINAL TRADE WAS ULTIMATELY SETTLED ON JANUARY 27, 2021 (T+5). BAMC WAS SUBSEQUENTLY NOTIFIED ON JULY 17, 2024 OF THE IMPOSITION OF AN ADMINISTRATIVE FINE OF KRW 30,000,000, WHICH WAS REDUCED TO KRW 24,000,000 UPON TIMELY PAYMENT OF THIS FINE. THE FINE WAS PAID ON AUGUST 20, 2024. Status: Final Sanction Detail: BAMC PAID THIS FINE ON AUGUST 20, 2024. Summary: ON WEDNESDAY, JANUARY 20, 2021, BAMC PLACED A SELL ORDER OF 1,984 SHARES OF NHN KCP, ERRONEOUSLY BELIEVING THAT IT HAD HELD MORE SHARES THAN THE SELL ORDER AMOUNT DUE TO A MISTAKEN BELIEF THAT 134 SHARES THAT WERE EXPECTED TO BE RECEIVED AS STOCK DIVIDENDS WERE PART OF BAMC'S INVENTORY. BAMC BECAME AWARE OF THE SHORTAGE OF SHARES ON THURSDAY, JANUARY 21, 2021 (T+1). ON FRIDAY, JANUARY 22, 2021 (T+2), BAMC RESOLVED THIS SHORTAGE BY PURCHASING THE 56 SHARES IT WAS SHORT TO SETTLE THE ORIGINAL TRADE. BAMC EXECUTED THE PURCHASE ORDER ON MONDAY, JANUARY 25, 2021 (T+3). THE ORIGINAL TRADE WAS ULTIMATELY SETTLED ON WEDNESDAY, JANUARY 27, 2021 (T+5).

Allegations: THE U.S. COMMODITY FUTURE TRADING COMMISSION ("CFTC") ALLEGED THAT, FROM AT LEAST 2019 THROUGH THE DATE OF THE ORDER, BANK OF MONTREAL ("BMO") (I) FAILED TO KEEP CERTAIN REQUIRED RECORDS IN VIOLATION OF SECTIONS 4S(F)(1)(C) AND 4S(G)(1) AND (3) OF THE COMMODITY EXCHANGE ACT ("CEA") AND CFTC REGULATIONS 23.201(A) AND 23.202(A)(1) AND (B)(1), (II) FAILED TO KEEP RECORDS IN THE MANNER REQUIRED BY CFTC REGULATION 1.31, AND (III) FAILED TO SUPERVISE ITS SWAP DEALER BUSINESS ACTIVITIES DILIGENTLY IN VIOLATION OF SECTION 4S(H)(1)(B) OF THE CEA AND CFTC REGULATION 23.602(A). Status: Final Sanction Detail: BANK OF MONTREAL ("BMO") ADMITTED TO THE FACTS IN THE CFTC'S ORDER, ACKNOWLEDGED ITS CONDUCT VIOLATED THE COMMODITY EXCHANGE ACT ("CEA") AND CFTC REGULATIONS, AND AGREED TO (I) THE ENTRY OF THE CFTC'S FINDINGS; (II) CEASE AND DESIST FROM VIOLATING SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE CEA AND CFTC REGULATIONS 1.31, 23.201(A), 23.202(A)(1) AND (B)(1), AND 23.602(A); (III) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $35,000,000; AND (IV) COMPLY WITH CERTAIN UNDERTAKINGS. Summary: ON AUGUST 8, 2023, THE U.S. COMMODITY FUTURES TRADING COMMISSION ("CFTC") ALLEGED THAT BANK OF MONTREAL ("BMO") (I) FAILED TO KEEP CERTAIN REQUIRED RECORDS IN VIOLATION OF SECTIONS 4S(F)(1)(C) AND 4S(G)(1) AND (3) OF THE COMMODITY EXCHANGE ACT ("CEA") AND CFTC REGULATIONS 23.201(A) AND 23.202(A)(1) AND (B)(1), (II) FAILED TO KEEP RECORDS IN THE MANNER REQUIRED BY CFTC REGULATION 1.31, AND (III) FAILED TO SUPERVISE ITS SWAP DEALER BUSINESS ACTIVITIES DILIGENTLY IN VIOLATION OF SECTION 4S(H)(1)(B) OF THE CEA AND CFTC REGULATION 23.602(A). BMO ADMITTED TO THE FACTS IN THE CFTC'S ORDER, ACKNOWLEDGED THAT ITS CONDUCT VIOLATED THE CEA AND CFTC REGULATIONS, AND AGREED TO (I) THE SERVICE OF THE CFTC'S ORDER; (II) CEASE AND DESIST FROM VIOLATING SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE CEA AND CFTC REGULATIONS 1.31, 23.201(A), 23.202(A)(1) AND (B)(1), AND 23.602(A); (III) PAY A CIVIL MONETARYPENALTY IN THE AMOUNT OF $35,000,000; AND (IV) COMPLY WITH CERTAIN UNDERTAKINGS.

Allegations: ON SEPTEMBER 27, 2019, BMO ASSET MANAGEMENT CORP. AND ITS AFFILIATE, BMO HARRIS FINANCIAL ADVISORS, INC. (BHFA) (BOTH, THE "SETTLING PARTIES") ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION (SEC). THE SEC ORDER MADE FINDINGS, WHICH THE SETTLING PARTIES NEITHER ADMITTED NOR DENIED, AND THE SETTLING PARTIES CONSENTED TO THE ENTRY OF THE ORDER (ORDER) FINDINGS THAT THE SETTLING PARTIES VIOLATED SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-7 THEREUNDER. THE SEC ALLEGED THAT FROM JULY 2012 THROUGH MARCH 2016, THE SETTLING PARTIES DID NOT DISCLOSE THAT THEY PREFERRED PROPRIETARY MUTUAL FUNDS FOR RETAIL INVESTORS IN A SPECIFIC INVESTMENT ADVISORY PROGRAM OFFERED BY BHFA AND ADVISED BY BMO ASSET MANAGEMENT CORP. THE ORDER ALSO FOUND THAT BHFA BREACHED ITS DUTY OF BEST EXECUTION, AND THE SETTLING PARTIES INSUFFICIENTLY IMPLEMENTED POLICIES AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT CONFLICTS OF INTEREST. THE ORDER CENSURES THE SETTLING PARTIES AND DIRECTS THEM TO CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF THE ABOVE-ENUMERATED STATUTORY PROVISIONS. ADDITIONALLY, THE ORDER REQUIRES THE SETTLING PARTIES TO PAY A TOTAL OF $37,983,542 COMPOSED OF DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL PENALTY, AND TO USE THOSE MONIES TO REPAY AFFECTED CLIENTS OF BHFA. Status: Final Sanction Detail: CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. WITH AFFILIATE BMO HARRIS FINANCIAL ADVISORS, INC., JOINTLY AND SEVERALLY, DISGORGEMENT OF $25 MILLION, PREJUDGMENT INTEREST OF $4,733,542, AND A CIVIL MONETARY PENALTY TOTALING $8.25 MILLION. PAID INTO ESCROW ON OCTOBER 7, 2019. Summary: PAYMENT WILL BE MADE TO AFFECTED CLIENTS OF BMO HARRIS FINANCIAL ADVISORS, INC., IN ACCORDANCE WITH THE TERMS OF THE SEC'S ORDER ISSUED ON SEPTEMBER 27, 2019, IN THE MATTER OF BMO HARRIS FINANCIAL ADVISORS, INC., AND BMO ASSET MANAGEMENT CORP.