Wilmington Trust Investment Advisors, Inc.

Allegations: THE BOARD OF GOVERNORS ALLEGED THAT PRIOR TO 2018 M&T BANK FAILED TO REQUIRE FLOOD INSURANCE IN CONNECTION WITH CERTAIN LOANS. Status: Final Sanction Detail: MONETARY/FINE AMOUNT: $ 546,000.00 Summary: ON OCTOBER 14, 2020 THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "BOARD OF GOVERNORS") ISSUED AN ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY RELATING TO M&T BANK'S COMMERCIAL AND BUSINESS BANKING BUSINESS. THE BOARD OF GOVERNORS ALLEGED THAT PRIOR TO 2018 M&T FAILED TO REQUIRE FLOOD INSURANCE IN CONNECTION WITH CERTAIN LOANS. M&T CONSENTED TO PAY A CIVIL MONEY PENALTY TO THE NATIONAL FLOOD INSURANCE PROGRAM WITHOUT ADMITTING OR DENYING ANY ALLEGATION MADE OR IMPLIED BY THE BOARD OF GOVERNORS.

Allegations: THE CFPB ALLEGED THAT M&T FAILED TO PROPERLY DISCLOSE IN ITS ADVERTISING AT VARIOUS POINTS BETWEEN 2009 AND 2012 THAT MINIMUM ACCOUNT ACTIVITY REQUIREMENTS EXISTED AND THAT FAILURE TO MEET THOSE REQUIREMENTS WOLD RESULT IN THE FREE CHECKING ACCOUNT CONVERTING TO A DIFFERENT ACCOUNT WHICH HAD A MONTHLY MAINTENANCE FEE. Status: Final Sanction Detail: ADVISORY AFFILIATE - $2,245,000 Summary: ON OCTOBER 9, 2014 THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ISSUED A CONSENT ORDER RELATING TO M&T BANKS ADVERTISING OF CONSUMER FREE CHECKING ACCOUNTS (THE "CONSENT ORDER") TO WHICH M&T CONSENTED WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OF FACTS OR CONCLUSIONS OF LAW (EXCEPT TO THE EXTENT NECESSARY TO ESTABLISH THE CFPB'S JURISDICTION OVER THE SUBJECT MATTER OF THE CONSENT ORDER).