Alliancebernstein L.P.

Allegations: ALLIANCEBERNSTEIN, IN ERROR, INTERNALLY APPROVED AN EMPLOYEE TO ACT AS AN INVESTMENT ADVISER REPRESENTATIVE IN ITS DENVER OFFICE BEFORE THAT EMPLOYEE WAS LICENSED BY THE COLORADO DIVISION OF SECURITIES TO ACT IN THAT CAPACITY. Status: Final Sanction Detail: A MONETARY FIND OF $20232.36 WAS PAID BY THE FIRM WITHIN 10 DAYS OF THE RESOLUTION DATE. Summary: IN ACCORD WITH A STIPULATION EXECUTED BY ALLIANCEBERNSTEIN L.P. AND THE COLORADO DIVISION OF SECURITIES, A CONSENT ORDER WITH THE SANCTIONS ABOVE WAS ISSUED ON MARCH 22, 2012. THE CONSENT ORDER DISPOSED OF THE MATTER.

Allegations: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ALLEGED THAT AXA EQUITABLE LIFE INSURANCE COMPANY VIOLATED NEW YORK INSURANCE LAW SECTION 4240(E) BY FILING PLANS OF OPERATION WITH RESPECT TO CERTAIN OF ITS SEPARATE ACCCUONTS WITH THE NEW YORK STATE INSURANCE DEPARTMENT AND NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (COLLECTIVELY, THE "DEPARTMENT") WITHOUT ADEQUATELY INFORMING AND EXPLAINING TO THE DEPARTMENT THE SIGNIFICANCE OF THE IMPLEMENTATION OF THE AXA TACTICAL MANAGER STRATEGY. Status: Final Sanction Detail: AXA EQUITABLE LIFE INSURANCE COMPANY CONSENTED TO THE IMPOSITION OF A CIVIL PENALTY ON MARCH 17, 2014 IN THE SUM OF $20,000,000, AGREED TO SEEK ALL NECESSARY APPROVALS WITH REGARD TO NEW YORK INSURANCE LAW SECTION 4240(E) AND AGREED TO PROVIDE DEPARTMENT-APPROVED COMMUNICATIONS TO POLICYHOLDERS WHEN AXA EQUITABLE LIFE INSURANCE COMPANY IS REVISING FUND CHOICES IN CONNECTION WITH THE AXA TACTICAL MANAGER STRATEGY AND TO COMPLY WITH ANY OTHER CONDITIONS PLACED ON SUCH APPROVALS. AXA EQUITABLE LIFE INSURANCE COMPANY ALSO AGREED TO ISSUE A WRITTEN REPORT TO THE DEPARTMENT CONCERNING CHANGES TO THE PLAN OF OPERATIONS FOR CERTAIN OF ITS SEPARATE ACCOUNTS ON A QUARTERLY BASIS FOR A PERIOD OF FIVE YEARS FROM MARCH 17, 2014. Summary: THE MATTER WAS SETTLED ON MARCH 17, 2014, THE DATE AXA EQUITABLE LIFE INSURANCE COMPANY ENTERED INTO A CONSENT ORDER WITH THE DEPARTMENT CONSENTING TO THE SANCTIONS LISTED ABOVE.

Allegations: IN A NOTICE OF ADMINISTRATIVE FINE, THE FSC ALLEGED THAT THE REGISTRANT IN 2008 DID NOT TIMELY REPORT ITS CLIENTS' BENEFICIAL OWNERSHIP OF MORE THAN 4% OF SHARES IN TWO BANK HOLDING COMPANIES PURSUANT TO ARTICLES 8 AND 72 OF THE FINANCIAL HOLDING COMPANIES ACT AND ARTICLE 6-2 OF THE PRESIDENTIAL DECREE OF THE FINANCIAL HOLDING COMPANIES ACT. Status: Final Sanction Detail: REGISTRANT PAID AN ADMINISTRATIVE FINE OF KOREAN WON 16,000,000 (APPROXIMATELY USD $12,500) TO RESOLVE THE MATTER. Summary: REGISTRANT PAID AN ADMINISTRATIVE FINE OF KOREAN WON 16,000,000 (APPROXIMATELY USD $12,500) TO RESOLVE THE MATTER.

Allegations: SEBI ALLEGED THAT CHANGES IN THE NAMES OF INDIAN TRADING ACCOUNTS FOR CERTAIN AUSTRALIAN UNIT TRUSTS WERE NOT REPORTED IN A TIMELY MANNER, PURSUANT TO SECTION 13(1)(E) OF SEBI'S FOREIGN INSTITUTIONAL INVESTOR REGULATIONS. THE REGISTRANT IS THE MANAGER OF THE UNIT TRUSTS, BUT IS NOT THEIR CUSTODIAN OR TRUSTEE. THE REGISTRANT AGREED TO RESOLVE THE ALLEGATIONS WITHOUT ADMITTING OR DENYING A VIOLATION, AND A CONSENT ORDER DISPOSING OF THE MATTER WAS ISSUED ON MARCH 20, 2009. Status: Final Sanction Detail: PURSUANT TO A CONSENT ORDER DATED MARCH 20, 2009, WHICH DISPOSED OF THE MATTER, THE REGISTRANT PAID SEBI A FINE AND ADMINISTRATIVE FEE OF RPS. 1,025,000 (APPROXIMATELY USD $22,500). Summary: PURSUANT TO A CONSENT ORDER DATED MARCH 20, 2009, WHICH DISPOSED OF THE MATTER, THE REGISTRANT PAID SEBI A FINE AND ADMINISTRATIVE FEE OF RPS. 1,025,000 (APPROXIMATELY USD $22,500).

Allegations: THE STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION ("FLORIDA") ALLEGED THAT THE REGISTRANT CONDUCTED INVESTMENT ADVISORY ACTIVITIES THROUGH CERTAIN INDIVIDUAL EMPLOYEES FROM OFFICES WITHIN FLORIDA WITHOUT THE BENEFIT OF THEIR LAWFUL ASSOCIATED PERSON REGSITRATION, IN VIOLATION OF SECTION 517.12(4), FLORIDA STATUTES. Status: Final Sanction Detail: UNDER THE CONSENT AGREEMENT, REGISTRANT PAID ADMINISTRATIVE FINES TOTALING $51,675.00 ON BEHALF OF ITSELF AND THE EMPLOYEES, DISPOSING OF THE MATTER. THE FINE WAS PAID IN FULL ON JANUARY 24, 2014. Summary: ON JANUARY 17, 2014, THE FIRM AND THREE EMPLOYEES ENTERED A STIPULATION AND CONSENT AGREEMENT WITH THE FLORIDA OFFICE OF FINANCIAL REGULATION TO RESOLVE SIMILAR ALLEGATIONS THAT, DUE TO ADMINISTRATIVE OVERSIGHT BY THE FIRM, CERTAIN EMPLOYEES HAD NOT BEEN REGISTERED WITH FLORIDA AS ASSOCIATED PERSONS OF AN INVESTMENT ADVISER. UNDER THE CONSENT AGREEMENT, REGISTRANT PAID ADMINISTRATIVE FINES TOTALING $51,675 ON BEHALF OF ITSELF AND THE EMPLOYEES, DISPOSING OF THE MATTER.

Allegations: ON JULY 2, 2008, THE NETHERLANDS AUTHORITY FOR THE FINANCIAL MARKETS (AFM) IMPOSED AN ADMINISTRATIVE FINE OF EUR 120,000 ON ALLIANCEBERNSTEIN CORPORATION THE GENERAL PARTNER OF ALLIANCEBERNSTEIN L.P. THE FINE CONCERNED THE UNTIMELY SUBMISSION OF FIVE BENEFICIAL OWNERSHIP REPORTS UNDER ARTICLE 5:38, SECTION 1, OF THE NETHERLANDS' FINANCIAL SUPERVISION ACT. THE FIRM'S PAYMENT OF THE FINE RESOLVED THE AFM'S INQUIRY. Status: Final Sanction Detail: ON JULY 2, 2008, THE NETHERLANDS AUTHORITY FOR THE FINANCIAL MARKETS (AFM) IMPOSED AN ADMINISTRATIVE FINE OF EUR 120,000 ON ALLIANCEBERNSTEIN CORPORATION THE GENERAL PARTNER OF ALLIANCEBERNSTEIN L.P. THE FINE CONCERNED THE UNTIMELY SUBMISSION OF FIVE BENEFICIAL OWNERSHIP REPORTS UNDER ARTICLE 5:38, SECTION 1, OF THE NETHERLANDS' FINANCIAL SUPERVISION ACT. THE FIRM'S PAYMENT OF THE FINE RESOLVED THE AFM'S INQUIRY. Summary: ON JULY 2, 2008, THE NETHERLANDS AUTHORITY FOR THE FINANCIAL MARKETS (AFM) IMPOSED AN ADMINISTRATIVE FINE OF EUR 120,000 ON ALLIANCEBERNSTEIN CORPORATION THE GENERAL PARTNER OF ALLIANCEBERNSTEIN L.P. THE FINE CONCERNED THE UNTIMELY SUBMISSION OF FIVE BENEFICIAL OWNERSHIP REPORTS UNDER ARTICLE 5:38, SECTION 1, OF THE NETHERLANDS' FINANCIAL SUPERVISION ACT. THE FIRM'S PAYMENT OF THE FINE RESOLVED THE AFM'S INQUIRY.