U.S. Bancorp Asset Management, Inc.

Event Detail: A CRIMINAL INFORMATION WAS FILED ON FEBRUARY 15, 2018, IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CHARGING U.S. BANCORP ("USB") WITH (1) ONE COUNT OF WILLFULLY FAILING TO MAINTAIN AN ADEQUATE ANTI-MONEY LAUNDERING PROGRAM, IN VIOLATION OF 31 U.S.C. §§ 5318(H) AND 5322(A), AND (2) ONE COUNT OF WILLFULLY FAILING TO FILE A SUSPICIOUS ACTIVITY REPORT, IN VIOLATION OF 31 U.S.C. §§ 5318(G) AND 5322(A) AND 31 C.F.R. § 1020.320(A) (THE "INFORMATION"). USB WAIVED INDICTMENT, AGREED TO THE FILING OF THE INFORMATION, AND ACCEPTED AND ACKNOWLEDGED RESPONSIBILITY FOR THE ACTS OF ITS OFFICERS AND EMPLOYEES AS SET FORTH IN THE ACCOMPANYING STATEMENT OF FACTS. A PLEA WAS NOT ENTERED IN RESPECT OF ANY OF THE CHARGES. Status: Pending Disposition: ON FEBRUARY 15, 2018, USB ENTERED INTO A DEFERRED PROSECUTION AGREEMENT ("DPA") WITH THE OFFICE OF THE UNITED STATES ATTORNEY FOR THE SOUTHERN DISTRICT OF NEW YORK ("DOJ"). PROSECUTION WAS DEFERRED FOR TWO YEARS FROM THE DATE OF THE DPA. AS PART OF THE DPA, USB SETTLED ANY AND ALL CRIMINAL CLAIMS FOR THE SUM OF $528,000,000, LESS THE AMOUNT OF ANY CIVIL MONEY PENALTY PAID BY USB TO THE OFFICE OF THE COMPTROLLER OF THE CURRENCY IN CONNECTION WITH ITS CONCURRENT SETTLEMENT, PAID TO THE DOJ ON FEBRUARY 15, 2018. Summary: AS DESCRIBED IN THE DPA, FROM 2009 TO 2014, USB WILLFULLY FAILED TO ESTABLISH, IMPLEMENT, AND MAINTAIN AN ADEQUATE ANTI-MONEY LAUNDERING PROGRAM AND INTENTIONALLY IMPLEMENTED AND MAINTAINED BANK SECRECY ACT AND ANTI-MONEY LAUNDERING ("BSA/AML") SYSTEMS AND POLICIES THAT RESULTED IN USB FAILING TO IDENTIFY SUSPICIOUS ACTIVITY FLOWING THROUGH USB DUE TO A FAILURE TO PROVIDE ADEQUATE BSA/AML STAFFING AND RESOURCES. FROM OCTOBER 2011 TO NOVEMBER 2013, USB, ACCORDING TO THE DPA, ALSO WILLFULLY FAILED TO TIMELY REPORT SUSPICIOUS TRANSACTIONS OF A PARTICULAR CLIENT INVOLVING PROCEEDS FROM AN ILLEGAL PAYDAY LENDING SCHEME. PURSUANT TO THE DPA, USB AGREED TO PAY A CRIMINAL FINE, CONTINUE ITS ONGOING EFFORT TO IMPLEMENT AND MAINTAIN AN ADEQUATE BSA/AML PROGRAM, PROVIDE SEMI-ANNUAL REPORTS TO THE DOJ OF REMEDIAL CHANGES TO USB'S BSA/AML COMPLIANCE PROGRAM, AND CONTINUE COOPERATING WITH GOVERNMENT AGENCIES REGARDING RELATED MATTERS FOR TWO YEARS (UNLESS THE DPA IS OTHERWISE EXTENDED).

Allegations: PLAINTIFF CFTC ALLEGED VIOLATIONS OF SECTION 4D(B) OF THE COMMODITY EXCHANGE ACT, 7 U.S.C. § 6D(B), AND REGULATION 1.20(A), 17 C.F.R. § 1.20(A). THOSE PROVISIONS ADDRESS SEGREGATION AND HANDLING OF FUTURES COMMISSION MERCHANT ("FCM") CUSTOMER FUNDS. PEREGRINE FINANCIAL GROUP, INC. ("PEREGRINE"), AN FCM, WAS A U.S. BANK CUSTOMER AND HAD AN ACCOUNT AT U.S. BANK DESIGNATED TO HOLD CUSTOMER SEGREGATED FUNDS. THE CFTC ALLEGED THAT U.S. BANK'S HANDLING OF THAT ACCOUNT DID NOT CONFORM TO STATUTORY AND REGULATORY REQUIREMENTS. Status: Final Summary: IN AGREEING TO THE ENTRY OF THE CONSENT ORDER, U.S. BANK ADMITTED NO WRONGDOING, AND THE COURT HAS MADE NO FINDING THAT U.S. BANK COMMITTED ANY VIOLATION OF THE COMMODITY EXCHANGE ACT, 7 U.S.C. § 6D(B), OR REGULATION 1.20(A), 17 C.F.R. § 1.20(A). PURSUANT TO THE CONSENT ORDER, U.S. BANK'S PAYMENT OF $18 MILLION IS NOT A FINE OR PENALTY, AND THE MONIES SHALL BE PAID BY THE PEREGRINE TRUSTEE TO PEREGRINE CUSTOMERS HOLDING DOMESTIC FUTURES ACCOUNTS.

Allegations: THE OCC IDENTIFIED CERTAIN DEFICIENCIES AND UNSAFE OR UNSOUND PRACTICES IN U.S. BANK'S RESIDENTIAL MORTGAGE SERVICING AND IN U.S. BANK'S INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. Status: Final Sanction Detail: U.S. BANK WAS REQUIRED TO (1) IMPLEMENT A COMPLIANCE PROGRAM DESIGNED TO ENSURE THAT U.S. BANK'S MORTGAGE SERVICING AND FORECLOSURE OPERATIONS COMPLY WITH ALL APPLICABLE LEGAL REQUIREMENTS, OCC SUPERVISORY GUIDANCE, AND THE REQUIREMENTS OF THE ORDER AND ARE CONDUCTED IN A SAFE AND SOUND MANNER; (2) RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A FORECLOSURE REVIEW FOR LOANS SERVICED BY U.S. BANK PENDING AT ANY TIME FROM JANUARY 1, 2009 TO DECEMBER 31, 2010, AS WELL AS RESIDENTIAL FORECLOSURE SALES THAT OCCURRED DURING THIS TIME PERIOD (THE "FORECLOSURE REPORT"); AND (3) REMEDIATE ANY FINANCIAL INJURY TO BORROWERS CAUSED BY ANY ERRORS, MISREPRESENTATIONS, OR OTHER DEFICIENCIES IDENTIFIED IN THE FORECLOSURE REPORT. PURSUANT TO AN AMENDMENT TO THE CONSENT ORDER, DATED FEBRUARY 28, 2013, U.S. BANK WAS REQUIRED TO MAKE A CASH PAYMENT OF $80,060,193 INTO A QUALIFIED SETTLEMENT FUND FOR THE BENEFIT OF BORROWERS. ON FEBRUARY 8, 2016, IN CONNECTION WITH THE OCC'S TERMINATION OF THE ORDER, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $10 MILLION. Summary: ON APRIL 13, 2011, THE OCC ISSUED A CONSENT ORDER REQUIRING U.S. BANK TO TAKE CERTAIN MEASURES WITH RESPECT TO ITS GOVERNANCE AND OVERSIGHT OF RESIDENTIAL MORTGAGE SERVICING AND INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. U.S. BANK CONSENTED TO THE ENTRY OF THE ORDER. PURSUANT TO AN AMENDMENT TO THE CONSENT ORDER, DATED FEBRUARY 28, 2013, U.S. BANK WAS REQUIRED TO MAKE A CASH PAYMENT OF $80,060,193 INTO A QUALIFIED SETTLEMENT FUND FOR THE BENEFIT OF BORROWERS. ON JUNE 16, 2015, U.S. BANK AGREED TO AMEND THE CONSENT ORDER. THE AMENDMENT REQUIRED U.S. BANK TO COMPLETE AN ACTION PLAN TO RESOLVE OUTSTANDING ISSUES UNDER THE CONSENT ORDER AND OBTAIN APPROVAL FROM THE OCC BEFORE TAKING CERTAIN ACTIONS RELATED TO RESIDENTIAL MORTGAGE SERVICING. ON FEBRUARY 8, 2016, IN CONNECTION WITH THE OCC'S TERMINATION OF THE ORDER, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $10 MILLION.

Allegations: THE FEDERAL RESERVE BOARD IDENTIFIED CERTAIN DEFICIENCIES AND UNSAFE OR UNSOUND PRACTICES IN U.S. BANK'S RESIDENTIAL MORTGAGE SERVICING AND IN U.S. BANK'S INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. Status: Final Sanction Detail: ON JANUARY 12, 2018, IN CONNECTION WITH THE FEDERAL RESERVE BOARD'S TERMINATION OF ENFORCEMENT ACTIONS AGAINST U.S. BANK, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $4.4 MILLION. Summary: ON APRIL 13, 2011, THE FEDERAL RESERVE BOARD ISSUED A CONSENT ORDER REQUIRING U.S. BANK TO TAKE CERTAIN MEASURES WITH RESPECT TO ITS GOVERNANCE AND OVERSIGHT OF RESIDENTIAL MORTGAGE SERVICING AND INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. U.S. BANK CONSENTED TO THE ENTRY OF THE ORDER. ON FEBRUARY 28, 2013, THE CONSENT ORDER WAS AMENDED TO MEMORIALIZE U.S. BANK'S AGREEMENT TO MAKE A CASH PAYMENT OF $80,060,193 INTO A QUALIFIED SETTLEMENT FUND FOR THE BENEFIT OF BORROWERS. ON JANUARY 12, 2018, IN CONNECTION WITH THE FEDERAL RESERVE BOARD'S TERMINATION OF ENFORCEMENT ACTIONS AGAINST U.S. BANK, U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $4.4 MILLION.

Allegations: ON SEPTEMBER 20, 2021, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ISSUED A CONSENT ORDER AGAINST AFFILIATE MUFG UNION BANK, N.A., PURSUANT TO 12 U.S.C. § SECTION 1818(B), THROUGH THE ISSUANCE OF A NOTICE OF CHARGES, FOR ENGAGING IN UNSAFE OR UNSOUND PRACTICES AND ITS NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX B. Status: Final Sanction Detail: ON SEPTEMBER 20, 2021, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ISSUED A CONSENT ORDER AGAINST AFFILIATE MUFG UNION BANK, N.A., PURSUANT TO 12 U.S.C. § SECTION 1818(B), THROUGH THE ISSUANCE OF A NOTICE OF CHARGES, FOR ENGAGING IN UNSAFE OR UNSOUND PRACTICES AND ITS NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX B. Summary: ON SEPTEMBER 20, 2021, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ISSUED A CONSENT ORDER AGAINST AFFILIATE MUFG UNION BANK, N.A., PURSUANT TO 12 U.S.C. § SECTION 1818(B), THROUGH THE ISSUANCE OF A NOTICE OF CHARGES, FOR ENGAGING IN UNSAFE OR UNSOUND PRACTICES AND ITS NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX B.

Allegations: THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC") IDENTIFIED DEFICIENCIES IN U.S. BANK'S BANK SECRECY ACT/ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM. Status: Final Sanction Detail: THE OCC REQUIRED U.S. BANK TO IMPLEMENT CERTAIN ENHANCEMENTS TO U.S. BANK'S BANK SECRECY ACT/ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM. SOME OF THE COMPLIANCE PROGRAM ENHANCEMENTS AND OTHER ACTIONS REQUIRED BY THE CONSENT ORDER HAVE ALREADY BEEN, OR ARE CURRENTLY IN THE PROCESS OF BEING, IMPLEMENTED. Summary: ON OCTOBER 23, 2015, U.S. BANK ENTERED INTO A CONSENT ORDER WITH THE OCC CONCERNING DEFICIENCIES IN ITS BANK SECRECY ACT/ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM, AND REQUIRING AN ONGOING EVALUATION AND REMEDIATION OF THAT PROGRAM.

Allegations: U.S. BANCORP ("USB") LACKED ADEQUATE RISK MANAGEMENT AND COMPLIANCE POLICIES AND PROCEDURES TO ENSURE THAT ACTIVITIES CONDUCTED AT U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") AND USB AMERICAS HOLDINGS COMPANY (THE "AGREEMENT CORPORATION") COMPLIED WITH APPLICABLE BANK SECRECY ACT AND ANTI-MONEY LAUNDERING ("BSA/AML") AND OFAC RULES AND REGULATIONS AND WERE TIMELY REPORTED IN RESPONSE TO INQUIRIES BY THE FEDERAL RESERVE BANK OF MINNEAPOLIS ("RESERVE BANK"). Status: Final Sanction Detail: PURSUANT TO AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY (THE "BOARD ORDER"), THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ORDERED USB TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $15,000,000. Summary: IN ADDITION TO PAYMENT OF THE CIVIL MONEY PENALTY, THE BOARD ORDER REQUIRES THAT USB AND/OR THE AGREEMENT CORPORATION SUBMIT TO THE RESERVE BANK WRITTEN PLANS REGARDING ITS BSA/AML AND OFAC COMPLIANCE AND BOARD OVERSIGHT THEREOF. THE BOARD ORDER ALSO REQUIRES THAT USB ACT AS A SOURCE OF STRENGTH TO U.S. BANK, INCLUDING TAKING STEPS TO ENSURE U.S. BANK COMPLIES WITH ANY SUPERVISORY ACTION TAKEN AGAINST U.S. BANK BY ITS REGULATORS.

Allegations: U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") WILLFULLY FAILED TO MAINTAIN AN ADEQUATE ANTI-MONEY LAUNDERING ("AML") PROGRAM AND TO REPORT SUSPICIOUS TRANSACTIONS RELEVANT TO A POSSIBLE VIOLATION OF LAW OR REGULATIONS. Status: Final Sanction Detail: PURSUANT TO A STIPULATION AND ORDER OF SETTLEMENT AND DISMISSAL (THE "FINCEN SETTLEMENT"), U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") ACCEPTED AND ACKNOWLEDGED RESPONSIBILITY FOR FACTS AND CONDUCT PROVIDED IN A STATEMENT OF FACTS BY THE FINANCIAL CRIMES ENFORCEMENT NETWORK ("FINCEN") AND AGREED TO PAY A PENALTY OF $185 MILLION, WHICH WILL BE DEEMED SATISFIED BY A PAYMENT OF $70 MILLION TO THE TREASURY DEPARTMENT AND PAYMENT BY U.S. BANCORP OF ITS PAYMENT OBLIGATION UNDER THE DEFERRED PROSECUTION AGREEMENT WITH THE UNITED STATES. Summary: PURSUANT TO THE FINCEN SETTLEMENT, FOR A PERIOD OF TWO YEARS, U.S. BANK WILL PROVIDE FINCEN WITH ANNUAL REPORTS IDENTIFYING REMEDIAL ACTIONS U.S. BANK HAS TAKEN TO ADDRESS PRIOR DEFICIENCIES IN ITS BSA/AML PROGRAM AND DESCRIBING INDEPENDENT TESTING CONDUCTED ON THE BANK'S BSA FUNCTIONS. U.S. BANK ALSO AGREED TO COOPERATE WITH FINCEN IN ITS RELATED INVESTIGATIONS AND TO CONTINUE ITS COMMITMENT TO IMPROVE ITS BSA/AML PROGRAM AND TRANSACTION MONITORING. U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $70,000,000.

Allegations: U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") FAILED TO ADOPT AND IMPLEMENT AN ADEQUATE BANK SECRECY ACT AND ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM AND FAILED TO FILE ALL NECESSARY SUSPICIOUS ACTIVITY REPORTS RELATED TO SUSPICIOUS CUSTOMER ACTIVITY. Status: Final Sanction Detail: PURSUANT TO A CONSENT ORDER FOR A CIVIL MONEY PENALTY (THE "OCC ORDER"), THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC") REQUIRED U.S. BANK TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000,000. Summary: U.S. BANK PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000,000 TO THE OCC.

Allegations: THE OCC IDENTIFIED DEFICIENCIES IN U.S. BANK'S PRACTICES RELATED TO BILLING PRACTICES WITH REGARD TO IDENTITY PROTECTION PRODUCTS THAT RESULTED IN A VIOLATION OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT, 15 U.S.C. SEC. 45(A)(1), WHICH PROHIBITS UNFAIR ACTS OR PRACTICES. FROM FEBRUARY 2003 TO AUGUST 2012, U.S. BANK RECEIVED A SUBSTANTIAL PORTION OF THE FEES PAID BY CUSTOMERS OF U.S. BANK FOR IDENTITY THEFT PROTECTION PRODUCTS SOLD AND BILLED TO SUCH CUSTOMERS BY A THIRD PARTY SERVICE PROVIDER, INCLUDING FEES PAID BY CERTAIN CUSTOMERS WHO WERE NOT RECEIVING THE CREDIT MONITORING AND/OR CREDIT REPORT RETRIEVAL SERVICES OFFERED BY SUCH PRODUCTS. Status: Final Sanction Detail: ON OCTOBER 3, 2014, U.S. BANK PAID A $4 MILLION CIVIL MONEY PENALTY TO THE U.S. TREASURY AS REQUIRED UNDER THE CONSENT ORDER. U.S. BANK WILL MAKE REDRESS PAYMENTS TO CUSTOMER ACCOUNTS IN THE TOTAL AMOUNT OF $50,574,500. REDRESS PAYMENTS WILL BEGIN UPON RECEIVING NON-OBJECTION DETERMINATIONS ON U.S. BANK'S REDRESS PLAN FROM THE OCC AND THE CONSUMER FINANCIAL PROTECTION BUREAU (CFPB). REDRESS PAYMENTS ARE EXPECTED TO BE COMPLETED BY FOURTH QUARTER 2015. Summary: ON SEPTEMBER 24, 2014, THE OCC ISSUED A CONSENT ORDER, IN COORDINATION WITH SEPARATE ACTION TAKEN BY THE CFPB, WHICH ASSESSED A $4 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK AND ORDERED RESTITUTION (REDRESS) TO AFFECTED CONSUMER ACCOUNTS. THE OCC ALSO REQUIRED U.S. BANK TO TAKE CERTAIN MEASURES WITH RESPECT TO ITS GOVERNANCE AND OVERSIGHT OF THIRD-PARTY VENDORS AND ADD-ON CONSUMER PRODUCTS. U.S. BANK CONSENTED TO THE ENTRY OF THE ORDER. U.S. BANK WILL MAKE REDRESS PAYMENTS TO CUSTOMER ACCOUNTS IN THE TOTAL AMOUNT OF $50,574,500. REDRESS PAYMENTS WILL BEGIN UPON RECEIVING NON-OBJECTION DETERMINATIONS ON U.S. BANK'S REDRESS PLAN FROM THE OCC AND THE CFPB. REDRESS PAYMENTS ARE EXPECTED TO BE COMPLETED BY FOURTH QUARTER 2015.

Allegations: THE CFPB IDENTIFIED DEFICIENCIES IN U.S. BANK'S PRACTICES RELATED TO BILLING PRACTICES WITH REGARD TO IDENTITY PROTECTION PRODUCTS THAT RESULTED IN VIOLATIONS OF SECTIONS 1031 AND 1036 OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010, 12 U.S.C. SECTIONS 5531 AND 5536, WHICH PROHIBIT "UNFAIR, DECEPTIVE, OR ABUSIVE" ACTS OR PRACTICES. FROM AT LEAST 2003 TO APPROXIMATELY AUGUST 2012, U.S. BANK RECEIVED A SUBSTANTIAL PORTION OF THE FEES PAID BY CUSTOMERS OF U.S. BANK FOR IDENTITY THEFT PROTECTION PRODUCTS SOLD AND BILLED TO SUCH CUSTOMERS BY A THIRD PARTY SERVICE PROVIDER, INCLUDING FEES PAID BY CERTAIN CUSTOMERS WHO WERE NOT RECEIVING THE CREDIT MONITORING AND/OR CREDIT REPORT RETRIEVAL SERVICES OFFERED BY SUCH PRODUCTS. Status: Final Sanction Detail: ON OCTOBER 3, 2014, U.S. BANK PAID A $5 MILLION CIVIL MONEY PENALTY TO THE CFPB AS REQUIRED UNDER THE CONSENT ORDER. U.S. BANK WILL MAKE REDRESS PAYMENTS TO CUSTOMER ACCOUNTS IN THE TOTAL AMOUNT OF $50,574,500. REDRESS PAYMENTS WILL BEGIN UPON RECEIVING NON-OBJECTION DETERMINATIONS ON U.S. BANK'S REDRESS PLAN FROM CFPB AND THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC). REDRESS PAYMENTS ARE EXPECTED TO BE COMPLETED BY FOURTH QUARTER 2015. Summary: ON SEPTEMBER 24, 2014, THE CFPB ISSUED A CONSENT ORDER, IN COORDINATION WITH SEPARATE ACTION TAKEN BY THE OCC, WHICH ASSESSED A $5 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK AND ORDERED RESTITUTION (REDRESS) TO AFFECTED CONSUMER ACCOUNTS. THE CFPB ALSO REQUIRED U.S. BANK TO TAKE CERTAIN MEASURES WITH RESPECT TO ITS GOVERNANCE AND OVERSIGHT OF THIRD-PARTY VENDORS AND ADD-ON CONSUMER PRODUCTS. U.S. BANK CONSENTED TO THE ENTRY OF THE ORDER. U.S. BANK WILL MAKE REDRESS PAYMENTS TO CUSTOMER ACCOUNTS IN THE TOTAL AMOUNT OF $50,574,500. REDRESS PAYMENTS WILL BEGIN UPON RECEIVING NON-OBJECTION DETERMINATIONS ON U.S. BANK'S REDRESS PLAN FROM THE CFPB AND THE OCC. REDRESS PAYMENTS ARE EXPECTED TO BE COMPLETED BY FOURTH QUARTER 2015.

Allegations: THE OCC IDENTIFIED DEFICIENCIES IN U.S. BANK'S PRACTICES RELATED TO BANKRUPTCY COURT FILINGS COMPLETED BETWEEN 2009 AND 2014 THAT DID NOT COMPLY WITH BANKRUPTCY LAWS. Status: Final Sanction Detail: ON APRIL 24, 2017, U.S. BANK PAID A $15 MILLION CIVIL MONEY PENALTY TO THE U.S. TREASURY AS REQUIRED UNDER THE CONSENT ORDER. Summary: ON APRIL 25, 2017, THE OCC ISSUED A CONSENT ORDER WHICH ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK. U.S. BANK CONSENTED TO ENTRY OF THE ORDER AND PAID THE CIVIL MONEY PENALTY TO THE U.S. TREASURY.

Allegations: THE CFPB IDENTIFIED DEFICIENCIES IN U.S. BANK'S PRACTICES RELATED TO OPENING OF CREDIT CARD, LINE OF CREDIT AND DEPOSIT ACCOUNTS WITHOUT CUSTOMER PERMISSION IN VIOLATION OF SECTION 1601 OF THE TRUTH IN LENDING ACT, SECTION 1681B(F) OF THE FAIR CREDIT REPORTING ACT, SECTION 4301 OF THE TRUTH IN SAVINGS ACT, AND SECTIONS 5531 AND 5536 OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010, WHICH PROHIBIT "UNFAIR, DECEPTIVE, OR ABUSIVE" ACTS OR PRACTICES. DURING THE PERIOD FROM JANUARY 2010 THROUGH DECEMBER 2020, U.S. BANK EMPLOYEES OPENED ACCOUNTS WITHOUT CONSUMERS' KNOWLEDGE AND CONSENT. THESE ACTS OR PRACTICES INVOLVED A SMALL PERCENTAGE OF U.S. BANK'S NEW ACCOUNTS. Status: Final Sanction Detail: ON AUGUST 2, 2022, U.S. BANK PAID A $37.5 MILLION CIVIL MONEY PENALTY TO THE CFPB AS REQUIRED UNDER THE CONSENT ORDER. U.S. BANK IS UNDERTAKING A REVIEW TO DETERMINE THE EXTENT TO WHICH REDRESS PAYMENTS SHOULD BE MADE TO AFFECTED CONSUMERS. REDRESS PAYMENTS WILL BE COMPLETED WITHIN ONE YEAR OF THE CFPB MAKING A DETERMINATION OF NON-OBJECTION TO U.S. BANK'S REDRESS PLAN. Summary: ON JULY 28, 2022, THE CFPB ISSUED A CONSENT ORDER THAT ASSESSED A $37.5 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK AND ORDERED RESTITUTION (REDRESS) TO AFFECTED CONSUMER ACCOUNTS. THE CFPB ALSO REQUIRED U.S. BANK TO IMPLEMENT A COMPLIANCE PLAN DESIGNED TO ENSURE THAT U.S. BANK'S CONDUCT COMPLIES WITH ALL APPLICABLE FEDERAL CONSUMER FINANCIAL LAWS AND TERMS OF THE CONSENT ORDER. U.S. BANK CONSENTED TO THE ENTRY OF THE ORDER. U.S. BANK IS UNDERTAKING A REVIEW TO DETERMINE THE EXTENT TO WHICH REDRESS PAYMENTS SHOULD BE MADE TO AFFECTED CONSUMERS. REDRESS PAYMENTS WILL BE COMPLETED WITHIN ONE YEAR OF THE CFPB MAKING A DETERMINATION OF NON-OBJECTION TO U.S. BANK'S REDRESS PLAN.

Allegations: ON MAY 10, 2023, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ISSUED A CONSENT ORDER AND ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST MUFG UNION BANK, NATIONAL ASSOCIATION (WHICH MERGED INTO U.S. BANK NATIONAL ASSOCIATION ON MAY 26, 2023) FOR ENGAGING IN DECEPTIVE PRACTICES IN VIOLATION OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT WITH RESPECT TO THE MARKETING AND FULFILLMENT OF CERTAIN RETAIL PRODUCTS AND SERVICES. Status: Final Sanction Detail: ON MAY 8, 2023, MUFG UNION BANK, NATIONAL ASSOCIATION PAID THE CIVIL MONEY PENALTY TO THE OFFICE OF THE COMPTROLLER OF THE CURRENCY. Summary: THE CIVIL MONEY PENALTY HAS BEEN PAID AND APPROPRIATE REMEDIAL ACTIONS ARE BEING TAKEN TO CORRECT THE VIOLATIONS.

Allegations: ON DECEMBER 19, 2023, THE CONSUMER FINANCIAL PROTECTION BUREAU ISSUED A CONSENT ORDER AND ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK NATIONAL ASSOCIATION FOR ENGAGING IN UNFAIR ACTS OR PRACTICES IN VIOLATION OF THE CONSUMER FINANCIAL PROTECTION BUREAU ACT OF 2010 WITH RESPECT TO ITS ADMINISTRATION OF PREPAID DEBIT CARDS THAT HELD UNEMPLOYMENT INSURANCE BENEFITS. Status: Final Sanction Detail: ON DECEMBER 20, 2023, U.S. BANK NATIONAL ASSOCIATION PAID THE $15 MILLION CIVIL MONEY PENALTY TO THE CONSUMER FINANCIAL PROTECTION BUREAU. THE ORDER ALSO REQUIRES U.S. BANK NATIONAL ASSOCIATION TO PROVIDE $5.7 MILLION IN REDRESS TO CONSUMERS. Summary: THE CIVIL MONEY PENALTY HAS BEEN PAID AND APPROPRIATE REMEDIAL ACTIONS ARE BEING TAKEN TO CORRECT THE VIOLATIONS.

Allegations: ON DECEMBER 19, 2023, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ISSUED A CONSENT ORDER AND ASSESSED A $15 MILLION CIVIL MONEY PENALTY AGAINST U.S. BANK NATIONAL ASSOCIATION FOR ENGAGING IN UNFAIR PRACTICES IN VIOLATION OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT WITH RESPECT TO ITS ADMINISTRATION OF PREPAID DEBIT CARDS THAT HELD UNEMPLOYMENT INSURANCE BENEFITS. Status: Final Sanction Detail: ON DECEMBER 13, 2023, U.S. BANK NATIONAL ASSOCIATION PAID THE $15 MILLION CIVIL MONEY PENALTY TO THE OFFICE OF THE COMPTROLLER OF THE CURRENCY. Summary: THE CIVIL MONEY PENALTY HAS BEEN PAID AND APPROPRIATE REMEDIAL ACTIONS ARE BEING TAKEN TO CORRECT THE VIOLATIONS.

Allegations: U.S. BANK MUNICIPAL SECURITIES GROUP, A DIVISION OF U.S. BANK NATIONAL ASSOCIATION ("USBMSG"), IS A REGISTERED MUNICIPAL SECURITIES DEALER AND UNDERWRITER. THE SECURITIES AND EXCHANGE COMMISSION ("SEC") IN 2014 INITIATED THE MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION INITIATIVE ("MCDC"). MCDC REQUIRED UNDERWRITERS OF MUNICIPAL SECURITIES TO SELF-REPORT TRANSACTIONS IN WHICH THE UNDERWRITER FAILED TO CONFIRM THE ACCURACY OF THE ISSUER'S REPRESENTATIONS REGARDING ITS COMPLIANCE WITH PRIOR CONTINUING DISCLOSURE UNDERTAKINGS. USBMSG SELF-REPORTED ONE SUCH INSTANCE. Status: Final Sanction Detail: ON OCTOBER 1, 2015, U.S. BANK PAID A CIVIL MONETARY PENALTY OF $60,000. Summary: USBMSG CONSENTED TO THE SEC'S OFFER OF SETTLEMENT AND THE SEC ISSUED A CEASE AND DESIST ORDER RELATED TO THAT VIOLATION ON SEPTEMBER 30, 2015. USBMSG PAID A CIVIL PENALTY OF $60,000 AND HAS, AMONG OTHER THINGS, AGREED TO RETAIN A CONSULTANT TO REVIEW ITS POLICIES AND PROCEDURES.

Allegations: ON MARCH 19, 2024, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ISSUED AN ADMINISTRATIVE ORDER FINDING THAT U.S. BANK, N.A. ("USBNA") VIOLATED CERTAIN PROVISIONS OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, WHICH REQUIRE A CFTC REGISTRANT TO MAINTAIN ALL WRITTEN COMMUNICATIONS RELATED TO, AND TO PROVIDE DILIGENT SUPERVISION OF, ITS BUSINESS AS A CFTC REGISTRANT. IN ADDITION,THE CFTC FOUND THAT THE USE OF UNAUTHORIZED COMMUNICATION METHODS BY USBNA EMPLOYEES VIOLATED USBNA'S OWN POLICIES AND PROCEDURES, WHICH PROHIBITED SUCH COMMUNICATIONS. Status: Final Sanction Detail: USBNA PAID A FINE OF $6,000,000 ON MARCH 27, 2024, AND AGREED TO COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING THE REVIEW OF USBNA'S SUPERVISORY, COMPLIANCE, AND OTHER POLICIES AND PROCEDURES RELATED TO THE PRESERVATION OF ELECTRONIC COMMUNICATIONS. Summary: THE MONETARY FINE HAS BEEN PAID AND USBNA IS COMPLYING WITH THE ORDERED UNDERTAKINGS.