Wells Fargo Investment Institute, Inc.

Allegations: THE COMPLAINT ALLEGES THAT WELLS FARGO PERSONNEL ENGAGED IN VARIOUS ALLEGEDLY IMPROPER ACTS AND PRACTICES DESIGNED TO MEET SALES GOALS AND QUOTAS, SUCH AS OPENING ACCOUNTS WITHOUT CUSTOMER AUTHORIZATION, MISREPRESENTING THAT CERTAIN PRODUCTS WERE AVAILABLE ONLY IN PACKAGES WITH OTHER PRODUCTS, MISUSING CUSTOMER DATA IN CONNECTION WITH THE FOREGOING, AND NOT DISCLOSING SUCH ALLEGED MISUSE TO CUSTOMERS. THE COMPLAINT ALLEGES THAT CUSTOMERS WERE HARMED BY, AMONG OTHER THINGS, INCURRING UNAUTHORIZED FEES. Status: Final Summary: NOT APPLICABLE.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK, N.A. (WFBNA) CONSENTS TO THE FINDING THAT BETWEEN JANUARY 1, 2008 AND JULY 1, 2015, WFBNA VIOLATED THE SERVICEMEMBER CIVIL RELEIF ACT (SCRA) BY FAILING TO OBTAIN COURT ORDERS PRIOR TO REPOSSESSING SERVICES MEMBER'S AUTOMOBILES. Status: Final Summary: N/A

Allegations: THE COMPLAINT ALLEGES FROM 2009 THROUGH 2013, GENUINE TITLE, LLC PROVIDED WELLS FARGO LOAN OFFICERS MARKETING SERVICES THAT ASSISTED THE LOAN OFFICERS IN GENERATING BUSINESS AND INCREASING THE NUMBER OF LOANS WELLS FARGO ORIGINATED OR FINANCED. THE COMPLAINT ALLEGES THAT UNDER AGREEMENTS OR UNDERSTANDING BETWEEN GENUINE TITLE AND THE LOAN OFFICERS, THE LOAN OFFICERS REFERRED SETTLEMENT SERVICE BUSINESS TO GENUINE TITLE. Status: Final Summary: WELLS FARGO BANK, N.A., NEITHER ADMITS OR DENIES ANY ALLEGATIONS EXCEPT TO ESTABLISH THE COURT'S JURISDICTION OVER WELLS FARGO AND THE SUBJECT MATTER. WELLS FARGO BANK, N.A. AGREES TO THE ENTRY OF THE ORDER IN THE PUBLIC INTEREST.

Allegations: THE UNITED STATES ATTORNEY'S OFFICE FOR THE SOUTHERN DISTRICT OF NEW YORK ALLEGED THAT FROM 2010 THROUGH 2017, WELLS FARGO BANK, N.A. DEFRAUDED 771 COMMERCIAL CUSTOMERS WHO USED THE BANK'S FX SERVICES BY MISREPRESENTING FX PRICING LEVELS AND ENGAGING IN OTHER IMPROPER FX PRICING PRACTICES IN VIOLATION OF THE MAIL FRAUD, WIRE FRAUD, AND BANK FRAUD STATUTES 18 U.S.C. §§ 1341, 1343, 1344. Status: Final Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT, FROM APRIL 2016THROUGH OCTOBER OF 2016, THE FIRM DISTRIBUTED 6,851 ACCOUNT STATEMENTS TO CUSTOMERS CONTAINING VALUATION INFORMATION FORONE OR MORE DIRECT PARTICIPATION PROGRAMS (DPPS) OR REAL ESTATE INVESTMENT TRUSTS (REITS) THAT DID NOT COMPLY WITH NASD RULE2340(C). THE FIRM ALSO FAILED TO ESTABLISH AND MAINTAIN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ENSURE THAT ITSCUSTOMER ACCOUNT STATEMENTS REFLECTED DPP AND REIT PRICES DERIVED FROM A VALUATION METHODOLOGY ALLOWED BY NASD RULE 2340(C). FOR THE SAME REASONS THE FIRM ALSO FAILED TO MAINTAIN ACCURATE BOOKS AND RECORDS VIOLATING FINRA RULES 3110(A) AND (B),4511 AND 2010 Status: Final Sanction Detail: THE FIRM IS ORDERED TO PAY A FINE TO FINRA IN THE AMOUNT OF $300,000, AND, THE FIRM WAS CENSURED BY FINRA. (13) THE FIRMENTERED INTO AN AWC AGREEMENT WITH FINRA ON NOVEMBER 4, 2020, FULLY RESOLVING THIS MATTER, WHICH INCLUDED AN AGREEMENT TOTHE ENTRY OF A CENSURE AGAINST THE FIRM, AND AN AGREEMENT TO PAY A FINE TO FINRA IN THE AMOUNT OF $300,000, AS SET FORTH INTHE AGREEMENT. Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, FAILED TO MAKE ACCURATE ORDER MEMORANDA IN VIOLATION OF RULE 17A-3(A)(6) UNDER THE SECURITIES EXCHANGE ACT OF 1934 AND FINRA RULES 4511 AND 2010, AND TRANSMITTED INACCURATE REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) IN VIOLATION OF FINRA RULES 7450 AND 2010 Status: Final Sanction Detail: THE FIRM PAID A FINE TO FINRA IN THE AMOUNT OF $75,000, AND THE FIRM WAS ALSO CENSURED BY FINRA. Summary: THE FIRM ENTERED INTO AN AWC AGREEMENT WITH FINRA ON NOVEMBER 25, 2020, FULLY RESOLVING THIS MATTER, WHICH INCLUDED AGREEMENT TO THE ENTRY OF A CENSURE AGAINST THE FIRM AND A FINE PAYABLE TO FINRA IN THE AMOUNT OF $75,000. FINRA RECEIVED THE FINE ON DECEMBER 10, 2020.

Allegations: WITHOUT ADMITTING THE ALLEGATIONS, WELLS FARGO BANK, N.A. ("WFBNA") CONSENTED TO A SETTLEMENT IN WHICH IT WAS ALLEGED AND FOUND TO HAVE VIOLATED NFA COMPLIANCE RULE 2-49(A) BY FAILING TO COMMUNICATE WITH A COUNTERPARTY IN A FAIR AND BALANCED MANNER AS REQUIRED UNDER COMMODITY FUTURES TRADING COMMISSION REGULATION 23-433. WFBNA AGREED TO PAY A CIVIL MONEY PENALTY OF $2,500,000.00 TO THE NATIONAL FUTURES ASSOCIATION WITHIN 30 DAYS. Status: Final Sanction Detail: $2,500,000. FINE DUE WITHIN 30 DAYS OF SETTLEMENT AGREEMENT. Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REASONABLY SUPERVISE A FORMER REGISTERED REPRESENTATIVE WHO EXCESSIVELY TRADED EQUITY POSITIONS IN ACCOUNTS BELONG TO AN ELDERLY CUSTOMER. THE FINDINGS STATED THAT THE CUSTOMER WAS 88 YEARS OLD WHEN THE TRADING COMMENCED AND THAT AS A RESULT OF THE EXCESSIVE TRADING SHE PAID AT LEAST $300,000 IN COMMISSIONS AND OTHER FEES. THE FIRM'S COMPUTER PROGRAM FLAGGED THE CUSTOMER'S ACCOUNTS FOR HIGH VELOCITY; HOWEVER, THE FIRM DID NOT REASONABLY ADDRESS THESE FLAGS. FOLLOWING ITS INVESTIGATION, THE FIRM DISCHARGED THE REPRESENTATIVE RESPONSIBLE FOR THE CUSTOMER'S ACCOUNTS. ULTIMATELY, THE FIRM PAID $1 MILLION IN RESTITUTION TO THE CUSTOMER IN SETTLEMENT OF A COMPLAINT THAT SHE FILED REGARDING THE ACTIVITY IN HER ACCOUNTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $175,000. Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO SUPERVISE REPRESENTATIVES' 529 PLAN SHARE-CLASS RECOMMENDATIONS. THE FINDINGS STATED THAT THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) DID NOT REASONABLY ADDRESS THE SHARE-CLASS SUITABILITY FACTORS SPECIFIC TO 529 PLAN INVESTMENTS. THE FIRM'S WSPS FOR 529 PLANS DID NOT SPECIFICALLY ADDRESS THE RELATIONSHIP BETWEEN ACCOUNT BENEFICIARY AGE, THE NUMBER OF YEARS UNTIL FUNDS WOULD BE NEEDED TO PAY QUALIFIED EDUCATION EXPENSES, AND 529 PLAN SHARE-CLASS SUITABILITY. INSTEAD, THEY MERELY REFERENCED SUITABILITY FACTORS GENERALLY APPLICABLE TO ALL INVESTMENT PRODUCTS, SUCH AS FEES AND EXPENSES, INVESTMENT OBJECTIVE AND RISK TOLERANCE. IN ADDITION, THE FIRM'S ELECTRONIC ALERT SYSTEM DID NOT INCLUDE PARAMETERS TO IDENTIFY 529 PLAN SHARE-CLASS RECOMMENDATIONS THAT APPEARED TO BE INCONSISTENT WITH THE AGE OF THE ACCOUNT BENEFICIARY OR THE ACCOUNT'S STATED INVESTMENT HORIZON. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND ORDERED TO PAY $3,367,929, PLUS INTEREST, JOINTLY AND SEVERALLY, IN RESTITUTION TO CUSTOMERS. THE FIRM PROVIDED SUBSTANTIAL ASSISTANCE TO FINRA IN ITS INVESTIGATION. ACCORDINGLY, NO MONETARY SANCTION HAS BEEN IMPOSED. Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO SUPERVISE REPRESENTATIVES' 529 PLAN SHARE-CLASS RECOMMENDATIONS. THE FINDINGS STATED THAT THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) DID NOT REASONABLY ADDRESS THE SHARE-CLASS SUITABILITY FACTORS SPECIFIC TO 529 PLAN INVESTMENTS. THE FIRM'S WSPS FOR 529 PLANS DID NOT SPECIFICALLY ADDRESS THE RELATIONSHIP BETWEEN ACCOUNT BENEFICIARY AGE, THE NUMBER OF YEARS UNTIL FUNDS WOULD BE NEEDED TO PAY QUALIFIED EDUCATION EXPENSES, AND 529 PLAN SHARE-CLASS SUITABILITY. INSTEAD, THEY MERELY REFERENCED SUITABILITY FACTORS GENERALLY APPLICABLE TO ALL INVESTMENT PRODUCTS, SUCH AS FEES AND EXPENSES, INVESTMENT OBJECTIVE AND RISK TOLERANCE. IN ADDITION, THE FIRM'S ELECTRONIC ALERT SYSTEM DID NOT INCLUDE PARAMETERS TO IDENTIFY 529 PLAN SHARE-CLASS RECOMMENDATIONS THAT APPEARED TO BE INCONSISTENT WITH THE AGE OF THE ACCOUNT BENEFICIARY OR THE ACCOUNT'S STATED INVESTMENT HORIZON. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND ORDERED TO PAY $3,367,929, PLUS INTEREST, JOINTLY AND SEVERALLY, IN RESTITUTION TO CUSTOMERS. THE FIRM PROVIDED SUBSTANTIAL ASSISTANCE TO FINRA IN ITS INVESTIGATION. ACCORDINGLY, NO MONETARY SANCTION HAS BEEN IMPOSED. Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THEENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM THAT WASREASONABLY DESIGNED TO SUPERVISE SHORT-TERM TRADING OF UNIT INVESTMENT TRUSTS (UITS). THEFINDINGS STATED THAT THE FIRM DID NOT ESTABLISH A SUPERVISORY SYSTEM THAT WAS REASONABLYDESIGNED TO IDENTIFY EARLY UIT ROLLOVERS. THE FIRM HAD AN AUTOMATED REPORT THAT FLAGGED SALESOF A MUTUAL FUND OR UIT FOLLOWED WITHIN 25 DAYS BY A PURCHASE OF ANY OF THOSE SAME PRODUCTS,AND IN THE ORDINARY COURSE THE FIRM SENT SWITCH LETTERS TO CUSTOMERS WHEN THIS REPORT WASGENERATED. HOWEVER, THAT REPORT DID NOT ACCOUNT FOR THE LENGTH OF TIME A UIT WAS HELD BEFOREIT WAS SOLD. AS A RESULT, THE FIRM DID NOT HAVE ANY AUTOMATED SYSTEM TO IDENTIFY WHEN UITSWERE ROLLED OVER SIGNIFICANTLY IN ADVANCE OF THEIR MATURITY DATE - EVEN THOUGH THE FIRM'SWRITTEN SUPERVISORY PROCEDURES (WSPS) RECOGNIZED THAT UITS SHOULD GENERALLY BE HELD TOMATURITY. AS SUCH, THE FIRM FAILED TO DETECT THAT ON THOUSANDS OF OCCASIONS, ITSREPRESENTATIVES RECOMMENDED POTENTIALLY UNSUITABLE EARLY SERIES-TO-SERIES ROLLOVERS. ONTHOUSANDS OF OTHER OCCASIONS, THE FIRM FAILED TO DETECT THAT ITS REPRESENTATIVES REPEATEDLY RECOMMENDED OTHER POTENTIALLY UNSUITABLE EARLY UIT ROLLOVERS THAT CAUSED CUSTOMERS TO PAY UNNECESSARY SALES CHARGES. COLLECTIVELY, THESE EARLY UIT ROLLOVERS MAY HAVE CAUSED CUSTOMERS TO PAY $375,137.67 IN SALES CHARGES THAT THEY WOULD NOT HAVE INCURRED HAD THEY HELD THE UITS UNTIL THEIR MATURITY DATES. THE FIRM HAS VOLUNTARILY EMPLOYED CORRECTIVE MEASURES TO REVISE ITS PROCEDURES, INCLUDING BY REVISING ITS WSPS AND BY IMPLEMENTING IMPROVED CONTROLS RELEVANT TO ITS UIT BUSINESS, SUCH AS ESTABLISHING AUTOMATED ALERTS TO ASSIST IN IDENTIFYING WHEN REPRESENTATIVES RECOMMEND EARLY UIT ROLLOVERS. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $100,000, AND ORDERED TO PAY $375,137.67, PLUS INTEREST, INRESTITUTION TO CUSTOMERS. THE FIRM PAID THE FINE ON JANUARY 6TH, 2022. Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THEENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM THAT WASREASONABLY DESIGNED TO SUPERVISE SHORT-TERM TRADING OF UNIT INVESTMENT TRUSTS (UITS). THEFINDINGS STATED THAT THE FIRM DID NOT ESTABLISH A SUPERVISORY SYSTEM THAT WAS REASONABLYDESIGNED TO IDENTIFY EARLY UIT ROLLOVERS. THE FIRM HAD AN AUTOMATED REPORT THAT FLAGGED SALESOF A MUTUAL FUND OR UIT FOLLOWED WITHIN 25 DAYS BY A PURCHASE OF ANY OF THOSE SAME PRODUCTS, AND IN THE ORDINARY COURSE THE FIRM SENT SWITCH LETTERS TO CUSTOMERS WHEN THIS REPORT WAS GENERATED. HOWEVER, THAT REPORT DID NOT ACCOUNT FOR THE LENGTH OF TIME A UIT WAS HELD BEFORE IT WAS SOLD. AS A RESULT, THE FIRM DID NOT HAVE ANY AUTOMATED SYSTEM TO IDENTIFY WHEN UITS WERE ROLLED OVER SIGNIFICANTLY IN ADVANCE OF THEIR MATURITY DATE - EVEN THOUGH THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) RECOGNIZED THAT UITS SHOULD GENERALLY BE HELD TO MATURITY. AS SUCH, THE FIRM FAILED TO DETECT THAT ON THOUSANDS OF OCCASIONS, ITS REPRESENTATIVES RECOMMENDED POTENTIALLY UNSUITABLE EARLY SERIES-TO-SERIES ROLLOVERS. ON THOUSANDS OF OTHER OCCASIONS, THE FIRM FAILED TO DETECT THAT ITS REPRESENTATIVES REPEATEDLY RECOMMENDED OTHER POTENTIALLY UNSUITABLE EARLY UIT ROLLOVERS THAT CAUSED CUSTOMERS TO PAY UNNECESSARY SALES CHARGES. COLLECTIVELY, THESE EARLY UIT ROLLOVERS MAY HAVE CAUSED CUSTOMERS TO PAY $2,083,624.66 IN SALES CHARGES THAT THEY WOULD NOT HAVE INCURRED HAD THEY HELD THE UITS UNTIL THEIR MATURITY DATES. THE FIRM HAS VOLUNTARILY EMPLOYED CORRECTIVE MEASURES TO REVISE ITS PROCEDURES, INCLUDING BY REVISING ITS WSPS AND BY IMPLEMENTING IMPROVED CONTROLS RELEVANT TO ITS UIT BUSINESS, SUCH AS ESTABLISHING AUTOMATED ALERTS TO ASSIST IN IDENTIFYING WHEN REPRESENTATIVES RECOMMEND EARLY UIT ROLLOVERS. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $550,000, AND ORDERED TO PAY $2,083,624.66, PLUS INTEREST, INRESTITUTION TO CUSTOMERS. THE FIRM PAID THE FINE ON JANUARY 6TH 2022. Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO STORE RECORDS RELATED TO ITS CUSTOMER IDENTIFICATION PROGRAM (CIP)-AN INTEGRAL PART OF AN ANTI-MONEY LAUNDERING PROGRAM-IN THE REQUIRED NON-ERASABLE AND NON-WRITABLE FORMAT, KNOWN AS "WRITE ONCE, READ MANY" (WORM) FORMAT. THE FINDINGS STATED THAT FIRM PERSONNEL DISCOVERED THAT THE FIRM WAS STORING RECORDS RELATED TO ITS CIP ON A SYSTEM THAT WAS NOT WORM COMPLIANT, AND ADVISED AN INTERNAL WORKING GROUP THAT ADDRESSED BOOKS AND REQUIREMENTS OF THE ISSUE. THE WORKING GROUP CONCLUDED THAT THE ISSUE SHOULD BE ESCALATED TO DETERMINE IF IT NEEDED TO BE REPORTED TO FINRA. THE ISSUE, HOWEVER, WAS NOT ESCALATED TO THE FIRMS' WORKING GROUP THAT CONSIDERED FINRA REPORTING OBLIGATIONS, AND THE FIRM DID NOT REPORT IT TO FINRA OR REMEDIATE IT AT THAT TIME. THE FIRM CONTINUED TO STORE CIP RECORDS ON THE NON-WORM COMPLIANT PLATFORM FOR MORE THAN THREE YEARS. APPROXIMATELY 13 MILLION CIP-RELATED RECORDS, PERTAINING TO APPROXIMATELY 8.2 MILLION CUSTOMERS, WERE STORED ON THE NON-WORM COMPLIANT PLATFORM, WITH APPROXIMATELY 4 MILLION DOCUMENTS HAVING BEEN STORED ON THE FIRM'S NON-WORM COMPLIANT PLATFORM AFTER THE ISSUE WAS DISCOVERED. THEREFORE, THE FIRM VIOLATED EXCHANGE ACT RULE 17A-4(F)(2)(II)(A). IN ADDITION, THE FIRM FAILED TO NOTIFY FINRA, ITS DESIGNATED EXAMINING AUTHORITY, AT LEAST 90 DAYS PRIOR TO USING THE NON-WORM COMPLIANT PLATFORM ON WHICH IT STORED THE CIP-RELATED RECORDS. THEREFORE, THE FIRM VIOLATED EXCHANGE ACT RULES 17A-4(F)(3)(V) AND 17A-4(F)(2)(I). Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $2,250,000, JOINTLY AND SEVERALLY WITH WELLS FARGO CLEARING SERVICES, LLC. WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC CONTRIBUTED $250,000 TO THE PAYMENT OF THE FINE. Summary: THE FIRM ENTERED INTO AN AWC AGREEMENT WITH FINRA ON DECEMBER 6, 2021, FULLY RESOLVING THIS MATTER, WHICH INCLUDED AGREEMENT TO THE ENTRY OF A CENSURE AGAINST THE FIRM AND A FINE PAYABLE TO FINRA. FINE WAS RECEIVED BY FINRA ON DECEMBER 23, 2021.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO STORE RECORDS RELATED TO ITS CUSTOMER IDENTIFICATION PROGRAM (CIP)-AN INTEGRAL PART OF AN ANTI-MONEY LAUNDERING PROGRAM-IN THE REQUIRED NON-ERASABLE AND NON-WRITABLE FORMAT, KNOWN AS "WRITE ONCE, READ MANY" (WORM) FORMAT. THE FINDINGS STATED THAT FIRM PERSONNEL DISCOVERED THAT THE FIRM WAS STORING RECORDS RELATED TO ITS CIP ON A SYSTEM THAT WAS NOT WORM COMPLIANT, AND ADVISED AN INTERNAL WORKING GROUP THAT ADDRESSED BOOKS AND REQUIREMENTS OF THE ISSUE. THE WORKING GROUP CONCLUDED THAT THE ISSUE SHOULD BE ESCALATED TO DETERMINE IF IT NEEDED TO BE REPORTED TO FINRA. THE ISSUE, HOWEVER, WAS NOT ESCALATED TO THE FIRMS' WORKING GROUP THAT CONSIDERED FINRA REPORTING OBLIGATIONS, AND THE FIRM DID NOT REPORT IT TO FINRA OR REMEDIATE IT AT THAT TIME. THE FIRM CONTINUED TO STORE CIP RECORDS ON THE NON-WORM COMPLIANT PLATFORM FOR MORE THAN THREE YEARS. APPROXIMATELY 13 MILLION CIP-RELATED RECORDS, PERTAINING TO APPROXIMATELY 8.2 MILLION CUSTOMERS, WERE STORED ON THE NON-WORM COMPLIANT PLATFORM, WITH APPROXIMATELY 4 MILLION DOCUMENTS HAVING BEEN STORED ON THE FIRM'S NON-WORM COMPLIANT PLATFORM AFTER THE ISSUE WAS DISCOVERED. THEREFORE, THE FIRM VIOLATED EXCHANGE ACT RULE 17A-4(F)(2)(II)(A). IN ADDITION, THE FIRM FAILED TO NOTIFY FINRA, ITS DESIGNATED EXAMINING AUTHORITY, AT LEAST 90 DAYS PRIOR TO USING THE NON-WORM COMPLIANT PLATFORM ON WHICH IT STORED THE CIP-RELATED RECORDS. THEREFORE, THE FIRM VIOLATED EXCHANGE ACT RULES 17A-4(F)(3)(V) AND 17A-4(F)(2)(I). Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $2,250,000, JOINTLY AND SEVERALLY WITH WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC. WELLS FARGO CLEARING SERVICES CONTRIBUTED $2,000,000 TO THE PAYMENT OF THE FINE. Summary: THE FIRM ENTERED INTO AN AWC AGREEMENT WITH FINRA ON DECEMBER 6, 2021, FULLY RESOLVING THIS MATTER, WHICH INCLUDED AGREEMENT TO THE ENTRY OF A CENSURE AGAINST THE FIRM AND A FINE PAYABLE TO FINRA. FINE WAS RECEIVED BY FINRA ON DECEMBER 23, 2021.

Allegations: THE OCC FOUND THAT WELLS FARGO BANK, N.A. ("WFBNA") FAILED TO MAKE ACCEPTABLE SUBSTANTIAL PROGRESS TOWARD CORRECTING PREVIOUSLY IDENTIFIED BSA/AML PROBLEMS RELATING TO DUE DILIGENCE PRACTICES AND CUSTOMER RISK ASSESSMENT IN THE WHOLESALE BANKING GROUP RESULTING IN A VIOLATION OF 12 USC 1818(S); AND CRITICAL INTERNAL CONTROL DEFICIENCIES IN THE WHOLESALE BANKING GROUP'S BSA/AML COMPLIANCE PROGRAM RESULTED IN AN INTERNAL CONTROL PILLAR VIOLATION (12 CFR 21.21(D)(1)). Status: Final Sanction Detail: WELLS FARGO BANK, N.A. BOARD OF DIRECTORS CONSENTED TO THE ISSUANCE OF THE CONSENT ORDER. Summary: WELLS FARGO BANK, N.A. BOARD OF DIRECTORS CONSENTED TO THE ISSUANCE OF THE CONSENT ORDER.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE ORDER TO CEASE AND DESIST AND TO TAKE AFFIRMATIVE ACTION TO TAKE STEPS TO ENSURE THE BANK COMPLIES WITH CONSENT ORDERS ISSUED BY THE OCC AND CFPB, WITHIN SIXTY DAYS, SUBMIT A WRITTEN PLAN TO FURTHER ENHANCE THE EFFECTIVENESS IN CARRYING OUT OVERSIGHT AND GOVERNANCE OF WFC, IMPROVE ITS OVERSIGHT OF SENIOR MANAGEMENT INCLUDING AN EFFECTIVE RISK TOLERANCE PROGRAM AND RISK IDENTIFICATION AND ESCALATION FRAMEWORK. FOLLOWING THE ADOPTION FO THE PLANS AND IMPROVEMENTS, WFC SHALL CONDUCT BY SEPTEMBER 30, 2018 AND INDEPENDENT REVIEW OF THE BOARD'S IMPROVEMENTS, ENHANCEMENTS TO THE FIRM'S COMPLIANCE AND OPERATIONAL RISK MANAGEMENT PROGRAM. WFC MUST CONDUCT A SECOND INDEPENDENT REVIEW INTO WFC'S "BUSINESS-AS-USUAL PRACTICES AND OPERATIONS TO ASSESS THE EFFICACY AND SUSTAINABILITY OF THE IMPROVEMENTS. BOTH REVIEWS MUST BE CONDUCTED BY THIRD PARTY EXPERTS WITH RESULTS SUBMITTED TO THE FEDERAL RESERVE WITHIN 30 DAYS OF COMPLETION OF THE REPORTS. WFC IS RESTRICTED, WITHOUT PRIOR WRITTEN APPOVAL, TO TAKE ANY ACTION THAT WOULD CAUSE THE AVERAGE OF WFC'S TOTAL CONSOLIDATED ASSETS FOR THE CURRENT AND PRECEDING QUARTER TO EXCEED A SPECIFIED LEVEL AS DESCRIBED MORE FULLY IN THE ORDER. Status: Final Sanction Detail: RESTRICTED, WITHOUT PRIOR WRITTEN APPROVAL, FROM EXCEEDING CERTAIN ASSET LEVELS AS DESCRIBED MORE FULLY IN THE ORDER. Summary: N/A

Allegations: WELLS FARGO & COMPANY ENTERED INTO A SETTLEMENT WITH ALL 50 STATE ATTORNEYS GENERAL AND THE DISTRICT OF COLUMBIA REGARDING PREVIOUSLY DISCLOSED RETAIL SALES PRACTICES, AUTO COLLATERAL PROTECTION INSURANCE AND GUARANTEED ASSET/AUTO PROTECTION, AND MORTGAGE INTEREST RATE LOCK MATTERS. UNDER THE TERMS OF THE AGREEMENT, WELLS FARGO AGREED TO PAY A TOTAL OF $575 MILLION TO RESOLVE POTENTIAL CIVIL CLAIMS BY STATE ATTORNEYS GENERAL. Status: Final Sanction Detail: FIRM WILL MAKE PAYMENT UPON RECEIPT AND PROCESSING INSTRUCTIONS. Summary: STATE SETTLEMENT AMOUNT DOCKET/CASE NUMBER: ALASKA $1,486,804.01 ALABAMA $7,945,123.52 ARKANSAS $1,298,019.87 ARIZONA $37,136,571.08 CALIFORNIA $148,733,525.16 18-ST-CV-09856 COLORADO $21,476,334.34 CONNECTICUT $5,242,279.59 DELAWARE $2,007,548.53 DISTRICT OF COLUMBIA $1,112,853.08 FLORIDA $28,301,139.58 GEORGIA $16,346,293.31 HAWAII $1,468,038.75 IDAHO $5,276,628.87 CV01-18-23986 ILLINOIS $10,857,474.49 INDIANA $5,202,676.45 IOWA $6,180,941.33 KANSAS $2,307,874.13 KENTUCKY $3,675,446.17 LOUISIANA $1,911,733.65 MAINE $1,136,559.61 MASSACHUSETTS $6,182,546.05 MARYLAND $7,916,350.19 MICHIGAN $5,235,475.56 MINNESOTA $9,361,299.85 62-CV-18-8322 MISSOURI $5,616,485.55 18AC-CC00516 MISSISSIPPI $2,538,491.41 MONTANA $2,779,651.69 NEBRASKA $5,210,423.09 NEVADA $13,363,512.80 NEW HAMPSHIRE $1,167,689.76 217-2018-CV-00811 NEW JERSEY $16,989,709.60 NEW MEXICO $6,449,106.00 D-101-CV-2018-02395 NEW YORK $11,854,349.87 NORTH CAROLINA $15,174,791.40 NORTH DAKOTA $1,215,310.89 OHIO $2,974,953.32 OKLAHOMA $2,640,251.14 OREGON $9,766,546.95 PENNSYLVANIA $16,526,551.91 RHODE ISLAND $1,216,915.47 PC-2018-9401 SOUTH CAROLINA $6,788,785.83 SOUTH DAKOTA $1,827,596.64 TENNESSEE $4,989,322.01 19C69 TEXAS $47,378,217.69 D-1-GN-18-007683 UTAH $10,232,596.05 VERMONT $1,984,047.03 VIRGINIA $11,546,080.48 WASHINGTON $16,147,093.34 18-2-06490-34 WEST VIRGINIA $1,652,275.25 WISCONSIN $8,565,813.31 WYOMING $1,603,894.35

Allegations: A FORMER AFFILIATE OF WELLS FARGO BANK, N.A. WAS ALLEGED TO HAVE OFFERED CREDIT CARDS TO NEW YORK STATE RESIDENTS SECURED BY RESIDENTIAL REAL ESTATE AND ORIGINATED RESIDENTIAL MORTGAGES IN A MANNER INCONSISTENT WITH NEW YORK LAW. Status: Final Sanction Detail: SANCTION DETAIL: THE BANK AGREED TO RELEASE SECURITY INTERESTS RELATING TO THE CREDIT CARDS SECURED BY RESIDENTIAL PROPERTY IN NEW YORK, PROVIDE INTEREST REFUNDS AND RATE REDUCTION TO SOME BORROWERS, CONSIDER LOAN MODIFICATIONS, AND PAY A PENALTY. Summary: SANCTION DETAIL: THE BANK AGREED TO RELEASE SECURITY INTERESTS RELATING TO THE CREDIT CARDS SECURED BY RESIDENTIAL PROPERTY IN NEW YORK, PROVIDE INTEREST REFUNDS AND RATE REDUCTION TO SOME BORROWERS, CONSIDER LOAN MODIFICATIONS, AND PAY A PENALTY.

Allegations: ON MARCH 30TH, 2023, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "BOARD OF GOVERNORS") ISSUED AN ORDER OF ASSESSMENT OF CIVIL MONEY PENALTY ISSUED UPON CONSENT PURSUANT TO THE FEDERAL DEPOSIT INSURANCE ACT, AS AMENDED (THE "ORDER") IMPOSING A CIVIL MONEY PENALTY ON WELLS FARGO & COMPANY ("WFC"), THE APPLICANT'S PARENT ENTITY, FOR UNSAFE AND UNSOUND PRACTICES RELATING TO FAILURES IN WFC'S RISK-MANAGEMENT AND OVERSIGHT FRAMEWORK FOR IDENTIFYING AND ADDRESSING LEGAL AND COMPLIANCE RISKS. SPECIFICALLY, WFC'S SUBSIDIARY BANK, WELLS FARGO BANK, N.A., (THE "BANK"), PROVIDED A TRADE FINANCE SOFTWARE PLATFORM TO A NON-US BANK, WHICH, DURING THE PERIOD OF DECEMBER 2011 TO DECEMBER 2015, THE NON-US BANK USED TO PROCESS NON-US DOLLAR TRADE FINANCE INSTRUMENTS OUTSIDE THE US FINANCIAL SYSTEM INVOLVING PARTIES IN JURISDICTIONS SUBJECT AT THE TIME TO SANCTIONS REGULATIONS. THE ORDER PROVIDES THAT WFC'S RISK-MANAGEMENT AND OVERSIGHT FRAMEWORK FAILURE TO IDENTIFY AND ADDRESS THE LEGAL AND COMPLIANCE RISKS WITH RESPECT TO THE BANK'S PROVISION OF THE SOFTWARE TO A NONUS BANK CONSTITUTES UNSAFE AND UNSOUND PRACTICES. Status: Final Sanction Detail: THE ORDER REQUIRES WELLS FARGO & COMPANY TO PAY A CIVIL MONEY PENALTY IN AMOUNT OF $67,762,500, WHICH IT PAID ON MARCH 30TH, 2023. Summary: THE BOARD OF GOVERNORS ASSESSED A CIVIL MONEY PENALTY ON WELLS FARGO & COMPANY FOR UNSAFE AND UNSOUND PRACTICES IN RESPECT OF FAILURES IN ITS RISKMANAGEMENT AND OVERSIGHT FRAMEWORK THAT ENABLED WELLS FARGO & COMPANY'S SUBSIDIARY BANK TO PROVIDE A TRADING PLATFORM TO A NON-US BANK THAT ALLOWED THAT BANK TO PROCESS CERTAIN NON-US DOLLAR TRANSACTIONS INVOLVING PARTIES IN JURISDICTIONS SUBJECT TO OFAC REGULATIONS.

Allegations: THE COMPLAINT ALLEGES FROM 2009 THROUGH 2013, GENUINE TITLE, LLC PROVIDED WELLS FARGO LOAN OFFICERS MARKETING SERVICES THAT ASSISTED THE LOAN OFFICERS IN GENERATING BUSINESS AND INCREASING THE NUMBER OF LOANS WELLS FARGO ORIGINATED OR FINANCED. THE COMPLAINT ALLEGES THAT UNDER AGREEMENTS OR UNDERSTANDING BETWEEN GENUINE TITLE AND THE LOAN OFFICERS, THE LOAN OFFICERS REFERRED SETTLEMENT SERVICE BUSINESS TO GENUINE TITLE. Status: Final Sanction Detail: WELLS FARGO IS ORDERED TO DISTRIBUTE AND ACKNOWLEDGE WITHIN 30 DAYS AND FOR FIVE (5) YEARS COPIES OF THE ORDER TO IT'S BOARD MEMBERS, EXECUTIVE OFFICERS, ALL MANAGEMENT PERSONNEL WITHIN ITS RETAIL SALES MORTGAGE ORIGINATION BUSINESS DOWN TO THE LEVEL OF HOME MORTGAGE CONSULTANT. Summary: WELLS FARGO BANK, N.A., NEITHER ADMITS OR DENIES ANY ALLEGATIONS EXCEPT TO ESTABLISH THE BUREAU'S JURISDICTION OVER WELLS FARGO AND THE SUBJECT MATTER.

Allegations: WITHOUT ADMITTING OR DENYING LIABILITY, WELLS FARGO & COMPANY (WF&CO) ENTERED INTO A CONSENT ORDER IN WHICH WF&CO WAS ALLEGED TO HAVE VIOLATED §11-301(2) OF THE MARYLAND SECURITIES ACT, RELATED TO THE CREATION, POOLING, STRUCTURING, SPONSORSHIP, PACKAGING, MARKETING, UNDERWRITING, SALE OR ISSUANCE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES ("RMBS") BETWEEN JANUARY 1, 2005 AND JANUARY 1, 2009. WF&CO AGREED TO PAY RESTITUTION OF $20,000,000 TO THE STATE OF MARYLAND WITHIN THIRTY (30) BUSINESS DAYS. Status: Final Sanction Detail: $20,000,000 RESTITUTION TO BE PAID WITHIN 30 BUSINESS DAYS OF SETTLEMENT AGREEMENT. Summary: N/A

Allegations: THE ALLEGATIONS WERE THAT, IN 2022, WELLS FARGO CLEARING SERVICES, LLC INADVERTENTLY DID NOT CONDUCT A BRANCH INSPECTION OF ONE MAINE BRANCH OFFICE (A REMOTE LOCATION NOT HELD OUT TO THE PUBLIC). THE MAINE SECURITIES ADMINISTRATOR TOOK THE POSITION THAT THIS VIOLATED MAINE'S ORDER 2021-12 AND MAINE OFFICE OF SECURITIES RULE CH. 504 SECTION (7)(4)(B) REGARDING THE ON-SITE BRANCH OFFICE INSPECTION REQUIREMENT. NO CUSTOMER IMPACT. Status: Final Sanction Detail: WELLS FARGO CLEARING SERVICES, LLC MAILED A $5,000 CHECK TO THE STATE OF MAINE ON OR ABOUT AUGUST 31, 2023. Summary: CONDITIONS AND DATES. (THE INFORMATION MUST FIT WITHIN THE SPACE PROVIDED.) WELLS FARGO CLEARING SERVICES, LLC AGREED TO PAY $5,000 TO RESOLVE THE ALLEGATIONS OF A FAILURE TO COMPLY WITH MAINE'S ORDER NO. 2021-12, AN ORDER SUPERSEDING ORDER NO. 2020-45 REGARDING THE RESUMPTION OF ON-SITE BROKER-DEALER INSPECTIONS OF BRANCH OFFICES IN MAINE ("ORDER 2021-12"), AND MAINE OFFICE OF SECURITIES RULE CH. 504 SECTION (7)(4)(B) REGARDING THE ON-SITE BRANCH OFFICE INSPECTION REQUIREMENT. THE MATTER WAS RESOLVED BY CONSENT AND WITH NO FORMAL FINDINGS ISSUED BY THE MAINE OFFICE OF SECURITIES.

Allegations: WITHOUT ADMITTING LIABILITY, THE BANK CONSENTED TO A CIVIL SETTLEMENT AGREEMENT IN WHICH THE US DOJ ALLEGED THE BANK ENGAGED IN VIOLATIONS COVERED UNDER THE FINANCIAL INSTITUTIONS REFORM, RECOVERY AND ENFORCEMENT ACT OF 1989, 12 U.S.C. § 1833A, RELATED TO REPRESENTATIONS, DISCLOSURES OR NON-DISCLOSURES TO RMBS INVESTORS OR THIRD PARTIES THAT WERE PASSED THROUGH TO RMBS INVESTORS. WELLS FARGO BANK, N.A. AGREED TO PAY A CIVIL MONEY PENALTY OF $2,090,000,000 TO THE CIVIL DIVISION OF THE U.S. DEPARTMENT OF JUSTICE WITHIN FIFTEEN (15) DAYS. Status: Final Sanction Detail: $2,090,000,000. FINE DUE WITHIN 15 DAYS OF SETTLEMENT AGREEMENT. Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE BANK CONSENTED TO THE ISSUANCE OF AN ORDER IN WHICH THE OCC FOUND THAT THE BANK FAILED TO IMPLEMENT AND MAINTAIN AN ENTERPRISE-WIDE COMPLIANCE RISK MANAGEMENT PROGRAM COMMENSURATE WITH THE BANK'S SIZE, COMPLEXITY, AND RISK PROFILE. THE OCC FOUND THAT THE DEFICIENCIES IN THE BANK'S ENTERPRISE-WIDE COMPLIANCE RISK MANAGEMENT PROGRAM, WHICH WERE IDENTIFIED DURING THE OCC'S ONGOING SUPERVISION OF THE BANK, CONSTITUTED RECKLESS UNSAFE OR UNSOUND PRACTICES RESULTING IN VIOLATIONS OF THE UNFAIR ACTS OR PRACTICES PROVISION OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT. THE OCC ALSO FOUND THAT DEFICIENCIES IN THE BANK'S AUTOMOBILE COLLATERAL PROTECTION INSURANCE (CPI) PROGRAM AND MORTGAGE INTEREST RATE LOCK EXTENSION FEE PRACTICES CONSTITUTED UNFAIR ACTS OR PRACTICES AND WERE UNSAFE OR UNSOUND. THE ORDER REQUIRES THE BANK TO: (1) MAINTAIN A COMPLIANCE COMMITTEE RESPONSIBLE FOR MONITORING AND OVERSEEING THE BANK'S COMPLIANCE WITH THE PROVISIONS OF THE ORDER; (2) DEVELOP AND EXECUTE A COMPLIANCE RISK MANAGEMENT PLAN, A CONSENT ORDER ACTION PLAN, A STAFFING ASSESSMENT FOR THE COMPLIANCE RISK MANAGEMENT PROGRAM, AND A PLAN TO ENHANCE THE INTERNAL AUDIT PROGRAM WITH RESPECT TO COMPLIANCE; (3) ESTABLISH A COMPREHENSIVE REMEDIATION PROGRAM FOR REMEDIATION ACTIVITIES CONDUCTED BY THE BANK AND ESTABLISH REMEDIATION PLANS ADDRESSING CPI AND MORTGAGE INTEREST RATE LOCK EXTENSION FEES; (4) PAY A CIVIL MONEY PENALTY OF $500,000,000; AND (5) COMPLY WITH VARIOUS REPORTING AND APPROVAL REQUIREMENTS. Status: Final Sanction Detail: $500,000,000.00 FINE Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT OR CONCLUSIONS OF LAW, THE BANK CONSENTED TO THE ISSUANCE OF AN ORDER IN WHICH THE CFPB FOUND THAT THE BANK ENGAGED IN UNFAIR ACTS OR PRACTICES IN VIOLATION OF SECTIONS 1031(C) AND 1036(A)(1)(B) OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010 (CFPA) FOR CERTAIN SPECIFIED ACTS AND PRACTICES RELATED TO: (1) THE BANK'S FAILURE TO FOLLOW THE MORTGAGE-INTEREST-RATE-LOCK PROCESS IT EXPLAINED TO SOME PROSPECTIVE BORROWERS; AND (2) THE BANK'S FORCE-PLACED AUTOMOBILE COLLATERAL PROTECTION INSURANCE (CPI) PROGRAM. IN ADDITION TO ORDERING THE BANK TO STOP ENGAGING IN THE SPECIFIED ACTS AND PRACTICES, THE ORDER FURTHER REQUIRES THE BANK TO: (1) MAINTAIN A COMPLIANCE COMMITTEE RESPONSIBLE FOR MONITORING AND OVERSEEING THE BANK'S COMPLIANCE WITH THE PROVISIONS OF THE ORDER; (2) SUBMIT AN ACCEPTABLE ENTERPRISE-WIDE COMPLIANCE RISK MANAGEMENT PLAN DESIGNED TO ENSURE THE BANK'S ACTS AND PRACTICES COMPLY WITH FEDERAL CONSUMER FINANCIAL LAW AND THE TERMS OF THE ORDER, A STAFFING ASSESSMENT FOR THE COMPLIANCE RISK MANAGEMENT PROGRAM, AND A PLAN TO ENHANCE THE INTERNAL AUDIT PROGRAM WITH RESPECT TO COMPLIANCE; (3) ESTABLISH A COMPREHENSIVE REMEDIATION PROGRAM FOR REMEDIATION ACTIVITIES CONDUCTED BY THE BANK AND ESTABLISH REMEDIATION PLANS ADDRESSING THE CPI AND MORTGAGE-INTEREST-RATE-LOCK FINDINGS IN THE ORDER; (4) PAY A CIVIL MONEY PENALTY OF $1 BILLION, FOR WHICH ONLY $500 MILLION MUST BE PAID TO THE CFPB AS THE CFPB IS TREATING THE PAYMENT OF THE $500 MILLION OCC PENALTY AS PARTIAL SATISFACTION OF THE PENALTY; AND (5) COMPLY WITH VARIOUS REPORTING AND APPROVAL REQUIREMENTS. Status: Final Sanction Detail: $500,000,000. FINE Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK, N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT ITS COMMUNITY BANK GROUP HAD UNSAFE OR UNSOUND PRACTICES IN RISK MANAGEMENT AND OVERSIGHT OF SALES PRACTICES, AND UNSAFE OR UNSOUND SALES PRACTICES BY SELLING UNWANTED DEPOSIT OR CREDIT CARD ACCOUNTS, THE UNAUTHORIZED OPENING OF SUCH ACCOUNTS, THE TRANSFER OF FUNDS TO UNAUTHORIZED ACCOUNTS, AND UNAUTHORIZED CREDIT INQUIRIES TO OPEN THE ACCOUNTS. Status: Final Sanction Detail: FINE PAID OF $35,000,000.00 Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK, N.A. (WFBNA) CONSENTS TO THE FINDING THAT BETWEEN 2007 AND 2014, WFBNA FAILED TO ACCURATELY DISCLOSE SOME SERVICE MEMBER'S MILITARY STATUS IN AFFIDAVITS FILED IN EVICTION PROCEEDINGS AND BETWEEN 2006 AND 2011, FAILED TO OBTAIN COURT ORDERS PRIOR TO REPOSSESING SERVICES MEMBER'S AUTOMOBILES. Status: Final Sanction Detail: $20,000,000.00 FINE PAID Summary: N/A

Allegations: THE MASSACHUSETTS SECURITIES DIVISION ALLEGED CERTAIN WFCS SUPERVISORS REQUIRED TO BE REGISTERED IN MASSACHUSETTS AND WFCS AGENTS HAD A LAPSE IN MASSACHUSETTS REGISTRATION FOR SOME PERIOD DURING THE RELEVANT TIME PERIOD OF JANUARY 1, 2016 TO JUNE 28, 2018. Status: Final Sanction Detail: WFCS NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS OR CONCLUSIONS OF LAW CONTAINED IN THE ADMINISTRATIVE CONSENT ORDER, AND CONSENTED TO THE ENTRYOF THE ORDER BY THE DIVISION. WFCS ALSO AGREED TO (1) CEASE AND DESIST, (2) CENSURE BY THE DIVISION, (3) ADDITIONAL UNDERTAKINGS, AND (4) PAY THE DIVISION AN ADMINISTRATIVE FINE IN THE AMOUNT OF $450,000. Summary: N/A

Allegations: WITHOUT ADMITTING LIABILITY, THE BANK CONSENTED TO CONSENT AGREEMENTS IN WHICH THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ALLEGED THE BANK ENGAGED IN (1) UNSAFE OR UNSOUND PRACTICES RELATED TO LOSS MITIGATION ACTIVITIES AND INADEQUATE INDEPENDENT RISK MANAGEMENT AND INTERNAL AUDIT OF THE LOSS MITIGATION AND (2) VIOLATIONS COVERED UNDER THE 2018 CONSENT ORDER, AA-EC-2018-15. WELLS FARGO BANK, N.A. AGREED TO PAY A CIVIL MONEY PENALTY OF $250,000,000. TO THE OCC UPON ACCEPTANCE OF THE CONSENT AGREEMENT AND WITHIN 150 DAYS PROVIDE THE OCC EXAMINER-IN-CHARGE A WRITTEN ACCEPTABLE ACTION PLAN FOR REMEDIAL ACTIONS UNDER THE AGREEMENT. Status: Final Sanction Detail: $250,000,000. PAID IMMEDIATELY UPON CONSENT AGREEMENT. WFBNA SHALL CREATE A WRITTEN ACTION PLAN FOR REMEDIAL ACTIONS REQUIRED UNDER THE CONSENT AGREEMENT. Summary: N/A

Allegations: THE CALIFORNIA DEPARTMENT OF INSURANCE FILED A DISCIPLINARY ACTION FOR ALLEGED IMPROPER SALES PRACTICES BETWEEN 2008 AND 2016 CONCERNING THE BANK'S ONLINE INSURANCE REFERRAL PROGRAM FOR RENTERS AND SIMPLIFIED-ISSUE TERM LIFE INSURANCE. THE INSURANCE PRODUCTS WERE OFFERED BY REFERRAL THROUGH THIRD-PARTY CARRIERS AMERICAN MODERN INSURANCE GROUP, ASSURANT, GREAT WEST FINANCIAL, AND PRUDENTIAL INSURANCE COMPANY. THE CALIFORNIA DEPARTMENT OF INSURANCE ALLEGES THAT WELLS FARGO'S ACTIONS ARE GROUNDS FOR SUSPENDING OR REVOKING THE INSURANCE LICENSES FOR WELLS FARGO BANK, N.A. AND WELLS FARGO INSURANCE, INC. Status: Final Sanction Detail: $5,000,000 OF THE PENALTY SHALL BE PAID WITHIN 30 DAYS OF THE EFFECTIVE DATE, AND $345,816 WILL BE TO COVER ANY AND ALL ATTORNEY FEES, COSTS AND/OR EXPENSES RECOVERABLE. AND THE REMAINING $5,000,000 SHALL BE PAYABLE ONLY IF, AFTER A PERIOD OF NO LESS THAN TWO YEARS FOLLOWING THE LAST OF THE RESPECTIVE EXPIRATION DATES OF ITS LICENSES, WELLS FARGO FILES AN APPLICATION WITH THE DEPARTMENT FOR REISSUANCE OF EITHER OF ITS LICENSES, OR APPLIES FOR ANY LICENSE, AND THE INSURANCE COMMISSIONER GRANTS ANY SUCH LICENSES. Summary: N/A

Allegations: WITHOUT ADMITTING LIABILITY, WELLS FARGO & COMPANY (WF&CO) CONSENTED TO A SETTLEMENT AGREEMENT IN WHICH THE OFFICE OF ATTORNEY GENERAL, STATE OF NEW YORK (OAG), ALLEGED WF&CO ENGAGED IN VIOLATIONS OF NY GENERAL BUSINESS LAW, § 352 ET SEQ., EXECUTIVE LAW § 63(12), AND THE COMMON LAW OF THE STATE OF NY, RELATED TO REPRESENTATIONS TO INVESTORS. WELLS FARGO & COMPANY AGREED TO PAY A CIVIL MONEY PENALTY OF $65,000,000. TO THE OAG WITHIN TEN (10) BUSINESS DAYS. Status: Final Sanction Detail: $65,000,000. FINE PAID WITHIN 10 BUSINESS DAYS OF SETTLEMENT AGREEMENT. Summary: N/A

Allegations: WITHOUT ADMITTING LIABILITY, WELLS FARGO & COMPANY (WFC) CONSENTED TO A SETTLEMENT AGREEMENT WITH THE ILLINOIS ATTORNEY GENERAL'S OFFICE IN WHICH WFC AGREED TO PAY $17.25MM IN RESTITUTION TO DESIGNATED ILLINIOIS STATE PENSIONS TO RESOLVE AN INVESTIGATION OF . WELLS FARGO MORTGAGE - RELATED SECURITIZATIONS ISSUED BEFORE JANUARY 1, 2009. Status: Final Sanction Detail: $17,250,000. RESTITUTION PAID WITHIN 10 BUSINESS DAYS OF SETTLEMENT AGREEMENT. Summary: N/A

Allegations: THE OCC ALLEGED WELLS FARGO BANK, N.A. ENGAGED IN UNFAIR BILLING AND DECEPTIVE MARKETING PRACTICES WITH REGARD TO IDENTITY PROTECTION AND DEBT CANCELLATION PRODUCTS THAT RESULTED IN VIOLATIONS OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE OCC FINDINGS, WELLS FARGO BANK, N.A. ENTERED INTO A STIPULATION AND CONSENT TO THE ISSUANCE OF A CONSENT ORDER AND A CONSENT ORDER PURSUANT TO WHICH WELLS FARGO BANK, N.A. WAS REQUIRED TO CEASE AND DESIST FROM VIOLATION OF SECTION 5 OF THE FTC ACT, PAY A CIVIL MONEY PENALTY OF $4,000,000 (PAID), MAKE REIMBURSEMENTS TO CONSUMERS AFTER A PLAN WAS DEVELOPED, AND ADDRESS MANAGEMENT OF THIRD-PARTIES PROVIDING SERVICES TO CONSUMERS. Summary: SEE SANCTION DETAILS IN 12B.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK, N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT ITS COMMUNITY BANK GROUP ENGAGED IN UNFAIR AND ABUSIVE PRACTICES BY OPENING DEPOSIT ACCOUNTS, TRANSFERRING FUNDS BETWEEN ACCOUNTS, APPLYING FOR CREDIT CARDS, ISSUING DEBIT CARDS AND ENROLLING CUSTOMERS IN ON-LINE BANKING SERVICES WITHOUT THE CUSTOMERS' CONSENT. Status: Final Sanction Detail: 100,000,000.00 FINE PAID Summary: N/A

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK, N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT UNDER CERTAIN SCENARIOS AND IN CERTAIN TIMEFRAMES ITS EDUCATION FINANCIAL SERVICES BUSINESS (EFS)ALLOCATED PARTIAL PAYMENTS, AGGREGATED PARTIAL BUSINESS (EFS)ALLOCATED PARTIAL PAYMENTS, AGGREGATED PARTIAL PAYMENTS, AND CHARGED LATE FEES IN WAYS THAT WERE ALLEGED TO BE UNLAWFUL. Status: Final Sanction Detail: $3,600,000.00 FINE PAID Summary: N/A

Allegations: THE CFPB ALLEGED THAT CERTAIN OF THE BANK'S AUTO LOAN SERVICING, MORTGAGE LOAN SERVICING, AND CONSUMER DEPOSIT ACCOUNT PRACTICES WERE UNFAIR, AND THAT ONE CONSUMER DEPOSIT ACCOUNT PRACTICE WAS DECEPTIVE, AS FURTHER DESCRIBED IN THE CONSENT ORDER. Status: Final Sanction Detail: PENALTY PAID 12/27/2022. REMEDIATION TO CUSTOMERS AND CERTAIN PROCESS CHANGES ARE IN PROCESS, AS FURTHER DESCRIBED IN THE ORDER. Summary: THE ORDER IS FINAL AND THE PENALTY HAS BEEN PAID.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION (SEC) ALLEGED WELLS FARGO BANK, N.A. MUNICIPAL PRODUCTS GROUP (WFBNA MPG) CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN WFBNA MPG OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE SEC ALLEGES WFBNA MPG VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933. Status: Final Sanction Detail: THIS ACTION RESULTED FROM A VOLUNTARY SELF-REPORT SUBMITTED TO THE SEC BY WELLS FARGO BANK, N.A. MUNICIPAL PRODUCTS GROUP PURSUANT TO THE SEC'S MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION INITIATIVE ("MCDC"); HTTPS://WWW.SEC.GOV/DIVISIONS/ENFORCE;MUNICIPALITIES-CONTINUING-DISCLOSURE-COOPERATION-INITIATIVE.SHTML). STANDARD MCDC SETTLEMENT TERMS AS DESCRIBED IN THE SEC'S MCDC WEB PAGE WERE IMPOSED. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS OR VIOLATIONS OF SECURITIES LAWS OR RULES, WELLS FARGO BANK, N.A. MUNICIPAL PRODUCTS GROUP AGREES TO THE OFFER OF SETTLEMENT AND THIS ORDER.

Allegations: SEC ADMIN RELEASE 33-10511; 34-83508; IA RELEASE 4947, JUNE 25, 2018: THE SECURITIES AND EXCHANGE COMMISSION (COMMISSION) DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 (SECURITIES ACT), SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT), AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AGAINST WELLS FARGO ADVISORS, LLC. FROM AT LEAST JANUARY 2009 THROUGH JUNE 2013, CERTAIN REGISTERED REPRESENTATIVES AT WELLS FARGO ADVISORS, LLC (WFA) AND ITS PREDECESSOR WELLS FARGO INVESTMENTS, LLC (WFI) IMPROPERLY SOLICITED CUSTOMERS TO REDEEM THEIR MARKET-LINKED INVESTMENTS (MLI) EARLY AND PURCHASE NEW MLIS WITHOUT ADEQUATE ANALYSIS OR CONSIDERATION OF THE SUBSTANTIAL COSTS ASSOCIATED WITH SUCH TRANSACTIONS. AN MLI IS A FIXED MATURITY FINANCIAL PRODUCT WHOSE INTEREST IS DETERMINED BY THE PERFORMANCE OF A REFERENCE ASSET OR MARKET MEASURE SUCH AS AN EQUITY OR COMMODITY INDEX OVER THE TERM OF THE PRODUCT. MLIS HAVE LIMITED LIQUIDITY AND SIGNIFICANT UPFRONT FEES, AND ACCORDINGLY WFA CONSIDERED THEM TO BE PRODUCTS INTENDED TO BE HELD TO MATURITY AND IN 2011 IMPLEMENTED A POLICY PROHIBITING REPRESENTATIVES FROM ENGAGING IN "SHORT-TERM TRADING" OR "FLIPPING" OF MLIS. NOTWITHSTANDING WFA'S INTERNAL GUIDANCE AND POLICY, AND DESPITE THE ADVERSE ECONOMIC CONSEQUENCES TO WFA CUSTOMERS, CERTAIN WFA REPRESENTATIVES DID NOT REASONABLY INVESTIGATE OR UNDERSTAND THE SIGNIFICANT COSTS OF MLI EXCHANGES. NEVERTHELESS, THEY RECOMMENDED TO THEIR CUSTOMERS THAT THEY REDEEM THEIR MLIS EARLY, TYPICALLY TO REALIZE PROFITS, AND TO USE THE PROCEEDS FROM THOSE REDEMPTIONS TO PURCHASE NEW MLIS. SUPERVISORS ROUTINELY APPROVED THE RECOMMENDATIONS OR THE EXCHANGES. THIS PRACTICE CAUSED CERTAIN WFA CUSTOMERS TO INCUR SIGNIFICANT COSTS AND IMPAIRED THE CUSTOMERS' ABILITY TO ACHIEVE THEIR INVESTMENT OBJECTIVES. AS A CONSEQUENCE, WFA OBTAINED COMMISSIONS BY MEANS OF RECOMMENDATIONS THAT CONTAINED IMPLIED REPRESENTATIONS THAT WFA PERSONNEL HAD FORMED A REASONABLE BASIS FOR THE RECOMMENDATIONS WHEN THEY HAD NOT, IN FACT, DONE SO. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, WFA WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. Status: Final Sanction Detail: WFA IS CENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT, AND SHALL PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL MONETARY PENALTY TOTALING $5,108,441.27. Summary: IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT (THE OFFER) WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933, SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER (ORDER). AS A RESULT OF THE CONDUCT DESCRIBED, WFA WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN WFA'S OFFER. ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIES ACT, SECTION 15(B) OF THE EXCHANGE ACT, AND SECTION 203(E) OF THE ADVISERS ACT IT IS HEREBY ORDERED THAT WFA IS CENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT, AND SHALL PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL MONETARY PENALTY TOTALING $5,108,441.27 AS FOLLOWS: WFA SHALL PAY DISGORGEMENT OF $930,377, WHICH REPRESENTS THE COMMISSIONS WFA EARNED ON REPRESENTATIVES RECURRENT MLI EXCHANGES BETWEEN JANUARY 1, 2009 AND AUGUST 31, 2012, PREJUDGMENT INTEREST THEREON OF $178,064.27, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $4,000,000, CONSISTENT WITH THE PROVISIONS OF THE ORDER.

Allegations: THE CFTC FOUND THAT BETWEEN MARCH 1, 2013 AND NOVEMBER 13, 2015, EVERY LARGE TRADER REPORT ("LTR") SUBMITTED BY WELLS FARGO BANK, N.A. FAILED TO MEET THE PART 20 REQUIREMENTS. LTRS SUBMITTED BY THE BANK OMITTED REQUIRED DATA ELEMENTS AND REPORTED CERTAIN DATA IN A MANNER THAT DID NOT CONFORM TO THE SPECIFICATIONS REQUIRED BY THE CFTC. ACCORDINGLY, THE BANK VIOLATED SECTION 4S(F)(1)(A) OF THE COMMODITY EXCHANGE ACT, 7 U.S.C. SEC. 6S(F)(1)(A) (2012), AND REGULATIONS 20.4 AND 20.7, 17 C.F.R. SECS. 20.4 AND 20.7 (2015). WITHOUT ADMITTING OR DENYING THE FINDINGS, THE BANK CONSENTED TO ENTRY OF THE CFTC'S ORDER. Status: Final Sanction Detail: $400,000.00 FINE PAID Summary: N/A

Allegations: THE CFTC FOUND THAT WELLS FARGO BANK, N.A. (WFBNA) MISPRICED A FOREIGN EXCHANGE TRANSACTION EXECUTED ON BEHALF OF A COUNTERPARTY IN AUGUST 2014, BECAUSE WFBNA DID NOT HAVE A SYSTEM IN PLACE TO ACCURATELY TRACK TRADES USED TO FILL A COUNTERPARTY'S ORDERS AND DID NOT IMPLEMENT PROCEDURES DESIGNED TO ENSURE THAT ACCURATE INFORMATION WAS PROVIDED TO THE COUNTERPARTY. ACCORDINGLY, THE CFTC FOUND THAT THE BANK VIOLATED SECTION 4S(H)(1)(B) AND (3)(C) OF THE COMMODITY EXCHANGE ACT, 7 U.S.C. SEC. 6S(H)(1)(B) AND (3)(C) (2012), AND REGULATIONS 23.4.02(A)(1)(I) AND (2) AND 23.433, 17 C.F.R. SECS. 23.402(A)(1)(I) AND (2) AND 23.433 (2019). WITHOUT ADMITTING OR DENYING THE FINDINGS, WFBNA CONSENTED TO ENTRY OF THE CFTC'S ORDER. Status: Final Sanction Detail: MONETARY FINE PAID OF $10,000,000 Summary: N/A

Allegations: THE SECURITIES AND EXCHANGE COMMISSION (SEC) CHARGED WELLS FARGO CLEARING SERVICES, LLC AND WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC WITH WILLFULLY VIOLATING SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AND RULE 206(4)-7 THEREUNDER, FAILING REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT AND FAILING REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT). Status: Final Sanction Detail: THE CIVIL PENALTY WILL BE PAID OUT WITHIN THE TIMELINE SPECIFIED BY THE ORDER. Summary: THE COMMISSION FOUND THAT, FROM APRIL 2012 THROUGH SEPTEMBER 2019, THE FIRMS RECOMMENDED THAT MANY RETAIL INVESTMENT ADVISORY CLIENTS AND BROKERAGE CUSTOMERS BUY AND HOLD SINGLE-INVERSE EXCHANGE-TRADED FUNDS (ETFS) WITHOUT HAVING ADEQUATE COMPLIANCE POLICIES AND PROCEDURES AND WITHOUT PROVIDING FINANCIAL ADVISORS PROPER TRAINING AND SUPERVISION OF SINGLE-INVERSE ETFS. THE COMMISSION FOUND THAT, AS A RESULT, CERTAIN INVESTMENT ADVISER REPRESENTATIVES AND REGISTERED REPRESENTATIVES MADE UNSUITABLE RECOMMENDATIONS TO CERTAIN CLIENTS. THE COMMISSION FOUND THAT THE FIRMS WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, FAILED REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT AND FAILED REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. THE FIRMS CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE ORDER, TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, (B) BE CENSURED, AND (C) JOINTLY AND SEVERALLY PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $35,000,000.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION (SEC) CHARGED WELLS FARGO CLEARING SERVICES, LLC AND WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC WITH WILLFULLY VIOLATING SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AND RULE 206(4)-7 THEREUNDER, FAILING REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT AND FAILING REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT). Status: Final Sanction Detail: THE CIVIL PENALTY WILL BE PAID OUT WITHIN THE TIMELINE SPECIFIED BY THE ORDER Summary: THE COMMISSION FOUND THAT, FROM APRIL 2012 THROUGH SEPTEMBER 2019, THE FIRMS RECOMMENDED THAT MANY RETAIL INVESTMENT ADVISORY CLIENTS AND BROKERAGE CUSTOMERS BUY AND HOLD SINGLE-INVERSE EXCHANGE-TRADED FUNDS (ETFS) WITHOUT HAVING ADEQUATE COMPLIANCE POLICIES AND PROCEDURES AND WITHOUT PROVIDING FINANCIAL ADVISORS PROPER TRAINING AND SUPERVISION OF SINGLE-INVERSE ETFS. THE COMMISSION FOUND THAT, AS A RESULT, CERTAIN INVESTMENT ADVISER REPRESENTATIVES AND REGISTERED REPRESENTATIVES MADE UNSUITABLE RECOMMENDATIONS TO CERTAIN CLIENTS. THE COMMISSION FOUND THAT THE FIRMS WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, FAILED REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT AND FAILED REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. THE FIRMS CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE ORDER, TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, (B) BE CENSURED, AND (C) JOINTLY AND SEVERALLY PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $35,000,000.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION (SEC) ALLEGED THAT WELLS FARGO CLEARING SERVICES, LLC (THE FIRM), IN CONNECTION WITH THE FIRM'S FAILURE TO TIMELY FILE CERTAIN SUSPICIOUS ACTIVITY REPORTS ("SARS"), WILLFULLY VIOLATED SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-8 THEREUNDER. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE ORDER, WITH THE EXCEPTION OF THE SEC'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS, THE FIRM CONSENTED TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8 PROMULGATED THEREUNDER, (B) BE CENSURED, AND (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $7,000,000. THE FIRM PAID THE CIVIL PENALTY ON OR ABOUT JUNE 2, 2022 Summary: ON MAY 20, 2022, THE SEC ANNOUNCED THAT THE FIRM AGREED TO A SETTLEMENT OF ALLEGATIONS THAT, IN CONNECTION WITH THE FIRM'S FAILURE TO TIMELY FILE CERTAIN SARS BETWEEN APRIL 2017 AND OCTOBER 2021, IT WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8 THEREUNDER. WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE ORDER, WITH THE EXCEPTION OF THE SEC'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS, THE FIRM CONSENTED TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8 PROMULGATED THEREUNDER, (B) BE CENSURED, AND (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $7,000,000. THE FIRM PAID THE CIVIL PENALTY ON OR ABOUT JUNE 2, 2022

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT WELLS FARGO CLEARING SERVICES, LLC, WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC, AND THEIR PREDECESSOR FIRMS (COLLECTIVELY, "WELLS FARGO" OR THE "FIRM") OVERCHARGED APPROXIMATELY 10,945 ADVISORY ACCOUNTS OF ADVISORY CLIENTS OPENED THROUGH 2014 MORE THAN $26.8 MILLION IN ADVISORY FEES FROM AT LEAST 2002 THROUGH DECEMBER 2022 AND FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE OVERBILLING IN WILLFUL VIOLATION OF SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AND RULE 206(4)-7 THEREUNDER. SPECIFICALLY, FROM AT LEAST 2002 THROUGH 2014, CERTAIN INVESTMENT ADVISER REPRESENTATIVES FROM WELLS FARGO AND ITS PREDECESSOR FIRMS AGREED TO REDUCE THE FIRMS' STANDARD, PRE-SET ADVISORY FEE RATE FOR CERTAIN CLIENTS AT THE TIME THESE CLIENTS AGREED TO OPEN ACCOUNTS. THE REPRESENTATIVES MADE HANDWRITTEN OR TYPED CHANGES ON THE CLIENTS' STANDARD INVESTMENT ADVISORY AGREEMENTS THAT REFLECTED THE REDUCED FEE RATE. HOWEVER, IN CERTAIN INSTANCES, THE ACCOUNT PROCESSING EMPLOYEES AT WELLS FARGO AND ITS PREDECESSOR FIRMS FAILED TO ENTER THE AGREED-UPON REDUCED ADVISORY FEE RATE INTO THE FIRMS' BILLING SYSTEMS WHEN SETTING UP THE CLIENTS' ACCOUNTS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO AGREED TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, (B) BE CENSURED, AND (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $35,000,000. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: ON AUGUST 25, 2023, THE SEC ENTERED INTO A SETTLEMENT ORDER WITH WELLS FARGO TO SETTLE AN ADMINISTRATIVE ACTION WHICH ALLEGED THAT WELLS FARGO OVERCHARGED APPROXIMATELY 10,945 ADVISORY ACCOUNTS OF ADVISORY CLIENTS OPENED THROUGH 2014 MORE THAN $26.8 MILLION IN ADVISORY FEES FROM AT LEAST 2002 THROUGH DECEMBER 2022 AND FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE OVERBILLING IN WILLFUL VIOLATION OF SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AND RULE 206(4)-7 THEREUNDER. SPECIFICALLY, FROM AT LEAST 2002 THROUGH 2014, CERTAIN INVESTMENT ADVISER REPRESENTATIVES FROM WELLS FARGO AND ITS PREDECESSOR FIRMS AGREED TO REDUCE THE FIRMS' STANDARD, PRE-SET ADVISORY FEE RATE FOR CERTAIN CLIENTS AT THE TIME THESE CLIENTS AGREED TO OPEN ACCOUNTS. THE REPRESENTATIVES MADE HANDWRITTEN OR TYPED CHANGES ON THE CLIENTS' STANDARD INVESTMENT ADVISORY AGREEMENTS THAT REFLECTED THE REDUCED FEE RATE. HOWEVER, IN CERTAIN INSTANCES, THE ACCOUNT PROCESSING EMPLOYEES AT WELLS FARGO AND ITS PREDECESSOR FIRMS FAILED TO ENTER THE AGREED-UPON REDUCED ADVISORY FEE RATE INTO THE FIRMS' BILLING SYSTEMS WHEN SETTING UP THE CLIENTS' ACCOUNTS. IN 2022 AND 2023, THE FIRM CORRECTED THE ADVISORY FEES TO BE CHARGED TO THE ACCOUNTS AND ISSUED PAYMENTS FOR THE OVERCHARGED ADVISORY FEES, PLUS INTEREST, TO THE AFFECTED ACCOUNTHOLDERS. WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO AGREED TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, (B) BE CENSURED, AND (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $35,000,000. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED, IN CONNECTION WITH THE BROKER-DEALER OFF-CHANNEL COMMUNICATIONS INITIATIVE, THAT WELLS FARGO SECURITIES, LLC, WELLS FARGO CLEARING SERVICES, LLC, AND WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC (COLLECTIVELY, "WELLS FARGO") FAILED TO (1) MAINTAIN AND PRESERVE OFF-CHANNEL COMMUNICATIONS RELATED TO THE BUSINESS OF THE BROKER-DEALERS OPERATED BY WELLS FARGO, IN WILLFUL VIOLATION OF SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-4(B)(4) THEREUNDER; AND (2) REASONABLY SUPERVISE THEIR EMPLOYEES WITH A VIEW TO PREVENTING OR DETECTING CERTAIN OF THEIR EMPLOYEES' AIDING AND ABETTING VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER, WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. Status: Final Sanction Detail: WELLS FARGO ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED THEIR CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS AND AGREED TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER, (B) BE CENSURED, (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $125,000,000, AND (D) COMPLY WITH CERTAIN UNDERTAKINGS RELATED TO RETENTION OF ELECTRONIC COMMUNICATIONS. Summary: ON AUGUST 8, 2023, THE SEC ENTERED INTO A SETTLEMENT ORDER WITH WELLS FARGO TO SETTLE AN ADMINISTRATIVE ACTION, IN CONNECTION WITH THE BROKER-DEALER OFF-CHANNEL COMMUNICATIONS INITIATIVE, WHICH ALLEGED THAT WELLS FARGO FAILED TO (1) MAINTAIN AND PRESERVE OFF-CHANNEL COMMUNICATIONS RELATED TO THE BUSINESS OF THE BROKER-DEALERS OPERATED BY WELLS FARGO, IN WILLFUL VIOLATION OF SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-4(B)(4) THEREUNDER; AND (2) REASONABLY SUPERVISE THEIR EMPLOYEES WITH A VIEW TO PREVENTING OR DETECTING CERTAIN OF THEIR EMPLOYEES' AIDING AND ABETTING VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER, WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. WELLS FARGO ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED THEIR CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS AND AGREED TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER, (B) BE CENSURED, (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $125,000,000, AND (D) COMPLY WITH CERTAIN UNDERTAKINGS RELATED TO RETENTION OF ELECTRONIC COMMUNICATIONS. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ENTERED INTO A SETTLEMENT ORDER ("ORDER") WITH WELLS FARGO SECURITIES, LLC ("WFS") AND WELLS FARGO BANK NA ("WFB" AND COLLECTIVELY WITH WFS, THE "RESPONDENTS") TO SETTLE AN ADMINISTRATIVE ACTION CONCERNING (A) WFB'S FAILURE TO MAINTAIN REQUIRED RECORDS IN VIOLATION OF SECTIONS 4S(F)(1)(C) AND 4S(G)(1) AND (3) OF THE COMMODITY EXCHANGE ACT ("ACT") AND REGULATIONS 23.201(A) AND 23.202(A)(1) AND (B)(1); (B) WFS'S FAILURE TO KEEP REQUIRED RECORDS IN VIOLATION OF SECTION 4G OF THE ACT AND REGULATION 1.35; (C) RESPONDENTS' FAILURE TO KEEP RECORDS IN THE REQUIRED MANNER IN VIOLATION OF REGULATION 1.31; (D) WFB'S FAILURE TO SUPERVISE DILIGENTLY IN VIOLATION OF SECTIONS 4S(H)(1)(B) OF THE ACT AND REGULATION 23.602(A); AND (E) WFS'S FAILURE TO DILIGENTLY SUPERVISE IN VIOLATION OF REGULATION 166.3. Status: Final Sanction Detail: THE RESPONDENTS ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED THEIR CONDUCT VIOLATED THE ACT AND REGULATIONS AND CONSENTED TO: (A) THE ENTRY OF THE CFTC'S FINDINGS; (B) HAVE WFB CEASE AND DESIST FROM VIOLATING SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE ACT, AND REGULATIONS 1.31, 23.201(A), 23.202(A)(1) AND (B)(1) AND 23.602(A) AND TO HAVE WFS CEASE AND DESIST FROM VIOLATING SECTION 4G OF THE ACT AND REGULATIONS 1.31, 1.35 AND 166.3, (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $75,000,000, AND (D) COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: ON AUGUST 8, 2023, THE CFTC ENTERED INTO AN ORDER WITH THE RESPONDENTS TO SETTLE AN ADMINISTRATIVE ACTION CONCERNING (A) WFB'S FAILURE TO MAINTAIN REQUIRED RECORDS IN VIOLATION OF SECTIONS 4S(F)(1)(C) AND 4S(G)(1) AND (3) OF THE ACT AND REGULATIONS 23.201(A) AND 23.202(A)(1) AND (B)(1); (B) WFS'S FAILURE TO KEEP REQUIRED RECORDS IN VIOLATION OF SECTION 4G OF THE ACT AND REGULATION 1.35; (C) RESPONDENTS' FAILURE TO KEEP RECORDS IN THE REQUIRED MANNER IN VIOLATION OF REGULATION 1.31; (D) WFB'S FAILURE TO SUPERVISE DILIGENTLY IN VIOLATION OF SECTIONS 4S(H)(1)(B) OF THE ACT AND REGULATION 23.602(A); AND (E) WFS'S FAILURE TO DILIGENTLY SUPERVISE IN VIOLATION OF REGULATION 166.3. THE RESPONDENTS ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED THEIR CONDUCT VIOLATED THE ACT AND REGULATIONS AND CONSENTED TO: (A) THE ENTRY OF THE CFTC'S FINDINGS; (B) HAVE WFB CEASE AND DESIST FROM VIOLATING SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE ACT, AND REGULATIONS 1.31, 23.201(A), 23.202(A)(1) AND (B)(1) AND 23.602(A) AND TO HAVE WFS CEASE AND DESIST FROM VIOLATING SECTION 4G OF THE ACT AND REGULATIONS 1.31, 1.35 AND 166.3, (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $75,000,000, AND (D) COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: WELLS FARGO & COMPANY ("WFC") VIOLATED SECTION 10(B) OF THE EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND RULE 10B-5 THEREUNDER WITH RESPECT TO ITS HISTORICAL COMMUNITY BANK SALES PRACTICES AND RELATED DISCLOSURES. Status: Final Sanction Detail: PURSUANT TO A CEASE AND DESIST ORDER (THE "SEC ORDER"), THE SECURITIES AND EXCHANGE COMMISSION ("SEC") REQUIRED WFC TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000,000. Summary: WFC CONSENTED TO THE ENTRY OF THE SEC ORDER AND AGREED TO PAY A CIVIL PENALTY OF $500 MILLION AND TO BE ENJOINED FROM FUTURE VIOLATIONS OF SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER. WFC ALSO AGREED TO ENGAGE OUTSIDE EXPERIENCED SECURITIES COUNSEL TO CONDUCT AN ASSESSMENT OF THE REGULATION D POLICIES AND PROCEDURES OF WFC AND CERTAIN OF ITS SUBSIDIARIES AND TO PRESENT TO THE SEC ON THE IMPLEMENTATION OF RECOMMENDATIONS MADE BY OUTSIDE COUNSEL.