Metlife Investment Management, Llc

Allegations: IN 2009, ALICO AND ITS OUTSIDE COUNSEL MADE CERTAIN REPRESENTATIONS IN A LETTER TO THE NEW YORK STATE INSURANCE DEPARTMENT (THE PREDECESSOR OF DFS) CONCERNING ITS OPERATIONS IN NEW YORK. IT WAS ALLEGED THAT CONTRARY TO THESE REPRESENTATIONS, ALICO AND DELAM, SUBSIDIARIES OF AMERICAN INTERNATIONAL GROUP ("AIG") UNTIL NOVEMBER 2010, AND LATER OF METLIFE AFTER NOVEMBER 2010, WERE DOING INSURANCE BUSINESS IN NEW YORK WITHOUT A LICENSE. FURTHER, IT WAS ALLEGED THAT, BY CONDUCTING CERTAIN ACTIVITIES IN NEW YORK, REPRESENTATIVES ON BEHALF OF ALICO, DELAM, AIG AND METLIFE WERE SOLICITING INSURANCE BUSINESS WITHOUT A LICENSE. Status: Final Sanction Detail: $50,000,000 PAID BY METLIFE, INC. TO DFS [PAYMENT DATE - MARCH 31, 2014] $10,000,000 PAID BY METLIFE, INC. TO DANY [PAYMENT DATE - MARCH 31, 2014] Summary: CONSENT ORDER WITH DFS, METLIFE, ALICO AND DELAM, EFFECTIVE MARCH 31, 2014. FINE OF $50,000,000 ASSESSED AGAINST METLIFE TO BE PAID WITHIN SEVEN DAYS OF EFFECTIVE DATE. DEFERRED PROSECUTION AGREEMENT (THE "AGREEMENT") SIGNED BY DANY, METLIFE, ALICO AND DELAM ON MARCH 28, 2014. PAYMENT OF $10,000,000 TO BE MADE BY METLIFE. IF COMPLIANCE WITH THE AGREEMENT FOR 24 MONTHS, THE AGREEMENT SHALL EXPIRE AND BE OF NO FURTHER FORCE AND EFFECT. AS REQUIRED BY THE CONSENT ORDER WITH DFS, REPRESENTATIVES ENGAGING IN CERTAIN ACTIVITIES IN NEW YORK MUST OBTAIN AN INSURANCE LICENSE AND AN AUTHORIZED INSURER IN NEW YORK MUST FILE CERTAIN INFORMATION CONCERNING ISSUANCE OF COVERAGE BY INSURERS LICENSED OUTSIDE THE UNITED STATES. METLIFE, ALICO AND DELAM ARE CONTINUING TO COOPERATE WITH A PARALLEL INVESTIGATION BY THE NEW YORK STATE OFFICE OF THE ATTORNEY GENERAL TAXPAYER PROTECTION BUREAU CONCERNING ALICO AND DELAM'S NEW YORK STATE TAX FILINGS.

Allegations: METLIFE, INC. IS ALLEGED TO HAVE MADE MATERIALLY MISLEADING STATEMENTS IN ITS PUBLIC FILINGS REGARDING THE EFFECTIVENESS OF ITS INTERNAL CONTROLS OVER FINANCIAL REPORTING FOR ITS PENSION RISK TRANSFER BUSINESS AND THE SUFFICIENCY OF ITS RESERVES FOR GROUP ANNUITY CONTRACTS. Status: Final Sanction Detail: ON DECEMBER 18, 2018 A CONSENT ORDER WAS ISSUED, WITH METLIFE, INC. NEITHER ADMITTING NOR DENYING THE FINDINGS CONTAINED IN THE ORDER (EXCEPT AS TO METLIFE, INC.'S CORPORATE IDENTITY AND ORGANIZATION). THE CONSENT ORDER PROVIDES FOR A CEASE AND DESIST, A CENSURE, THE PROVISION OF INFORMATION TO THE MSD REGARDING CERTAIN ANNUITANTS IN MASSACHUSETTS, UNDERTAKING SEVERAL MEASURES WITH RESPECT TO OUTREACH AND PAYMENT OF BENEFITS TO THOSE ANNUITANTS, AND THE PAYMENT BY METLIFE, INC. OF A $1 MILLION ADMINISTRATIVE FINE. Summary: ON DECEMBER 17, 2018, METLIFE, INC. SUBMITTED AN OFFER OF SETTLEMENT TO THE MASSACHUSETTS SECURITIES DIVISION ("MSD") IN CONNECTION WITH THE MSD'S ADMINISTRATIVE COMPLAINT FILED ON JUNE 25, 2018. ON DECEMBER 18, 2018 A CONSENT ORDER WAS ISSUED, WITH METLIFE, INC. NEITHER ADMITTING NOR DENYING THE FINDINGS CONTAINED IN THE ORDER (EXCEPT AS TO METLIFE, INC.'S CORPORATE IDENTITY AND ORGANIZATION). THE CONSENT ORDER PROVIDES FOR A CEASE AND DESIST, A CENSURE, THE PROVISION OF INFORMATION TO THE MSD REGARDING CERTAIN ANNUITANTS IN MASSACHUSETTS, UNDERTAKING SEVERAL MEASURES WITH RESPECT TO OUTREACH AND PAYMENT OF BENEFITS TO THOSE ANNUITANTS, AND THE PAYMENT BY METLIFE, INC. OF A $1 MILLION ADMINISTRATIVE FINE.

Allegations: METLIFE, INC. PREVIOUSLY DISCLOSED ERRORS IN ITS ACCOUNTING FOR RESERVES ASSOCIATED WITH CERTAIN ANNUITIES, AND REMEDIATED THESE ERRORS AS OF DECEMBER 31, 2018. THE U.S. SECURITIES AND EXCHANGE COMMISSION CHARGED METLIFE, INC. WITH VIOLATING THE BOOKS AND RECORDS AND INTERNAL ACCOUNTING CONTROLS PROVISIONS OF THE FEDERAL SECURITIES LAWS RELATING TO THESE ERRORS. WITHOUT ADMITTING OR DENYING THE COMMISSION'S FINDINGS, METLIFE AGREED TO PAY A CIVIL PENALTY. Status: Final Sanction Detail: METLIFE, INC. PREVIOUSLY DISCLOSED ERRORS IN ITS ACCOUNTING FOR RESERVES ASSOCIATED WITH CERTAIN ANNUITIES, AND REMEDIATED THESE ERRORS AS OF DECEMBER 31, 2018. THE U.S. SECURITIES AND EXCHANGE COMMISSION CHARGED METLIFE, INC. WITH VIOLATING THE BOOKS AND RECORDS AND INTERNAL ACCOUNTING CONTROLS PROVISIONS OF THE FEDERAL SECURITIES LAWS RELATING TO THESE ERRORS. WITHOUT ADMITTING OR DENYING THE COMMISSION'S FINDINGS, METLIFE AGREED TO PAY A CIVIL PENALTY. Summary: METLIFE, INC. PREVIOUSLY DISCLOSED ERRORS IN ITS ACCOUNTING FOR RESERVES ASSOCIATED WITH CERTAIN ANNUITIES, AND REMEDIATED THESE ERRORS AS OF DECEMBER 31, 2018. THE U.S. SECURITIES AND EXCHANGE COMMISSION CHARGED METLIFE, INC. WITH VIOLATING THE BOOKS AND RECORDS AND INTERNAL ACCOUNTING CONTROLS PROVISIONS OF THE FEDERAL SECURITIES LAWS RELATING TO THESE ERRORS. WITHOUT ADMITTING OR DENYING THE COMMISSION'S FINDINGS, METLIFE AGREED TO PAY A CIVIL PENALTY.