Managed Account Advisors Llc

Allegations: ON AUGUST 6, 2013, THE DEPARTMENT OF JUSTICE FILED A CIVIL ACTION AGAINST MERRILL LYNCH, PIERCE, FENNER & SMITH, INC. F/K/A BANC OF AMERICA SECURITIES LLC (THE "FIRM") AND OTHER ENTITIES (COLLECTIVELY THE "ENTITIES"). THE DEPARTMENT OF JUSTICE ALLEGES THAT THE ENTITIES VIOLATED THE FINANCIAL INSTITUTIONS REFORM, RECOVERY AND ENFORCEMENT ACT OF 1989, 12 U.S.C. § 1833A, THROUGH CIVIL VIOLATIONS OF 18 U.S.C. §§ 1001 AND 1014. THE COMPLAINT CLAIMS THAT THE ENTITIES MADE FALSE STATEMENTS TO AND OMITTED MATERIAL INFORMATION FROM THE GOVERNMENT AND FEDERALLY INSURED FINANCIAL INSTITUTIONS. SPECIFICALLY, THE COMPLAINT ALLEGES THAT THE ENTITIES FAILED TO DISCLOSE THE DISPROPORTIONATE CONCENTRATION OF WHOLESALE CHANNEL LOANS ORIGINATED BY THIRD PARTIES UNDERLYING THE RESIDENTIAL MORTGAGE BACKED SECURITIES. THE COMPLAINT ALLEGES THAT THE ENTITIES KNEW THE WHOLESALE CHANNEL LOANS WERE RISKIER AS COMPARED TO SIMILAR MORTGAGES ORIGINATED BY THE ENTITIES DIRECTLY. THE COMPLAINT ALSO ALLEGES THAT THE ENTITIES FAILED TO DISCLOSE THE PERCENTAGE OF PAPERSAVER LOANS MADE TO SELF-EMPLOYED BORROWERS. THE COMPLAINT ALLEGES THAT THE ENTITIES KNEW PAPERSAVER LOANS WERE RISKIER THAN MORTGAGES GIVEN TO SALARIED BORROWERS. THE COMPLAINT FURTHER ALLEGES THAT, EVEN THOUGH THE ENTITIES WERE AWARE OF THE RISKS ASSOCIATED WITH THE CHARACTERISTICS OF THE POOL, THE ENTITIES FAILED TO CONDUCT THIRD-PARTY DUE DILIGENCE ON THE MORTGAGES IN THE POOL AND VIOLATED THE FIRM'S DUE DILIGENCE POLICIES. THE COMPLAINT SEEKS A CIVIL MONETARY JUDGMENT IN AN UNSTATED AMOUNT PURSUANT TO 12 U.S.C. § 1833A(B), PREJUDGMENT INTEREST, AND ATTORNEYS' FEES. Status: Final Summary: ON AUGUST 21, 2014, THE U.S. DEPARTMENT OF JUSTICE ("DOJ") ANNOUNCED A GLOBAL SETTLEMENT AGREEMENT BETWEEN BANK OF AMERICA CORPORATION AND SEVERAL OF ITS AFFILIATES (TOGETHER "BANK OF AMERICA") AND THE DOJ, AMONG OTHERS, IN CONNECTION WITH THE PACKAGING, ORIGINATION, MARKETING, SALE STRUCTURING, ARRANGEMENT, AND ISSUANCE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES ("RMBS") AND COLLATERALIZED DEBT OBLIGATIONS ("CDOS"). AS PART OF THE GLOBAL SETTLEMENT AGREEMENT, THE DOJ RELEASED BANK OF AMERICA FROM THE CONDUCT ALLEGED IN THE COMPLAINT FILED ON AUGUST 6, 2013. ON AUGUST 29, 2014, THE DISTRICT COURT DISMISSED THE DOJ COMPLAINT (THE SUBJECT OF THIS DRP) WITH PREJUDICE. THE DOJ DID NOT ENJOIN BANK OF AMERICA AND, THEREFORE, 11H(1)(A) IS NOT APPLICABLE. THERE WAS NO FINDING OF VIOLATIONS OF INVESTMENT-RELATED STATUTES OR REGULATIONS BY THE DOJ AND, THEREFORE, 11H(1)(B) IS NOT APPLICABLE. AND THE DOJ IS NOT A STATE OR FOREIGN FINANCIAL REGULATORY AUTHORITY AND, THEREFORE, 11H(1)(C) IS NOT APPLICABLE. *****THE FIRM THEREFORE REQUESTS THAT THIS DRP RELATED TO THIS DOJ DRP BE REMOVED AS THE MATTER WAS DISMISSED AND THERE WAS NO FINDING/ACTION AGAINST BANK OF AMERICA BY THE DOJ.*****

Allegations: THE ATTORNEY GENERAL OF THE STATE OF NEW YORK ALLEGES THAT BANK OF AMERICA CORPORATION ("BAC"), ITS FORMER CEO KENNETH D. LEWIS AND ITS FORMER CFO JOSEPH L. PRICE ENGAGED IN ACTS AND PRACTICES IN CONNECTION WITH THE MERGER (THE "MERGER") BETWEEN BAC AND MERRILL LYNCH & CO. INC. ("MERRILL LYNCH") THAT VIOLATED CERTAIN PROVISIONS OF THE NEW YORK GENERAL BUSINESS LAW (THE "MARTIN ACT") AND THE NEW YORK EXECUTIVE LAW. Status: Final Summary: ON FEBRUARY 4, 2010, THE NEW YORK ATTORNEY GENERAL FILED A CIVIL COMPLAINT IN THE SUPREME COURT OF NEW YORK STATE, ENTITLED PEOPLE OF THE STATE OF NEW YORK V. BANK OF AMERICA, ET AL. THE COMPLAINT NAMES AS DEFENDANTS BAC AND BAC'S FORMER CHIEF EXECUTIVE AND CHIEF FINANCIAL OFFICERS, KENNETH D. LEWIS, AND JOSEPH L. PRICE, AND ALLEGES VIOLATIONS OF SECTIONS 352, 352-C(1)(A), 352-C(1)(C), AND 353 OF THE NEW YORK MARTIN ACT, AND SECTION 63(12) OF THE NEW YORK EXECUTIVE LAW. THE COMPLAINT ATTACKS THE SUFFICIENCY AND ACCURACY OF BAC'S DISCLOSURES AND ITS PRACTICES RELATED TO BAC'S MERGER WITH MERRILL LYNCH, INCLUDING: (I) THE DISCLOSURE OF MERRILL LYNCH'S FINANCIAL CONDITION AND ITS INTERIM AND PROJECTED LOSSES DURING THE FOURTH QUARTER OF 2008, (II) BAC'S CONTACTS WITH FEDERAL GOVERNMENT OFFICIALS REGARDING BAC'S CONSIDERATION OF INVOKING THE MATERIAL ADVERSE EFFECT CLAUSE IN THE MERGER AGREEMENT WITH MERRILL LYNCH AND THE POSSIBILITY OF OBTAINING ADDITIONAL GOVERNMENT ASSISTANCE, (III) THE DISCLOSURE OF THE PAYMENT AND TIMING OF YEAR-END INCENTIVE COMPENSATION TO MERRILL LYNCH EMPLOYEES, AND (IV) PUBLIC STATEMENTS REGARDING THE DUE DILIGENCE CONDUCTED IN CONNECTION WITH THE MERGER AND POSITIVE STATEMENTS REGARDING THE MERGER. THE COMPLAINT SEEKS AN UNSPECIFIED AMOUNT IN DISGORGEMENT, PENALTIES, RESTITUTION, AND DAMAGES, COSTS AND OTHER EQUITABLE RELIEF, ALTHOUGH THE NYAG WITHDREW ITS DEMAND FOR DAMAGES. ON MARCH 25, 2014, BAC ENTERED INTO A SETTLEMENT AGREEMENT TERMINATING THE NEW YORK ATTORNEY GENERAL'S LAWSUIT AGAINST BAC.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT BANK OF AMERICA CORPORATION (THE "CORPORATION") VIOLATED SECTION 14(A) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND RULE 14A-9 THEREUNDER BY FAILING TO DISCLOSE IN THE CORPORATION'S JOINT PROXY STATEMENT FILED ON NOVEMBER 3, 2008 THE INCENTIVE COMPENSATION THAT MERRILL LYNCH & CO., INC. COULD, IN ITS DISCRETION, AWARD TO ITS EMPLOYEES PRIOR TO COMPLETION OF ITS MERGER WITH THE CORPORATION. Status: Final Summary: ON FEBRUARY 24, 2010, A FINAL CONSENT JUDGMENT (THE "FINAL JUDGMENT") WAS ENTERED BY THE COURT. UNDER THE TERMS OF THE FINAL JUDGMENT, THE CORPORATION AGREED TO PAY $1 IN DISGORGEMENT AND A $150 MILLION CIVIL PENALTY TO BE DISTRIBUTED TO SHAREHOLDERS AS PART OF THE SEC'S FAIR FUNDS PROGRAM AT A LATER DATE IN ACCORDANCE WITH FURTHER ORDER OF THE COURT. IN ADDITION, AS PART OF THE FINAL JUDGMENT, THE CORPORATION AGREED, FOR A PERIOD OF THREE YEARS, TO COMPLY WITH AND MAINTAIN CERTAIN REQUIREMENTS RELATED TO THE CORPORATION'S CORPORATE GOVERNANCE AND DISCLOSURE PRACTICES.

Allegations: ON MARCH 12, 2012, THE DEPARTMENT OF JUSTICE AND THE ATTORNEYS GENERAL OF 49 STATES AND THE DISTRICT OF COLUMBIA FILED A COMPLAINT ("COMPLAINT") AND CONSENT JUDGMENT AGAINST BANK OF AMERICA CORPORATION, BANK OF AMERICA, N.A., BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, COUNTRYWIDE HOME LOANS, INC., COUNTRYWIDE FINANCIAL CORPORATION, COUNTRYWIDE MORTGAGE VENTURES, LLC, AND/OR COUNTRYWIDE BANK, FSB (TOGETHER, "BANK OF AMERICA") AND OTHER MAJOR MORTGAGE SERVICERS TO SETTLE A NUMBER OF RELATED INVESTIGATIONS INTO RESIDENTIAL LOAN SERVICING AND ORIGINATION PRACTICES (THE "SETTLEMENT"). THE COMPLAINT ALLEGED THE DEFENDANT'S MISCONDUCT RELATED TO ITS ORIGINATION AND SERVICING OF SINGLE FAMILY RESIDENTIAL MORTGAGES CAUSED THE DEFENDANTS TO HAVE VIOLATED, AMONG OTHER LAWS, THE UNFAIR AND DECEPTIVE ACTS AND PRACTICES LAWS OF THE PLAINTIFF STATES, THE FALSE CLAIMS ACT, THE FINANCIAL INSTITUTIONS REFORM, RECOVERY, AND ENFORCEMENT ACT OF 1989, THE SERVICEMEMBERS CIVIL RELIEF ACT, AND THE BANKRUPTCY CODE AND FEDERAL RULES OF BANKRUPTCY PROCEDURE. Status: Final Summary: BANK OF AMERICA CONSENTED TO THE ENTRY OF THE CONSENT JUDGMENT WITHOUT ADMITTING THE ALLEGATIONS IN THE COMPLAINT OTHER THAN THOSE FACTS DEEMED NECESSARY TO JURISDICTION. THE ALLEGATIONS ARE DESCRIBED IN ITEM 7 ABOVE AND THE SANCTIONS ARE DESCRIBED IN ITEM 13 ABOVE. BANK OF AMERICA MADE ITS PAYMENT TO THE ESCROW AGENT ON APRIL 11, 2012. THE SETTLEMENT DOES NOT RESULT IN AN INJUNCTION OR ANY FINDINGS OF VIOLATIONS OF LAW.

Allegations: ON MARCH 12, 2012, THE DEPARTMENT OF JUSTICE AND THE ATTORNEYS GENERAL OF 49 STATES AND THE DISTRICT OF COLUMBIA FILED A COMPLAINT ("COMPLAINT") AND CONSENT JUDGMENT AGAINST BANK OF AMERICA CORPORATION, BANK OF AMERICA, N.A., BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, COUNTRYWIDE HOME LOANS, INC., COUNTRYWIDE FINANCIAL CORPORATION, COUNTRYWIDE MORTGAGE VENTURES, LLC, AND/OR COUNTRYWIDE BANK, FSB (TOGETHER, "BANK OF AMERICA") AND OTHER MAJOR MORTGAGE SERVICERS TO SETTLE A NUMBER OF RELATED INVESTIGATIONS INTO RESIDENTIAL LOAN SERVICING AND ORIGINATION PRACTICES (THE "SETTLEMENT"). THE COMPLAINT ALLEGED THE DEFENDANT'S MISCONDUCT RELATED TO ITS ORIGINATION AND SERVICING OF SINGLE FAMILY RESIDENTIAL MORTGAGES CAUSED THE DEFENDANTS TO HAVE VIOLATED, AMONG OTHER LAWS, THE UNFAIR AND DECEPTIVE ACTS AND PRACTICES LAWS OF THE PLAINTIFF STATES, THE FALSE CLAIMS ACT, THE FINANCIAL INSTITUTIONS REFORM, RECOVERY, AND ENFORCEMENT ACT OF 1989, THE SERVICEMEMBERS CIVIL RELIEF ACT, AND THE BANKRUPTCY CODE AND FEDERAL RULES OF BANKRUPTCY PROCEDURE. Status: Final Summary: BANK OF AMERICA CONSENTED TO THE ENTRY OF THE CONSENT JUDGMENT WITHOUT ADMITTING THE ALLEGATIONS IN THE COMPLAINT OTHER THAN THOSE FACTS DEEMED NECESSARY TO JURISDICTION. THE ALLEGATIONS ARE DESCRIBED IN ITEM 7 ABOVE AND THE SANCTIONS ARE DESCRIBED IN ITEM 13 ABOVE. BANK OF AMERICA MADE ITS PAYMENT TO THE ESCROW AGENT ON APRIL 11, 2012. THE SETTLEMENT DOES NOT RESULT IN AN INJUNCTION OR ANY FINDINGS OF VIOLATIONS OF LAW.

Allegations: AFTER AN INDIVIDUAL COMMENCED A QUI TAM LAWSUIT, THE U.S. ATTORNEY FILED A COMPLAINT-IN-INTERVENTION IN 2012 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ("COURT") AGAINST COUNTRYWIDE HOME LOANS, INC., COUNTRYWIDE BANK, FSB, BANK OF AMERICA, N.A. AND CERTAIN AFFILIATES ("DEFENDANTS") ALLEGING THAT THE DEFENDANTS ENGAGED IN AN INTENTIONAL SCHEME TO MISREPRESENT THE QUALITY OF THE MORTGAGE LOANS THAT IT PROCESSED THROUGH A PARTICULAR LOAN ORIGINATION PROGRAM AND SOLD TO FANNIE MAE AND FREDDIE MAC DURING AUGUST 2007 TO MAY 2008. THE COMPLAINT SOUGHT TO RECOVER TREBLE DAMAGES AND PENALTIES UNDER THE FALSE CLAIMS ACT, 31 U.S.C. § 3729 ET. SEQ. ("FCA") AND CIVIL PENALTIES UNDER THE FINANCIAL INSTITUTIONS REFORM, RECOVERY, AND ENFORCEMENT ACT, 12 U.S.C. § 1833A ("FIRREA"). Status: Final Summary: THE ACTIONS, ALLEGATIONS, DISPOSITION, AND FINDINGS OF THIS MATTER ARE DESCRIBED IN ITEMS 7 AND 13 ABOVE.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT BANK OF AMERICA CORPORATION (THE "CORPORATION") VIOLATED THE FEDERAL PROXY RULES BY FAILING TO DISCLOSE INFORMATION CONCERNING MERRILL LYNCH & CO., INC.'S KNOWN AND ESTIMATED LOSSES IN THE FOURTH QUARTER OF 2008 PRIOR TO THE SHAREHOLDER VOTE ON DECEMBER 5, 2008 TO APPROVE THE MERGER BETWEEN THE TWO COMPANIES. Status: Final Summary: ON FEBRUARY 24, 2010, A FINAL CONSENT JUDGMENT (THE "FINAL JUDGMENT") WAS ENTERED BY THE COURT. UNDER THE TERMS OF THE FINAL JUDGMENT, THE CORPORATION AGREED TO PAY $1 IN DISGORGEMENT AND A $150 MILLION CIVIL PENALTY TO BE DISTRIBUTED TO SHAREHOLDERS AS PART OF THE SEC'S FAIR FUNDS PROGRAM AT A LATER DATE IN ACCORDANCE WITH FURTHER ORDER OF THE COURT. IN ADDITION, AS PART OF THE FINAL JUDGMENT, THE CORPORATION AGREED, FOR A PERIOD OF THREE YEARS, TO COMPLY WITH AND MAINTAIN CERTAIN REQUIREMENTS RELATED TO THE CORPORATION'S CORPORATE GOVERNANCE AND DISCLOSURE PRACTICES.

Allegations: SEC LITIGATION RELEASE 22772, AUGUST 7, 2013: ON AUGUST 6, 2013, THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") FILED A CIVIL INJUNCTIVE ACTION AGAINST MERRILL LYNCH, PIERCE, FENNER & SMITH, INC. F/K/A BANC OF AMERICA SECURITIES LLC ("FIRM") AND OTHER ENTITIES (COLLECTIVELY THE "ENTITIES"). THE COMMISSION ALLEGES THAT THE ENTITIES MADE MATERIAL MISREPRESENTATIONS AND OMISSIONS IN CONNECTION WITH THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES. SPECIFICALLY, THE COMPLAINT ALLEGES THAT THE ENTITIES FAILED TO DISCLOSE THE DISPROPORTIONATE CONCENTRATION OF WHOLESALE LOANS (72% BY UNPAID PRINCIPAL BALANCE) UNDERLYING THE RESIDENTIAL MORTGAGE-BACKED SECURITIES AS COMPARED TO PRIOR RESIDENTIAL MORTGAGE-BACKED SECURITIES OFFERINGS. THE COMPLAINT ALSO ALLEGES THAT THE ENTITIES FAILED TO DISCLOSE KNOWN RISKS ASSOCIATED WITH THE HIGH CONCENTRATION OF WHOLESALE LOANS IN THE RESIDENTIAL MORTGAGE-BACKED SECURITIES INCLUDING HIGHER LIKELIHOOD THAT THE LOANS WOULD BE SUBJECT TO MATERIAL UNDERWRITING ERRORS, BECOME SEVERELY DELINQUENT, FAIL EARLY IN THE LIFE OF THE LOAN, OR PREPAY. THE COMPLAINT FURTHER ALLEGES THAT THE ENTITIES VIOLATED REGULATION S-K AND SUBPART REGULATION AB OF THE SECURITIES ACT OF 1933 (THE "SECURITIES ACT") BY FAILING TO DISCLOSE THE MATERIAL CHARACTERISTICS OF THE POOL OF LOANS UNDERLYING THE RESIDENTIAL MORTGAGE-BACKED SECURITIES. THE COMPLAINT ALSO ALLEGES THAT THE ENTITIES MADE MATERIAL MISREPRESENTATIONS AND OMISSIONS IN ITS PUBLIC FILINGS AND IN THE LOAN TAPES IT PROVIDED TO INVESTORS AND RATING AGENCIES THAT THE LOANS IN THE RESIDENTIAL MORTGAGE-BACKED SECURITIES COMPLIED WITH UNDERWRITING STANDARDS WHEN A MATERIAL AMOUNT DID NOT. FINALLY, THE COMPLAINT ALLEGES THAT THE FIRM VIOLATED SECTION 5(B)(1) OF THE SECURITIES ACT BY FAILING TO FILE WITH THE COMMISSION CERTAIN LOAN TAPES THAT IT PROVIDED ONLY TO SELECT INVESTORS. THE COMMISSION'S COMPLAINT, FILED IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA, CHARGES THE FIRM WITH VIOLATING THE ANTIFRAUD PROVISIONS OF THE FEDERAL SECURITIES LAWS. THE COMPLAINT ALLEGES THAT THAT THE FIRM VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. THE COMPLAINT ALSO ALLEGES THAT THE FIRM VIOLATED SECTION 5(B)(1) OF THE SECURITIES ACT. THE COMPLAINT SEEKS AGAINST THE FIRM A PERMANENT INJUNCTION, DISGORGEMENT WITH PREJUDGMENT INTEREST AND CIVIL MONETARY PENALTIES PURSUANT SECTION 20(D) OF THE SECURITIES ACT. Status: Final Summary: ON NOVEMBER 25, 2014, THE DISTRICT COURT ENTERED A FINAL JUDGMENT AGAINST THE RESPONDENTS THAT ENJOINED RESPONDENTS FROM VIOLATING, DIRECTLY OR INDIRECTLY, SECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), AND MLPF&S AND BOAMS FROM VIOLATING, DIRECTLY OR INDIRECTLY, SECTION 5(B)(1) OF THE SECURITIES ACT. BANA WAS NOT NAMED AS A DEFENDANT IN CONNECTION WITH THE SECTION 5(B)(1) CLAIM AND THEREFORE DID NOT CONSENT TO ENTRY OF AN INJUNCTION UNDER THAT SECTION. THE RESPONDENTS CONSENTED TO THE ENTRY OF THE FINAL JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE COMPLAINT. THE DISTRICT COURT RETAINED JURISDICTION OVER THE ADMINISTRATION OF ANY DISTRIBUTION OF THE FUNDS.

Allegations: THE ATTORNEY GENERAL OF THE STATE OF NEW YORK INVESTOR PROTECTION BUREAU ALLEGED THAT BANK OF AMERICA CORPORATION (BAC) AND THE FIRM (1) CONCEALED FROM ITS INSTITUTIONAL CLIENTS THAT ORDERS WERE ROUTED TO AND EXECUTED BY "ELECTRONIC LIQUIDITY PROVIDERS," (2) MISSTATED THE COMPOSITION OF ORDERS AND TRADES IN ITS DARK POOL, AND (3) DID NOT ACCURATELY DESCRIBE ITS USE OF A PROPRIETARY "VENUE RANKING" ANALYSIS, IN VIOLATION OF THE MARTIN ACT AND EXECUTIVE LAW § 63(12). Status: Final Sanction Detail: IN CONNECTION WITH THE AGREEMENT, BOFAML AGREED (1) NOT TO ENGAGE, OR ATTEMPT TO ENGAGE, IN CONDUCT IN VIOLATION OF ANY APPLICABLE LAWS, INCLUDING BUT NOT LIMITED TO THE MARTIN ACT AND EXECUTIVE LAW § 63(12); (2) TO PAY A PENALTY IN THE AMOUNT OF $42,000,000; AND (3) PROVIDE THE NYAG A SUMMARY OF THE REVIEW OF ITS ELECTRONIC TRADING POLICIES AND PROCEDURES. Summary: IN CONNECTION WITH THE AGREEMENT, BOFAML AGREED (1) NOT TO ENGAGE, OR ATTEMPT TO ENGAGE, IN CONDUCT IN VIOLATION OF ANY APPLICABLE LAWS, INCLUDING BUT NOT LIMITED TO THE MARTIN ACT AND EXECUTIVE LAW § 63(12); (2) TO PAY A PENALTY IN THE AMOUNT OF $42,000,000; AND (3) PROVIDE THE NYAG A SUMMARY OF THE REVIEW OF ITS ELECTRONIC TRADING POLICIES AND PROCEDURES.

Allegations: THE BANGKO SENTRAL NG PILIPINAS (BS") APPROVED THE IMPOSITION OF A MONETARY PENALTY ON THE FIRM FOR THE FOLLOWING VIOLATIONS OF THE MANUAL OF REGULATIONS ON FOREIGN EXCHANGE TRANSACTIONS: DEFICIENCY IN E/FOREIGN CURRENCY DEPOSIT UNIT (FCDU) ASSET COVER REQUIREMENT, FALSE/ERRONEOUS CERTIFICATION OF COMPLIANCE WITH E/FCDU COVER AND BREACH ON THE CAP ON ALLOWABLE LENDING OF FCDU FUNDS TO REGULAR BANKING UNITS. Status: Final Sanction Detail: THE MONETARY BOARD IMPOSED A PENALTY IN THE AMOUNT OF PHP67,303,484.29 (APPROX. USD1,306,930) ON THE FIRM. PURSUANT TO THE BSP'S RULES, THE FIRM'S DEMAND DEPOSIT ACCOUNT WITH THE BSP SHALL BE AUTOMATICALLY DEBITED THE ABOVE REFERENCED AMOUNT UPON THE LAPSE OF FIFTEEN CALENDAR DAYS FROM RECEIPT OF THE FINAL BILLING LETTER. THEREFORE, THE AMOUNT MAY BE DEBITED NO EARLIER THAN OCTOBER 12, 2017. Summary: THE MONETARY BOARD IMPOSED A PENALTY IN THE AMOUNT OF PHP67,303,484.29 (APPROX. USD1,306,930) ON THE FIRM. PURSUANT TO THE BSP'S RULES, THE FIRM'S DEMAND DEPOSIT ACCOUNT WITH THE BSP SHALL BE AUTOMATICALLY DEBITED THE ABOVE REFERENCED AMOUNT UPON THE LAPSE OF FIFTEEN CALENDAR DAYS FROM RECEIPT OF THE FINAL BILLING LETTER. THEREFORE, THE AMOUNT MAY BE DEBITED NO EARLIER THAN OCTOBER 12, 2017.

Allegations: THE BUNDESANSTALT FUR FINANZDIENSTLEISTUNGSAUFSICHT (BAFIN) APPROVED THE IMPOSITION OF AN ADMINISTRATIVE FINE ON BANK OF AMERICA CORPORATION FOR FAILURE TO TAKE THE SUPERVISORY AND ORGANISATIONAL MEASURES THAT WOULD HAVE BEEN REQUIRED IN ORDER TO ENSURE THE CORRECT AND COMPLETE SUBMISSION OF VOTING RIGHTS NOTIFICATIONS WITHIN THE PRESCRIBED PERIOD, IN BREACH OF SECTION 130(1) OF THE GERMAN ACT ON BREACHES OF ADMINISTRATIVE REGULATIONS IN CONJUNCTION WITH SECTIONS 33 (1) SENTENCE 1, SECTION 38(1) SENTENCE 1 AND 39 (1) OF THE GERMAN SECURITIES TRADING ACT. Status: Final Sanction Detail: BAFIN IMPOSED A PENALTY IN THE AMOUNT OF EUR5,100,000 (APPROXIMATELY USD5,071,950) ON BAC AND COSTS OF THE PROCEEDING IN THE AMOUNT OF EUR7,500 (APPROXIMATELY USD 7,479). THE PAYMENTS WERE MADE IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: BAFIN IMPOSED A PENALTY IN THE AMOUNT OF EUR5,100,000 (APPROXIMATELY USD5,071,950) ON BAC AND COSTS OF THE PROCEEDING IN THE AMOUNT OF EUR7,500 (APPROXIMATELY USD 7,479). THE PAYMENTS WERE MADE IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: THE BANGKO SENTRAL NG PILIPINAS (BSP) APPROVED THE IMPOSITION OF A MONETARY PENALTY ON THE FIRM FOR NON-COMPLIANCE WITH THE 100.0 PERCENT EXPANDED/FOREIGN CURRENCY DEPOSIT UNIT (E/FCDU) ASSET COVER REQUIREMENT. Status: Final Sanction Detail: THE MONETARY BOARD IMPOSED A PENALTY IN THE AMOUNT OF PHP1,011,442 (USD19,473.80) ON THE FIRM. PURSUANT TO THE BSP'S RULES, THE FIRM'S DEMAND DEPOSIT ACCOUNT WITH THE BSP SHALL BE AUTOMATICALLY DEBITED THE ABOVE REFERENCED AMOUNT UPON THE LAPSE OF FIFTEEN CALENDAR DAYS FROM RECEIPT OF THE FINAL BILLING LETTER. THEREFORE, THE AMOUNT MAY BE DEBITED NO EARLIER THAN APRIL 26, 2019. Summary: THE MONETARY BOARD IMPOSED A PENALTY IN THE AMOUNT OF PHP1,011,442 (USD19,473.80) ON THE FIRM. PURSUANT TO THE BSP'S RULES, THE FIRM'S DEMAND DEPOSIT ACCOUNT WITH THE BSP SHALL BE AUTOMATICALLY DEBITED THE ABOVE REFERENCED AMOUNT UPON THE LAPSE OF FIFTEEN CALENDAR DAYS FROM RECEIPT OF THE FINAL BILLING LETTER. THEREFORE, THE AMOUNT MAY BE DEBITED NO EARLIER THAN APRIL 26, 2019.

Allegations: ON JUNE 29, 2015, THE COMPTROLLER OF THE CURRENCY ("OCC") ISSUED A CONSENT ORDER AND A CONSENT ORDER FOR A CIVIL MONEY PENALTY (TOGETHER, THE "ORDERS") AGAINST BANK OF AMERICA, N.A. ("BANA") RELATING TO THE BANA'S PRACTICES THAT RESULTED IN VIOLATIONS OF THE NATIONAL FLOOD INSURANCE ACT OF 1968, AS AMENDED, AND THE FLOOD DISASTER PROTECTION ACT OF 1973, AS AMENDED (COLLECTIVELY, "FDPA"), 42 U.S.C. § 4001, ET SEQ., AND THEIR IMPLEMENTING REGULATIONS. SPECIFICALLY, THE OCC FOUND THAT, SINCE AT LEAST 2011, BANA VIOLATED 42 U.S.C. § 4012A(E) (PLACEMENT OF FLOOD INSURANCE BY LENDER) AND 12 C.F.R. §§ 22.3 (REQUIREMENT TO PURCHASE FLOOD INSURANCE WHERE AVAILABLE) AND 22.9 (NOTICE OF SPECIAL FLOOD HAZARDS AND AVAILABILITY OF FEDERAL DISASTER RELIEF ASSISTANCE) IN MAKING, INCREASING, EXTENDING, RENEWING, AND/OR SERVICING "DESIGNATED LOANS" (LOANS SECURED BY BUILDINGS OR MOBILE HOMES LOCATED IN SPECIAL FLOOD HAZARD AREAS IN WHICH FLOOD INSURANCE IS AVAILABLE UNDER THE NATIONAL FLOOD INSURANCE ACT OF 1968). THE OCC FOUND THAT THESE VIOLATIONS RESULTED FROM DEFICIENT POLICIES, PROCEDURES, AND PROCESSES AND AN INEFFECTIVE FDPA COMPLIANCE PROGRAM. Status: Final Sanction Detail: IN THE ORDERS, BANA AGREED TO PAY A CIVIL MONEY PENALTY IN THE TOTAL AMOUNT OF $1,104,530.00, WHICH WAS PAID ON JULY 1, 2015, AND HAS AGREED TO CERTAIN REMEDIAL ACTIONS. SPECIFICALLY, BANA AGREED TO: (A) APPOINT AND MAINTAIN A COMPLIANCE COMMITTEE TO MONITOR AND OVERSEE BANA'S COMPLIANCE WITH THE ORDERS AND TO APPROVE MEASURES TO ENSURE COMPLIANCE; (B) SUBMIT AN ACCEPTABLE PLAN CONTAINING A COMPLETE DESCRIPTION OF THE ACTIONS TO ACHIEVE COMPLIANCE WITH THE ORDERS; (C) SUBMIT A WRITTEN PLAN TO EFFECTIVELY IMPLEMENT AN ENTERPRISE-WIDE PROGRAM TO ENSURE BANA'S COMPLIANCE WITH THE FDPA, ITS IMPLEMENTING REGULATIONS, AND FDPA-RELATED REGULATORY GUIDANCE; (D) SUBMIT POLICIES AND PROCEDURES FOR OUTSOURCING FDPA COMPLIANCE FUNCTIONS TO ANY AGENT, INDEPENDENT CONTRACTOR, CONSULTING FIRM, LAW FIRM, OR OTHER THIRD-PARTY (INCLUDING ANY AFFILIATE OF BANA); (E) DEVELOP A COMPREHENSIVE WRITTEN FDPA COMPLIANCE AUDIT PROGRAM; AND (F) SUBMIT THE WRITTEN PLANS, PROGRAMS, POLICIES, AND PROCEDURES REQUIRED BY THE ORDERS FOR REVIEW AND DETERMINATION OF NO SUPERVISORY OBJECT WITHIN A SPECIFIC TIME. Summary: IN SETTLEMENT OF THIS MATTER, BANA CONSENTED AND AGREED TO THE ISSUANCE OF THE ORDERS, WHICH THE OCC HAS DETERMINED TO ACCEPT AND HAS ISSUED. BANA NEITHER ADMITS NOR DENIES THE FINDINGS IN THE ORDERS. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDERS ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

Allegations: ON MAY 29, 2015, THE COMPTROLLER OF THE CURRENCY ("OCC") ISSUED AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY (TOGETHER, THE "ORDERS") AGAINST BANK OF AMERICA, N.A. ("BANA") RELATING TO THE SERVICEMEMBERS CIVIL RELIEF ACT ("SCRA") AND BANA'S SWORN DOCUMENT AND COLLECTIONS LITIGATION PRACTICES. IN THE ORDERS, THE OCC IDENTIFIED (I) UNSAFE OR UNSOUND PRACTICES IN CONNECTION WITH BANA'S EFFORTS TO COMPLY WITH THE SCRA, (II) SCRA VIOLATIONS, AND (III) UNSAFE OR UNSOUND PRACTICES IN CONNECTION WITH BANA'S SWORN DOCUMENT AND COLLECTIONS LITIGATION PRACTICES. REGARDING THE SCRA, THE ORDERS STATED BANA FAILED TO HAVE EFFECTIVE POLICIES AND PROCEDURES TO ENSURE COMPLIANCE WITH SCRA; FAILED TO DEVOTE SUFFICIENT FINANCIAL, STAFFING, AND MANAGERIAL RESOURCES TO ENSURE PROPER ADMINISTRATION OF ITS SCRA COMPLIANCE PROCESSES; FAILED TO DEVOTE TO ITS SCRA COMPLIANCE PROCESSES ADEQUATE INTERNAL CONTROLS, COMPLIANCE RISK MANAGEMENT, INTERNAL AUDIT, THIRD PARTY MANAGEMENT, AND TRAINING; AND ENGAGED IN VIOLATIONS OF THE SCRA. REGARDING THE SWORN DOCUMENT AND COLLECTIONS LITIGATION PROCESS, THE ORDERS STATED THAT BANA FILED OR CAUSED TO BE FILED IN COURTS AFFIDAVITS EXECUTED BY ITS EMPLOYEES OR EMPLOYEES OF THIRD PARTY SERVICE PROVIDERS MAKING ASSERTIONS THAT, IN MANY CASES, WERE NOT BASED ON PERSONAL KNOWLEDGE OR REVIEW OF RELEVANT BOOKS AND RECORDS; FILED OR CAUSED TO BE FILED IN COURT AFFIDAVITS WHEN BANA DID NOT FOLLOW PROPER NOTARY PROCEDURES; FAILED TO DEVOTE SUFFICIENT FINANCIAL, STAFFING, AND MANAGERIAL RESOURCES TO ENSURE PROPER ADMINISTRATION OF ITS SWORN DOCUMENT AND COLLECTIONS LITIGATION PROCESSES; AND FAILED TO SUFFICIENTLY OVERSEE OUTSIDE COUNSEL AND OTHER THIRD-PARTY PROVIDERS HANDLING SWORN DOCUMENT AND COLLECTIONS LITIGATION SERVICES. Status: Final Sanction Detail: IN THE ORDERS, BANA AGREED TO PAY A CIVIL MONEY PENALTY IN THE TOTAL AMOUNT OF $30 MILLION, HAS BEGUN CORRECTIVE ACTION, AND IS COMMITTED TO TAKING ALL NECESSARY AND APPROPRIATE STEPS TO REMEDY THE DEFICIENCIES, UNSAFE OR UNSOUND PRACTICES, AND VIOLATIONS OF LAW IDENTIFIED BY THE OCC, AND TO ENHANCE ITS SCRA COMPLIANCE PRACTICES AND SWORN DOCUMENT AND COLLECTIONS LITIGATION PRACTICES. SPECIFICALLY, BANA AGREED TO: (A) APPOINT AND MAINTAIN A COMPLIANCE COMMITTEE TO MONITOR AND OVERSEE BANA'S COMPLIANCE WITH THE ORDERS AND TO APPROVE MEASURES TO ENSURE COMPLIANCE; (B) SUBMIT AN ACCEPTABLE PLAN CONTAINING A COMPLETE DESCRIPTION OF THE ACTIONS TO ACHIEVE COMPLIANCE WITH THE ORDERS; (C) SUBMIT A WRITTEN PLAN TO EFFECTIVELY IMPLEMENT AN ENTERPRISE-WIDE COMPLIANCE RISK MANAGEMENT PROGRAM REGARDING COMPLIANCE WITH ALL APPLICABLE LAWS, REGULATIONS, AND REGULATORY GUIDANCE; (D) CONDUCT A WRITTEN, COMPREHENSIVE ASSESSMENT OF ITS RISK IN SCRA COMPLIANCE OPERATIONS, INCLUDING BUT NOT LIMITED TO, OPERATIONAL, COMPLIANCE, LEGAL, AND REPUTATIONAL RISKS; (E) SUBMIT ACCEPTABLE WRITTEN PLANS TO ENSURE ITS COMPLIANCE WITH THE SCRA AND WITH REGARD TO COLLECTIONS LITIGATION; (F) SUBMIT PLANS TO CONDUCT A SCRA REVIEW AND A COLLECTIONS LITIGATION REVIEW OF ACCOUNTS, SCRA AND COLLECTIONS LITIGATION REMEDIATION, AND SCRA INTERNAL AUDIT; (G) SUBMIT POLICIES AND PROCEDURES FOR SCRA THIRD PARTY MANAGEMENT AND IMPROVEMENTS TO ITS MANAGEMENT INFORMATION SYSTEMS FOR SCRA COMPLIANCE ACTIVITIES, AND TO PROVIDE CERTAIN REPORTS TO THE COMPLIANCE COMMITTEE; (H) SUBMIT WRITTEN PLANS, PROGRAMS, POLICIES, AND PROCEDURES REQUIRED BY THE ORDERS; AND (I) SUBMIT A WRITTEN PROGRESS REPORT DEALING THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE WITH THE PROVISION OF THE ORDERS AND THE RESULTS THEREOF. Summary: IN SETTLEMENT OF THIS MATTER, BANA CONSENTED AND AGREED TO THE ISSUANCE OF THE ORDERS, WHICH THE OCC HAS DETERMINED TO ACCEPT AND HAS ISSUED. BANA NEITHER ADMITS NOR DENIES THE FINDINGS IN THE ORDERS. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDERS ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

Allegations: THE RESERVE BANK OF INDIA ("RBI") ALLEGED THAT THE FIRM'S RECONCILIATION OF LOGS GENERATED FROM SWIFT WAS NOT SUFFICIENT AND VIOLATED THE DIRECTION OF THE RBI. Status: Final Sanction Detail: THE RBI ORDERED THE FIRM TO PAY A MONETARY PENALTY IN THE AMOUNT OF INR10,000,000, WHICH IS APPROXIMATELY USD $144,952.00. Summary: THE RBI ORDERED THE FIRM TO PAY A MONETARY PENALTY IN THE AMOUNT OF INR10,000,000, WHICH IS APPROXIMATELY USD $144,952.00.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION OF THE PHILIPPINES ("PHILIPPINES SEC") ALLEGED THAT THE FIRM DID NOT MEET CERTAIN REPORTING REQUIREMENTS IN THE PHILIPPINES REGARDING ITS REGIONAL AREA HEADQUARTERS ("RHQ"), WHICH HAD NOT ENGAGED IN ANY OPERATIONS IN THE PHILIPPINES FOR DECADES AND DID NOT PLAN TO ENGAGE IN ANY OPERATIONS IN THE PHILIPPINES IN THE FUTURE. Status: Final Sanction Detail: THE PHILIPPINES SEC SUSPENDED THE FIRM'S RHQ LICENSE TO TRANSACT BUSINESS IN THE PHILIPPINES. Summary: AN RHQ IS A SPECIAL TYPE OF "BRANCH" WHOSE AUTHORIZED ACTIVITIES ARE LIMITED TO ACTING AS AN ADMINISTRATIVE BRANCH OF A MULTINATIONAL COMPANY ENGAGED IN INTERNATIONAL TRADE AND PRINCIPALLY SERVES AS A SUPERVISION, COMMUNICATIONS AND COORDINATION CENTER FOR ITS SUBSIDIARIES, BRANCHES OR AFFILIATES IN THE ASIA-PACIFIC REGION AND OTHER FOREIGN MARKETS. THE FIRM'S RHQ HAD BEEN DORMANT FOR DECADES AND DID NOT ENGAGE IN ANY SECURITIES ACTIVITIES. AS A MEANS TO DEREGISTER THE RHQ, THE FIRM REQUESTED THAT THE PHILIPPINES SEC SUSPEND ITS LICENSE AND THE PHILIPPINES SEC GRANTED THE FIRM'S REQUEST.

Allegations: ON APRIL 7, 2014, THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ISSUED A CONSENT ORDER AGAINST BANK OF AMERICA, NATIONAL ASSOCIATION AND FIA CARD SERVICES, NATIONAL ASSOCIATION. THE ORDER IDENTIFIED DEFICIENCIES IN CONNECTION WITH FULFILLMENT OF CUSTOMER PROCESSING CONCERNING THE PROVISION OF IDENTITY THEFT PROTECTION PRODUCTS AS WELL AS VENDOR AND RISK MANAGEMENT PROTOCOLS CONCERNING SO-CALLED "ADD-ON" PRODUCTS. IN ADDITION, THE CFPB IDENTIFIED WHAT IT ALLEGED WERE DECEPTIVE STATEMENTS IN CONNECTION WITH THE MARKETING AND SALE OF CREDIT CARD DEBT CANCELLATION PRODUCTS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ANY FINDINGS OF FACT OR VIOLATIONS OF LAW OR WRONGDOING, BANK OF AMERICA, NATIONAL ASSOCIATION AND FIA CARD SERVICES, NATIONAL ASSOCIATION CONSENTED TO A CIVIL MONETARY PENALTY OF $20,000,000 AND TO CEASE AND DESIST FROM ENGAGING IN FURTHER VIOLATIONS OF LAW IN CONNECTION WITH THE MARKETING AND ADMINISTRATION OF CREDIT PROTECTION PRODUCTS AND THE BILLING AND ADMINISTRATION OF IDENTITY PROTECTION PRODUCTS. FURTHER, THE CONSENT ORDER REQUIRES A RESTITUTION PLAN TO BE SUBMITTED TO THE CFPB AND, FOLLOWING APPROVAL, THE PROVISION OF RESTITUTION TO BORROWERS. IN ADDITION, THE CONSENT ORDER REQUIRES THE SUBMISSION OF ENHANCED VENDOR MANAGEMENT POLICIES; ENHANCED RISK MANAGEMENT POLICIES AND PROCEDURES; AND ENHANCED INTERNAL AUDIT REVIEWS OF ADD-ON PRODUCTS TO ASSESS UNFAIR, DECEPTIVE, OR ABUSIVE ACTS OR PRACTICES ("UDAAP") RISK. Summary: WITHOUT ADMITTING OR DENYING ANY FINDINGS OF FACT OR VIOLATIONS OF LAW OR WRONGDOING, BANK OF AMERICA, NATIONAL ASSOCIATION AND FIA CARD SERVICES, NATIONAL ASSOCIATION CONSENTED TO A CIVIL MONETARY PENALTY OF $20,000,000 AND TO CEASE AND DESIST FROM ENGAGING IN FURTHER VIOLATIONS OF LAW IN CONNECTION WITH THE MARKETING AND ADMINISTRATION OF CREDIT PROTECTION PRODUCTS AND THE BILLING AND ADMINISTRATION OF IDENTITY PROTECTION PRODUCTS. FURTHER, THE CONSENT ORDER REQUIRES A RESTITUTION PLAN TO BE SUBMITTED TO THE CFPB AND, FOLLOWING APPROVAL, THE PROVISION OF RESTITUTION TO BORROWERS. IN ADDITION, THE CONSENT ORDER REQUIRES THE SUBMISSION OF ENHANCED VENDOR MANAGEMENT POLICIES; ENHANCED RISK MANAGEMENT POLICIES AND PROCEDURES; AND ENHANCED INTERNAL AUDIT REVIEWS OF ADD-ON PRODUCTS TO ASSESS UNFAIR, DECEPTIVE, OR ABUSIVE ACTS OR PRACTICES ("UDAAP") RISK.

Allegations: ON APRIL 7, 2014, THE COMPTROLLER OF THE CURRENCY OF THE UNITED STATES OF AMERICA ("OCC") ISSUED A CONSENT ORDER AGAINST BANK OF AMERICA, NATIONAL ASSOCIATION AND FIA CARD SERVICES, NATIONAL ASSOCIATION. THE ORDER IDENTIFIED DEFICIENCIES IN CONNECTION WITH FULFILLMENT OF CUSTOMER PROCESSING CONCERNING THE PROVISION OF IDENTITY THEFT PROTECTION PRODUCTS AS WELL AS VENDOR AND RISK MANAGEMENT PROTOCOLS CONCERNING SO-CALLED "ADD-ON" PRODUCTS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, BANK OF AMERICA, NATIONAL ASSOCIATION AND FIA CARD SERVICES, NATIONAL ASSOCIATION CONSENTED TO A CIVIL MONETARY PENALTY OF $25,000,000. FURTHER, THE CONSENT ORDER REQUIRES A RESTITUTION PLAN TO BE SUBMITTED TO THE OCC AND, FOLLOWING APPROVAL, THE PROVISION OF RESTITUTION TO BORROWERS. IN ADDITION, THE CONSENT ORDER REQUIRES THE SUBMISSION OF ENHANCED VENDOR MANAGEMENT POLICIES; ENHANCED RISK MANAGEMENT POLICIES AND PROCEDURES; AND ENHANCED INTERNAL AUDIT REVIEWS OF ADD-ON PRODUCTS TO ASSESS UNFAIR, DECEPTIVE, OR ABUSIVE ACTS OR PRACTICES ("UDAAP") RISK. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, BANK OF AMERICA, NATIONAL ASSOCIATION AND FIA CARD SERVICES, NATIONAL ASSOCIATION CONSENTED TO A CIVIL MONETARY PENALTY OF $25,000,000. FURTHER, THE CONSENT ORDER REQUIRES A RESTITUTION PLAN TO BE SUBMITTED TO THE OCC AND, FOLLOWING APPROVAL, THE PROVISION OF RESTITUTION TO BORROWERS. IN ADDITION, THE CONSENT ORDER REQUIRES THE SUBMISSION OF ENHANCED VENDOR MANAGEMENT POLICIES; ENHANCED RISK MANAGEMENT POLICIES AND PROCEDURES; AND ENHANCED INTERNAL AUDIT REVIEWS OF ADD-ON PRODUCTS TO ASSESS UNFAIR, DECEPTIVE, OR ABUSIVE ACTS OR PRACTICES ("UDAAP") RISK.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") ALLEGED THAT BANK OF AMERICA CORPORATION ("BAC") FAILED TO MAKE REQUIRED DISCLOSURES IN THE MANAGEMENT'S DISCUSSION AND ANALYSIS AND RESULTS OF OPERATIONS ("MD&A") SECTIONS OF PERIODIC FILINGS, RELATED TO KNOWN UNCERTAINTIES AS TO WHETHER CERTAIN COSTS RELATED TO LOANS BAC WOULD ULTIMATELY BE REQUIRED TO REPURCHASE FROM CERTAIN INSURERS WOULD HAVE A MATERIAL EFFECT ON BAC'S FUTURE INCOME FROM CONTINUING OPERATIONS. THE COMMISSION ALLEGED THAT BAC VIOLATED SECTION 13(A) OF THE EXCHANGE ACT AND RULES 12B-20 AND 13A-13 THEREUNDER. Status: Final Sanction Detail: BAC AGREED TO (1) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 13(A) OF THE EXCHANGE ACT AND RULES 12B-20 AND 13A-13 PROMULGATED THEREUNDER; AND (2) PAY A CIVIL MONEY PENALTY OF $20 MILLION. Summary: BAC ADMITTED TO CERTAIN FACTS SET OUT IN AN ANNEX TO THE ADMINISTRATIVE ORDER, ACKNOWLEDGED THAT ITS CONDUCT SET FORTH IN THE ANNEX TO THE ADMINISTRATIVE ORDER VIOLATED THE FEDERAL SECURITIES LAW AND ADMITTED TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") ALLEGED THAT BANK OF AMERICA CORPORATION ("BAC"), AS PART OF ITS REGULATORY CAPITAL CALCULATIONS, FAILED TO DEDUCT CERTAIN REALIZED LOSSES ON CERTAIN STRUCTURED NOTES AND OTHER FINANCIAL INSTRUMENTS (THE "NOTES") ISSUED BY MERRILL LYNCH & CO., INC. ("ML&CO.") THAT BAC ASSUMED OR ACQUIRED AS PART OF ITS ACQUISITION OF ML&CO. AND, THEREFORE, BAC OVERSTATED ITS REGULATORY CAPITAL IN ITS FORM 10-Q FILINGS FROM 2009-2014 AND IN ITS FORM 10-K FILINGS FOR FINANCIAL YEARS 2009-2013. THE COMMISSION ALLEGED THAT BAC VIOLATED SECTION 13(B)(2)(A) AND (B) OF THE EXCHANGE ACT. Status: Final Sanction Detail: BAC, WITHOUT ADMITTING OR DENYING THE COMMISSION'S FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS, AGREED TO (1) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE EXCHANGE ACT, AND (2) PAY A CIVIL MONEY PENALTY OF $7,650,000. THE PENALTY WAS PAID ON OCTOBER 7, 2014. Summary: THE COMMISSION NOTED THAT BAC SELF IDENTIFIED AND SELF REPORTED THE OVERSTATEMENTS AND THE COMMISSION NOTED THAT BAC HAD PROVIDED SUBSTANTIAL COOPERATION TO THE COMMISSION STAFF. THE COMMISSION ALSO NOTED THAT BAC HAD VOLUNTARILY UNDERTAKEN STEPS TO REMEDIATE AND ADDRESS, AMONG OTHER THINGS, THE INADEQUATE BOOKS AND RECORDS AND INTERNAL ACCOUNTING CONTROL DEFICIENCIES THAT WERE THE SUBJECT OF THE PROCEEDING.

Allegations: THE U.S. COMMODITY FUTURES TRADING COMMISSION (CFTC) ALLEGED THAT, ON OCCASION FROM JANUARY 2007 THROUGH DECEMBER 2012, THE FIRM, BY AND THROUGH CERTAIN OF ITS TRADERS, ATTEMPTED TO MANIPULATE THE U.S. DOLLAR INTERNATIONAL SWAPS AND DERIVATIVES ASSOCIATION FIX (USD ISDAFIX), A BENCHMARK RELATED TO INTEREST-RATE PRODUCTS, TO BENEFIT THE FIRM'S DERIVATIVES POSITIONS IN VIOLATION OF SECTION 9(A)(2) OF THE COMMODITY EXCHANGE ACT (CEA); SECTION 6(C) AND 6(D) OF THE CEA, FOR CONDUCT OCCURRING PRIOR TO AUGUST 15, 2011; AND SECTION 6(C)(1), 6(C)(1)(A), 6(C)(3) AND 6(D) OF THE CEA, AND REGULATIONS 180.1(A) AND 180.2, FOR CONDUCT OCCURRING ON OR AFTER AUGUST 15, 2011. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS IN THE ORDER, THE FIRM CONSENTED TO THE IMPOSITION OF THE FOLLOWING SANCTIONS: (1) TO CEASE AND DESIST FROM VIOLATING SECTIONS 6(C)(1), 6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2) OF THE CEA AND REGULATIONS 180.1(A) AND 180.2 THEREUNDER, (2) TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $30,000,000, AND (3) TO COMPLY WITH CERTAIN UNDERTAKINGS. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS IN THE ORDER, THE FIRM CONSENTED TO THE IMPOSITION OF THE FOLLOWING SANCTIONS: (1) TO CEASE AND DESIST FROM VIOLATING SECTIONS 6(C)(1), 6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2) OF THE CEA AND REGULATIONS 180.1(A) AND 180.2, (2) TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $30,000,000, WHICH THE FIRM PAID ON SEPTEMBER 24, 2018, AND (3) CONTINUE TO UNDERTAKE CERTAIN REMEDIATION EFFORTS, INCLUDING PROVIDING A REPORT TO THE CFTC WITHIN 120 DAYS OF THE ORDER ADDRESSING REMEDIATION EFFORTS BOTH PRIOR TO AND SINCE ENTRY OF THE ORDER, AND PROVIDING AN ADDITIONAL REPORT TO THE CFTC, NO LATER THAN 365 DAYS FROM ENTRY OF THE ORDER, EXPLAINING HOW THE FIRM HAS COMPLIED WITH THE UNDERTAKINGS SET FORTH IN THE ORDER.