Old Bellows Partners L.P.

Allegations: ON JUNE 27, 2014, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY ("FSA") ISSUED A DECISION OF SURRENDER OF GAIN (THE "DECISION") AGAINST SCOGGIN WORLDWIDE FUND LTD., A PRIVATE INVESTMENT FUND ("FUND"), MANAGED BY REGISTRANT FOR VIOLATING THE SHORT SALE PROHIBITION OF SECTION 3-14 OF THE NORWEGIAN SECURITIES TRADING ACT WHICH REQUIRES A SHORT SELLER OF FINANCIAL INSTRUMENTS ("SECURITIES") TO ENSURE TIMELY DELIVERY OF SUCH SECURITIES ON THE TRADE SETTLEMENT DATE. THE DECISION FINDS THAT IN AUGUST 2013 THE FUND SOLD SHORT SHARES OF NORTHLAND RESOURCES S.A. ("NAUR") WITHOUT BEING ABLE TO DELIVER THE NAUR SHARES ON THE TRADE SETTLEMENT DATE. AT THE TIME THE FUND SHORT SOLD THE NAUR SHARES, REGISTRANT BELIEVED THAT THE FUND WOULD BE ABLE TO ENSURE TIMELY DELIVERY OF THE NAUR SHARES BY THE TRADE SETTLEMENT DATE. HOWEVER, THE FUND WAS ONLY ABLE TO SECURE ACCESS TO THE NAUR SHARES ONE DAY AFTER THE TRADE SETTLEMENT DATE. IN A RELATED ACTION, TWO ADVISORY AFFILIATES OF SCOGGIN MANAGEMENT LP, AN AFFILIATE OF REGISTRANT, WERE ALSO ASKED TO SURRENDER GAINS DUE TO THIS TRANSACTION. PLEASE SEE THE FORM ADV OF SCOGGIN MANAGEMENT LP FOR INFORMATION ABOUT THAT ACTION. Status: Final Sanction Detail: THE FUND WAS ORDERED TO DISGORGE A PORTION OF THE GAINS IT OBTAINED BY SELLING THE NAUR SHARES ONE DAY TOO EARLY. THE FSA CALCULATED SUCH GAINS AS THE PRICE DIFFERENCE BETWEEN THE FUND'S ACTUAL SALE PRICE FOR THE NAUR SHARES AND THE ESTIMATED HYPOTHETICAL SALE PRICE FOR THE SAME NUMBER OF SHARES ONE DAY LATER. BASED ON THAT CALCULATION, THE FSA ORDERED THE FUND TO DISGORGE NOK 1,844,423 WHICH EQUALED USD $301,324 ON THE DATE THE DECISION WAS ACCEPTED. Summary: ON JULY 24, 2014, THE FUND ACCEPTED THE DECISION TO DISGORGE THE GAINS ORDERED BY THE FSA. THE AMOUNT ORDERED TO BE DISGORGED BY THE FUND IS NOK 1,844,423 WHICH EQUALED USD $301,324 ON THE DATE THE DECISION WAS ACCEPTED.