Credicorp Capital Advisors Llc

Allegations: ON SEPTEMBER 3RD AND 4TH OF 2014, THE FIRM ENTERED INTO CERTAIN TRANSACTIONS OF FIXED INCOME COLOMBIAN TREASURIES AND OTHER BONDS WHICH CAUSED THE FIRM TO EXCEED ITS TRADING LIMITS AND CAUSED THE FIRM TO VIOLATE ITS "NET CAPITAL LIMITS" WHICH ARE KNOWN AS "PATRIMONIO TECNICO" IN COLOMBIA. THIS VIOLATION INVOLVED THE AMV (AUTOREGULADOR MERCADO DE VALORES) AND A SETTLEMENT WAS REACHED. Status: Final Sanction Detail: ULTRABURSATILES (NOW ULTRASERFINCO) WAS FINED $9,870 ($33,880,000 COLOMBIAN PESOS) AS RESULT OF REGULATORY ACTION. FINE WAS PAID IN FULL BY ULTRASERFINCO ON 09/07/2015. Summary: ULTRABURSATILES (NOW ULTRASERFINCO) WAS FINED $9,870 ($33,880,000 COLOMBIAN PESOS) AS RESULT OF REGULATORY ACTION. FINE WAS PAID IN FULL BY ULTRASERFINCO ON 09/07/2015.

Allegations: FAILURE TO TIMELY SUBMIT A REPORT OF CURRENCY EXCHANGE TRANSACTIONS TO THE COLOMBIAN CENTRAL BANK (BANCO DE LA REPÚBLICA) DUE TO A PLATFORM ERROR AND A HUMAN MISTAKE, SINCE THE PERSON IN CHARGE DID NOT VERIFY THAT THE INFORMATION WAS DULY SUBMITTED. REFERENCED REPORTS ARE REQUIRED TO BE SENT WITHIN TWO BUSINESS DAYS OF CURRENCY EXCHANGE TRANSACTION. THIS FAILURE RESULTED IN AN EXTEMPORARY SUBMISSION OF THE EXCHANGE STATEMENTS AND CONSEQUENTLY IN A BREACH OF AN EXCHANGE OBLIGATION. Status: Final Sanction Detail: ULTRASERFINCO WAS FINED $4,413 ($15,000,000 COLOMBIAN PESOS) AS RESULT OF REGULATORY ACTION. FINE WAS PAID IN FULL BY ULTRASERFINCO ON 12/01/2008. Summary: ULTRASERFINCO WAS FINED $4,413 ($15,000,000 COLOMBIAN PESOS) AS RESULT OF REGULATORY ACTION. FINE WAS PAID IN FULL BY ULTRASERFINCO ON 12/01/2008.

Allegations: 1. DUE TO HUMAN ERROR, THE CLASSIFICATION OF ACCOUNTING AND FINANCIAL INFORMATION REGARDING THE FIRM'S (HEREINAFTER, THE "FIRM") ASSETS AND THIRD PARTIES ASSETS WAS INCORRECTLY MADE. 2. APPLICABLE REGULATION PROVIDES THAT THE FIRM CANNOT CARRY OUT ITS ACTIVITIES THROUGH THIRD PARTIES, UNLESS THERE IS AN EXCEPTION IN THE APPLICABLE REGULATION, WHICH WAS NOT THE CASE. BASED ON ADVICE FROM AN UNRELATED THIRD-PARTY ATTORNEY, CERTAIN EMPLOYEES ESTABLISHED CORPORATIONS IN ORDER TO HAVE THEIR COMMISSIONS PAID INTO THE CORPORATIONS INSTEAD OF THEIR PERSONAL ACCOUNTS. THE FIRM HAD AGREEMENTS WITH THESE CORPORATIONS. THIS PRACTICE HAS BEEN ABOLISHED SINCE THEN. 3.APPLICABLE REGULATION HAS ESTABLISHED A MINIMUM LIMIT FOR MARGIN ACCOUNTS WHICH SHALL BE OBSERVED AT ALL TIMES AND THE FIRM INCURRED IN A BREACH OF THIS OBLIGATION. THE FIRM DID NOT SEGREGATE OR "HOLD" 5% OF THE AMOUNT OF EACH CLIENT TRANSACTION ON MARGIN PRIOR TO THE TRANSACTION. 4.THE FIRM ACCIDENTALLY REGISTERED A LOAN GRANTED TO A SHAREHOLDER WHO IS ALSO AN EMPLOYEE, AS A SHAREHOLDER'S LOAN IN THE FIRM'S BALANCE SHEET, ALTHOUGH IT WAS INTENDED TO BE AN EMPLOYEE`S LOAN. SINCE APPLICABLE REGULATION ESTABLISHES CERTAIN LIMITATIONS AND CONDITIONS TO SHAREHOLDERS' LOANS, THE LOAN AS GRANTED COULD NOT BE GIVEN TO A SHAREHOLDER AS IT WOULD RESULT INTO A BREACH OF A LEGAL RESTRICTION, AS IT WOUND OUT TO BE. LOANS COULD ONLY BE GRANTED TO EMPLOYEES FOR THE PURPOSE OF HOUSING, EDUCATION OR HEALTH. 5. AN EMPLOYEE FROM THE COMMERCIAL DEPARTMENT PROVIDED INACCURATE ADVICE TO A CLIENT REGARDING CERTAIN INVESTMENTS. Status: Final Sanction Detail: ULTRASERFINCO WAS FINED $20,770 ($70,587,338.67 COLOMBIAN PESOS) AS RESULT OF REGULATORY ACTION. FINE WAS PAID IN FULL BY ULTRASERFINCO ON 10/01/2017. Summary: ULTRASERFINCO WAS FINED $20,770 ($70,587,338.67 COLOMBIAN PESOS) AS RESULT OF REGULATORY ACTION. FINE WAS PAID IN FULL BY ULTRASERFINCO ON 10/01/2017.

Allegations: THE SEC ALLEGED THAT CREDICORP PUBLISHED COMMUNICATIONS ON ITS PUBLIC WEBSITE THAT CONSTITUTED "ADVERTISEMENTS" BECAUSE THEY OFFERED CREDICORP'S INVESTMENT ADVISORY SERVICES WITH REGARD TO SECURITIES TO PROSPECTIVE CLIENTS AND OFFERED NEW INVESTMENT ADVISORY SERVICES WITH REGARD TO SECURITIES TO CURRENT CLIENTS. THE ADVERTISEMENTS INCLUDED HYPOTHETICAL PERFORMANCE THAT CONSISTED OF PERFORMANCE DERIVED FROM MODEL PORTFOLIOS. THE ADVERTISEMENTS ON THE WEBSITE WERE DISSEMINATED TO THE GENERAL PUBLIC RATHER THAN TO A PARTICULAR INTENDED AUDIENCE. CREDICORP DISSEMINATED HYPOTHETICAL PERFORMANCE IN ADVERTISEMENTS TO A MASS AUDIENCE RATHER THAN PRESENTING HYPOTHETICAL PERFORMANCE RELEVANT TO THE LIKELY FINANCIAL SITUATION AND INVESTMENT OBJECTIVES OF THE INTENDED AUDIENCE. IN DOING SO, CREDICORP ALLEGEDLY FAILED TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT THE PERFORMANCE WAS RELEVANT TO THE LIKELY FINANCIAL SITUATION AND INVESTMENT OBJECTIVES OF THE INTENDED AUDIENCE. Status: Final Sanction Detail: THE ADVISER WAS ORDERED TO PAY A CIBIL MONEY PENALTY IN THE AMOUNT OF 30,000 TO THE COMMISSION. THE PAYMENT WAS COMPLETED ON 04/17/2024. Summary: ON JUNE 8, 2023, CREDICORP REMOVED THE ADVERTISEMENTS CONTAINING HYPOTHETICAL PERFORMANCE FROM ITS PUBLIC WEBSITE PRIOR TO BEING CONTACTED BY THE STAFF. TO THE EXTENT THE ADVISER PLANS TO DISSEMINATE ADVERTISEMENTS THAT CONTAIN HYPOTHETICAL PERFORMANCE, IT WILL EVALUATE, UPDATE, AND REVIEW FOR THE EFFECTIVENESS OF ITS IMPLEMENTATION, CREDICORP'S POLICIES AND PROCEDURES CONCERNING ADVERTISEMENTS THAT INCLUDE HYPOTHETICAL PERFORMANCE TO ENSURE THAT ITS POLICIES AND PROCEDURES ARE REASONABLY DESIGNED TO ENSURE THAT THE HYPOTHETICAL PERFORMANCE IS RELEVANT TO THE LIKELY FINANCIAL SITUATION AND INVESTMENT OBJECTIVES OF THE INTENDED AUDIENCE OF THE ADVERTISEMENT.