Morgan Stanley Eaton Vance Clo Manager Llc

Allegations: THE HELLENIC CAPITAL MARKET COMMISSION (HCMC) ALLEGED THAT MORGAN STANLEY COMMITTED MARKET MANIPULATION PURSUANT TO ARTICLE 7, PAR. 2(C) OF LAW 3340/2005 BY DISCLOSING THAT THE FIRM, THROUGH VARIOUS SUBSIDIARIES, HAD ACQUIRED MORE THAN 5% OF ALPHA BANK, HOWEVER 4.16% OF THE HOLDING WAS HELD BY A SUBSIDIARY AS CUSTODIAN ON BEHALF OF A CUSTOMER. Status: Final Sanction Detail: THE 50,000 EURO (APPROXIMATELY $52,960 USD) SUMMARY FINE WAS PAID ON JUNE 28, 2017. Summary: THE 50,000 EURO (APPROXIMATELY $52,960 USD) SUMMARY FINE WAS APPEALED ON MARCH 6, 2017, BUT THE APPEAL WAS REJECTED AND THE SUMMARY FINE BECAME FINAL ON APRIL 24, 2019.

Allegations: THE PORTUGUESE SECURITIES MARKET COMMISSION (CMVM) ALLEGED THAT THE FIRM DID NOT NOTIFY THE CMVM OR THE ISSUING COMPANY OF CHANGES TO CERTAIN QUALIFYING HOLDINGS WITHIN THE REQUIRED TIME PERIOD, IN VIOLATION OF ARTICLE 16 OF THE PORTUGUESE SECURITIES CODE Status: Final Sanction Detail: CAUTION Summary: ON MARCH 5, 2018, MORGAN STANLEY BECAME SUBJECT TO A DECISION BY THE PORTUGUESE SECURITIES MARKET COMMISSION (CMVM) IN WHICH THE CMVM ISSUED THE FIRM A CAUTION FOR THE WILLFUL BREACH OF (I) THE DUTY TO NOTIFY THE CMVM OF ITS QUALIFYING HOLDING, AND (II) THE DUTY TO NOTIFY THE ISSUING COMPANY OF ITS QUALIFYING HOLDING. THE CMVM ALSO REMINDED THE FIRM THAT IT IS UNDER STRICT LEGAL OBLIGATIONS THAT MUST BE COMPLIED WITH. THE CMVM SPECIFICALLY NOTED THAT, IN QUALIFYING THE FIRM'S CONDUCT AS WILLFUL MISCONDUCT, THIS DOES NOT MEAN THAT THE FIRM (SPECIFICALLY) ACTED WITH THE GOAL OF BREACHING THE LEGAL NORM IN QUESTION.

Allegations: HCMC ALLEGED THAT MS FAILED TO PROPERLY OR TIMELY REPORT WHEN MS HOLDINGS IN CERTAIN COMPANIES INCREASED OR DECREASED BY MORE THAN 3%, OR EXCEEDED OR FELL BELOW 5%, 10% AND 15% THRESHOLDS, AS REQUIRED BY GREEK PRESIDENTIAL DECREE PD 51/1992 AND LAW 3556/2007. Status: Final Sanction Detail: THE 71,000 EURO (~$94400 USD) SUMMARY FINE WAS PAID ON NOVEMBER 28, 2014. Summary: ON AUGUST 21, 2014, MORGAN STANLEY (MS) WAS INFORMED THAT THE BOARD OF DIRECTORS OF THE HELLENIC CAPITAL MARKET COMMISSION (HCMC) ISSUED A DECISION THAT COMMENDED A PROCEEDING ASSERTING THAT A) MS FAILED TO PROPERLY OR TIMELY REPORT WHEN MS HOLDINGS IN CERTAIN COMPANIES INCREASED OR DECREASED MORE BY THAN 3%, OR EXCEEDED OR FELL BELOW 5%, 10% AND 15% THRESHOLDS, AS REQUIRED BY GREEK PRESIDENTIAL DECREE PD 51/1992 AND LAW 3556/2007, AND B) MS SHOULD BE SUMMARILY FINED 71,000 EUROS (~$94400 USD). MS DID NOT CHALLENGE THE SUMMARY DECISION AND FINE, WHICH BECAME FINAL ON NOVEMBER 28, 2014 WHEN MS PAID THE SUMMARY FINE.

Allegations: THE ILLINOIS ATTORNEY GENERAL'S OFFICE ("ILAG") ALLEGED THAT MORGAN STANLEY VIOLATED ILLINOIS LAW IN CONNECTION WITH THE MARKETING, SALE, AND ISSUANCE OF CERTAIN RESIDENTIAL MORTGAGE-BACKED SECURITIES BETWEEN 2002 AND 2008. Status: Final Sanction Detail: MORGAN STANLEY MADE PAYMENT OF $22,500,000 BY WIRE TRANSFER ON 2/24/2016. Summary: ACTION STATUS AND (OR) DISPOSITION AND INCLUDE RELEVANT TERMS, CONDITIONS AND DATES: ON FEBRUARY 11, 2016, MORGAN STANLEY ENTERED INTO AN AGREEMENT (THE "ILAG SETTLEMENT AGREEMENT") WITH THE ILLINOIS ATTORNEY GENERAL TO PAY $22.5 MILLION TO RESOLVE CERTAIN POTENTIAL CLAIMS RELATED TO MORGAN STANLEY'S MARKETING, SALE AND ISSUANCE OF CERTAIN RESIDENTIAL MORTGAGE-BACKED SECURITIES. THE ILAG SETTLEMENT AGREEMENT WAS MADE IN CONJUNCTION WITH AN AGREEMENT BETWEEN MORGAN STANLEY AND CERTAIN MEMBERS OF THE PRESIDENT'S RMBS WORKING GROUP OF THE FINANCIAL FRAUD ENFORCEMENT TASK FORCE. THIS SETTLEMENT DOES NOT RESULT IN ANY FINDING OF VIOLATIONS OF LAW, AND CONSTITUTES A FINAL DEPOSITION OF THE POTENTIAL CLAIMS REFERENCED ABOVE.

Allegations: THE NEW YORK ATTORNEY GENERAL'S OFFICE ("NYAG") ALLEGED THAT MORGAN STANLEY VIOLATED NEW YORK LAW IN CONNECTION WITH THE MARKETING, SALE, AND ISSUANCE OF CERTAIN RESIDENTIAL MORTGAGE-BACKED SECURITIES BETWEEN 2006 AND 2007. Status: Final Sanction Detail: MORGAN STANLEY MADE PAYMENT OF $150,000,000 BY WIRE TRANSFER ON 2/24/2016. Summary: ACTION STATUS AND (OR) DISPOSITION AND INCLUDE RELEVANT TERMS, CONDITIONS AND DATES: ON FEBRUARY 11, 2016, MORGAN STANLEY ENTERED INTO AN AGREEMENT (THE "NYAG SETTLEMENT AGREEMENT") WITH THE NEW YORK ATTORNEY GENERAL TO PAY $150 MILLION TO RESOLVE CERTAIN POTENTIAL CLAIMS RELATED TO MORGAN STANLEY'S MARKETING, SALE AND ISSUANCE OF CERTAIN RESIDENTIAL-MORTGAGE BACKED SECURITIES. MORGAN STANLEY ALSO AGREED TO PROVIDE $400 MILLION OF CONSUMER RELIEF, ANDTHE REQUIREMENT OF AN INDEPENDENT MONITOR TO OVERSEE MORGAN STANLEY'S PROVISION OF THE CONSUMER RELIEF. THE NYAG SETTLEMENT AGREEMENT WAS MADE IN CONJUNCTION WITH AN AGREEMENT BETWEEN MORGAN STANLEY AND CERTAIN MEMBERS OF THE PRESIDENT'S RMBS WORKING GROUP OF THE FINANCIAL FRAUD ENFORCEMENT TASK FORCE. THIS SETTLEMENT DOES NOT RESULT IN ANY FINDING OF VIOLATIONS OF LAW, AND CONSTITUTES A FINAL DEPOSITION OF THE POTENTIAL CLAIMS REFERENCED ABOVE.