Nomura Securities International, Inc.

Allegations: THE FEDERAL HOUSING FINANCE AGENCY (FHFA), AS CONSERVATOR FOR THE FEDERAL NATIONAL MORTGAGE ASSOCIATION (FANNIE MAE) AND THE FEDERAL HOME LOAN MORTGAGE CORPORATION (FREDDIE MAC) FILED A COMPLAINT AGAINST NOMURA HOLDING AMERICA INC., NOMURA ASSET ACCEPTANCE CORPORATION, NOMURA HOME EQUITY LOAN, INC., NOMURA CREDIT & CAPITAL, INC., NOMURA SECURITIES INTERNATIONAL, INC., CERTAIN OF THEIR OFFICERS AND AN UNAFFILIATED UNDERWRITER. THE SUIT ASSERTS CLAIMS PURSUANT TO SECTIONS 11, 12, AND 15 OF THE SECURITIES ACT OF 1933, STATE SECURITIES LAW AND STATE COMMON LAW IN CONNECTION WITH THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES TO FANNIE MAE AND FREDDIE MAC. THE SUIT ALLEGES THAT THE REGISTRATION STATEMENTS FOR SUCH SECURITIES CONTAINED MISSTATEMENTS AND OMISSIONS CONCERNING THE UNDERLYING MORTGAGES. Status: Final Summary: ON MAY 15, 2015 THE COURT ENTERED A FINAL JUDGMENT IN FAVOR OF THE PLAINTIFF AGAINST THE DEFENDANTS, JOINTLY AND SEVERALLY, ORDERING DEFENDANTS TO PAY APPROXIMATELY $806,000,000, PLUS ATTORNEY FEES AND COSTS, UPON DELIVERY OF THE RMBS CERTIFICATES TO DEFENDANTS BY THE GSES. A STAY OF EXECUTION HAS BEEN ENTERED. ON JUNE 10, 2015, THE DEFENDANTS FILED A NOTICE TO APPEAL WITH THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK. THE SUPREME COURT DENIED NOMURA'S PETITION FOR WRIT OF CERTIORARI ON JUNE 25, 2018.

Allegations: ALLEGED VIOLATIONS OF NASD MARKETPLACE RULE 6130 (D) AND NASD CONDUCT RULES 2110 AND 3010. Status: Final Sanction Detail: UNDERTAKING TO REVISE WRITTEN SUPERVISORY PROCEDURES. Summary: NASD ALLEGED THAT NOMURA DID NOT (A) REPORT TO ACT THE CORRECT SYMBOL INDICATING THE CAPACITY IN WHICH THE FIRM EXECUTED CERTAIN EQUITY TRANSACTIONS, AND (B) SPECIFY IN WRITTEN SUPERVISORY PROCEDURES CERTAIN MATTERS PERTAINING TO THE ALLEGED REPORTING INFRACTIONS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS , NOMURA CONSENTED TO THE SANCTIONS DESCRIBED ABOVE.

Allegations: NYSE ALLEDGED VIOLATIONS OF: SECTION 220.19 OF REGULATION T OF THE FEDERAL RESERVE SYSTEM AND EXCHANGE RULE 431(B), BY IMPROPERLY EXTENDING CREDIT TO A CUSTOMER; SEA RULE 15C3-1, BY FAILING TO DEDUCT CERTAIN MARGIN MAINTENANCE FROM ITS NET CAPITAL CALCULATION; SEA RULES 17A-3(A)(4)(VIII) AND 17A-4(B)(1) AND EXCHANGE RULE 440, BY FAILING TO PRESERVE AND MAINTAIN RECORDS OF CERTAIN EQUITY REVERSE REPURCHASE TRANSACTIONS FOR THE REQUIRED RETENTION PERIODS; AND EXCHANGE RULES 342(A) AND (B), BY FAILING TO REASONABLY SUPERVISE A BUSINESS ACTIVITY AND FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES FOR SUPERVISION AND CONTROL. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM HAS CONSENTED TO A CENSURE AND A FINE OF $400,000. Status: Final Sanction Detail: CENSURE AND FINE OF $400,000.

Allegations: NYSE ALLEGED VIOLATIONS: 1.VIOLATED EXCHANGE RULE 342.17 IN THAT THE FIRM FAILED TO PROVIDE FOR SURVEILLANCE AND FOLLOW-UP TO ENSURE THAT ITS WRITTEN POLICIES AND PROCEDURES ON ELECTRONIC COMMUNICATIONS WITH THE PUBLIC WERE IMPLEMENTED AND ADHERED TO BY ITS SUPERVISORY EMPLOYEES;2.VIOLATED EXCHANGE RULE 472(A)(1) IN THAT, ON ONE OR MORE OCCASIONS, THE FIRM FAILED TO ENSURE THAT ONE OR MORE EMPLOYEES' ELECTRONIC COMMUNICATIONS TO CUSTOMERS OR THE PUBLIC CONSTITUTING SALES LITERATURE AND/OR MARKET LETTERS WERE PROPERLY REVIEWED AND APPROVED;3.VIOLATED EXCHANGE RULE 345(A) IN THAT THE FIRM PERMITTED AN UNREGISTERED INDIVIDUAL TO PERFORM DUTIES CUSTOMARILY PERFORMED BY A REGISTERED REPRESENTATIVE;4.ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE IN THAT THE FIRM, ON ONE OR MORE OCCASIONS, THROUGH ONE OR MORE EMPLOYEES IMPROPERLY DISTRIBUTED TO THE PUBLIC A PROSPECTUS, AS DEFINED IN SECTION 2A(10) OF THE SECURITIES ACT OF 1933, PRIOR TO THE EFFECTIVE DATE OF REGISTRATION OF A SECONDARY OFFERING IN VIOLATION OF SECTION 5(B)(1) OF THE SECURITIES ACT OF 1933; 5.VIOLATED EXCHANGE RULE 342 IN THAT THE FIRM FAILED TO REASONABLY SUPERVISE ONE OR MORE EMPLOYEES TO PREVENT VIOLATIONS OF THE SECURITIES ACT OF 1933; AND 6.VIOLATED EXCHANGE RULE 440 AND SEA RULE 17A-4 IN THAT THE FIRM FAILED TO RETAIN CERTAIN ELECTRONIC MAIL MESSAGE ATTACHMENTS TRANSMITTED VIA BLOOMBERG INET SERVICE TO AND FROM ITS EMPLOYEES. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS THE FIRM HAS CONSENTED TO A CENSURE AND FINE OF$400,000. Status: Final Sanction Detail: CENSURE AND FINE OF $400,000.

Allegations: THE NYSE DIVISION OF ENFORCEMENT HAS NOTIFIED THE FIRM THAT IT IS NOW CONSIDERING BRINGING FORMAL DISCIPLINARY ACTION AGAINST THE FIRM FOR VIOLATING RULES 342, 401, 476 (A)(6) AND 345.11 Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF CENSURE AND A FINE IN THE AMOUNT OF $75,000.

Allegations: ALLEGED VIOLATION OF NASD RULE 6955(A). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS FINED $5,000. Summary: IT IS ALLEGED AS DURING THE PERIOD OF AUGUST 1 THROUGH DECEMBER 31, 2006, NOMURA SECURITIES INTERNATIONAL, INC. (NMRA) SUBMITTED 2,366 ROUTE REPORTS TO OATS THAT WERE INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED CONSTITUTING SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6955(A).

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM DID NOT ADHERE TO ISE RULE 400.02 BY FAILING TO EXPOSE THE FULL TERMS AND CONDITIONS OF AN ORDER TO THE MARKETPLACE PRIOR TO HEDGING ITS ANTICIPATED FACILITATION OF THE CUSTOMER ORDER. THE FIRM DID NOT MAINTAIN WRITTEN SUPERVISORY PROCEDURES ADDRESSING THE SUPERVISION OF THE PRE-HEDGE DISCLOSURE TO THE MARKETAND DID NOT ADEQUATELY TRAIN ITS STAFF WITH RESPECT TO THE FOREGOING IN VIOLATION OF ISE RULES 400 AND 401. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $22,750 WAS PAID TO ISE.

Allegations: WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, NOMURA SECURITIES INTERNATIONAL, INC. ("FIRM") CONSENTED TO THE SANCTIONS AND THE FINDINGS THAT FOR THE REVIEW PERIOD JANUARY 12-16, 2015, THE FIRM DID NOT SHOW THE TRANSMISSION TIMES FOR CUSTOMER ORDERS ROUTED TO THIRD-PARTY BROKERS ON THE MEMORANDA OF FIVE OPTIONS ORDERS FOUROF WHICH THE FIRM DID NOT RECORD THE CORRECT TIME OF ORDER RECEIPT IN VIOLATION OF EXCHANGE ACT RULE 17A-3(A)(6)(I) AND NASDAQ OMX PHLX, LLC RULE 760. THE FIRM ALSO FAILED TO MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO RECORDKEEPING REGARDING TRANSMISSION TIMES AND ACCURACY OF ORDER TIMESTAMPS IN VIOLATION OF EXCHANGE RULES 707 AND 748(H). Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED A TOTAL OF $24,000 TO BE PAID JOINTLY TO THE EXCHANGES IN RELATED DISCIPLINARY MATTERS, OF WHICH $8,000 WAS PAID TO NASDAQ PHLX, LLC, AND THE FIRM REVISED ITS WSPS.

Allegations: ALLEGES VIOLATION OF CBOE RULES 4.2,4.24 AND EXCHANGE ACT RULE 14E-4. Status: Final Sanction Detail: NOMURA SECURITIES INTERNATIONAL INC., WITHOUT ADMITTING OR DENYING A VIOLATION OF CBOE RULES HAS BEEN COMMITTED, AGREED TO THE LETTER OF CONSENT.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, CONSENTED THE SANCTIONS AND ENTRY OF VIOLATIONS INCLUDING (1) INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (FINRA RULE 7450(A); (2) INADEQUATE SUPERVISORY PROCEDURES REGARDING ACCURATE AND TIMELY REPORTING OF OATS DATA (FINRA RULE 2010 AND NASD RULE 3010); AND (3) FAILURE TO PROVIDE ACCURATE WRITTEN NOTIFICATIONS DISCLOSING TRANSACTION INFORMATION TO CUSTOMERS (SEC RULE 10B-10). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED $35,000.

Allegations: FINRA RULES 2010, 6730(A), 6730(C)(8): THE FIRM FAILED TO REPORT CERTAIN TRANSACTIONS IN TRACE ELIGIBLE SECURITIES (INCLUDING CERTAIN BLOCK TRANSACTIONS) TIMELY AND ACCURATELY. SEC RULE 17A-3, NASD RULE 3110: THE FIRM FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF CERTAIN BROKERAGE ORDERS. FINRA RULES 6622(A), 6380A(A), 6380A(A)(5), 7230A: THE FIRM FAILED TO TRANSMIT TO THE OTCRF AND FNTRF LAST SALE REPORTS OF CERTAIN TRANSACTIONS IN OTC EQUITY AND DESIGNATED SECURITIES TIMELY. FINRA RULE 2010 AND NASD RULE 3010: THE FIRM FAILED TO REASONABLY SUPERVISE TRADE REPORTING TO THE OTCRF AND FNTRF. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $32,500.

Allegations: SEC RULE 17A-3 AND NASD RULE 3110: THE FIRM FAILED TO DOCUMENT AN ACCURATE LONG/SHORT SELL INDICATION ON ITS LEDGER FOR CERTAIN TRANSACTIONS. FINRA RULE 6182: THE FIRM FAILED TO ACCURATELY REPORT CERTAIN TRANSACTIONS AS LONG OR SHORT TO THE FNTRF. FINRA RULE 7230A: IN CERTAIN INSTANCES, THE FIRM FAILED TO SUBMIT TO THE FNTRF THE CORRECT RELATED MARKET CENTER INDICATOR TO A NON-TAPE REPORT, FAILED TO MEDIA REPORT TRADES TO THE FNTRF AND FAILED TO REPORT TO THE FNTRF THE CORRECT SYMBOL INDICATING EXECUTION CAPACITY. SEC RULE 605 OF REGULATION NMS: THE FIRM IMPROPERLY CLASSIFIED NOT HELD ORDERS AS COVERED, ORDERS AS COVERED AND FAILED TO DISCLOSE CORRECT SEC RULE 605 ORDER EXECUTION STATISTICS FOR CERTAIN ORDER TYPE/SIZE CATEGORIES. FINRA RULE 7450: THE FIRM TRANSMITTED CERTAIN REPORTS TO OATS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. FINRA RULE 2010 AND NASD RULE 3010: THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $45,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES WITHIN 30 BUSINESS DAYS OF ACCEPTANCE.

Allegations: VIOLATIONS OF NYSE RULES 132.30(10), 342(A) AND (B), 440B.12, RULE 200(G) OF REGULATION SHO BASED ON THE FOLLOWING ALLEGATIONS: BETWEEN DECEMBER 3, 2008 AND JANUARY 20, 2010, NSI TRANSMITTED 74,343 ORDERS TO THE NYSE WITH INACCURATE ACCOUNT-TYPE INDICATORS, RESULTING IN 1,315,405 TRADE EXECUTIONS THAT WERE SUBMITTED FOR COMPARISON OR SETTLEMENT WITH INACCURATE ACCOUNT-TYPE INDICATORS. THE ORDERS WERE SUBMITTED WITH THE "A" ACCOUNT-TYPE INDICATOR RATHER THAN THE "P", "J," "K", OR "Y" ACCOUNT-TYPE INDICATORS. NSI FAILED TO IMPLEMENT ADEQUATE SYSTEMS AND CONTROLS, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH NYSE RULE 132.30(10). IN ADDITION, NSI MISMARKED APPROXIMATELY 957 LONG SALE ORDERS AS SHORT SALE ORDERS BETWEEN OCTOBER 30, 2009 AND JANUARY 28, 2010. NSI FAILED TO HAVE IN PLACE A SYSTEM OR PROCEDURE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH NYSE RULE 440B.12 AND RULE 200(G) OF REGULATION SHO. Status: Final Sanction Detail: CENSURE AND FINE OF $95,000 ORDERED AGAINST NSI. PAID 03/08/2013 Summary: WITHOUT ADMITTING OR DENYING GUILT, NSI CONSENTED TO THE ABOVE STIPULATED FACTS AND VIOLATIONS AND CONSENTED TO A CENSURE AND A $95,000 FINE. THE HEARING BOARD OFFICER, IN ACCEPTING THE STIPULATION OF FACTS AND CONSENT TO PENALTY, FOUND THAT NSI COMMITTED THE ABOVE VIOLATIONS. THE DECISION WAS RENDERED ON FEBRUARY 4, 2013, AND BECAME FINAL AT THE CLOSE OF BUSINESS ON MARCH 1, 2013 AFTER THE EXPIRATION OF THE REVIEW PERIOD. NO REVIEW WAS REQUESTED.

Allegations: WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, NOMURA SECURITIES INTERNATIONAL, INC. ("FIRM") AND NYSE ARCA, INC. ENTERED INTO AN OFFER OF SETTLEMENT AND CONSENT WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA"). DURING THE REVIEW PERIOD, THE FIRM DID NOT SHOW THE TRANSMISSION TIMES FOR CUSTOMER ORDERS ROUTED TO THIRD-PARTY BROKERS ON THE MEMORANDA OF NINE OPTIONS ORDERS, SIX OF WHICH THE FIRM DID NOT RECORD THE CORRECT TIME OF ORDER RECEIPT IN VIOLATION OF EXCHANGE ACT RULE 17A-3(A)(6)(I) AND NYSE ARCA OPTIONS RULE 6.68. THE FIRM ALSO FAILED TO MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO ADEQUATE RECORDKEEPING REGARDING TRANSMISSION TIMES AND ACCURACY OF ORDER TIMESTAMPS IN VIOLATION OF NYSE ARCA OPTIONS RULE 11.18. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED A TOTAL OF $24,000 TO BE PAID JOINTLY TO THE EXCHANGES IN RELATED DISCIPLINARY MATTERS, OF WHICH $8,000 WAS PAID TO NYSE ARCA, INC., AND THE FIRM REVISED ITS WSPS.

Allegations: SEC RULE 611(A)(1) OF REGULATION NMS - THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT TRADE-THROUGHS OF PROTECTED QUOTATIONS IN NATIONAL MARKET SYSTEM (NMS) STOCKS THAT DO NOT FALL WITHIN ANY APPLICABLE EXCEPTIONS, AND IF RELYING ON AN EXCEPTION, ARE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH THE TERMS OF THE EXCEPTION. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $7,500. THE FINE WAS PAID ON 5/10/13.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO A MONETARY FINE OF $12,500.00 AND A CENSURE AS ISO NON-IOC ORDERS LOCKED OR CROSSED PROTECTED QUOTES IN THE NASDAQ SINGLE BOOK. IN ADDITION, THE FIRM'S SUPERVISORY PROCEDURES DID NOT INCLUDE A SUPERVISORY REVIEW WITH RESPECT TO SUCH ORDERS AND ACTIVITY THEREBY VIOLATING RULES 3010, 4613(E) AND 4755(A) DURING THE PERIOD OF APRIL 1 - JUNE 30, 2011. Status: Final Sanction Detail: SEE QUESTION 7

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EFFECTED 29 TRANSACTIONS IN 21 SECURITIES IN VIOLATION OF NASD RULE 3340 AND SUBSEQUENTLY FINRA RULE 5260 ON OR AFTER DECEMBER 14, 2009 WHILE A TRADING HALT WAS IN EFFECT WITH RESPECT TO EACH OF THE SECURITIES DURING THE PERIOD OF 1/1/2009 TO 6/30/2011. Status: Final Sanction Detail: SEE ABOVE. FINE HAS BEEN PAID.

Allegations: VIOLATIONS OF NYSE RULES 132.30(10), 342(A) AND (B), 440B.12, RULE 200(G) OF REGULATION SHO BASED ON THE FOLLOWING ALLEGATIONS: BETWEEN DECEMBER 3, 2008 AND JANUARY 20, 2010, NSI TRANSMITTED 74,343 ORDERS TO THE NYSE WITH INACCURATE ACCOUNT-TYPE INDICATORS, RESULTING IN 1,315,405 TRADE EXECUTIONS THAT WERE SUBMITTED FOR COMPARISON OR SETTLEMENT WITH INACCURATE ACCOUNT-TYPE INDICATORS. THE ORDERS WERE SUBMITTED WITH THE "A" ACCOUNT-TYPE INDICATOR RATHER THAN THE "P", "J," "K", OR "Y" ACCOUNT-TYPE INDICATORS. NSI FAILED TO IMPLEMENT ADEQUATE SYSTEMS AND CONTROLS, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH NYSE RULE 132.30(10). IN ADDITION, NSI MISMARKED APPROXIMATELY 957 LONG SALE ORDERS AS SHORT SALE ORDERS BETWEEN OCTOBER 30, 2009 AND JANUARY 28, 2010. NSI FAILED TO HAVE IN PLACE A SYSTEM OR PROCEDURE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH NYSE RULE 440B.12 AND RULE 200(G) OF REGULATION SHO. Status: Final Sanction Detail: CENSURE AND FINE OF $95,000 ORDERED AGAINST NSI. Summary: WITHOUT ADMITTING OR DENYING GUILT, NSI CONSENTED TO THE ABOVE STIPULATED FACTS AND VIOLATIONS AND CONSENTED TO A CENSURE AND A $95,000 FINE. THE HEARING BOARD OFFICER, IN ACCEPTING THE STIPULATION OF FACTS AND CONSENT TO PENALTY, FOUND THAT NSI COMMITTED THE ABOVE VIOLATIONS. THE DECISION WAS RENDERED ON FEBRUARY 4, 2013, AND BECAME FINAL AT THE CLOSE OF BUSINESS ON MARCH 1, 2013 AFTER THE EXPIRATION OF THE REVIEW PERIOD. NO REVIEW WAS REQUESTED.

Allegations: THE NYSE DIVISION OF ENFORCEMENT HAS NOTIFIED THE FIRM THAT IT IS NOW CONSIDERING BRINGING FORMAL DISCIPLINARY ACTION AGAINST THE FIRM FOR VIOLATING RULES 342, 401, 476(A)(6) AND 345.11. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF CENSURE AND A FINE IN THE AMOUNT OF $75,000. Summary: CORRECTED INITIATED DATE TO 04/16/2007, Q8 TO FINAL AND Q10 TO ACCEPTANCE, WAIVER & CONSENT(AWC)

Allegations: ALLEGED VIOLATION OF NASD RULE 6955(A). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS FINED $5,000. Summary: IT IS ALLEGED AS DURING THE PERIOD AUGUST 1 THROUGH DECEMBER 31, 2006, NOMURA SECURITIES INTERNATIONAL, INC. (NMRA) SUBMITTED 2,366 ROUTE REPORTS TO OATS THAT WERE INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED CONSTITUTING SEPARATE AND DISTINCE VIOLATIONS OF NASD RULE 6955(A).

Allegations: SEC RULE 17A-3 AND NASD RULE 3110: THE FIRM FAILED TO DOCUMENT AN ACCURATE LONG/SHORT SELL INDICATION ON ITS LEDGER FOR CERTAIN TRANSACTIONS. FINRA RULE 6182: THE FIRM FAILED TO ACCURATELY REPORT CERTAIN TRANSACTIONS AS LONG OR SHORT TO THE FNTRF. FINRA RULE 7230A: IN CERTAIN INSTANCES, THE FIRM FAILED TO SUBMIT TO THE FNTRF THE CORRECT RELATED MARKET CENTER INDICATOR TO A NON-TAPE REPORT, FAILED TO MEDIA REPORT TRADES TO THE FNTRF AND FAILED TO REPORT TO THE FNTRF THE CORRECT SYMBOL INDICATING EXECUTION CAPACITY. SEC RULE 605 OF REGULATION NMS: THE FIRM IMPROPERLY CLASSIFIED NOT HELD ORDERS AS COVERED, ORDERS AS COVERED AND FAILED TO DISCLOSE CORRECT SEC RULE 605 ORDER EXECUTION STATISTICS FOR CERTAIN ORDER TYPE/SIZE CATEGORIES. FINRA RULE 7450: THE FIRM TRANSMITTED CERTAIN REPORTS TO OATS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. FINRA RULE 2010 AND NASD RULE 3010: THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $45,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES WITHIN 30 BUSINESS DAYS OF ACCEPTANCE. Summary: SEE ABOVE

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO A MONETARY FIND OF $12,500.00 AND A CENSURE AS ISO NON-IOC ORDERS LOCKED OR CROSSED PROTECTED QUOTES IN THE NASDAQ SINGLE BOOK. IN ADDITION, THE FIRM'S SUPERVISORY PROCEDURES DID NOT INCLUDE A SUPERVISORY REVIEW WITH RESPECT TO SUCH ORDERS AND ACTIVITY THEREBY VIOLATING RULES 3010, 4613(E) AND 4755(A) DURING THE PERIOD OF APRIL 1- JUNE 30, 2011 Status: Final Sanction Detail: SEE QUESTION 7 Summary: SEE ABOVE FOR DETAILS.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EFFECTED 29 TRANSACTIONS IN 21 SECURITIES IN VIOLATIN OF NASD RULE 3340 AND SUBSEQUENTLY FINRA RULE 5260 ON OR AFTER DECEMBER 14, 2009 WHILE A TRADING HALT WAS IN EFFECT WITH RESPECT TO EACH OF THE SECURITIES DURING THE PERIOD OF 1/1/2009-6/30/2011 Status: Final Sanction Detail: SEE ABOVE. FINE HAS BEEN PAID. Summary: SEE ABOVE.

Allegations: FINRA RULES 2010, 6730(A), 6730(C)(8): THE FIRM FAILED TO REPORT CERTAIN TRANSACTIONS IN TRACE ELIGIBLE SECURITIES (INCLUDING CERTAIN BLOCK TRANSACTIONS) TIMELY AND ACCURATELY. SEC RULE 17A-3, NASD RULE 3110: THE FIRM FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF CERTAIN BROKERAGE ORDERS. FINRA RULES 6622(A), 6380A(A), 6380A(A)(5), 7230A: THE FIRM FAILED TO TRANSMIT TO THE OTCRF AND FNTRF LAST SALE REPORTS OF CERTAIN TRANSACTIONS IN OTC EQUITY AND DESIGNATED SECURITIES TIMELY. FINRA RULE 2010 AND NASD RULE 3010: THE FIRM FAILED TO REASONABLY SUPERVISE TRADE REPORTING TO THE OTCRF AND FNTRF. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $32,500. Summary: SEE 7. ABOVE.

Allegations: SEC RULE 611(A)(1) OF REGULATION NMS - THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT TRADE-THROUGHS OF PROTECTED QUOTATIONS IN NATIONAL MARKET SYSTEM (NMS) STOCKS THAT DO NOT FALL WITHIN ANY APPLICABLE EXCEPTIONS, AND IF RELYING ON AN EXCEPTION, ARE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH THE TERMS OF THE EXCEPTION. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $7,500. THE FINE WAS PAID ON 5/10/13. Summary: SEE ABOVE FOR ALL DETAILS.

Allegations: FAILURE TO COMPLY WITH FREE RIDING AND WITHHOLDING Status: Final Sanction Detail: SEE ABOVE

Allegations: FAILED TO REPORT NASDAWQ VOLUME Status: Final Sanction Detail: SEE ABOVE

Allegations: FAILED TO SUBMIT AUDIT TRAIL DATA Status: Final Sanction Detail: SEE ABOVE

Allegations: ENTERED NASDAQ QUOTATIONS WITH EXCESS SPREADS Status: Final Sanction Detail: SEE ABOVE

Allegations: NMS TRADE REPORTING RULES XII SECTION 2 SCHEDULE D Status: Final Sanction Detail: SEE ABOVE

Allegations: FAILURE TO COMPLY WITH NET CAPITAL, CONDUCT INCONSISTENT WITH JUST/EQUITABLE PRINCIPAL OF TRADE-SRO; FAILURE TO SUPPLY NET CAPITAL INFORMATION OTHER-LEFT NON-QUALIFIED SECURITIES IN SPECIAL RESERVE ACCOUNT;FAILURE TO PROPERLY SUPERVISE, FAILURE TO MAKE REQUIRED DEPOSITS IN RESERVE ACCOUNTS; FAILURE TO MAKE ACCURATE RES FORMULA COMP SEC REGS 240 15C3-1, 240 15C3-3(E), 240 15C0-3(G); EXCHANGE RULE 342 Status: Final Sanction Detail: SEE ABOVE

Allegations: ENTERED TRANSACTIONS INTO SOES CONTRARY TO RULES; VIOLATED SOES C)3(C) AND ARTICLE III, SECTION 1 OF RULES OF FAIR PRACTICE. Status: Final Sanction Detail: SEE ABOVE

Allegations: VIOLATION OF NEW YORK STOCK EXCHANGE RULE 476(A)(11), LATE AND INACCURATE SUBMISSION OF RECORDS. THIS VIOLATION IS CONSIDERED TO BE MINOR IN NATURE BY THE EXCHANGE. Status: Final Sanction Detail: SEE ABOVE

Allegations: BOOKS AND RECORDS VIOLATION(S), FAILURE TO MEET FINANCIAL STANDARDS, FAILURE TO SUPERVISE, FALSE STATEMENTS OR OMISSIONS. Status: Final Sanction Detail: SEE ABOVE

Allegations: DURING THE PERIOD DECEMBER 18, 1996, THROUGH FEBRUARY 6, 1997, NOMURA SECURITIES INTERNATIONAL, INC. ALLEGEDLY EXECUTED CERTAIN SHORT SALES ORDERS IN A SECURITY WITHOUT MAKING AN AFFIRMATIVE DETERMINATION IN VIOLATION OF NASD CONDUCT RULE 3370 Status: Final Sanction Detail: SEE ABOVE

Allegations: CTR REPORTING INACCURACIES; RULE VIOLATIONS: 332.02; 332.08 AND 465.01 Status: Final Sanction Detail: SEE ABOVE

Allegations: THE AMEX ALLEGED THAT THE FIRM: 1) VIOLATED EXCHANGE RULE 30 BY FILING INACCURATE SHORT INTEREST REPORTS IN CERTAIN EQUITIES AND ETFS. 2) VIOLATED EXCHANGE RULE 320 BY FAILING TO HAVE WRITTEN SUPERVISORY PROCEDURES IN PLACE WITH RESPECT TO SHORT INTEREST REPORTING. Status: Final Sanction Detail: CENSURE AND FINE OF $30,000.

Allegations: ALLEGED VIOLATION OF NASD CONDUCT RULE 2110; DISTRICT VIOLATIONS OF NASD MARKETPLACE RULE 4632; VIOLATIONS OF NASD MARKETPLACE RULE 6420 Status: Final Sanction Detail: $5000.000, PAID ON NOVEMBER 9, 1999 Summary: IT IS ALLEGED AS DURING THE PERIOD OF OCTOBER 1 THROUGH DECEMBER 31, 1998, NOMURA SECURITIES INTERNATIONAL, INC. (NMRA) ENGAGED (1)IN A PATTERN OR PRACTICE OF LATE TRANSACTION REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES BY FAILING TO REPORT WITHIN 90 SECONDS AFTER EXECUTION 430 TRANSACTIONS IN ACT-ELIGIBLE SECURITIES TO ACT, RESULTING IN A VIOLATION OF NASD CONDUCT RULE 2110;(2) NMRA FAILED TO TRASMIT THROUGH ACT, WITHIN 90 SECONDS AFTER EXECUTION, LAST SALE REPORTS OF 31 TRANSACTIONS AS LATE TO ACT, CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD MARKETPLACE RULE 4632; (3)NMRA RESULTING IN A FAILURE TO REPORT TO ACT ON THE NEXT BUSINESS DAY BETWEEN 8:00AM AND 1:30PM NINE TRANSACTIONS IN LISTED SECURITIES AND FAILED TO DESIGNATE EACH SUCH TRANSACTION AS LATE TO ACT; AND(4)NMRA FAILED TO TRANSMIT THROUGH ACT, WITHIN 90 SECONDS AFTER EXECUTION, LAST SALE REPORTS OF SEVEN TRANSACTIONS IN LISTED SECURITIES AND FAILED TO DESIGNATE EACH SUCH TRANSACTION AS LATE TO ACT.ITEMS (3)AND(4) CONSTITUTING SEPARATE AND DISTINCT VIOLATIONS OF NASD MARKETPLACE RULE 6420.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH, DOCUMENT AND MAINTAIN A SYSTEM OF RISK MANAGEMENT CONTROLS AND WSPS REASONABLY DESIGNED TO MANAGE THE REGULATORY RISKS IN CONNECTION WITH MARKET ACCESS, FAILED TO PREVENT THE ENTRY OF ORDERS THAT EXCEED APPROPRIATE PRE-SET CREDIT LIMITS, FAILED TO HAVE SUPERVISORY CONTROLS AND PROCEDURES SUFFICIENT TO DETECT AND PREVENT POTENTIAL LAYERING, SPOOFING, WASH TRADING AND PRE-ARRANGED TRADING, AND FAILED TO DESIGNATE IN ITS WSPS THE INDIVIDUAL RESPONSIBLE FOR REVIEW, DESCRIBE THE TYPE OF ACTIVITY THAT WOULD WARRANT ADDITIONAL REVIEW, AND STATE SPECIFIC STEPS TO BE TAKEN AS PART OF THE REVIEW PROCESS. FURTHERMORE, THE FIRM FAILED TO TAKE REASONABLE STEPS TO PREVENT A CUSTOMER FROM ENGAGING IN POTENTIALLY MANIPULATIVE STRATEGIES. Status: Final Sanction Detail: THE FIRM WAS FINED A TOTAL OF $120,000 TO BE PAID JOINTLY TO EDGX, BATS EDGA EXCHANGE, INC., BATS BZX EXCHANGE, INC., THE NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NYSE MKT LLC, AND NEW YORK STOCK EXCHANGE LLC, OF WHICH A $20,000 FINE WAS TO BE PAID TO NYSE. THE FIRM WAS ALSO REQUIRED TO REVISE ITS WSPS TO ADDRESS THE DEFICIENCIES.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH, DOCUMENT AND MAINTAIN A SYSTEM OF RISK MANAGEMENT CONTROLS AND WSPS REASONABLY DESIGNED TO MANAGE THE REGULATORY RISKS IN CONNECTION WITH MARKET ACCESS, FAILED TO PREVENT THE ENTRY OF ORDERS THAT EXCEED APPROPRIATE PRE-SET CREDIT LIMITS, FAILED TO HAVE SUPERVISORY CONTROLS AND PROCEDURES SUFFICIENT TO DETECT AND PREVENT POTENTIAL LAYERING, SPOOFING, WASH TRADING AND PRE-ARRANGED TRADING, AND FAILED TO DESIGNATE IN ITS WSPS THE INDIVIDUAL RESPONSIBLE FOR REVIEW, DESCRIBE THE TYPE OF ACTIVITY THAT WOULD WARRANT ADDITIONAL REVIEW, AND STATE SPECIFIC STEPS TO BE TAKEN AS PART OF THE REVIEW PROCESS. FURTHERMORE, THE FIRM FAILED TO TAKE REASONABLE STEPS TO PREVENT A CUSTOMER FROM ENGAGING IN POTENTIALLY MANIPULATIVE STRATEGIES. Status: Final Sanction Detail: THE FIRM WAS FINED A TOTAL OF $120,000 TO BE PAID JOINTLY TO EDGX, BATS EDGA EXCHANGE, INC., BATS BZX EXCHANGE, INC., THE NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NYSE MKT LLC, AND NEW YORK STOCK EXCHANGE LLC, OF WHICH A $20,000 FINE WAS TO BE PAID TO NYSE MKT. THE FIRM WAS ALSO REQUIRED TO REVISE ITS WSPS TO ADDRESS THE DEFICIENCIES.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH, DOCUMENT AND MAINTAIN A SYSTEM OF RISK MANAGEMENT CONTROLS AND WSPS REASONABLY DESIGNED TO MANAGE THE REGULATORY RISKS IN CONNECTION WITH MARKET ACCESS, FAILED TO PREVENT THE ENTRY OF ORDERS THAT EXCEED APPROPRIATE PRE-SET CREDIT LIMITS, FAILED TO HAVE SUPERVISORY CONTROLS AND PROCEDURES SUFFICIENT TO DETECT AND PREVENT POTENTIAL LAYERING, SPOOFING, WASH TRADING AND PRE-ARRANGED TRADING, AND FAILED TO DESIGNATE IN ITS WSPS THE INDIVIDUAL RESPONSIBLE FOR REVIEW, DESCRIBE THE TYPE OF ACTIVITY THAT WOULD WARRANT ADDITIONAL REVIEW, AND STATE SPECIFIC STEPS TO BE TAKEN AS PART OF THE REVIEW PROCESS. FURTHERMORE, THE FIRM FAILED TO TAKE REASONABLE STEPS TO PREVENT A CUSTOMER FROM ENGAGING IN POTENTIALLY MANIPULATIVE STRATEGIES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT THE INTERMARKET SWEEP ORDERS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS AND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT DID NOT INCLUDE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS AND THE RULES OF BZX: (1) WRITTEN SUPERVISORY PROCEDURES THAT STATED ADEQUATE STEPS TO REVIEW INTERMARKET SWEEP ORDERS OF ITS SPONSORED ACCESS CLIENTS AND (2) REGULATORY RISK MANAGEMENT CONTROLS REASONABLY DESIGNED TO PREVENT THE ENTRY OF ORDERS THAT DO NOT COMPLY WITH ALL REGULATORY REQUIREMENTS. Status: Final Sanction Detail: THE FIRM WAS FINED A TOTAL OF $120,000 TO BE PAID JOINTLY TO EDGX, BATS EDGA EXCHANGE, INC., BATS BZX EXCHANGE, INC., THE NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NYSE MKT LLC, AND NEW YORK STOCK EXCHANGE LLC, OF WHICH A $20,000 FINE WAS TO BE PAID TO BATS BZX. THE FIRM WAS ALSO REQUIRED TO REVISE ITS WSPS TO ADDRESS THE DEFICIENCIES.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH, DOCUMENT AND MAINTAIN A SYSTEM OF RISK MANAGEMENT CONTROLS AND WSPS REASONABLY DESIGNED TO MANAGE THE REGULATORY RISKS IN CONNECTION WITH MARKET ACCESS, FAILED TO PREVENT THE ENTRY OF ORDERS THAT EXCEED APPROPRIATE PRE-SET CREDIT LIMITS, FAILED TO HAVE SUPERVISORY CONTROLS AND PROCEDURES SUFFICIENT TO DETECT AND PREVENT POTENTIAL LAYERING, SPOOFING, WASH TRADING AND PRE-ARRANGED TRADING, AND FAILED TO DESIGNATE IN ITS WSPS THE INDIVIDUAL RESPONSIBLE FOR REVIEW, DESCRIBE THE TYPE OF ACTIVITY THAT WOULD WARRANT ADDITIONAL REVIEW, AND STATE SPECIFIC STEPS TO BE TAKEN AS PART OF THE REVIEW PROCESS. FURTHERMORE, THE FIRM FAILED TO TAKE REASONABLE STEPS TO PREVENT A CUSTOMER FROM ENGAGING IN POTENTIALLY MANIPULATIVE STRATEGIES. Status: Final Sanction Detail: THE FIRM WAS FINED A TOTAL OF $120,000 TO BE PAID JOINTLY TO EDGX, BATS EDGA EXCHANGE, INC., BATS BZX EXCHANGE, INC., THE NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NYSE MKT LLC, AND NEW YORK STOCK EXCHANGE LLC, OF WHICH A $10,000 FINE WAS TO BE PAID TO BATS EDGA. THE FIRM WAS REQUIRED TO REVISE ITS WSPS TO ADDRESS THE DEFICIENCIES.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH, DOCUMENT AND MAINTAIN A SYSTEM OF RISK MANAGEMENT CONTROLS AND WSPS REASONABLY DESIGNED TO MANAGE THE REGULATORY RISKS IN CONNECTION WITH MARKET ACCESS, FAILED TO PREVENT THE ENTRY OF ORDERS THAT EXCEED APPROPRIATE PRE-SET CREDIT LIMITS, FAILED TO HAVE SUPERVISORY CONTROLS AND PROCEDURES SUFFICIENT TO DETECT AND PREVENT POTENTIAL LAYERING, SPOOFING, WASH TRADING AND PRE-ARRANGED TRADING, AND FAILED TO DESIGNATE IN ITS WSPS THE INDIVIDUAL RESPONSIBLE FOR REVIEW, DESCRIBE THE TYPE OF ACTIVITY THAT WOULD WARRANT ADDITIONAL REVIEW, AND STATE SPECIFIC STEPS TO BE TAKEN AS PART OF THE REVIEW PROCESS. FURTHERMORE, THE FIRM FAILED TO TAKE REASONABLE STEPS TO PREVENT A CUSTOMER FROM ENGAGING IN POTENTIALLY MANIPULATIVE STRATEGIES. Status: Final Sanction Detail: THE FIRM WAS FINED A TOTAL OF $120,000 TO BE PAID JOINTLY TO EDGX, BATS EDGA EXCHANGE, INC., BATS BZX EXCHANGE, INC., THE NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NYSE MKT LLC, AND NEW YORK STOCK EXCHANGE LLC, OF WHICH A $10,000 FINE WAS TO BE PAID TO BATS EDGX. THE FIRM WAS REQUIRED TO REVISE ITS WSPS TO ADDRESS THE DEFICIENCIES.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REASONABLY AVOID DISPLAYING, AND ENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED A PROTECTED QUOTATION. ALSO, THE FIRM FAILED TO ESTABLISH, DOCUMENT AND MAINTAIN A SYSTEM OF RISK MANAGEMENT CONTROLS AND WSPS REASONABLY DESIGNED TO MANAGE THE REGULATORY RISKS IN CONNECTION WITH MARKET ACCESS, FAILED TO PREVENT THE ENTRY OF ORDERS FOR WHICH ALL REGULATORY REQUIREMENTS HAD NOT BEEN MET ON A PRE-ORDER BASIS, FAILED TO PREVENT THE ENTRY OF ORDERS THAT EXCEED APPROPRIATE PRE-SET CREDIT LIMITS, FAILED TO HAVE SUPERVISORY CONTROLS AND PROCEDURES SUFFICIENT TO DETECT AND PREVENT POTENTIAL LAYERING, SPOOFING, WASH TRADING AND PRE-ARRANGED TRADING, AND FAILED TO DESIGNATE IN ITS WSPS THE INDIVIDUAL RESPONSIBLE FOR REVIEW, DESCRIBE THE TYPE OF ACTIVITY THAT WOULD WARRANT ADDITIONAL REVIEW, AND STATE SPECIFIC STEPS TO BE TAKEN AS PART OF THE REVIEW PROCESS. FURTHERMORE, THE FIRM FAILED TO TAKE REASONABLE STEPS TO PREVENT A CUSTOMER FROM ENGAGING IN POTENTIALLY MANIPULATIVE STRATEGIES. Status: Final Sanction Detail: THE FIRM WAS FINED A TOTAL OF $30,000 TO BE PAID TO NASDAQ STOCK MARKET LLC. THE FIRM WAS REQUIRED TO REVISE ITS WSPS TO ADDRESS THE DEFICIENCIES.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH, DOCUMENT AND MAINTAIN A SYSTEM OF RISK MANAGEMENT CONTROLS AND WSPS REASONABLY DESIGNED TO MANAGE THE REGULATORY RISKS IN CONNECTION WITH MARKET ACCESS, FAILED TO PREVENT THE ENTRY OF ORDERS THAT EXCEED APPROPRIATE PRE-SET CREDIT LIMITS, FAILED TO HAVE SUPERVISORY CONTROLS AND PROCEDURES SUFFICIENT TO DETECT AND PREVENT POTENTIAL LAYERING, SPOOFING, WASH TRADING AND PRE-ARRANGED TRADING, AND FAILED TO DESIGNATE IN ITS WSPS THE INDIVIDUAL RESPONSIBLE FOR REVIEW, DESCRIBE THE TYPE OF ACTIVITY THAT WOULD WARRANT ADDITIONAL REVIEW, AND STATE SPECIFIC STEPS TO BE TAKEN AS PART OF THE REVIEW PROCESS. FURTHERMORE, THE FIRM FAILED TO TAKE REASONABLE STEPS TO PREVENT A CUSTOMER FROM ENGAGING IN POTENTIALLY MANIPULATIVE STRATEGIES. Status: Final Sanction Detail: THE FIRM WAS FINED A $20,000 PAID TO NASDAQ PHLX. THE FIRM WAS ALSO REQUIRED TO REVISE ITS WSPS TO ADDRESS THE DEFICIENCIES.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) THE CORRECT CONTRA PARTY IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE AGENCY DEBT SECURITIES. THE FINDINGS STATED THAT THE FIRM OVER-REPORTED TRANSACTIONS IN TRACE-ELIGIBLE AGENCY DEBT SECURITIES. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $7,500.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM'S SUPERVISORY SYSTEM FOR REVIEWING SECURITIES TRANSACTIONS WAS NOT REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE ANTICIPATORY HEDGING AND FRONTRUNNING RULES, IN THAT THE FIRM FAILED TO ENFORCE COMPLIANCE WITH ITS WRITTEN SUPERVISORY PROCEDURES (WSPS) APPLICABLE TO ANTICIPATORY HEDGING AND FRONT-RUNNING TRANSACTIONS AND FAILED TO HAVE WSPS TO ADDRESS, OR PROVIDE FOR THE SUPERVISION OF, TRANSACTIONS DESIGNED TO HEDGE THE PARTIAL EXPOSURE OF CUSTOMER ORDERS TO ENSURE COMPLIANCE WITH APPLICABLE ANTICIPATORY HEDGING AND FRONT-RUNNING RULES. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $40,000.

Allegations: NASDAQ PHLX LLC FOUND THAT WHILE IN POSSESSION OF THE MATERIAL TERMS AND CONDITIONS OF A CUSTOMER'S IMMINENT TRANSACTION AND AFTER PARTIALLYEXPOSING A PORTION OF THAT CUSTOMER'S ORDER TO THE MARKETPLACE, THE FIRM SOLD SHARES OF THE COMPANY'S SECURITIES FOR ITS PROPRIETARY ACCOUNT TO HEDGE ITS ANTICIPATED FACILITATION OF THE CUSTOMER'S ORDER. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ENFORCE COMPLIANCE WITH ITS WSPS REGARDING ESCALATION OF ANTICIPATORY AND FRONT-RUNNING RULES TO PROPER FIRM PERSONNEL AND THAT THE FIRM'S WSPS DID NOT PROVIDE FOR THE SUPERVISION OFTRANSACTIONS DESIGNED TO HEDGE THE PARTIAL EXPOSURE OF CUSTOMER ORDERS. THE FINDINGS ALSO INCLUDED THAT THE FIRM ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE IN VIOLATION OF EXCHANGE RULE 707. Status: Final Sanction Detail: THE FIRM IS CENSURED AND FINED $40,000.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS FOR REG SHO VIOLATIONS, SPECIFICALLY, THAT THE FIRM ALLOWED A DIRECT MARKET ACCESS CUSTOMER TO ENTER SHORT SALE ORDERS THROUGH ITS SYSTEM WITHOUT DETERMINING THAT ITS SHORT SALE VOLUME DID NOT EXCEED ITS APPROVED LOCATE QUANTITY AND FAILURE TO ESTABLISH AND MAINTAIN A SYSTEM OF CONTROLS AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RULE 203(B)(1) OF REGULATION SHO. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $17,500 AND HAD AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES.

Allegations: WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND THE FINDINGS THAT THE FIRM DID NOT ADHERE TO NYSE AMERICAN RULE 995NY(C) BY FAILING TO EXPOSE THE FULL TERMS AND CONDITIONS OF AN ORDER TO THE MARKETPLACE PRIOR TO HEDGING ITS ANTICIPATED FACILITATION OF THE CUSTOMER ORDER. THE FIRM DID NOT MAINTAIN WRITTEN SUPERVISORY PROCEDURES ADDRESSING THE SUPERVISION OF THE PRE-HEDGE DISCLOSURE TO THE MARKET AND DID NOT ADEQUATELY TRAIN ITS STAFF WITH RESPECT TO THE FOREGOING IN VIOLATION OF EXCHANGE RULE 320. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $29,500 WAS PAID TO NYSE AMERICAN.

Allegations: WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND THE FINDINGS THAT THE FIRM DID NOT ADHERE TO PHLX RULES 1064(D) AND 707 BY FAILING TO EXPOSE THE FULL TERMS AND CONDITIONS OF AN ORDER TO THE MARKETPLACE PRIOR TO HEDGING ITS ANTICIPATED FACILITATION OF THE CUSTOMER ORDER. THE FIRM DID NOT MAINTAIN WRITTEN SUPERVISORY PROCEDURES ADDRESSING THE SUPERVISION OF THE PRE-HEDGE DISCLOSURE TO THE MARKET AND DID NOT ADEQUATELY TRAIN ITS STAFF WITH RESPECT TO THE FOREGOING IN VIOLATION OF PHLX RULE 748, SUBPARAGRAPHS (B), (D), AND (H). Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $30,250 WAS PAID TO PHLX.

Allegations: WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, NOMURA SECURITIES INTERNATIONAL, INC. ("FIRM") CONSENTED TO THE SANCTIONS AND THE FINDINGS THAT FOR THE REVIEW PERIOD JANUARY 12-16, 2015, THE FIRM DID NOT SHOW THE TRANSMISSION TIMES FOR CUSTOMER ORDERS ROUTED TO THIRD-PARTY BROKERS ON THE MEMORANDA OF FIVE OPTIONS ORDERS FOUROF WHICH THE FIRM DID NOT RECORD THE CORRECT TIME OF ORDER RECEIPT IN VIOLATION OF EXCHANGE ACT RULE 17A-3(A)(6)(I) AND NYSE AMERICAN RULE 956NY. THE FIRM ALSO FAILED TO MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO RECORDKEEPING REGARDING TRANSMISSION TIMES AND ACCURACY OF ORDER TIMESTAMPS IN VIOLATION OF NYSE AMERICAN RULE 320. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED A TOTAL OF $24,000 TO BE PAID JOINTLY TO THE EXCHANGES IN RELATED DISCIPLINARY MATTERS, OF WHICH $8,000 WAS PAID TO NYSE AMERICAN, AND THE FIRM REVISED ITS WSPS.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO EXPOSE THE FULL TERMS AND CONDITIONS OF AN ORDER TO THE MARKETPLACE PRIOR TO HEDGING ITS ANTICIPATED FACILITATION OF THE CUSTOMER ORDER. THE FIRM DID NOT ADEQUATELY SUPERVISE TO ASSURE COMPLIANCE WITH EXCHANGE RULES, INCLUDING EXCHANGE RULES 4.1, 4.2 AND 6.9. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $17,500 WAS PAID TO CBOE AND DISGORGEMENT IN THE AMOUNT OF $5,134 TO CBOE.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO A CENSURE AND A FINE IN THE AMOUNT OF $875,000 AND TO THE ENTRY OF FINDINGS THAT THE FIRM INCORRECTLY CALCULATED ITS PROPRIETARY ACCOUNTS OF BROKER DEALERS ("PAB") RESERVE COMPUTATION, RESULTING IN A SHORTFALL IN THE FIMR'S PAB RESERVE ACCOUNT. THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ENSURE THAT THE FIRM PROPERLY CALCULATED THE PAB RESERVE COMPUTATION AND PREVENT AND DETECT ANY ERRORS IN THAT CALCULATION. BECAUSE OF ITS FAILURE TO CORRECTLY CALCULATE THE PAB RESERVE COMPUTATION, NOMURA ALSO FAILED TO MAINTAIN ACCURATE BOOKS AND RECORDS. BY VIRTUE OF THE FOREGOING, THE FIRM VIOLATED RULE 15C-3-3 AND FINRA RULES 2010, 3110 AND 4511. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL OF $875,000.

Allegations: OFFER OF SETTLEMENT IN WHICH NSI NEITHER ADMITTED OR DENIED THE RULE VIOLATIONS UPON WHICH PENALTY IS BASED. Status: Final Sanction Detail: OFFER OF SETTLEMENT IN WHICH NSI NEITHER ADMITTED OR DENIED THE RULE VIOLATIONS UPON WHICH PENALTY IS BASED.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO COMPLY WITH FINRA'S SHORT INTEREST REPORTING REQUIREMENTS CONCERNING THE REPORTING OF CERTAIN FOREIGN-LISTED SECURITIES. THE FINDINGS STATED THAT THE FIRM EXPERIENCED A SYSTEM RELATED CODING ISSUE THAT RESULTED IN THE EXCLUSION OF CERTAIN FOREIGN-LISTED SECURITIES FROM ITS SHORT INTEREST SUBMISSIONS TO FINRA. AS A RESULT OF THE CODING ISSUE, THE FIRM FAILED TO REPORT 3,129 SHORT INTEREST POSITIONS TOTALING 885,607,733 SHARES. IN ADDITION, THE FIRM INACCURATELY REPORTED SIX SHORT INTEREST POSITIONS TOTALING 6,790 SHARES WHEN IT SHOULD HAVE REPORTED SIX SHORT INTEREST POSITIONS TOTALING 68,724 SHARES. UPON RECEIVING NOTIFICATION FROM FINRA OF THE REPORTING DEFICIENCIES, THE FIRM IDENTIFIED AND CORRECTED THE CODING ISSUE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM TO ENSURE THAT IT WAS IN FACT INCLUDING ALL REPORTABLE POSITIONS IN ITS FINRA RULE 4560 SUBMISSIONS, INCLUDING REPORTABLE POSITIONS IT HELD IN FOREIGN-LISTED SECURITIES. THE FIRM HAS UPDATED ITS SUPERVISORY SYSTEM, INCLUDING ITS WRITTEN SUPERVISORY PROCEDURES, AND ADDRESSED THE SUPERVISORY DEFICIENCIES. Status: Final Sanction Detail: CENSURED AND FINED $300,000.00

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES, OR FAILED TO INCLUDE ANY TRANSMISSION TIME, ON MANUAL OPTIONS ORDERS IT HAD ROUTED TO PHLX AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FIRM ALSO FAILED TO ESTABLISH AND MAINTAIN WSPS AND A SUPERVISORY SYSTEM APPLICABLE TO ITS EQUITY DERIVATIVES TRADING DESK THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND PHLX RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES ON OPTIONS ORDERS. ALTHOUGH THE FIRM'S WSPS REQUIRED ENTRY OF THE ORDER RECEIPT TIME, THEY DID NOT REQUIRE THE ENTRY OF THE ORDER TRANSMISSION TIME. ADDITIONALLY, THE SUPERVISORY REVIEW ACTUALLY CONDUCTED WAS LIMITED TO DETERMINING WHETHER THE TIMESTAMP WAS PRESENT. GIVEN THE POTENTIAL FOR HUMAN ERROR IN CONNECTION WITH MANUAL ORDERS, THE FIRM'S QUARTERLY SAMPLING OF FIVE RANDOMLY SELECTED MANUAL ORDERS WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND PHLX RULES. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $33,333.34 SHALL BE PAID TO THE EXCHANGE. THE BALANCE OF THE FINE SHALL BE PAID TO NYSE ARCA, INC. AND NYSE AMERICAN LLC.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES, OR FAILED TO INCLUDE ANY TRANSMISSION TIME, ON MANUAL OPTIONS ORDERS IT HAD ROUTED TO NYSE AMERICAN AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FIRM ALSO FAILED TO ESTABLISH AND MAINTAIN WSPS AND A SUPERVISORY SYSTEM APPLICABLE TO ITS EQUITY DERIVATIVES TRADING DESK THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND NYSE AMERICAN RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES ON OPTIONS ORDERS. ALTHOUGH THE FIRM'S WSPS REQUIRED ENTRY OF THE ORDER RECEIPT TIME, THEY DID NOT REQUIRE THE ENTRY OF THE ORDER TRANSMISSION TIME. ADDITIONALLY, THE SUPERVISORY REVIEW ACTUALLY CONDUCTED WAS LIMITED TO DETERMINING WHETHER THE TIMESTAMP WAS PRESENT. GIVEN THE POTENTIAL FOR HUMAN ERROR IN CONNECTION WITH MANUAL ORDERS, THE FIRM'S QUARTERLY SAMPLING OF FIVE RANDOMLY SELECTED MANUAL ORDERS WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND NYSE AMERICAN RULES. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $100,000, OF WHICH $33,333.33 SHALL BE PAID TO THE EXCHANGE. THE BALANCE OF THE FINE SHALL BE PAID TO NASDAQ PHLX LLC AND NYSE ARCA, INC.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES, OR FAILED TO INCLUDE ANY TRANSMISSION TIME, ON MANUAL OPTIONS ORDERS IT HAD ROUTED TO NYSE ARCA AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FIRM ALSO FAILED TO ESTABLISH AND MAINTAIN WSPS AND A SUPERVISORY SYSTEM APPLICABLE TO ITS EQUITY DERIVATIVES TRADING DESK THAT WERE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND NYSE ARCA RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES ON OPTIONS ORDERS. ALTHOUGH THE FIRM'S WSPS REQUIRED ENTRY OF THE ORDER RECEIPT TIME, THEY DID NOT REQUIRE THE ENTRY OF THE ORDER TRANSMISSION TIME. ADDITIONALLY, THE SUPERVISORY REVIEW ACTUALLY CONDUCTED WAS LIMITED TO DETERMINING WHETHER THE TIMESTAMP WAS PRESENT. GIVEN THE POTENTIAL FOR HUMAN ERROR IN CONNECTION WITH MANUAL ORDERS, THE FIRM'S QUARTERLY SAMPLING OF FIVE RANDOMLY SELECTED MANUAL ORDERS WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND NYSE ARCA RULES. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $100,000, OF WHICH $33,333.33 SHALL BE PAID TO THE EXCHANGE. THE BALANCE OF THE FINE SHALL BE PAID TO NASDAQ PHLX LLC AND NYSE AMERICAN LLC.

Allegations: WITHOUT EITHER ADMITTING NOR DENYING VIOLATING EXCHANGE RULES, FOUND THE FIRM GUILTY OF VIOLATING CBOT RULE 980.B.3., AND FINED THE FIRM $50,000. Status: Final Sanction Detail: WITHOUT EITHER ADMITTING NOR DENYING VIOLATING EXCHANGE RULES, FOUND THE FIRM GUILTY OF VIOLATING CBOT RULE 980.B.3., AND FINED THE FIRM $50,000.

Allegations: WITHOUT EITHER ADMITTING NOR DENYING VIOLATING EXCHANGE RULES, FOUND THE FIRM GUILTY OF VIOLATING CBOT RULES 538.C (RELATED POSITION) AND 543 (WASH TRADES PROHIBITED) Status: Final Sanction Detail: WITHOUT EITHER ADMITTING NOR DENYING VIOLATING EXCHANGE RULES, FOUND THE FIRM GUILTY OF VIOLATING CBOT RULES 538.C (RELATED POSITION) AND 543 (WASH TRADES PROHIBITED)

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ACCURATELY CALCULATE ITS NET CAPITAL. THE FINDINGS STATED THAT THE FIRM MISCLASSIFIED CERTAIN REVERSE REPURCHASE AGREEMENTS WITH ITS CORPORATE AFFILIATE AS ALLOWABLE ASSETS. BECAUSE THE SECURITIES SUBJECT TO THE REVERSE REPURCHASE AGREEMENTS WERE UNDER THE CORPORATE AFFILIATE'S CUSTODY AND CONTROL, THE FIRM SHOULD HAVE CLASSIFIED THE REVERSE REPURCHASE AGREEMENTS AS NON-ALLOWABLE ASSETS IN ITS NET CAPITAL CALCULATIONS Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $125,000.

Allegations: PURSUANT TO AN OFFER OF SETTLEMENT THAT NOMURA SECURITIES CO., LTD. ("NOMURA") PRESENTED AT A HEARING, TWO TRADERS EMPLOYED BY NOMURA PREARRANGED FIVE TRADES TOTALING 600 LOTS OF DECEMBER 2011 GOLD FUTURES CONTRACTS FOR THE PURPOSE OF TRANSFERRING POSITIONS BETWEEN TWO PROPRIETARY ACCOUNTS WITH COMMON BENEFICIAL OWNERSHIP AS PART OF NOMURA'S MIGRATION OF ITS COMMODITIES BUSINESS, INCLUDING POSITIONS USED FOR HEDGING, FROM ITS FIXED INCOME DEPARTMENT TO ITS EQUITIES DEPARTMENT. THE PANEL ALSO FOUND THAT THE TRADES WERE EXECUTED ON GLOBEX WITH THE BUY AND SELL ORDERS BEING ENTERED LESS THAN 5 SECONDS APART. THE PANEL ALSO FOUND THAT NOMURA FAILED TO DILIGENTLY SUPERVISE ITS TRADERS IN A MANNER SUFFICIENT TO ENSURE THAT THEY WERE FAMILIAR WITH EXCHANGE RULES SUCH AS THROUGH APPROPRIATE COMPLIANCE TRAINING. THE PANEL FOUND THAT AS A RESULT OF THE FOREGOING, NOMURA VIOLATED EXCHANGE RULES 432.W., 534 AND 539.A. AND C. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, NOMURA PAID THE $50,000 FINE ON 11/20/2012.

Allegations: ALLEGED VIOLATION OF S.798H(1) OF THE CORPORATIONS ACT, 2001 BY FAILING TO COMPLY WITH RULE 5.6.1(A) OF THE ASIC MARKET INTEGRITY RULES (ASX MARKET) 2010 AS A RESULT OF INSTINET AUSTRALIA PTY LIMITED (IAPL) NOT HAVING IN PLACE AT ALL TIMES AN APPROPRIATE FILTER IN ITS AUTOMATED ORDER PROCESSING SYSTEM TO ADDRESS THE ISSUE OF WASH TRADES OR NO CHANGE OF BENEFICIAL OWNERSHIP TRADES. ALLEGED CONTRAVENTION IN 2010 Status: Final Sanction Detail: FINE PAID ON JULY 23, 2013. AUD $130,000.00

Allegations: NOMURA INTERNATIONAL PLC. FAILED TO CONDUCT ITS BUSINESS WITH DUE SKILL, CARE AND DILIGENCE AND FAILED TO TAKE REASONABLE CARE TO ORGANIZE AND CONTROL ITS AFFAIRS REASONABLY AND EFFECTIVELY WITH ADEQUATE RISK MANAGEMENT SYSTEMS. Status: Final Sanction Detail: £1.75 MILLION - THE PENALTY IMPOSED IS DISCOUNTED BY 30% PURSUANT TO THE STAGE 1 EARLY SETTLEMENT DISCOUNT SCHEME. WERE IT NOT FOR THIS DISCOUNT, THE FSA WOULD HAVE IMPOSED A FINANCIAL PENALTY OF £2.5 MILLION.

Allegations: THE FSAJ INSTRUCTED THE NOMURA SECURITIES CO.,LTD. ("NOMURA TOKYO") AND THREE OTHER JAPNAESE SECURITIES COMPANIES AND 9 LEADING JAPANESE BANKS TO STRENGTHEN THIER RESPECTIVE INTERNAL CONTROLS, FOLLOWING AN INDUSTRY-WIDE INVESTIGATION BY FSAJ OF THE PRACTICE OF EXCESSIVELY ENTERTAINING PUBLIC OFFICIALS. IN PARTICULAR FSAJ INSTRUCTED NOMURA TOKYO, AMOUNG OTHERS TO TAKE THE FOLLOWING STEPS IN ORDER TO STRENGTHEN ITS INTERNAL CONTROLS;(I)TO ENHANCE THE AWARENESS OF COMPLIANCE POLICIES AND PROCEDURES AMONG ITS MANAGEMENT AND EMPLOYEES,(II)TO IMPLEMENT MEASURES DESIGNED TO PREVENT THE REOCCURRENCE OF EXCESSIVE ENTERTAINMENT PRACTICES,(III)TO IMPROVE ITS INTERNAL COMPLIANCE SYSTEMS AND,(IV)TO STRENGTHEN ITS INTERNAL CONTROLS ON ENTERTAINMENT EXPENSES. IN THIS CONNECTION, FSAJ FURTHER INSTRUCTED NOMURA TOKYO TO SUBMIT TO FSAJ A COMPREHENSIVE OPERATIONAL PLAN SETTING FORTH SPECIFIC MEASURES IN RESPECT OF (I) THROUGH (IV) ABOVE AND THE TIME BY WITH SUCH MEASURES WOULD BE IMPLEMENTED BY SEPTEMBER 30, 1998. THE FOREGOING INSTRUCTIONS OF FSAJ TO NOMURA TOKYO WERE ISSUED BY WAY OF ADMINISTRATIVE GUIDANCE BASED ON FSAJ'S GENERAL SUPERVISORY POWER OVER SECURITIES COMPANIES LICENSED IN JAPAN (INCLUDING NOMURA TOKYO). Status: Final Sanction Detail: THE FSAJ INSTRUCTED THE NOMURA SECURITIES CO.,LTD. ("NOMURA TOKYO") AND THREE OTHER JAPNAESE SECURITIES COMPANIES AND 9 LEADING JAPANESE BANKS TO STRENGTHEN THIER RESPECTIVE INTERNAL CONTROLS, FOLLOWING AN INDUSTRY-WIDE INVESTIGATION BY FSAJ OF THE PRACTICE OF EXCESSIVELY ENTERTAINING PUBLIC OFFICIALS. IN PARTICULAR FSAJ INSTRUCTED NOMURA TOKYO, AMOUNG OTHERS TO TAKE THE FOLLOWING STEPS IN ORDER TO STRENGTHEN ITS INTERNAL CONTROLS;(I)TO ENHANCE THE AWARENESS OF COMPLIANCE POLICIES AND PROCEDURES AMONG ITS MANAGEMENT AND EMPLOYEES,(II)TO IMPLEMENT MEASURES DESIGNED TO PREVENT THE REOCCURRENCE OF EXCESSIVE ENTERTAINMENT PRACTICES,(III)TO IMPROVE ITS INTERNAL COMPLIANCE SYSTEMS AND,(IV)TO STRENGTHEN ITS INTERNAL CONTROLS ON ENTERTAINMENT EXPENSES. IN THIS CONNECTION, FSAJ FURTHER INSTRUCTED NOMURA TOKYO TO SUBMIT TO FSAJ A COMPREHENSIVE OPERATIONAL PLAN SETTING FORTH SPECIFIC MEASURES IN RESPECT OF (I) THROUGH (IV) ABOVE AND THE TIME BY WITH SUCH MEASURES WOULD BE IMPLEMENTED BY SEPTEMBER 30, 1998. THE FOREGOING INSTRUCTIONS OF FSAJ TO NOMURA TOKYO WERE ISSUED BY WAY OF ADMINISTRATIVE GUIDANCE BASED ON FSAJ'S GENERAL SUPERVISORY POWER OVER SECURITIES COMPANIES LICENSED IN JAPAN (INCLUDING NOMURA TOKYO).

Allegations: AN INCIDENT OCCURED WHEREBY INFORMATION RELATED TO THE LISTING AND DELISTING CRITERIA FOR THE UPPER MARKET UNDER REVIEW BY THE TOKYO STOCK EXCHANGE WAS COMMUNICATED IMPROPERLY. Status: Final Sanction Detail: THE FINANCIAL SERVICES AGENCY, GOVERNMENT OF JAPAN ISSUED BUSINESS IMPROVEMENT ORDERS.

Allegations: AN INCIDENT OCCURRED WHEREBY INFORMATION RELATED TO THE LISTING AND DELISTING CRITERIA FOR THE UPPER MARKET UNDER REVIEW BY THE TOKYO STOCK EXCHANGE WAS COMMUNICATED IMPROPERLY. Status: Final Sanction Detail: IMPOSITION OF JAPAN YEN 10 MILLION FINE

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT AND INACCURATELY REPORTED REPORTABLE OTC POSITIONS TO THE LARGE OPTIONS POSITIONS REPORTING SYSTEM (LOPR) AND UNTIMELY REPORTED OPTIONS POSITION TO THE FINRA TRADE REPORTING FACILITY. THE FINDINGS STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WSPS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULES RELATED TO THE REPORTING OF OPTIONS POSITIONS TO THE LOPR. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $225,000.

Allegations: ALLEGED BREACHES OF CHAPTER 17 OF THE SUPERVISION MANUAL, WHICH IS PART OF THE FSA HANDBOOK (SUP 17) AND PRINCIPLES 2 AND 3 OF THE FSA'S PRINCIPLES FOR BUSINESSES. Status: Final Sanction Detail: £1.05 MILLION FINE. PAID ON APRIL 13, 2010. Summary: FSA ALLEGED THAT INSTINET EUROPE LIMITED FAILED TO (I) SUBMIT ACCURATE TRANSACTION REPORTS IN RESPECT TO MORE THAN 22.1 MILLION TRANSACTIONS, (II) CONDUCT BUSINESS WITH DUE SKILL, CARE AND DILIGENCE THROUGH FAILING TO RESPOND APPROPRIATELY TO CLEAR INDICATIONS THAT THERE WERE ISSUES WITH THE EFFECTIVENESS OF THE TRANSACTION REPORTING PROCESS, AND (III) TAKE REASONABLE CARE TO ORGANIZE AND CONTROL ITS AFFAIRS RESPONSIBLY AND EFFECTIVELY WITH ADEQUATE RISK MANAGEMENT SYSTEMS BETWEEN APRIL 2007 AND JUNE 2009.

Allegations: VIOLATIONS OF ARTICLE 28, PARAGRAPH 1, OF THE ASSOCIATION'S ARTICLES OF INCORPORATION AND RECOMMENDATION BASED ON ARTICLE 29 OF THE ARTICLES OF INCORPORATION, IN CONNECTION WITH A FAILURE TO TAKE NECESSARY AND APPROPRIATE MEASURES TO PREVENT ILLEGAL TRADING BY TAKING SUFFICIENT MEASURES TO PROTECT CONFIDENTIAL INFORMATION RELATING TO THE PUBLIC OFFERING OF NEW SHARES. Status: Final Sanction Detail: NOMURA SECURITIES CO., LTD. WAS FINED 300 MILLION YEN (APPROX $3,800,000)AND ADMONISHED BY THE JAPANESE FINANCIAL SERVICES AGENCY IN A RELATED ACTION.

Allegations: DISCIPLINARY ACTION PURSUANT TO RULE 34, PARAGRAPH 2 OF THE TRADING PARTCIPANT REGULATIONS, IN CONNECTION WITH A FAILURE TO TAKE NECESSARY AND APPROPRIATE MEASURES TO PREVENT ILLEGAL TRADING BY TAKING SUFFICIENT MEASURES TO PROTECT CONFIDENTIAL INFORMATION RELATING TO THE PUBLIC OFFERING OF NEW SHARES. Status: Final Sanction Detail: NOMURA SECURITIES CO., LTD. WAS FINED 200 MILLION YEN (APPROX $2,400,000).

Allegations: DISCIPLINARY ACTION PURSUANT TO RULE 42(1)(IX) OF THE REGULATIONS FOR TRANSACTION PARTICPANTS, IN CONNECTION WITH A FAILURE TO TAKE NECESSARY AND APPROPRIATE MEASURES TO PREVENT ILLEGAL TRADING BY TAKING SUFFICIENT MEASURES TO PROTECT CONFIDENTIAL INFORMATION RELATING TO THE PUBLIC OFFERING OF NEW SHARES. Status: Final Sanction Detail: NOMURA SECURITIES CO., LTD. WAS FINED 16 MILLION YEN (APPROX $200,000)

Allegations: DISCIPLINARY ACTION PURSUANT TO RULE 37 OF THE TRADING PARTICIPANT REGULATIONS, IN CONNECTION WITH A FAILURE TO TAKE NECESSARY AND APPROPRIATE MEASURES TO PREVENT ILLEGAL TRADING BY TAKING SUFFICIENT MEASURES TO PROTECT CONFIDENTIAL INFORMATION RELATING TO THE PUBLIC OFFERING OF NEW SHARES. Status: Final Sanction Detail: NOMURA SECURITIES CO., LTD. WAS FINED 8 MILLION YEN (APPROX $100,000).

Allegations: ALLEGED BREACHES OF KOREAN SHORT SALE REGULATION. Status: Final Sanction Detail: $50,000,000 (USD$46,974.83) FINE. PAID 12/18/2012 Summary: FINANCIAL SUPERVISORY SERVICE (FSS) OF KOREA ALLEGED BREACHES OF KORAN SHORT SALE REGULATIONS. FINANCIAL SERVICES COMMISSION (FSC) OF KOREA FOUND BREACHES OF LOCAL SHORT SALE RULES IN CONNECTION WITH THE EXECUTION OF TO CUSTOMER ODD LOT TRADES BETWEEN JANUARY 2, 2010 AND MAY 31, 2012.

Allegations: VIOLATIONS OF ARTICLE 24, PARAGRAPH 1, SUBPARAGRAPH 4 OF THE ASSOCIATION'S ARTICLES OF ASSOCIATION (PRINCIPLES OF FAIR AND EQUITABLE TRADE), IN CONNECTION WITH EXCESSIVE SALES PROMOTION AND WITH LOSS COMPENSATION Status: Final Sanction Detail: THE NOMURA SECURITIES CO., LTD. FINED 80 MILLION YEN (US$608,000) 75 MILLIONS YEN ((US$ 570,000)FOR VIOLATION OF ARTICLE 24,PARAGRAPH 1, SUBPARAGRAPH 4 OF THE ASSOCIATION'S ARTUCKES OF ASSOCIATION IN CONNECTION WITH EXCESSIVE SALES PROMOTION, AND FINED 5 MILLION YEN (US$38,000)FOR VIOLATION OF ARTICLE 24, PARAGRAPH 1, SUBPARAGRAPH 4 OF THE ASSOCIATION IN CONNECTION WITH LOSS COMPENSATION.

Allegations: VIOLATION OF ARTICLE 59 OF THE CONSTITUTION OF THE EXCHANGE (VIOLATION OF THE JUST AND EQUITABLE PRINCIPLES OF TRADE). Status: Final Sanction Detail: THE TOKYO STOCK EXCHANGE IMPOSED A FINE OF 5 MILLION YEN (US$ 38,000)UPON THE NOMURA SECURITIES CO., LTD.

Allegations: VIOLATION OF ARTICLE 8 OF FAIR BUSINESS PRACTICE REGULATIONS NO.9 (REGULATIONS CONCERNING SOLICITATION FOR INVESTMENT AND MANAGEMENT OF CUSTOMER ACCOUNTS BY ASSOCIATION MEMBERS) AND FOR VIOLATION OF ARTICLE 24, PARAGRAPH 1, SUBPARAGRAPH 4 OF THE ASSOCIATION'S ARTICLES OF ASSOCIATION (PRINCIPLES OF FAIR AND EQUITABLE TRADE), IN CONNECTION WITH PAYMENTS FOR LOSS COMPENSATION; AND FOR VIOLATION OF ARTICLE 24, PARAGRAPH 1, SUBPARAGRAPH 4 OF THE ASSOCIATION'S ARTICLES OF ASSOCIATION (PRINCIPLES OF FAIR AND EQUITABLE TRADE), IN CONNECTION WITH DEALINGS WITH A JAPANESE CRIME ORGANIZATION. Status: Final Sanction Detail: FINED OF 5 MILLION YEN ( US$ 38,000)UPON THE NOMURA SECURITIES CO., LTD.

Allegations: THE SECURITIES AND EXCHANGE SURVEILLANCE COMMISSION IN JAPAN MADE FINDINGS THAT THE NOMURA SECURITIES CO., LTD. ("NOMURA TOKYO") HAD VIOLATED SECTION 2(3) OF ORDINANCE OF THE MINISTRY OF FINANCE NAMED "RULES OF SOUNDNESS OF SECURITIES COMPANIES" BY ITS CONDUCT INVOLVING INTENTIONAL PRICE FORMATION (ESTABLISHMENT OF CERTAIN MARKET LEVELS) IN CONNECTION WITH EXECUTING THREE CROSS TRANSACTIONS BETWEEN NOMURA TOKYO AND ITS CUSTOMERS DURING MARCH 1995. Status: Final Sanction Detail: THE SECURITIES AND EXCHANGE SURVEILLANCE COMMISSION IN JAPAN MADE FINDINGS THAT THE NOMURA SECURITIES CO., LTD. ("NOMURA TOKYO") HAD VIOLATED SECTION 2(3) OF ORDINANCE OF THE MINISTRY OF FINANCE NAMED "RULES OF SOUNDNESS OF SECURITIES COMPANIES" BY ITS CONDUCT INVOLVING INTENTIONAL PRICE FORMATION (ESTABLISHMENT OF CERTAIN MARKET LEVELS) IN CONNECTION WITH EXECUTING THREE CROSS TRANSACTIONS BETWEEN NOMURA TOKYO AND ITS CUSTOMERS DURING MARCH 1995. Summary: THE SECURITIES AND EXCHANGE SURVEILLANCE COMMISSION IN JAPAN MADE FINDINGS THAT THE NOMURA SECURITIES CO., LTD. ("NOMURA TOKYO") HAD VIOLATED SECTION 2(3) OF ORDINANCE OF THE MINISTRY OF FINANCE NAMED "RULES OF SOUNDNESS OF SECURITIES COMPANIES" BY ITS CONDUCT INVOLVING INTENTIONAL PRICE FORMATION (ESTABLISHMENT OF CERTAIN MARKET LEVELS) IN CONNECTION WITH EXECUTING THREE CROSS TRANSACTIONS BETWEEN NOMURA TOKYO AND ITS CUSTOMERS DURING MARCH 1995.

Allegations: ON DECEMBER 2, 1991 THE FAIR TRADE COMMISSION OF JAPAN IMPOSED A PROHIBITION ON THE NOMURA SECURITIES CO., LTD. AGAINST FUTURE VIOLATIONS OF ARTICLE 19 OF THE ANTIMONOPOLY LAW IN CONNECTION WITH LOSS COMPENSATION Status: Final Sanction Detail: ON DECEMBER 21, 1991 THE FAIR TRADE COMMISSION OF JAPAN IMPOSED A PROHIBITION ON THE NOMURA SECURITIES CO., LTD. AGAINST FUTURE VIOLATIONS OF ARTICLE 19 OF THE ANTIMONOPOLY LAW IN CONNECTION WITH LOSS COMPENSATION

Allegations: VIOLATION OF ARTICLE 59 OF THE CONSTITUTION OF THE EXCHANGE (VIOLATION OF JUST AND EQUITABLE PRINCIPLES OF TRADE, IN CONNECTION WITH LOSS COMPENSATION AND IN CONNECTION WITH EXCESSIVE SALES PROMOTION Status: Final Sanction Detail: FINED FIVE (5) MILLION YEN (US$38,000.00) AND IMPOSED A FOUR WEEK AND A SIX WEEK SUSPENSION UPON CERTAIN BRANCH OFFICES AND CERTAIN SALES DEPARTMENTS OF THE NOMURA SECURITES CO., LTD.

Allegations: VIOLATION OF MINISTERIAL ORDINANCE CONCENING RULES, ETC. OF SOUNDNESS OF SECURITIES COMPANIES, ARTICLE 3, PARAGRAPH 7, IN CONNECTION WITH EXCESSIVE SALES PROMOTION, AND FOR VIOLATION OF DIRECTIVES FROM THE DIRECTOR - GENERAL OF SECURITIES BUREAU OF MINISTRY OF FINANCE DATED DECEMBER 26, 1989 IN CONNECTION Status: Final Sanction Detail: THE MINISTRY OF FINANCE OF JAPAN IMPOSED A FOUR WEEK AND A SIX WEEK SUSPENSION UPON CERTAIN BRANCH OFFICES AND CERTAIN SALES AND RESEARCH DEPARTMENTS OF THE NOMURA SECURITIES CO., LTD. FOR VIOLATION OF MINISTERIAL ORDIANCE CONCERNING RULES, ETC. OF SOUNDNESS OF SECURITIES COMPANIES, ARTICLE 3 PARAGRAPH 7, IN CONNECTION WITH EXCESSIVE SALES PROMOTION, AND ORDERED TNSC TO CONDUCT A REVIEW OF ITS INTERNAL MEASURES; AND IMPOSED A ONE WEEK SUSPENSION UPON THE CORPORATE SERVICE DIVISION OF TNSC FOR VIOLATION OF DIRECTIVES FROM THE DIRECTOR- GENERAL SECURITIES BUREAU OF MINISTRY OF FINANCE DATED DECEMBER 26, 1989 IN CONNECTION WITH LOSS COMPENSATION.

Allegations: THE FSA FOUND THAT NSC: 1. SOLD SECURITIES BY PUBLIC OFFERING TO ITS CUSTOMERS WITHOUT DELIVERING PROSPECTUSES DURING THE CALENDAR YEARS 1999 AND 2000 IN VIOLATION OF ART. 15 (2) OF THE SECURITIES AND EXCHANGE LAW. (LAW NO. 25 OF 1948) 2. CONVEYED TO ITS SUBSIDIARY, NOMURA TRUST AND BANKING CO., LTD. UNDISCLOSED INFORMATION OF PRIVATE COMPANIES' FINANCIAL RESULTS WITHOUT OBTAINING WRITTEN CONSENTS FROM SUCH COMPANIES DURING THE PERIOD OF APRIL 1999 TO APRIL 2000 IN VIOLATION OF ART. 45(3) OF THE SECURITIES AND EXCHANGE LAW AND ARTICLE 12(7) ORDINANCE OF THE CABINET OFFICE CONCERNING REGULATION, ETC. OF CONDUCTS OF SECURITIES COMPANIES. Status: Final Sanction Detail: THE FSA ORDERED NSC TO: 1. STRENGTHEN INTERNAL CONTROLS AND COMPLIANCE EFFORTS TO PREVENT RECURRENCE OF VIOLATIONS. 2. SUBMIT WRITTEN REPORT TO FSA BY 1/29/2001. 3. SUBMIT ONGOING QUARTERLY REPORTS TO FSA REGARDING COMPLIANCE EFFORT

Allegations: THE FSA FOUND THAT SECURITIES TRANSACTIONS PERFORMED BY NAM ON BEHALF OF ITS SUBSIDIARIES FOR CERTAIN OVERSEAS ACCOUNTS WERE IN VIOLATION OF ARTICLE 18 OF THE LAW FOR REGULATING SECURITIES INVESTMENT ADVISORY BUSINESS (THE "ADVISORY LAW") WHICH PROHIBITS EXECUTION OF A SECURITIES TRANSACTION ON BEHALF OF A CLIENT WITHOUT ENTERING INTO A DISCRETIONARY MANAGEMENT AGREEMENT. Status: Final Sanction Detail: ON DECEMBER 28, 2000 THE FSA ISSUED AN ADMINISTRATIVE SANCTION, PURSUANT TO ARTICLE 38, PARAGRAPH 1 OF THE ADVISORY LAW, REQUIRING NAM TO SUSPEND ENTERING INTO NEW ADVISORY AGREEMENTS FOR INVESTMENT RECOMMENDATIONS WITH OVERSEAS CLIENTS FOR TWO MONTHS FROM JANUARY 9, 2001, AS WELL AS THE PROVISION OF INVESTMENT RECOMMENDATIONS FOR CERTAIN OVERSEAS ACCOUNTS DURING THE SUSPENSION PERIOD. THE ADMINISTRATIVE SANCTION FOLLOWED A DETERMINATION THAT SECURITIES TRANSACTIONS PERFORMED BY NAM ON BEHALF OF ITS SUBSIDIARIES FOR CERTAIN OVERSEAS ACCOUNTS WERE IN VIOLATION OF ARTICLE 18 OF THE ADVISORY LAW, WHICH PROHIBITS EXECUTION OF A SECURITIES TRANSACTION ON BEHALF OF A CLIENT WITHOUT ENTERING INTO A DISCRETIONARY MANAGEMENT AGREEMENT. THE FSA ALSO ORDERED NAM, PURSUANT TO ARTICLE 37 OF THE ADVISORY LAW, TO CLARIFY WHERE RESPONSIBILIITES LIE, REINFORCE AND ENHANCE THE INTERNAL CONTROL SYSTEM AND IMPLEMENT PLANS TO PROMOTE THE LAW-ABIDING SPIRIT OF THE OFFICERS AND EMPLOYEES IN ORDER TO PREVENT ANY FUTURE VIOLATIONS. Summary: ON DECEMBER 28, 2000 THE FSA ISSUED AN ADMINISTRATIVE SANCTION, PURSUANT TO ARTICLE 38, PARAGRAPH 1 OF THE ADVISORY LAW, REQUIRING NAM TO SUSPEND ENTERING INTO NEW ADVISORY AGREEMENTS FOR INVESTMENT RECOMMENDATIONS WITH OVERSEAS CLIENTS FOR TWO MONTHS FROM JANUARY 9, 2001, AS WELL AS THE PROVISION OF INVESTMENT RECOMMENDATIONS FOR CERTAIN OVERSEAS ACCOUNTS DURING THE SUSPENSION PERIOD. THE ADMINISTRATIVE SANCTION FOLLOWED A DETERMINATION THAT SECURITIES TRANSACTIONS PERFORMED BY NAM ON BEHALF OF ITS SUBSIDIARIES FOR CERTAIN OVERSEAS ACCOUNTS WERE IN VIOLATION OF ARTICLE 18 OF THE ADVISORY LAW, WHICH PROHIBITS EXECUTION OF A SECURITIES TRANSACTION ON BEHALF OF A CLIENT WITHOUT ENTERING INTO A DISCRETIONARY MANAGEMENT AGREEMENT. THE FSA ALSO ORDERED NAM, PURSUANT TO ARTICLE 37 OF THE ADVISORY LAW, TO CLARIFY WHERE RESPONSIBILIITES LIE, REINFORCE AND ENHANCE THE INTERNAL CONTROL SYSTEM AND IMPLEMENT PLANS TO PROMOTE THE LAW-ABIDING SPIRIT OF THE OFFICERS AND EMPLOYEES IN ORDER TO PREVENT ANY FUTURE VIOLATIONS.

Allegations: ALLEGED CONFERRING OF UNDUE PROFITS TO A SHAREHOLDER/CLIENT OF NOMURA TOKYO, INCLUDING DISCRETIONARY SECURITIES TRADING FOR HIS BENIFIT, FOR THE PURPOSE OF REWARDING HIM FOR COOPERATING WITH NOMURA TOKYO IN ENSURING THE SMOOTH CONDUCT OF AN ANNUAL SHAREHOLDERS' MEETING. Status: Final Sanction Detail: ON JUNE 30, 1997, THEMINISTRY OF FINANCE ("MOF") OF JAPAN ORDERED THE NOMURA SECURITIES CO., LTD. ("NOMURA TOKYO") TO SUSPEND (I)EQUITY -RELATED PROPRIETARY TRANSACTIONS INCLUDING TRADES IN STOCKS, WARRANT, CONVERTIBLE BONDS, INDEX FUTURES AND SECURITIESOPTIONS 9WITH CERTAIN EXCEPTIONS) FROM AUGUST 6, 1997, TO DECEMBER 31, 1997, (II)ALL EQUITY-RELATED TRANSACTIONS (WITH CERTAIN EXCEPTIONS AT THE HEAD OFFICE AND ALL BRANCH OFFICES OF NOMURA TOKYO FROM AUGUST 6, 1997, TO AUGUST 12, 1997,(III)BROKERAGE TRANSACTION IN SECURITIES, INDEX FUTURES AND SECURITIES OPTIONS (WITH CERTAIN EXCEPTIONS) BY THE CORPORATE DEVELOPMENT AND SERVICES DEPARTMENT I OF NOMURA TOKYO'S HEAD OFFICE FROM AUGUST 6, 1997 TO DECEMBER 5, 1997, (IV)BROKERAGE TRANSACTIONS IN SECURITIES, INDEX FUTURES AND SECURITIES OPTIONS (WITH CERTAIN EXCEPTIONS BY THE SALES DEPARTMENT, CORPORATE DEVELOPMENT AND SERVICES DEPARTMENT II, INVESTMENT CONSULTING DEPARTMENT, AND CORPORATE SERVICES DEPARTMENT OF THE HEAD OFFICE FROM AUGUST 6, 1997 TO SEPTEMBER 5, 1997, (V)UNDERWRITING AND BIDDINGFOR JAPANESE GOVERNMENT BONDS, MUNICIPAL BONDS, AND BOND GUARANTEE BY THE JAPANESE GOVERNMENT (WITH CERTAIN EXCEPTIONS) FROM AUGUST 6, 1997, TO DECEMBER 31, 1997. ALSO, THE MOF DIRECTED NOMURA TOKYO TO IMPLEMENT MEASURES TO REINFORCE NOMURA TOKYO'S COMPLIANCE SYSTEM AND PREVENT THE REOCCURRENCE OF THE EVENTS THAT LED TO THESE PENALTIES AND TO REPORT TO THE MOF THE STATUS OF IMPLEMENTATION OF SUCH MEASURES IN WRITING NOT LATER THAN SEPTEMBER 19, 1997. THESE ACTIONS WERE TAKEN BY THE MOF IN VIEW OF ITS FINDING THAT NOMURA TOKYO VIOLATED JAPAN'S SECURITIES AND EXCHANGE LAW AND THE COMMERCIAL CODE IN CONNECTION WITH THE CONFERRING OF UNDUE PROFITS TO A SHAREHOLDER/CLIENT OF NOMURA TOKYO, INCLUDINGDISCRETIONARY SECURITIES TRADING FOR HIS BENIFIT, FORTHE PURPOSE OF REWARDING HIM FOR HIS COOPERATING WITH NOMURA TOKYO IN ENSURING THE SMOOTHCONDUCT OF AN ANNUAL SHAREHOLDERS' MEETING. CONTINUED IN #13... Summary: FURTHERMORE, ON JULY 31, 1997, THE TOKYO STOCK EXCHANGE ("TSE") AND SEVEN OTHER JAPANESE STOCK EXCHANGES SIMILARLY ORDERED NOMURA TOKYO TO SUSPEND THE SAME TRANSACTIONS STATED IN (I) THROUGH (IV) ABOVE ON EACH SUCH EXCHANGE FOR THE RESPECTIVE SAME PERIODS IN LIGHT OF THE ABOVE-MENTIONED ADMINISTRATIVE SANTIONS IMPOSED BY THE MOF. ALSO, ON AUGUST 8, 1997, THE TSE FINED NOMURA TOKYO 100 MILLION YEN FOR VIOLATIONS OF THE JAPANESE SECURITIES EXCHANGE LAW AND THE COMMERCIAL CODE. ON THE SAME DATE, THE JAPANESE SECURITIES DEALERS ASSOCIATION ("JSDA") IMPOSED A SIMILAR FINE FOR VIOLATIONS OF ITS ARTICLES OF ASS0CIATION. BOTH THE TSE AND THE JSDA ALSO DIRECTED NOMURA TOKYO TO SUBMIT REPORT AS TO THE STATUS OF THE IMPLEMENTATION OF THE MEASURES BEING TAKEN FOR IMPROVING BUSINERSS OPERATIONS AND COMPLIANCE.

Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION") HAS REASON TO BELIEVE THAT FROM AT LEAST 2015 TO THE PRESENT ("RELEVANT PERIOD"), NOMURA GLOBAL FINANCIAL PRODUCTS INC., NOMURA SECURITIES INTERNATIONAL, INC., AND NOMURA INTERNATIONAL PLC (COLLECTIVELY, "NOMURA" OR "RESPONDENTS") VIOLATED, AS SET FORTH BELOW, SECTIONS 4G, 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. §§ 6G, 6S(F)(1)(C), 6S(G)(1), (3), 6S(H)(1)(B), AND COMMISSION REGULATIONS ("REGULATIONS") 1.31, 1.35, 23.201(A), 23.202(A)(1) AND (B)(1), 23.602(A), AND 166.3, 17 C.F.R. §§ 1.31, 1.35, 23.201(A), 23.202(A)(1), (B)(1), 23.602(A), 166.3 (2021). Status: Final Sanction Detail: THE FIRM SHALL CEASE AND DESIST; SHALL PAY, JOINTLY AND SEVERALLY, A CIVIL MONETARY PENALTY IN THE AMOUNT OF $50,000,000; AND SHALL COMPLY WITH THE CONDITIONS AND UNDERTAKINGS SET FORTH IN THE OFFER. Summary: NOMURA SECURITIES INTERNATIONAL, INC. ("NSI") CONSENTED TO THE ENTRY OF THE ORDER DATED SEPTEMBER 27, 2022 BY THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION"), PURSUANT TO WHICH NSI (I) SHALL CEASE AND DESIST FROM VIOLATING SECTION 4G OF THE COMMODITY EXCHANGE ACT, AND COMMISSION REGULATIONS 1.31, 1.35 AND 166.3; (II) SHALL PAY, JOINTLY AND SEVERALLY WITH TWO AFFILIATES WHO ALSO CONSENTED TO THE ORDER, A CIVIL A MONETARY PENALTY IN THE AMOUNT OF $50 MILLION (III) SHALL COMPLY WITH THE CONDITIONS AND UNDERTAKINGS ENUMERATED IN THE ORDER, INCLUDING CONDUCTING A REVIEW OF THE FIRM'S POLICIES, PROCEDURES, AND CONTROLS AS THEY RELATE TO OFF-CHANNEL COMMUNICATIONS, AND SUBMITTING A WRITTEN REPORT AND ADOPTING THE REPORT'S RECOMMENDATIONS.

Allegations: VIOLATION OF CERTAIN BROKER DEALER AND GOVERNMENT SECURITIES BROKER DEALER RECORD KEEPING PROVISIONS OF THE SECURITIES AND EXCHANGE ACT OF 1934 Status: Final Sanction Detail: SEE ABOVE

Allegations: NSI EMPLOYEES SENT AND RECEIVED OFF-CHANNEL COMMUNICATIONS THAT RELATED TO THE BUSINESS OF BROKER-DEALER OPERATED BY NSI. RESPONDENT DID NOT MAINTAIN OR PRESERVE THE SUBSTANTIAL MAJORITY OF THESE COMMUNICATIONS. NSI'S FAILURE WAS FIRM-WIDE AND INVOLVED EMPLOYEES AT ALL LEVELS OF AUTHORITY. AS A RESULT, NSI VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER. Status: Final Sanction Detail: NSI WAS CENSURED; ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FURTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER; SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $50,000,000.00; AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER. Summary: NOMURA SECURITIES INTERNATIONAL, INC. ("NSI") CONSENTED TO THE ENTRY OF THE ORDER DATED SEPTEMBER 27, 2022 BY THE U.S. SECURITIES EXCHANGE COMMISSION ("COMMISSION"), PURSUANT TO WHICH NSI (I) SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER; (II) IS CENSURED; (III) SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER, INCLUDING RETAINING A COMPLIANCE CONSULTANT TO CONDUCT A REVIEW OF THE FIRM'S POLICIES, PROCEDURES, AND CONTROLS AS THEY RELATE TO OFF-CHANNEL COMMUNICATIONS, AND ADOPTING THE COMPLIANCE CONSULTANT'S RECOMMENDATIONS; AND (IV) SHALL PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $50,000,000.

Allegations: NOMURA IS CENSURED FOR FAILING REASONABLY TO SUPERVISE THREE TRADERS WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. Status: Final Sanction Detail: PAY CUSTOMERS IN THE AGGREGATE AMOUNT OF $20,704,337 AND CIVIL MONETARY PENALTY OF $1,000,000.

Allegations: FAILURE TO PROPERLY SUPERVISE Status: Final Sanction Detail: IMPLEMENT COMPLIANCE AND SUPERVISORY PROCEDURES, SECT. 7(C)EXCHANGE ACT; REGULATION T; SECT 17(A) SECURITIES ACT OF 1933; SECT 7 & 10(B)EXCHANGE ACT; RULE 10B-5; REGULATION X. SEC NEWS DIGEST ISSUE 85-171

Allegations: NOMURA FAILED REASONABLY TO SUPERVISE TWO TRADERS TO PREVENT VIOLATIONS OF ANTIFRAUD PROVISION OF THE FEDERAL SECURITIES LAWS WITHIN THE MEANING ON SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. Status: Final Sanction Detail: PAY CUSTOMERS IN THE AGGREGATE AMOUNT OF APPROXIMATELY $4,275,035 AND CIVIL MONETARY PENALTY OF $500,000.

Allegations: FAILURE TO MAINTAIN COPIES OF REGISTRATION DEFICIENCY MEMORANDA; FAILURE TO MAINTAIN RECORDS Status: Final Sanction Detail: 2/25/1993 Summary: ON FEBRUARY 25, 1993, THE REGISTRANT CONSENTED TO THE ENTRY OF AN ORDER BY THE SEC WITH RESPECT TO CERTAIN ALLEGED BOOKS AND RECORDS VIOLATIONS IN CONNECTION WITH AN ORDER FOR THE PURCHASE OF CERTAIN SECURITIES AND CERTAIN EMPLOYEES REGISTRATION MEMORANDA. WITHOUT ADMITTING OT DENYING THE MATTERS SET FORTH IN THE ORDER, THE REGISTRANT AGREED TO THE IMPOSITION OF A CENSURE; A CEASE AND DESIST ORDER;A CIVIL MONETARY PENALTY OF $50,000 AND TO COMPLY WITH CERTAIN UNDERTAKINGS INCLUDING THE RETENTION OF AN OUTSIDE CONSULTANT AND THE IMPPLEMENTATION OF RECOMMENDED PROCEDURES IN CONNECTION WITH ALLEDED BOOKS AND RECORDS VIOLATIONS AND REGISTRATION OF PERSONNEL.

Allegations: SEC RULE 10B-10(A), NASD RULE 2230 AND FINRA RULE 2010: THE FIRM FAILED TO DELIVER CERTAIN TRADE CONFIRMATIONS FOR FORWARD TRANSACTIONS IN MORTGAGE-BACKED SECURITIES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED $50,000.

Allegations: VIOLATIONS OF FINRA RULE 2010, AND NASD RULES 2110, 3010, AND 3360 BASED ON THE FOLLOWING ALLEGATIONS: BETWEEN MARCH 2007 AND NOVEMBER 2008, NOMURA SECURITIES INTERNATIONAL, INC. SUBMITTED SHORT INTEREST POSITION REPORTS TO NASD, LATER FINRA, THAT INCLUDED SHORT INTEREST POSITIONS THAT SHOULD NOT HAVE BEEN REPORTED BECAUSE THE POSITIONS HAD NOT RESULTED FROM SHORT SALES AS DEFINED BY RULE 200(A) OF REGULATION SHO. THE PRACTICES THAT LED TO THE FIRM'S INACCURATE SHORT INTEREST REPORTS DATED BACK TO OCTOBER 2004. IN ITS SHORT INTEREST REPORT FOR SETTLEMENT DATE SEPTEMBER 15, 2008, THE FIRM INCLUDED A SHORT INTEREST POSITION OF 5000 SHARES IN AN INCORRECT SYMBOL FOR THE FIRM'S POSITION. IN 2007 AND 2008, THE FIRM'S WRITTEN SUPERVISORY PROCEDURES DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN ASPECTS OF ITS BUSINESS AND THE APPLICABLE SECURITIES LAWS AND REGULATIONS, OR NASD RULES, SPECIFICALLY CONCERNING NASD RULE 3360. IN ADDITION, THE FIRM FAILED TO ADEQUATELY SUPERVISE ITS PRODUCTIONS OF DOCUMENTS AND INFORMATION TO THE STAFF IN CONNECTION WITH FINRA'S INVESTIGATION. Status: Final Sanction Detail: CENSURE AND FINE OF $75,000 ORDERED AGAINST NSI. PAYMENT MADE ON APRIL 3RD. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, NSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT CONSENTING TO A CENSURE AND A FINE OF $75,000.

Allegations: FINRA RULES 2010, 6622, 7450(A) - NOMURA SECURITIES INTERNATIONAL, INC. TRANSMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA; FAILED TO SUBMIT CONTRA SIDE PROPRIETARY COMBINED ORDER/EXECUTION REPORTS FOR TRANSACTIONS EFFECTED AGAINST A CUSTOMER ORDER; AND SUBMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS TO OATS THAT IT WAS NOT REQUIRED TO SUBMIT. THE FIRM TRANSMITTED REPORTABLE ORDER EVENTS (ROES) TO OATS THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE BUT THE FIRM FAILED TO REPAIR MOST OF THE REJECTED ROES SO THAT IT FAILED TO TRANSMIT THEM TO OATS. THE FIRM ALSO FAILED TO REPAIR A FEW OF THE REJECTED ROES WITHIN THE REQUIRED FIVE BUSINESS DAYS AND FAILED TO POPULATE THE CORRECT REJECTED ROE ID FOR TWO REJECTED SUBMISSIONS AND THEN FAILED TO REPAIR THESE REJECTIONS WITHIN THE REQUIRED FIVE BUSINESS DAYS. THE FIRM FAILED, WITHIN 30 SECONDS AFTER EXECUTION, TO TRANSMIT LAST SALE REPORTS OF TRANSACTIONS IN OVER-THE-COUNTER (OTC) EQUITY SECURITIES TO THE OTC TRADING FACILITY (OTCRF). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $17,500. THE FINE WAS PAID ON JULY 8, 2013.

Allegations: ALLEGED VIOLATIONS OF ISE RULE 400.02 RESULTING FROM EXECUTION OF PROPRIETARY TRADE OR HEDGE AFTER RECEIVING AND/OR EXECUTING A PORTION OF CUSTOMER LISTED OPTION ORDERS BUT PRIOR TO THE DISCLOSURE OF THE ENTIRE CUSTOMER ORDER TO THE MARKETPLACE. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE DESCRIBED FINDINGS AND SANCTIONS AND PAID THE FINE ON FEBRUARY 26, 2014.

Allegations: ON FEBRUARY 14, 2014, THE CLEARING HOUSE RISK COMMITTEE OF THE CHICAGO MERCANTILE EXCHANGE ACCEPTED THE SETTLEMENT IN A MATTER CAPTIONED 13-CH-1303, WHICH INVOLVED THE CHARGE THAT NSI VIOLATED CBOT RULE 971.E.. THE SETTLEMENT INCLUDED A FINE WHICH WAS PAID. NOMURA SECURITIES INTERNATIONAL, INC. NEITHER ADMITTED NOR DENIED VIOLATING CME RULES. Status: Final Sanction Detail: FINE OF $25,000 WHICH WAS PAID ON FEBRUARY 24, 2014

Allegations: WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, THE FIRM STIPULATED TO THE FACTS AND FINDINGS THAT ON THREE OCCASIONS, THE FIRM IMPROPERLY HEDGED ITS ANTICIPATED FACILITATION OF A CUSTOMER ORDER BEFORE IT DISCLOSED ALL MATERIAL TERMS AND CONDITIONS OF THE CUSTOMER ORDER TO THE TRADING CROWD, IN VIOLATION OF NYSE MKT RULE 995NY(C). THEREFORE THE FIRM WAS CENSURED AND FINED $90,000. Status: Final Sanction Detail: FINE WAS PAID ON 6/27/14. Summary: PLEASE SEE QUESTION #7 ABOVE.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED NYSE RULE 342 AND SEA RULE 15C3-5(C)(1)(II) BY NOT HAVING IN PLACE CONTROLS TO PREVENT THE ENTRY OF CERTAIN ORDERS THAT EXCEED PRICE AND/OR TIME PARAMETERS. Status: Final Sanction Detail: SEE ABOVE. FINE PAID OF $40,000

Allegations: SEC RULE 10B-10-NOMURA SECURITIES INTERNATIONAL, INC. FAILED TO PROVIDE WRITTEN NOTIFICATION TO ITS CUSTOMERS ITS CORRECT CAPACITY IN TRANSACTIONS IN THAT THE FIRM EXECUTED ORDERS ON A PRINCIPAL BASIS, IN WHOLE OR IN PART, BUT INCORRECTLY INDICATED ON THE CUSTOMER CONFIRMATIONS THAT THE FIRM EXECUTED SUCH ORDERS ON AN AGENCY BASIS AND THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH SEC RULE 10B-10. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $50,000.

Allegations: ALLEGED VIOLATIONS OF NASD RULE 3010, FINRA RULE 204 OF REGULATION SHO, SECURITIES EXCHANGE ACT RULE 15C3-3 AND FEDERAL RESERVE BOARD REGULATION T IN RESPECT TO THE UNTIMELY CLOSEOUT OF FAILS TO DELIVER. Status: Final Sanction Detail: CENSURE AND FINE OF $150,000.

Allegations: ALLEGED VIOLATIONS OF NYSE ARCA RULE 6.18 AND RULE 204 OF REGULATION SHO IN RESPECT TO THE UNTIMELY CLOSEOUT OF FAILS TO DELIVER. Status: Final Sanction Detail: CENSURE AND FINE OF $100,000.

Allegations: ALLEGED VIOLATIONS OF CBOE RULES 4.13 AND 4.2, IN RELATION TO POSITION LIMITS. Status: Final Sanction Detail: CENSURE AND FINE OF $800,000.00.

Allegations: IN THREE SEPARATE INSTANCES ON JANUARY 17, 2014, FEBRUARY 21, 2014 AND APRIL 17, 2014, NOMURA SECURITIES INTERNATIONAL INC. RECEIVED AND SUBMITTED AMENDED EXPIRING EXERCISE DECLARATION ("EED") INSTRUCTIONS AFTER THE 5:30 P.M. ET CUT-OFF TIME AND FAILED TO MAINTAIN A MEMORANDUM SETTING FORTH THE CIRCUMSTANCES REGARDING SUCH EXCEPTION. AS A RESULT, THE FIRM VIOLATED NYSE ARCA OPTIONS RULE 6.24, COMMENTARY .06. THE FIRM FAILED TO FOLLOW ITS WRITTEN SUPERVISORY PROCEDURES RELATED TO NYSE ARCA OPTIONS RULE 6.24, COMMENTARY .06. AS A RESULT, THE FIRM VIOLATED NYSE ARCA OPTIONS RULE 11.18(C). Status: Final Sanction Detail: THE FIRM WAS FINED $4,500.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE FOR NOT TRANSMITTING TO THE FINRA/NASDAQ TRADE REPORTING FACILITY LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES AND REPORTING CORRECT EXECUTION TIMES OF CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES. Status: Final Sanction Detail: $10,000 FINE.

Allegations: APPLICANT VIOLATED CBOT RULES 538.C., 534 AND 432.W Status: Final Sanction Detail: ON OCTOBER 1, 2024, NOMURA SECURITIES INTERNATIONAL, INC., PAID A $80,000 FINE.

Allegations: REFER TO QUESTION 13 Status: Final Sanction Detail: FINE OF $30,000 WHICH WAS PAID BY NSI. Summary: ON MAY 2, 2014, THE BUSINESS CONDUCT COMMITTEE OF THE CBOT ACCEPTED NSI'S OFFER OF SETTLEMENT WHICH INVOLVED THE CHARGE THE NSA VIOLATED CBOT RULES 526(F) AND 536(A). THE SETTLEMENT INCLUDED A FINE OF $30,000 WHICH WAS PAID BY NSI. AS PART OF THE SETTLEMENT, NSI NEITHER ADMITTED NOR DENIED VIOLATING CBOT RULES.

Allegations: FSC ALLEGES THAT NSI ACTED NEGLIGENTLY ON THEIR OBLIGATION TO LOOK OUT FOR THEIR SHORT SALE. Status: Final Sanction Detail: FINE IN THE AMOUNT OF 12,500,000 KRW, APPROXIMATELY 12,250 USD, LEVIED IN FULL AGAINST NSI. THIS AMOUNT WAS PAID IN FULL ON MAY 19, 2014

Allegations: WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, THE FIRM CONSENTED TO A STIPULATION THAT IT DID NOT QUALIFY AND REGISTER CERTAIN PERSONNEL IN ALL CATEGORIES REQUIRED BY CBOE RULE 3.6A. Status: Final Sanction Detail: $60,000 FINE AND CENSURE