First Citizens Investor Services, Inc.

Allegations: VA 38.2-502.1 MISREPRESENTATION OF THE BENEFITS, ADVANTAGES, CONDITIONS OR TERMS OF AN INSURANCE POLICY. A) ALLEGATION THAT THE SURRENDER SCHEDULE FOLLOWING THE INITIAL 3 YEAR TERM WAS NOT FULLY DISCLOSED TO THREE CLIENTS B) AGENT SHRIVER DID NOT PERSONALLY MEET WITH FOUR CLIENTS TO VERIFY IDENTITIES AND VERIFY SUITABILITY OF THE TRANSACTIONS. VA 38.2.2-512 MISREPRESENTATION IN INSURANCE DOCUMENTS OR COMMUNICATIONS. AGENT SHRIVER SIGNED APPLICATIONS WITHOUT PERSONALLY MEETING CLIENTS THOUGH THE CERTIFICATION INDICATED HE HAD. Status: Final Sanction Detail: $1,000 SETTLEMENT PAID TO THE COMMONWEALTH OF VIRGINIA BY THE AGENT ON OR AROUND JANUARY 25, 2022. Summary: ON JANUARY 25, 2022 THE INVESTIGATION WAS SETTLED WITHOUT ADMITTING OR DENYING ANY ALLEGATION. A MONETARY SETTLEMENT OF $1,000.00 USD WAS PAID TO THE COMMONWEALTH OF VIRGINIA.

Allegations: IN FEBRUARY 2018, THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC") ANNOUNCED AN INDUSTRY-WIDE INITIATIVE TO IDENTIFY AND REMEDY CONFLICTS OF INTEREST THAT ARISE WHERE INVESTMENT ADVISERS FAILED TO MAKE REQUIRED DISCLOSURES RELATING TO THEIR SELECTION OF CERTAIN MUTUAL FUND SHARE CLASSES THAT PAID THE ADVISER (OR ITS RELATED ENTITIES) A FEE PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEE") WHEN A LOWER-COST SHARE CLASS FOR THE SAME FUND WAS AVAILABLE TO CLIENTS. BASED ON INFORMATION THAT FIRST CITIZENS INVESTOR SERVICES, INC. ("FCIS") SELF-DISCLOSED, THE SEC ISSUED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST FCIS ON MARCH 11, 2019 (THE "ORDER"). THE SEC DETERMINED THAT, FOR THE PERIOD FROM JANUARY 1, 2014 TO JULY 20, 2018, FCIS PURCHASED, RECOMMENDED OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT PAID 12B-1 FEES TO FCIS INSTEAD OF LOWER-COST SHARE CLASSES FOR THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. THE SEC DETERMINED THAT FCIS DID NOT ADEQUATELY DISCLOSE: (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. THE SEC FOUND THAT THIS CONDUCT VIOLATED SECTIONS 206(2) AND 207 OF THE INVESTMENT ADVISERS ACT OF 1940 (THE "ADVISERS ACT"). FCIS CONSENTED TO THE ORDER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. Status: Final Sanction Detail: THE SEC CENSURED AND ORDERED FCIS TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. THE SEC ALSO ORDERED FCIS TO PAY $359,872.11 IN DISGORGEMENT AND $42,793.07 IN PREJUDGMENT INTEREST TO FCIS INVESTORS AFFECTED BY THE CONDUCT DESCRIBED IN THE ORDER, PURSUANT TO PROCEDURES OUTLINED THEREIN. THE SEC DID NOT ORDER A CIVIL MONETARY PENALTY OR FINE. Summary: ON MARCH 11, 2019, FCIS CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS (EXCEPT AS TO JURISDICTION), TO THE ISSUANCE OF THE ORDER. (ON THE SAME DAY, THE SEC ISSUED SIMILAR ORDERS AGAINST 78 OTHER INVESTMENT ADVISERS.) THE SEC'S FINDINGS AGAINST FCIS ARE SUMMARIZED IN RESPONSE TO QUESTION 7 ABOVE. IN ACCORDANCE WITH THE SEC'S ORDER, FCIS HAS DEPOSITED THE DISGORGEMENT AND PREJUDGMENT INTEREST AMOUNTS INTO AN ESCROW ACCOUNT AND HAS COMPLIED WITH ALL RELEVANT DEADLINES RELATED TO THE CONTEMPLATED DISTRIBUTION OF THESE FUNDS. FCIS ALSO IS IN THE PROCESS OF IMPLEMENTING (AND IN SOME CASES ALREADY HAS IMPLEMENTED) THE UNDERTAKINGS SET FORTH IN RESPONSE TO QUESTION 12.B, ABOVE.

Allegations: FAILURE TO TIMELY REPORT AN ADMINISTRATIVE ACTION IN VIOLATION OF LA.R.S. 22:1563A Status: Final Sanction Detail: FINE WAS PAID IN FULL TO THE LOUISIANA DEPARTMENT OF INSURANCE ON 01/29/2020. Summary: NOTE THE ACTION WAS APPEALED ON 12/04/2019 WITHIN THE 30 DAY ALLOWABLE TIMEFRAME. THE APPEAL WAS WITHDRAWN ON 01/24/2020.