DocuSign Envelope ID: FC6993F6-6A5C-4E2A-B038-CC8FA5AB66C4

Report of Organizational Actions Form 8937 (December 2017) Affecting Basis of Securities OMB No. 1545-0123 Department of the Treasury Internal Revenue Service a See separate instructions. Part I Reporting Issuer 1 Issuer's name 2 Issuer's employer identification number (EIN)

LENDINGCLUB CORPORATION 51-0605731 3 Name of contact for additional information 4 Telephone No. of contact 5 Email address of contact

LENDINGCLUB CORPORATION 415-632-5600 N/A 6 Number and street (or P.O. box if mail is not delivered to street address) of contact 7 City, town, or post office, state, and ZIP code of contact

595 MARKET STREET, SUITE 200 SAN FRANCISCO, CA 94105 8 Date of action 9 Classification and description

JULY 5, 2019 1 TO 5 REVERSE STOCK SPLIT OF COMMON STOCK 10 CUSIP number 11 Serial number(s) 12 Ticker symbol 13 Account number(s)

52603A208 LC Part II Organizational Action Attach additional statements if needed. See back of form for additional questions. 14 Describe the organizational action and, if applicable, the date of the action or the date against which shareholders' ownership is measured for the action a On July 5, 2019, the Board of Directors of LendingClub Corporation approved a 1-for-5 reverse stock split of shares of common stock. No fractional shares of common stock of the Company were issued in connection with the reverse stock split. Each stockholder who would otherwise have been entitled to a fraction of a share in connection with the reverse stock split was entitled to cash payment.

15 Describe the quantitative effect of the organizational action on the basis of the security in the hands of a U.S. taxpayer as an adjustment per share or as a percentage of old basis a Upon the effective date of July 5, 2019 of the reverse stock split, every five (5) shares of common stock of LendingClub Corporation automatically converted into one (1) share of common stock. As a result, stockholders must allocate the aggregate tax basis in their shares held immediately prior to the reverse stock split among the shares held immediately after the reverse stock split (excluding any fractional shares for which cash in lieu was received). Stockholders of common stock acquired on different dates and at different prices should consult their own tax advisors regarding the allocation of the tax basis and holding period of that common stock.

16 Describe the calculation of the change in basis and the data that supports the calculation, such as the market values of securities and the valuation dates a Please refer to Line 15. While the basis “per share” is impacted, the basis of the stockholder's total investment remains unchanged. Because no fractional shares were issued, the aggregate tax basis of LendingClub Corporation common stock held by a stockholder immediately after the reverse stock split could be less than the preͲsplit aggregate tax basis by an amount equal to the aggregate tax basis allocated to the fractional shares, if any. Stockholders are advised to consult their own tax advisors.

For Paperwork Reduction Act Notice, see the separate Instructions. Cat. No. 37752P Form 8937 (12-2017) DocuSign Envelope ID: FC6993F6-6A5C-4E2A-B038-CC8FA5AB66C4

Form 8937 (12-2017) Page 2 Part II Organizational Action (continued)

17 List the applicable Internal Revenue Code section(s) and subsection(s) upon which the tax treatment is based a Pursuant to IRC sections 368(a), 354(a) and 1001.

18 Can any resulting loss be recognized? a The reverse stock split is intended to be treated as a “recapitalization” for U.S. federal income tax purposes. A stockholder generally should not recognize gain or loss pursuant to the reverse stock split, except with respect to cash received in lieu of a fractional share of common stock.

In general, a stockholder who receives cash in lieu of a fractional share will recognize capital gain or loss equal to the difference between the amount of cash received and the tax basis in the shares of common stock pre-reverse split. Such capital gain or loss will be long term capital gain or loss if the holding period of common stock pre-reverse split exceed one year as of the reverse stock split date. Stockholders are advised to consult their own tax advisors.

19 Provide any other information necessary to implement the adjustment, such as the reportable tax year a The reportable tax year is 2019 for calendar year stockholders. For fiscal year stockholders, the reportable tax year is one that includes the effective date of July 5, 2019. Stockholders are advised to consult their own tax advisors.

Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete. Declaration of preparer (other than officer) is based on all information of which preparer has any knowledge. Sign 4/24/2020 Here Signature a Date a

Print your name a JOANNE CHANG Title a VP, CORPORATE TAX Print/Type preparer's name Preparer's signature Date PTIN Paid Check if Preparer self-employed Use Only Firm's name a Firm's EIN a Firm's address a Phone no. Send Form 8937 (including accompanying statements) to: Department of the Treasury, Internal Revenue Service, Ogden, UT 84201-0054