Regulatory Bulletin NYSE American RB-18-45

April 2, 2018

To: MEMBERS AND MEMBER ORGANIZATIONS

Subject: GS FINANCE CORP. LARGE CAP GROWTH INDEX-LINKED ETNS DUE 2028

Members and member organizations are informed that shares (“Shares”) of the Index-Linked Securities, (also referred to as Exchange-Traded Notes or “ETNs”) identified on Appendix A will commence trading pursuant to unlisted trading privileges on the NYSE American LLC (“NYSE American” or the “Exchange”) on April 2, 2018. Shares of the ETNs will be traded pursuant to NYSE American Rule 5.2E(j)(6) (Equity-Linked Securities). Please forward this Regulatory Bulletin to other interested persons within your organization.

Background on the Securities

Exchange-Traded Notes are unsecured obligations of financial institutions that provide for the payment at maturity of a cash amount based on the performance of an index or indexes or other reference assets (e.g., commodities, currencies or other financial instruments or benchmarks). As described in NYSE American Equities Rule 5.2E(j)(6), Exchange-Traded Notes include Equity- Linked Securities. These securities may or may not provide for the repayment of the original principal investment amount. Certain ETNs may provide leveraged exposure based on the performance of a specified index or reference asset. The index underlying each series of ETNs is identified on Appendix A.

Additional information regarding each series of ETNs, including information about payment at maturity, redemption features, fees and can be found in the applicable ETN prospectus and prospectus supplement.

Risk Factor Information

As described in the pricing supplement, prospectus and prospectus supplement for each series of ETNs, investing in ETNs involves a number of risks not associated with an investment in conventional debt securities. An investment in ETNs involves significant risks and is not appropriate for every . Investing in ETNs is not equivalent to investing directly in the index underlying a series of ETNs. Accordingly, ETNs should be purchased only by knowledgeable who understand the terms of the investment in a particular series of ETNs and are familiar with the behavior of the Index and financial markets generally. ETNs are riskier than ordinary unsecured debt securities

Interested persons are referred to the pricing supplement, prospectus and prospectus supplement for each series of ETNs for a full description of risks associated with an investment in such series of ETNs. These risks include, but are not limited to, the following: Non-Interest Bearing Risk, Risk of Losing Entire Investment, Fee Risks, Financing Cost Risk, Leverage Risk, Highly Speculative and Highly Risky, Automatic Redemption Risks, Redemption Risks, Risk that Sale of Notes may be limited or suspended, Issuer has no obligation to Sell Additional Notes, Liquidity Risk, Sensitivity to Index Changes, Notional Exposure Fluctuation Risk, Lack of Daily Reset Mechanism Risk, Loss

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Rebalancing Event Risks, Value Risks, Risk of Purchasing at a Premium to Face Amount, Index Tracking Risk, Interest Rate Benchmark Discontinuation Risk, Benchmark Regulation Risks, Floating Rate Risk, Historical Value Risks, Hedging Risk, Conflict of Interest Risks, Index Sponsor Risks, Calculation Agent Risks, Trading Halt Risks, Market Disruption Risks, Total Return vs. Price Return Risks and Tax Risk.

Other Information About the ETNs

ETNs may be subject to early redemption or acceleration in whole or in part at any time. Accordingly, an investor should not expect to be able to hold ETNs to maturity. Additionally, ETNs do not guarantee any return of principal at, or prior to, maturity or call, or upon early redemption. Instead, at maturity, investors will receive a cash payment, the amount of which will vary depending on the performance of the applicable index or reference asset, reduced by any applicable fees, and may be zero.

Typically, ETNs may be redeemed early, at the investor’s , subject to a minimum redemption amount of a specified number (e.g., 12,500) of ETNs. Upon such early redemption, the investor would receive a cash payment that is based on the performance of the applicable index or reference asset, less any applicable fees.

With respect to each ETN issue, the following information is included on Appendix A: ETN name; Name of Underlying Index / Reference Asset, ETN trading symbol; IIV symbol; and ETN issuer’s website name.

Exchange Rules Applicable to Trading in the ETNs

The ETNs are considered equity securities, thus rendering trading in the ETNs subject to the Exchange's existing rules governing the trading of equity securities.

Trading Hours

The value of each underlying index or reference asset will be disseminated to data vendors every 15 seconds or 60 seconds, as applicable, from 9:30 a.m. ET until 4:00 p.m. ET. The ETNs will trade on NYSE American from 7:00 a.m. ET until 8:00 p.m. ET on every business day in accordance with NYSE American Equities Rule 7.34E.

Extended Hours Trading

Members and member organizations are reminded of NYSE American Rule 7.34E(e) regarded Customer Disclosure and that trading in a Fund’s Shares during the Exchange’s Early and Late Trading Sessions may result in additional trading risks which include: (1) that the current applicable underlying Index value may not be updated during the Early and Late Trading Sessions, (2) the intraday indicative value may not be updated during the Early and Late Trading Sessions, (3) lower liquidity in the Early or Late Trading Sessions may impact pricing, (4) higher in the Early or Late Trading Sessions may impact pricing, (5) wider spreads may occur in the Early or Late Trading Sessions, and (6) since the intraday indicative value is not calculated or widely disseminated during the Early and Late Trading Sessions, an investor who is unable to calculate an implied value for Shares of a Fund in those sessions may be at a disadvantage to market professionals.

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Suitability

Trading in the ETNs on the Exchange will be subject to the provisions of NYSE American Rule 2111 - Equities and other applicable suitability rules. Members and member organizations recommending transactions in the ETNs to customers should make a determination that the recommendation is suitable for the customer.

FINRA has implemented increased sales practice and customer requirements for FINRA members applicable to leveraged exchange-traded products (which includes the ETNs identified on Appendix A) and options on such products, as described in FINRA Regulatory Notices 09-31 (June 2009), 09-53 (August 2009) and 09-65 (November 2009).

Leveraged ETNs are riskier than ordinary debt securities and are not suitable for all investors. In particular, leveraged ETNs should be purchased only by investors who understand leverage risk and the consequences of seeking monthly compounded leveraged investment results, and who intend to actively monitor and manage their investments. The Exchange makes no representation regarding the suitability of an investment in leveraged ETNs.

Trading Halts

The Exchange will halt trading in the Shares for a regulatory halt similar to a halt based on NYSE American Rule 7.18E and/or a halt because dissemination of the intraday indicative value of the Shares and/or the underlying value of the index has ceased. Further, the Exchange will halt trading in the Shares in accordance with NYSE American Rule 7.12E (“Trading Halts Due to Extraordinary Market Volatility”). The Shares will be traded following a trading halt in accordance with NYSE American Equities Rule 7.35E (“Auctions”).

Exemptive, Interpretive and No-Action Relief Under Federal Securities Regulations

The Securities and Exchange Commission has issued no-action relief from certain provisions of and rules under the Securities Exchange Act of 1934 (the “Exchange Act”). In connection with the ETNs, the Issuer is relying on the SEC No-Action Letters issued to Barclays Bank PLC (SEC Letters dated May 30, 2006 and July 27, 2006) for securities with structures similar to that of the securities described herein (the “Letters”). The issuer relies on these Letters, and what follows is only a summary of the relief outlined in the Letters; the Exchange also advises interested members to consult the Letters, available at www.sec.gov, for more complete information regarding the matters covered therein.

AS WHAT FOLLOWS IS ONLY A SUMMARY OF THE RELIEF OUTLINED IN THE NO-ACTION LETTERS REFERENCED ABOVE, THE EXCHANGE ADVISES INTERESTED PARTIES TO CONSULT THE NO-ACTION LETTERS FOR MORE COMPLETE INFORMATION REGARDING THE MATTERS COVERED THEREIN AND THE APPLICABILITY OF THE RELIEF GRANTED IN RESPECT OF TRADING IN SECURITIES. INTERESTED PARTIES SHOULD ALSO CONSULT THEIR PROFESSIONAL ADVISORS.

Regulation M Exemptions Generally, Rule 101 of Regulation M is an anti-manipulation regulation that, subject to certain exemptions, prohibits a “distribution participant” and the issuer or selling security holder, in connection with a distribution of securities, from bidding for, purchasing, or attempting to induce any person to bid for or purchase, any security which is the subject of a distribution until after the

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NYSE American RB-18-45 April 2, 2018 Page 4 of 5 applicable restricted period, except as specifically permitted in Regulation M. The provisions of the Rules apply to underwriters, prospective underwriters, brokers, dealers, and other persons who have agreed to participate or are participating in a distribution of securities, and affiliated purchasers of such persons.

The Letters state that the SEC Division of Trading and Markets will not recommend enforcement action under Rule 101 of Regulation M against persons who may be deemed to be participating in a distribution of the notes to bid for or purchase the notes during their participation in such distribution.

Rule 102 of Regulation M prohibits issuers, selling security holders, or any affiliated purchaser of such person from bidding for, purchasing, or attempting to induce any person to bid for or purchase a covered security during the applicable restricted period in connection with a distribution of securities effected by or on behalf of an issuer or selling security holder. Rule 100 of Regulation M defines “distribution” to mean any offering of securities that is distinguished from ordinary trading transactions by the magnitude of the offering and the presence of special selling efforts and selling methods.

The Letters state that the SEC Division of Trading and Markets will not recommend enforcement action under Rule 102 of Regulation M against Barclays and its affiliated purchasers who bid for or purchase or redeem notes during the continuous offering of the notes.

Section 11(d)(1) of the Exchange Act; Exchange Act Rule 11d1-2 Section 11(d)(1) of the Exchange Act generally prohibits a person who is both a broker and a dealer from effecting any transaction in which the broker-dealer extends credit to a customer on any security which was part of a new issue in the distribution of which he or she participated as a member of a selling syndicate or group within thirty days prior to such transaction.

The Letters state that the SEC Division of Trading and Markets will not recommend enforcement action under Section 11(d)(1) of the Exchange Act against broker-dealers who treat the notes, for purposes of Rule 11d1-2, as “securities issued by a registered . . . open-end investment company as defined in the Investment Company Act” and thereby, extend credit or maintain or arrange for the extension or maintenance of credit on the notes that have been owned by the persons to whom credit is provided for more than 30 days, in reliance on the exemption contained in the rule.

This Information Bulletin is not a statutory prospectus. Members and member organizations should consult each applicable trust’s registration statement, Statement of Additional Information, prospectus and the ETNs’ website for relevant information.

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Appendix A

ETN Name Name of Underlying ETN IIV Symbol Issuer Website Index/Reference Trading Asset Symbol GS Finance Corp. Russell 1000 Growth FRLG FRLG.IV www.goldmansachs.com Large Cap Growth Index Index-Linked ETNs due 2028

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