Lehman Brothers Inc. Crd# 7506

BrokerCheck Report LEHMAN BROTHERS INC. CRD# 7506

Section Title Page(s) Report Summary 1

Firm Profile 2 - 8

Firm History 9

Firm Operations 10 - 29

Disclosure Events 30

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This firm conducts 22 types of businesses. This firm is affiliated with financial or investment institutions. This firm does not have referral or financial arrangements with other brokers or dealers.

This firm is classified as a corporation. This firm was formed in Delaware on 01/21/1965. Its fiscal year ends in November.

Firm Names and Locations This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailing addresses, telephone number, and any alternate name by which the firm conducts business and where such name is used.

LEHMAN BROTHERS INC. Doing business as LEHMAN BROTHERS INC. CRD# 7506 SEC# 8-12324

Main Office Location 100 WALL STREET 17TH FLOOR NEW YORK, NY 10005 Regulated by FINRA New York Office

Mailing Address 100 WALL STREET 17TH FLOOR NEW YORK, NY 10005

Business Telephone Number 646-348-7100

Other Names of this Firm

Name Where is it used LEHMAN BROTHERS AK, AL, AR, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VA, VT, WA, WI, ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. WV, WY 2 AK, AL, AR, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, PR, www.finra.org/brokercheck RI, SC, SD, TN, TX, User Guidance UT, VA, VT, WA, WI, WV, WY LEHMAN BROTHERS MARKET MAKERS NY

©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 3 www.finra.org/brokercheck User Guidance Firm Profile This section provides information relating to all direct owners and executive officers of the brokerage firm. Direct Owners and Executive Officers

Legal Name & CRD# (if any): LEHMAN BROTHERS HOLDINGS INC. Is this a domestic or foreign Domestic Entity entity or an individual?

Position SOLE SHAREHOLDER Position Start Date 05/1988 Percentage of Ownership 75% or more Does this owner direct the Yes management or policies of the firm?

Is this a public reporting Yes company?

Legal Name & CRD# (if any): CLARK, HOWARD LONGSTRETH JR 47587 Is this a domestic or foreign Individual entity or an individual?

Position DIRECTOR Position Start Date 09/1994 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting company?

Legal Name & CRD# (if any): CRUIKSHANK, THOMAS HENRY 4708135 Is this a domestic or foreign Individual entity or an individual?

Position DIRECTOR Position Start Date 05/2003 Percentage of Ownership Less than 5% ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 4 www.finra.org/brokercheck User Guidance Firm Profile

Direct Owners and Executive Officers (continued) Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting company?

Legal Name & CRD# (if any): FREIDHEIM, SCOTT JON 1766230 Is this a domestic or foreign Individual entity or an individual?

Position CO-CHIEF ADMINISTRATIVE OFFICER Position Start Date 10/2006 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): FULD, RICHARD SEVERIN JR 215527 Is this a domestic or foreign Individual entity or an individual?

Position DIRECTOR/CHAIRMAN AND CEO Position Start Date 08/1984 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): LOWITT, IAN THEO

Direct Owners and Executive Officers (continued) 4210205 Is this a domestic or foreign Individual entity or an individual?

Position CO-CHIEF ADMINISTRATIVE OFFICER Position Start Date 08/2008 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): MCDADE III, HERBERT H. 1185218 Is this a domestic or foreign Individual entity or an individual?

Position PRESIDENT AND CHIEF OPERATING OFFICER Position Start Date 06/2008 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): RUSSO, THOMAS ANTHONY 3188169 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF LEGAL OFFICER Position Start Date 11/1998 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the©2021 firm? FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 6 www.finra.org/brokercheck User Guidance Firm Profile

Direct Owners and Executive Officers (continued) Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 7 www.finra.org/brokercheck User Guidance Firm Profile This section provides information relating to any indirect owners of the brokerage firm. Indirect Owners No information reported.

©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 8 www.finra.org/brokercheck User Guidance Firm History This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.

Registrations This section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatory organizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered and licensed, the date the license became effective, and certain information about the firm's SEC registration. This firm is currently registered with 1 SRO and 0 U.S. states and territories.

Self-Regulatory Organization Status Date Effective FINRA Receivership 09/19/2008

Registrations (continued)

Types of Business This section provides the types of business, including non-securities business, the brokerage firm is engaged in or expects to be engaged in. This firm currently conducts 22 types of businesses. Types of Business

Exchange member engaged in exchange commission business other than floor activities Exchange member engaged in floor activities Broker or dealer making inter-dealer markets in corporation securities over-the-counter Broker or dealer retailing corporate equity securities over-the-counter Broker or dealer selling corporate debt securities Underwriter or selling group participant (corporate securities other than mutual funds) Mutual fund underwriter or sponsor Mutual fund retailer U S. government securities dealer U S. government securities broker Municipal securities dealer Municipal securities broker Solicitor of time deposits in a financial institution Real estate syndicator Broker or dealer selling oil and gas interests Put and call broker or dealer or option writer Broker or dealer selling securities of non-profit organizations (e.g., churches, hospitals) Investment advisory services Broker or dealer selling tax shelters or limited partnerships in primary distributions Trading securities for own account Private placements of securities Broker or dealer selling interests in mortgages or other receivables

Other Types of Business This firm does effect transactions in commodities, commodity futures, or commodity options. This firm does not engage in other non-securities business. Non-Securities Business Description: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 12 www.finra.org/brokercheck User Guidance Non-Securities Business Description:

Clearing Arrangements This firm does hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does not refer or introduce customers to other brokers and dealers.

This firm does not have books or records maintained by a third party.

This firm does not have accounts, funds, or securities maintained by a third party.

This firm does not have customer accounts, funds, or securities maintained by a third party.

Control Persons/Financing This firm does not have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

Organization Affiliates This section provides information on control relationships the firm has with other firms in the securities, investment advisory, or banking business.

This firm is, directly or indirectly: · in control of · controlled by · or under common control with the following partnerships, corporations, or other organizations engaged in the securities or investment advisory business. OOO LEHMAN BROTHERS is under common control with the firm. Business Address: OFFICE 1409 3SMDENSKAYA SQ MOSCOW, RUSSIA 121099 Effective Date: 07/02/2008 Foreign Entity: Yes Country: RUSSIA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS ASSET MANAGEMENT LIMITED is under common control with the firm. Business Address: LEVEL 33, 264 GEORGE STREET SYDNEY, AUSTRALIA 2000 Effective Date: 03/07/2007 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS AUSTRALIA LIMITED is under common control with the firm.

Organization Affiliates (continued)

Business Address: LEVEL 33, 264 GEORGE STREET SYDNEY, AUSTRALIA 2000 Effective Date: 03/07/2007 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

NEUBERGER BERMAN INVESTMENT SERVICES, LLC is under common control with the firm. CRD #: 129618 Business Address: 605 THIRD AVENUE NEW YORK, NY 10158 Effective Date: 02/01/2004 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

NEUBERGER BERMAN PTY LTD is under common control with the firm. Business Address: 255 GEORGE STREET LEVEL 5 SIDNEY, AUSTRALIA 2000 Effective Date: 10/31/2003 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: No Investment Advisory Yes Activities: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 17 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

NEUBERGER BERMAN MANAGEMENT INC. is under common control with the firm. CRD #: 5493 Business Address: 605 THIRD AVENUE NEW YORK, NY 10158 Effective Date: 10/31/2003 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

SAGE PARTNERS LLC is under common control with the firm. CRD #: 106780 Business Address: 220 EAST 42ND STREET 32ND FLOOR NEW YORK, NY 10017 Effective Date: 10/31/2003 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

EXECUTIVE MONETARY MANAGEMENT INC is under common control with the firm. CRD #: 108194

Organization Affiliates (continued)

Business Address: 220 EAST 42ND STREET 32ND FLOOR NEW YORK, NY 10017 Effective Date: 10/31/2003 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

NEUBERGER BERMAN, LLC is under common control with the firm. CRD #: 2908 Business Address: 605 THIRD AVENUE NEW YORK, NY 10158 Effective Date: 10/31/2003 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS PRIVATE FUND MANAGEMENT, LP is under common control with the firm. CRD #: 124969 Business Address: 325 NORTH ST PAUL ST SUITE 4900 DALLAS, TX 75201 Effective Date: 07/22/2005 Foreign Entity: No Country: Securities Activities: No ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 19 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS PRIVATE FUND ADVISERS, LP is under common control with the firm. CRD #: 124970 Business Address: 325 NORTH ST PAUL ST SUITE 4900 DALLAS, TX 75201 Effective Date: 07/22/2005 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS OTC DERIVATIVES INC. is under common control with the firm. CRD #: 124518 Business Address: 745 SEVENTH AVENUE NEW YORK, NY 10019 Effective Date: 07/31/2001 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS A DIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS ASSET MANAGEMENT LLC is under common control with the firm.

Organization Affiliates (continued)

CRD #: 124687 Business Address: 745 SEVENTH AVENUE NEW YORK, NY 10019 Effective Date: 04/01/2005 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS A DIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

EDGEWORTH CAPITAL LLP is under common control with the firm. Business Address: ONE BROADGATE LONDON, ENGLAND EC2M 7HA Effective Date: 03/15/2002 Foreign Entity: Yes Country: ENGLAND Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS (LUXEMBOURG) S.A. is under common control with the firm. Business Address: 7, VAL SAINTE-CROIX LUXEMBOURG, LUXEMBOURG L-1371 Effective Date: 02/05/1992 Foreign Entity: Yes Country: LUXEMBOURG Securities Activities: Yes Investment Advisory No Activities:

Description:©2021 FINRA. All rights reserved. Report aboutUNDER LEHMAN COMMON BROTHERS CONTROL INC. WITH THE REGISTRANT AS A DIRECT 21 SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC. www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS A DIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

BANQUE LEHMAN BROTHERS S.A. is under common control with the firm. Business Address: 21 RUE BALZAC PARIS CEDEX 08, FRANCE 75406 Effective Date: 12/15/1986 Foreign Entity: Yes Country: FRANCE Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS A DIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS EUROPE LIMITED is under common control with the firm. Business Address: ONE BROADGATE LONDON, ENGLAND EC2M 7HA Effective Date: 03/14/2000 Foreign Entity: Yes Country: ENGLAND Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS A DIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

COHANE RAFFERTY, LLC is under common control with the firm. Business Address: 745 SEVENTH AVENUE NEW YORK, NY 10019 Effective Date: 11/28/2001 Foreign Entity: No Country: Securities Activities: Yes ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 22 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS A DIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS (TAIWAN) LTD is under common control with the firm. Business Address: 4TH FLOOR, 205, SUITE 405 TUN HWA N. ROAD TAIPEI, TAIWAN Effective Date: 10/09/1987 Foreign Entity: Yes Country: TAIWAN Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS (THAILAND) LIMITED is under common control with the firm. Business Address: 990 ABDULRAHIM PLACE, 26TH FLOOR, UNIT 2601 RAMA IV ROAD, SILOM, BANGRAK BANGKOK, THAILAND 10500 Effective Date: 07/30/2004 Foreign Entity: Yes Country: THAILAND Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS A DIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS SUDAMERICA S.A. is controlled by the firm. Business Address: 25 DE MAYO 195 PISO 8 ©2021 FINRA. All rights reserved. Report aboutBUENOS LEHMAN AIRES, BROTHERS ARGENTINA INC. 23 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)25 DE MAYO 195 PISO 8 BUENOS AIRES, ARGENTINA Effective Date: 07/28/1980 Foreign Entity: Yes Country: ARGENTINA Securities Activities: Yes Investment Advisory No Activities: Description: CONTROLLED BY APPLICANT

LEHMAN BROTHERS AUSTRALIA PTY LIMITED is under common control with the firm. Business Address: LEVEL 27, 530 COLLINS STREET MELBOURNE, AUSTRALIA Effective Date: 06/27/2000 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS BANKHAUS AKTIENGESELLSCHAFT is under common control with the firm. Business Address: GRUENEBURGWEG 18 D-60322, FRANKFURT AM MAIN, GERMANY Effective Date: 06/03/1987 Foreign Entity: Yes Country: GERMANY Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS A DIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

Organization Affiliates (continued)

LEHMAN BROTHERS INVESTMENTS PTE LIMITED is under common control with the firm. Business Address: 5 TEMASEK BOULEVARD #11-01 SUNTEC CITY TOWER, SINGAPORE 0103 Effective Date: 06/07/1990 Foreign Entity: Yes Country: SINGAPORE Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS A DIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS PRIVATE EQUITY ADVISERS LLC is under common control with the firm. CRD #: 112468 Business Address: 399 PARK AVENUE NEW YORK, NY 10022 Effective Date: 03/01/2001 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS A DIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC

LEHMAN BROTHERS ALTERNATIVE INVESTMENT MANAGEMENT LLC is under common control with the firm. CRD #: 117035 Business Address: 399 PARK AVENUE 5TH FLOOR NEW YORK, NY 10022 Effective Date: 09/01/2001 Foreign Entity: No ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 25 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS JAPAN INC. is under common control with the firm. Business Address: 10-1, ROPPONGI 6-CHOME MINATO-KU, TOKYO, JAPAN 106-6131 Effective Date: 01/13/2004 Foreign Entity: Yes Country: CAYMAN ISLANDS Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS INTERNATIONAL (EUROPE) is under common control with the firm. Business Address: 25 BANK STREET LONDON, ENGLAND E14 5LE Effective Date: 10/14/2003 Foreign Entity: Yes Country: ENGLAND Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS ASSET MANAGEMENT INC. is under common control with the firm.

Organization Affiliates (continued)

CRD #: 109009 Business Address: 399 PARK AVENUE NEW YORK, NY 10022 Effective Date: 04/09/2003 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH REGISTRANT AS A DIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS PTE LTD. is under common control with the firm. Business Address: 5 TEMASEK BOULEVARD #11-01 SUNTEC CITY TOWER, SINGAPORE 0103 Effective Date: 08/16/1980 Foreign Entity: Yes Country: SINGAPORE Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS ASIA LIMITED is under common control with the firm. Business Address: LEVEL 38 ONE PACIFIC PLACE 88 QUEENSWAY HONG KONG, CHINA 1111100000 Effective Date: 05/17/1985 Foreign Entity: Yes Country: HONG KONG Securities Activities: Yes Investment Advisory Yes Activities:©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 27 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS SECURITIES ASIA LIMITED is under common control with the firm. Business Address: LEVEL 38 ONE PACIFIC 88 QUEENSWAY HONG KONG, CHINA 11111 Effective Date: 11/17/1987 Foreign Entity: Yes Country: HONG KONG Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS OFFSHORE PARTNERS LTD. is under common control with the firm. Business Address: CLARENDON HOUSE CHURCH STREET HAMILTON, BERMUDA HM DX Effective Date: 12/13/1988 Foreign Entity: Yes Country: BERMUDA Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

LEHMAN BROTHERS ASIA HOLDINGS LIMITED is under common control with the firm. Business Address: LEVEL 38 ONE PACIFIC 88 QUEENSWAY HONG KONG, CHINA 111111

Organization Affiliates (continued)

Effective Date: 02/27/1976 Foreign Entity: Yes Country: HONG KONG Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL WITH THE REGISTRANT AS AN INDIRECT SUBSIDIARY OF LEHMAN BROTHERS HOLDINGS INC.

This firm is not directly or indirectly, controlled by the following: · bank holding company · national bank · state member bank of the Federal Reserve System · state non-member bank · savings bank or association · credit union · or foreign bank

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal or civil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved. For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm or one of its control affiliates. Further information regarding these events can be found in the subsequent pages of this report. Pending Final On Appeal Regulatory Event 0 359 0 Civil Event 0 1 0 Arbitration N/A 527 N/A

Disclosure Event Details What you should know about reported disclosure events:

1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includes summary information regarding FINRA arbitration awards in cases where the brokerage firm was named as a respondent. 2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a particular criminal event. 3. Disclosure events in BrokerCheck reports come from different sources: o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firm and a regulator report information for the same event, both versions of the event will appear in the BrokerCheck report. The different versions will be separated by a solid line with the reporting source labeled. 4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final. § A "pending" event involves allegations that have not been proven or formally adjudicated. § An event that is "on appeal" involves allegations that have been adjudicated but are currently being appealed. § A "final" event has been concluded and its resolution is not subject to change. o A final event generally has a disposition of adjudicated, settled or otherwise resolved. § An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter, or (2) an administrative panel in an action brought by a regulator that is contested by the party charged with some alleged wrongdoing. § A "settled" matter generally involves an agreement by the parties to resolve the matter. Please note that firms may choose to settle customer disputes or regulatory matters for business or other reasons. § A "resolved" matter usually involves no payment to the customer and no finding of wrongdoing on the part of the individual broker. Such matters generally involve customer disputes. 5. You may wish to contact the brokerage firm to obtain further information regarding any of the disclosure events contained in this BrokerCheck report. Regulatory - Final This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a state securities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission, foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation or suspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federal contractor. Disclosure 1 of 359 Reporting Source: Regulator Current Status: Final Allegations: SEC RULES 10A-1, 200(F)(1), 200(F)(3), NASD RULES 2110, 3010, 3350, ©2021 FINRA. All rights reserved. Report about3370(B)(2), LEHMAN 6130BROTHERS - LEHMAN INC. BROTHERS, INC.'S WRITTEN PLAN OF 31 ORGANIZATION MAINTAINED TO IDENTIFY EACH AGGREGATION UNIT, SPECIFY ITS TRADING OBJECTIVE(S) AND SUPPORT ITS INDEPENDENT IDENTITY FAILED TO DESCRIBE ACCURATELY A SEPARATE AGGREGATION UNIT ESTABLISHED FOR THE FIRM'S RISK MANAGEMENT PURPOSES. THE FIRM FAILED TO ENSURE THAT ALL TRADERS IN EACH AGGREGATION UNIT PURSUED ONLY THE PARTICULAR TRADING OBJECTIVE(S) OR STRATEGY(IES) OF THAT AGGREGATION UNIT AND DID NOT COORDINATE STRATEGY(IES) WITH ANY OTHER AGGREGATION UNIT. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS, INCLUDING SEC RULE 200(F), ACCORDING TO WHICH THE FIRM SHOULD HAVE MAINTAINED A WRITTEN PLAN OF ORGANIZATION THAT IDENTIFIED EACH AGGREGATION UNIT, SPECIFIED ITS TRADING OBJECTIVE(S), SUPPORTED ITS INDEPENDENT IDENTITY AND ENSURED THAT ALL TRADERS IN AN AGGREGATION UNIT PURSUED ONLY THE PARTICULAR TRADING OBJECTIVE(S) OF THAT AGGREGATION UNIT. THE FIRM'S FAILURE TO COMPLY WITH THESE REQUIREMENTS AFFECTED THE ACCURACY OF THE AGGREGATION METHODOLOGY USED BY THE FIRM TO SUPPORT ITS TRADE BY TRADE CALCULATIONS OF NET POSITION. THE FIRM'S ABILITY TO ENSURE THE ACCURACY OF ITS TRADE REPORTS AS TO WHETHER A PARTICULAR TRADE WAS LONG OR SHORT, AND WHETHER A PARTICULAR SHORT SALE WAS PROHIBITED, WAS IMPAIRED. IN SOME INSTANCES, THIS IMPAIRMENT RESULTED IN FLAWED CALCULATIONS OF NET POSITIONS WHICH IN TURN RESULTED IN VIOLATIONS OF NASD RULES 6130, 3350 (THE SHORT SALE RULE) AND SEC RULE 10A-1. [CONTINUED IN COMMENTS.] www.finra.org/brokercheck User Guidance

Allegations: SEC RULES 10A-1, 200(F)(1), 200(F)(3), NASD RULES 2110, 3010, 3350, 3370(B)(2), 6130 - LEHMAN BROTHERS, INC.'S WRITTEN PLAN OF ORGANIZATION MAINTAINED TO IDENTIFY EACH AGGREGATION UNIT, SPECIFY ITS TRADING OBJECTIVE(S) AND SUPPORT ITS INDEPENDENT IDENTITY FAILED TO DESCRIBE ACCURATELY A SEPARATE AGGREGATION UNIT ESTABLISHED FOR THE FIRM'S RISK MANAGEMENT PURPOSES. THE FIRM FAILED TO ENSURE THAT ALL TRADERS IN EACH AGGREGATION UNIT PURSUED ONLY THE PARTICULAR TRADING OBJECTIVE(S) OR STRATEGY(IES) OF THAT AGGREGATION UNIT AND DID NOT COORDINATE STRATEGY(IES) WITH ANY OTHER AGGREGATION UNIT. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS, INCLUDING SEC RULE 200(F), ACCORDING TO WHICH THE FIRM SHOULD HAVE MAINTAINED A WRITTEN PLAN OF ORGANIZATION THAT IDENTIFIED EACH AGGREGATION UNIT, SPECIFIED ITS TRADING OBJECTIVE(S), SUPPORTED ITS INDEPENDENT IDENTITY AND ENSURED THAT ALL TRADERS IN AN AGGREGATION UNIT PURSUED ONLY THE PARTICULAR TRADING OBJECTIVE(S) OF THAT AGGREGATION UNIT. THE FIRM'S FAILURE TO COMPLY WITH THESE REQUIREMENTS AFFECTED THE ACCURACY OF THE AGGREGATION METHODOLOGY USED BY THE FIRM TO SUPPORT ITS TRADE BY TRADE CALCULATIONS OF NET POSITION. THE FIRM'S ABILITY TO ENSURE THE ACCURACY OF ITS TRADE REPORTS AS TO WHETHER A PARTICULAR TRADE WAS LONG OR SHORT, AND WHETHER A PARTICULAR SHORT SALE WAS PROHIBITED, WAS IMPAIRED. IN SOME INSTANCES, THIS IMPAIRMENT RESULTED IN FLAWED CALCULATIONS OF NET POSITIONS WHICH IN TURN RESULTED IN VIOLATIONS OF NASD RULES 6130, 3350 (THE SHORT SALE RULE) AND SEC RULE 10A-1. [CONTINUED IN COMMENTS.] Initiated By: FINRA Date Initiated: 08/18/2008 Docket/Case Number: 2004100012901

Principal Product Type: Other Other Product Type(s): UNKNOWN TYPE OF SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/18/2008 Does the order constitute a No ©2021final orderFINRA. basedAll rights on reserved. Report about LEHMAN BROTHERS INC. 32 violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $250,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: 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 $250,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING COMPLIANCE WITH NASD RULE 3370(B)(2), MAINTAINING A WRITTEN PLAN OF ORGANIZATION IDENTIFYING EACH AGGREGATION UNIT, ITS TRADING OBJECTIVE(S), SUPPORTING ITS INDEPENDENT IDENTITY AND ENSURING THAT ALL TRADERS IN AN AGGREGATION UNIT PURSUED ONLY THE PARTICULAR TRADING OBJECTIVE(S) OF THAT AGGREGATION UNIT WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE ODA OR THE NAC. Regulator Statement THE FIRM ACCEPTED SHORT SALES IN CERTAIN SECURITIES FOR ITS PROPRIETARY ACCOUNT AND CUSTOMER SHORT SALE ORDERS AND, FOR EACH ORDER, FAILED TO ANNOTATE AN AFFIRMATIVE DETERMINATION THAT THE FIRM WOULD RECEIVE DELIVERY OF THE SECURITY OR THAT THE FIRM COULD BORROW THE SECURITY OR OTHERWISE PROVIDE FOR DELIVERY OF THE SECURITIES BY SETTLEMENT DATE. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULE 3370(B)(2). i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGED THAT THE FIRM'S WRITTEN PLAN OF ORGANIZATION MAINTAINED TO DEFINE ITS AGGREGATION UNITS DID NOT PROPERLY DESCRIBE THE TRADING OBJECTIVES OF AN AGGREGATION UNIT ESTABLISHED FOR RISK MANAGEMENT PURPOSES. AS A RESULT, FINRA ALLEGED THAT THAT THE FIRM'S AGGREGATION METHODOLOGY AFFECTED THE FIRM'S ABILITY TO ENSURE THE ACCURACY OF ITS TRADE REPORTS. FURTHER, FINRA ALLEGED THAT FOR CERTAIN FIRM AND CUSTOMER SHORT SALE ORDERS, THE FIRM DID NOT MAINTAIN ADEQUATE AFFIRMATIVE DETERMINATION DOCUMENTATION.

Initiated By: FINRA Date Initiated: 08/18/2008 Docket/Case Number: 20041000129-01

Principal Product Type: Equity - OTC Other Product Type(s): EQUITY LISTED (COMMON & PREFERRED STOCK) Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief UNDERTAKING AND FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/18/2008 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Other Sanctions Ordered: UNDERTAKING TO REVISE CERTAIN WRITTEN SUPERVIOSTY PROCEDURES. Sanction Details: A CENSURE, UNDERTAKING AND A FINE OF $250,000. Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO A CENSURE, UNDERTAKING, AND TO PAY A FINE OF $250,000. i Disclosure 2 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 1050 AND 2110: FROM MARCH 30, 2004 THROUGH AUGUST 15, 2005, THE NAMES OF TEN PERSONS ASSOCIATED WITH RESPONDENT FIRM, INCLUDING TWO PERSONS IN THE BRANCH OFFICE IN TAIWAN, APPEARED ON RESEARCH REPORTS WHEN THOSE INDIVIDUALS DID NOT HAVE THEIR RESEARCH ANALYST REGISTRATION (SERIES 86 AND 87) AND THUS THEY WERE UNQUALIFIED. DURING THAT PERIOD, RESPONDENT FIRM PUBLISHED APPROX. 77 RESEARCH REPORTS WITH THE NAMES OF THE UNREGISTERED ANALYSTS APPEARING ON THOSE REPORTS. Initiated By: FINRA Date Initiated: 07/01/2008 Docket/Case Number: 2005002206301

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/01/2008 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $75,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBER FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $75,000. i Reporting Source: Firm Current Status: Final Allegations: NASD RULES 1050 AND 2110: FINRA ALLEGED THAT DURING THE REVIEW PERIOD MARCH 30, 2004 THROUGH AUGUST 15, 2005, LEHMAN BROTHERS INC. ALLOWED INDIVIDUALS WHO HAD NOT TAKEN THE SERIES 86 AND 87 EXAMS TO FUNCTION AS RESEARCH ANALYSTS BY HAVING THEIR NAMES APPEAR ON THE COVER OF RESEARCH REPORTS. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) Date Initiated: 07/01/2008 Docket/Case Number: 2005002206301

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought:

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/01/2008 Sanctions Ordered: Censure Monetary/Fine $75,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $75,000. LEHMAN BROTHERS INC. PAID THE FINE ON JULY 11, 2008. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS INC. CONSENTED TO A CENSURE AND A FINE OF $75,000. THE AWC BECAME FINAL ON JULY 1, 2008. i Disclosure 3 of 359 Reporting Source: Regulator Current Status: Final Allegations: RULE 15C3-1 OF THE SECURITIES EXCHANGE ACT OF 1934, SECTION 17(A)(1) OF THE SECURITIES EXCHANGE ACT OF 1934, AND RULE 17A- 3(A)(11), 17A-4(B)(5) AND 17A-5 THEREUNDER AND NASD RULES 2110, 3110, 3130(B): IN 1984 AND 1996, LEHMAN BROTHERS INC., (THE "FIRM") EXECUTED TWO ORIGINAL SUBORDINATED INDENTURES, BOTH OF WHICH HAD BEEN APPROVED PRIOR TO EXECUTION BY NYSE. INCLUDED IN THOSE ORIGINAL INDENTURES WAS THE REQUIREMENT THAT THE FIRM OBTAIN THE APPROVAL OF NYSE PRIOR TO EXECUTING ANY SUPPLEMENTAL SUBORDINATED INDENTURES. IN OCTOBER 2003, NYSE REGULATION INC. ("NYSE REGULATION") DETERMINED THAT THE FIRM DID NOT OBTAIN THE REQUIRED PRIOR APPROVAL OF NYSE BEFORE EXECUTING TWO SUPPLEMENTAL SUBORDINATED INDENTURES COVERING APPROXIMATELY $1.493 BILLION OF DEBT. THE TWO SUPPLEMENTAL SUBORDINATED INDENTURES OF OCTOBER 2003 CONTAINED LANGUAGE THAT DID NOT COMPLY WITH THE REQUIREMENTS OF SECTION 15C3-1 OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT" OR "1934 ACT") AND RULE 15C3-LD(A)(1), APPENDIX D ("APPENDIX D") THEREUNDER, RELATING TO THE "MINIMUM REQUIREMENTS FOR SUBORDINATION AGREEMENTS." AS A RESULT, THIS LANGUAGE DISQUALIFIED APPROXIMATELY $1.493 BILLION OF DEBT FROM EXCLUSION AS SUBORDINATED DEBT IN THE FIRM'S NET CAPITAL CALCULATIONS. CONSEQUENTLY, NYSE REGULATION DETERMINED THAT THE FIRM DID NOT ACCURATELY CALCULATE ITS NET CAPITAL AND EXCESS NET CAPITAL AND OVERSTATED BOTH BY APPROXIMATELY $1.493 ©2021 FINRA. All rights reserved. Report aboutBILLION LEHMAN IN ITSBROTHERS FOCUS INC. REPORT CALCULATIONS FROM OCTOBER 2003 36 THROUGH MARCH 2004. (CONTINUED IN COMMENTS) RULE 15C3-1 OF THE SECURITIES EXCHANGE ACT OF 1934, SECTION 17(A)(1) OF THE SECURITIES EXCHANGE ACT OF 1934, AND RULE 17A- 3(A)(11), 17A-4(B)(5) AND 17A-5 THEREUNDER AND NASD RULES 2110, 3110, 3130(B): IN 1984 AND 1996, LEHMAN BROTHERS INC., (THE "FIRM") EXECUTED TWO ORIGINAL SUBORDINATED INDENTURES, BOTH OF WHICH HAD BEEN APPROVED PRIOR TO EXECUTION BY NYSE. INCLUDED IN THOSE ORIGINAL INDENTURES WAS THE REQUIREMENT THAT THE FIRM OBTAIN THE APPROVAL OF NYSE PRIOR TO EXECUTING ANY SUPPLEMENTAL SUBORDINATED INDENTURES. IN OCTOBER 2003, NYSE REGULATION INC. ("NYSE REGULATION") DETERMINED THAT THE FIRM DID NOT OBTAIN THE REQUIRED PRIOR APPROVAL OF NYSE BEFORE EXECUTING TWO SUPPLEMENTAL SUBORDINATED INDENTURES COVERING APPROXIMATELY $1.493 BILLION OF DEBT. THE TWO SUPPLEMENTAL SUBORDINATED INDENTURES OF OCTOBER 2003 CONTAINED LANGUAGE THAT DID NOT COMPLY WITH THE REQUIREMENTS OF SECTION 15C3-1 OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT" OR "1934 ACT") AND RULE 15C3-LD(A)(1), APPENDIX D ("APPENDIX D") THEREUNDER, RELATING TO THE "MINIMUM REQUIREMENTS FOR SUBORDINATION AGREEMENTS." AS A RESULT, THIS www.finra.org/brokercheck LANGUAGE DISQUALIFIED APPROXIMATELY $1.493 BILLION OF DEBT FROM User Guidance EXCLUSION AS SUBORDINATED DEBT IN THE FIRM'S NET CAPITAL CALCULATIONS. CONSEQUENTLY, NYSE REGULATION DETERMINED THAT THE FIRM DID NOT ACCURATELY CALCULATE ITS NET CAPITAL AND EXCESS NET CAPITAL AND OVERSTATED BOTH BY APPROXIMATELY $1.493 BILLION IN ITS FOCUS REPORT CALCULATIONS FROM OCTOBER 2003 THROUGH MARCH 2004. (CONTINUED IN COMMENTS) Initiated By: FINRA Date Initiated: 04/28/2008 Docket/Case Number: 2007009486201

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/28/2008 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $125,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED AND FINED $125,000. Regulator Statement (FINDINGS CONTINUED)LEHMAN VIOLATED EXCHANGE ACT RULE 15C3-1 AND NASD RULE 3130(B) IN THAT ON ONE OR MORE OCCASIONS THE FIRM FAILED TO ACCURATELY COMPUTE ITS NET CAPITAL. LEHMAN VIOLATED SECTION 17(A)(1) OF THE SECURITIES EXCHANGE ACT OF 1934, AND RULE 17A-5 THEREUNDER, IN THAT THE FIRM FILED FOCUS REPORTS WITH THE NYSE REFLECTING A NET CAPITAL FIGURE WHICH INCORRECTLY INCLUDED THE $1.49 BILLION COVERED BY THE SUPPLEMENTAL SUBORDINATED INDENTURES OF OCTOBER 3,.2003 AND OCTOBER 14, 2003. LEHMAN VIOLATED SECTION 17(A)(1) OF THE SECURITIES EXCHANGE ACT OF 1934, AND RULES 17A-3(A)(11) AND 17A-4(B)(5) THEREUNDER, AND NASD RULE 3110 ©2021 FINRA. All rights reserved. Report aboutAND LEHMAN NASD BROTHERS INC. 37 RULE 3130(B) IN THAT THE FIRM FAILED TO MAKE AND/OR PRESERVE ACCURATE BOOKS AND RECORDS REFLECTING AND/OR RELATING TO ITS NET CAPITAL AND EXCESS NET CAPITAL. BY REASON OF THE FOREGOING, LEHMAN VIOLATED NASD RULE 2110 IN THAT THE FIRM FAILED TO ADHERE TO HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE. (FINDINGS CONTINUED)LEHMAN VIOLATED EXCHANGE ACT RULE 15C3-1 AND NASD RULE 3130(B) IN THAT ON ONE OR MORE OCCASIONS THE FIRM FAILED TO ACCURATELY COMPUTE ITS NET CAPITAL. LEHMAN VIOLATED SECTION 17(A)(1) OF THE SECURITIES EXCHANGE ACT OF 1934, AND RULE 17A-5 THEREUNDER, IN THAT THE FIRM FILED FOCUS REPORTS WITH THE NYSE REFLECTING A NET CAPITAL FIGURE WHICH INCORRECTLY INCLUDED THE $1.49 BILLION COVERED BY THE SUPPLEMENTAL SUBORDINATED INDENTURES OF OCTOBER 3,.2003 AND OCTOBER 14, www.finra.org/brokercheck 2003. User Guidance LEHMAN VIOLATED SECTION 17(A)(1) OF THE SECURITIES EXCHANGE ACT OF 1934, AND RULES 17A-3(A)(11) AND 17A-4(B)(5) THEREUNDER, AND NASD RULE 3110 AND NASD RULE 3130(B) IN THAT THE FIRM FAILED TO MAKE AND/OR PRESERVE ACCURATE BOOKS AND RECORDS REFLECTING AND/OR RELATING TO ITS NET CAPITAL AND EXCESS NET CAPITAL. BY REASON OF THE FOREGOING, LEHMAN VIOLATED NASD RULE 2110 IN THAT THE FIRM FAILED TO ADHERE TO HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE. i Reporting Source: Firm Current Status: Final Allegations: IN OCTOBER 2003, THE FIRM MADE CHANGES TO TWO INDENTURES COVERING CERTAIN PUBLICLY-TRADED DEBT OF LEHMAN BROTHERS INC. FINRA ALLEGED THAT THE CHANGES RENDERED THE DEBT COVERED BY THE INDENTURES RETROACTIVELY INELIGIBLE FOR INCLUSION IN THE FIRM'S NET CAPITAL COMPUTATION FOR THE SIX-MONTH PERIOD FROM OCTOBER 2003 TO MARCH 2004 AND IN THE FIRM'S MONTHLY FOCUS REPORTS FOR THAT PERIOD. AT ALL TIMES, THE FIRM MAINTAINED ADEQUATE NET CAPITAL, IN COMPLIANCE WITH REGULATORY REQUIREMENTS. IN ADDITION, DURING THE TIME PERIOD, THE FIRM HAD A $1 BILLION LINE OF CREDIT WHICH WAS NEVER DRAWN DOWN. Initiated By: FINRA Date Initiated: 04/28/2008 Docket/Case Number: 2007009486201

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/28/2008 Sanctions Ordered: Censure Monetary/Fine $125,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND FINE OF $125,000. Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED ©2021 FINRA. All rights reserved. Report aboutTO A LEHMAN CENSURE BROTHERS AND INC.TO PAY A FINE OF $125,000. 38 www.finra.org/brokercheck User Guidance

Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO A CENSURE AND TO PAY A FINE OF $125,000. i Disclosure 4 of 359 Reporting Source: Firm Current Status: Final Allegations: ALLEGED OVERSTATEMENT OF OPEN CONTRACTS IN A CLIENT ACCOUNT Initiated By: ICE CLEAR U.S. INC. Date Initiated: 02/21/2008 Docket/Case Number:

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 02/21/2008 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: $500 ASSESSMENT PAID FEBRUARY 29, 2008. Firm Statement ON FEBRUARY 21, 2008, ICE CLEAR U.S. INC. ISSUED LEHMAN A SUMMARY FINE OF $500 FOR ALLEGED OVERSTATEMENT OF OPEN CONTRACTS IN AN ACCOUNT. i Disclosure 5 of 359 Reporting Source: Firm Current Status: Final Allegations: ON DECEMBER 6, 2007, CME GROUP'S BUSINESS CONDUCT COMMITTEE ISSUED A NOTICE OF PRELIMINARY CHARGES, ALLEGING THAT LEHMAN VIOLATED CHICAGO BOARD OF TRADE ("CBOT") REGULATIONS 331.08 AND 331.09 AND ALSO DID NOT PROVIDE CERTAIN REQUESTED DOCUMENTATION IN CONNECTION WITH CERTAIN EXCHANGE FOR PHYSICALS TRANSACTIONS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 39 ON DECEMBER 6, 2007, CME GROUP'S BUSINESS CONDUCT COMMITTEE www.finra.org/brokercheck ISSUED A NOTICE OF PRELIMINARY CHARGES, ALLEGING THAT LEHMAN User Guidance VIOLATED CHICAGO BOARD OF TRADE ("CBOT") REGULATIONS 331.08 AND 331.09 AND ALSO DID NOT PROVIDE CERTAIN REQUESTED DOCUMENTATION IN CONNECTION WITH CERTAIN EXCHANGE FOR PHYSICALS TRANSACTIONS. Initiated By: CME GROUP Date Initiated: 12/06/2007 Docket/Case Number: 2007-MSR-003

Principal Product Type: Futures - Financial Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 12/21/2007 Sanctions Ordered: Monetary/Fine $70,000.00 Other Sanctions Ordered: Sanction Details: A $70,000 FINE. Firm Statement ON JANUARY 4, 2008, THE BUSINESS CONDUCT COMMITTEE ENTERED A DECISION ACCEPTING LEHMAN'S OFFER OF SETTLEMENT WHICH, WITHOUT ACCEPTING OR DENYING THE ALLEGATIONS IN THE NOTICE OF PRELIMINARY CHARGES, AGREED TO ENTRY OF A FINE IN THE AMOUNT OF $70,000. i Disclosure 6 of 359 Reporting Source: Firm Current Status: Final Allegations: ISE ALLEGED THAT THE FIRM FAILED TO PARTICIPATE IN THE OPENING ROTATION FOR CERTAIN OPTIONS MARKET MAKING ACTIVITY AND FAILED TO MAINTAIN CONTINUOUS QUOTATIONS IN THOSE OPTIONS. Initiated By: INTERNATIONAL SECURITIES EXCHANGE (ISE) Date Initiated: 12/11/2007 Docket/Case Number: 2005-06, ET AL

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 40 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/11/2007 Sanctions Ordered: Monetary/Fine $55,000.00 Other Sanctions Ordered: Sanction Details: A FINE OF $55,000. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO A FINE OF $55,000. THE AWC BECAME FINAL ON DECEMBER 11, 2007. i Disclosure 7 of 359 Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF RULE 4.11 RELATING TO POSITION LIMITS. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 11/30/2007 Docket/Case Number: ICT NO. 89030

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 11/30/2007 Sanctions Ordered: Monetary/Fine $3,500.00 Other Sanctions Ordered: Sanction Details: CBOE ISSUED LEHMAN FINES ON NOVEMBER 30, 2007 FOR $1,000 AND $2,500 FOR MINOR RULE VIOLATIONS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 41 www.finra.org/brokercheck User Guidance

Firm Statement ON NOVEMBER 30, 2007 CBOE ISSUED A NOTICE OF FINE FOR MINOR RULE VIOLATIONS OF RULE 4.11 RELATING TO POSITION LIMITS IN CONNECTION WITH CERTAIN OPTIONS POSITIONS FROM NOVEMBER 12TH THROUGH 14TH 2007, AND ISSUED FINES IN THE AMOUNTS OF $1,000 AND $2,500 ($3,500 TOTAL). i Disclosure 8 of 359 Reporting Source: Firm Current Status: Final Allegations: ALLEGED OVERSTATEMENT OF OPEN CONTRACTS IN AN ACCOUNT. Initiated By: ICE CLEAR U.S. INC. Date Initiated: 11/26/2007 Docket/Case Number:

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 11/26/2007 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: ICE CLEAR U.S. INC. ASSESSED A $500 FINE WHICH WAS PAID DECEMBER 19, 2007. Firm Statement ON NOVEMBER 26, 2007, ICE CLEAR U.S. INC. ISSUED LEHMAN A SUMMARY FINE OF $500 FOR ALLEGED OVERSTATEMENT OF OPEN CONTRACTS IN AN ACCOUNT. i Disclosure 9 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010, 3310 - LEHMAN BROTHERS, INC.'S AGGREGATE ©2021 FINRA. All rights reserved. Report aboutTRADE LEHMAN VOLUME BROTHERS (BUY INC. AND SELL) FOR EQUITY SECURITIES ADVERTISED IN 42 PRIVATE SERVICE PROVIDERS FOR ONE MONTH SUBSTANTIALLY EXCEEDED THE FIRM'S EXECUTED TRADE VOLUME FOR THE SAME SECURITIES. THE FIRM FAILED TO DETERMINE WHETHER THE TRADE VOLUME THAT IT ADVERTISED IN THESE SERVICES ACCURATELY REFLECTED ITS EXECUTED TRADE VOLUME. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING NASD RULE 3310 - THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE ADVERTISED TRADE VOLUME ON SUBSCRIBER SERVICES AND APPLICABLE RULES. THE FIRM DID NOT SUPERVISE THE TRADE VOLUME THAT IT ADVERTISED IN THESE SYSTEMS. www.finra.org/brokercheck User Guidance

Allegations: NASD RULES 2110, 3010, 3310 - LEHMAN BROTHERS, INC.'S AGGREGATE TRADE VOLUME (BUY AND SELL) FOR EQUITY SECURITIES ADVERTISED IN PRIVATE SERVICE PROVIDERS FOR ONE MONTH SUBSTANTIALLY EXCEEDED THE FIRM'S EXECUTED TRADE VOLUME FOR THE SAME SECURITIES. THE FIRM FAILED TO DETERMINE WHETHER THE TRADE VOLUME THAT IT ADVERTISED IN THESE SERVICES ACCURATELY REFLECTED ITS EXECUTED TRADE VOLUME. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING NASD RULE 3310 - THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE ADVERTISED TRADE VOLUME ON SUBSCRIBER SERVICES AND APPLICABLE RULES. THE FIRM DID NOT SUPERVISE THE TRADE VOLUME THAT IT ADVERTISED IN THESE SYSTEMS. Initiated By: FINRA Date Initiated: 12/18/2007 Docket/Case Number: 2006005986801

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/18/2007 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $200,000.00 Other Sanctions Ordered: Sanction Details: 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 $200,000. i Reporting Source: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 43 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGED THAT LEHMAN BROTHERS INC. INACCURATELY ADVERTISED CERTAIN TRADE VOLUMES TO CERTAIN THIRD PARTY VENDORS. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 12/18/2007 Docket/Case Number: 20060059868-01

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/18/2007 Sanctions Ordered: Censure Monetary/Fine $200,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $200,000. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS INC. CONSENTED TO A CENSURE AND A FINE OF $200,000. THE AWC BECAME FINAL ON DECEMBER 18, 2007. THE FINE WAS PAID TO FINRA ON JANUARY 4, 2008. i Disclosure 10 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 1021 AND 2110: LEHMAN PERMITTED AN INDIVIDUAL, A MANAGING DIRECTOR OF ITS OFFICE DESIGNATED AS AN OFFICE OF SUPERVISORY JURISDICTION, TO PERFORM CERTAIN FUNCTIONS REQUIRING PRINCIPAL REGISTRATION PRIOR TO BEING REGISTERED WITH FINRA IN THAT CAPACITY. Initiated By: FINRA

Date Initiated: 11/29/2007 Docket/Case Number: 2005003424802

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/29/2007 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBER FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $50,000. i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGED THAT THE FIRM PERMITTED AN UNREGISTERED PERSON TO PERFORM CERTAIN INTERNAL FUNCTIONS THAT REQUIRED REGISTRATION. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) Date Initiated: 12/06/2007 Docket/Case Number: 2005003424802

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 45 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/06/2007 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $50,000. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO A CENSURE AND A FINE OF $50,000. THE AWC BECAME FINAL ON DECEMBER 6, 2007. i Disclosure 11 of 359 Reporting Source: Firm Current Status: Final Allegations: ALLEGED LATE REPORTING OF CERTAIN TRADE INFORMATION ON SEPTEMBER 14, 2007 IN VIOLATION OF ARTICLE 75-5 OF THE OPERATING RULES OF THE TAIWAN STOCK EXCHANGE CORPORATION. Initiated By: TAIWAN STOCK EXCHANGE CORPORATION Date Initiated: 09/20/2007 Docket/Case Number: 09860204372

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Other Resolution Date: 09/20/2007 Sanctions Ordered: Monetary/Fine $909.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 46 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: FINE OF NTD 30,000 (APPROXIMATELY US $900 AT THE TIME). Firm Statement ON SEPTEMBER 20, 2007, THE TAIWAN BRANCH OF LEHMAN BROTHERS INC. WAS FINED NTD 30,000 FOR ALLEGED LATE REPORTING OF CERTAIN TRADE INFORMATION ON SEPTEMBER 14, 2007 IN VIOLATION OF ARTICLE 75-5 OF THE OPERATING RULES OF THE TAIWAN STOCK EXCHANGE CORPORATION. THE FINE WAS PAID. i Disclosure 12 of 359 Reporting Source: Regulator Current Status: Final Allegations: SEC RULE 203(B)(3) - LEHMAN BROTHERS, INC. HAD A FAIL TO DELIVER POSITION IN A THRESHOLD SECURITY AT A REGISTERED CLEARING AGENCY FOR 13 CONSECUTIVE SETTLEMENT DAYS AND FAILED TO IMMEDIATELY THEREAFTER CLOSE OUT THE FAIL TO DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY. THE FIRM CONTINUED TO HAVE A FAIL TO DELIVER POSITION WHICH IT FAILED TO CLOSE OUT AS REQUIRED AT THE REGISTERED CLEARING AGENCY FOR 10 CONSECUTIVE SETTLEMENT DAYS THEREAFTER. Initiated By: FINRA Date Initiated: 09/07/2007 Docket/Case Number: 2005002802601

Principal Product Type: Other Other Product Type(s): THRESHOLD SECURITY Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/07/2007 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct?

Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: 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 $20,000. i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGED THAT LEHMAN BROTHERS INC. FAILED TO CLOSE OUT A FAIL TO DELIVER POSITION IN A THRESHOLD SECURITY WITHIN THE REQUIRED TIMEFRAME. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 09/07/2007 Docket/Case Number: 20050028026-01

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/07/2007 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $20,000. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO A CENSURE AND A FINE OF $20,000. THE AWC BECAME FINAL ON SEPTEMBER 7, 2007. THE FINE WAS PAID TO FINRA ON SEPTEMBER 24, 2007. i Disclosure 13 of 359

Reporting Source: Regulator Current Status: Final Allegations: **6/29/07**STIPULATION AND CONSENT TO PENALTY FILED BY NYSE REGULATION'S DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYING GUILT, LEHMAN BROTHERS INC. CONSENTS TO FINDINGS THAT IT VIOLATED: 1.NYSE RULES 401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM:A.FAILED TO ENSURE THE DELIVERY OF PROSPECTUSES IN CONNECTION WITH CERTAIN SALES OF REGISTERED SECURITIES IN VIOLATION OF SECTION 5(B)(2) OF THE SECURITIES ACT; AND B.FAILED TO ENSURE THE DELIVERY OF CERTAIN CHANGE OF NAME AND ADDRESS LETTERS, ACCOUNT VERIFICATION PROFILES, MARGIN ACCOUNT DISCLOSURES, PRIVACY STATEMENTS, OPTION SUITABILITY LETTERS, EXTERNAL MANAGER FORMS, DOMESTIC MAIL WAIVER LETTERS, MISSING MARGIN AGREEMENT LETTERS AND STATEMENT CONSOLIDATION LETTERS. 2.NYSE RULE 1100(B) BY FAILING TO DELIVER PRODUCT DESCRIPTIONS TO CERTAIN CUSTOMERS THAT PURCHASED EXCHANGE TRADED FUNDS; 3.RULE 10B-10 OF THE SECURITIES EXCHANGE ACT OF 1934 BY FAILING TO PROVIDE CERTAIN CUSTOMERS WITH TRADE CONFIRMATIONS FOR CERTAIN SECURITIES TRANSACTIONS; AND 4.NYSE RULE 342:A.IN THAT THE FIRM FAILED TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITS OPERATIONAL AND TECHNOLOGICAL ACTIVITIES RELATING TO THE DELIVERY OF PRODUCT DESCRIPTIONS AND PROSPECTUSES;B.IN THAT THE FIRM FAILED TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITS OPERATIONAL AND TECHNOLOGICAL ACTIVITIES RELATING TO THE DELIVERY OF CERTAIN TRADE CONFIRMATIONS AND VARIOUS OTHER DOCUMENTS AS DESCRIBED ABOVE; AND C.BY FAILING TO EVIDENCE ITS SUPERVISORY REVIEW OF CERTAIN LETTERS OF AUTHORIZATION RECEIVED FROM CUSTOMERS, WHICH REQUESTED A CHANGE OF ADDRESS. **CONTINUED AT 13C** Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 06/29/2007 Docket/Case Number: HPD 07-112

Principal Product Type: Other Other Product Type(s):

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 10/04/2007 Sanctions Ordered: Censure Monetary/Fine $1,250,000.00 Other Sanctions Ordered: CONSENT TO CENSURE, $1,250,000 FINE AND UNDERTAKING. Sanction Details: **9/7/07**DECISION 07-112 ISSUED BY NYSE HEARING BOARD DECISION:LEHMAN BROTHERS INC. CONSENTED TO FINDINGS THAT IT VIOLATED:1.NYSE RULES 401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM: A. FAILED TO ENSURE THE DELIVERY OF PROSPECTUSES IN CONNECTION WITH CERTAIN SALES OF REGISTERED SECURITIES IN VIOLATION OF SECTION 5(B)(2) OF THE SECURITIES ACT OF 1933; AND B. FAILED TO ENSURE THE DELIVERY OF CERTAIN CHANGE OF NAME AND ADDRESS LETTERS, ACCOUNT VERIFICATION PROFILES, MARGIN ACCOUNT DISCLOSURES, PRIVACY STATEMENTS, OPTION SUITABILITY LETTERS, EXTERNAL MANAGER FORMS, DOMESTIC MAIL WAIVER LETTERS, MISSING MARGIN AGREEMENT LETTERS AND STATEMENT CONSOLIDATION LETTERS.2.NYSE RULE 1100(B) BY FAILING TO DELIVER PRODUCT DESCRIPTIONS TO CERTAIN CUSTOMERS THAT PURCHASED EXCHANGE TRADED FUNDS;3.RULE 10B- 10 OF THE SECURITIES EXCHANGE ACT OF 1934 BY FAILING TO PROVIDE CERTAIN CUSTOMERS WITH TRADE CONFIRMATIONS FOR CERTAIN SECURITIES TRANSACTIONS; AND NYSE RULE 342:A.IN THAT THE FIRM FAILED TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITS OPERATIONAL AND TECHNOLOGICAL ACTIVITIES RELATING TO THE DELIVERY OF PRODUCT DESCRIPTIONS AND PROSPECTUSES;B.IN THAT THE FIRM FAILED TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITS OPERATIONAL AND TECHNOLOGICAL ACTIVITIES RELATING TO THE DELIVERY OF CERTAIN TRADE CONFIRMATIONS AND VARIOUS OTHER DOCUMENTS AS DESCRIBED IN PARAGRAPH 1(B) ABOVE; ANDC. BY FAILING TO EVIDENCE ITS SUPERVISORY REVIEW OF CERTAIN LETTERS OF AUTHORIZATION RECEIVED FROM CUSTOMERS, WHICH REQUESTED A CHANGE OF ADDRESS.SANCTION: CENSURE, A $1,250,000 FINE AND AN UNDERTAKING Regulator Statement **10/4/07**THE DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESS ON OCTOBER 2, 2007 AND THE FINE BECAME PAYABLE ON THAT SAME ©2021 FINRA. All rights reserved. Report aboutDATE. LEHMAN CONTACT: BROTHERS PEGGY INC. GERMINO 212-656-8450. 50 www.finra.org/brokercheck User Guidance

Regulator Statement **10/4/07**THE DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESS ON OCTOBER 2, 2007 AND THE FINE BECAME PAYABLE ON THAT SAME DATE. CONTACT: PEGGY GERMINO 212-656-8450. i Reporting Source: Firm Current Status: Final Allegations: THE NEW YORK STOCK EXCHANGE ("NYSE") ALLEGED LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED (I) NYSE RULE 401 BY FAILING TO ENSURE COMPLETE DELIVERY OF PROSPECTUSES IN CONNECTION WITH SALES OF CERTAIN REGISTERED SECURITIES DURING THE PERIOD JULY 2003 THROUGH OCTOBER 2004, AND BY FAILING TO ENSURE THE DELIVERY OF CERTAIN REQUIRED CLIENT COMMUNICATIONS BETWEEN OCTOBER 2003 AND JUNE 2004; (II) NYSE RULE 1100(B) BY FAILING TO ENSURE COMPLETE DELIVERY OF PRODUCT DESCRIPTIONS IN CONNECTION WITH SALES OF CERTAIN EXCHANGE TRADED FUNDS DURING THE PERIOD JULY 2003 THROUGH OCTOBER 2004, (III) SECURITIES AND EXCHANGE ACT RULE 10B-10 BY FAILING TO PROVIDE CERTAIN CUSTOMERS WITH TRADE CONFIRMATIONS FOR CERTAIN SECURITIES TRANSACTIONS BETWEEN MARCH AND JUNE 2004; (IV) NYSE RULE 342 BY FAILING TO MAINTAIN SUFFICIENT SUPERVISORY PROCEDURES CONCERNING THE DELIVERY OF PRODUCT DESCRIPTIONS AND PROSPECTUSES, CONFIRMATIONS, AND OTHER REQUIRED CLIENT COMMUNICATIONS. Initiated By: NEW YORK STOCK EXCHANGE REGULATION Date Initiated: 09/07/2007 Docket/Case Number: NYSE HEARING BOARD DECISION 07-112

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): EQUITY - OTC, TAXABLE FIXED INCOME PRODUCTS, EXCHANGE TRADED FUNDS. Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Stipulation and Consent Resolution Date: 10/02/2007 Sanctions Ordered: Censure Monetary/Fine $1,250,000.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 51 www.finra.org/brokercheck User Guidance

Sanction Details: A CENSURE AND UNDERTAKING TO PROVIDE A WRITTEN CERTIFICATION THAT LEHMAN'S CURRENT POLICIES AND PROCEDURES, INCLUDING WRITTEN SUPERVISORY AND OPERATIONAL POLICIES AND PROCEDURES, REGARDING THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS ARE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND NYSE RULES APPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY, IN WHICH LEHMAN AGREED TO A CENSURE, A FINE OF $1,250,000 AND AN UNDERTAKING TO PROVIDE A WRITTEN CERTIFICATION THAT LEHMAN'S CURRENT POLICIES AND PROCEDURES, INCLUDING WRITTEN SUPERVISORY AND OPERATIONAL POLICIES AND PROCEDURES, ARE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND NYSE RULES APPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS. i Disclosure 14 of 359 Reporting Source: Regulator Current Status: Final Allegations: LEHMAN BROTHERS INC., AN EXCHANGE MEMBER ORGANIZATION, WAS CENSURED, FINED IN THE AMOUNT OF 50,000 AND WAS ORDERED TO PAY DISGORGEMENT IN THE AMOUNT OF $263,205 FOR THE FOLLOWING CONDUCT. LEHMAN CONTROLLED UNHEDGED AGGREGATE LONG CALL/SHORT PUT SPY OPTION CONTRACTS AND AGGREGATE SHORT CALL/LONG PUT SPY OPTION CONTRACTS IN ITS AGGREGATED PROPRIETARY ACCOUNTS IN EXCESS OF THE ESTABLISHED POSITION LIMIT. LEHMAN'S PROPRIETARY ACCOUNT EXERCISED 1,277,529 SPY LONG CALL OPTION CONTRACTS, 977,529 CONTRACTS IN EXCESS OF THE ESTABLISHED EXERCISE LIMIT. IN ACCEPTING THIS OFFER OF SETTLEMENT, THE BUSINESS CONDUCT COMMITTEE CONSIDERED CERTAIN MITIGATING FACTS, INCLUDING THE FACT THAT AT THE TIME THE TRANSACTION IN THIS MATTER WAS EXECUTED, LEHMAN PAID TO THE EXCHANGE APPROXIMATELY $251,000 IN SPY LICENSING FEES. AS A RESULT, THE DISGORGEMENT AMOUNT WOULD HAVE BEEN SET-OFF BY THE AMOUNT OF THESE FEES AND LEHMAN'S DISGORGEMENT AMOUNT WOULD HAVE BEEN ONLY APPROXIMATELY $11,000. DUE TO A REFUND BY STANDARD & POOR'S OF THESE FEES, TO BE FORWARDED TO LEHMAN BY THE EXCHANGE, THIS SET-OFF IS NO LONGER APPLICABLE. (CBOE RULES 4.1 – JUST AND EQUITABLE PRINCIPLES OF TRADE, 4.2 – ADHERENCE TO LAW, 4.11 – POSITION LIMITS AND 4.12 – EXERCISE LIMITS.) Initiated By: CHICAGO BOARD OPTIONS EXCHANGE ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 52 www.finra.org/brokercheck User Guidance

Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 08/08/2007 Docket/Case Number: 07-0057

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 12/11/2007 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Disgorgement/Restitution Other Sanctions Ordered: LEHMAN BROTHERS INC. SHALL BE AND HEREBY IS CENSURED, FINED IN THE AMOUNT OF FIFTY THOUSAND DOLLARS ($50,000) AND A DISGORGEMENT IN THE AMOUNT OF $263,205. IN ACCEPTING THIS OFFER OF SETTLEMENT, THE BUSINESS CONDUCT COMMITTEE CONSIDERED CERTAIN MITIGATING FACTS, INCLUDING THE FACT THAT AT THE TIME THE TRANSACTION IN THIS MATTER WAS EXECUTED, LEHMAN PAID TO THE EXCHANGE APPROXIMATELY $251,000 IN SPY LICENSING FEES. AS A RESULT, THE DISGORGEMENT AMOUNT WOULD HAVE BEEN SETOFF BY THE AMOUNT OF THESE FEES AND LEHMAN'S DISGORGEMENT AMOUNT WOULD HAVE BEEN ONLY APPROXIMATELY $11,000. DUE TO A REFUND BY STANDARD & POOR'S OF THESE FEES, TO BE FORWARDED TO LEHMAN BY THE EXCHANGE, THIS SETOFF IS NO LONGER APPLICABLE. Sanction Details: LEHMAN BROTHERS INC. SHALL BE AND HEREBY IS CENSURED, FINED IN THE AMOUNT OF FIFTY THOUSAND DOLLARS ($50,000) AND A DISGORGEMENT IN THE AMOUNT OF $263,205. IN ACCEPTING THIS OFFER OF SETTLEMENT, THE BUSINESS CONDUCT COMMITTEE CONSIDERED CERTAIN MITIGATING FACTS, INCLUDING THE FACT THAT AT THE TIME THE TRANSACTION IN THIS MATTER WAS EXECUTED, LEHMAN PAID TO THE EXCHANGE APPROXIMATELY $251,000 IN SPY LICENSING FEES. AS A RESULT, THE DISGORGEMENT AMOUNT WOULD HAVE BEEN SETOFF BY THE AMOUNT OF THESE FEES AND LEHMAN'S DISGORGEMENT AMOUNT WOULD HAVE BEEN ONLY APPROXIMATELY $11,000. DUE TO A REFUND BY STANDARD & POOR'S OF THESE FEES, TO BE FORWARDED TO LEHMAN BY THE EXCHANGE, THIS SETOFF IS NO LONGER APPLICABLE.

i Reporting Source: Firm Current Status: Final Allegations: THE CHICAGO BOARD OPTIONS EXCHANGE ("CBOE") ALLEGED THAT LEHMAN VIOLATED RULES 4.1, 4.2, 4.11, 4.12 BY EXCEEDING CERTAIN POSITION AND EXERCISE LIMITS. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 08/08/2007 Docket/Case Number: 07-0057

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINES(S); DISGORGMENT Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 12/11/2007 Sanctions Ordered: Censure Monetary/Fine $313,205.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: A CENSURE AND FINE OF $50,000, AS WELL AS, DISGORGEMENT IN THE AMOUNT OF $263,205. THE BUSINESS CONDUCT COMMITTEE OF THE CBOE ISSUED ITS FINAL ORDER ON DECEMBER 11, 2007. Firm Statement WITHOUT ADMITTING OR DENYING THE CBOE'S ALLEGATIONS, LEHMAN AGREED TO A CENSURE, A FINE OF $50,000, AND DISGORGEMENT IN THE AMOUNT OF $263,205. i Disclosure 15 of 359 Reporting Source: Firm Current Status: Final Allegations: THE ISE ALLEGED THAT LEHMAN BROTHERS INC. VIOLATED ISE RULE 717(D) BY TRADING AGAINST CUSTOMER ORDERS WITHOUT FIRST EXPOSING THEM TO THE MARKET FOR 30 SECONDS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 54 www.finra.org/brokercheck User Guidance

Initiated By: INTERNATIONAL SECURITIES EXCHANGE Date Initiated: 06/19/2007 Docket/Case Number: 2005-187; 2005-191; 2006-554; 2006-75; 2

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/19/2007 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF $25,000. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO A CENSURE AND A FINE OF $25,000. THE AWC BECAME FINAL ON JUNE 19, 2007. i Disclosure 16 of 359 Reporting Source: Regulator Current Status: Final Allegations: **5/10/07**STIPULATION AND CONSENT TO PENALTY SENT BY DIVISION OF ENFORCEMENT TO NYSE HEARING BOARD AND PENDING.

CONSENTED TO FINDINGS (WITHOUT ADMITTING OR DENYING GUILT): (1) VIOLATED RULE 97 ON MULTIPLE TRADE DATES BY PURCHASING FOR ONE OF ITS OWN ACCOUNTS A PARTICULAR SECURITY ON A PLUS TICK WITHIN THE LAST 20 MINUTES OF THE TRADING DAY, ON THE SAME DAY THAT THE FIRM ACQUIRED AND HELD A LONG POSITION IN THAT SECURITY, WHERE THAT POSITION RESULTED FROM A BLOCK TRANSACTION EFFECTED WITH A CUSTOMER AND WHERE THE FIRM KNEW OF THIS BLOCK POSITION; AND (2) VIOLATED NYSE RULE 440G.10 BY FILING WITH THE NYSE INACCURATE FORM 121 REPORTS.STIPULATION SANCTION: CENSURE AND A FINE IN THE AMOUNT OF $140,000. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 55 www.finra.org/brokercheck User Guidance

Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 05/10/2007 Docket/Case Number: HPD# 07-79

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 06/26/2007 Sanctions Ordered: Censure Monetary/Fine $140,000.00 Other Sanctions Ordered: Sanction Details: **5/31/07**DECISION # 07-79 ISSUED BY NYSE HEARING BOARD

DECISION: VIOLATED (1) NYSE RULE 97, BY PURCHASING FOR A PROPRIETARY ACCOUNT SECURITY ON A PLUS TICK WITHIN THE LAST TWENTY MINUTES OF TRADING ON THE SAME DAY THAT THE FIRM ACQUIRED AND HELD A LONG POSITION IN THAT SAME SECURITY, WHERE THAT POSITION RESULTED FROM A BLOCK TRANSACTION EFFECTED WITH A CUSTOMER AND WHERE FIRM KNEW OF BLOCK POSITION; (2) NYSE RULE 440G.10, BY FILING WITH THE NYSE INACCURATE FORM 121 REPORTS - CONSENT TO CENSURE AND A FINE OF $140,000. Regulator Statement **6/26/07**DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESS ON JUNE 25, 2007. CONTACT: PEGGY GERMINO 212-656-8450 i Reporting Source: Firm Current Status: Final Allegations: THE NEW YORK STOCK EXCHANGE ("NYSE") ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED EXCHANGE RULE 97 IN CONNECTION WITH CERTAIN TRANSACTIONS. THE NYSE ALSO ALLEGED THAT LEHMAN VIOLATED EXCHANGE RULE 440G.10 BY FILING INACCURATE FORM 121 REPORTS WITH THE NYSE. Initiated By: NEW YORK STOCK EXCHANGE, INC. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 56 www.finra.org/brokercheck User Guidance

Initiated By: NEW YORK STOCK EXCHANGE, INC. Date Initiated: 06/25/2007 Docket/Case Number: NYSE HEARING PANEL DECISION 07-79

Resolution: Stipulation and Consent Resolution Date: 08/01/2007 Sanctions Ordered: Censure Monetary/Fine $140,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $140,000. THE FINE WAS PAID TO THE NYSE ON AUGUST 1, 2007. Firm Statement WITHOUT ADMITTING OR DENYING GUILT, LEHMAN BROTHERS INC. ("LEHMAN") ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY ON MAY 31, 2007 IN WHICH LEHMAN AGREED TO A CENSURE AND A FINE OF $140,000. THE FINE WAS PAID ON AUGUST 1, 2007. i Disclosure 17 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASAD RULE 3360 - LEHMAN BROTHERS, INC. REPORTED SHORT INTEREST POSITIONS INCORRECTLY. Initiated By: NASD Date Initiated: 01/23/2007 Docket/Case Number: 20041000076

Principal Product Type: Other Other Product Type(s): UNKNOWN TYPE OF SECURITIES Principal Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 57 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/23/2007 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $60,000.00 Other Sanctions Ordered: Sanction Details: 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 $60,000. i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGED THAT LEHMAN BROTHERS INC. VIOLATED NASD CONDUCT RULE 3360 BY INACCURATELY REPORTING SHORT INTEREST POSITIONS DURING THE REVIEW PERIOD. Initiated By: NASD Date Initiated: 01/23/2007 Docket/Case Number: 20041000076

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/23/2007 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine LEHMAN BROTHERS $60,000.00 INC. 58 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $60,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $60,000. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO A CENSURE AND A FINE OF $60,000. THE AWC BECAME FINAL ON JANUARY 23, 2007. i Disclosure 18 of 359 Reporting Source: Regulator Current Status: Final Allegations: SEC RULES 10B-10, 11AC1-5, NASD RULES 2110, 3010, 3370,4632, 6130(D), 6620 -LEHMAN BROTHERS, INC.'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES RELATING TO ORDER HANDLING, BEST EXECUTION, ANTI-INTIMIDATION AND COORDINATION, CUSTOMER SALES TRANSACTIONS, PREPARATION AND MAINTENANCE OF BOOKS AND RECORDS, TRADE REPORTING, AND OATS REPORTING. THE FIRM ACCEPTED CUSTOMER SHORT SALE ORDERS IN CERTAIN SECURITIES AND, FOR EACH ORDER, FAILED TO ANNOTATE AN AFFIRMATIVE DETERMINATION THAT THE FIRM WOULD RECEIVE DELIVERY OF THE SECURITY ON BEHALF OF THE CUSTOMER OR THAT THE FIRM COULD BORROW THE SECURITY ON BEHALF OF THE CUSTOMER FOR DELIVERY BY SETTLEMENT DATE; FAILED TO CORRECTLY REPORT TRADES EFFECTED IN NASADAQ NATIONAL MARKET (NNM) SECURITIES TO ACT AS RISKLESS PRINCIPAL AND FAILED IN INSTANCES TO REPORT A TRADE IN AN NNM SECURITY TO ACT; FAILED TO REPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER THE FIRM EXECUTED TRANSACTIONS IN ELIGIBLE SECURITIES IN A PRINCIPAL OR AGENCY CAPACITY; FAILED TO REPORT TO ACT THE CONTRA SIDE EXECUTING BROKER IN TRANSACTIONS IN ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER THE TRANSACTION WAS A BUY, SELL, SELL SHORT, SELL SHORT EXEMPT OR CROSS FOR TRANSACTIONS IN ELIGIBLE SECURITIES; FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY IN TRANSACTIONS AND/OR THAT THE TRANSACTIONS WERE EXECUTED AT AN AVERAGE PRICE; AND FAILED TO PROVIDE CLASSIFICATION INFORMATION FOR APPARENT CUSTOMER ORDERS; UNNECESSARILY PUBLISHED STATISTICS BY CLASSIFYING ORDERS AS COVERED WHICH WERE FOUND TO BE ROUTED AWAY AND IN NON-MARKET MAKING SECURITIES; AND IN ONE INSTANCE,FAILED TO INCLUDE A COVERED ©2021 FINRA. All rights reserved. Report aboutORDER LEHMAN AND BROTHERS MISCALCULATED INC. THE"AWAY EXECUTED SHARES" IN ITS 59 MONTHLY DATA. SEC RULES 10B-10, 11AC1-5, NASD RULES 2110, 3010, 3370,4632, 6130(D), 6620 -LEHMAN BROTHERS, INC.'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES RELATING TO ORDER HANDLING, BEST EXECUTION, ANTI-INTIMIDATION AND COORDINATION, CUSTOMER SALES TRANSACTIONS, PREPARATION AND MAINTENANCE OF BOOKS AND RECORDS, TRADE REPORTING, AND OATS REPORTING. THE FIRM ACCEPTED CUSTOMER SHORT SALE ORDERS IN CERTAIN SECURITIES AND, FOR EACH ORDER, FAILED TO ANNOTATE AN AFFIRMATIVE DETERMINATION THAT THE FIRM WOULD RECEIVE DELIVERY OF THE SECURITY ON BEHALF OF THE CUSTOMER OR THAT THE FIRM COULD BORROW THE SECURITY ON BEHALF OF THE CUSTOMER FOR DELIVERY BY SETTLEMENT DATE; FAILED TO CORRECTLY REPORT TRADES EFFECTED IN NASADAQ NATIONAL MARKET (NNM) SECURITIES TO ACT AS RISKLESS PRINCIPAL AND FAILED IN INSTANCES TO REPORT A TRADE IN AN NNM SECURITY TO ACT; FAILED TO REPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER THE FIRM EXECUTED TRANSACTIONS IN ELIGIBLE SECURITIES IN A PRINCIPAL OR AGENCY CAPACITY; FAILED TO REPORT TO ACT THE CONTRA SIDE EXECUTING BROKER IN TRANSACTIONS IN ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER THE TRANSACTION WAS A BUY, SELL, SELL SHORT, SELL SHORT EXEMPT OR CROSS FOR TRANSACTIONS IN ELIGIBLE SECURITIES; FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY IN TRANSACTIONS AND/OR THAT THE TRANSACTIONS WERE EXECUTED www.finra.org/brokercheck AT AN AVERAGE PRICE; AND FAILED TO PROVIDE CLASSIFICATION User Guidance INFORMATION FOR APPARENT CUSTOMER ORDERS; UNNECESSARILY PUBLISHED STATISTICS BY CLASSIFYING ORDERS AS COVERED WHICH WERE FOUND TO BE ROUTED AWAY AND IN NON-MARKET MAKING SECURITIES; AND IN ONE INSTANCE,FAILED TO INCLUDE A COVERED ORDER AND MISCALCULATED THE"AWAY EXECUTED SHARES" IN ITS MONTHLY DATA. Initiated By: NASD Date Initiated: 01/09/2007 Docket/Case Number: 2005000260501

Principal Product Type: Other Other Product Type(s): UNKNOWN TYPE OF SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/09/2007 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $45,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, IT IS CENSURED, FINED $45,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING ORDER HANDLING, BEST EXECUTION, ANTI-INTIMIDATION AND COORDINATION, CUSTOMER SALES TRANSACTIONS, PREPARATION AND MAINTENANCE OF BOOKS AND RECORDS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY ODA OR THE NAC. i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGED THAT IN CERTAIN INSTANCES THE FIRM: DID NOT REPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER A TRANSACTION WAS A BUY, SELL, SELL SHORT, SELL SHORT EXEMPT OR CROSS, DID NOT ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 60 PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY, AND MISCLASSIFIED CERTAIN STATISTICS REGARDING THE DISCLOSURE OF ORDER EXECUTION INFORMATION. www.finra.org/brokercheck User Guidance

NASD ALLEGED THAT IN CERTAIN INSTANCES THE FIRM: DID NOT REPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER A TRANSACTION WAS A BUY, SELL, SELL SHORT, SELL SHORT EXEMPT OR CROSS, DID NOT PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY, AND MISCLASSIFIED CERTAIN STATISTICS REGARDING THE DISCLOSURE OF ORDER EXECUTION INFORMATION. Initiated By: NASD Date Initiated: 01/09/2007 Docket/Case Number: 2005000260501

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE, UNDERTAKING TO REVISE WRITTEN SUPERVISORY PROCEDURES Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/09/2007 Sanctions Ordered: Censure Monetary/Fine $45,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: A CENSURE, A FINE OF $45,000 AND AN UNDERTAKING TO REVISE CERTAIN WRITTEN SUPERVISORY PROCEDURES. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO A CENSURE, A FINE OF $45,000 AND AN UNDERTAKING TO REVISE CERTAIN WRITTEN SUPERVISORY PROCEDURES. THE AWC BECAME FINAL ON JANUARY 9, 2007. i Disclosure 19 of 359 Reporting Source: Firm Current Status: Final Allegations: ON JULY 19, 2006, THE CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE NOTIFIED LEHMAN BROTHERS INC. ("LBI") IT HAD PRELIMINARILY CONCLUDED THAT THE FIRM VIOLATED REGULATION 444.01 BY ENTERING INTO AN EXCHANGE OF FUTURES FOR CASH COMMODITIES, ALSO KNOWN AS AN EXCHANGE FOR PHYSICALS ("EFP"), IN WHICH THE VALUE OF THE CASH EXCHANGED DID NOT EQUAL THE VALUE OF THE FUTURES, RESULTING IN AN OFF-EXCHANGE SPREAD. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 61 ON JULY 19, 2006, THE CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE NOTIFIED LEHMAN BROTHERS INC. ("LBI") IT HAD PRELIMINARILY CONCLUDED THAT THE FIRM VIOLATED REGULATION www.finra.org/brokercheck 444.01 BY ENTERING INTO AN EXCHANGE OF FUTURES FOR CASH User Guidance COMMODITIES, ALSO KNOWN AS AN EXCHANGE FOR PHYSICALS ("EFP"), IN WHICH THE VALUE OF THE CASH EXCHANGED DID NOT EQUAL THE VALUE OF THE FUTURES, RESULTING IN AN OFF-EXCHANGE SPREAD. Initiated By: CHICAGO BOARD OF TRADE Date Initiated: 08/15/2006 Docket/Case Number: 05-MSR-27

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 08/15/2006 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: NONE Sanction Details: A FINE OF $10,000.00. LBI PAID THE FULL AMOUNT OF THE FINE ON JULY 27, 2006. Firm Statement ON JULY 27, 2006 WITHOUT ADMITTING OR DENYING THE CBOT'S ALLEGATIONS LEHMAN BROTHERS INC. SUBMITTED AN OFFER OF SETTLEMENT AND PAID THE FINE OF $10,000.00. THE CBOT'S BUSINESS CONDUCT COMMITTEE ACCEPTED LEHMAN'S SETTLEMENT OFFER AND RENDERED IT'S DECISION ON AUGUST 15, 2006. i Disclosure 20 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD RULE 6955(A) - DURING SEVERAL REVIEW PERIODS, LEHMAN BROTHERS INC. SUBMITTED TO OATS REPORTS WITH RESPECT TO EQUITY SECURITIES TRADED ON THE NASDAQ STOCK MARKET THAT WERE NOT IN THE ELECTRONIC FORM PRESCRIBED BY NASD AND WERE REPAIRABLE. THE SUBJECT REPORTS WERE REJECTED BY THE OATS SYSTEM AND NOTICE OF SUCH REJECTION WAS MADE AVAILABLE TO THE FIRM ON THE OATS WEBSITE BUT THE FIRM FAILED TO CORRECT OR REPLACE MANY OF THE REJECTED REPAIRABLE REPORTS. Initiated By: NASD Date Initiated: 08/10/2006 Docket/Case Number: 2004200011901 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 62 www.finra.org/brokercheck User Guidance

Docket/Case Number: 2004200011901

Principal Product Type: Other Other Product Type(s): EQUITY SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/10/2006 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: 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. i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGED THAT DURING SEVERAL REVIEW PERIODS, LEHMAN BROTHERS INC. SUBMITTED OATS REPORTS WITH RESPECT TO EQUITY SECURITIES TRADED ON THE NASDAQ STOCK MARKET THAT WERE NOT IN THE ELECTRONIC FORM PRESCRIBED BY NASD AND WERE ALLEGEDLY REPAIRABLE. THE SUBJECT REPORTS WERE REJECTED BY THE OATS SYSTEM BUT THE FIRM ALLEGEDLY FAILED TO CORRECT OR REPLACE SOME PORTION OF THE REJECTED REPAIRABLE REPORTS IN VIOLATION OF NASD RULE 6955(A). Initiated By: NASD Date Initiated: 09/19/2006 Docket/Case Number: 20042000119-01

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/19/2006 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $50,000.00. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS INC. CONSENTED TO A CENSURE AND A FINE OF $50,000.00. THE FINE WAS PAID ON SEPTEMBER 19, 2006. i Disclosure 21 of 359 Reporting Source: Regulator Current Status: Final Allegations: LEHMAN BROTHERS KNEW OR SHOULD HAVE KNOWN THAT THE AGENT WAS POTENTIALLY ENGAGING IN A PRIVATE SECURITIES TRANSACTION IN CONNECTION WITH HIS OUTSIDE BUSINESS ACTIVITY. LEHMAN BROTHERS FAILED TO DETECT THE AGENT'S PRIVATE SECURITIES TRANSACTION. ON AUGUST 20, 2003, LEHMAN TERMINATED THE AGENT FOR HIS ROLE IN THE OPTION TRANSACTION. LEHMAN BROTHERS FAILURE TO DETECT THE AGENT'S PRIVATE SECURITIES TRANSACTION, CONSTITUTES A FAILURE TO SUPERVISE ITS AGENTS IN A MATTER REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE TEXAS SECURITIES ACT AND BOARD RULES, AND IS A VIOLATION OF SECTION 115.10 OF THE BOARD RULES. Initiated By: TEXAS Date Initiated: 07/31/2006 Docket/Case Number: IC06-CAF-25 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): PRIVATE SECURITIES ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 64 www.finra.org/brokercheck User Guidance

Other Product Type(s): PRIVATE SECURITIES Principal Sanction(s)/Relief Reprimand Sought: Other Sanction(s)/Relief ADMINISTRATIVE FINE Sought:

Resolution: Order Resolution Date: 07/31/2006 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $15,000.00 Other Sanctions Ordered: REPRIMAND Sanction Details: NO OTHER SANCTIONS TO FOLLOW. i Reporting Source: Firm Current Status: Final Allegations: THE TEXAS STATE SECURITIES BOARD ALLEGED THAT ON OR ABOUT FEBURARY 15, 2001, LEHMAN BROTHERS INC. FAILED TO DETECT AN AGENT'S PRIVATE SECURITIES TRANSACTION. Initiated By: TEXAS STATE SECURITIES BOARD Date Initiated: 07/31/2006 Docket/Case Number: IC06-CAF-25

Principal Product Type: Other Other Product Type(s): PRIVATE SECURITY Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 07/31/2006

Sanctions Ordered: Monetary/Fine $15,000.00 Other Sanctions Ordered: REPRIMAND Sanction Details: UNDERTAKING AND FINE OF $15,000. THE TEXAS STATE SECURITIES BOARD ENTERED ITS FINAL ORDER ON JULY 31, 2006. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS OF FACT, THE FIRM ENTERED INTO A SETTLEMENT CONSENTING TO AN ADMINISTRATIVE FINE OF $15,000.00 AND THE ENTRY OF A REPRIMAND. THE FINE WAS PAID ON OR ABOUT JULY 31, 2006. i Disclosure 22 of 359 Reporting Source: Regulator Current Status: Final Allegations: LEHMAN BROTHERS, INC. ("LEHMAN"), AN EXCHANGE MEMBER ORGANIZATION REGISTERED TO TRANSACT BUSINESS AS A MARKET- MAKER AND A FLOOR BROKER, AND AUTHORIZED TO CONDUCT A NON- MEMBER CUSTOMER BUSINESS, WAS CENSURED AND FINED $50,000 FOR THE FOLLOWING CONDUCT. IN ACCEPTING THE OFFER OF SETTLEMENT, THE COMMITTEE CONSIDERED CERTAIN FACTORS INCLUDING THE FACT THAT LEHMAN, UPON NOTIFICATION OF THE SYSTEMS DEFICIENCY, TOOK IMMEDIATE CORRECTIVE MEASURES TO ENHANCE AND UPDATE ITS COMPUTER SYSTEM TO EFFECTIVELY MONITOR EMPLOYEE OPTION TRADING ACTIVITY. LEHMAN FAILED TO EFFECTIVELY MONITOR EMPLOYEE OPTION TRADING ACTIVITY. IN ADDITION, LEHMAN FAILED TO ADEQUATELY REVIEW AND SUPERVISE IMPLEMENTATION OF ITS EXCEPTION REPORTS USED TO MONITOR EMPLOYEE OPTION TRADING ACTIVITY. (CBOE RULES 4.1 JUST AND EQUITABLE PRINCIPLES OF TRADE; 4.2 - ADHERENCE TO LAW, 9.8(A) - SUPERVISION OF ACCOUNTS.) Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 05/30/2006 Docket/Case Number: 06-0008

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 07/31/2006 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: LEHMAN BROTHERS, INC. SHALL BE AND HEREBY IS CENSURED AND FINED IN THE AMOUNT OF FIFTY THOUSAND DOLLARS ($50,000). IN ACCEPTING THE OFFER OF SETTLEMENT, THE COMMITTEE CONSIDERED CERTAIN FACTORS INCLUDING THE FACT THAT LEHMAN, UPON NOTIFICATION OF THE SYSTEMS DEFICIENCY, TOOK IMMEDIATE CORRECTIVE MEASURES TO ENHANCE AND UPDATE ITS COMPUTER SYSTEM TO EFFECTIVELY MONITOR EMPLOYEE OPTION TRADING ACTIVITY. Sanction Details: LEHMAN BROTHERS, INC. SHALL BE AND HEREBY IS CENSURED AND FINED IN THE AMOUNT OF FIFTY THOUSAND DOLLARS ($50,000). IN ACCEPTING THE OFFER OF SETTLEMENT, THE COMMITTEE CONSIDERED CERTAIN FACTORS INCLUDING THE FACT THAT LEHMAN, UPON NOTIFICATION OF THE SYSTEMS DEFICIENCY, TOOK IMMEDIATE CORRECTIVE MEASURES TO ENHANCE AND UPDATE ITS COMPUTER SYSTEM TO EFFECTIVELY MONITOR EMPLOYEE OPTION TRADING ACTIVITY. i Reporting Source: Firm Current Status: Final Allegations: THE CHICAGO BOARD OPTIONS EXCHANGE ("CBOE") ALLEGED THAT LEHMAN VIOLATED CBOE RULES 4.1, 4.2 AND 9.8 FOR FAILING TO MONITOR EFFECTIVELY CERTAIN EMPLOYEE TRADING IN OPTIONS FOR POTENTIAL CHINESE WALL AND INSIDER TRADING VIOLATIONS AND TO SUPERVISE IMPLEMENTATION OF EXCEPTION REPORTS USED TO MONITOR SUCH TRADING. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 05/30/2006 Docket/Case Number: 06-0008

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE $50,000.00 Sought:

Resolution: Settled Resolution Date: 07/31/2006 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND FINE OF $50,000. THE BUSINESS CONDUCT COMMITTEE OF THE CBOE ISSUED ITS FINAL ORDER ON JULY 31, 2006. Firm Statement WITHOUT ADMITTING OR DENYING THE CBOE'S ALLEGATIONS, LEHMAN AGREED TO THE ENTRY OF AN ORDER CENSURING AND FINING LEHMAN $50,000 AND FINDING LEHMAN VIOLATED CBOE RULES 4.1, 4.2 AND 9.8(A) BY FAILING TO MONITOR EFFECTIVELY EMPLOYEE OPTION TRADING ACTIVITY, AND ADEQUATELY REVIEW AND SUPERVISE IMPLEMENTATION OF EXCEPTION REPORTS FOR MONITORING OPTION ACTIVITY. THE FINE WAS PAID ON AUGUST 14, 2006. i Disclosure 23 of 359 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 33-8684, 34-53888, DATED MAY 31, 2006, THE SECURITIES AND EXCHANGE COMMISSION COMPLAINT ALLEGES THAT RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. AS PART OF ITS BROKER-DEALER BUSINESS, RESPONDENT UNDERWRITE, AND MANAGE AUCTIONS FOR, AUCTION RATE SECURITIES. FROM AT LEAST JANUARY 1, 2003 THROUGH JUNE 30, 2004, IN CONNECTION WITH CERTAIN AUCTIONS, RESPONDENT ENGAGED IN ONE OR MORE OF THE FOLLOWING PRACTICES VIOLATIONS: COMPLETION OF OPEN OR MARKET BIDS, INTERVENTION IN AUCTIONS, BIDS TO PREVENT FAILED AUCTIONS, BIDS TO A SET A "MARKET" RATE, BIDS TO PREVENT ALL-HOLD AUCTIONS, PRIORITIZATION OF BIDS, SUBMISSION OR REVISION OF BIDS AFTER DEADLINES, ALLOCATION OF SECURITIES, PARTIAL ORDERS, EXPRESS OR TACTIC UNDERSTANDING TO PROVIDE HIGHER RETURNS, AND PRICE TALK. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 05/31/2006 Docket/Case Number: 3-12310

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): MUNICIPAL BONDS, CORPORATE BONDS

Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CENSURE, CIVIL MONEY PENALTY Sought:

Resolution: Order Resolution Date: 05/31/2006 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $1,500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THIS ORDER, RESPONDENT SHALL PROVIDE ALL OF ITS CUSTOMERS WHO HOLD AUCTION RATE SECURITIES ("HOLDERS") AND THE ISSUERS OF SUCH SECURITIES ("ISSUERS") WITH A WRITTEN DESCRIPTION OF THE RESPONDENT'S MATERIAL AUCTION PRACTICES AND PROCEDURES. FURTHERMORE, COMMENCING NOT LATER THAN 3 MONTHS AFTER THE ENTRY OF THIS ORDER, RESPONDENT SHALL AT ALL TIMES MAKE A DESCRIPTION OF ITS THEN-CURRENT MATERIAL AUCTION PRACTICES AND PROCEDURES AVAILABLE TO (1) ALL CUSTOMERS AND BROKER- DEALERS WHO ARE PARTICIPATING THROUGH SUCH RESPONDENT IN AN AUCTION OF AUCTION RATE SECURITIES ON THE PORTION OF ITS WEBSITE THAT IS ACCESSIBLE TO SUCH CUSTOMERS AND BROKER- DEALERS AND IS RELATED TO SUCH AUCTION AND (2) THE GENERAL PUBLIC ON ANOTHER PORTION OF ITS WEBSITE ACCESSIBLE TO THE GENERAL PUBLIC. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THIS ORDER, UNLESS OTHERWISE EXTENDED BY THE STAFF OF THE COMMISSION FOR GOOD CAUSE SHOWN, RESPONDENT'S CHIEF EXECUTIVE OFFICER OR GENERAL COUNSEL SHALL CERTIFY IN WRITING TO THE STAFF OF THE COMMISSION THAT RESPONDENT HAS IMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TO PREVENT AND DETECT FAILURES BY RESPONDENT TO CONDUCT THE AUCTION PROCESS IN ACCORDANCE WITH THE AUCTION PROCEDURES DISCLOSED IN THE DISCLOSURE DOCUMENTS AND ANY SUPPLEMENTAL DISCLOSURES AND THAT THE RESPONDENT IS IN COMPLIANCE WITH SECTION IV.E. OF THIS ORDER. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT CONSENTED TO THE ENTRY OF THIS ORDER; ACCORDINGLY, PURSUANT ©2021 FINRA. All rights reserved. Report aboutTO SECTION LEHMAN BROTHERS 8A OF THE INC. SECURITIES ACT AND SECTION 15(B) OF THE 69 EXCHANGE ACT, IS ORDERED THAT RESPONDENT IS CENSURED, SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT; AND SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY OF $1,500,000 TO THE UNITED STATES TREASURY. www.finra.org/brokercheck User Guidance

WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT CONSENTED TO THE ENTRY OF THIS ORDER; ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIES ACT AND SECTION 15(B) OF THE EXCHANGE ACT, IS ORDERED THAT RESPONDENT IS CENSURED, SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT; AND SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY OF $1,500,000 TO THE UNITED STATES TREASURY. i Reporting Source: Firm Current Status: Final Allegations: THE SEC ALLEGED THAT FIFTEEN FIRMS, INCLUDING LEHMAN BROTHERS INC., IN CONNECTION WITH CERTAIN AUCTIONS OF AUCTION RATE SECURITIES, ENGAGED IN ONE OR MORE OF THE FOLLOWING PRACTICES IN VIOLATION OF SECTION 17(A)(2) OF THE SECURITIES ACT: COMPLETION OF OPEN OR MARKET BIDS, INTERVENTION IN AUCTIONS, BIDS TO PREVENT FAILED AUCTIONS, BIDS TO SET A "MARKET" RATE, BIDS TO PREVENT ALL-HOLD AUCTIONS, PRIORITIZATION OF BIDS, SUBMISSION OR REVISION OF BIDS AFTER DEADLINES, ALLOCATION OF SECURITIES, PARTIAL ORDERS, EXPRESS OR TACIT UNDERSTANDING TO PROVIDE HIGHER RETURNS, AND PRICE TALK. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 05/31/2006 Docket/Case Number: ADMINISTRATIVE PROCEEDING, NO. 3-12310

Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CIVIL MONETARY PENALTY, CENSURE Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 05/31/2006 Sanctions Ordered: Censure Monetary/Fine $1,500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: NOT LATER THAN 3 MONTHS AFTER THE ENTRY OF THE ORDER, THE FIRM SHALL AT ALL TIMES MAKE A DESCRIPTION OF ITS THEN-CURRENT MATERIAL AUCTION PRACTICES AND PROCEDURES AVAILABLE TO (1) ALL CUSTOMERS AND BROKER-DEALERS WHO ARE PARTICIPATING THROUGH ©2021 FINRA. All rights reserved. Report aboutTHE LEHMAN FIRM IN BROTHERS AN AUCTION INC. OF AUCTION RATE SECURITIES ON A PORTION 70 OF ITS WEBSITE THAT IS ACCESSIBLE TO CUSTOMERS AND BROKER- DEALERS AND IS RELATED TO SUCH AUCTIONS AND (2) THE GENERAL PUBLIC. NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THIS ORDER, THE FIRM SHALL PROVIDE ALL OF ITS CUSTOMERS WHO HOLD AUCTION RATE SECURITIES ("HOLDERS") AND THE ISSUERS OF SUCH SECURITIES ("ISSUERS") WITH A WRITTEN DESCRIPTION OF ITS MATERIAL AUCTION PRACTICES AND PROCEDURES. IN ADDITION, COMMENCING NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THE ORDER, THE FIRM SHALL PROVIDE ALL FIRST TIME PURCHASERS AND BROKER-DEALER PURCHASERS WITH A SIMILAR WRITTEN DESCRIPTION OF ITS PRACTICES AND PROCEDURES. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THIS ORDER, THE FIRM'S CHIEF EXECUTIVE OFFICER OR GENERAL COUNSEL SHALL CERTIFY IN WRITING TO THE STAFF THAT THE FIRM HAS IMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TO PREVENT AND DETECT FAILURES BY THE FIRM TO CONDUCT THE AUCTION PROCEDURES IN ACCORDANCE WITH THE AUCTION PROCEDURES DISCLOSED IN THE DISCLOSURE DOCUMENTS AND ANY SUPPLEMENTAL DISCLOSURES AND THAT THE FIRM IS IN COMPLIANCE WITH SECTION IV. E. OF THE ORDER. www.finra.org/brokercheck NOT LATER THAN 3 MONTHS AFTER THE ENTRY OF THE ORDER, THE FIRM User Guidance SHALL AT ALL TIMES MAKE A DESCRIPTION OF ITS THEN-CURRENT MATERIAL AUCTION PRACTICES AND PROCEDURES AVAILABLE TO (1) ALL CUSTOMERS AND BROKER-DEALERS WHO ARE PARTICIPATING THROUGH THE FIRM IN AN AUCTION OF AUCTION RATE SECURITIES ON A PORTION OF ITS WEBSITE THAT IS ACCESSIBLE TO CUSTOMERS AND BROKER- DEALERS AND IS RELATED TO SUCH AUCTIONS AND (2) THE GENERAL PUBLIC. NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THIS ORDER, THE FIRM SHALL PROVIDE ALL OF ITS CUSTOMERS WHO HOLD AUCTION RATE SECURITIES ("HOLDERS") AND THE ISSUERS OF SUCH SECURITIES ("ISSUERS") WITH A WRITTEN DESCRIPTION OF ITS MATERIAL AUCTION PRACTICES AND PROCEDURES. IN ADDITION, COMMENCING NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THE ORDER, THE FIRM SHALL PROVIDE ALL FIRST TIME PURCHASERS AND BROKER-DEALER PURCHASERS WITH A SIMILAR WRITTEN DESCRIPTION OF ITS PRACTICES AND PROCEDURES. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THIS ORDER, THE FIRM'S CHIEF EXECUTIVE OFFICER OR GENERAL COUNSEL SHALL CERTIFY IN WRITING TO THE STAFF THAT THE FIRM HAS IMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TO PREVENT AND DETECT FAILURES BY THE FIRM TO CONDUCT THE AUCTION PROCEDURES IN ACCORDANCE WITH THE AUCTION PROCEDURES DISCLOSED IN THE DISCLOSURE DOCUMENTS AND ANY SUPPLEMENTAL DISCLOSURES AND THAT THE FIRM IS IN COMPLIANCE WITH SECTION IV. E. OF THE ORDER. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM HAS CONSENTED TO A CENSURE, A FINE OF $1,500,000.00 AND AGREES TO CEASE AND DESIST FROM COMMITTING OR CAUSING VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT. THE FINE WAS PAID ON JUNE 8, 2006. Firm Statement SEE ABOVE. i Disclosure 24 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010, 6130(B), 6420(A), 6620(A), 6620(A)(3) - LEHMAN BROTHERS, INC.'S SUPERVISORY SYSTEM FAILED TO PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS RELATING TO NASD CONDUCT RULE 2110 (90 SECOND RULE), REPORTING OF TRANSACTIONS IN CQS SECURITIES AND MARKETPLACE RULE 6130(B)(20 MINUTE RULE); THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN CQS SECURITIES AND OTC EQUITY SECURITIES; FAILED TO DESIGNATE THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN CQS SECURITIES AND OTC EQUITY SECURITIES AND FAILED TO DESIGNATE THROUGH ACT SUCH LAST SALE REPORTS AS LATE; INCORRECTLY DESIGNATED AS ".SLD" THROUGH ACT LAST SALE REPORTS OF ©2021 FINRA. All rights reserved. Report aboutTRANSACTIONS LEHMAN BROTHERS IN CQS INC. SECURITIES REPORTED TO ACT WITHIN 90 71 SECONDS OF EXECUTION; INCORRECTLY DESIGNATED AS ".T" THROUGH ACT TRANSACTIONS IN OTC EQUITY SECURITIES EXECUTED DURING NORMAL MARKET HOURS; FAILED TO ACCEPT OR DELINE TRANSACTIONS IN WHICH THE FIRM REPORTED TO ACT AS THE ORDER ENTRY FIRM WITHIN 20 MINUTES AFTER EXECUTION. NASD RULES 2110, 3010, 6130(B), 6420(A), 6620(A), 6620(A)(3) - LEHMAN BROTHERS, INC.'S SUPERVISORY SYSTEM FAILED TO PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS RELATING TO NASD CONDUCT RULE 2110 (90 SECOND RULE), REPORTING OF TRANSACTIONS IN CQS SECURITIES AND MARKETPLACE RULE 6130(B)(20 MINUTE RULE); THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN CQS www.finra.org/brokercheck SECURITIES AND OTC EQUITY SECURITIES; FAILED TO DESIGNATE User Guidance THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN CQS SECURITIES AND OTC EQUITY SECURITIES AND FAILED TO DESIGNATE THROUGH ACT SUCH LAST SALE REPORTS AS LATE; INCORRECTLY DESIGNATED AS ".SLD" THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN CQS SECURITIES REPORTED TO ACT WITHIN 90 SECONDS OF EXECUTION; INCORRECTLY DESIGNATED AS ".T" THROUGH ACT TRANSACTIONS IN OTC EQUITY SECURITIES EXECUTED DURING NORMAL MARKET HOURS; FAILED TO ACCEPT OR DELINE TRANSACTIONS IN WHICH THE FIRM REPORTED TO ACT AS THE ORDER ENTRY FIRM WITHIN 20 MINUTES AFTER EXECUTION. Initiated By: NASD Date Initiated: 03/23/2006 Docket/Case Number: 2004200005001

Principal Product Type: Equity - OTC Other Product Type(s): CQS SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/23/2006 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $70,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $70000, AND REQUIRED TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REGARDING NASD CONDUCT RULE 2110 (90 SECOND RULE), REPORTING OF TRANSACTIONS IN CQS SECURITIES AND MARKETPLACE RULE 6130(B)(20 MINUTE RULE) WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. i Reporting Source: Firm

Current Status: Final Allegations: NASD ALLEGED THAT THE FIRM'S SUPERVISORY SYSTEM FAILED TO PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD CONDUCT RULE 2110 FOR REPORTING OF TRANSACTIONS WITHIN 90 SECONDS FOR CQS AND OTC SECURITIES, AND NASD CONDUCT RULE 6130(B) FOR ACCEPTING OR DECLINING CERTAIN TRADES WITHIN 20 MINUTES. NASD ALSO ALLEGED THAT FIRM DID NOT TRANSMIT CERTAIN LAST SALE REPORTS IN CQS AND OTC EQUITY SECURITIES WITHIN 90 SECONDS AFTER EXECUTION, AND DESIGNATE CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN CQS AND OTC EQUITY SECURITIES AS LATE. THE FINDINGS ALSO ALLEGED THAT THE FIRM INCORRECTLY DESIGNATED CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN CERTAIN CQS SECURITIES REPORTED TO ACT AS LATE, AND THAT THE FIRM INCORRECTLY DESIGNATED TRANSACTIONS IN CERTAIN OTC EQUITY SECURITIES EXECUTED DURING NORMAL MARKET HOURS AS OUTSIDE NORMAL MARKET HOURS. Initiated By: NASD Date Initiated: 03/23/2006 Docket/Case Number: 20042000050-01

Principal Product Type: Equity - OTC Other Product Type(s): EQUITY - CONSOLIDATED QUOTATION SERVICE ("CQS") SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE, UNDERTAKING AND FINE $70,000 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/23/2006 Sanctions Ordered: Censure Monetary/Fine $70,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT WITH THE NASD TO SETTLE FOUR AUTOMATED CONFIRMATION TRANSACTION SERVICE ("ACT") REPORTING CASES. THE FIRM CONSENTED TO A FINE OF $70,000.00 AND AN UNDERTAKING. THE FIRM PAID THE FINE ON APRIL 17, 2006. Firm Statement PLEASE SEE ITEM 12C.

i Disclosure 25 of 359 Reporting Source: Regulator Current Status: Final Allegations: SEC RULE 10B-10, NASD RULES 2110, 2320, 3010, 4632 - LEHMAN BROTHERS INC. FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET IN CUSTOMER TRANSACTIONS AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICES TO ITS CUSTOMERS WERE AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS; DOUBLE REPORTED ONE RISKLESS PRINCIPAL EXECUTION AND FAILED TO REPORT RISKLESS PRINCIPAL TRADES CORRECTLY; FAILED TO DISCLOSE THE CORRECT CAPACITY ON CUSTOMER CONFIRMATIONS; THE FIRM'S SUPERVISORY SYSTEM FAILED TO PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE CONMPLIANCE WITH NASD CONDUCT RULE 2320 WITH RESPECT TO ITS OBLIGATION TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS; AND IN CQS SECURTIES TRANSACTIONS FOR OR WITH A CUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICES TO ITS CUSTOMERS WERE AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. Initiated By: NASD Date Initiated: 01/26/2006 Docket/Case Number: 2004200008201

Principal Product Type: Other Other Product Type(s): SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/26/2006 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about LEHMAN BROTHERS INC. 74 fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $95,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,LEHMAN BROTHERS CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE NETRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED $95,000, ORDERED TO PAY $5,933.04, PLUS INTEREST, IN RESTITUTION TO PUBLIC CUSTOMERS, AND REQUIRED TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REGARDING AREAS DESCRIBED IN THE ALLEGATIONS WITHIN 30 BUSINESS DAYS. THE FIRM SHALL SUBMIT TO NASD NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC BY THE NAC A SCHEDULE SHOWING RESTITUTION PAYMENTS AND SATISFACTORY PROOF OF RESTITUTION PAYMENTS AND REASONABLE AND DOCUMENTED EFFORTS TO EFFECT RESTITUTION PRIOR TO MAKING PAYMENTS TO ESCHEAT, UNCLAIMED PROPERTY, OR ABANDONED PROPERTY FUNDS. ANY UNDISTRIBUTED RESTITUTION AND INTEREST SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY, OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LAST RESIDED. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED FAILURE TO OBTAIN THE BEST INTER-DEALER MARKET IN CUSTOMER TRANSACTIONS. Initiated By: NASD Date Initiated: 02/14/2006 Docket/Case Number: 20042000082-01

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought:

Other Sanction(s)/Relief FINE, UNDERTAKING, RESTITUTION. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/14/2006 Sanctions Ordered: Censure Monetary/Fine $95,000.00 Disgorgement/Restitution Other Sanctions Ordered: RESTITUTION OF $5,933.04 Sanction Details: IN ADDITION TO A CENSURE, FINE AND RESTITUTION, THE FIRM IS REVISING ITS APPLICABLE WRITTEN SUPERVISORY PROCEDURES. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO THE ENTRY OF AN AWC PROVIDING THAT THE FIRM FAILED TO OBTAIN THE BEST INTER-DEALER MARKET FOR CERTAIN CUSTOMER PURCHASES AND SALES OF SECURITIES, AND FAILED TO REPORT CERTAIN RISKLESS PRINCIPAL TRADES CORRECTLY, AND TO DISCLOSE THE CORRECT CAPACITY ON CERTAIN CUSTOMER CONFIRMATIONS. i Disclosure 26 of 359 Reporting Source: Regulator Current Status: Final Allegations: **1/13/06**STIPULATION OF FACTS AND CONSENT TO PENALTY EXECUTED.HEARING REQUESTED.ALLEGATIONS:1.VIOLATED NYSE RULE 421 IN THAT THE FIRM SUBMITTED INACCURATE REPORTS OF SHORT POSITIONS IN SECURITIES LISTED ON THE NYSE. 2. VIOLATED NYSE RULE 342 IN THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS AND PROCEDURES FOR THE REASONABLE SUPERVISION AND CONTROL OF AREAS RESPONSIBLE FOR COMPLYING WITH NYSE SHORT INTEREST REPORTING REQUIREMENTS, AND FAILED TO ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO COMPLY WITH, OR DETECT AND PREVENT VIOLATIONS OF, NYSE SHORT INTEREST REPORTING REQUIREMENTS.PROPOSED SANCTION:CENSURE AND A $400,000 FINE. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 01/13/2006 Docket/Case Number: HPD#06-53

Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 06/09/2006 Sanctions Ordered: Censure Monetary/Fine $400,000.00 Other Sanctions Ordered: Sanction Details: **4/27/06** HEARING PANEL DECISION ISSUED HPD 06-53 HEARING PANEL DECISION: I.VIOLATED NYSE RULE 421 BY SUBMITTING INACCURATE REPORTS OF SHORT POSITIONS IN SECURITIES LISTED ON THE NYSE. II.VIOLATED NYSE RULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS AND PROCEDURES FOR REASONABLE SUPERVISION AND CONTROL OF AREAS RESPONSIBLE FOR COMPLYING WITH NYSE SHORT-INTEREST REPORTING REQUIREMENTS AND FAILING TO ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO COMPLY WITH, OR DETECT AND PREVENT VIOLATIONS OF, NYSE SHORT-INTEREST REPORTING REQUIREMENTS. CONSENT TO CENSURE AND $400,000 FINE. Regulator Statement **6/9/06**DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY. CONTACT:PEGGY GERMINO 212-656-8450 i Reporting Source: Firm Current Status: Final Allegations: THE NEW YORK STOCK EXCHANGE, LLC. ("NYSE") ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED NYSE RULE 421 BY SUBMITTING INACCURATE REPORTS OF SHORT POSITIONS IN SECURITIES LISTED ON THE NYSE. THE NYSE ALSO ALLEGED THAT LEHMAN VIOLATED NYSE RULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS AND PROCEDURES FOR REASONABLE SUPERVISION AND CONTROL OF AREAS RESPONSIBLE FOR COMPLYING WITH NYSE SHORT- INTEREST REPORTING REQUIREMENTS AND FAILING TO ESTABLISH A SEPARATE FOLLOW-UP AND REVIEW TO COMPLY WITH, OR DETECT AND PREVENT VIOLATIONS OF, NYSE SHORT-INTEREST REPORTING REQUIREMENTS. Initiated By: NEW YORK STOCK EXCHANGE, LLC. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 77 www.finra.org/brokercheck User Guidance

Initiated By: NEW YORK STOCK EXCHANGE, LLC. Date Initiated: 06/09/2006 Docket/Case Number: NYSE HEARING PANEL DECISION 06-53

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief CENSURE AND A FINE OF $400,000.00 Sought:

Resolution: Consent Resolution Date: 06/09/2006 Sanctions Ordered: Censure Monetary/Fine $400,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $400,000.00. THE HEARING PANELS DECISION BECAME FINAL ON JUNE 9, 2006. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FACTS, CONCLUSIONS OR FINDINGS, LEHMAN ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY ON JANUARY 13, 2006 IN WHICH LEHMAN AGREED TO A CENSURE, AND A FINE OF $400,000.00. ON JUNE 9, 2006, THE NYSE ADVISED LEHMAN THAT THE HEARING PANEL'S DECISION, IN WHICH IT ACCEPTED THE STIPULATION AND CONSENT, HAD BECOME FINAL. i Disclosure 27 of 359 Reporting Source: Regulator Current Status: Final Allegations: MEMBER FIRM VIOLATED PCXE RULE 7.23(A)(1) WHEN IT FAILED TO MAINTAIN CONTINUOUS TWO-SIDED Q ORDERS FOR ISSUES IN WHICH IT IS REGISTERED TO TRADE AS A MARKET MAKER. Initiated By: PACIFIC STOCK EXCHANGE Date Initiated: 08/01/2004 Docket/Case Number: 05-24

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief LEHMAN BROTHERS MUST AMEND ITS OPERATIONAL AND SUPERVISORY Sought: PROCEDURES TO GREATLY REDUCE IF NOT ELIMINATE FUTURE VIOLATIONS OF ITS MARKET MAKER OBLIGATIONS TO MAINTAIN CONTINUOUS TWO-SIDED Q ORDERS.

Resolution: Decision & Order of Offer of Settlement Resolution Date: 09/08/2005 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $30,750.00 Other Sanctions Ordered: AMEND OPERATIONAL AND SUPERVISORY PROCEDURES TO GREATLY REDUCE IF NOT ELIMINATE LEHMAN BROTHERS' FUTURE VIOLATION OF ITS MARKET MAKER OBLIGATION TO MAINTAIN CONTINUOUS TWO-SIDED Q ORDERS. Sanction Details: $30,750.00 FINE LEVIED AGAINST LEHMAN BROTHERS WAS PAID ON OCTOBER 10, 2005. i Reporting Source: Firm Current Status: Final Allegations: THE FIRM WAS REGISTERED AS A MARKET MAKER AND FAILED TO MAINTAIN A CONTINUOUS TWO-SIDED QUOTE IN ARCHIPELAGO HOLDINGS, INC. Initiated By: PCX EQUITIES, INC. Date Initiated: 07/15/2005 Docket/Case Number: 05-24

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 79 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief UNDERTAKING Sought:

Resolution: Consent Resolution Date: 10/10/2005 Sanctions Ordered: Monetary/Fine $30,750.00 Other Sanctions Ordered: UNDERTAKING TO NOT RE-REGISTER AS A MARKET MAKER UNTIL CERTAIN SYSTEM CHANGES HAVE BEEN MADE. Sanction Details: FROM AUGUST 2004 TO MAY 2005 THE FIRM FAILED TO MAINTAIN A CONTINUOUS, TWO-SIDED QUOTE IN ARCHIPELAGO HOLDINGS, INC. WHILE REGISTERED AS A MARKET MAKER WITH PCX EQUITIES, INC. i Disclosure 28 of 359 Reporting Source: Regulator Current Status: Final Allegations: **9/28/05**STIPULATION AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS: 1.VIOLATED EXCHANGE RULE 410A BY FAILING TO SUBMIT ACCURATE TRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONIC BLUE SHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR SUCH INFORMATION BY THE EXCHANGE;2.VIOLATED EXCHANGE RULE 401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THE CONDUCT OF THEIR BUSINESS AFFAIRS IN THAT IT SUBMITTED INACCURATE TRADING INFORMATION ON ELECTRONIC BLUE SHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR SUCH INFORMATION BY THE EXCHANGE; AND 3.VIOLATED EXCHANGE RULES 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS AND PROCEDURES FOR THE SUPERVISION AND CONTROL OF AREAS RESPONSIBLE FOR COMPLYING WITH ELECTRONIC BLUE SHEET REPORTING REQUIREMENTS, AND FAILED TO ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO REASONABLY ENSURE COMPLIANCE WITH EXCHANGE RULES RELATING TO THE PREPARATION AND SUBMISSION OF ELECTRONIC BLUE SHEETS. STIPULATED SANCTION:THE IMPOSITION BY THE EXCHANGE OF A CENSURE, A $150,000 FINE AND A REQUIREMENT THAT RESPONDENT WILL CONDUCT A VALIDATION OF ALL REQUIRED BLUE SHEET DATA ELEMENTS IN ACCORDANCE WITH ISG REGULATORY MEMORANDUM, ISG 2005-01. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT

Date Initiated: 09/28/2005 Docket/Case Number: HPD# 05-148

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 02/17/2006 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: Sanction Details: **1/5/06**DECISION 05-148 ISSUED BY NYSE HEARING PANEL DECISION: VIOLATED NYSE RULE 410A BY FAILING TO SUBMIT ACCURATE TRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONIC BLUE SHEETS; VIOLATED NYSE RULE 401 BY SUBMITTING INACCURATE TRADING INFORMATION ON ELECTRONIC BLUE SHEETS; VIOLATED NYSE RULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS AND PROCEDURES FOR THE SUPERVISION AND CONTROL OF AREAS RESPONSIBLE FOR COMPLYING WITH ELECTRONIC BLUE SHEET REPORTING REQUIREMENTS AND FAILING TO ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO REASONABLY ENSURE COMPLIANCE WITH NYSE RULES RELATING TO THE PREPARATION AND SUBMISSION OF ELECTRONIC BLUE SHEETS. -CONSENT TO CENSURE, FINE OF $150,000, AND A REQUIREMENT TO CONDUCT VALIDATION OF ALL REQUIRED BLUE SHEET DATA ELEMENTS, AND UNDERTAKING TO INFORM NYSE IN WRITING THAT VALIDATION HAS BEEN COMPLETED. Regulator Statement **2/17/06**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT:PEGGY GERMINO AT 212-656-8450 i Reporting Source: Firm Current Status: Final Allegations: NYSE ALLEGED THAT THE FIRM SUBMITTED INACCURATE ELECTRONIC BLUE SHEETS, IN VIOLATION OF NYSE RULES 410A AND 401 AND FAILED TO PROPERLY SUPERVISE THE PREPARATION OF ITS BLUE SHEET SUBMISSIONS IN VIOLATION OF NYSE RULE 342. NYSE ALLEGED THAT ©2021 FINRA. All rights reserved. Report aboutTHE LEHMAN INACCURACIES BROTHERS ININC. THE BLUE SHEET SUBMISSIONS RESULTED FROM 81 DEFICIENCIES IN THE FIRM'S BLUE SHEET SYSTEMS. NYSE ALLEGED THAT THE INACCURACIES WERE SYSTEMIC IN NATURE AND CONSISTED OF THE REPORTING OF SHORT EQUITY SALES, AS LONG SALES. www.finra.org/brokercheck User Guidance NYSE ALLEGED THAT THE FIRM SUBMITTED INACCURATE ELECTRONIC BLUE SHEETS, IN VIOLATION OF NYSE RULES 410A AND 401 AND FAILED TO PROPERLY SUPERVISE THE PREPARATION OF ITS BLUE SHEET SUBMISSIONS IN VIOLATION OF NYSE RULE 342. NYSE ALLEGED THAT THE INACCURACIES IN THE BLUE SHEET SUBMISSIONS RESULTED FROM DEFICIENCIES IN THE FIRM'S BLUE SHEET SYSTEMS. NYSE ALLEGED THAT THE INACCURACIES WERE SYSTEMIC IN NATURE AND CONSISTED OF THE REPORTING OF SHORT EQUITY SALES, AS LONG SALES. Initiated By: NYSE Date Initiated: 06/16/2005 Docket/Case Number: HEARING PANEL DECISION 05-148

Resolution: Stipulation and Consent Resolution Date: 02/17/2006 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: UNDERTAKING TO VALIDATE ALL REQUIRED BLUESHEET DATA ELEMENTS. Sanction Details: IN ADDITION TO A CENSURE AND A FINE, THE FIRM HAS CONSENTED TO AN UNDERTAKING TO VALIDATE ALL REQUIRED BLUESHEET DATA ELEMENTS. Firm Statement WITHOUT ADMITTING OR DENYING ALLEGATIONS, FACTS, CONCLUSIONS OR FINDINGS, REFERRED TO IN THE STIPULATION OF FACTS AND CONSENT TO PENALTY, THE FIRM CONSENTED TO A FINDING BY THE HEARING PANEL THAT IT 1) VIOLATED NYSE RULE 410A BY FAILING TO SUBMIT ACCURATE ELECTRONIC BLUE SHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR INFORMATION BY THE NYSE, 2) VIOLATED NYSE RULE 401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THE CONDUCT OF ITS BUSINESS AFFAIRS IN THAT IT SUBMITTED INACCURATE TRADING INFORMATION ON ELECTRONIC BLUE SHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR SUCH INFORMATION BY THE NYSE, 3) VIOLATED NYSE RULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS AND PROCEDURES FOR THE SUPERVISION AND CONTROL OF AREAS RESPONSIBLE FOR COMPLYING WITH ELECTRONIC BLUE SHEET REQUIREMENTS AND FAILING TO ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO REASONABLY ENSURE COMPLIANCE WITH NYSE RULES RELATING TO THE PREPARATION AND SUBMISSION OF ELECTRONIC BLUE SHEETS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 82 WITHOUT ADMITTING OR DENYING ALLEGATIONS, FACTS, CONCLUSIONS OR FINDINGS, REFERRED TO IN THE STIPULATION OF FACTS AND CONSENT TO PENALTY, THE FIRM CONSENTED TO A FINDING BY THE HEARING PANEL THAT IT 1) VIOLATED NYSE RULE 410A BY FAILING TO SUBMIT ACCURATE ELECTRONIC BLUE SHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR INFORMATION BY THE NYSE, 2) VIOLATED NYSE RULE 401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THE CONDUCT OF ITS BUSINESS AFFAIRS IN THAT IT SUBMITTED INACCURATE TRADING INFORMATION ON ELECTRONIC BLUE SHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR SUCH INFORMATION BY THE NYSE, 3) VIOLATED NYSE RULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS AND PROCEDURES www.finra.org/brokercheck FOR THE SUPERVISION AND CONTROL OF AREAS RESPONSIBLE FOR User Guidance COMPLYING WITH ELECTRONIC BLUE SHEET REQUIREMENTS AND FAILING TO ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO REASONABLY ENSURE COMPLIANCE WITH NYSE RULES RELATING TO THE PREPARATION AND SUBMISSION OF ELECTRONIC BLUE SHEETS. i Disclosure 29 of 359 Reporting Source: Regulator Current Status: Final Allegations: **8/17/05**CONSENTED TO FINDINGS THAT IT: 1. VIOLATED EXCHANGE RULE 342 BY:A. FAILING TO HAVE REASONABLE POLICIES AND PROCEDURES IN PLACE TO SUPERVISE THE MANNER IN WHICH TRADES RELATING TO FACILITATION CONTRACTS FOR THE PURCHASE OF STOCK AT PRICES DERIVED FROM THE CLOSING PRICE WERE SUBMITTED, PARTICULARLY WHERE THERE WAS AN ECONOMIC INCENTIVE TO IMPACT THE CLOSING PRICE, AND B. FAILING TO HAVE ADEQUATE CONTROLS TO EVALUATE AND SCRUTINIZE THE RISKS ASSOCIATED WITH TRADES RELATING TO SUCH FACILITATION CONTRACTS TO PREVENT SUCH TRADES FROM OCCURRING AT THE CLOSE WHEN THEY COULD BE DISRUPTIVE OR CAUSE EXCESS MARKET VOLATILITY.2.VIOLATED EXCHANGE RULE 401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE BY ENGAGING IN SEVERAL TRANSACTIONS FOR THE SALE OF STOCK AT OR NEAR THE CLOSE OF TRADING WHICH WERE DISRUPTIVE AND CAUSED EXCESS MARKET VOLATILITY WITHOUT HAVING ADEQUATE POLICES, PROCEDURES AND CONTROLS IN PLACE TO MONITOR SUCH TRANSACTIONS.STIPULATED SANCTION:1.CENSURE; AND 2. A FINE IN THE AMOUNT OF $500,000; AND 3.A REQUIREMENT TO COMPLY WITH THE FOLLOWING UNDERTAKING:A.THE FIRM WILL CAUSE ITS OFFICE OF GENERAL COUNSEL TO PERFORM A REVIEW TO IDENTIFY THE PROCEDURES AND SYSTEMS OF FOLLOW-UP AND REVIEW THE FIRM HAS IN PLACE OR HAS ADOPTED WHICH ARE REASONABLY DESIGNED TO PREVENT RECURRENCE OF THE FOREGOING VIOLATIONS, INCLUDING THOSE INVOLVING STOCK INDEX MIGRATIONS AND ADDITIONS AND FACILITATION CONTRACTS GENERALLY THAT DERIVE THEIR PRICE FROM THE CLOSE, TO ENSURE COMPLIANCE WITH APPLICABLE EXCHANGE RULES AND FEDERAL SECURITIES LAWS, TO EVALUATE WHETHER FURTHER ENHANCEMENTS OR IMPROVEMENTS TO SUCH PROCEDURES AND SYSTEMS ARE APPROPRIATE, TO MAKE ANY APPROPRIATE RECOMMENDATIONS FOR ADDITIONAL PROCEDURES AND SYSTEMS, IF NECESSARY, AND TO PREPARE A WRITTEN REPORT (THE "REPORT").**CONTINUED AT #13C** Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCMENT Date Initiated: 08/17/2005 Docket/Case Number: HPD#:05-108

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 11/10/2005 Sanctions Ordered: Censure Monetary/Fine $500,000.00 Other Sanctions Ordered: Sanction Details: **CONTINUED FROM #7**B. THE FIRM'S OFFICE OF GENERAL COUNSEL SHALL PREPARE THE REPORT, WITHIN 120 DAYS FROM THE DATE THIS DECISION BECOMES FINAL, ADDRESSING THE AFOREMENTIONED REVIEW, AND THE FIRM SHALL ADOPT AND IMPLEMENT ANY RECOMMENDATIONS RESULTING FROM THE OFFICE OF GENERAL COUNSEL'S REVIEW TO PREVENT THE RECURRENCE OF THE VIOLATIONS DESCRIBED HEREIN AND PROVIDE A COPY OF THE REPORT TO THE EXCHANGE AND THE FIRM'S GLOBAL HEAD OF EQUITIES **9/29/05**DECISION NO. 05-108 ISSUED BY NYSE HEARING PANEL. VIOLATED EXCHANGE RULE 342 BY FAILING TO HAVE REASONABLE POLICIES AND PROCEDURES IN PLACE TO SUPERVISE MANNER IN WHICH TRADES RELATING TO FACILITATION CONTRACTS FOR PURCHASE OF STOCK AT PRICES DERIVED FROM THE CLOSING PRICE WERE SUBMITTED AND BY FAILING TO HAVE ADEQUATE CONTROLS TO EVALUATE AND SCRUTINIZE RISKS ASSOCIATED WITH TRADES AT CLOSE WHEN THEY COULD BE DISRUPTIVE OR CAUSE EXCESS MARKET VOLATILITY; VIOLATED EXCHANGE RULE 401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE BY ENGAGING IN SEVERAL TRANSACTIONS FOR SALE OF STOCK AT OR NEAR THE CLOSE OF TRADING.SANCTION:LEHMAN BROTHERS INC. WAS FOUND GUILTY OF THE ABOVE CHARGES AND CONSENTED TO A CENSURE, $500,000 FINE AND UNDERTAKING TO CONDUCT INTERNAL REVIEW TO IDENTIFY ADDITIONAL PROCEDURES AND SYSTEMS OF FOLLOW-UP REASONABLY DESIGNED TO PREVENT RECURRENCE OF ABOVE VIOLATIONS. Regulator Statement **11/10/05**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT: EVELYN KRIEGEL 212-656-6444 i Reporting Source: Firm

Current Status: Final Allegations: THE NEW YORK STOCK EXCHANGE ("NYSE") ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED EXCHANGE RULE 342 BY FAILING TO HAVE REASONABLE POLICIES AND PROCEDURES IN PLACE TO SUPERVISE THE MANNER IN WHICH TRADES RELATING TO FACILITATION CONTRACTS FOR THE PURCHASE OF STOCK AT PRICES DERIVED FROM THE CLOSING PRICE WERE SUBMITTED AND FOR FAILING TO HAVE ADEQUATE CONTROLS TO EVALUATE AND SCRUTINIZE THE RISKS ASSOCIATED WITH THESE TRADES TO PREVENT THEM FROM OCCURRING AT THE CLOSE WHEN THEY COULD BE DISRUPTIVE OR CAUSE EXCESS MARKET VOLATILITY. THE NYSE ALSO ALLEGED THAT LEHMAN VIOLATED EXCHANGE RULE 401 BY ENGAGING IN SEVERAL TRANSACTIONS FOR THE SALE OF STOCK AT OR NEAR THE CLOSE OF TRADING WHICH WERE DISRUPTIVE AND CAUSED EXCESS MARKET VOLATILITY WITHOUT HAVING ADEQUATE POLICIES, PROCEDURES AND CONTROLS IN PLACE TO MONITOR SUCH TRANSACTIONS. Initiated By: NEW YORK STOCK EXCHANGE, INC. Date Initiated: 11/10/2005 Docket/Case Number: NYSE HEARING PANEL DECISION 05-108

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief A CENSURE AND AN UNDERTAKING TO CONDUCT A REVIEW OF Sought: PROCEDURES AND SYSTEMS REASONABLY DESIGNED TO PREVENT RECURRENCE OF THE ALLEGED VIOLATIONS.

Resolution: Stipulation and Consent Resolution Date: 11/10/2005 Sanctions Ordered: Censure Monetary/Fine $500,000.00 Other Sanctions Ordered: REQUIREMENT TO COMPLY WITH AN UNDERTAKING TO PERFORM A REVIEW. Sanction Details: A CENSURE, A FINE OF $500,000 AND AN UNDERTAKING TO CONDUCT A REVIEW OF PROCEDURES AND SYSTEMS REASONABLY DESIGNED TO PREVENT RECURRENCE OF THE ALLEGED VIOLATIONS. THE HEARING PANEL'S DECISION BECAME FINAL ON NOVEMBER 10, 2005 AND THE FINE WILL BE PAID WITHIN 45 DAYS OF THIS DATE. Firm Statement WITHOUT ADMITTING OR DENYING GUILT, LEHMAN BROTHERS INC. ©2021 FINRA. All rights reserved. Report about("LEHMAN") LEHMAN BROTHERS ENTERED INC. INTO A STIPULATION OF FACTS AND CONSENT TO 85 PENALTY ON AUGUST 17, 2005 IN WHICH LEHMAN AGREED TO A CENSURE, A FINE OF $500,000 AND AN UNDERTAKING TO CONDUCT A REVIEW OF PROCEDURES AND SYSTEMS REASONABLY DESIGNED TO PREVENT RECURRENCE OF THE ALLEGED VIOLATIONS. ON NOVEMBER 10, 2005, THE NYSE ADVISED LEHMAN BROTHERS THAT THE HEARING PANEL'S DECISION, IN WHICH IT ACCEPTED THE STIPULATION AND CONSENT, HAD BECOME FINAL. www.finra.org/brokercheck User Guidance

Firm Statement WITHOUT ADMITTING OR DENYING GUILT, LEHMAN BROTHERS INC. ("LEHMAN") ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY ON AUGUST 17, 2005 IN WHICH LEHMAN AGREED TO A CENSURE, A FINE OF $500,000 AND AN UNDERTAKING TO CONDUCT A REVIEW OF PROCEDURES AND SYSTEMS REASONABLY DESIGNED TO PREVENT RECURRENCE OF THE ALLEGED VIOLATIONS. ON NOVEMBER 10, 2005, THE NYSE ADVISED LEHMAN BROTHERS THAT THE HEARING PANEL'S DECISION, IN WHICH IT ACCEPTED THE STIPULATION AND CONSENT, HAD BECOME FINAL. i Disclosure 30 of 359 Reporting Source: Regulator Current Status: Final Allegations: LEHMAN BROTHERS, INC. VIOLATED ARTICLE V, SECTION 4(H) OF THE EXCHANGE CONSTITUTION, AND EXCHANGE RULE 16 BY ALLOWING ITS TRADING DESK TO ENTER A SERIES OF ODD LOT ORDERS DURING ONE TRADING DAY THROUGH THE EXCHANGE'S ELECTRONIC ORDER ENTRY SYSTEM AS A TEST OF THE CAPACITY OF THE FIRM'S OWN ORDER ENTRY SYSTEM IN A "LIVE" ENVIRONMENT. THE FIRM ALSO VIOLATED EXCHANGE RULE 320(B) AND (C) BY FAILING TO HAVE IN PLACE WRITTEN SUPERVISORY PROCEDURES, OR A SYSTEM OF CONTROLS, DESIGNED TO DETECT AND PREVENT THE ENTRY OF MULTIPLE ODD LOT ORDERS THROUGH THE EXCHANGE'S ELECTRONIC ORDER ENTRY SYSTEM WHEN CONDUCTING A TEST OF THE CAPACITY OF THE FIRM'S OWN ORDER ENTRY SYSTEM IN A "LIVE" ENVIRONMENT. Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 03/18/2005 Docket/Case Number: 04-217

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE. Sought:

Resolution: Stipulation and Consent Resolution Date: 05/23/2005 Does the order constitute a No final order based on ©2021violations FINRA. of All any rights laws reserved. or Report about LEHMAN BROTHERS INC. 86 regulations that prohibit fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: NONE. Sanction Details: FINE OF $10,000 AND A CENSURE. Regulator Statement PLEASE CONTACT THE ENFORCEMENT DEPARTMENT OF THE NASD AMERICAN STOCK EXCHANGE REGULATION DIVISION FOR FURTHER DETAILS. i Reporting Source: Firm Current Status: Final Allegations: THE AMEX ALLEGED LEHMAN VIOLATED ARTICLE V, SECTION 4(H) OF THE AMEX CONSTITUTION, AND AMEX RULE 16, BY ENTERING ODD LOT ORDERS DURING ONE TRADING DAY AS A TEST OF LEHMAN'S ORDER ENTRY SYSTEM IN A "LIVE" ENVIRONMENT. THE AMEX FURTHER ALLEGED LEHMAN VIOLATED AMEX RULE 320(B) AND (C) BY NOT HAVING APPROPRIATE PROCEDURES AND CONTROLS CONCERNING TESTING. Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 03/18/2005 Docket/Case Number: DOCKET: 04-217

Resolution: Stipulation and Consent Resolution Date: 06/01/2005 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 87 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: 10,000 FINE AGAINST LEHMAN BROTHERS INC. AND A CENSURE. LEHMAN PAID THE ENTIRE $10,000 FINE ON JUNE 27, 2005. Firm Statement PURSUANT TO A STIPULATION OF FACTS AND CONSENT TO PENALTY, ON MAY 23, 2005, THE AMEX DISCIPLINARY PANEL CHAIR DETERMINED THAT LEHMAN BROTHERS INC. VIOLATED ARTICLE V, SECTION 4(H), EXCHANGE RULE 16 AND EXCHANGE RULE 320(B) AND (C), AND IMPOSED A $10,000 FINE AND CENSURE. PURSUANT TO ARTICLE V, SECTION 2 OF THE EXCHANGE CONSTITUTION, THE DISCIPLINARY DECISION BECAME FINAL JUNE 1, 2005. i Disclosure 31 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 6955(A) - LEHMAN BROTHERS, INC. SUBMITTED TO OATS 178,451 REPORTABLE ORDER EVENTS (ROES) AFTER THE 4:00 A.M. DEADLINE THAT WERE MARKED LATE BY OATS, REPRESENTING 31% OF ALL ROES SUBMITTED BY THE FIRM TO OATS DURING THE REVIEW PERIOD. Initiated By: NASD Date Initiated: 11/09/2004 Docket/Case Number: CMS040169

Principal Product Type: Other Other Product Type(s): SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/09/2004 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct?

Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $7,500. i Reporting Source: Firm Current Status: Final Appealed To and Date Appeal N/A Filed: Allegations: NASD ALLEGED THAT DURING THE PERIOD JULY 1, 2002 THROUGH SEPTEMBER 30, 2002, LEHMAN BROTHERS INC. SUBMITTED CERTAIN OATS REPORTABLE ORDER EVENTS AFTER 4:00 A.M. IN VIOLATION OF NASD CONDUCT RULE 2110 AND MARKETPLACE RULE 6955(A). Initiated By: NASD Date Initiated: 11/09/2004 Docket/Case Number: CMS 040169

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $7,500. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/09/2004 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS INC. CONSENTED TO A CENSURE AND A FINE OF $7,500. THE FINE WAS PAID ON DECEMBER 03, 2004. Firm Statement PLEASE SEE ABOVE.

i Disclosure 32 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE SECURITIES DIVISION, COMMONWEALTH OF MASSACHUSETTS, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE GENERAL LAWS OF MASSACHUSETTS: CHAPTER 110A, UNIFORM SECURITIES ACT, ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECURITIES DIVISION, COMMONWEALTH OF MASSACHUSETTS Date Initiated: 10/29/2003 Docket/Case Number: E-2003-43

Resolution: Consent Resolution Date: 10/20/2004 Sanctions Ordered: Monetary/Fine $489,205.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM VIOLATING THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 ©2021 FINRA. All rights reserved. Report aboutMILLION LEHMAN AS BROTHERS DISGORGEMENT INC. OF COMMISSIONS AND OTHER MONIES, $25 90 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE COMMONWEALTH OF MASSACHUSETTS' PORTION WAS $489,205.00. THE PAYMENT WAS MADE ON OR ABOUT OCTOBER 21, 2003. WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM VIOLATING THE ACT IN CONNECTION WITH CERTAIN RESEARCH www.finra.org/brokercheck PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH User Guidance PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE COMMONWEALTH OF MASSACHUSETTS' PORTION WAS $489,205.00. THE PAYMENT WAS MADE ON OR ABOUT OCTOBER 21, 2003. Firm Statement SEE ABOVE. i Disclosure 33 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE DIRECTOR, SECURITIES COMMISSION, STATE OF ALABAMA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE ALABAMA SECURITIES ACT, ("ACT") AND THE RULES OF THE ALABAMA SECURITIES COMMISSION ("RULE") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: DIRECTOR, SECURITIES COMMISSION, STATE OF ALABAMA Date Initiated: 04/23/2003 Docket/Case Number: CO-2003-0010

Resolution: Consent Resolution Date: 11/04/2004 Sanctions Ordered: Monetary/Fine $342,654.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING

©2021Sanction FINRA. Details: All rights reserved. Report aboutWITHOUT LEHMAN ADMITTING BROTHERS INC. OR DENYING ANY OF THE FINDINGS OR LEGAL 91 CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM VIOLATING SECTION 8-6-3(J)7 OF THE ACT AND RULES 830-X-3-.13(1), (3) AND 830-X-2-.06(2) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF ALABAMA'S PORTION WAS $342,654.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 26, 2003. www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM VIOLATING SECTION 8-6-3(J)7 OF THE ACT AND RULES 830-X-3-.13(1), (3) AND 830-X-2-.06(2) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF ALABAMA'S PORTION WAS $342,654.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 26, 2003. Firm Statement SEE ABOVE. i Disclosure 34 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE COMMISSIONER OF SECURITIES, STATE AUDITOR'S OFFICE, STATE OF MONTANA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE SECURITIES ACT OF MONTANA ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER OF SECURITIES, STATE AUDITOR'S OFFICE, STATE OF MONTANA Date Initiated: 09/23/2003 Docket/Case Number: I 05-01-03-114

Principal Product Type: Other Other Product Type(s): EQUITY RESEARCH Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST, AND UNDERTAKING ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 92 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief CEASE AND DESIST, AND UNDERTAKING Sought:

Resolution: Consent Resolution Date: 07/29/2004 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM VIOLATING THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF MONTANA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 23, 2003. Firm Statement SEE ABOVE. i Disclosure 35 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULES 2110, 3010, AND 3370 AND SEC RULE S 10A-1 AND 10B-10 - RESPONDENT MEMBER ACCEPTED CUSTOMER SHORT SALE ORDERS IN CERTAIN SECURITIES, AND FOR EACH ORDER, FAILED TO MAKE/ANNOTATE AN AFFIRMATIVE DETERMINATION THAT THE FIRM WOULD RECEIVE DELIVERY OF THE SECURITY ON BEHALF OF THE CUSTOMER OR THAT THE FIRM COULD BORROW THE SECURITY ON BEHALF OF THE CUSTOMER FOR DELIVERY BY SETTLEMENT DATE; EFFECTED SHORT SALES IN CERTAIN SECURITIES FOR THE FIRM'S PROPRIETARY ACCOUNTS AND FAILED TO MAKE/ANNOTATE AN AFFIRMATIVE DETERMINATION THAT THE FIRM COULD BORROW THE SECURITIES OR OTHERWISE PROVIDE FOR DELIVERY OF THE SECURITIES BY SETTLEMENT DATE; FAILED TO MARK MEMORANDA OF ORDERS FOR CQS PROPREITARY TRANSACTIONS AS LONG OR SHORT; EXECUTED SHORT SALES OF CQS SECURITIES AT PRICES BELOW THE LAST SALE PRICES OF THE SECURITIES; FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THAT THE TRANSACTIONS WERE ©2021 FINRA. All rights reserved. Report aboutEXECUTED LEHMAN BROTHERSAT AN AVERAGE INC. PRICE; AND, THE FIRM'S SUPERVISORY 93 SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLIABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD, CONCERNING SEC RULES 11AC105 AND 11AC1-6, BEST EXEUCTION, AND SEC RULE 10A-1. NASD CONDUCT RULES 2110, 3010, AND 3370 AND SEC RULE S 10A-1 AND 10B-10 - RESPONDENT MEMBER ACCEPTED CUSTOMER SHORT SALE ORDERS IN CERTAIN SECURITIES, AND FOR EACH ORDER, FAILED TO MAKE/ANNOTATE AN AFFIRMATIVE DETERMINATION THAT THE FIRM WOULD RECEIVE DELIVERY OF THE SECURITY ON BEHALF OF THE CUSTOMER OR THAT THE FIRM COULD BORROW THE SECURITY ON BEHALF OF THE CUSTOMER FOR DELIVERY BY SETTLEMENT DATE; EFFECTED SHORT SALES IN CERTAIN SECURITIES FOR THE FIRM'S PROPRIETARY ACCOUNTS AND FAILED TO MAKE/ANNOTATE AN AFFIRMATIVE DETERMINATION THAT THE FIRM COULD BORROW THE SECURITIES OR OTHERWISE PROVIDE FOR DELIVERY OF THE SECURITIES www.finra.org/brokercheck BY SETTLEMENT DATE; FAILED TO MARK MEMORANDA OF ORDERS FOR User Guidance CQS PROPREITARY TRANSACTIONS AS LONG OR SHORT; EXECUTED SHORT SALES OF CQS SECURITIES AT PRICES BELOW THE LAST SALE PRICES OF THE SECURITIES; FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THAT THE TRANSACTIONS WERE EXECUTED AT AN AVERAGE PRICE; AND, THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLIABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD, CONCERNING SEC RULES 11AC105 AND 11AC1-6, BEST EXEUCTION, AND SEC RULE 10A-1. Initiated By: NASD Date Initiated: 09/20/2004 Docket/Case Number: CMS040140

Principal Product Type: Other Other Product Type(s): SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/20/2004 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $13,000.00 Other Sanctions Ordered: UNDERTAKE TO REVISE THE FIRM'S SUPERVISORY PROCEDURES WITH RESPECT TO SEC RULES 11AC105 AND 11AC1-6, BEST EXEUCTION, AND SEC RULE 10A-1. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT MEMBER CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED $13,000, AND REQUIRED TO UNDERTAKE TO REVISE THE FIRM'S SUPERVISORY PROCEDURES WITH RESPECT TO TRACE SEC RULES 11AC105 AND 11AC1-6, BEST EXEUCTION, AND SEC RULE 10A-1. i Reporting Source: Firm

Current Status: Final Allegations: IN CONNECTION WITH THE 2003 TRADING AND MARKET MAKING EXAMINATION NASD ALLEGED THAT LEHMAN FAILED TO MARK CERTAIN CUSTOMER ORDER TICKETS PROPERLY, DID NOT OBTAIN AN AFFIRMATIVE DETERMINATION FOR CERTAIN SHORT SALE ORDERS, AND DID NOT DISCLOSE THAT CERTAIN TRANSACTIONS WERE EXECUTED AT AVERAGE PRICES. IN ADDITION NASD ALLEGED THAT THE FIRM DID NOT HAVE ADEQUATE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECURITIES EXCHANGE RULES 11AC1-5, 11AC1-6 NASD RULE 3110 AND SECURITIES EXCHANGE ACT RULE 10A-1. Initiated By: NASD Date Initiated: 10/04/2004 Docket/Case Number: CMS 040140

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE, UNDERTAKING TO REVISE OUR WRITTEN SUPERVISORY Sought: PROCEDURES.

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/04/2004 Sanctions Ordered: Censure Monetary/Fine $13,000.00 Other Sanctions Ordered: UNDERTAKING TO REVISE OUR WRITTEN SUPERVISORY PROCEDURES. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS LEHMAN CONSENTED TO A CENSURE, A FINE OF $13,000 AND AN UNDERTAKING TO REVISE CERTAIN WRITTEN SUPERVISORY PROCEDURES. THE FINE WAS PAID ON 10/25/2004. Firm Statement SEE ABOVE. i Disclosure 36 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULES 2110, 3110, AND 3320, NASD MARKETPLACE RULES ©2021 FINRA. All rights reserved. Report about4613(B) LEHMAN AND BROTHERS 4632, AND INC. SEC RULE 11AC1-1, 17A-3, AND 17A-4 - 95 RESPONDENT MEMBER'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISON REASONBLY DESIGNED TO ACHIEVE COMPLIACNE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD CONCERNING CROSSING INCOMING ORDERS AGAINST NON-DISPLAYED LIMIT ORDERS AND TRADE REPORTING FOR TRADES REPORTED BY OTHER ENTITIES ON THE FIRM'S BEHALF AND FOR RISKLESS PRINCIPAL TRADES; FAILED TO REPORT THROUGH ACT THE CORRECT SYMBOL INDICATING WHETHER THE FIRM EXECUTED TRASNACTIONS IN ELIGIBLE SECURITIES IN A PRINCIPAL, RISKLESS PRINCIPAL OR AN AGENCY CAPACITY; FAILED TO SHOW THE CORRECT TIME OF EXECUTION IN THE MEMORANDA OF BROKERAGE ORDERS, FOR AN ERROR RATE OF 7.65 PERCENT; THE FIRM'S RECORDS DID NOT CONTAIN AN ORDER TICKET FOR A TRANSACTION; AND, AS A MARKET MAKER IN SECURITIES, THE FIRM FAILED TO EXECUTE ORDERS UPON PRESENTMENT AND THEREBY FAILED TO HONOR ITS PUBLISHED QUOTATION. www.finra.org/brokercheck User Guidance

Allegations: NASD CONDUCT RULES 2110, 3110, AND 3320, NASD MARKETPLACE RULES 4613(B) AND 4632, AND SEC RULE 11AC1-1, 17A-3, AND 17A-4 - RESPONDENT MEMBER'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISON REASONBLY DESIGNED TO ACHIEVE COMPLIACNE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD CONCERNING CROSSING INCOMING ORDERS AGAINST NON-DISPLAYED LIMIT ORDERS AND TRADE REPORTING FOR TRADES REPORTED BY OTHER ENTITIES ON THE FIRM'S BEHALF AND FOR RISKLESS PRINCIPAL TRADES; FAILED TO REPORT THROUGH ACT THE CORRECT SYMBOL INDICATING WHETHER THE FIRM EXECUTED TRASNACTIONS IN ELIGIBLE SECURITIES IN A PRINCIPAL, RISKLESS PRINCIPAL OR AN AGENCY CAPACITY; FAILED TO SHOW THE CORRECT TIME OF EXECUTION IN THE MEMORANDA OF BROKERAGE ORDERS, FOR AN ERROR RATE OF 7.65 PERCENT; THE FIRM'S RECORDS DID NOT CONTAIN AN ORDER TICKET FOR A TRANSACTION; AND, AS A MARKET MAKER IN SECURITIES, THE FIRM FAILED TO EXECUTE ORDERS UPON PRESENTMENT AND THEREBY FAILED TO HONOR ITS PUBLISHED QUOTATION. Initiated By: NASD Date Initiated: 07/16/2004 Docket/Case Number: CMS040098

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/16/2004 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: UNDERTAKING: TO REVISE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO CROSSING INCOMING ORDERS AGAINST NON- DISPLAYED LIMIT ORDERS AND TRADE REPORTING FOR TRADES REPORTED BY OTHER ENTITIES ON THE FIRM'S BEHALF AND FOR ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 96 RISKLESS PRINCIPAL TRADES. www.finra.org/brokercheck User Guidance UNDERTAKING: TO REVISE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO CROSSING INCOMING ORDERS AGAINST NON- DISPLAYED LIMIT ORDERS AND TRADE REPORTING FOR TRADES REPORTED BY OTHER ENTITIES ON THE FIRM'S BEHALF AND FOR RISKLESS PRINCIPAL TRADES. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED $20,000 AND REQUIRED TO UNDERTAKE TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO CROSSING INCOMING ORDERS AGAINST NON-DISPLAYED LIMIT ORDERS AND TRADE REPORTING FOR TRADES REPORTED BY OTHER ENTITIES ON THE FIRM'S BEHALF AND FOR RISKLESS PRINCIPAL TRADES WITHIN 30 BUSINESS DAYS. i Reporting Source: Firm Current Status: Final Allegations: LEHMAN AND NASD SETTLED A PROCEEDING RELATING TO THE 2002 TRADING AND MARKET MAKING EXAMINATION ("TMMS EXAM") AND AN INVESTIGATION RELATING TO ALLEGED "BACKING AWAY" FROM QUOTATIONS. WITH RESPECT TO THE TMMS EXAM, THE NASD ALLEGED VIOLATIONS REGARDING CROSSING OF ORDERS IN VIOLATION OF NASD CONDUCT RULES 2110 AND 3010, ACT REPORTING ITEMS IN VIOLATION OF NASD MARKETPLACE RULE 4632, AND CERTAIN RECORDKEEPING ITEMS REGARDING ORDER TICKETS AND CONFIRMATIONS IN VIOLATION OF SECURITIES EXCHANGE ACT RULES 17A-3, 17A-4, AND NASD CONDUCT RULE 3110. FOR THE BACKING AWAY ALLEGATION, NASD CITED INSTANCES DURING THE THIRD QUARTER OF 2002 WHERE THE FIRM ALLEGEDLY VIOLATED SECURITIES EXCHANGE ACT RULE 11AC1-1, NASD CONDUCT RULE 3320, AND NASD MARKETPLACE RULE 4613(B). Initiated By: NASD Date Initiated: 06/07/2004 Docket/Case Number: CMS040098

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief UNDERETAKING, CENSURE Sought:

Resolution Date: 07/16/2004 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: ON JULY 16, 2004 NASD ACCEPTED A STIPULATION REGARDING THIS MATTER. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO A CENSURE, A FINE OF $20,000, AND AN UNDERTAKING TO REVISE CERTAIN OF ITS WRITTEN SUPERVISORY PROCEDURES. THE FIRM EXPECTS TO PAY THE FINE SHORTLY. Firm Statement SEE ABOVE. i Disclosure 37 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE COMMISSIONER, SECURITIES DIVISION OF THE ATTORNEY GENERAL, SATE OF SOUTH CAROLINA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE SOUTH CAROLINA UNIFORM SECURITIES ACT, S.C. CODE ANN. (1976) SECTION 35-1-10 ET SEQ. ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER, SECURITIES DIVISION OF THE ATTORNEY GENERAL, STATE OF SOUTH CAROLINA Date Initiated: 06/23/2004 Docket/Case Number: 03091

Resolution: Consent Resolution Date: 06/23/2004 Sanctions Ordered: Monetary/Fine $309,130.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM VIOLATING THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF SOUTH CAROLINA'S PORTION WAS $309,130.00. THE PAYMENT WAS MADE ON OR ABOUT JUNE 24, 2004. Firm Statement SEE ABOVE. i Disclosure 38 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE COMMISSIONER OF THE DIVISION OF SECURITIES, DEPARTMENT OF JUSTICE, STATE OF DELAWARE, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE DELAWARE SECURITIES ACT, 6 DEL.C. CHAP. 73, ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER, DIVISION OF SECURITIES, DEPARTMENT OF JUSTICE, STATE OF DELAWARE Date Initiated: 09/11/2003 Docket/Case Number: C.A. NO. 03-6-7

Resolution: Consent Resolution Date: 06/18/2004 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM VIOLATING THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF DELAWARE'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 3, 2003. Firm Statement SEE ABOVE. i Disclosure 39 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE COMMISSIONER OF SECURITIES, STATE OF LOUISIANA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE LOUISIANA SECURITIES LAW, SECTIONS 701-724, IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 100 IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE COMMISSIONER www.finra.org/brokercheck OF SECURITIES, STATE OF LOUISIANA, INVESTIGATED WHETHER LEHMAN User Guidance BROTHERS VIOLATED CERTAIN PROVISIONS OF THE LOUISIANA SECURITIES LAW, SECTIONS 701-724, IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER OF SECURITIES, STATE OF LOUISIANA Date Initiated: 05/18/2004 Docket/Case Number: N/A

Resolution: Consent Resolution Date: 06/21/2004 Sanctions Ordered: Monetary/Fine $344,339.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM VIOLATING THE LOUISIANA SECURITIES LAW IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF LOUISIANA'S PORTION WAS $344,339.00. THE PAYMENT WAS MADE ON OR ABOUT MAY 18, 2004. Firm Statement SEE ABOVE. i Disclosure 40 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL ©2021 FINRA. All rights reserved. Report aboutAND LEHMAN STATE BROTHERS REGULATORS INC. AND SELF-REGULATORY ORGANIZATIONS 101 RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE COMMISSIONER, DIVISION OF SECURITIES, STATE OF COLORADO, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE COLORADO SECURITIES ACT ("ACT"), SECTIONS 11-51-101 THROUGH 803, COLORADO REVISED STATUTES (2003) AND THE COLORADO RULES AND REGULATIONS ("RULES") PROMULGATED THEREUNDER IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. www.finra.org/brokercheck User Guidance IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE COMMISSIONER, DIVISION OF SECURITIES, STATE OF COLORADO, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE COLORADO SECURITIES ACT ("ACT"), SECTIONS 11-51-101 THROUGH 803, COLORADO REVISED STATUTES (2003) AND THE COLORADO RULES AND REGULATIONS ("RULES") PROMULGATED THEREUNDER IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER, DIVISION OF SECURITIES, STATE OF COLORADO Date Initiated: 12/02/2003 Docket/Case Number: 04-L-23

Resolution: Consent Resolution Date: 04/06/2004 Sanctions Ordered: Monetary/Fine $331,417.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) PROHIBIT THE FIRM FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTION 11-51-410(1)(G) OF THE ACT AND RULE 51-4.7 PROMULGATED THEREUNDER AND SECTION 11-51-410(1)(I) OF THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF COLORADO'S PORTION WAS $331,417.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 24, 2003. Firm Statement SEE ABOVE ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 102 www.finra.org/brokercheck User Guidance

Firm Statement SEE ABOVE i Disclosure 41 of 359 Reporting Source: Firm Current Status: Final Allegations: ON APRIL 16, 2004, THE CTR SUBCOMMITTEE OF THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT BASED UPON EVIDENCE PRESENTED BY THE REGULATORY REPORTING DEPARTMENT OF THE OFFICE OF INVESTIGATIONS AND AUDITS ("OIA"), LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED CBOT REGULATIONS 332.02 AND 332.08 IN THAT IT HAD, ON CERTAIN OCCASIONS ON DECEMBER 1ST AND 2ND, 2003, FAILED TO SUBMIT INFORMATION AND/OR FAILED TO CORRECTLY KEYPUNCH INFORMATION INTO THE TRADE ENTRY SYSTEM IN ACCORDANCE WITH THE TIME PERIODS REQUIRED BY THESE RULES. Initiated By: CHICAGO BOARD OF TRADE Date Initiated: 05/03/2004 Docket/Case Number: 03-RFT-097

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Other Resolution Date: 05/03/2004 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN SUBMITTED AN OFFER OF SETTLEMENT ALONG WITH PAYMENT OF THE $2,000 FINE ON MAY 3, 2004. Firm Statement SEE ABOVE. i Disclosure 42 of 359

Reporting Source: Regulator Current Status: Final Allegations: **03/18/2004** STIPULATION OF FACTS AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING. CONSENTED TO FINDINGS: (1) VIOLATED EXCHANGE RULE 401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THE CONDUCT OF ITS BUSINESS AFFAIRS IN THAT, IN FOUR INSTANCES, THE FIRM IMPROPERLY TESTED ITS ELECTRONIC ORDER ROUTING SYSTEMS' CONNECTIVITY AND/OR FUNCTIONALITY TO THE EXCHANGE'S SYSTEMS IN A MANNER THAT WAS IN CONTRAVENTION OF EXCHANGE POLICY, AND FAILED TO FOLLOW THE APPROPRIATE ESTABLISHED TESTING PROCEDURES REQUIRED BY THE EXCHANGE. (2) VIOLATED EXCHANGE RULE 123C BY FAILING TO COMPLY WITH REQUIREMENTS GOVERNING THE ENTRY AND CANCELLATION OF MARKET-ON-CLOSE AND LIMIT-ON-CLOSE ORDERS, AND ENTERED AND/OR CANCELED OVER 245 MOC/LOC ORDERS. (3) VIOLATED EXCHANGE RULE 342(A) AND (B) BY FAILING TO REASONABLY SUPERVISE AND IMPLEMENT ADEQUATE CONTROLS OVER CERTAIN OF ITS BUSINESS ACTIVITIES BY FAILING TO HAVE ADEQUATE SYSTEMS FOR MONITORING THE TESTING OF ITS ELECTRONIC ORDER ROUTING SYSTEMS' CONNECTIVITY AND/OR FUNCTIONALITY TO THE EXCHANGE'S SYSTEMS WITH ACTUAL ORDERS DURING TRADING HOURS WHICH WAS DISRUPTIVE TO THE EXCHANGE, AND BY FAILING TO HAVE ADEQUATE CONTROLS OVER THE ENTRY AND CANCELLATION OF MOC/LOC ORDERS. THE FIRM CONSENTED TO THE IMPOSITION BY THE EXCHANGE OF THE SANCTION OF A CENSURE AND A $175,000 FINE. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 03/18/2004 Docket/Case Number: HPD#: 04-65

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 06/02/2004 Does the order constitute a No final order based on ©2021violations FINRA. of All any rights laws reserved. or Report about LEHMAN BROTHERS INC. 104 regulations that prohibit fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $175,000.00 Other Sanctions Ordered: Sanction Details: **4/27/04**DECISION 04-65 ISSUED BY NYSE HEARING PANEL. DECISION:VIOLATED EXCHANGE RULE 401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM IMPROPERLY TESTED ITS ELECTRONIC ORDER ROUTING SYSTEMS' CONNECTIVITY AND/OR FUNCTIONALITY TO THE EXCHANGE'S SYSTEMS IN CONTRAVENTION OF EXCHANGE POLICY, AND FAILED TO FOLLOW THE APPROPRIATE ESTABLISHED TESTING PROCEDURES; VIOLATED EXCHANGE RULE 123C BY FAILING TO COMPLY WITH REQUIREMENTS GOVERNING THE ENTRY AND CANCELLATION OF MARKET-ON-CLOSE AND LIMIT-ON-CLOSE ORDERS, AND ENTERED AND/OR CANCELED OVER 245 MOC/LOC ORDERS; VIOLATED EXCHANGE RULE 342(A) AND (B) BY FAILING TO REASONABLY SUPERVISE AND IMPLEMENT ADEQUATE CONTROLS BY FAILING TO HAVE ADEQUATE SYSTEMS FOR MONITORING THE TESTING OF ITS ELECTRONIC ORDER ROUTING SYSTEMS' CONNECTIVITY AND/OR FUNCTIONALITY TO THE EXCHANGE'S SYSTEMS WITH ACTUAL ORDERS DURING TRADING HOURS WHICH WAS DISRUPTIVE TO THE EXCHANGE,AND BY FAILING TO HAVE ADEQUATE CONTROLS OVER THE ENTRY AND CANCELLATION OF MOC/LOC ORDERS. CENSURE AND FINE IN THE AMOUNT OF $175,000. Regulator Statement **06/02/2004** THE DECISION IS NOW FINAL AND IS EFFECTIVE IMMEDIATELY. CONTACT: MICHELE VAN TASSEL (212) 656-5340. i Reporting Source: Firm Current Status: Final Allegations: THE NYSE ALLEGED THAT: LEHMAN BROTHERS INC. ("LEHMAN") FAILED TO ADHERE TO PRINCIPLES OF GOOD BUSINESS PRACTICE IN VIOLATION OF NYSE RULE 401 IN CONNECTION WITH ALLEGED IMPROPER TESTING OF ELECTRONIC ORDER ROUTING CONNECTIVITY AND/OR FUNCTIONALITY; VIOLATED NYSE RULE 123C RELATING TO THE ALLEGED ENTRY AND CANCELLATION OF MOC/LOC ORDERS; AND VIOLATED EXCHANGE RULES 342(A) AND 342(B) FOR ALLEGED FAILURE TO SUPERVISE AND IMPLEMENT ADEQUATE CONTROLS BY FAILING TO HAVE ADEQUATE SYSTEMS FOR MONITORING THE TESTING OF ELECTRONIC ORDER ROUTING SYSTEM ©2021 FINRA. All rights reserved. Report aboutCONNECTIVITY LEHMAN BROTHERS AND/OR INC. FUNCTIONALITY TO THE NYSE'S SYSTEMS, AND 105 FOR ALLEGED FAILURE TO HAVE ADEQUATE CONTROLS OVER THE ENTRY AND CANCELLATION OF MOC/LOC ORDERS. THE NYSE ALLEGED THAT: LEHMAN BROTHERS INC. ("LEHMAN") FAILED TO ADHERE TO PRINCIPLES OF GOOD BUSINESS PRACTICE IN VIOLATION OF NYSE RULE 401 IN CONNECTION WITH ALLEGED IMPROPER TESTING OF ELECTRONIC ORDER ROUTING CONNECTIVITY AND/OR FUNCTIONALITY; www.finra.org/brokercheck VIOLATED NYSE RULE 123C RELATING TO THE ALLEGED ENTRY AND User Guidance CANCELLATION OF MOC/LOC ORDERS; AND VIOLATED EXCHANGE RULES 342(A) AND 342(B) FOR ALLEGED FAILURE TO SUPERVISE AND IMPLEMENT ADEQUATE CONTROLS BY FAILING TO HAVE ADEQUATE SYSTEMS FOR MONITORING THE TESTING OF ELECTRONIC ORDER ROUTING SYSTEM CONNECTIVITY AND/OR FUNCTIONALITY TO THE NYSE'S SYSTEMS, AND FOR ALLEGED FAILURE TO HAVE ADEQUATE CONTROLS OVER THE ENTRY AND CANCELLATION OF MOC/LOC ORDERS. Initiated By: NEW YORK STOCK EXCHANGE, INC. Date Initiated: 06/02/2004 Docket/Case Number: HPD 04-65

Resolution: Stipulation and Consent Resolution Date: 06/02/2004 Sanctions Ordered: Censure Monetary/Fine $175,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF $175,000.00 TO BE PAID BY LEHMAN BROTHERS INC. THE DECISION BECAME FINAL ON JUNE 2, 2004 AND THE FINE WILL BE PAID WITHIN THE SUBSEQUENT 45 DAYS. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, LEHMAN ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY WITH THE NYSE ON MARCH 18, 2004 IN WHICH LEHMAN AGREED TO (I) A CENSURE AND (II) A $175,000.00 FINE. ON JUNE 2, 2004 THE NYSE ADVISED LEHMAN BROTHERS THAT THE HEARING PANEL'S DECISION, IN WHICH IT ACCEPTED THE STIPULATION AND CONSENT, HAD BECOME FINAL. i Disclosure 43 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS ©2021 FINRA. All rights reserved. Report aboutRELATING LEHMAN TOBROTHERS INVESTMENT INC. RESEARCH ACTIVITIES, THE SECURITIES 106 DIVISION, STATE OF NEW MEXICO, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE NEW MEXICO SECURITIES ACT OF 1986, SECTION 58-13B-1 ET SEQ., NMSA 1978 (THE "ACT") AND NEW MEXICO ADMINISTRATIVE CODE, SECTION 12.11.1 ET SEQ., NMAC (THE "RULES') IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. www.finra.org/brokercheck IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT User Guidance INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE SECURITIES DIVISION, STATE OF NEW MEXICO, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE NEW MEXICO SECURITIES ACT OF 1986, SECTION 58-13B-1 ET SEQ., NMSA 1978 (THE "ACT") AND NEW MEXICO ADMINISTRATIVE CODE, SECTION 12.11.1 ET SEQ., NMAC (THE "RULES') IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECURITIES DIVISION, STATE OF NEW MEXICO Date Initiated: 12/16/2003 Docket/Case Number: 03-03-029-054 (CO)

Resolution: Consent Resolution Date: 02/13/2004 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 58-13B-16. A(2)(H) AND (K) OF THE ACT AND RULES 12.11.4.10; 12.11.4.15.C AND Q; 12.11.7.8; 12.11.7.13.K AND 12.11.7.14 IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF NEW MEXICO'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT DECEMBER 18, 2003. Firm Statement SEE ABOVE.

i Disclosure 44 of 359 Reporting Source: Regulator Current Status: Final Appealed To and Date Appeal N/A Filed: Allegations: FAILED TO EXERCISE DILIGENT SUPERVISION OVER ALL THE SECURITIES ACTIVITIES OF ITS ASSOCIATED PERSONS, CREATED OR MAINTAINED INAPPROPRIATE INFLUENCES BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, VIOLATED NASD AND NYSE ETHICAL STANDARDS INCLUDING EXAGERRATED CLAIMS IN ADVERTISING WITHOUT A REASONABLE BASIS. Initiated By: IOWA Date Initiated: 04/15/2002 Docket/Case Number: C04-12-431 URL for Regulatory Action: Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): N/A Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Consent Resolution Date: 02/12/2004 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: RESPONDENT CONSENTED TO THE ENTRY OF THE ORDER WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FINDINGS OF FACT, OR CONCLUSIONS OF LAW. Sanction Details: ONE OF SEVERAL ANALYST TASK FORCE SETTLEMENTS. THE CONSENT ORDER ALSO CONTAINED SEVERAL UNDERTAKINGS BY RESPONDENT. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 108 www.finra.org/brokercheck User Guidance

Sanction Details: ONE OF SEVERAL ANALYST TASK FORCE SETTLEMENTS. THE CONSENT ORDER ALSO CONTAINED SEVERAL UNDERTAKINGS BY RESPONDENT. Regulator Statement N/A i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE SUPERINTENDENT, SECURITIES BUREAU, STATE OF IOWA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE IOWA UNIFORM SECURITIES ACT, CHAPTER 502, CODE OF IOWA (2003) IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SUPERINTENDENT, SECURITIES BUREAU, STATE OF IOWA Date Initiated: 02/12/2004 Docket/Case Number: C-04-12-431

Resolution: Consent Resolution Date: 02/12/2004 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTION 502.304(1)(G) & (J), CODE OF IOWA (2003) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A ©2021 FINRA. All rights reserved. Report aboutRELATED LEHMAN ACTION BROTHERS FILED INC. BY THE SECURITIES AND EXCHANGE 109 COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF IOWA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT FEBRUARY 12, 2004. WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL www.finra.org/brokercheck CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST User Guidance FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTION 502.304(1)(G) & (J), CODE OF IOWA (2003) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF IOWA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT FEBRUARY 12, 2004. Firm Statement SEE ABOVE. i Disclosure 45 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULE 2110 - RESPONDENT MEMBER SOLD SHARES ISSUED BY MUTUAL FUNDS WITHOUT PROVIDING CERTAIN CUSTOMERS WITH THE REDUCTION IN THE FRONT-END LOADS, OR SALES CHARGES DESCRIBED IN THE PROSPECTUSES OF THE FUNDS; FAILED TO GIVE ITS CUSTOMERS BREAKPOINT DISCOUNTS IN 59.96% OF ELIGIBLE MUTUAL FUND TRANSACTIONS IN 2001 AND 2002, THAT RESULTED IN MISSED BREAKPOINTS THAT WOULD HAVE REDUCED CUSTOMERS CHARGES BY AT LEAST $123,882 ON THEIR PURCHASES OF MUTUAL FUND SHARES WITH FRONT-END LOADS DURING THE RELEVANT PERIOD. Initiated By: NASD Date Initiated: 02/12/2004 Docket/Case Number: CAF040015

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/12/2004 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about LEHMAN BROTHERS INC. 110 fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $123,882.00 Other Sanctions Ordered: UNDERTAKINGS Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS, INC. CONSENTED TO THE FINDING OF THE ALLEGATIONS AND TO THE FOLLOWING SANCTIONS: CENSURED AND FINED $123,882.00, AND REQUIRED TO PROVIDE WRITTEN NOTIFICATION TO EACH CUSTOMER WHO PURCHASED FRONT-END LOAD MUTUAL FUNDS THROUGH THE FIRM FROM JANUARY 1, 1999 THROUGH NOVEMBER 3, 2003 THAT THE FIRM EXPERIENCED A PROBLEM DELIVERING BREAKPOINT DISCOUNTS AND THAT AS A RESULT, THE CUSTOMER MAY BE ENTITLED TO A REFUND; PERFORM A TRADE-BY-TRADE ANALYSIS OF ALL FRONT-END LOAD MUTUAL FUND PURCHASES OF $2,500 OR MORE AND ALL OVERCHARGES IDENTIFIED REFUNDED BY MARCH 31, 2004; PROVIDE REFUNDS TO ALL CUSTOMERS WHO DID NOT RECEIVE ALL APPLICABLE BREAKPOINT DISCOUNTS AS DESCRIBED IN NTM 03-47; PROVIDE NASD A REPORT ON RESPONDENT'S PROGRAM BY 4/16/04; AND NOT LATER THAN SIX MONTHS AFTER THE DATE OF THIS ORDER, RESPONDENT'S CHIEF EXECUTIVE OFFICER OR ANOTHER SENIOR EXEUCTIVE OFFICER SHALL CERTIFY IN WRITING TO NASD THAT RESPONDENT HAS IMPLEMENTED PROCEDURES AND A SYSTEM FOR IDNETIFYING SUCH PROCEDURES THAT CAN REASONABLY BE EXPECTED TO PREVENT AND DETECT FAILURES TO PROVIDE BREAKPOINT DISCOUNTS FOR WHICH CUSTOMERS ARE ELIGIBLE ON PURCHASES OF FRONT-END LOAD MUTUAL FUNDS. i Reporting Source: Firm Current Status: Final Allegations: ACCORDING TO THE NASD'S LETTER OF ACCEPTANCE, WAIVER AND CONSENT ISSUED ON JANUARY 7, 2004, DURING 2001 AND 2002, LEHMAN SOLD MUTUAL FUND SHARES WITHOUT PROVIDING CERTAIN CUSTOMERS THE APPROPRIATE "BREAKPOINT" DISCOUNT, OR REDUCTION IN THE FRONT-END LOAD OR SALES CHARGE. THE NASD ESTIMATED THAT LEHMAN FAILED TO GIVE CUSTOMERS BREAKPOINT DISCOUNTS TOTALING AT LEAST $123,882 DURING THIS PERIOD. BY FAILING TO GIVE CERTAIN CUSTOMERS THE BENEFIT OF THE APPLICABLE BREAKPOINT DISCOUNTS, AND BY FAILING TO DISCLOSE TO THOSE CUSTOMERS THAT ©2021 FINRA. All rights reserved. Report aboutTHEY LEHMAN WERE BROTHERS NOT RECEIVING INC. THE BENEFIT OF THE APPLICABLE 111 BREAKPOINT DISCOUNTS, LEHMAN VIOLATED NASD CONDUCT RULE 2110. ACCORDING TO THE NASD'S LETTER OF ACCEPTANCE, WAIVER AND CONSENT ISSUED ON JANUARY 7, 2004, DURING 2001 AND 2002, LEHMAN SOLD MUTUAL FUND SHARES WITHOUT PROVIDING CERTAIN CUSTOMERS THE APPROPRIATE "BREAKPOINT" DISCOUNT, OR REDUCTION IN THE FRONT-END LOAD OR SALES CHARGE. THE NASD ESTIMATED THAT www.finra.org/brokercheck LEHMAN FAILED TO GIVE CUSTOMERS BREAKPOINT DISCOUNTS User Guidance TOTALING AT LEAST $123,882 DURING THIS PERIOD. BY FAILING TO GIVE CERTAIN CUSTOMERS THE BENEFIT OF THE APPLICABLE BREAKPOINT DISCOUNTS, AND BY FAILING TO DISCLOSE TO THOSE CUSTOMERS THAT THEY WERE NOT RECEIVING THE BENEFIT OF THE APPLICABLE BREAKPOINT DISCOUNTS, LEHMAN VIOLATED NASD CONDUCT RULE 2110. Initiated By: NASD Date Initiated: 02/12/2004 Docket/Case Number: CAF040015

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE AND UNDERTAKING Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/12/2004 Sanctions Ordered: Censure Monetary/Fine $123,882.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: LEHMAN WILL PAY THE TOTAL FINE OF $123,882.00 Firm Statement ON FEBRUARY 12, 2004, THE NAC ACCEPTED THE AWC. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO A CENSURE, A $123,882.00 FINE, AN UNDERTAKING TO IDENTIFY, NOTIFY AND PROVIDE RESTITUTION TO CERTAIN CUSTOMERS WHO DID NOT RECEIVE APPLICABLE BREAKPOINT DISCOUNTS, IMPLEMENT PROCEDURES TO DETECT AND PREVENT FUTURE FAILURES TO PROVIDE BREAKPOINT DISCOUNTS, AND PROVIDE A REPORT TO THE NASD AS TO THE STATUS OF THE UNDERTAKING. i Disclosure 46 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE DEPARTMENT OF STATE, BUREAU OF SECURITIES REGULATION, STATE OF NEW HAMPSHIRE, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED ©2021 FINRA. All rights reserved. Report aboutCERTAIN LEHMAN PROVISIONS BROTHERS INC. OF THE NEW HAMPSHIRE SECURITIES ACT, 112 REVISED STATUTES ANNOTATED ("RSA") 421-B IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL www.finra.org/brokercheck AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS User Guidance RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE DEPARTMENT OF STATE, BUREAU OF SECURITIES REGULATION, STATE OF NEW HAMPSHIRE, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE NEW HAMPSHIRE SECURITIES ACT, REVISED STATUTES ANNOTATED ("RSA") 421-B IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: DEPARTMENT OF STATE, BUREAU OF SECURITIES REGULATION, STATE OF NEW HAMPSHIRE Date Initiated: 01/21/2004 Docket/Case Number: N/A

Resolution: Consent Resolution Date: 01/21/2004 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF RSA 421-B:10(I)(B)(10) AND RSA 421-B:10(I)(B)(7) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF NEW HAMPSHIRE'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT JANUARY 7, 2004. Firm Statement SEE ABOVE. i Disclosure 47 of 359 Reporting Source: Firm ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 113 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE DEPARTMENT OF COMMERCE, DIVISION OF SECURITIES, STATE OF OHIO, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF CHAPTER 1707 OF THE OHIO REVISED CODE IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: DEPARTMENT OF COMMERCE, DIVISION OF SECURITIES, STATE OF OHIO Date Initiated: 01/20/2004 Docket/Case Number: N/A

Resolution: Consent Resolution Date: 01/20/2004 Sanctions Ordered: Monetary/Fine $874,773.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF CHAPTER 1707 OF THE OHIO REVISED CODE IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF OHIO'S PORTION WAS $874,773.00. THE ©2021 FINRA. All rights reserved. Report aboutPAYMENT LEHMAN WAS BROTHERS MADE INC. ON OR ABOUT DECEMBER 7, 2003. 114 WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF CHAPTER 1707 OF THE OHIO REVISED CODE IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 www.finra.org/brokercheck MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 User Guidance MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF OHIO'S PORTION WAS $874,773.00. THE PAYMENT WAS MADE ON OR ABOUT DECEMBER 7, 2003. Firm Statement SEE ABOVE. i Disclosure 48 of 359 Reporting Source: Regulator Current Status: Final Allegations: RESEARCH ANALYST CONFLICTS OF INTEREST Initiated By: UTAH DIVISION OF SECURITIES Date Initiated: 11/18/2003 Docket/Case Number: SD-03-0044 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief MONETARY PENALTY Sought:

Resolution: Consent Resolution Date: 11/18/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CEASE & DESIST AND PAY $250,000.00 TO THE SECURITIES INVESTOR EDUCATION AND TRAINING FUND Regulator Statement FOR MORE INFORMATION, PLEASE VISIT THE DIVISION'S WEB SITE AT: HTTP://WWW.SECURITIES.STATE.UT.US/ACTIONSEVENTS.ASP? DOCKET+NUMBER=SD%2D03%2D0044 i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL ©2021 FINRA. All rights reserved. Report aboutAND LEHMAN STATE BROTHERS REGULATORS INC. AND SELF-REGULATORY ORGANIZATIONS 115 RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE DEPARTMENT OF COMMERCE, DIVISION OF SECURITIES, STATE OF UTAH, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE UTAH UNIFORM SECURITIES ACT IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. www.finra.org/brokercheck User Guidance

IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE DEPARTMENT OF COMMERCE, DIVISION OF SECURITIES, STATE OF UTAH, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE UTAH UNIFORM SECURITIES ACT IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: DEPARTMENT OF COMMERCE, DIVISION OF SECURITIES, STATE OF UTAH Date Initiated: 11/18/2003 Docket/Case Number: SD-03-0044

Resolution: Consent Resolution Date: 01/21/2004 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF THE UTAH UNIFORM SECURITIES ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF UTAH'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 10, 2003. Firm Statement SEE ABOVE.

i Disclosure 49 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE SECRETARY OF STATE, SECURITIES DIVISION, STATE OF NORTH CAROLINA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE NORTH CAROLINA SECURITIES ACT, NORTH CAROLINA GENERAL STATUTES ("N.C.G.S.") §78A-39 IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECRETARY OF STATE, SECURITIES DIVISION, STATE OF NORTH CAROLINA Date Initiated: 01/08/2004 Docket/Case Number: 03-010-IG

Resolution: Consent Resolution Date: 01/08/2004 Sanctions Ordered: Monetary/Fine $620,209.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF N.C.G.S. §78A-39(A)(2)(G) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN ©2021 FINRA. All rights reserved. Report aboutWHICH, LEHMAN AMONG BROTHERS OTHER INC. THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 117 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF NORTH CAROLINA'S PORTION WAS $620,209.00. THE PAYMENT WAS MADE ON OR ABOUT JANUARY 7, 2004. WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST www.finra.org/brokercheck FROM ENGAGING IN ANY ACTS IN VIOLATION OF N.C.G.S. §78A-39(A)(2)(G) User Guidance IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF NORTH CAROLINA'S PORTION WAS $620,209.00. THE PAYMENT WAS MADE ON OR ABOUT JANUARY 7, 2004. Firm Statement SEE ABOVE. i Disclosure 50 of 359 Reporting Source: Regulator Current Status: Final Allegations: THIS ACTION IS IN CONNECTION WITH THE GLOBAL ANALYST SETTLEMENT WHICH INCORPORATED THE FINAL JUDGMENT OF THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, CIVIL ACTION NO. 03 CIV. 2940 (WHP) ENTERED OCTOBER 31, 2003. Initiated By: PA SECURITIES COMMISSION CONTACT: G. PHILIP RUTLEDGE (717) 787-8059 Date Initiated: 12/29/2003 Docket/Case Number: 2003-04-44 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): SECURITIES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RESPONDENT LEHMAN BROTHERS INC., PAID A $946,269.00 Sought: ADMINISTRATIVE ASSESSMENT.

Resolution: Settled Resolution Date: 12/29/2003 Sanctions Ordered: Monetary/Fine $946,269.00 Other Sanctions Ordered: Sanction Details: RESPONDENT LEHMAN BROTHERS INC., PAID A $946,269.00 ADMINISTRATIVE ASSESSMENT.

i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE SECURITIES COMMISSION, COMMONWEALTH OF PENNSYLVANIA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF PENNSYLVANIA SECURITIES ACT OF 1972 (70 P. S. § § 1-101—1-704) ("1972 ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECURITIES COMMISSION, COMMONWEALTH OF PENNSYLVANIA Date Initiated: 12/29/2003 Docket/Case Number: 2003-04-44

Resolution: Consent Resolution Date: 12/29/2003 Sanctions Ordered: Monetary/Fine $946,269.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF THE 1972 ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF ©2021 FINRA. All rights reserved. Report aboutCOMMISSIONS LEHMAN BROTHERS AND OTHER INC. MONIES, $25 MILLION OVER FIVE YEARS FOR 119 PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE COMMONWEALTH OF PENNSYLVANIA'S PORTION WAS $946,269.00. THE PAYMENT WAS MADE ON OR ABOUT DECEMBER 18, 2003. WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF THE 1972 ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY www.finra.org/brokercheck AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED User Guidance BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE COMMONWEALTH OF PENNSYLVANIA'S PORTION WAS $946,269.00. THE PAYMENT WAS MADE ON OR ABOUT DECEMBER 18, 2003. Firm Statement SEE ABOVE i Disclosure 51 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE COMMISSIONER, DEPARTMENT OF COMMERCE, STATE OF MINNESOTA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF MINNESOTA STATUTES CHAPTER 80A (2002) AND MINNESOTA RULES CHAPTER 2875 (2001) IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER, DEPARTMENT OF COMMERCE, STATE OF MINNESOTA Date Initiated: 12/30/2003 Docket/Case Number: SE2304868/BJP

Resolution: Consent Resolution Date: 12/30/2003 Sanctions Ordered: Monetary/Fine $379,051.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL ©2021 FINRA. All rights reserved. Report aboutCONCLUSIONS, LEHMAN BROTHERS LEHMAN INC. BROTHERS AGREED TO ( I ) CEASE AND DESIST 120 FROM ENGAGING IN ANY ACTS IN VIOLATION OF MINNESOTA STATUTES CHAPTER 80A.07, SUBDIVISIONS 1(7) AND 1(10) (2002) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF MINNESOTA'S PORTION WAS $379,051.00. THE PAYMENT WAS MADE ON OR ABOUT DECEMBER 18, 2003. www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF MINNESOTA STATUTES CHAPTER 80A.07, SUBDIVISIONS 1(7) AND 1(10) (2002) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF MINNESOTA'S PORTION WAS $379,051.00. THE PAYMENT WAS MADE ON OR ABOUT DECEMBER 18, 2003. Firm Statement SEE ABOVE. i Disclosure 52 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE SECURITIES DIVISION, STATE OF WEST VIRGINIA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF WEST VIRGINIA UNIFORM SECURITIES ACT, WEST VIRGINIA CODE SECTIONS 32-1-101 ET SEQ., ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECURITIES DIVISION, STATE OF WEST VIRGINIA Date Initiated: 12/16/2003 Docket/Case Number: MAT NO.: E03-1348, ADM. ORD NO.: CO-2003

Principal Product Type: Other Other Product Type(s): EQUITY RESEARCH Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST, AND UNDERTAKING Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 121 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief CEASE AND DESIST, AND UNDERTAKING Sought:

Resolution: Consent Resolution Date: 12/16/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF WEST VIRGINIA CODE SECTION 032-2-204(A)(2)(G) AND (J) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF WEST VIRGINIA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT DECEMBER 18, 2003. i Disclosure 53 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE DEPARTMENT OF CORPORATIONS, STATE OF CALIFORNIA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE CORPORATE SECURITIES LAW OF 1968 AND CALIFORNIA CORPORATIONS CODE SECTIONS 25000 ET SEQ. IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER, DEPARTMENT OF CORPORATIONS, STATE OF CALIFORNIA Date Initiated: 12/15/2003

Docket/Case Number: N/A

Resolution: Consent Resolution Date: 12/15/2003 Sanctions Ordered: Monetary/Fine $2,609,851.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF THE CORPORATE SECURITIES LAW OF 1968 AND CALIFORNIA CORPORATIONS CODE SECTIONS 25000 ET SEQ, IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF CALIFORNIA'S PORTION WAS $2,609,851.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 13, 2003. Firm Statement SEE ABOVE i Disclosure 54 of 359 Reporting Source: Regulator Current Status: Final Allegations: COMMISSION RULES 21 VAC 5-20-260 B AND 21 VAC 5-20-280 E 12 WERE VIOLATED. CONTACT THE UNDERSIGNED FOR FURTHER INFORMATION ABOUT THE CONCLUSIONS OF LAW. Initiated By: VIRGINIA - DIVISIO OF SECURITIES Date Initiated: 12/11/2003 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 123 www.finra.org/brokercheck User Guidance

Date Initiated: 12/11/2003 Docket/Case Number: SEC-2003-00018 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): CONTACT THE UNDERSIGNED FOR FURTHER INFORMATION. Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 12/11/2003 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $545,408.00 Other Sanctions Ordered: CONTACT THE UNDERSIGNED FOR FURTHER INFORMATION Sanction Details: CONTACT THE UNDERSIGNED FOR FURTHER INFORMATION Regulator Statement $545,408.00 WAS RECEIVED AS PART OF THE SETTLEMENT AGREEMENT LEHMAN BROTHERS, INC. ENTERED INTO WITH ALL FIFTY STATES, THE DISTRICT OF COLUMBIA AND THE COMMONWEALTH OF PUERTO RICO, THROUGH A COMMITTEE OF THE NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION ("NASAA") JURISDICTION REPORTING INCIDENT: VIRGINIA, STATE CORPORATION COMMISSION, DIVISION OF SECURITIES & RETAIL FRANCHISING. CONTACT KEVIN M. FURR AT 804-371- 9081 FOR MORE INFORMATION. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE STATE CORPORATION COMMISSION, COMMONWEALTH OF VIRGINIA, ©2021 FINRA. All rights reserved. Report aboutINVESTIGATED LEHMAN BROTHERS WHETHER INC. LEHMAN BROTHERS VIOLATED CERTAIN 124 PROVISIONS OF THE VIRGINIA SECURITIES ACT ("ACT"), SECTIONS 13.1- 501 ET SEQ OF THE CODE OF VIRGINIA AND THE VIRGINIA ADMINISTRATIVE CODE ("VAC"), IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT www.finra.org/brokercheck INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED User Guidance STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE STATE CORPORATION COMMISSION, COMMONWEALTH OF VIRGINIA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE VIRGINIA SECURITIES ACT ("ACT"), SECTIONS 13.1- 501 ET SEQ OF THE CODE OF VIRGINIA AND THE VIRGINIA ADMINISTRATIVE CODE ("VAC"), IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: STATE CORPORATION COMMISSION, COMMONWEALTH OF VIRGINIA Date Initiated: 12/11/2003 Docket/Case Number: SEC-2003-00018

Resolution: Consent Resolution Date: 12/11/2003 Sanctions Ordered: Monetary/Fine $545,408.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF 21 VAC 5-20-280(E)(12) AND 21 VAC 5-20-260, IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE COMMONWEALTH OF VIRGINIA'S PORTION WAS $545,408.00. THE PAYMENT WAS MADE ON OR ABOUT DECEMBER 2, 2003. Firm Statement SEE ABOVE. i Disclosure 55 of 359 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 125 www.finra.org/brokercheck User Guidance

Disclosure 55 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE OFFICE OF THE COMMISSIONER OF FINANCIAL INSTITUTIONS, COMMONWEALTH OF PUERTO RICO, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF ACT NO. 60 OF JUNE 18, 1963, AS AMENDED, AND KNOWN AS THE PUERTO RICO UNIFORM SECURITIES ACT ("ACT NO. 60") AND REGULATION 6078 OF JANUARY 19, 2000, REGULATION UNDER THE UNIFORM SECURITIES ACT OF PUERTO RICO ("REGULATION 6078") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: OFFICE OF THE COMMISSIONER OF FINANCIAL INSTITUTIONS, COMMONWEALTH OF PUERTO RICO Date Initiated: 11/13/2003 Docket/Case Number: C 03-V-011

Resolution: Consent Resolution Date: 12/12/2003 Sanctions Ordered: Monetary/Fine $293,457.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF THE SECTION 204(A)(G) AND (J) OF ACT NO. 60 AND SECTIONS 25.4.4, 26.1 AND 28.2 OF REGULATION 6078 IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH ©2021 FINRA. All rights reserved. Report aboutPRACTICES LEHMAN BROTHERS AND ( III )INC. PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A 126 RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE COMMONWEALTH OF PUERTO RICO'S PORTION WAS $293,457.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 24, 2003. WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL www.finra.org/brokercheck CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST User Guidance FROM ENGAGING IN ANY ACTS IN VIOLATION OF THE SECTION 204(A)(G) AND (J) OF ACT NO. 60 AND SECTIONS 25.4.4, 26.1 AND 28.2 OF REGULATION 6078 IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE COMMONWEALTH OF PUERTO RICO'S PORTION WAS $293,457.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 24, 2003. Firm Statement SEE ABOVE i Disclosure 56 of 359 Reporting Source: Regulator Current Status: Final Allegations: RESPONDENT ENGAGED IN UNETHICAL AND DISHONEST PRACTICES IN CONNECTION WITH THE OFFER AND SALE OF SECURITIES. RESPONDENT ALSO FAILED REASONABLY TO SUPERVISE THEIR EMPLOYEES. ALL ALLEGATIONS RELATED TO PRACTICES OF THE RESEARCH AND INVESTMENT BANKING SECTIONS OF THE RESPONDENT'S FIRM. Initiated By: OREGON DIVISION OF FINANCE AND CORPORATE SECURITIES Date Initiated: 07/24/2003 Docket/Case Number: S-03-0030 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): COMMON STOCK Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST Sought:

Resolution: Consent Resolution Date: 12/04/2003 Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or ©2021deceptive FINRA. conduct? All rights reserved. Report about LEHMAN BROTHERS INC. 127 www.finra.org/brokercheck User Guidance

Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $263,622.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: NO PORTION OF PENALTY SUSPENDED Regulator Statement RESEARCH ANALYSTS AT THE FIRM WERE SUBJECTED TO PRESSURES FROM THE INVESTMENT BANKING SECTION OF THE FIRM TO RATE STOCKS FAVORABLY SO AS TO GAIN THE INVESTMENT BANKING BUSINESS OF THE FIRMS ISSUING STOCKS. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE DIRECTOR OF THE DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, STATE OF OREGON, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE OREGON REVISED STATUTES ("ORS"), CHAPTER 59 AND THE OREGON ADMINISTRATIVE RULES ("OAR"), CHAPTER 441 IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: DIRECTOR, DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, STATE OF OREGON Date Initiated: 12/04/2003 Docket/Case Number: S-03-0030

Other Sanction(s)/Relief CEASE AND DESIST, AND UNDERTAKING Sought:

Resolution: Consent Resolution Date: 12/04/2003 Sanctions Ordered: Monetary/Fine $263,622.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF ORS 59.205(13), 59.205(2) AS IT RELATES TO DISHONEST AND UNETHICAL PRACTICES AND OAR 441- 205-0210 IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF OREGON'S PORTION WAS $ 263,622.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 24, 2003. Firm Statement SEE ABOVE. i Disclosure 57 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE SECURITIES DEPARTMENT, SECRETARY OF STATE, STATE OF ILLINOIS INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE ILLINOIS SECURITIES ACT OF 1953, AS AMENDED, [815 ILCS 5/1 ET SEQ.] (THE "ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECURITIES DEPARTMENT, SECRETARY OF STATE, STATE OF ILLINOIS ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 129 www.finra.org/brokercheck User Guidance

Date Initiated: 12/04/2003 Docket/Case Number: 0300909

Resolution: Consent Resolution Date: 12/04/2003 Sanctions Ordered: Monetary/Fine $956,921.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTION 8.E(1)(B) AS IT RELATES TO UNETHICAL BUSINESS PRACTICES AND SECTION 8.E(1)(E)(IV) OF THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF ILLINOIS' PORTION WAS $ 956,921.00. THE PAYMENT WAS MADE ON OR ABOUT DECEMBER 8, 2003. Firm Statement SEE ABOVE. i Disclosure 58 of 359 Reporting Source: Regulator Current Status: Final Allegations: SEC TOOK ACTION AGAINST THE FIRM ALLEGING CONFLICT OF INTEREST ARISING FROM THE FACT THAT THE RESEARCH ANALYSTS WERE PRESSURED AND SUBJECT TO INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKERS EMPLOYED BY THE FIRM TO EXAGGERATE ©2021 FINRA. All rights reserved. Report aboutRESEARCH LEHMAN BROTHERS FINDINGS INC. IN ORDER TO OBTAIN INVESTMENT BANKING 130 BUSINESS. THE FIRM FAILED TO MAINTAIN APPROPRIATE SUPERVISION OVER ITS RESEARCH AND INVESTMENT BANKING OPERATIONS www.finra.org/brokercheck User Guidance SEC TOOK ACTION AGAINST THE FIRM ALLEGING CONFLICT OF INTEREST ARISING FROM THE FACT THAT THE RESEARCH ANALYSTS WERE PRESSURED AND SUBJECT TO INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKERS EMPLOYED BY THE FIRM TO EXAGGERATE RESEARCH FINDINGS IN ORDER TO OBTAIN INVESTMENT BANKING BUSINESS. THE FIRM FAILED TO MAINTAIN APPROPRIATE SUPERVISION OVER ITS RESEARCH AND INVESTMENT BANKING OPERATIONS Initiated By: MICHIGAN Date Initiated: 09/23/2003 Docket/Case Number: 03-037-M URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): RESEARCH Principal Sanction(s)/Relief Injunction Sought: Other Sanction(s)/Relief CIVIL MONETARY PENALTY; DISGORGEMENT Sought:

Resolution: Consent Resolution Date: 09/23/2003 Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Cease and Desist/Injunction Other Sanctions Ordered: COMPLIANCE WITH THE NASD AND NYSE RULES GOVERNING ETHICAL PRACTICES AND CONDUCT. CEASE AND DESIST FROM ENGAGING IN ACTS OR PRACTICES THAT VIOLATE THE MICHIGAN UNIFORM SECURITIES ACT. Sanction Details: PAYMENT OF THE $80,000,000 AS ORDERED IN THE SEC JUDGMENT IN ACCORDANCE WITH THAT JUDGMENT, AND COMPLIANCE WITH THE UNDERTAKINGS LISTED IN THAT JUDGMENT. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS ©2021 FINRA. All rights reserved. Report aboutRELATING LEHMAN TOBROTHERS INVESTMENT INC. RESEARCH ACTIVITIES THE COMMISSIONER, 131 OFFICE OF FINANCIAL AND INSURANCE SERVICES ("OFIS"), STATE OF MICHIGAN, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE OFIS UNIFORM SECURITIES ACT, ("ACT"), MICHIGAN COMPILED LAWS 451.501 ET SEQ. IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. www.finra.org/brokercheck IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT User Guidance INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE COMMISSIONER, OFFICE OF FINANCIAL AND INSURANCE SERVICES ("OFIS"), STATE OF MICHIGAN, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE OFIS UNIFORM SECURITIES ACT, ("ACT"), MICHIGAN COMPILED LAWS 451.501 ET SEQ. IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER, OFFICE OF FINANCIAL AND INSURANCE SERVICES, STATE OF MICHIGAN Date Initiated: 10/03/2003 Docket/Case Number: ADMINISTRATIVE ORDER NO. 03-037-M

Resolution: Consent Resolution Date: 10/03/2003 Sanctions Ordered: Monetary/Fine $765,768.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF MCL 451.604(A)(1)(G) AND 451.604(A)(2) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF MICHIGAN'S PORTION WAS $765,768.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 5, 2003. Firm Statement SEE ABOVE.

i Disclosure 59 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE, DIRECTOR, DEPARTMENT OF BANKING AND FINANCE, STATE OF NEBRASKA INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE SECURITIES ACT OF NEBRASKA, NEB. REV. STAT. SECTIONS 8-1101 TO 8-1124 (REISSUE 1997; CUM. SUPP.2002) ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: DIRECTOR, DEPARTMENT OF BANKING AND FINANCE, STATE OF NEBRASKA Date Initiated: 11/17/2003 Docket/Case Number: NA

Resolution: Consent Resolution Date: 11/17/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 8-1103 (A)(VII) AND (XI) OF THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A ©2021 FINRA. All rights reserved. Report aboutRELATED LEHMAN ACTION BROTHERS FILED INC. BY THE SECURITIES AND EXCHANGE 133 COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF NEBRASKA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 10, 2003. WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL www.finra.org/brokercheck CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST User Guidance FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 8-1103 (A)(VII) AND (XI) OF THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF NEBRASKA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 10, 2003. Firm Statement SEE ABOVE. i Disclosure 60 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE COMMISSIONER, DIVISION OF SECURITIES, STATE OF MARYLAND, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE MARYLAND SECURITIES ACT, CORPORATIONS AND ASSOCIATIONS ARTICLE, TITLE 11, ANNOTATED CODE OF MARYLAND (1999 REPL. VOL. & SUPP. 2002)("MARYLAND SECURITIES ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER, DIVISION OF SECURITIES, STATE OF MARYLAND Date Initiated: 11/21/2003 Docket/Case Number: FILE NO. 2002-0892

Resolution: Consent Resolution Date: 11/21/2003

Sanctions Ordered: Monetary/Fine $408,100.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF THE MARYLAND SECURITIES ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF MARYLAND'S PORTION WAS $408,100.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 11, 2003. Firm Statement SEE ABOVE. i Disclosure 61 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE, DIRECTOR, DIVISION OF SECURITIES, STATE OF SOUTH DAKOTA INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE SOUTH DAKOTA UNIFORM SECURITIES ACT, CHAPTER 47-31A, IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: DIRECTOR, DIVISION OF SECURITIES, STATE OF SOUTH DAKOTA Date Initiated: 11/07/2003 Docket/Case Number: ADMINISTRATIVE CASE# 648

Principal Product Type: Other Other Product Type(s): EQUITY RESEARCH Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 135 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST, AND UNDERTAKING Sought:

Resolution: Consent Resolution Date: 11/07/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SOUTH DAKOTA CODIFIED LAW SECTIONS 47-31A-204(A)(2)(G) AND (J) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF SOUTH DAKOTA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 10, 2003. Firm Statement SEE ABOVE. i Disclosure 62 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE, ADMINISTRATOR, SECRETARY OF STATE, SECURITIES DIVISION, STATE OF NEVADA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE NEVADA SECURITIES ACT, NEVADA REVISED STATUTES ("NRS") CHAPTER 90, AND THE NEVADA ADMINISTRATIVE CODE ("NAC") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING ©2021 FINRA. All rights reserved. Report aboutDEPARTMENTS. LEHMAN BROTHERS INC. 136 IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE, ADMINISTRATOR, SECRETARY OF STATE, SECURITIES DIVISION, STATE OF NEVADA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN www.finra.org/brokercheck PROVISIONS OF THE NEVADA SECURITIES ACT, NEVADA REVISED User Guidance STATUTES ("NRS") CHAPTER 90, AND THE NEVADA ADMINISTRATIVE CODE ("NAC") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: ADMINISTRATOR, SECRETARY OF STATE, SECURITIES DIVISION, STATE OF NEVADA Date Initiated: 11/25/2003 Docket/Case Number: FILE NO.: I03-185

Resolution: Consent Resolution Date: 11/25/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF NRS 90.420(1)(H), NRS 90.420(1)(K), AND NAC 90.327(1) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF NEVADA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 13, 2003. Firm Statement SEE ABOVE. i Disclosure 63 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT ©2021 FINRA. All rights reserved. Report aboutINVOLVING LEHMAN BROTHERSSEVERAL INC. OF THE LEADING SECURITIES FIRMS IN THE UNITED 137 STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE, ADMINISTRATOR OF THE DIVISION OF SECURITIES, STATE OF WISCONSIN, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE WISCONSIN UNIFORM SECURITIES LAW, CH 551, WIS. STATS., IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. www.finra.org/brokercheck User Guidance

Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE, ADMINISTRATOR OF THE DIVISION OF SECURITIES, STATE OF WISCONSIN, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE WISCONSIN UNIFORM SECURITIES LAW, CH 551, WIS. STATS., IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: ADMINISTRATOR, DIVISION OF SECURITIES, STATE OF WISCONSIN Date Initiated: 10/23/2003 Docket/Case Number: FILE NO.: S-03103(LX)

Resolution: Consent Resolution Date: 10/23/2003 Sanctions Ordered: Monetary/Fine $413,277.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF WISCONSIN UNIFORM SECURITIES LAW, CH 551, WIS. STATS. IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF WISCONSIN'S PORTION WAS $413,277.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 26, 2003. Firm Statement SEE ABOVE. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 138 www.finra.org/brokercheck User Guidance

Firm Statement SEE ABOVE. i Disclosure 64 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE COMMISSIONER OF THE DEPARTMENT OF INSURANCE AND SECURITIES REGULATION, DISTRICT OF COLUMBIA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE SECURITIES ACT OF 2000, D.C. OFFICIAL CODE SECTIONS 31-5601.01 ET SEQ. ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER OF THE DEPARTMENT OF INSURANCE AND SECURITIES REGULATION, DISTRICT OF COLUMBIA Date Initiated: 11/12/2003 Docket/Case Number: SEC. CO 03-09

Resolution: Consent Resolution Date: 11/12/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 31-5602. 07(A)(9) AND (12) OF THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A ©2021 FINRA. All rights reserved. Report aboutRELATED LEHMAN ACTION BROTHERS FILED INC. BY THE SECURITIES AND EXCHANGE 139 COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE DISTRICT OF COLUMBIA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 4, 2003. WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL www.finra.org/brokercheck CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST User Guidance FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 31-5602. 07(A)(9) AND (12) OF THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE DISTRICT OF COLUMBIA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 4, 2003. Firm Statement SEE ABOVE. i Disclosure 65 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE, COMMISSIONER OF THE SECURITIES DEPARTMENT, STATE OF ARKANSAS, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE ARKANSAS SECURITIES ACT, ARKANSAS CODE ANNOTATED, SECTION 23- 42-101 ET. SEQ. ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER OF SECURITIES DEPARTMENT, STATE OF ARKANSAS Date Initiated: 10/01/2003 Docket/Case Number: S-03-016-03-C004

Resolution: Consent Resolution Date: 11/12/2003 Sanctions Ordered: Monetary/Fine $250,000.00 ©2021 FINRA. All rights reserved. Report aboutCease LEHMAN and Desist/Injunction BROTHERS INC. 140 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 23-42- 308(A)(2)(G) AND 23-42-308(A)(2)(J) OF THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF ARKANSAS' PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 26, 2003. Firm Statement SEE ABOVE. i Disclosure 66 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE, SECURITIES ADMINISTRATOR, DEPARTMENT OF FINANCIAL INSTITUTIONS, STATE OF WASHINGTON, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE SECURITIES ACT OF WASHINGTON, REVISED CODE OF WASHINGTON, CH 21.20 ET. SEQ. ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECURITIES ADMINISTRATOR, DEPARTMENT OF FINANCIAL INSTITUTIONS, STATE OF WASHINGTON Date Initiated: 11/07/2003 Docket/Case Number: CASE NO.: S-03-093

Other Product Type(s): EQUITY RESEARCH Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST, AND UNDERTAKING Sought:

Resolution: Consent Resolution Date: 11/07/2003 Sanctions Ordered: Monetary/Fine $454,149.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF WASHINGTON'S PORTION WAS $454,149.00. THE PAYMENT WAS MADE ON OR ABOUT OCTOBER 27, 2003. Firm Statement SEE ABOVE. i Disclosure 67 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE, COMMISSIONER OF COMMERCE AND INSURANCE, SECURITIES DIVISION, STATE OF TENNESSEE, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF TENNESSEE CODE ANNOTATED SECTION 48-2- 116 OF THE TENNESSEE SECURITIES ACT OF 1980 AS AMENDED, TENNESSEE CODE ANNOTATED 48-2-101, ET. SEQ. ("ACT") IN CONNECTION ©2021 FINRA. All rights reserved. Report aboutWITH LEHMAN ALLEGED BROTHERS CONFLICTS INC. OF INTEREST BETWEEN LEHMAN BROTHERS' 142 RESEARCH AND INVESTMENT BANKING DEPARTMENTS. IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE, COMMISSIONER www.finra.org/brokercheck OF COMMERCE AND INSURANCE, SECURITIES DIVISION, STATE OF User Guidance TENNESSEE, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF TENNESSEE CODE ANNOTATED SECTION 48-2- 116 OF THE TENNESSEE SECURITIES ACT OF 1980 AS AMENDED, TENNESSEE CODE ANNOTATED 48-2-101, ET. SEQ. ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER OF COMMERCE AND INSURANCE, SECURITIES DIVISION, STATE OF TENNESSEE Date Initiated: 10/31/2003 Docket/Case Number: FILE NO.: 03-006

Resolution: Consent Resolution Date: 10/31/2003 Sanctions Ordered: Monetary/Fine $438,366.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 48-2- 112(A)(2)(G) AND (J) OF THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF TENNESSEE'S PORTION WAS $438,366.00. THE PAYMENT WAS MADE ON OR ABOUT OCTOBER 21, 2003. Firm Statement SEE ABOVE. i Disclosure 68 of 359 Reporting Source: Regulator

Current Status: Final Allegations: RESPONDENT FAILED TO EXERCISE DILIGENT SUPERVISION OVER ALL SECURITIES ACTIVITIES OF ITS ASSOCIATED PERSONS AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES IN VIOLATION OF CHAPTER 517.161(1)(A) FLORIDA STATUTES AND NASD CONDUCT RULE 3010. RESPONDENT FROM JULY 1999 THRU JUNE 2001 ENGAGED IN ACTS OR PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCES BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, AND FAILED TO MANAGE THESE CONFLICTS IN AN APPROPRIATE MANNER. Initiated By: FLORIDA Date Initiated: 10/31/2003 Docket/Case Number: 0046-S-06/03 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): RESEARCH. Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 10/31/2003 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $1,231,461.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: NA Regulator Statement RESPONDENT FAILED TO EXERCISE DILIGENT SUPERVISION OVER ALL SECURITIES ACTIVITIES OF ITS ASSOCIATED PERSONS AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES IN VIOLATION OF CHAPTER 517.161(1)(A) FLORIDA STATUTES AND NASD CONDUCT RULE 3010. RESPONDENT FROM JULY 1999 THRU JUNE 2001 ©2021 FINRA. All rights reserved. Report aboutENGAGED LEHMAN INBROTHERS ACTS OR INC. PRACTICES THAT CREATED OR MAINTAINED 144 INAPPROPRIATE INFLUENCES BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, AND FAILED TO MANAGE THESE CONFLICTS IN AN APPROPRIATE MANNER. RESPONDENT FAILED TO EXERCISE DILIGENT SUPERVISION OVER ALL www.finra.org/brokercheck SECURITIES ACTIVITIES OF ITS ASSOCIATED PERSONS AND FAILED TO User Guidance ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES IN VIOLATION OF CHAPTER 517.161(1)(A) FLORIDA STATUTES AND NASD CONDUCT RULE 3010. RESPONDENT FROM JULY 1999 THRU JUNE 2001 ENGAGED IN ACTS OR PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCES BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, AND FAILED TO MANAGE THESE CONFLICTS IN AN APPROPRIATE MANNER. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE DIRECTOR OF THE OFFICE OF FINANCIAL REGULATION, STATE OF FLORIDA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE FLORIDA SECURITIES AND INVESTOR PROTECTION ACT ("ACT") AND FLORIDA ADMINISTRATIVE CODE IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: OFFICE OF FINANCIAL REGULATION, STATE OF FLORIDA Date Initiated: 10/31/2003 Docket/Case Number: OFR NO. 0046-S-6/03

Resolution: Consent Resolution Date: 10/31/2003 Sanctions Ordered: Monetary/Fine $1,231,461.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTION 517.161 (1)(A) OF THE ACT AND RULE 3E-600.013 OF THE FLORIDA ADMINISTRATIVE CODE IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN ©2021 FINRA. All rights reserved. Report aboutUNDERTAKINGS LEHMAN BROTHERS WITH INC. RESPECT TO RESEARCH PRACTICES AND ( III ) PAY 145 AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF FLORIDA'S PORTION WAS $1,231,461.00. THE PAYMENT WAS MADE ON OR ABOUT OCTOBER 21, 2003. www.finra.org/brokercheck WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL User Guidance CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTION 517.161 (1)(A) OF THE ACT AND RULE 3E-600.013 OF THE FLORIDA ADMINISTRATIVE CODE IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF FLORIDA'S PORTION WAS $1,231,461.00. THE PAYMENT WAS MADE ON OR ABOUT OCTOBER 21, 2003. Firm Statement SEE ABOVE. i Disclosure 69 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE, COMMISSIONER OF SECURITIES, OFFICE OF THE SECRETARY OF STATE, STATE OF MISSOURI, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE MISSOURI SECURITIES ACT, CHAPTER 409, RSMO, ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER OF SECURITIES, OFFICE OF THE SECRETARY OF STATE, STATE OF MISSOURI Date Initiated: 10/23/2003 Docket/Case Number: CASE NO.: AO-03-18

Resolution Date: 10/23/2003 Sanctions Ordered: Monetary/Fine $431,117.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 409. 204(A)(2)(G) AND (J) OF THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF MISSOURI'S PORTION WAS $431,117.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 22, 2003. Firm Statement SEE ABOVE. i Disclosure 70 of 359 Reporting Source: Regulator Current Status: Final Allegations: LEHMAN BROTHERS, INC. HAS BEEN A BROKER-DEALER REGISTERED WITH THE TEXAS STATE SECURITIES BOARD SINCE AUGUST 19, 1983 AND AN INVESTMENT ADVISER SINCE MARCH 23, 1965. RESPONDENT, DURING THE PERIOD FROM JULY 1999 THRU JUNE 2001, FAILED TO EXERCISE DILIGENT SUPERVISION OVER ALL SECURITIES ACTIVITIES OF ITS ASSOCIATED PERSONS & FAILED TO ESTABLISH MAINTAIN OR ENFORCE WRITTEN PROCEDURES WHICH IS IN VIOLATION OF SECTION 115.10 OF THE RULES & REG'S OF THE TEXAS SECURITIES BOARD. RESPONDENT, DURING THE PERIOD FROM JULY 1999 THRU JULY 2001, ENGAGED IN ACTS OR PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCES BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, IMPOSED CONFLICTS OF INTEREST IN ITS RESEARCH ANALYSTS, AND FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER IN VIOLATION OF SECTION 14.A(3) OF THE TEXAS SECURITIES ACT. RESPONDENT, DURING THE PERIOD FROM JULY 1999 THRU JUNE 2001, ISSUED RESEARCH REPORTS THAT WERE NOT BASED ON PRINCIPLES OF FAIR DEALING AND GOOD FAITH, DID NOT PROVIDE SOUND BASIS FOR EVALUATING FACTS, WERE NOT PROPERLY BALANCED ©2021 FINRA. All rights reserved. Report aboutAND/OR LEHMAN CONTAINED BROTHERS INC.EXAGGERATED OR UNWARRANTED CLAIMS AND 147 OPINIONS OF WHICH THERE WAS NO REASONABLE BASIS, IN VIOLATION OF SECTION 14.A(3) OF THE TEXAS SECURITIES ACT. LEHMAN BROTHERS, INC. HAS BEEN A BROKER-DEALER REGISTERED WITH THE TEXAS STATE SECURITIES BOARD SINCE AUGUST 19, 1983 AND AN INVESTMENT ADVISER SINCE MARCH 23, 1965. RESPONDENT, DURING THE PERIOD FROM JULY 1999 THRU JUNE 2001, FAILED TO EXERCISE DILIGENT SUPERVISION OVER ALL SECURITIES ACTIVITIES OF ITS ASSOCIATED PERSONS & FAILED TO ESTABLISH MAINTAIN OR ENFORCE WRITTEN PROCEDURES WHICH IS IN VIOLATION OF SECTION 115.10 OF THE RULES & REG'S OF THE TEXAS SECURITIES BOARD. RESPONDENT, DURING THE PERIOD FROM JULY 1999 THRU JULY 2001, ENGAGED IN ACTS OR PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCES BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, IMPOSED CONFLICTS OF INTEREST IN ITS RESEARCH ANALYSTS, AND FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR www.finra.org/brokercheck APPROPRIATE MANNER IN VIOLATION OF SECTION 14.A(3) OF THE TEXAS User Guidance SECURITIES ACT. RESPONDENT, DURING THE PERIOD FROM JULY 1999 THRU JUNE 2001, ISSUED RESEARCH REPORTS THAT WERE NOT BASED ON PRINCIPLES OF FAIR DEALING AND GOOD FAITH, DID NOT PROVIDE SOUND BASIS FOR EVALUATING FACTS, WERE NOT PROPERLY BALANCED AND/OR CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS AND OPINIONS OF WHICH THERE WAS NO REASONABLE BASIS, IN VIOLATION OF SECTION 14.A(3) OF THE TEXAS SECURITIES ACT. Initiated By: TEXAS Date Initiated: 11/19/2003 Docket/Case Number: SSB DKT NO 03-050;ORDER NO CDO/FIN-1549 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CEASE AND DESIST FROM VIOLATING SECTION 14.A(3) OF THE TEXAS Sought: SECURITIES ACT.

Resolution: Order Resolution Date: 11/19/2003 Sanctions Ordered: Monetary/Fine $1,606,657.00 Other Sanctions Ordered: CEASE AND DESIST FROM VIOLATING THE TEXAS SECURITIES ACT AND AGREED TO AN UNDERTAKING Sanction Details: $1,606,657 WAS PAID CONTEMPORANEOUSLY WITH THE DELIVERY OF THE ORDER TO THE TEXAS SECURITIES COMMISSIONER. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE SECURITIES COMMISSIONER OF THE STATE SECURITIES BOARD, STATE OF TEXAS, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE SECURITIES ACT, TEX. REV. CIV. STAT. ANN. ART. 581-1 ET SEQ. (VERNON 1964 & SUPP. 2003)("TEXAS SECURITIES ACT"), AND THE ADMINISTRATIVE PROCEDURE ACT, TEX. GOV'T CODE ANN. §2001.001 ET SEQ. (VERNON SUPP. 2003)("ADMINISTRATIVE PROCEDURE ACT"), IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING ©2021 FINRA. All rights reserved. Report aboutDEPARTMENTS. LEHMAN BROTHERS INC. 148 IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE SECURITIES COMMISSIONER OF THE STATE SECURITIES BOARD, STATE OF TEXAS, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE SECURITIES ACT, TEX. REV. CIV. STAT. ANN. ART. 581-1 www.finra.org/brokercheck ET SEQ. (VERNON 1964 & SUPP. 2003)("TEXAS SECURITIES ACT"), AND THE User Guidance ADMINISTRATIVE PROCEDURE ACT, TEX. GOV'T CODE ANN. §2001.001 ET SEQ. (VERNON SUPP. 2003)("ADMINISTRATIVE PROCEDURE ACT"), IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECURITIES COMMISSIONER, STATE SECURITIES BOARD, STATE OF TEXAS Date Initiated: 11/19/2003 Docket/Case Number: DOCK NO.: 03-050; ORD NO.: CDO/FIN 1549

Resolution: Consent Resolution Date: 11/19/2003 Sanctions Ordered: Monetary/Fine $1,606,657.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTION 14.A(3) OF THE TEXAS SECURITIES ACT AS IT RELATES TO INEQUITABLE PRACTICES IN THE SALE OF SECURITIES AND SECTION 115.10 OF THE BOARD RULES IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF TEXAS' PORTION WAS $ 1,606,657.00. THE PAYMENT WAS MADE ON OR ABOUT NOVEMBER 11, 2003. Firm Statement SEE ABOVE. i Disclosure 71 of 359 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 149 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: RESPONDENT, DURING THE PERIOD FROM JULY 1999 THROUGH JUNE 2001, FAILED TO EXERCISE DILIGENT SUPERVISION OVER ALL THE SECURITIES ACTIVITIES OF ITS ASSOCIATED PERSONS AND FAILED TO ESTABLISH, MAINTAIN OR ENFORCE WRITTEN PROCEDURES, A COPY OF WHICH SHOULD BE KEPT IN EACH BUSINESS OFFICE, WHICH SET FORTH THE PROCEDURES ADOPTED BY THE DEALER, ISSUER OR INVESTMENT ADVISOR TO COMPLY WITH THE LISTED DUTIES IMPOSED BY THE NORTH DAKOTA CENTURY CODE. RESPONDENT ENGAGED IN ACTS OR PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCES BY INVESTMENT BANKING OVER RESEARCH ANALYSTS AND FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER IN VIOLATION OF JUST AND EQUITABLE PRINCIPLES OF TRADE. Initiated By: NORTH DAKOTA SECURITIES DEPARTMENT Date Initiated: 09/22/2003 Docket/Case Number: URL for Regulatory Action: Principal Product Type: Investment Contract(s) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief ADMINISTRATIVE ORDER Sought:

Resolution: Order Resolution Date: 09/22/2003 Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: LEHMAN BROTHERS PAID THE FINE ON 9/22/2003 Regulator Statement FROM AT LEAST JULY 1999 THROUGH AT LEAST JUNE 2001, LEHMAN COMPETED VIGOROUSLY WITH OTHER INVESTMENT BANKS TO BE SELECTED AS THE LEAD MANAGER FOR SECURITIES OFFERINGS, IN PART ©2021 FINRA. All rights reserved. Report aboutBECAUSE LEHMAN OF BROTHERS THE FINANCIAL INC. REWARDS ASSOCIATED WITH THAT ROLE. IN 150 ADDITION, LEHMAN HOPED TO GAIN ONGOING TRANSACTIONAL AND ADVISORY WORK FROM EXISTING AND POTENTIAL CLIENTS, INCLUDING SECONDARY OFFERINGS AND FINANCIAL ADVISORY ARRANGEMENTS. www.finra.org/brokercheck User Guidance FROM AT LEAST JULY 1999 THROUGH AT LEAST JUNE 2001, LEHMAN COMPETED VIGOROUSLY WITH OTHER INVESTMENT BANKS TO BE SELECTED AS THE LEAD MANAGER FOR SECURITIES OFFERINGS, IN PART BECAUSE OF THE FINANCIAL REWARDS ASSOCIATED WITH THAT ROLE. IN ADDITION, LEHMAN HOPED TO GAIN ONGOING TRANSACTIONAL AND ADVISORY WORK FROM EXISTING AND POTENTIAL CLIENTS, INCLUDING SECONDARY OFFERINGS AND FINANCIAL ADVISORY ARRANGEMENTS. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE COMMISSIONER OF THE SECURITIES DEPARTMENT, STATE OF NORTH DAKOTA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE NORTH DAKOTA SECURITIES ACT IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER OF THE SECURITIES DEPARTMENT, STATE OF NORTH DAKOTA Date Initiated: 09/22/2003 Docket/Case Number: IN THE MATTER OF LEHMAN BROTHERS INC.

Resolution: Consent Resolution Date: 10/07/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 10-04-11(1)(C) AND 10-04-11(1)(M) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH ©2021 FINRA. All rights reserved. Report aboutPRACTICES LEHMAN BROTHERS AND ( III )INC. PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A 151 RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF NORTH DAKOTA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 10, 2003. www.finra.org/brokercheck WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL User Guidance CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 10-04-11(1)(C) AND 10-04-11(1)(M) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF NORTH DAKOTA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 10, 2003. Firm Statement SEE ABOVE. i Disclosure 72 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE CHIEF OF THE BUREAU OF SECURITIES, STATE OF NEW JERSEY, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE UNIFORM SECURITIES LAW (1997) IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: CHIEF OF THE BUREAU OF SECURITIES, STATE OF NEW JERSEY Date Initiated: 09/03/2003 Docket/Case Number: IN THE MATTER OF LEHMAN BROTHERS INC.

Resolution: Consent Resolution Date: 10/07/2003 Sanctions Ordered: Monetary/Fine $648,335.00 ©2021 FINRA. All rights reserved. Report aboutCease LEHMAN and Desist/Injunction BROTHERS INC. 152 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $648,335.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF THE UNIFORM SECURITIES LAW (1997), N.J.S.A. 49:3-47 ET SEQ. IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF NEW JERSEY'S PORTION WAS $648,335.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 26, 2003. Firm Statement SEE ABOVE. i Disclosure 73 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE CORPORATION COMMISSION, STATE OF ARIZONA INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE SECURITIES ACT OF ARIZONA ("SECURITIES ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: CORPORATION COMMISSION, STATE OF ARIZONA Date Initiated: 09/29/2003 Docket/Case Number: S-03535A-03-0000, DECISION NO.: 66320

Principal Product Type: Other Other Product Type(s): EQUITY RESEARCH Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought:

Other Sanction(s)/Relief CEASE AND DESIST, AND UNDERTAKING Sought:

Resolution: Consent Resolution Date: 09/29/2003 Sanctions Ordered: Monetary/Fine $395,321.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECURITIES ACT OF ARIZONA SECTION 44-1961(A)(13) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF ARIZONA'S PORTION WAS $395,321.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 26, 2003. Firm Statement SEE ABOVE. i Disclosure 74 of 359 Reporting Source: Regulator Current Status: Final Allegations: THE RESPONDENT SETTLED DALLEGATIONS THAT UNDUE INFLUENCE BY INVESTMENT BANKING DIVISION ON SECURITIES RESEARCH AT FIRM RESULTED IN TAINTED RESEARCH. Initiated By: GEORGIA SECRETARY OF STATE-SECURITIES DIVISION. Date Initiated: 09/08/2003 Docket/Case Number: EN-19513 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): SEE #7 Principal Sanction(s)/Relief Cease and Desist Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 154 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief THE RESPONDENT SHALL PAY $500,000.00 IN CIVIL PENALTIES TO GA, Sought: $50,000.00 AS INVESTIGATIVE COSTS TO GA, AND $80,775.00 TO THE INVESTOR PROTECTION TRUST FOR THE PROMOTION OF INVESTOR PROTECTION AND EDUCATION FOR THE BENEFIT OF GA INVESTORS AND CITIZENS.

Resolution: Consent Resolution Date: 09/25/2003 Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $630,775.00 Cease and Desist/Injunction Other Sanctions Ordered: SEE #2 Sanction Details: FIRM AGREED TO PAY MONETARY PENALTIES, DISGORGEMENT, AND FUND INDEPENDENT RESEARCH AND INVESTOR EDUCATION. FIRM ALSO AGREED TO REFORM PRACTICES TO MINIMIZE POSSIBILITY OF FUTURE CONFLICTS OF INTEREST. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE COMMISSIONER OF SECURITIES, STATE OF GEORGIA INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE GEORGIA SECURITIES ACT OF 1973 ("ACT") AND CERTAIN RULES OF THE OFFICE OF SECRETARY OF STATE ("RULES") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER OF SECURITIES, STATE OF GEORGIA Date Initiated: 09/25/2003

Docket/Case Number: EN-19513

Resolution: Consent Resolution Date: 09/25/2003 Sanctions Ordered: Monetary/Fine $630,775.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 10-5-4 (A)(8) AND (11) AND 10-5-12(A)(1) OF THE ACT AND 590-4-2-.08(1) AND 590-4-2-. 14(1) OF THE RULES IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF GEORGIA'S PORTION WAS $630,775.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 26, 2003. Firm Statement SEE ABOVE. i Disclosure 75 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE SECRETARY OF STATE AND THE ATTORNEY GENERAL OF THE STATE OF WYOMING ©2021 FINRA. All rights reserved. Report aboutINVESTIGATED LEHMAN BROTHERS WHETHER INC. LEHMAN BROTHERS VIOLATED CERTAIN 156 PROVISIONS OF THE WYOMING SECURITIES ACT ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT www.finra.org/brokercheck INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED User Guidance STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE SECRETARY OF STATE AND THE ATTORNEY GENERAL OF THE STATE OF WYOMING INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE WYOMING SECURITIES ACT ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECRETARY OF STATE AND THE ATTORNEY GENERAL, STATE OF WYOMING Date Initiated: 09/15/2003 Docket/Case Number: NO. 02-11

Resolution: Consent Resolution Date: 09/26/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 17-4-106 (A)(II)(G) AND (B)(II)(A) OF THE WYOMING SECURITIES ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF WYOMING'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 3, 2003. Firm Statement SEE ABOVE. i Disclosure 76 of 359 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 157 www.finra.org/brokercheck User Guidance

Disclosure 76 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE COMMISSIONER OF THE SECURITIES DIVISION OF THE OFFICE OF THE SECRETARY OF STATE, STATE OF INDIANA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE INDIANA SECURITIES ACT ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: INDIANA SECURITIES COMMISSIONER, SECURITIES DIVISION OF THE OFFICE OF THE SECRETARY OF STATE Date Initiated: 09/24/2003 Docket/Case Number: CAUSE #03-00557CO

Resolution: Consent Resolution Date: 09/24/2003 Sanctions Ordered: Monetary/Fine $468,508.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF INDIANA CODE 23-2-1-11 (A)(6) AND -11(A)(14), AND 710 INDIANA ADMINISTRATIVE CODE 1-17-1(V) AND -1(W) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY ©2021 FINRA. All rights reserved. Report about$80,000,000 LEHMAN BROTHERS ($25 MILLION INC. AS A PENALTY, $25 MILLION AS DISGORGEMENT 158 OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF INDIANA'S PORTION WAS $468,508.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 3, 2003. WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF INDIANA CODE 23-2-1-11 (A)(6) AND -11(A)(14), AND 710 INDIANA ADMINISTRATIVE CODE 1-17-1(V) www.finra.org/brokercheck AND -1(W) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) User Guidance CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF INDIANA'S PORTION WAS $468,508.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 3, 2003. Firm Statement SEE ABOVE. i Disclosure 77 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE COMMISSIONER OF THE DEPARTMENT OF FINANCIAL INSTITUTIONS, STATE OF KENTUCKY, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE SECURITIES ACT OF KENTUCKY ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER OF THE DEPARTMENT OF FINANCIAL INSTITUTIONS, STATE OF KENTUCKY Date Initiated: 09/10/2003 Docket/Case Number: NOT AVAILABLE

Resolution: Consent Resolution Date: 09/23/2003 Sanctions Ordered: Monetary/Fine $311,423.00 Cease and Desist/Injunction ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 159 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 292.330(13)(A)7 AND 292.330(13)(A)9A OF THE ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF KENTUCKY'S PORTION WAS $311,423.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 28, 2003. Firm Statement SEE ABOVE. i Disclosure 78 of 359 Reporting Source: Regulator Current Status: Final Allegations: TIME PERIOD BEGINNING JULY 1, 1999, TO JUNE 30, 2001, TO WIT, LEHMAN BROTHERS FAILED TO ENSURE THAT RESEARCH ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING, AND LEHMAN BROTHERS FAILED TO REASONABLY SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS RESEARCH ANALYSTS WERE ADEQUATELY INSULATED FROM SUCH PRESSURES AND INFLUENCES. Initiated By: OKLAHOMA Date Initiated: 05/02/2003 Docket/Case Number: ODS 03-134 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): ANALYST INDEPENDENCE (IPO) Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/12/2003 Sanctions Ordered: Monetary/Fine $265,877.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: LEHMAN BROTHERS ALSO AGREED TO COMPLY WITH ALL UNDERTAKINGS ESTABLISHED AS PART OF THE GLOBAL ANALYST SETTLEMENT IN CONNECTION WITH THE FIRM'S RESEARCH PRACTICES. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE DEPARTMENT OF SECURITIES, STATE OF OKLAHOMA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE OKLAHOMA SECURITIES ACT ("ACT") AND THE RULES OF THE OKLAHOMA SECURITIES COMMISSION AND THE ADMINISTRATOR OF THE DEPARTMENT OF SECURITIES ("RULES"), IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: ADMINISTRATOR OF THE OKLAHOMA DEPARTMENT OF SECURITIES Date Initiated: 09/12/2003 Docket/Case Number: ODS FILE NO. 03-134

Resolution: Consent Resolution Date: 09/22/2003 Sanctions Ordered: Monetary/Fine $265,877.00 Cease and Desist/Injunction ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 161 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $265,877.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF CERTAIN SECTIONS OF THE ACT AND RULES IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF OKLAHOMA'S PORTION WAS $265,877.00. THE PAYMENT WAS MADE ON SEPTEMBER 22, 2003. Firm Statement SEE ABOVE. i Disclosure 79 of 359 Reporting Source: Regulator Current Status: Final Allegations: LEHMAN BROTHERS, INC.'S ACTIVITIES IN CONNECTION WITH CERTAIN CONFLICTS OF INTEREST THAT RESEARCH ANALYSTS WERE SUBJECT TO DURING THE PERIOD OF JULY 1, 1999 THRU JUNE 30, 2001. Initiated By: KANSAS SECURITIES COMMISSIONER Date Initiated: 05/05/2003 Docket/Case Number: 2003E047/KSC 2003-4740 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): SECURITIES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CONSENT ORDER AND FINE. Sought:

Resolution: Stipulation and Consent Resolution Date: 09/30/2003

Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: LEHMAN BROTHERS, INC.'S WILL CEASE AND DESIST FROM VIOLATING KSC 17-1254(M)(7) & (12) IN CONNECTION WITH THE RESEARCH PRACTICES REFERENCED IN THE ORDER, WILL COMPLY WITH KSA 17-1254 (M)(7) & (12) IN CONNECTION WITH THE RESEARCH PRACTICES REFERENCED IN THE ORDER, AND WILL COMPLY WITH THE UNDERTAKINGS. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE SECURITIES COMMISSIONER OF THE STATE OF KANSAS INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE KANSAS SECURITIES ACT ("ACT") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: OFFICE OF THE SECURITIES COMMISSIONER, STATE OF KANSAS Date Initiated: 09/30/2003 Docket/Case Number: 2003E047, K.S.C. NO., 2003-4740

Resolution Date: 09/30/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 17-1254(M)(7) & (12) OF THE KANSAS SECURITIES ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF KANSAS'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT SEPTEMBER 22, 2003. Firm Statement SEE ABOVE. i Disclosure 80 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE DEPARTMENT OF FINANCE, STATE OF IDAHO, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE IDAHO SECURITIES ACT, IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: DIRECTOR OF THE DEPARTMENT OF FINANCE, STATE OF IDAHO Date Initiated: 09/08/2003 Docket/Case Number: DOCKET NO. 2003-7-23

Other Product Type(s): EQUITY RESEARCH Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST, AND UNDERTAKING Sought:

Resolution: Consent Resolution Date: 09/16/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF THE IDAHO SECURITIES ACT, IDAHO CODE 30-1413(7) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF IDAHO'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 28, 2003. Firm Statement SEE ABOVE. i Disclosure 81 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE DIVISION OF BANKING, SECURITIES AND CORPORATIONS, STATE OF ALASKA, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE ALASKA SECURITIES ACT, IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 165 IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES THE DIVISION OF www.finra.org/brokercheck BANKING, SECURITIES AND CORPORATIONS, STATE OF ALASKA, User Guidance INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE ALASKA SECURITIES ACT, IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: ADMINISTRATOR OF SECURITIES, DIVISION OF BANKING, SECURITIES AND CORPORATIONS, STATE OF ALASKA Date Initiated: 08/20/2003 Docket/Case Number: ALASKA ORDER 04-04-S

Resolution: Consent Resolution Date: 09/18/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 45.55.060(A)(7) AND (B)(1) OF THE ALASKA SECURITIES ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF ALASKA'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 26, 2003. Firm Statement SEE ABOVE. i Disclosure 82 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT ©2021 FINRA. All rights reserved. Report aboutINVOLVING LEHMAN BROTHERSSEVERAL INC. OF THE LEADING SECURITIES FIRMS IN THE UNITED 166 STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE RHODE ISLAND UNIFORM SECURITIES ACT OF 1990, IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. www.finra.org/brokercheck User Guidance

Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE RHODE ISLAND UNIFORM SECURITIES ACT OF 1990, IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION Date Initiated: 09/08/2003 Docket/Case Number: 03-122

Resolution: Consent Resolution Date: 09/08/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 7-11-212(B)(8) AND (11) OF THE RHODE ISLAND UNIFORM SECURITIES ACT OF 1990 IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF RHODE ISLAND'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 28, 2003. Firm Statement SEE ABOVE. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 167 www.finra.org/brokercheck User Guidance

Firm Statement SEE ABOVE. i Disclosure 83 of 359 Reporting Source: Regulator Current Status: Final Allegations: VIOLATION OF THE VERMONT SECURITIES ACT IN THAT: (A) FIRM FAILED TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING WHICH CONDUCT IS A DISHONEST AND UNETHICAL PRACTICE UNDER SECTION 4221A(A)(8) OF THE ACT; AND (B) FIRM FAILED TO REASONABLY SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING AS REQUIRED UNDER SECTION 4221A(A)(11) OF THE ACT. Initiated By: VERMONT Date Initiated: 07/01/2002 Docket/Case Number: 03-059-S URL for Regulatory Action: Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 09/03/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: GLOBAL SETTLEMENT RESULTING FROM INVESTIGATION OF ANALYST TASK FORCE. FIRM ADMITS THE JURISDICTION OF THE COMMISSIONER, NEITHER ADMITS NOR DENIES THE FINDINGS OF FACT AND CONCLUSIONS OF LAW CONTAINED IN THE ORDER, AND CONSENTS TO THE ENTRY OF THE ORDER BY THE COMMISSIONER.

i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE COMMISSIONER OF THE DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE VERMONT SECURITIES ACT ("V.S.A."), IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: COMMISSIONER OF THE DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION, STATE OF VERMONT Date Initiated: 09/03/2003 Docket/Case Number: 03-059-S

Resolution: Consent Resolution Date: 09/03/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 4221A(A)(8) AND (11) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY ©2021 FINRA. All rights reserved. Report about$80,000,000 LEHMAN BROTHERS ($25 MILLION INC. AS A PENALTY, $25 MILLION AS DISGORGEMENT 169 OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF VERMONT'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 28, 2003. WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 4221A(A)(8) AND (11) IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) www.finra.org/brokercheck CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND User Guidance ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF VERMONT'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 28, 2003. Firm Statement SEE ABOVE. i Disclosure 84 of 359 Reporting Source: Regulator Current Status: Final Allegations: THE FIRM ENGAGED IN UNETHICAL AND DISHONEST CONDUCT BY FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES OF COVERED COMPANIES AND INVESTMENT BANKING. THE FIRM ALSO FAILED TO REASONABLY SUPERVISE ITS EMPLOYEES IN CONNECTION WITH THE ISSUANCE OF RESEARCH. Initiated By: MAINE OFFICE OF SECURITIES Date Initiated: 05/30/2003 Docket/Case Number: 03-105 URL for Regulatory Action: Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 08/28/2003 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 170 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: PENALTY OF $250,000 WAS PAID ON 8/28/2003. Regulator Statement THE FIRM WAS ORDERED TO CEASE AND DESIST FROM VIOLATING THE RMSA IN CONNECTION WITH CERTAIN CONFLICTS OF INTEREST TO WHICH ITS RESEARCH ANALYSTS WERE SUBJECT AND TO IMPLEMENT CERTAIN CHANGES WITH RESPECT TO ITS RESEARCH AND BANKING PRACTICES. THE CONSENT ORDER WAS EXECUTED AS PART OF A GLOBAL SETTLEMENT OF COORDINATED INVESTIGATIONS ENTERED INTO BY FEDERAL AND STATE REGULATORS, AND SEVERAL LARGE BROKER- DEALERS WHO ENGAGED IN THE RESEARCH PRACTICES AT ISSUE. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE SECURITIES ADMINISTRATOR OF THE OFFICE OF SECURITIES, STATE OF MAINE, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE REVISED MAINE SECURITIES ACT ("M.R.S.A."), IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECURITIES ADMINISTRATOR OF THE OFFICE OF SECURITIES, STATE OF MAINE Date Initiated: 08/28/2003 Docket/Case Number: 03-105

Resolution Date: 08/28/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTIONS 10313(1)(G) AND 10313(1)(J) OF THE M.R.S.A. IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF MAINE'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 26, 2003. Firm Statement SEE ABOVE. i Disclosure 85 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE SECRETARY OF STATE OF THE STATE OF MISSISSIPPI, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE MISSISSIPPI SECURITIES ACT, IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECRETARY OF STATE OF THE STATE OF MISSISSIPPI Date Initiated: 09/04/2003 Docket/Case Number: 02-11-06-S

Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST, AND UNDERTAKING Sought:

Resolution: Consent Resolution Date: 09/04/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF CERTAIN PROVISIONS OF THE MISSISSIPPI SECURITIES ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES REFERENCED IN THE CONSENT ORDER, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF MISSISSIPPI'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 26, 2003. Firm Statement SEE ABOVE. i Disclosure 86 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE COMMISSIONER OF SECURITIES, STATE OF HAWAII, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE HAWAII REVISED STATUTES ("H.R.S."), UNIFORM SECURITIES ACT, IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 173 www.finra.org/brokercheck User Guidance

Initiated By: COMMISSIONER OF SECURITIES, STATE OF HAWAII, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS Date Initiated: 09/03/2003 Docket/Case Number: SEU2002-047

Resolution: Consent Resolution Date: 09/03/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTION H.R.S. 485-15(7) AND 485-15(10) OF THE UNIFORM SECURITIES ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES AND ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF HAWAII'S PORTION WAS $250,000.00. THE PAYMENT WAS MADE ON OR ABOUT AUGUST 26, 2003. Firm Statement SEE ABOVE. i Disclosure 87 of 359 Reporting Source: Regulator Current Status: Final Allegations: **08/04/2003** LEHMAN BROTHERS FAILED REASONABLY TO SUPERVISE GRUTTADAURIA WITH A VIEW TO PREVENTING AND DETECTING HIS VIOLATION OF THE FEDERAL SECURITIES LAWS DURING THE 15 - MONTH ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 174 PERIOD THAT IT EMPLOYED HIM FROM OCTOBER 2000 TO JANUARY 2002. FROM 1987 TO JANUARY 2002, WHILE EMPLOYED AT A SERIES OF FIVE DIFFERENT REGISTERED BROKER-DEALERS, GRUTTADAURIA DEFRAUDED OVER 60 CUSTOMERS BY LYING ABOUT PURCHASES AND SALES OF SECURITIES, MISAPPROPRIATING FUNDS AND SECURITIES, AND SENDING FALSIFIED ACCOUNT DOCUMENTS. BY THE TIME THAT GRUTTADAURIA CONFESSED GENERALLY TO HIS FRAUDULENT CONDUCT IN A LETTER TO THE FEDERAL BUREAU OF INVESTIGATION ON JANUARY 11, 2002, HE HAD MISAPPROPRIATED OVER $115 MILLION FROM CUSTOMERS OVER A PERIOD OF 15 YEARS – TRANSFERRING MOST OF THE MONEY TO OTHER CUSTOMERS TO COVER WITHDRAWAL REQUESTS – AND OVERSTATED ACCOUNT VALUES BY MORE THAT $280 MILLION. www.finra.org/brokercheck User Guidance

**08/04/2003** LEHMAN BROTHERS FAILED REASONABLY TO SUPERVISE GRUTTADAURIA WITH A VIEW TO PREVENTING AND DETECTING HIS VIOLATION OF THE FEDERAL SECURITIES LAWS DURING THE 15 - MONTH PERIOD THAT IT EMPLOYED HIM FROM OCTOBER 2000 TO JANUARY 2002. FROM 1987 TO JANUARY 2002, WHILE EMPLOYED AT A SERIES OF FIVE DIFFERENT REGISTERED BROKER-DEALERS, GRUTTADAURIA DEFRAUDED OVER 60 CUSTOMERS BY LYING ABOUT PURCHASES AND SALES OF SECURITIES, MISAPPROPRIATING FUNDS AND SECURITIES, AND SENDING FALSIFIED ACCOUNT DOCUMENTS. BY THE TIME THAT GRUTTADAURIA CONFESSED GENERALLY TO HIS FRAUDULENT CONDUCT IN A LETTER TO THE FEDERAL BUREAU OF INVESTIGATION ON JANUARY 11, 2002, HE HAD MISAPPROPRIATED OVER $115 MILLION FROM CUSTOMERS OVER A PERIOD OF 15 YEARS – TRANSFERRING MOST OF THE MONEY TO OTHER CUSTOMERS TO COVER WITHDRAWAL REQUESTS – AND OVERSTATED ACCOUNT VALUES BY MORE THAT $280 MILLION. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 08/04/2003 Docket/Case Number: HPD# 03-157

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 09/05/2003 Sanctions Ordered: Censure Monetary/Fine $2,500,000.00 Other Sanctions Ordered: Sanction Details: **08/06/2003** EXCHANGE HEARING PANEL DECISION 03-157 FAILED TO ADEQUATELY IMPLEMENT POLICIES AND PROCEDURES TO SUPERVISE A PRODUCING BRANCH OFFICE MANAGER WHO ENGAGED IN FRAUDULENT CONDUCT; VIOLATED EXCHANGE RULE 342 BY FAILING TO PROVIDE FOR ADEQUATE SUPERVISORY CONTROL OF CERTAIN BUSINESS ACTIVITIES, AND BY FAILING TO PROVIDE ADEQUATE SYSTEMS AND PROCEDURES TO ENSURE ADEQUATE SUPERVISION OF PRODUCING BRANCH OFFICE MANAGERS AND TO SUPERVISE CORRESPONDENCE OF PRODUCING BRANCH OFFICE MANAGERS; VIOLATED EXCHANGE RULE 405 IN THAT IT FAILED TO SUPERVISE DILIGENTLY CERTAIN ACCOUNTS HANDLED BY A PRODUCING BRANCH OFFICE MANAGER; VIOLATED EXCHANGE RULE 405 AND SEC RULE 17A-3 BY FAILING TO MAINTAIN ©2021 FINRA. All rights reserved. Report aboutCOMPLETE LEHMAN BROTHERS AND ACCURATE INC. BOOKS AND RECORDS - CONSENT TO 175 CENSURE; $2,500,000 FINE JOINTLY IMPOSED BY THE EXHANGE AND THE SEC; AND SPECIAL UNDERTAKINGS. **08/06/2003** EXCHANGE HEARING PANEL DECISION 03-157 FAILED TO ADEQUATELY IMPLEMENT POLICIES AND PROCEDURES TO SUPERVISE A PRODUCING BRANCH OFFICE MANAGER WHO ENGAGED IN FRAUDULENT CONDUCT; VIOLATED EXCHANGE RULE 342 BY FAILING TO PROVIDE FOR ADEQUATE SUPERVISORY CONTROL OF CERTAIN BUSINESS ACTIVITIES, AND BY FAILING TO PROVIDE ADEQUATE SYSTEMS AND PROCEDURES TO ENSURE ADEQUATE SUPERVISION OF PRODUCING www.finra.org/brokercheck BRANCH OFFICE MANAGERS AND TO SUPERVISE CORRESPONDENCE OF User Guidance PRODUCING BRANCH OFFICE MANAGERS; VIOLATED EXCHANGE RULE 405 IN THAT IT FAILED TO SUPERVISE DILIGENTLY CERTAIN ACCOUNTS HANDLED BY A PRODUCING BRANCH OFFICE MANAGER; VIOLATED EXCHANGE RULE 405 AND SEC RULE 17A-3 BY FAILING TO MAINTAIN COMPLETE AND ACCURATE BOOKS AND RECORDS - CONSENT TO CENSURE; $2,500,000 FINE JOINTLY IMPOSED BY THE EXHANGE AND THE SEC; AND SPECIAL UNDERTAKINGS. Regulator Statement **09/05/2003** THE DECISION IS NOW FINAL AND IS EFFECTIVE IMMEDIATELY. CONTACT: PEGGY GERMINO (212) 656-8450. i Reporting Source: Firm Current Status: Final Allegations: THE NEW YORK STOCK EXCHANGE ("NYSE") ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED EXCHANGE RULES 342 AND 405 IN THAT IT FAILED TO PROVIDE FOR APPROPRIATE SUPERVISORY CONTROL OF FRANK D. GRUTTADAURIA DURING THE 15 MONTH PERIOD THAT LEHMAN EMPLOYED HIM FROM OCTOBER 2000 TO JANUARY 2002. THE NYSE ALSO ALLEGED THAT LEHMAN HAD VIOLATED EXCHANGE RULE 440 AND SEC 17 A-3 IN THAT IT FAILED TO MAINTAIN COMPLETE AND ACCURATE BOOKS AND RECORDS. Initiated By: NEW YORK STOCK EXCHANGE, INC. Date Initiated: 09/05/2003 Docket/Case Number: EXCHANGE HEARING PANEL DECISION 03-157

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE, UNDERTAKE A SPECIAL ARBITRATION PROCESS FOR Sought: POTENTIAL VICTIMS, UNDERTAKE A REVIEW OF CERTAIN FIRM POLICIES, PROCEDURES, PRACTICES AND SUPERVISORY SYSTEMS RELATED TO THE FIRM'S USE OF PERSONAL COMPUTERS, ACCOUNTS WITH POST OFFICE AND "CARE OF" ADDRESSES, AND THIRD PARTY DISBURSEMENTS.

Resolution: Stipulation and Consent Resolution Date: 09/05/2003 Sanctions Ordered: Censure Monetary/Fine $2,500,000.00 Other Sanctions Ordered: UNDERTAKING TO PARTICIPATE IN A SPECIAL ARBITRATION PROCESS FOR POTENTIAL VICTIMS. UNDERTAKE A REVIEW OF CERTAIN FIRM POLICIES, PROCEDURES, PRACTICES AND SUPERVISORY SYSTEMS RELATED TO THE FIRM'S USE OF PERSONAL COMPUTERS, ACCOUNTS WITH POST ©2021 FINRA. All rights reserved. Report aboutOFFICE LEHMAN AND BROTHERS "CARE OF" INC. ADDRESSES, AND THIRD PARTY DISBURSEMENTS. 176 www.finra.org/brokercheck User Guidance UNDERTAKING TO PARTICIPATE IN A SPECIAL ARBITRATION PROCESS FOR POTENTIAL VICTIMS. UNDERTAKE A REVIEW OF CERTAIN FIRM POLICIES, PROCEDURES, PRACTICES AND SUPERVISORY SYSTEMS RELATED TO THE FIRM'S USE OF PERSONAL COMPUTERS, ACCOUNTS WITH POST OFFICE AND "CARE OF" ADDRESSES, AND THIRD PARTY DISBURSEMENTS. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, LEHMAN CONSENTED TO PAY $2.5 MILLION DOLLARS. HALF OF THIS AMOUNT, $1,250,000.00, WAS PAID TO THE U.S. TREASURY AS A CIVIL MONETARY PAYMENT ON AUGUST 22, 2003. THE SECOND HALF SHALL BE PAID TO THE NYSE PURSUANT TO THE HEARING PANEL'S DECISION. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, LEHMAN ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY WITH THE NYSE ON AUGUST 2, 2003 IN WHICH LEHMAN AGREED TO ( I ) A CENSURE; ( II ) PAYMENT OF $2.5 MILLION DOLLARS IN ACCORDANCE WITH THE SETTLEMENTS OF THE NYSE AND SECURITIES AND EXCHANGE COMMISSION PROCEEDINGS; ( III ) PARTICIPATION IN A SPECIAL ARBITRATION PROCESS FOR POTENTIAL VICTIMS AND ( IV ) UNDERTAKE A REVIEW OF CERTAIN FIRM POLICIES, PROCEDURES, PRACTICES AND SUPERVISORY SYSTEMS. ON SEPTEMBER 5, 2003, THE NYSE ADVISED LEHMAN BROTHERS THAT THE HEARING PANEL'S DECISION, IN WHICH IT ACCEPTED THE STIPULATION AND CONSENT, HAD BECOME FINAL. i Disclosure 88 of 359 Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE NEW YORK STATE ATTORNEY GENERAL INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED NEW YORK'S MARTIN ACT IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: ATTORNEY GENERAL OF THE STATE OF NEW YORK, BUREAU OF INVESTMENT PROTECTION Date Initiated: 08/21/2003 Docket/Case Number: IN THE MATTER OF LEHMAN BROTHERS INC.

Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST, UNDERTAKING, AND VOLUNTARY INITIATIVE Sought:

Resolution: Consent Resolution Date: 08/21/2003 Sanctions Ordered: Monetary/Fine $1,462,158.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING, VOLUNTARY INITIATIVE Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF THE MARTIN ACT IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES (III) A VOLUNTARY INITIATIVE REGARDING ALLOCATION OF "HOT" IPOS TO EXECUTIVES OR DIRECTORS OF PUBLIC COMPANIES AND (IV) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). NEW YORK STATE'S PORTION WAS $1,462,158.00. THE PAYMENT WAS MADE ON AUGUST 21, 2003. Firm Statement SEE ABOVE. i Disclosure 89 of 359 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULES G-12, G-14 - RESPONDENT MEMBER FAILED TO PROVIDE ACCURATE AND TIMELY INFORMATION REGARDING MUNICIPAL SECURITIES TRADES TO THE NATIONAL SECURITIES CLEARING CORPORATION. Initiated By: NASD Date Initiated: 08/28/2003 Docket/Case Number: C10030074

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/28/2003 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS, INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $7,500. i Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED MSRB RULES G-12 AND G-14. Initiated By: NASD - NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/30/2003 Docket/Case Number: AWC NO. C10030074

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/28/2003 Sanctions Ordered: Censure Monetary/Fine $7,500.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 179 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: LEHMAN WILL PAY THE TOTAL FINE OF $7,500.00 Firm Statement LEHMAN CONSENTED, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS OF THE AWC, THAT DURING THE PERIOD JANUARY THROUGH AUGUST OF 2001, LEHMAN'S T-INPUT PERCENTAGE FOR REPORTING TO THE NSCC WAS BELOW THE INDUSTRY AVERAGE THEREBY, VIOLATING MSRB RULES G-12 AND G-14. i Disclosure 90 of 359 Reporting Source: Regulator Current Status: Final Allegations: ON SEPTEMBER 2, 2003, THE BANKING COMMISSIONER ENTERED A CONSENT ORDER WITH RESPECT TO LEHMAN BROTHERS INC. THE AGENCY INVESTIGATION LEADING UP TO THE CONSENT ORDER FOCUSED ON THE FIRMS' RESEARCH PRACTICES FOR THE PERIOD 1999 THROUGH 2001, AND WAS PART OF SIMILAR INVESTIGATIONS CONDUCTED BY A MULTI-STATE TASK FORCE AND A JOINT TASK FORCE OF THE SEC, THE NEW YORK STOCK EXCHANGE AND THE NATIONAL ASSOCIATION OF SECURITIES DEALERS. THE GLOBAL RESOLUTION CAPPING THE INVESTIGATIONS RESULTED IN $25 MILLION ALLOCATED TO THE STATES; $25 MILLION REPRESENTING THE DISGORGEMENT OF COMMISSIONS AND FEES; $25 MILLION TO BE EARMARKED FOR THE PROCUREMENT OF INDEPENDENT RESEARCH BY THE RESPONDENT; AND $5 MILLION TO BE USED FOR INVESTOR EDUCATION. THE RESPONDENT ALSO AGREED TO ABIDE BY CERTAIN UNDERTAKINGS DESIGNED TO SEPARATE ITS INVESTMENT BANKING AND RESEARCH FUNCTIONS. Initiated By: CONNECTICUT Date Initiated: 09/02/2003 Docket/Case Number: CO-2003-6799-S URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): ANALYST CONFLICT OF INTEREST Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution Date: 09/02/2003 Sanctions Ordered: Monetary/Fine $262,402.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CONSENT ORDER DIRECTED THE RESPONDENT TO CEASE AND DESIST FROM REGULATORY VIOLATIONS AND FINED THE RESPONDENT $262,402. Regulator Statement IN ENTERING THE CONSENT ORDER, THE COMMISSIONER FOUND THAT THE RESPONDENT HAD 1) VIOLATED SECTION 36B-4(B) OF THE CONNECTICUT UNIFORM SECURITIES ACT BY FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCE FROM COVERED COMPANIES AND INVESTMENT BANKING; 2) VIOLATED SECTION 36B-4(B) OF THE ACT BY ISSUING RESEARCH REPORTS THAT WERE NOT BASED ON PRINCIPLES OF FAIR DEALING AND GOOD FAITH AND THAT CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS AND OPINIONS; AND 3) FAILED TO ESTABLISH, ENFORCE AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE BANKING COMMISSIONER OF THE STATE OF CONNECTICUT, DEPARTMENT OF BANKING, INVESTIGATED WHETHER LEHMAN BROTHERS VIOLATED CERTAIN PROVISIONS OF THE CONNECTICUT UNIFORM SECURITIES ACT ("ACT") AND THE REGULATIONS OF CONNECTICUT STATE AGENCIES PROMULGATED UNDER THE ACT ("REGULATIONS") IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: BANKING COMMISSIONER, STATE OF CONNECTICUT, DEPARTMENT OF BANKING Date Initiated: 09/02/2003 Docket/Case Number: C0-2003-6799-S

Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST, AND UNDERTAKING Sought:

Resolution: Consent Resolution Date: 09/02/2003 Sanctions Ordered: Monetary/Fine $262,402.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR LEGAL CONCLUSIONS, LEHMAN BROTHERS AGREED TO ( I ) CEASE AND DESIST FROM ENGAGING IN ANY ACTS IN VIOLATION OF SECTION 36B-4(B) OF THE ACT AND SECTION 36B-31-6F(B) OF THE REGULATIONS IN CONNECTION WITH CERTAIN RESEARCH PRACTICES, ( II ) CERTAIN UNDERTAKINGS WITH RESPECT TO RESEARCH PRACTICES ( III ) PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT") IN WHICH, AMONG OTHER THINGS, LEHMAN AGREED TO PAY $80,000,000 ($25 MILLION AS A PENALTY, $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25 MILLION OVER FIVE YEARS FOR PROCUREMENT OF INDEPENDENT RESEARCH, AND $5 MILLION OVER FIVE YEARS FOR INVESTOR EDUCATION). THE STATE OF CONNECTICUT'S PORTION WAS $262,402.00. THE PAYMENT WAS MADE ON AUGUST 27, 2003. Firm Statement SEE ABOVE. i Disclosure 91 of 359 Reporting Source: Regulator Current Status: Final Allegations: FAILURE TO SUPERVISE A PRODUCING BRANCH OFFICE MANAGER Initiated By: OHIO DIVISION OF SECURITIES Date Initiated: 08/14/2003 Docket/Case Number: 03-174 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): STOCK Principal Sanction(s)/Relief Undertaking ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 182 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Undertaking Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 08/14/2003 Sanctions Ordered: Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: REQUIRED TO FILE WITH OHIO ALL REPORTS FILED WITH SEC AND NYSE IN CONNECTION WITH THEIR SETTLEMENT Regulator Statement FRANK GRUTTADAURIA WAS A PRODUCING BRANCH OFFICE MANAGER IN CLEVELAND FROM OCTOBER 2000 THROUGH JANUARY 2002. DURING THAT TIME, HE STOLE MILLIONS OF DOLLARS IN CLIENT'S FUNDS. THIS OCCURRED, IN PART, BECAUSE OF HIS BROKER'S FAILURE TO PROPERLY SUPERVISE HIM. i Reporting Source: Firm Current Status: Final Allegations: THE OHIO DIVISION OF SECURITIES ("DIVISION") ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED OAC RULE 1301: 6-3-15(C)(1) IN THAT IT FAILED TO KEEP ACCURATE BOOKS AND RECORDS; VIOLATED OAC RULE 1301: 6-3-15(C)(13) IN THAT IT FAILED TO MAINTAIN COMPLETE RECORDS FOR ALL OHIO BRANCH OFFICE TRANSACTIONS AND FAILED TO ESTABLISH AND KEEP CURRENT DAILY BLOTTERS AND LEDGER ACCOUNTS; AND VIOLATED OAC RULE 1301: 6-3-19(B)(9) IN THAT IT FAILED TO REASONABLY SUPERVISE FRANK GRUTTADAURIA DURING THE 15 MONTH PERIOD THAT LEHMAN EMPLOYED HIM FROM OCTOBER 2000 TO JANUARY 2002. Initiated By: OHIO DIVISION OF SECURITIES Date Initiated: 08/14/2003 Docket/Case Number: 03-174

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Undertaking Sought: Other Sanction(s)/Relief ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 183 Sought: www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 08/14/2003 Sanctions Ordered: Other Sanctions Ordered: UNDERTAKING TO PROMPTLY FILE WITH THE DIVISION A COPY OF ANY REPORTS REQUIRED TO BE SUBMITTED TO THE SECURITIES AND EXCHANGE COMMISSION (SEC) AND NEW YORK STOCK EXCHANGE (NYSE) PURSUANT TO LEHMAN'S SETTLEMENTS WITH THE SEC AND NYSE. Sanction Details: SEE ABOVE. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, LEHMAN AGREED TO THE ISSUANCE OF AN ORDER BY THE DIVISION THAT FOUND THAT LEHMAN VIOLATED OAC RULE 1301: 6-3-15(C)(1) IN THAT IT FAILED TO KEEP ACCURATE BOOKS AND RECORDS; VIOLATED OAC RULE 1301: 6-3-15(C)(13) IN THAT IT FAILED TO MAINTAIN COMPLETE RECORDS FOR ALL OHIO BRANCH OFFICE TRANSACTIONS AND FAILED TO ESTABLISH AND KEEP CURRENT DAILY BLOTTERS AND LEDGER ACCOUNTS; AND VIOLATED OAC RULE 1301: 6-3-19(B)(9) IN THAT IT FAILED TO REASONABLY SUPERVISE FRANK GRUTTADAURIA DURING THE 15 MONTH PERIOD THAT LEHMAN EMPLOYED HIM FROM OCTOBER 2000 TO JANUARY 2002 AND THAT LEHMAN MUST PROMPTLY FILE WITH THE DIVISION A COPY OF ANY REPORTS REQUIRED TO BE SUBMITTED TO THE SECURITIES AND EXCHANGE COMMISSION (SEC) AND NEW YORK STOCK EXCHANGE (NYSE) PURSUANT TO LEHMAN'S SETTLEMENTS WITH THE SEC AND NYSE. i Disclosure 92 of 359 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN PROCEEDING FILE NO. 3-11217, REL 34-48336, DATED AUGUST 14, 2003 - THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST LEHMAN BROTHERS, INC. ("RESPONDENT" OR "LEHMAN BROTHERS").IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT.

Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 08/14/2003 Docket/Case Number: SEC ADMIN FILE NO. 3-11217/REL 34-48336

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 08/14/2003 Sanctions Ordered: Censure Monetary/Fine $2,500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING Sanction Details: IT IS HEREBY ORDERED: THAT LEHMAN BROTHERS BE, AND HEREBY IS, CENSURED. PURSUANT TO SECTION 21C OF THE EXCHANGE ACT, THAT LEHMAN BROTHERS CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER. THAT LEHMAN BROTHERS SHALL, WITHIN TEN DAYS OF THE ENTRY OF THIS ORDER, PAY THE AMOUNT OF $2.5 MILLION. LEHMAN BROTHERS SHALL MAKE PAYMENTS AS FOLLOWS: (I) PURSUANT TO SECTION 21B OF THE EXCHANGE ACT, LEHMAN BROTHERS SHALL PAY A CIVIL MONETARY PENALTY OF $1,250,000 TO THE UNITED STATES TREASURY; AND (II) PURSUANT TO LEHMAN BROTHERS' AGREEMENT WITH THE NEW YORK STOCK EXCHANGE IN RELATED PROCEEDINGS, LEHMAN BROTHERS SHALL PAY A FINE IN THE AMOUNT OF $1,250,000 TO THE NEW YORK STOCK EXCHANGE. RESPONDENT UNDERTAKES TO PARTICIPATE IN A SPECIAL ARBITRATION PROCESS FOR POTENTIAL VICTIMS OF A REGISTERED REPRESENATIVE'S FRAUDULENT ACTS. IN DETERMINING WHETHER TO ACCEPT THE OFFER, THE COMMISSION HAS CONSIDERED THIS UNDERTAKING. Regulator Statement THE FAILURE OF LEHMAN BROTHERS REASONABLY TO SUPERVISE A REGISTERED REPRESENTATIVE OCCURRED IN A CONTEXT THAT ITSELF CREATED AN INHERENT RISK THAT HE WOULD NOT BE ADEQUATELY SUPERVISED. THE REP WAS A PRODUCING BOM, WHICH MEANS THAT HE WAS RESPONSIBLE BOTH FOR THE OVERALL SUPERVISION OF THE CLEVELAND BRANCH AND FOR HIS OWN RETAIL BROKERAGE ©2021 FINRA. All rights reserved. Report aboutCUSTOMERS.LEHMAN LEHMAN BROTHERS INC. BROTHERS FAILED REASONABLY TO SUPERVISE 185 THE REP'S CONDUCT AS A PRODUCING BOM. ALTHOUGH LEHMAN BROTHERS HAD PROCEDURES ADDRESSING THE REVIEW OF OUTGOING AND INCOMING CORRESPONDENCE, THE REP WAS ABLE TO EVADE THAT REVIEW BECAUSE LEHMAN BROTHERS DID NOT HAVE AN ADEQUATE SYSTEM FOR APPLYING THESE PROCEDURES TO THE INDIVIDUAL, WHO AS A PRODUCING BOM HAD ACCESS TO A FACSIMILE MACHINE AND THE OFFICE'S POSTAGE METER. THE FAILURE OF LEHMAN BROTHERS REASONABLY TO SUPERVISE A www.finra.org/brokercheck REGISTERED REPRESENTATIVE OCCURRED IN A CONTEXT THAT ITSELF User Guidance CREATED AN INHERENT RISK THAT HE WOULD NOT BE ADEQUATELY SUPERVISED. THE REP WAS A PRODUCING BOM, WHICH MEANS THAT HE WAS RESPONSIBLE BOTH FOR THE OVERALL SUPERVISION OF THE CLEVELAND BRANCH AND FOR HIS OWN RETAIL BROKERAGE CUSTOMERS.LEHMAN BROTHERS FAILED REASONABLY TO SUPERVISE THE REP'S CONDUCT AS A PRODUCING BOM. ALTHOUGH LEHMAN BROTHERS HAD PROCEDURES ADDRESSING THE REVIEW OF OUTGOING AND INCOMING CORRESPONDENCE, THE REP WAS ABLE TO EVADE THAT REVIEW BECAUSE LEHMAN BROTHERS DID NOT HAVE AN ADEQUATE SYSTEM FOR APPLYING THESE PROCEDURES TO THE INDIVIDUAL, WHO AS A PRODUCING BOM HAD ACCESS TO A FACSIMILE MACHINE AND THE OFFICE'S POSTAGE METER. i Reporting Source: Firm Current Status: Final Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED SECTION 15 (B)(4)(E) OF THE EXCHANGE ACT IN THAT IT FAILED TO REASONABLY SUPERVISE FRANK D. GRUTTADAURIA DURING THE 15 MONTH PERIOD THAT LEHMAN EMPLOYED HIM FROM OCTOBER 2000 TO JANUARY 2002. IN ADDITION, IT ALLEGED LEHMAN VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER BECAUSE LEHMAN FAILED TO MAINTAIN COMPLETE AND ACCURATE BOOKS AND RECORDS AS REQUIRED. Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION Date Initiated: 08/14/2003 Docket/Case Number: ADMINISTRATIVE PROCEEDING 3-11217

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE, CEASE AND DESIST VIOLATION OF BOOKS AND RECORDS Sought: RULES 17(A) AND 17A-3, UNDERTAKE A SPECIAL ARBITRATION PROCESS FOR POTENTIAL VICTIMS

Resolution: Decision & Order of Offer of Settlement Resolution Date: 08/14/2003 Sanctions Ordered: Censure Monetary/Fine $2,500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKING TO PARTICIPATE IN A SPECIAL ARBITRATION PROCESS FOR POTENTIAL VICTIMS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 186 www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, LEHMAN CONSENTED TO PAY $2.5 MILLION DOLLARS. HALF OF THIS AMOUNT, $1,250,000.00, WAS PAID TO THE U.S. TREASURY AS A CIVIL MONETARY PAYMENT ON AUGUST 22, 2003. THE SECOND HALF SHALL BE PAID TO THE NEW YORK STOCK EXCHANGE PURSUANT TO THE HEARING PANEL'S DECISION. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, LEHMAN CONSENTED TO THE ENTRY OF AN ORDER BY THE SEC ON AUGUST 14, 2003 IN WHICH THE SEC ACCEPTED LEHMAN'S OFFER OF SETTLEMENT AND FOUND THAT LEHMAN VIOLATED SECTION 15 (B)(4)(E) OF THE EXCHANGE ACT IN THAT IT FAILED TO REASONABLY SUPERVISE FRANK D. GRUTTADAURIA DURING THE 15 MONTH PERIOD THAT LEHMAN EMPLOYED HIM FROM OCTOBER 2000 TO JANUARY 2002. IN ADDITION, IT FOUND LEHMAN VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER BECAUSE LEHMAN FAILED TO MAINTAIN COMPLETE AND ACCURATE BOOKS AND RECORDS AS REQUIRED.

PURSUANT TO THE ORDER, LEHMAN BROTHERS IS REQUIRED TO PAY $2.5 MILLION DOLLARS. HALF OF THIS AMOUNT, $1,250,000.00, WAS PAID TO THE U.S. TREASURY AS A CIVIL MONETARY PAYMENT ON AUGUST 22, 2003. THE SECOND HALF SHALL BE PAID TO THE NEW YORK STOCK EXCHANGE PURSUANT TO THE HEARING PANEL'S DECISION. ADDITIONALLY, LEHMAN MUST PARTICIPATE IN A SPECIAL ARBITRATION PROCESS FOR POTENTIAL VICTIMS. i Disclosure 93 of 359 Reporting Source: Regulator Current Status: Final Allegations: LEHMAN BROTHERS VIOLATED ARTICLE V, SECTION 4(H) OF THE EXCHANGE CONSTITUTION (AND MEHROTRA VIOLATED EXCHANGE RULE 345(A)(4)) IN THAT BOTH LEHMAN BROTHERS AND MEHROTRA FAILED TO EXERCISE DUE DILIGENCE IN CONNECTION WITH THE EXECUTION OF AN ORDER, WHEREBY AFTER OBTAINING A PRICE FROM THE PHILADELPHIA STOCK EXCHANGE, LEHMAN BROTHERS AND MEHROTRA EXECUTED THE ORDER AT THE AMERICAN STOCK EXCHANGE AT AN INFERIOR PRICE. ADDITIONALLY, THE FIRM VIOLATED EXCHANGE RULE 320(C) IN THAT IT FAILED TO DEVELOP, MAINTAIN AND ENFORCE REASONABLE WRITTEN SUPERVISORY PROCEDURES, AND A SYSTEM FOR APPLYING THOSE PROCEDURES, RELATING TO THE FIRM'S BEST EXECUTION RESPONSIBILITIES, AND FAILED TO REASONABLY SUPERVISE AND CONTROL MEHROTRA'S ACTIVITIES TO ENSURE HIS COMPLIANCE WITH THE DUTY OF ACHIEVING THE BEST EXECUTION FOR CUSTOMER ORDERS ENTRUSTED TO HIM. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 187 LEHMAN BROTHERS VIOLATED ARTICLE V, SECTION 4(H) OF THE EXCHANGE CONSTITUTION (AND MEHROTRA VIOLATED EXCHANGE RULE 345(A)(4)) IN THAT BOTH LEHMAN BROTHERS AND MEHROTRA FAILED TO EXERCISE DUE DILIGENCE IN CONNECTION WITH THE EXECUTION OF AN ORDER, WHEREBY AFTER OBTAINING A PRICE FROM THE PHILADELPHIA STOCK EXCHANGE, LEHMAN BROTHERS AND MEHROTRA EXECUTED THE ORDER AT THE AMERICAN STOCK EXCHANGE AT AN INFERIOR PRICE. ADDITIONALLY, THE FIRM VIOLATED EXCHANGE RULE 320(C) IN THAT IT FAILED TO DEVELOP, MAINTAIN AND ENFORCE REASONABLE WRITTEN SUPERVISORY PROCEDURES, AND A SYSTEM FOR APPLYING THOSE www.finra.org/brokercheck PROCEDURES, RELATING TO THE FIRM'S BEST EXECUTION User Guidance RESPONSIBILITIES, AND FAILED TO REASONABLY SUPERVISE AND CONTROL MEHROTRA'S ACTIVITIES TO ENSURE HIS COMPLIANCE WITH THE DUTY OF ACHIEVING THE BEST EXECUTION FOR CUSTOMER ORDERS ENTRUSTED TO HIM. Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 04/23/2003 Docket/Case Number: 03-13

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief THE AMERICAN STOCK EXCHANGE WILL ALSO SEEK A CENSURE, AND Sought: POSSIBLY UNDERTAKINGS, AS A RESULT OF THIS ACTION.

Resolution: Dismissed Resolution Date: 05/27/2004 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Other Sanctions Ordered: Sanction Details: FOLLOWING THE ISSUANCE OF THE DECISION IN A RELATED MATTER BY THE BUSINESS CONDUCT COMMITTEE OF THE PHILADELPHIA STOCK EXCHANGE ("PHLX"), DATED MAY 6, 2004, IN WHICH IT RULED THAT LEHMAN BROTHERS INC. ("LEHMAN") AND ITS EMPLOYEE DID NOT VIOLATE ANY PHLX RULES, THE AMERICAN STOCK EXCHANGE ("AMEX") FILED A NOTICE OF WITHDRAWAL OF CHARGES AGAINST LEHMAN AND ITS EMPLOYEE WITH THE AMEX DISCIPLINARY PANEL. BY ORDER DATED MAY 27, 2004, THE AMEX DISCIPLINARY PANEL DISMISSED ALL CHARGES AGAINST LEHMAN AND ITS EMPLOYEE. Regulator Statement PLEASE CONTACT ERIC BROWN, SENIOR ATTORNEY IN THE ENFORCEMENT DEPARTMENT OF THE AMERICAN STOCK EXCHANGE, FOR FURTHER DETAILS. i Reporting Source: Firm Current Status: Final Allegations: ARTICLE V, SECTION 4(H) OF THE CONSTITUTION OF THE AMERICAN ©2021 FINRA. All rights reserved. Report aboutSTOCK LEHMAN EXCHANGE BROTHERS ("EXCHANGE INC. CONSTITUTION"), AND AMERICAN STOCK 188 EXCHANGE RULE 320 (C) ("EXCHANGE RULE"). www.finra.org/brokercheck User Guidance

Allegations: ARTICLE V, SECTION 4(H) OF THE CONSTITUTION OF THE AMERICAN STOCK EXCHANGE ("EXCHANGE CONSTITUTION"), AND AMERICAN STOCK EXCHANGE RULE 320 (C) ("EXCHANGE RULE"). Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 04/23/2003 Docket/Case Number: CASE NUMBER 03-13

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Withdrawn Resolution Date: 05/27/2004 Firm Statement ON APRIL 23, 2003, THE DISCIPLINARY PANEL OF THE AMERICAN STOCK EXCHANGE LLC ISSUED A STATEMENT OF CHARGES, CASE NUMBER 03-13, ALLEGING THAT LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED ARTICLE V, SECTION 4(H) OF THE EXCHANGE CONSTITUTION, AND A LEHMAN EMPLOYEE VIOLATED EXCHANGE RULE 345(A)(4), IN THAT BOTH LEHMAN AND THE EMPLOYEE FAILED TO EXERCISE DUE DILIGENCE IN CONNECTION WITH THE EXECUTION OF A LISTED OPTIONS ORDER FOR A CUSTOMER ON APRIL 24, 2002. IT WAS ALSO ALLEGED THAT LEHMAN VIOLATED EXCHANGE RULE 320(C) IN THAT IT FAILED TO (I) DEVELOP, MAINTAIN AND ENFORCE REASONABLE WRITTEN SUPERVISORY PROCEDURES, AND A SYSTEM FOR APPLYING THOSE PROCEDURES, RELATING TO THE FIRM'S RESPONSIBILITY TO ACHIEVE THE BEST EXECUTION FOR ITS CUSTOMER ORDERS, AND (II) REASONABLY SUPERVISE AND CONTROL ITS EMPLOYEE'S ACTIVITIES TO ENSURE HIS COMPLIANCE WITH THE DUTY OF ACHIEVING THE BEST EXECUTION FOR CUSTOMER ORDERS ENTRUSTED TO HIM. LEHMAN AND ITS EMPLOYEE EACH FILED AN ANSWER TO THE CHARGES ON MAY 12, 2003.

FOLLOWING THE ISSUANCE OF THE DECISION IN A RELATED MATTER BY THE BUSINESS CONDUCT COMMITTEE OF THE PHILADELPHIA STOCK EXCHANGE ("PHLX"), DATED MAY 6, 2004, IN WHICH IT RULED THAT www.finra.org/brokercheck LEHMAN BROTHERS INC. ("LEHMAN") AND ITS EMPLOYEE DID NOT User Guidance VIOLATE ANY PHLX RULES, THE AMERICAN STOCK EXCHANGE ("AMEX") FILED A NOTICE OF WITHDRAWAL OF CHARGES AGAINST LEHMAN AND ITS EMPLOYEE WITH THE AMEX DISCIPLINARY PANEL. BY ORDER DATED MAY 27, 2004, THE AMEX DISCIPLINARY PANEL DISMISSED ALL CHARGES AGAINST LEHMAN AND ITS EMPLOYEE. i Disclosure 94 of 359 Reporting Source: Regulator Current Status: Final Allegations: **04/22/2003** STIPULATION AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING. CONSENTED TO FINDINGS: (1) VIOLATED EXCHANGE RULE 476(A)(6) BY ENGAGING IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE BY: A. ENGAGING IN ACTS AND PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, THEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS, AND FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER; AND B. ISSUING RESEARCH REPORTS ON RAZORFISH, INC., RSL COMMUNICATIONS, INC., DDI CORP., REALNETWORKS, INC., AND BROADWING, INC., THAT WERE AFFECTED BY THE CONFLICTS OF INTEREST IMPOSED ON ITS RESEARCH ANALYSTS. (2) VIOLATED EXCHANGE RULE 401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THE CONDUCT OF ITS BUSINESS AFFAIRS BY: A. ENGAGING IN ACTS AND PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, THEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS, AND FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER; AND B. ISSUING RESEARCH REPORTS ON RAZORFISH, INC., RSL COMMUNICATIONS, INC., DDI CORP., REALNETWORKS, INC., AND BROADWING, INC., THAT WERE AFFECTED BY THE CONFLICTS OF INTEREST IMPOSED ON ITS RESEARCH ANALYSTS. (3) VIOLATED EXCHANGE RULE 472 RELATING TO COMMUNICATIONS WITH THE PUBLIC BY ISSUING RESEARCH REPORTS ON RAZORFISH, INC., RSL COMMUNICATIONS, INC., DDI CORP., REALNETWORKS, INC., AND BROADWING, INC., THAT CONTAINED RECOMMENDATIONS AND/OR RATINGS THAT WERE EXAGGERATED OR UNWARRANTED OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS. **CONTINUED IN #13** Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 04/22/2003 Docket/Case Number: HPD# 03-66

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 05/23/2003 Sanctions Ordered: Censure Monetary/Fine $80,000,000.00 Other Sanctions Ordered: Sanction Details: **04/22/2003** DECISION 03-66 ISSUED BY NYSE HEARING PANEL DECISION: VIOLATED EXCHANGE RULES 476(A)(6) AND 401 BY ENGAGING IN ACTS AND PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, THEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS, BY FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER, AND BY ISSUING CERTAIN RESEARCH REPORTS THAT WERE AFFECTED BY THE CONFLICTS OF INTEREST; VIOLATED EXCHANGE RULE 472 BY ISSUING CERTAIN RESEARCH REPORTS THAT CONTAINED RECOMMENDATIONS AND/OR RATING THAT WERE EXAGGERATED OR UNWARRANTED AND/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; AND VIOLATED EXCHANGE RULE 342 BY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS AND PROCEDURES FOR SUPERVISION AND CONTROL OF ITS RESEARCH AND INVESTMENT BANKING DEPARTMENTS. CONSENT TO A CENSURE, A TOTAL PAYMENT OF $80,000,000 AS SPECIFIED IN THE FINAL JUDGMENT ORDERED IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION, THE PAYMENT PROVISIONS OF WHICH ARE INCORPORATED BY REFERENCE HEREIN. OF THIS AMOUNT, $25,000,000 CONSTITUTES A PENALTY, $25,000,000 CONSTITUTES DISGORGEMENT, $25,000,000, TO BE USED FOR THE PROCUREMENT OF INDEPENDENT RESEARCH, AS DESCRIBED IN THE UNDERTAKINGS SET FORTH IN ADDENDUM A: UNDERTAKING TO THE FINAL JUDGMENT (ADDENDUM A), INCORPORATED BY REFERENCE HEREIN; AND $5,000,000, TO BE USED FOR INVESTOR EDUCATION, AS DESCRIBED IN SECTION IX OF THE FINAL JUDGMENT. IN ADDITION, THE FIRM SHALL COMPLETE AN UNDERTAKING TO ENSURE COMPLIANCE WITH THE TERMS PROVIDED IN ADDENDUM A, INCLUDING AN UNDERTAKING TO INFORM THE EXCHANGE IN WRITING THAT IT HAS POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE PROVISIONS OF ADDENDUM A. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 191 **04/22/2003** DECISION 03-66 ISSUED BY NYSE HEARING PANEL DECISION: VIOLATED EXCHANGE RULES 476(A)(6) AND 401 BY ENGAGING IN ACTS AND PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, THEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS, BY FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER, AND BY ISSUING CERTAIN RESEARCH REPORTS THAT WERE AFFECTED BY THE CONFLICTS OF INTEREST; VIOLATED EXCHANGE RULE 472 BY ISSUING CERTAIN RESEARCH REPORTS THAT CONTAINED RECOMMENDATIONS AND/OR RATING THAT WERE EXAGGERATED OR UNWARRANTED AND/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; AND VIOLATED EXCHANGE RULE 342 BY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS AND PROCEDURES FOR SUPERVISION AND CONTROL OF ITS RESEARCH AND INVESTMENT BANKING DEPARTMENTS. CONSENT TO A CENSURE, A TOTAL PAYMENT OF $80,000,000 AS SPECIFIED IN THE FINAL JUDGMENT ORDERED IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION, THE PAYMENT PROVISIONS OF WHICH ARE INCORPORATED BY REFERENCE HEREIN. OF THIS AMOUNT, $25,000,000 CONSTITUTES A PENALTY, $25,000,000 CONSTITUTES DISGORGEMENT, $25,000,000, TO BE USED FOR THE PROCUREMENT OF INDEPENDENT RESEARCH, AS DESCRIBED IN THE UNDERTAKINGS SET FORTH IN ADDENDUM A: UNDERTAKING TO THE FINAL JUDGMENT (ADDENDUM A), INCORPORATED BY REFERENCE HEREIN; AND $5,000,000, TO BE USED FOR INVESTOR EDUCATION, AS DESCRIBED IN SECTION IX OF THE FINAL JUDGMENT. IN ADDITION, THE FIRM SHALL COMPLETE AN www.finra.org/brokercheck UNDERTAKING TO ENSURE COMPLIANCE WITH THE TERMS PROVIDED IN User Guidance ADDENDUM A, INCLUDING AN UNDERTAKING TO INFORM THE EXCHANGE IN WRITING THAT IT HAS POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE PROVISIONS OF ADDENDUM A. Regulator Statement (4) VIOLATED EXCHANGE RULE 342 BY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES FOR SUPERVISION AND CONTROL OF ITS RESEARCH AND INVESTMENT BANKING DEPARTMENTS THAT WERE REASONABLY DESIGNED TO DETECT AND PREVENT THE FOREGOING INVESTMENT BANKING INFLUENCES AND CONFLICTS OF INTEREST, INCLUDING A SEPARATE SYSTEM OF FOLLOW- UP AND REVIEW TO ASSURE COMPLIANCE WITH APPLICABLE EXCHANGE RULES. STIPULATED SANCTION: THE IMPOSITION BY THE EXCHANGE OF THE SANCTION OF: 1. A CENSURE; 2. A TOTAL PAYMENT OF $80,000,000 AS SPECIFIED IN THE FINAL JUDGMENT ORDERED IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION, THE PAYMENT PROVISIONS OF WHICH ARE INCORPORATED BY REFERENCE HEREIN. A. $25,000,000, AS A PENALTY; B. $25,000,000, AS DISGORGEMENT OF COMMISSIONS, FEES AND OTHER MONIES; C. $25,000,000, TO BE USED FOR THE PROCUREMENT OF INDEPENDENT RESEARCH, AS DESCRIBED IN THE UNDERTAKINGS SET FORTH IN ADDENDUM A: UNDERTAKING TO THE FINAL JUDGMENT (ADDENDUM A), INCORPORATED BY REFERENCE HEREIN; AND D. $5,000,000, TO BE USED FOR INVESTOR EDUCATION, AS DESCRIBED IN SECTION IX OF THE FINAL JUDGMENT. 3. IN ADDITION, THE FIRM SHALL COMPLETE AN UNDERTAKING TO ENSURE COMPLIANCE WITH THE TERMS PROVIDED IN ADDENDUM A, INCLUDING AN UNDERTAKING TO INFORM THE EXCHANGE IN WRITING THAT IT HAS POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE PROVISIONS OF ADDENDUM A. **05/23/2003** THE DECISION IS NOW FINAL AND IS EFFECTIVE IMMEDIATELY. CONTACT: EVELYN PENA (212) 656-5211. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE NYSE ALLEGED THAT LEHMAN BROTHERS VIOLATED CERTAIN NYSE RULES RESULTING FROM ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: NEW YORK STOCK EXCHANGE, INC Date Initiated: 05/23/2003 Docket/Case Number: EXCHANGE HEARING PANEL DECISION 03-66

Principal Product Type: Other Other Product Type(s): EQUITY RESEARCH Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief DISGORGEMENT; CENSURE; ALLOCATION OF FUNDS FOR PROCUREMENT Sought: OF INDEPENDENT RESEARCH AND INVESTOR EDUCATION

Resolution: Stipulation and Consent Resolution Date: 05/23/2003 Sanctions Ordered: Censure Monetary/Fine $25,000,000.00 Disgorgement/Restitution Other Sanctions Ordered: ALLOCATION OF FUNDS FOR PROCUREMENT OF INDEPENDENT RESEARCH AND INVESTOR EDUCATION. Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS OR FINDINGS, LEHMAN BROTHERS CONSENTED: (I) TO A CENSURE; AND (II) TO PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT"), IN WHICH, AMONG OTHER THINGS, LEHMAN BROTHERS AGREED TO PAY A TOTAL OF $80,000,000 ($25,000,000 AS A PENALTY, $25,000,000 AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25,000,000 OVER FIVE YEARS FOR THE PROCUREMENT OF INDEPENDENT RESEARCH, AND $5,000,000 FOR INVESTOR EDUCATION.) PAYMENT WILL BE MADE IN CONFORMANCE WITH THE PAYMENT PROVISIONS OF THE FINAL JUDGMENT, ONCE ENTERED. Firm Statement WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS OR FINDINGS, LEHMAN BROTHERS ENTERED INTO A STIPULATION AND CONSENT WITH THE NYSE IN WHICH LEHMAN BROTHERS AGREED TO (I) PAY THE AMOUNT SPECIFIED IN CONFORMITY WITH THE TERMS OF THE FINAL JUDGMENT; AND (II) A CENSURE. ON MAY 23, 2003, THE NYSE ADVISED LEHMAN BROTHERS THAT THE HEARING PANEL'S DECISION, IN WHICH IT ACCEPTED THE STIPULATION AND CONSENT, HAD BECOME FINAL. i Disclosure 95 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 2210(D)(1), 2210(D)(1)(2), 3010(A) – RESPONDENT MEMBER ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR ©2021 FINRA. All rights reserved. Report aboutMAINTAINED LEHMAN BROTHERS INAPPROPRIATE INC. INFLUENCE BY INVESTMENT BANKING OVER 193 RESEARCH ANALYSTS AND THEREFORE IMPOSED CONFLICTS OF INTEREST ON RESEARCH ANALYSTS AND FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE AND APPROPRIATE MANNER; ISSUED RESEARCH REPORTS THAT WERE NOT BASED ON PRINCIPLES OF FAIR DEALING AND GOOD FAITH AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS, CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS ABOUT THESE COMPANIES, AND/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; AND FAILED TO ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES TO PROTECT RESEARCH ANALYSTS FROM CONFLICTS OF INTEREST, FAILED TO IMPLEMENT A SYSTEM TO DETECT AND INSULATE ITS RESEARCH ANALYSTS FROM IMPROPER INFLUENCE AND PRESSURE BY INVESTMENT BANKING PERSONNEL AND, INSTEAD, MOTIVATED RESEARCH ANALYSTS TO ISSUE RESEARCH THAT WOULD ATTRACT AND RETAIN INVESTMENT BANKING BUSINESS. www.finra.org/brokercheck User Guidance

NASD RULES 2110, 2210(D)(1), 2210(D)(1)(2), 3010(A) – RESPONDENT MEMBER ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS AND THEREFORE IMPOSED CONFLICTS OF INTEREST ON RESEARCH ANALYSTS AND FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE AND APPROPRIATE MANNER; ISSUED RESEARCH REPORTS THAT WERE NOT BASED ON PRINCIPLES OF FAIR DEALING AND GOOD FAITH AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS, CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS ABOUT THESE COMPANIES, AND/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; AND FAILED TO ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES TO PROTECT RESEARCH ANALYSTS FROM CONFLICTS OF INTEREST, FAILED TO IMPLEMENT A SYSTEM TO DETECT AND INSULATE ITS RESEARCH ANALYSTS FROM IMPROPER INFLUENCE AND PRESSURE BY INVESTMENT BANKING PERSONNEL AND, INSTEAD, MOTIVATED RESEARCH ANALYSTS TO ISSUE RESEARCH THAT WOULD ATTRACT AND RETAIN INVESTMENT BANKING BUSINESS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/24/2003 Docket/Case Number: CAF030021

Principal Product Type: Other Other Product Type(s): RESEARCH Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/24/2003 Sanctions Ordered: Censure Monetary/Fine $25,000,000.00 Disgorgement/Restitution Other Sanctions Ordered: PAYMENT OF $25,000,000 FOR THE PROCUREMENT OF INDEPENDENT RESEARCH, AND $5,000,000 TO BE USED FOR INVESTOR EDUCATION Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS, INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, REQUIRED TO PAY $80,000,000 AS SPECIFIED IN THE FINAL JUDGMENT ORDERED IN A RELATED ACTION FILED BY THE SEC WHICH INCLUDES A FINE OF $25,000,000, DISGORGEMENT OF $25,000,000 IN COMMISSIONS, FEES AND OTHER MONIES, PAYMENT OF $25,000,000 FOR THE ©2021 FINRA. All rights reserved. Report aboutPROCUREMENT LEHMAN BROTHERS OF INDEPENDENT INC. RESEARCH, AND $5,000,000 TO BE 194 USED FOR INVESTOR EDUCATION. THE MONETARY SANCTIONS IMPOSED BY NASD SHALL BE REDUCED BY THE AMOUNTS PAID BY RESPONDENT PURSUANT TO THE FINAL JUDGMENT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS, INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, www.finra.org/brokercheck REQUIRED TO PAY $80,000,000 AS SPECIFIED IN THE FINAL JUDGMENT User Guidance ORDERED IN A RELATED ACTION FILED BY THE SEC WHICH INCLUDES A FINE OF $25,000,000, DISGORGEMENT OF $25,000,000 IN COMMISSIONS, FEES AND OTHER MONIES, PAYMENT OF $25,000,000 FOR THE PROCUREMENT OF INDEPENDENT RESEARCH, AND $5,000,000 TO BE USED FOR INVESTOR EDUCATION. THE MONETARY SANCTIONS IMPOSED BY NASD SHALL BE REDUCED BY THE AMOUNTS PAID BY RESPONDENT PURSUANT TO THE FINAL JUDGMENT. Regulator Statement RESPONDENT AGREES THAT IT SHALL NOT SEEK OR ACCEPT, DIRECTLY OR INDIRECTLY, REIMBURSEMENT OR INDEMNIFICATION, INCLUDING BUT NOT LIMITED TO PAYMENT MADE PURSUANT TO ANY INSURANCE POLICY, WITH REGARD TO ANY FINE/PENALTY AMOUNTS THAT RESPONDENT SHALL PAY PURSUANT TO SECTION II OF THE FINAL JUDGMENT, REGARDLESS OF WHETHER SUCH FINE/PENALTY AMOUNTS OR ANY PART THEREOF ARE ADDED TO THE DISTRIBUTION FUND ACCOUNT OR OTHERWISE USED FOR THE BENEFIT OF INVESTORS. RESPONDENT FURTHER AGREES THAT IT SHALL NOT CLAIM, ASSET, OR APPLY FOR A TAX DEDUCTION OR TAX CREDIT WITH REGARD TO ANY FEDERAL, STATE, OR LOCAL TAX FOR ANY FINE/PENALTY AMOUNTS THAT RESPONDENT SHALL PAY PURSUANT TO SECTION II OF THE FINAL JUDGMENT, REGARDLESS OF WHETHER SUCH FINE/PENALTY AMOUNTS OR ANY PART THEREOF ARE ADDED TO THE DISTRIBUTION FUND ACCOUNT OR OTHERWISE USED FOR THE BENEFIT OF INVESTORS. RESPONDENT UNDERSTANDS AND ACKNOWLEDGES THAT THESE PROVISIONS ARE NOT INTENDED TO IMPLY THAT NASD WOULD AGREE THAT ANY OTHER AMOUNTS RESPONDENT SHALL PAY PURSUANT TO THE FINAL JUDGMENT MAY BE REIMBURSED OR INDEMNIFIED (WHETHER PURSUANT TO AN INSURANCE POLICY OR OTHERWISE) UNDER APPLICABLE LAW OR MAY BE THE BASIS FOR ANY TAX DEDUCTION OR TAX CREDIT WITH REGARD TO ANY FEDERAL, STATE, OR LOCAL TAX. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES, INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE NASD ALLEGED THAT LEHMAN BROTHERS VIOLATED CERTAIN NASD RULES RESULTING FROM ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/24/2003 Docket/Case Number: CAF030021

Principal Product Type: Other Other Product Type(s): EQUITY RESEARCH Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief DISGORGEMENT; CENSURE; ALLOCATION OF FUNDS FOR PROCUREMENT Sought: OF INDEPENDENT RESEARCH AND INVESTOR EDUCATION

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/24/2003 Sanctions Ordered: Censure Monetary/Fine $25,000,000.00 Disgorgement/Restitution Other Sanctions Ordered: ALLOCATION OF FUNDS FOR PROCUREMENT OF INDEPENDENT RESEARCH AND INVESTOR EDUCATION Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS OR FINDINGS, LEHMAN BROTHERS CONSENTED: (I) TO A CENSURE; AND (II) TO PAY AMOUNTS SPECIFIED IN A FINAL JUDGMENT IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION ("FINAL JUDGMENT"), IN WHICH, AMONG OTHER THINGS, LEHMAN BROTHERS AGREED TO PAY A TOTAL OF $80,000,000 ($25,000,000 AS A PENALTY, $25,000,000 AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25,000,000 OVER FIVE YEARS FOR THE PROCUREMENT OF INDEPENDENT RESEARCH, AND $5,000,000 FOR INVESTOR EDUCATION.) PAYMENT WILL BE MADE IN CONFORMANCE WITH THE PAYMENT PROVISIONS OF THE FINAL JUDGMENT, ONCE ENTERED. Firm Statement WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS OR FINDINGS, LEHMAN BROTHERS ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, ACCEPTED BY THE NASD ON APRIL 24, 2003, IN WHICH LEHMAN BROTHERS AGREED TO (I) PAY THE AMOUNT SPECIFIED IN CONFORMITY WITH THE TERMS OF THE FINAL JUDGMENT; AND (II) A CENSURE. i Disclosure 96 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULE 2110, NASD MARKETPLACE RULE 6740, AND SEC RULE 15C2-11 - RESPONDENT MEMBER PUBLISHED QUOTATIONS FOR AN OTC EQUITY SECURITY, OR, DIRECTLY OR INDIRECTLY, SUBMITTED SUCH QUOTATIONS FOR PUBLICATION, IN A QUOTATION MEDIUM, THAT IS, INSTINET CORPORATION, AND: DID NOT HAVE IN ITS REOCRDS THE ©2021 FINRA. All rights reserved. Report aboutDOCUMENTATION LEHMAN BROTHERS REQUIRED INC. BY SEC RULE 15C2-11(A), DID NOT HAVE A 196 REASONABLE BASIS UNDER THE CIRUMSTANCES FOR BELIEVING THAT THE INFORMATIONW WAS ACCURATE IN ALL MATERIAL RESPECTS, OR DID NOT HAVE A REASONABLE BASIS UNDER THE CIRCUMSTANCES FOR BELIEVING THAT THE SOURCES OF THE INFORMATION WERE RELIABLE. THE QUOTATIONS DID NOT REPRESENT A CUSTOMER'S INDICATION OF UNSOLICITED INTEREST; AND, FAILED TO FILE A FORM 211 WITH NASD AT LEAST 3 BUSINESS DAYS BEFORE THE FIRM'S QUOTATIONS IN SUCH SECURITY WERE PUBLISHED OR DISPLAYED IN A QUOTATION MEDIUM. www.finra.org/brokercheck NASD CONDUCT RULE 2110, NASD MARKETPLACE RULE 6740, AND SEC User Guidance RULE 15C2-11 - RESPONDENT MEMBER PUBLISHED QUOTATIONS FOR AN OTC EQUITY SECURITY, OR, DIRECTLY OR INDIRECTLY, SUBMITTED SUCH QUOTATIONS FOR PUBLICATION, IN A QUOTATION MEDIUM, THAT IS, INSTINET CORPORATION, AND: DID NOT HAVE IN ITS REOCRDS THE DOCUMENTATION REQUIRED BY SEC RULE 15C2-11(A), DID NOT HAVE A REASONABLE BASIS UNDER THE CIRUMSTANCES FOR BELIEVING THAT THE INFORMATIONW WAS ACCURATE IN ALL MATERIAL RESPECTS, OR DID NOT HAVE A REASONABLE BASIS UNDER THE CIRCUMSTANCES FOR BELIEVING THAT THE SOURCES OF THE INFORMATION WERE RELIABLE. THE QUOTATIONS DID NOT REPRESENT A CUSTOMER'S INDICATION OF UNSOLICITED INTEREST; AND, FAILED TO FILE A FORM 211 WITH NASD AT LEAST 3 BUSINESS DAYS BEFORE THE FIRM'S QUOTATIONS IN SUCH SECURITY WERE PUBLISHED OR DISPLAYED IN A QUOTATION MEDIUM. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/06/2003 Docket/Case Number: CMS030022

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/06/2003 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: WITHIN 30 DAYS OF THE ACCEPTANCE OF THIS AWC, A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO NASD A SIGNED, DATED LETTER, PROVIDING A REFERENCE TO THIS MATTER, A REPRESENTATION THAT THE FIRM HAS REVISED ITS WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THE DEFICIENCIES CONCERNING SEC RULE 15C2-11 AND NASD MARKETPLACE RULE 6740, AND THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS FINED $5,000 AND WITHIN 30 DAYS OF THE ACCEPTANCE OF THIS AWC, A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO NASD A SIGNED, DATED LETTER, PROVIDING A REFERENCE TO THIS MATTER, A REPRESENTATION THAT THE FIRM HAS REVISED ITS WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THE DEFICIENCIES CONCERNING SEC RULE 15C2-11 AND NASD MARKETPLACE RULE 6740, AND THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 197 WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS FINED $5,000 AND WITHIN 30 DAYS OF THE ACCEPTANCE OF THIS AWC, A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO NASD A SIGNED, DATED LETTER, PROVIDING A www.finra.org/brokercheck REFERENCE TO THIS MATTER, A REPRESENTATION THAT THE FIRM HAS User Guidance REVISED ITS WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THE DEFICIENCIES CONCERNING SEC RULE 15C2-11 AND NASD MARKETPLACE RULE 6740, AND THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED. i Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED SECURITIES EXCHANGE ACT RULE ("RULE") 15C2-11, NASD MARKETPLACE RULE 6740, AND NASD CONDUCT RULE 2110. Initiated By: NASD - NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC Date Initiated: 02/06/2003 Docket/Case Number: CMS030022 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/10/2003 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: AN UNDERTAKING TO REVISE LEHMAN'S WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THE DEFICIENCIES CONCERNING RULE 15C2- 11 AND NASD MARKETPLACE RULE 6740. Sanction Details: IN ADDITION TO THE $5,000 FINE, A REGISTERED PRINCIPAL OF LEHMAN SHALL SUBMIT TO THE NASD A SIGNED, DATED LETTER, PROVIDING THE FOLLOWING INFORMATION: 1) A REFERENCE TO THIS MATTER; 2) A REPRESENTATION THAT THE FIRM HAS REVISED ITS WRITTEN SUPERVISORY PROCEDURE TO ADDRESS THE DEFICIENCIES CONCERNING RULE 15C2-11 AND NASD MARKETPLACE RULE 6740; AND, 3) THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO THE FINDINGS THAT ON JUNE 3, 2002, LEHMAN PUBLISHED QUOTATIONS FOR ADELPHIA, AN OTC EQUITY SECURITY, OR, DIRECTLY OR INDIRECTLY, SUBMITTED SUCH QUOTATIONS FOR PUBLICATION, IN A QUOTATION MEDIUM, AND EITHER, DID NOT HAVE IN ITS RECORDS THE DOCUMENTATION REQUIRED BY RULE 15C2-11; DID NOT HAVE A REASONABLE BASIS UNDER THE CIRCUMSTANCES FOR ©2021 FINRA. All rights reserved. Report aboutBELIEVING LEHMAN BROTHERSTHAT THE INC. INFORMATION WAS ACCURATE IN ALL MATERIAL 198 RESPECTS; OR DID NOT HAVE A REASONABLE BASIS UNDER THE CIRCUMSTANCES FOR BELIEVING THAT THE SOURCES OF THE INFORMATION WAS RELIABLE. THE ORDERS DID NOT REPRESENT A CUSTOMER'S UNSOLICITED INDICATION OF INTEREST. ADDITIONALLY, IT WAS FOUND THAT LEHMAN FAILED TO FILE A FORM 211 WITH THE NASD AT LEAST THREE BUSINESS DAYS BEFORE THE FIRM'S QUOTATIONS IN SUCH SECURITY WERE PUBLISHED OR DISPLAYED IN A QUOTATION MEDIUM. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO THE FINDINGS THAT ON JUNE 3, 2002, LEHMAN PUBLISHED QUOTATIONS FOR ADELPHIA, AN OTC EQUITY SECURITY, OR, www.finra.org/brokercheck DIRECTLY OR INDIRECTLY, SUBMITTED SUCH QUOTATIONS FOR User Guidance PUBLICATION, IN A QUOTATION MEDIUM, AND EITHER, DID NOT HAVE IN ITS RECORDS THE DOCUMENTATION REQUIRED BY RULE 15C2-11; DID NOT HAVE A REASONABLE BASIS UNDER THE CIRCUMSTANCES FOR BELIEVING THAT THE INFORMATION WAS ACCURATE IN ALL MATERIAL RESPECTS; OR DID NOT HAVE A REASONABLE BASIS UNDER THE CIRCUMSTANCES FOR BELIEVING THAT THE SOURCES OF THE INFORMATION WAS RELIABLE. THE ORDERS DID NOT REPRESENT A CUSTOMER'S UNSOLICITED INDICATION OF INTEREST. ADDITIONALLY, IT WAS FOUND THAT LEHMAN FAILED TO FILE A FORM 211 WITH THE NASD AT LEAST THREE BUSINESS DAYS BEFORE THE FIRM'S QUOTATIONS IN SUCH SECURITY WERE PUBLISHED OR DISPLAYED IN A QUOTATION MEDIUM. i Disclosure 97 of 359 Reporting Source: Firm Current Status: Final Allegations: THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN VIOLATION OF REGULATION 1049.02 FOR INACCURATELY REPORTING TO THE CLEARING HOUSE ITS CORN, WHEAT AND SOYBEAN OIL CONTACT POSITIONS THAT WERE ELIGIBLE FOR DELIVERY. Initiated By: CHICAGO BOARD OF TRADE - BUSINESS CONDUCT COMMITTEE Date Initiated: 11/20/2002 Docket/Case Number: 2002 - MSI-34

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 01/13/2003 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $2,500 WHICH WAS PAID ON JANUARY 13, 2003. Firm Statement WITHOUT ADMITTING OR DENYING ANY VIOLATION, LEHMAN MADE AN OFFER OF SETTLEMENT. THE CBOT BUSINESS CONDUCT COMMITTEE ACCEPTED THE OFFER OF SETTLEMENT AND RENDERED A DECISION, DATED DECEMBER 27, 2002, ORDERING LEHMAN TO PAY A FINE IN THE ©2021 FINRA. All rights reserved. Report aboutSUM LEHMAN OF $2,500.00. BROTHERS THE INC. FINE WAS PAID ON JANUARY 13, 2003. 199 www.finra.org/brokercheck WITHOUT ADMITTING OR DENYING ANY VIOLATION, LEHMAN MADE AN User Guidance OFFER OF SETTLEMENT. THE CBOT BUSINESS CONDUCT COMMITTEE ACCEPTED THE OFFER OF SETTLEMENT AND RENDERED A DECISION, DATED DECEMBER 27, 2002, ORDERING LEHMAN TO PAY A FINE IN THE SUM OF $2,500.00. THE FINE WAS PAID ON JANUARY 13, 2003. i Disclosure 98 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 4632(A)(9), 4632(C)(5), 4642(C)(5), 6620, 6620(A), 6620(A)(6) - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH AUTOMATED CONFIRMATION TRANSACTION SERVICE (?ACT?) LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET ("NNM"), NASDAQ SMALLCAP SECURITIES ("SC") AND OTC EQUITY SECURITIES. THIS CONDUCT CONSTITUTES A PATTERN AND PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES. NASD FOUND THAT FIRM FAILED TO REPORT THE CORRECT TIME OF EXECUTION THROUGH ACT IN LATE, LAST SALE REPORTS OF TRANSACTIONS IN NNM AND SC SECURITIES. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT THE CORRECT PRIOR REFERENCE TIME THROUGH ACT IN REPORTS OF TRANSACTIONS IN NNM SECURITIES DESIGNATED AS ".PRP." THE FINDINGS ALSO STATED THAT THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE THROUGH ACT SUCH LAST SALE REPORTS AS LATE. IN ADDITION, NASD FOUND THAT FIRM INCORRECTLY DESIGNATED AS ".SLD" THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES REPORTED TO ACT WITHIN 90 SECONDS OF EXECUTION. FURTHERMORE, THE FIRM FAILED TO REPORT THE CORRECT PRIOR REFERENCE TIME THROUGH ACT IN TWO REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES DESIGNATED AS ".PRP." Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/12/2002 Docket/Case Number: CMS020195

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/12/2002 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A $15,000 FINE. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN VIOLATION OF RULES 2110, 4632(A)(9), 4632(C)(5), 4642(C)(5), 6620, 6620(A), 6620(A)(6). Initiated By: NATIONAL ASSOCIATION SECURITIES DEALERS REGULATION, INC. Date Initiated: 11/12/2002 Docket/Case Number: CMS020195

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/12/2002 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $15,000 WHICH WAS PAID ON DECEMBER 9, 2002. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO THE FINDINGS THAT BETWEEN JANUARY 2, 2001 AND JUNE 29, 2001 IT FAILED, WITHIN 90 SECONDS OF EXECUTION, TO TRANSMIT THROUGH THE AUTOMATED CONFIRMATION TRANSACTION SERVICE ("ACT") LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET ("NNM"), NASDAQ SMALLCAP ("SC") AND OVER-THE- ©2021 FINRA. All rights reserved. Report aboutCOUNTER LEHMAN ("OTC") BROTHERS EQUITY INC. SECURITIES. THE FINDINGS ALSO STATE 201 LEHMAN FAILED TO REPORT THE CORRECT TIME OF EXECUTION THROUGH ACT IN LATE LAST REPORTS OF TRANSACTIONS IN NNM AND SC SECURITIES. THE FINDINGS FURTHER STATE THE FIRM FAILED TO REPORT THE CORRECT PRIOR REFERENCE TIME THROUGH ACT IN REPORTS OF TRANSACTIONS IN NNM AND OTC EQUITY SECURITIES DESIGNATED AS ".PRP". THE NASD FOUND THAT LEHMAN FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE SUCH REPORTS AS LATE. THE NASD FURTHER FOUND THAT LEHMAN INCORRECTLY DESIGNATED AS ".SDL" THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES REPORTED TO ACT WITHIN 90 SECONDS OF EXECUTION. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN www.finra.org/brokercheck CONSENTED TO THE FINDINGS THAT BETWEEN JANUARY 2, 2001 AND User Guidance JUNE 29, 2001 IT FAILED, WITHIN 90 SECONDS OF EXECUTION, TO TRANSMIT THROUGH THE AUTOMATED CONFIRMATION TRANSACTION SERVICE ("ACT") LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET ("NNM"), NASDAQ SMALLCAP ("SC") AND OVER-THE- COUNTER ("OTC") EQUITY SECURITIES. THE FINDINGS ALSO STATE LEHMAN FAILED TO REPORT THE CORRECT TIME OF EXECUTION THROUGH ACT IN LATE LAST REPORTS OF TRANSACTIONS IN NNM AND SC SECURITIES. THE FINDINGS FURTHER STATE THE FIRM FAILED TO REPORT THE CORRECT PRIOR REFERENCE TIME THROUGH ACT IN REPORTS OF TRANSACTIONS IN NNM AND OTC EQUITY SECURITIES DESIGNATED AS ".PRP". THE NASD FOUND THAT LEHMAN FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE SUCH REPORTS AS LATE. THE NASD FURTHER FOUND THAT LEHMAN INCORRECTLY DESIGNATED AS ".SDL" THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES REPORTED TO ACT WITHIN 90 SECONDS OF EXECUTION. i Disclosure 99 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 2320, 3370, 6130(D), AND SEC RULES 10B-10 AND 11AC1- 4 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED, IN TRANSACTIONS FOR OR WITH A CUSTOMER, TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. RESPONDENT ALSO FAILED TO EXECUTE AN ORDER FULLY AND PROMPTLY. FURTHER, RESPONDENT EXECUTED SHORT SALE ORDERS IN CERTAIN SECURITIES AND FAILED TO MAINTAIN A WRITTEN RECORD OF THE AFFIRMATIVE DETERMINATION MADE FOR SUCH ORDERS. IN ADDITION, THE RESPONDENT ALSO EXECUTED SHORT SALE TRANSACTIONS AND FAILED TO REPORT EACH OF THESE TRANSACTIONS TO ACT WITH A SHORT SALE MODIFIER. RESPONDENT ALSO FAILED TO DISCLOSE ON CUSTOMER CONFIRMATIONS THAT THE DISCLOSED PRICE WAS AN AVERAGE PRICE, AND TO REFERENCE THE REQUIRED AVERAGE PRICE LEGEND THAT DETAILS OF THE TRANSACTIONS WOULD BE PROVIDED UPON REQUEST. THE RESPONDENT FAILED TO DISPLAY IMMEDIATELY THE CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM?S BID OR OFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM?S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER IN SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH ITS BID OR OFFER IN EACH SUCH SECURITY. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 202 NASD RULES 2110, 2320, 3370, 6130(D), AND SEC RULES 10B-10 AND 11AC1- 4 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED, IN TRANSACTIONS FOR OR WITH A CUSTOMER, TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. RESPONDENT ALSO FAILED TO EXECUTE AN ORDER FULLY AND PROMPTLY. FURTHER, RESPONDENT EXECUTED SHORT SALE ORDERS IN CERTAIN SECURITIES AND FAILED TO MAINTAIN A WRITTEN RECORD OF THE AFFIRMATIVE DETERMINATION MADE FOR SUCH ORDERS. IN ADDITION, THE RESPONDENT ALSO EXECUTED SHORT SALE TRANSACTIONS AND FAILED TO REPORT EACH OF THESE TRANSACTIONS TO ACT WITH A SHORT SALE MODIFIER. RESPONDENT ALSO FAILED TO DISCLOSE ON CUSTOMER CONFIRMATIONS THAT THE DISCLOSED PRICE WAS AN AVERAGE PRICE, AND TO REFERENCE THE REQUIRED AVERAGE PRICE LEGEND THAT DETAILS OF THE TRANSACTIONS WOULD BE PROVIDED UPON REQUEST. THE RESPONDENT FAILED TO DISPLAY IMMEDIATELY THE CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM?S www.finra.org/brokercheck BID OR OFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER WAS User Guidance PRICED EQUAL TO THE FIRM?S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER IN SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH ITS BID OR OFFER IN EACH SUCH SECURITY. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/28/2002 Docket/Case Number: CMS020113

Principal Product Type: Other Other Product Type(s): UNKNOWN TYPE OF SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/28/2002 Sanctions Ordered: Censure Monetary/Fine $23,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: A CENSURE, A FINE OF $23,000 (COMPOSED OF A $5,000 FINE FOR THE BEST EXECUTION VIOLATIONS, A $2,000 FINE FOR THE SHORT SALE RULE VIOLATIOS, A $2,000 FINE FOR THE ACT REPORTING VIOLATIONS, A $2,000 FINE FOR THE RULE 10B-10 VIOLATIONS, AND A $12,000 FINE FOR THE LIMIT ORDER DISPLAY RULE VIOLATIONS), AND RESTITUTION IN THE TOTAL AMOUNT OF $568.75, PLUS INTEREST FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THE DATE THIS ACCEPTANCE, WAIVER AND CONSENT ("AWC") IS ACCEPTED BY THE NASD. A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION, TO THE NASD NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. IF FOR ANY REASON, RESPONDENT CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, OR SUCH ADDITIONAL PERIOD AGREED TO BY THE NASD, RESPONDENT SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE ESCHEAT, UNCLAIMED-PROPERTY OR ABANDONED- PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LAST RESIDED. i Reporting Source: Firm

Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN VIOLATION OF SEC RULES 10B-10 AND 11AC1-4, AND NASD CONDUCT RULES 2110, 2320, 3370 AND 6130(D). Initiated By: NASD REGULATION INC Date Initiated: 06/28/2002 Docket/Case Number: CMS020113 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE; RESTITUTION Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/28/2002 Sanctions Ordered: Censure Monetary/Fine $23,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $23,000 WHICH WAS PAID ON JULY 23, 2002. THE AMOUNT OF THE RESTITUTION IS $568.75, PLUS INTEREST, WHICH WILL BE PAID IN ACCORDANCE WITH THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO THE ENTRY OF FINDINGS THAT, IN CERTAIN INSTANCES ON DECEMBER 11, 2001 AND/OR DECEMBER 12, 2001, THE FIRM: (I) FAILED TO OBTAIN BEST EXECUTIONS IN VIOLATION OF NASD CONDUCT RULES 2110 AND 2320; (II) EXECUTED SHORT SALES AND FAILED TO MAINTAIN A WRITTEN RECORD OF THE AFFIRMATIVE DETERMINATION IN VIOLATION OF NASD CONDUCT RULE 3370; (III) EXECUTED SHORT SALE TRANSACTIONS AND FAILED TO REPORT THOSE TRANSACTIONS TO ACT WITH A SHORT SALE MODIFIER IN VIOLATION OF NASD CONDUCT RULE 6130(D); (IV) FAILED TO DISCLOSE THAT THE DISCLOSED PRICE ON CERTAIN TRANSACTIONS WERE AVERAGE PRICES AND TO REFERENCE THE REQUIRED AVERAGE PRICE LEGEND THAT DETAILS WOULD BE PROVIDED UPON REQUEST IN VIOLATION OF SEC RULE 10B-10; AND (V) DID NOT DISPLAY IMMEDIATELY CERTAIN CUSTOMER LIMIT ORDERS IN VIOLATION OF SEC RULE 11 AC1-4. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 204 WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO THE ENTRY OF FINDINGS THAT, IN CERTAIN INSTANCES ON DECEMBER 11, 2001 AND/OR DECEMBER 12, 2001, THE FIRM: (I) FAILED TO OBTAIN BEST EXECUTIONS IN VIOLATION OF NASD CONDUCT RULES 2110 AND 2320; (II) EXECUTED SHORT SALES AND FAILED TO MAINTAIN A WRITTEN RECORD OF THE AFFIRMATIVE DETERMINATION IN VIOLATION OF NASD CONDUCT RULE 3370; (III) EXECUTED SHORT SALE TRANSACTIONS AND FAILED TO REPORT THOSE TRANSACTIONS TO ACT WITH A SHORT SALE MODIFIER IN VIOLATION OF NASD CONDUCT RULE 6130(D); (IV) FAILED TO DISCLOSE THAT THE DISCLOSED PRICE ON www.finra.org/brokercheck CERTAIN TRANSACTIONS WERE AVERAGE PRICES AND TO REFERENCE User Guidance THE REQUIRED AVERAGE PRICE LEGEND THAT DETAILS WOULD BE PROVIDED UPON REQUEST IN VIOLATION OF SEC RULE 10B-10; AND (V) DID NOT DISPLAY IMMEDIATELY CERTAIN CUSTOMER LIMIT ORDERS IN VIOLATION OF SEC RULE 11 AC1-4. i Disclosure 100 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110 AND NASD MARKETPLACE RULES 6954 AND 6955 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT ALL APPLICABLE ORDER INFORMATION REQUIRED TO BE RECORDED UNDER NASD MARKETPLACE RULE TO ORDER AUDIT TRAIL SYSTEM ("OATS"). RESPONDENT MEMBER FAILED TO USE THE CORRECT ACRONYM FOR THE DESTINATION OF 10,989 ROUTE REPORTS TO OATS ON 18 BUSINESS DAYS. THE RESPONDENT MEMBER DID NOT CORRECT OR REPLACE THE SUBJECT REPORTS AND THUS, FAILED TO CORRECTLY REPORT SUCH INFORMATION TO OATS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/28/2002 Docket/Case Number: CMS020116

Principal Product Type: Other Other Product Type(s): UNKNOWN TYPE OF SECURITIES. Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/28/2002 Sanctions Ordered: Censure Monetary/Fine $9,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $9,000. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN ©2021 FINRA. All rights reserved. Report aboutVIOLATION LEHMAN BROTHERSOF NASD INC.MARKETPLACE RULE 6955, AND NASD CONDUCT 205 RULE 2110. www.finra.org/brokercheck User Guidance

Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN VIOLATION OF NASD MARKETPLACE RULE 6955, AND NASD CONDUCT RULE 2110. Initiated By: NASD REGULATION INC Date Initiated: 06/28/2002 Docket/Case Number: CMS020116 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/28/2002 Sanctions Ordered: Censure Monetary/Fine $9,000.00 Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $9,000 WHICH WAS PAID ON JULY 23, 2002. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO THE ENTRY OF FINDINGS THAT: 1) DURING THE PERIODS OCTOBER 18, 1999 THROUGH NOVEMBER 12, 1999 AND DECEMBER 1, 1999 THROUGH DECEMBER 31, 1999 LEHMAN FAILED TO REPORT ALL APPLICABLE ORDER INFORMATION REQUIRED TO BE RECORDED UNDER NASD MARKETPLACE RULE 6954 TO OATS, AND 2) FOR THE PERIOD SEPTEMBER 5, 2000 THROUGH SEPTEMBER 29, 2000, LEHMAN FAILED TO CORRECTLY REPORT CERTAIN INFORMATION TO OATS, IN VIOLATION OF NASD MARKETPLACE RULE 6955 AND NASD CONDUCT RULE 2110. i Disclosure 101 of 359 Reporting Source: Regulator Current Status: Final Allegations: NASD RULE 3320, NASD MARKETPLACE RULE 4613(B) AND SEC RULE 11AC1-1 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT RESPONDENT MEMBER, A MARKET MAKER IN THE RELEVANT SECURITIES, FAILED TO EXECUTE THE ORDERS UPON PRESENTMENT AND THEREBY FAILED TO HONOR ITS PUBLISHED QUOTATION. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 206 NASD RULE 3320, NASD MARKETPLACE RULE 4613(B) AND SEC RULE 11AC1-1 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE www.finra.org/brokercheck RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT User Guidance RESPONDENT MEMBER, A MARKET MAKER IN THE RELEVANT SECURITIES, FAILED TO EXECUTE THE ORDERS UPON PRESENTMENT AND THEREBY FAILED TO HONOR ITS PUBLISHED QUOTATION. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/28/2002 Docket/Case Number: CMS020114

Principal Product Type: Other Other Product Type(s): UNKNOWN TYPE OF SECURITIES. Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/28/2002 Sanctions Ordered: Censure Monetary/Fine $9,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $9,000. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN VIOLATION OF SEC RULE 11AC1-1, NASD CONDUCT RULE 3320 AND NASD MARKETPLACE RULE 4613(B). Initiated By: NASD REGULATION, INC. Date Initiated: 06/28/2002 Docket/Case Number: CMS020114 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC)

Resolution Date: 06/28/2002 Sanctions Ordered: Censure Monetary/Fine $9,000.00 Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $9,000 WHICH WAS PAID ON JULY 23, 2002. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO THE ENTRY OF FINDINGS THAT IN CERTAIN INSTANCES DURING THE PERIOD BETWEEN APRIL 2, 2001 AND JUNE 29, 2001, LEHMAN FAILED TO EXECUTE ORDERS UPON PRESENTMENT AND THEREBY FAILED TO HONOR ITS PUBLISHED QUOTATIONS IN VIOLATION OF SEC RULE 11AC1-1; NASD CONDUCT RULE 3320 AND NASD MARKETPLACE RULE 4613(B). i Disclosure 102 of 359 Reporting Source: Firm Current Status: Final Allegations: THE CHICAGO MERCANTILE EXCHANGE, INC. (CME) ALLEGED LEHMAN BROTHERS, INC. (LEHMAN) VIOLATED ITS RULE 536 BY EXCEEDING A 10% EXCEPTION RATE FOR FLOOR ORDERS ON MAY 1, 2002. THE CME IMPOSED A $1,000 FINE. Initiated By: CHICAGO MERCANTILE EXCHANGE, INC Date Initiated: 05/15/2002 Docket/Case Number: 02-20487-CTRA

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief NONE Sought:

Resolution: Decision Resolution Date: 06/04/2002 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: NONE Sanction Details: FINE - $1,000. LEHMAN PAID THE ENTIRE FINE ON MAY 23, 2002. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 208 www.finra.org/brokercheck User Guidance

Firm Statement ON MAY 23, 2002, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN PAID THE $1,000 FINE. THE CME'S DECISION IS FINAL AND EFFECTIVE ON JUNE 4, 2002 i Disclosure 103 of 359 Reporting Source: Firm Current Status: Final Allegations: ON MARCH 27, 2002, THE BUSINESS CONDUCT COMMITTEE OF THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED CBOT REGULATION 332.08 IN THAT IT HAD, ON SEVERAL OCCASIONS DURING THE PERIOD DECEMBER 3 AND 4, 2001, INCORRECTLY KEYPUNCHED INFORMATION INTO THE TRADE ENTRY SYSTEM Initiated By: CHICAGO BOARD OF TRADE - BUSINESS CONDUCT COMMITTEE Date Initiated: 03/27/2002 Docket/Case Number: 01-RFT-108

Principal Product Type: Futures - Financial Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 04/12/2002 Sanctions Ordered: Monetary/Fine $1,500.00 Other Sanctions Ordered: Sanction Details: ON APRIL 12, 2002, WITHOUT ADMITTING OR DENYING THAT IT HAD VIOLATED ANY REGULATIONS, LEHMAN PAID A FINE IN THE AMOUNT OF $1,500.00 i Disclosure 104 of 359 Reporting Source: Firm Current Status: Final Allegations: ON OCTOBER 9, 2001, THE BUSINESS CONDUCT COMMITTEE OF THE ©2021 FINRA. All rights reserved. Report aboutCHICAGO LEHMAN BOARD BROTHERS OF INC. TRADE ("CBOT") ALLEGED THAT LEHMAN BROTHERS 209 INC. ("LEHMAN") VIOLATED CBOT REGULATION 332.08 RELATING TO LATE TRADE DATA SUBMISSIONS. www.finra.org/brokercheck User Guidance

Allegations: ON OCTOBER 9, 2001, THE BUSINESS CONDUCT COMMITTEE OF THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") VIOLATED CBOT REGULATION 332.08 RELATING TO LATE TRADE DATA SUBMISSIONS. Initiated By: CHICAGO BOARD OF TRADE, BUSINESS CONDUCT COMMITTEE Date Initiated: 10/09/2001 Docket/Case Number: 01-RFT-042

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 02/05/2002 Sanctions Ordered: Monetary/Fine $750.00 Other Sanctions Ordered: Sanction Details: ON OCTOBER 15, 2001, WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, LEHMAN OFFERED TO PAY A FINE IN THE AMOUNT OF $750.00. THE SETTLEMENT OFFER WAS ACCEPTED BY THE COMMITTEE ON OCTOBER 24, 2001 AND RESULTED IN DECISION 01-RFT-042 (THE "DECISION") DATED DECEMBER 5, 2001. LEHMAN RECEIVED THE DECISION ON JANUARY 25, 2002 AND PAID THE $750.00 ON FEBRUARY 5, 2002. i Disclosure 105 of 359 Reporting Source: Regulator Current Status: Final Allegations: **01/15/2002**PLEASE BE ADVISED THAT THE EXCHANGE AND LEHMAN BROTHERS ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY. WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTED: A.TO A FINDING BY THE HEARING PANEL THAT THE FIRM:1.VIOLATED EXCHANGE RULE 345A, IN THAT THE FIRM PERMITTED PERSONS WITH INACTIVE REGISTRATIONS TO PERFORM DUTIES AND FUNCTIONS IN CAPACITIES WHICH REQUIRED REGISTRATION, FOR PERIODS RANGING FROM LESS THAN ONE MONTH TO TEN MONTHS.2.VIOLATED EXCHANGE RULE 342, IN THAT THE FIRM FAILED TO ©2021 FINRA. All rights reserved. Report aboutPROVIDE LEHMAN APPROPRIATE BROTHERS INC. SUPERVISORY PROCEDURES AND CONTROLS 210 AND AN APPROPRIATE SYSTEM OF FOLLOW-UP AND REVIEW WITH RESPECT TO ITS OBLIGATION TO ENSURE THAT ITS REGISTERED EMPLOYEES COMPLETED THE REGULATORY ELEMENT OF THE CONTINUING EDUCATION PROGRAM, AND B.TO THE IMPOSITION OF A PENALTY OF A CENSURE AND A $250,000 FINE. **01/15/2002**PLEASE BE ADVISED THAT THE EXCHANGE AND LEHMAN BROTHERS ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY. WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTED: A.TO A FINDING BY THE HEARING PANEL THAT THE www.finra.org/brokercheck FIRM:1.VIOLATED EXCHANGE RULE 345A, IN THAT THE FIRM PERMITTED User Guidance PERSONS WITH INACTIVE REGISTRATIONS TO PERFORM DUTIES AND FUNCTIONS IN CAPACITIES WHICH REQUIRED REGISTRATION, FOR PERIODS RANGING FROM LESS THAN ONE MONTH TO TEN MONTHS.2.VIOLATED EXCHANGE RULE 342, IN THAT THE FIRM FAILED TO PROVIDE APPROPRIATE SUPERVISORY PROCEDURES AND CONTROLS AND AN APPROPRIATE SYSTEM OF FOLLOW-UP AND REVIEW WITH RESPECT TO ITS OBLIGATION TO ENSURE THAT ITS REGISTERED EMPLOYEES COMPLETED THE REGULATORY ELEMENT OF THE CONTINUING EDUCATION PROGRAM, AND B.TO THE IMPOSITION OF A PENALTY OF A CENSURE AND A $250,000 FINE. Initiated By: NYSE DIVISION OF ENFORCEMENT Date Initiated: 01/15/2002 Docket/Case Number: HPD#:02-62

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 04/26/2002 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: **3/21/2002**DECISION 02-62 - ISSUED BY THE NYSE HEARING PANEL THE HEARING PANEL, ACCEPTING A STIPULATION OF FACTS AND CONSENT TO PENALTY, FOUND THAT THE FIRM VIOLATED EXCHANGE RULE 345A BY PERMITTING PERSONS WITH INACTIVE REGISTRATIONS TO PERFORM IN CAPACITIES WHICH REQUIRED REGISTRATION AND VIOLATED EXCHANGE RULE 342 BY FAILING TO PROVIDE APPROPRIATE SUPERVISORY PROCEDURES. CONSENT TO CENSURE AND A $250,000 FINE. Regulator Statement **4/26/2002** THE DECISION IS NOW FINAL AND IS EFFECTIVE IMMEDIATELY. CONTACT: PEGGY GERMINO 212-656-8450. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT: LEHMAN VIOLATED EXCHANGE RULE 345A BY PERMITTING PERSONS WITH INACTIVE REGISTRATIONS TO PERFORM ©2021 FINRA. All rights reserved. Report aboutDUTIES LEHMAN AND BROTHERS FUNCTIONS INC. IN CAPACITIES THAT REQUIRED REGISTRATION 211 FOR PERIODS RANGING FROM LESS THAN ONE MONTH TO TEN MONTHS; AND VIOLATED EXCHANGE RULE 342 BY FAILING TO PROVIDE APPROPRIATE SUPERVISORY PROCEDURES AND CONTROLS AND AN APPROPRIATE SYSTEM OF FOLLOW-UP AND REVIEW WITH RESPECT TO ITS OBLIGATION TO ENSURE THAT ITS REGISTERED EMPLOYEES COMPLETED THE REGULATORY ELEMENT OF THE CONTINUING EDUCATION PROGRAM. www.finra.org/brokercheck User Guidance

IT WAS ALLEGED THAT: LEHMAN VIOLATED EXCHANGE RULE 345A BY PERMITTING PERSONS WITH INACTIVE REGISTRATIONS TO PERFORM DUTIES AND FUNCTIONS IN CAPACITIES THAT REQUIRED REGISTRATION FOR PERIODS RANGING FROM LESS THAN ONE MONTH TO TEN MONTHS; AND VIOLATED EXCHANGE RULE 342 BY FAILING TO PROVIDE APPROPRIATE SUPERVISORY PROCEDURES AND CONTROLS AND AN APPROPRIATE SYSTEM OF FOLLOW-UP AND REVIEW WITH RESPECT TO ITS OBLIGATION TO ENSURE THAT ITS REGISTERED EMPLOYEES COMPLETED THE REGULATORY ELEMENT OF THE CONTINUING EDUCATION PROGRAM. Initiated By: NEW YORK STOCK EXCHANGE, INC. Date Initiated: 04/26/2002 Docket/Case Number: HPD 02-62

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Stipulation and Consent Resolution Date: 04/26/2002 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF $250,000. PURSUANT TO THE PROVISIONS OF THE EXCHANGE'S CONSTITUTION AND RULES, THE FINE WILL BE PAID WITHIN 45 DAYS OF THE DATE THE DECISION BECAME FINAL. THE DECISION BECAME FINAL ON APRIL 26, 2002. Firm Statement WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTED TO A FINDING BY THE HEARING PANEL THAT IT VIOLATED EXCHANGE RULE 345A BY PERMITTING PERSONS WITH INACTIVE REGISTRATIONS TO PERFORM DUTIES AND FUNCTIONS IN CAPACITIES WHICH REQUIRED REGISTRATION FOR PERIODS RANGING FROM LESS THAN ONE MONTH TO TEN MONTHS AND VIOLATED EXCHANGE RULE 342 BY FAILING TO PROVIDE APPROPRIATE SUPERVISORY PROCEDURES AND CONTROLS AND AN APPROPRIATE SYSTEM OF FOLLOW-UP AND REVIEW WITH RESPECT TO ITS OBLIGATION TO ENSURE THAT ITS REGISTERED EMPLOYEES COMPLETED THE REGULATORY ELEMENT OF THE CONTINUING EDUCATION PROGRAM.

i Disclosure 106 of 359 Reporting Source: Regulator Current Status: Final Allegations: 07/10/01GS: NASD RULE 4613 AND SEC RULE 11AC1-1 - FAILED TO IMMEDIATELY DISPLAY A REVISED QUOTATION AT A PRICE THAT WAS INFERIOR TO ITS PREVIOUS PUBLISHED QUOTATION; FAILED TO HONOR IT PUBLISHED QUOTATION; RECEIVED A TRADE-OR-MOVE MESSAGE THROUGH SELECTNET AND FAILED WITHIN 30 SECONDS OF RECEIVING SUCH MESSAGE TO FILL THE INCOMING TRADE-OR-MOVE MESSAGE FOR THE FULL SIZE OF THE MESSAGE OR MOVE ITS BID DOWN (OFFER UP) BY A QUOTATION INCREMENT THAT WOULD HAVE UNLOCKED/UNCROSSED THE MARKET; ENTERED A BID OR ASK QUOTATION IN THE NASDAQ STOCK MARKET, INC. WHICH CAUSED A LOCKED OR CROSS MARKET CONDITION TO OCCUR IN EACH INSTANCE; FAILED TO IMMEDIATELY SEND A TRADE- OR-MOVE MESSAGE THROUGH SELECTNET TO MARKET PARTICIPANTS WHOSE QUOTE IT LOCKED OR CROSSED AND WITH AN AGGREGATE SIZE OF AT LEAST 5,000 SHARES TO ALL MARKET PARTICIPANTS WHOSE QUOTES IT LOCKED/CROSSED. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 06/27/2001 Docket/Case Number: CMS010112

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/27/2001 Sanctions Ordered: Censure Monetary/Fine $97,500.00 Other Sanctions Ordered: Sanction Details: NONE i

Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS INC. CONSENTED TO THE ENTRY OF FINDINGS THAT ON CERTAIN OCCASIONS DURING AUGUST 28 THROUGH SEPTEMBER 1, 2000 AND ON DECEMBER 15, 2000 AND MARCH 16, 2001, IT FAILED TO COMPLY WITH THE TRADE-OR-MOVE RULE IN VIOLATION OF NASD MARKETPLACE RULE 4613(E)(1)(C); ON CERTAIN OCCASIONS FROM OCTOBER 1, 1999 THROUGH MARCH 31, 2000, IT FAILED TO COMPLY WITH THE TRADE-OR- FADE RULE IN VIOLATION OF NASD MARKETPLACE RULE 4613(B)(2); ON CERTAIN INSTANCES FROM APRIL THROUGH JUNE, 2000, IT FAILED TO COMPLY WITH THE FIRM QUOTE RULES IN VIOLATION OF NASD CONDUCT RULE 3320, NASD MARKETPLACE RULE 4613(B), AND EXCHANGE ACT RULE 11AC1-1; AND ON CERTAIN INSTANCES FROM JULY 1, THROUGH SEPTEMBER 30, 2000, IT CAUSED A LOCKED OR CROSSED MARKET IN VIOLATION OF NASD MARKETPLACE RULE 4613(E)(2). Initiated By: NASD REGULATION, INC. Date Initiated: 07/02/2001 Docket/Case Number: CMS010112

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/02/2001 Sanctions Ordered: Censure Monetary/Fine $97,500.00 Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $97,500. THE FINE WAS PAID ON JULY 24, 2001. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS INC. CONSENTED TO THE ENTRY OF FINDINGS THAT ON CERTAIN OCCASIONS DURING AUGUST 28 THROUGH SEPTEMBER 1, 2000 AND ON DECEMBER 15, 2000 AND MARCH 16, 2001, IT FAILED TO COMPLY WITH THE TRADE-OR-MOVE RULE IN VIOLATION OF NASD MARKETPLACE RULE 4613(E)(1)(C); ON CERTAIN OCCASIONS FROM OCTOBER 1, 1999 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 214 THROUGH MARCH 31, 2000, IT FAILED TO COMPLY WITH THE TRADE-OR- FADE RULE IN VIOLATION OF NASD MARKETPLACE RULE 4613(B)(2); ON CERTAIN INSTANCES FROM APRIL THROUGH JUNE, 2000, IT FAILED TO COMPLY WITH THE FIRM QUOTE RULES IN VIOLATION OF NASD CONDUCT RULE 3320, NASD MARKETPLACE RULE 4613(B), AND EXCHANGE ACT RULE 11AC1-1; AND ON CERTAIN INSTANCES FROM JULY 1, THROUGH SEPTEMBER 30, 2000, IT CAUSED A LOCKED OR CROSSED MARKET IN VIOLATION OF NASD MARKETPLACE RULE 4613(E)(2). WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN www.finra.org/brokercheck BROTHERS INC. CONSENTED TO THE ENTRY OF FINDINGS THAT ON User Guidance CERTAIN OCCASIONS DURING AUGUST 28 THROUGH SEPTEMBER 1, 2000 AND ON DECEMBER 15, 2000 AND MARCH 16, 2001, IT FAILED TO COMPLY WITH THE TRADE-OR-MOVE RULE IN VIOLATION OF NASD MARKETPLACE RULE 4613(E)(1)(C); ON CERTAIN OCCASIONS FROM OCTOBER 1, 1999 THROUGH MARCH 31, 2000, IT FAILED TO COMPLY WITH THE TRADE-OR- FADE RULE IN VIOLATION OF NASD MARKETPLACE RULE 4613(B)(2); ON CERTAIN INSTANCES FROM APRIL THROUGH JUNE, 2000, IT FAILED TO COMPLY WITH THE FIRM QUOTE RULES IN VIOLATION OF NASD CONDUCT RULE 3320, NASD MARKETPLACE RULE 4613(B), AND EXCHANGE ACT RULE 11AC1-1; AND ON CERTAIN INSTANCES FROM JULY 1, THROUGH SEPTEMBER 30, 2000, IT CAUSED A LOCKED OR CROSSED MARKET IN VIOLATION OF NASD MARKETPLACE RULE 4613(E)(2). i Disclosure 107 of 359 Reporting Source: Regulator Current Status: Final Allegations: 11/20/00GS: MSRB RULES G12 AND G14 - FAILED TO PROVIDE ACCURATE AND TIMELY INFORMATION REGARDING MUNICIPAL SECURITIES TRADES TO THE NATIONAL SECURITIES CLEARING CORPORATION. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 11/10/2000 Docket/Case Number: C8A000066

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/10/2000 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: NONE i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN ©2021 FINRA. All rights reserved. Report aboutVIOLATION LEHMAN BROTHERSOF MSRB INC. RULES G-12 AND G-14. 215 www.finra.org/brokercheck User Guidance

Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN VIOLATION OF MSRB RULES G-12 AND G-14. Initiated By: NASD REGULATION, INC. Date Initiated: 11/10/2000 Docket/Case Number: C8A000066

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/10/2000 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $2,000. PURSUANT TO THE NASD REGULATION, INC.'S PROCEDURES, LEHMAN WILL PAY THE FINE IN ACCORDANCE WITH THE INVOICE SENT BY THE NASD REGULATION, INC.'S DEPARTMENT OF FINANCE. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, LEHMAN ACCEPTED AND CONSENTED TO THE ENTRY OF THE FOLLOWING FINDINGS: DURING THE PERIOD JANUARY 2000 THROUGH JULY 2000, LEHMAN'S T-INPUT PERCENTAGE WAS BELOW THE INDUSTRY AVERAGE T- INPUT PERCENTAGE; AND 2) BY VIRTUE OF ITS FAILURE TO PROVIDE ACCURATE AND TIMELY INFORMATION REGARDING MUNICIPAL SECURITIES TRADES TO THE NSCC DURING THIS TIME PERIOD, LEHMAN VIOLATED MSRB RULES G-12 AND G-14. i Disclosure 108 of 359 Reporting Source: Regulator Current Status: Final Allegations: 08/17/00EC: NASD RULES 2110, 2320, 3370 AND SEC RULE 11AC1-4 - RESPONDENT MEMBER FAILED TO CONTEMPORANEOUSLY OR PARTIALLY EXECUTE CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT A PRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S ©2021 FINRA. All rights reserved. Report aboutLIMIT LEHMAN ORDER; BROTHERS RESPONDENT INC. MEMBER FAILED TO USE REASONABLE 216 DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS; RESPONDENT MEMBER FAILED TO EXECUTE MARKET ORDERS FULLY AND PROMPTLY; RESPONDENT FAILED TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED RESPONDENT MEMBER'S BID OR OFFER IN EACH SUCH SECURITY OR WHEN THE ORDER WAS PRICED EQUAL TO RESPONDENT MEMBER'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCH SECURITY AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH RESPONDENT MEMBER'S BID OR OFFER IN EACH SUCH SECURITY; RESPONDENT MEMBER EXECUTED SHORT SALE ORDERS IN CERTAIN SECURITIES AND FAILED TO MAKE AN AFFIRMATIVE DETERMINATION PRIOR TO EXECUTING SUCH TRANSACTIONS; AND RESPONDENT MEMBER'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS. www.finra.org/brokercheck 08/17/00EC: NASD RULES 2110, 2320, 3370 AND SEC RULE 11AC1-4 - User Guidance RESPONDENT MEMBER FAILED TO CONTEMPORANEOUSLY OR PARTIALLY EXECUTE CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT A PRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER; RESPONDENT MEMBER FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS; RESPONDENT MEMBER FAILED TO EXECUTE MARKET ORDERS FULLY AND PROMPTLY; RESPONDENT FAILED TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED RESPONDENT MEMBER'S BID OR OFFER IN EACH SUCH SECURITY OR WHEN THE ORDER WAS PRICED EQUAL TO RESPONDENT MEMBER'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCH SECURITY AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH RESPONDENT MEMBER'S BID OR OFFER IN EACH SUCH SECURITY; RESPONDENT MEMBER EXECUTED SHORT SALE ORDERS IN CERTAIN SECURITIES AND FAILED TO MAKE AN AFFIRMATIVE DETERMINATION PRIOR TO EXECUTING SUCH TRANSACTIONS; AND RESPONDENT MEMBER'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/17/2000 Docket/Case Number: CMS000158

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/17/2000 Sanctions Ordered: Censure Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: AN UNDERTAKING TO PROVIDE THE STAFF WITH REVISED WRITTEN SUPERVISORY PROCEDURES WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. FURTHER, RESPONDENT MEMBER SHALL PROVIDE RESTITUTION TO THE CUSTOMERS WHOSE TRANSACTIONS IN ©2021 FINRA. All rights reserved. Report aboutTHE LEHMAN TOTAL BROTHERS AMOUNT INC.OF $2,131.25, PLUS INTEREST. SATISFACTORY 217 PROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION, SHALL BE PROVIDED TO THE NASD REGULATION, INC., STAFF NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. www.finra.org/brokercheck User Guidance AN UNDERTAKING TO PROVIDE THE STAFF WITH REVISED WRITTEN SUPERVISORY PROCEDURES WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. FURTHER, RESPONDENT MEMBER SHALL PROVIDE RESTITUTION TO THE CUSTOMERS WHOSE TRANSACTIONS IN THE TOTAL AMOUNT OF $2,131.25, PLUS INTEREST. SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION, SHALL BE PROVIDED TO THE NASD REGULATION, INC., STAFF NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. Regulator Statement 01-08-01, $37,000 RESTITUTION PAID 08/28/00, INVOICE 00-MS-561 i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN VIOLATION OF SECURITIES EXCHANGE ACT RULE 11AC1-4 AND NASD CONDUCT RULES 2110, IM-2110-2, 2320, 3010 AND 3370. Initiated By: NASD REGULATION, INC. Date Initiated: 07/18/2000 Docket/Case Number: CMS000158

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought: RESTITUTION UNDERTAKING

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/18/2000 Sanctions Ordered: Censure Monetary/Fine $37,000.00 Disgorgement/Restitution Other Sanctions Ordered: AN UNDERTAKING TO PROVIDE THE MARKET REGULATION DEPARTMENT STAFF WITH REVISED WRITTEN SUPERVISORY PROCEDURES BY AUGUST 29, 2000. Sanction Details: THE AMOUNT OF THE FINE IS $37,000.00. PURSUANT TO NASD REGULATION, INC.'S PROCEDURES, LEHMAN WILL PAY THE FINE IN ACCORDANCE WITH THE INVOICE SENT BY THE NASD REGULATION, INC.'S DEPARTMENT OF FINANCE. THE AMOUNT OF THE RESTITUTION IS $2,131.25, PLUS INTEREST. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 218 THE AMOUNT OF THE FINE IS $37,000.00. PURSUANT TO NASD www.finra.org/brokercheck REGULATION, INC.'S PROCEDURES, LEHMAN WILL PAY THE FINE IN User Guidance ACCORDANCE WITH THE INVOICE SENT BY THE NASD REGULATION, INC.'S DEPARTMENT OF FINANCE. THE AMOUNT OF THE RESTITUTION IS $2,131.25, PLUS INTEREST. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, LEHMAN CONSENTED TO THE ENTRY OF FINDINGS THAT, ON SEVERAL OCCASIONS ON FEBRUARY 5, 1999, LEMAN: 1) DID NOT EXECUTE TIMELY CUSTOMER LIMIT ORDERS, IN VIOLATION OF NASD CONDUCT RULE 2110 AND IM-2110- 2; 2) FAILED TO OBTAIN BEST EXECUTIONS, IN VIOLATION OF NASD CONDUCT RULES 2110 AND 2320; 3) DID NOT DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS, IN VIOLATION OF SECURITIES EXCHANGE ACT RULE 11AC1-4; 4) EXECUTED SHORT SALES, WITHOUT MAKING AN AFFIRMATIVE DETERMINATION, IN VIOLATION OF NASD CONDUCT RULE 3370; AND 5)FAILED TO HAVE WRITTEN SUPERVISORY PROCEDURES IN PLACE IDENTIFYING PERSON(S) RESPONSIBLE TO ENSURE COMPLIANCE WITH RELEVANT NASD RULES, SETTING FORTH THE STEPS THE PERSON(S) SHOULD TAKE TO ENSURE COMPLIANCE, AND STATING HOW OFTEN THE PERSON(S) NEEDED TO CONDUCT AND DOCUMENT THEIR REVIEWS, IN VIOLATION OF NASD CONDUCT RULES 2110 AND 3010. i Disclosure 109 of 359 Reporting Source: Regulator Current Status: Final Allegations: 08/15/00GS: NASD RULE 6240 - REPORTED TRANSACTIONS TO THE FIXED INCOME PRICING SYSTEM ("FIPS") IN VIOLATION OF APPLICABLE SECURITIES LAWS AND REGULATIONS REGARDING THE REPORTING OF HIGH YIELD CORPORATE DEBTS SECURITIES Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 08/02/2000 Docket/Case Number: CMS000174

Principal Product Type: Debt - Asset Backed Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/02/2000 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 219 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: 01-08-01, $7,500 PAID 08/28/00, INVOICE 00-MS-578. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN VIOLATION OF NASD MARKETPLACE RULES 6240(A) AND 6240(B). Initiated By: NASD REGULATION, INC. Date Initiated: 08/03/2000 Docket/Case Number: CMS000174

Principal Product Type: Debt - Corporate Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/03/2000 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $7,500. THE FINE WAS PAID ON AUGUST 24, 2000. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO THE ENTRY OF FINDINGS THAT, IN INSTANCES DURING THE PERIODS SEPTEMBER 15TH THROUGH OCTOBER 18TH 1996, JULY 7TH THROUGH JULY 11TH 1997 AND JUNE 5TH THROUGH SEPTEMBER 15TH 1998, LEHMAN WAS IN VIOLATION OF NASD MARKETPLACE RULES 6240(A) AND 6240(B) RELATING TO REPORTING VIOLATIONS IN CERTAIN FIPS MANDATORY AND HIGH YIELD SECURITIES, RESPECTIVELY. i Disclosure 110 of 359 Reporting Source: Regulator

Current Status: Final Allegations: 08/13/00EC: NASD RULE 4613(E) - RESPONDED FIRM, WITHOUT MAKING REASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET BY EXECUTING TRANSACTIONS WITH ALL MARKET MAKERS WHOSE QUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED A BID OR ASK QUOTATION IN THE NASDAQ STOCK MARKET, INC. WHICH CAUSED A LOCKED OR CROSSED MARKET CONDITION TO OCCUR IN EACH INSTANCE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/17/2000 Docket/Case Number: CMS000159AWC

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/17/2000 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: 01-08-01, $5,000 PAID 08/28/00, INVOICE 00-MS-562. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN VIOLATION OF NASD MARKETPLACE RULE 4613(E). Initiated By: NASD REGULATION, INC. Date Initiated: 07/18/2000 Docket/Case Number: CMS000159

Principal Product Type: Equity - OTC Other Product Type(s):

Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 222 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/17/2000 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: 01-08-00, $5,000 PAID 08/28/00, INVOICE 00-MS-549 i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN VIOLATION OF NASD MARKETPLACE RULES 4632(A) AND 6620(A). Initiated By: NASD REGULATION, INC. Date Initiated: 07/18/2000 Docket/Case Number: CMS000147

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/18/2000 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $5,000. PURSUANT TO NASD REGULATION, INC.'S PROCEDURES, LEHMAN WILL PAY THE FINE IN ACCORDANCE WITH THE INVOICE SENT BY THE NASD REGULATION, INC.'S DEPARTMENT OF FINANCE. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, LEHMAN ACCEPTED AND CONSENTED TO THE ENTRY OF FINDINGS THAT, IN INSTANCES DURING THE PERIOD APRIL 1 THROUGH JUNE 30, 1999, LEHMAN FAILED TO PROPERLY DESIGNATE TRADES AS BEING EXECUTED ©2021 FINRA. All rights reserved. Report aboutOUTSIDE LEHMAN OF BROTHERS NORMAL INC. BUSINESS HOURS, IN VIOLATION OF NASD 223 MARKETPLACE RULES 4632(A) AND 6620(A). www.finra.org/brokercheck User Guidance WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, LEHMAN ACCEPTED AND CONSENTED TO THE ENTRY OF FINDINGS THAT, IN INSTANCES DURING THE PERIOD APRIL 1 THROUGH JUNE 30, 1999, LEHMAN FAILED TO PROPERLY DESIGNATE TRADES AS BEING EXECUTED OUTSIDE OF NORMAL BUSINESS HOURS, IN VIOLATION OF NASD MARKETPLACE RULES 4632(A) AND 6620(A). i Disclosure 112 of 359 Reporting Source: Regulator Current Status: Final Allegations: VIOLATIONS OF ARTICLE III, SECTIONS 1, 15(A), 15(B), AND 27(A) OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT SALYER WAS ORALLY GRANTED DISCRETIONARY POWER AND USED SUCH DISCRETIONARY POWER TO EFFECT TRANSACTIONS IN THE ACCOUNT OF A CUSTOMER, WHICH TRANSACTIONS WERE EXECESSIVE IN FREQUENCY; EXERCISED DISCRETION IN THIS CUSTOMER'S ACCOUNT WITHOUT FIRST HAVING SUCH DISCRETIONARY POWER REDUCED TO WRITING AND ACCEPTED BY THE RESPONDENT MEMBER; AND, RESPONDENT MEMBER, ACTING THROUGH RESPONDENT PEYTON, FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF RESPONDENT SALYER. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 12/04/1985 Docket/Case Number: WA-478

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 05/05/1989 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: DECISION RENDERED MAY 14, 1987, WHEREIN RESPONDENTS ARE CENSURED AND FINED $3,000.00, JOINTLY AND SEVERALLY. Regulator Statement [TOP] NASD COMPLAINT NO. WA-478 FILED 12/4/85 BY DISTRICT NO. 10 AGAINST SHEARSON LEHMAN BROTHERS, INC., RONALD L. SALYER AND RANDOLPH G. PEYTON, ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS ©2021 FINRA. All rights reserved. Report about1, 15(A), LEHMAN 15(B), BROTHERS AND 27(A) INC. OF THE RULES OF FAIR PRACTICE IN THAT 224 RESPONDENT SALYER WAS ORALLY GRANTED DISCRETIONARY POWER AND USED SUCH DISCRETIONARY POWER TO EFFECT TRANSACTIONS IN THE ACCOUNT OF A CUSTOMER, WHICH TRANSACTIONS WERE EXECESSIVE IN FREQUENCY; EXERCISED DISCRETION IN THIS CUSTOMER'S ACCOUNT WITHOUT FIRST HAVING SUCH DISCRETIONARY POWER REDUCED TO WRITING AND ACCEPTED BY THE RESPONDENT MEMBER; AND, RESPONDENT MEMBER, ACTING THROUGH RESPONDENT PEYTON, FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF RESPONDENT SALYER. DECISION RENDERED MAY 14, 1987, WHEREIN RESPONDENTS ARE CENSURED AND FINED $3,000.00, JOINTLY AND SEVERALLY. MAY 27, 1987 - APPEALED TO THE BOARD OF GOVERNORS. BOARD OF GOVERNORS' DECISION RENDERED OCTOBER 16, 1987, WHEREIN THE FINDINGS MADE AND THE SANCTIONS IMPOSED ARE AFFIRMED. 4/2/88 - APPEALED TO THE SEC. ***5/24/89-SEC NEWS DIGEST ISSUE 89-85, DATED 5/5/89 DISCLOSES: THE SEC AFFIRMED DISCIPLINARY ACTION TAKEN BY THE NASD AGAINST SHEARSON LEHMAN HUTTON INC., THE NASD CENSURED RESPONDENTS AND FINED THEM $3,000, JOINTLY AND SEVERALLY. THE COMMISSION FOUND, AS HAD THE NASD, THAT SALYER ENGAGED IN EXCESSIVE TRADING IN A CUSTOMER'S DISCRETIONARY ACCOUNT. IN A 13-MONTH PERIOD, THE ACCCOUNT WAS TURNEDOVER 7.4 TIMES, AND THE MARKUPS, COMMISSIONS, AND MARGIN INTEREST CHARGED TO THE ACCOUNT EXCEEDED 50% OF THE CUSTOMER'S ORIGINAL INVESTMENT. SALYER ALSO FAILED TO OBTAIN THE NECESSARY WRITTEN AUTHORIZATIONS FOR OPENING A DISCRETIONARY ACCOUNT. THE SEC ALSO AFFIRMED THE NASD'S FINDINGS THAT SHEARSON AND PEYTON FAILED TO EXERCISE PROPER SUPERVISION WITH RESPECT TO SALYER'S EXCESSIVE TRADING. (REL. 34-26766). $3,000 PAID J&S 6/29/89 www.finra.org/brokercheck User Guidance [TOP] NASD COMPLAINT NO. WA-478 FILED 12/4/85 BY DISTRICT NO. 10 AGAINST SHEARSON LEHMAN BROTHERS, INC., RONALD L. SALYER AND RANDOLPH G. PEYTON, ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 15(A), 15(B), AND 27(A) OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT SALYER WAS ORALLY GRANTED DISCRETIONARY POWER AND USED SUCH DISCRETIONARY POWER TO EFFECT TRANSACTIONS IN THE ACCOUNT OF A CUSTOMER, WHICH TRANSACTIONS WERE EXECESSIVE IN FREQUENCY; EXERCISED DISCRETION IN THIS CUSTOMER'S ACCOUNT WITHOUT FIRST HAVING SUCH DISCRETIONARY POWER REDUCED TO WRITING AND ACCEPTED BY THE RESPONDENT MEMBER; AND, RESPONDENT MEMBER, ACTING THROUGH RESPONDENT PEYTON, FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF RESPONDENT SALYER. DECISION RENDERED MAY 14, 1987, WHEREIN RESPONDENTS ARE CENSURED AND FINED $3,000.00, JOINTLY AND SEVERALLY. MAY 27, 1987 - APPEALED TO THE BOARD OF GOVERNORS. BOARD OF GOVERNORS' DECISION RENDERED OCTOBER 16, 1987, WHEREIN THE FINDINGS MADE AND THE SANCTIONS IMPOSED ARE AFFIRMED. 4/2/88 - APPEALED TO THE SEC. ***5/24/89-SEC NEWS DIGEST ISSUE 89-85, DATED 5/5/89 DISCLOSES: THE SEC AFFIRMED DISCIPLINARY ACTION TAKEN BY THE NASD AGAINST SHEARSON LEHMAN HUTTON INC., THE NASD CENSURED RESPONDENTS AND FINED THEM $3,000, JOINTLY AND SEVERALLY. THE COMMISSION FOUND, AS HAD THE NASD, THAT SALYER ENGAGED IN EXCESSIVE TRADING IN A CUSTOMER'S DISCRETIONARY ACCOUNT. IN A 13-MONTH PERIOD, THE ACCCOUNT WAS TURNEDOVER 7.4 TIMES, AND THE MARKUPS, COMMISSIONS, AND MARGIN INTEREST CHARGED TO THE ACCOUNT EXCEEDED 50% OF THE CUSTOMER'S ORIGINAL INVESTMENT. SALYER ALSO FAILED TO OBTAIN THE NECESSARY WRITTEN AUTHORIZATIONS FOR OPENING A DISCRETIONARY ACCOUNT. THE SEC ALSO AFFIRMED THE NASD'S FINDINGS THAT SHEARSON AND PEYTON FAILED TO EXERCISE PROPER SUPERVISION WITH RESPECT TO SALYER'S EXCESSIVE TRADING. (REL. 34-26766). $3,000 PAID J&S 6/29/89 i Reporting Source: Firm Current Status: Final Allegations: SHEARSON LEHMAN HUTTON HAD FAILED TO ADEQUATELY SUPERVISE THE ACTIVITIES OF ONE OF ITS REGISTERED REPRESENTATIVES. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC Date Initiated: 12/04/1985 Docket/Case Number: (NASD) WA-478

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 225 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 05/05/1989 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: DECISION RENDERED MAY 14, 1987, WHEREIN RESPONDENTS ARE CENSURED AND FINED $3,000.00 JOINTLY AND SEVERALLY. SEC NEWS DIGEST ISSUE 89-95, DATED 5/5/89 DISCLOSES: THE SEC AFFIRMED DISCIPLINARY ACTION TAKEN BY THE NASD AGAINST SHEARSON LEHMAN HUTTON INC., i Disclosure 113 of 359 Reporting Source: Regulator Current Status: Final Allegations: **07/13/2000** STIPULATION AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT, OR ANY ALLEGATIONS, FACTS OR CONCLUSIONS IN THE STIPULATION AND CONSENT, LEHMAN BROTHERS INC. CONSENTED TO FINDINGS BY THE HEARING PANEL THAT IT: (1) VIOLATED SEC RULES 10A-1(A), 10A-1(C) AND 10A-1(D) AND EXCHANGE RULES 440B, AND 440B.13 BY EXECUTING SHORT SALES AT PRICES AT OR BELOW THE PRICE AT WHICH THE LAST SALE WAS REPORTED REGULAR WAY AND BY FAILING TO MARK THESE ORDERS AS SHORT SALES; (2) VIOLATED EXCHANGE RULE 476(A)(11) BY FAILING TO SUBMIT ACCURATE DAILY PROGRAM TRADING REPORTS BETWEEN SEPTEMBER 1996 AND JANUARY 1998; (3) VIOLATED SEC RULES 17A-3 AND 17A-4 AND EXCHANGE RULE 440 BY FAILING TO MAKE AND KEEP ACCURATE VARIOUS BOOKS AND RECORDS; AND (4) VIOLATED EXCHANGE RULE 342 IN THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES FOR SUPERVISION AND CONTROL, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, TO ASSURE COMPLIANCE WITH THE SHORT SALE RULES (SEC RULE 10A-1 ET. SEQ. AND EXCHANGE RULE 440B, ET SEQ.)AND DPTR REPORTING (EXCHANGE RULE 476(A)(11)). LEHMAN BROTHERS INC. CONSENTED TO THE IMPOSITION BY THE EXCHANGE OF THE PENALTY OF A CENSURE AND A FINE IN THE AMOUNT OF $250,000. Initiated By: NYSE DIVISION OF ENFORCEMENT ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 226 www.finra.org/brokercheck User Guidance

Initiated By: NYSE DIVISION OF ENFORCEMENT Date Initiated: 07/13/2000 Docket/Case Number: HPD# 00-165

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 09/28/2000 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: **9/28/00** DECISION #00-165 ISSUED BY NYSE HEARING PANEL DECISION: VIOLATED SEC RULES 10A-1(A), 10A-1(C) AND 10A-1(D) AND EXCHANGE RULES 440B AND 440B.13 BY EXECUTING SHORT SALES AT OR BELOW THE LAST REPORTED PRICE AND BY FAILING TO MARK THEM AS SHORT SALES; VIOLATED EXCHANGE RULE 476(A)(11) BY FAILING TO SUBMIT ACCURATE DAILY PROGRAM TRADING REPORTS; VIOLATED SEC RULES 17A-3 AND 17A-4 AND EXCHANGE RULE 440 BY FAILING TO MAKE AND KEEP ACCURATE BOOKS AND RECORDS; AND VIOLATED EXCHANGE RULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES FOR SUPERVISION AND CONTROL. CONSENT TO A CENSURE AND A $250,000 FINE. Regulator Statement **9/28/00** UNLESS A REVIEW BY THE NYSE BOARD OF DIRECTORS IS REQUESTED, THIS DECISION WILL BECOME FINAL 25 CALENDAR DAYS AFTER NOTICE OF THE HEARING PANEL'S DETERMINATION HAS BEEN SERVED UPON THE RESPONDENT. THE DECISION IS NOW FINAL. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN VIOLATED SEC RULES 10A-1(A), 10A-1(C) AND 10A-1(D) AND EXCHANGE RULES 440B AND 440B.13 BY EXECUTING SHORT SALES AT OR BELOW THE LAST REPORTED PRICE AND BY FAILING TO MARK THEM SHORT SALES; VIOLATED RULE 476(A)(11) BY FAILING TO SUBMIT ACCURATE DAILY PROGRAM TRADING REPORTS; VIOLATED SEC ©2021 FINRA. All rights reserved. Report aboutRULES LEHMAN 17A-3 BROTHERS AND A-4 INC. AND EXCHANGE RULE 440 BY FAILING TO MAKE AND 227 KEEP ACCURATE BOOKS AND RECORDS; AND VIOLATED RULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES FOR SUPERVISION AND CONTROL. www.finra.org/brokercheck IT WAS ALLEGED THAT LEHMAN VIOLATED SEC RULES 10A-1(A), 10A-1(C) User Guidance AND 10A-1(D) AND EXCHANGE RULES 440B AND 440B.13 BY EXECUTING SHORT SALES AT OR BELOW THE LAST REPORTED PRICE AND BY FAILING TO MARK THEM SHORT SALES; VIOLATED RULE 476(A)(11) BY FAILING TO SUBMIT ACCURATE DAILY PROGRAM TRADING REPORTS; VIOLATED SEC RULES 17A-3 AND A-4 AND EXCHANGE RULE 440 BY FAILING TO MAKE AND KEEP ACCURATE BOOKS AND RECORDS; AND VIOLATED RULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES FOR SUPERVISION AND CONTROL. Initiated By: NEW YORK STOCK EXCHANGE, INC. Date Initiated: 11/03/2000 Docket/Case Number: HPD# 00-165

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): EQUITY - OTC Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Stipulation and Consent Resolution Date: 11/03/2000 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $250,000. PURSUANT TO THE PROVISIONS OF THE EXCHANGE'S CONSTITUTION AND RULES, THE FINE WILL BE PAID WITHIN 45 DAYS OF THE DECISION BECOMING FINAL. THE DECISION WAS FINAL ON NOVEMBER 3, 2000. Firm Statement WITHOUT ADMITTING OR DENYING GUILT, OR ANY ALLEGATIONS, FACTS OR CONCLUSIONS IN THE STIPULATION AND CONSENT, LEHMAN BROTHERS INC. CONSENTED TO THE FINDINGS BY THE HEARING PANEL. LEHMAN BROTHERS INC. CONSENTED TO THE IMPOSITION BY THE EXCHANGE OF THE PENALTY OF A CENSURE AND A FINE IN THE AMOUNT OF $250,000. i Disclosure 114 of 359 Reporting Source: Firm Current Status: Final Allegations: THE DEPARTMENT OF JUSTICE CIVIL COMPLAINT ALLEGED LEHMAN BROTHERS AND TWENTY THREE OTHER NASDAQ MARKET-MAKERS HAD VIOLATED SECTION 1 OF THE SHERMAN ACT IN CONNECTION WITH ©2021 FINRA. All rights reserved. Report aboutCERTAIN LEHMAN MARKET-MAKING BROTHERS INC. PRACTICES. 228 www.finra.org/brokercheck User Guidance THE DEPARTMENT OF JUSTICE CIVIL COMPLAINT ALLEGED LEHMAN BROTHERS AND TWENTY THREE OTHER NASDAQ MARKET-MAKERS HAD VIOLATED SECTION 1 OF THE SHERMAN ACT IN CONNECTION WITH CERTAIN MARKET-MAKING PRACTICES. Initiated By: UNITED STATES DEPARTMENT OF JUSTICE Date Initiated: 07/17/1996 Docket/Case Number: 96 CIV.5313 (RWS)

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief ALLEGED VIOLATION BY LEHMAN BROTHERS AND TWENTY THREE OTHER Sought: NASDAQ MARKET-MAKERS OF SECTION 1 OF THE SHERMAN ACT IN CONNECTION WITH CERTAIN MARKET-MAKING PRACTICES.

Resolution: Order Resolution Date: 07/17/1996 Sanctions Ordered: Other Sanctions Ordered: IN ENTERING INTO A STIPULATION AND ORDER, THE PARTIES AGREED THAT THE DEFENDANTS WOULD NOT ENGAGE IN CERTAIN TYPES OF MARKET-MAKING ACTIVITIES AND THE DEFENDANTS UNDERTOOK SPECIFIC STEPS TO ASSURE COMPLIANCE WITH THEIR AGREEMENT. Sanction Details: SEE ABOVE. i Disclosure 115 of 359 Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATION OF AMEX CONSTITUTION BY SHEARSON LEHMAN HUTTON FROM PERIOD JULY 23RD, 1987 THROUGH FEBRUARY 25TH, 1988 (ALLEGED FAILURE TO PRODUCE BOOKS AND RECORDS REQUESTED BY AMEX IN CONNECTION WITH AN EXCHANGE INVESTIGATION). Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 08/01/1988 Docket/Case Number: UNKNOWN

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 229 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Settled Resolution Date: 01/10/1989 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: THE FIRM SETTLED WITH THE AMEX WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AND PAID A FINE OF $2,000.00. Sanction Details: THE FIRM SETTLED WITH THE AMEX WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. THE FIRM PAID A FINE OF $2,000.00. i Disclosure 116 of 359 Reporting Source: Firm Current Status: Final Allegations: FAILED TO FOLLOW STAMPING REQUIREMENT Initiated By: NEW YORK MERCANTILE EXCHANGE Date Initiated: 02/12/1992 Docket/Case Number: 91-68

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Consent Resolution Date: 02/12/1992 Sanctions Ordered: Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: FIRM WAS FINED $15,000.00 i Disclosure 117 of 359 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 230 www.finra.org/brokercheck User Guidance

Disclosure 117 of 359 Reporting Source: Firm Current Status: Final Allegations: ALLEGED EMPLOYMENT OF UNREGISTERED (IN COLORADO) REPRESENTATIVES. Initiated By: STATE OF COLORADO Date Initiated: 09/01/1975 Docket/Case Number: UNKNOWN

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Settled Resolution Date: 09/01/1975 Sanctions Ordered: Censure Monetary/Fine $350.00 Suspension Other Sanctions Ordered: Sanction Details: SHEARSON HAYDEN STONE WAS FINED $350.00 AND CENSURED. THE STATE IMPOSED A FIVE DAY BAN ON SOLICITING ORDERS THROUGH THE FIRM'S DENVER, COLORADO OFFICE AND ON PUBLIC ADVERTISING IN THE STATE. i Disclosure 118 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS FOUND THAT E.F. HUTTON HAD ALLOWED AN AGENT TO EFFECT FIVE TRANSACTIONS FOR A TENNESSEE RESIDENT PRIOR TO THE AGENT'S REGISTRATION BEING EFFECTIVE IN TENNESSEE. Initiated By: STATE OF TENNESSEE Date Initiated: 03/11/1988 Docket/Case Number: UNKNOWN ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 231 www.finra.org/brokercheck User Guidance

Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief UNREGISTERED AGENT; FINE. Sought:

Resolution: Consent Resolution Date: 03/11/1988 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: FIRM TO IMPLEMENT A POLICY REGARDING TRANSACTION OF BUSINESS IN STATE. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT OR CONCLUSIONS OF LAW THEREIN, HUTTON AND ONE OF ITS AGENTS CONSENTED TO THE ENTRY OF AN ORDER BY THE COMMISSIONER OF COMMERCE AND INSURANCE WHICH MADE THE ABOVE FINDING. THE FIRM AGREED TO PAY A FINE OF $2,500.00 AND ALSO AGREED TO IMPLEMENT A POLICY AS OUTLINED ABOVE. i Disclosure 119 of 359 Reporting Source: Firm Current Status: Final Allegations: ACCORDING TO THE SEC, E.F. HUTTON FAILED TO COMPLY IN MATERIAL RESPECTS WITH SECTIONS 13(A) AND 13(B)(2)(B)(II) OF THE SECURITIES EXCHANGE ACT OF 1934, AND CERTAIN RULES AND REGULATIONS THEREUNDER IN THAT IT 1) FAILED TO DISCLOSE IN CONTINGENT LIABILITY FOOTNOTES IN THE COMPANY'S 1983, 1984 AND 1985 FINANCIAL STATEMENTS THE REASONABLE POSSIBILITY THAT A LOSS CONTINGENCY HAD ARISEN AS A RESULT OF THE THE UNCERTAINTIES RELATING TO HUTTON'S MARKET-MAKING FOR UPPER FLOATER INDUSTRIAL BONDS; AND 2) DID NOT MAINTAIN INTERNAL ACCOUNTING CONTROLS ADEQUATE TO ENABLE FINANCIAL PERSONNEL TO CONSIDER THE APPROPRIATENESS OF SUCH DISCLOSURE. Initiated By: SEC Date Initiated: 03/29/1988 Docket/Case Number: NOT GIVEN

Principal Product Type: Debt - Corporate Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FAIL TO COMPLY IN MATERIAL RESPECTS WITH CERTAIN SECTIONS OF Sought: THE SECURITIES EXCHANGE ACT OF 1934.

Resolution: Order Resolution Date: 03/29/1988 Sanctions Ordered: Other Sanctions Ordered: IN THE ORDER, HUTTON WAS REQUIRED IN ALL MATERIAL RESPECTS WITH SECTION 13(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND CERTAIN RULES AND REGULATIONS THEREUNDER; TO ATTACH A COPY OF THE ORDER AS AN EXHIBIT TO A CURRENT REPORT ON FORM 8-K TO BE FILED WITH THE SEC; AND TO INCLUDE IN ITS 1987 ANNUAL REPORT ON FORM 10K AN EXPLANATION OF THE ISSUES DISCUSSED IN THE ORDER Sanction Details: HUTTON CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING PROCEEDINGS BY THE SEC PURSUANT TO SECTION 15(C)(4) OF THE SECURITIES EXCHANGE ACT OF 1934, WITHOUT ADMITTING OR DENYING THE MATTERS SET FORTH IN THE ORDER. i Disclosure 120 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS FOUND BY THE NYSE THAT E.F. HUTTON & CO., DURING THE PERIOD 1980-1982, FAILED TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL WITH RESPECT TO ITS CASHIERING, MONEY MANAGEMENT AND CASH DESK OPERATIONS TO PREVENT THE PRACTICES AND TRANSACTIONS RELATING TO ITS COMMERCIAL BANK ACCOUNTS KNOWN AS "EXCESSIVE DRAW DOWNS" AND "CHAINING" WHICH FORMED THE BASIS FOR ITS GUILTY PLEA IN MAY 1985 TO MAIL AND WIRE FRAUD. THE FIRM WAS ALSO CITED FOR FAILING TO MAINTAIN A WRITTEN TABLE OF SUPERVISION IDENTIFYING THE SUPERVISORY RESPONSIBILITY FOR EACH AREA OF THE FIRM'S BUSINESS ACTIVITIES. FINALLY, THE EXCHANGE FOUND THAT HUTTON'S CONDUCT WAS INCONSISTENT WITH JUST AND EQUITABLE PRINCIPALS OF TRADE AND THAT HUTTON ENGAGED IN ACTS DETRIMENTAL TO THE INTEREST AND WELFARE OF THE EXCHANGE. Initiated By: NEW YORK STOCK EXCHANGE ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 233 www.finra.org/brokercheck User Guidance

Date Initiated: 04/11/1988 Docket/Case Number: NOT GIVEN

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Stipulation and Consent Resolution Date: 04/11/1988 Sanctions Ordered: Censure Monetary/Fine $400,000.00 Other Sanctions Ordered: Sanction Details: E.F.HUTTON WAS CENSURED, ASSESSED A FINE OF $400,000.00 AND AGREED TO VARIOUS UNDERTAKINGS AND ASSURANCES. i Disclosure 121 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED SHEARSON LEHMAN BROTHERS FAILED TO RESPOND TO TO THE ASSOCIATION'S FORMAL WRITTEN REQUESTS FOR INFORMATION, THIS IN VIOLATION OF ARTICLE III, SECTION 1 AND ARTICLE IV, SECTION 5 OF THE NASD'S RULES OF FAIR PRACTICE. Initiated By: NASD - DBCC FOR DISTRICT NO. 2N Date Initiated: 11/26/1985 Docket/Case Number: SF-1126

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 11/26/1985 Sanctions Ordered: Censure Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND A $2,500.00 FINE. i Disclosure 122 of 359 Reporting Source: Firm Current Status: Final Allegations: THE BUSINESS CONDUCT COMMITTEE OF THE NYME DETERMINED THAT A REASONABLE BASIS EXISTED TO BELIEVE THAT SHEARSON LEHMAN BROTHERS VIOLATED NYFE RULE 6.21(E), A RULE RELATING TO EXCHANGE FOR PHYSICAL TRANSACTIONS. Initiated By: NEW YORK MERCANTILE EXCHANGE Date Initiated: 05/14/1987 Docket/Case Number: 86-09

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION Sought:

Resolution: Consent Resolution Date: 07/11/1987 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: FIRM TO SUBMIT, WITHIN FORTY FIVE DAYS, A WRITTEN REPORT TO THE NYFE'S ADJUDICATION PANEL APPROVING THE SETTLEMENT AND DETAILING THE INTERNAL CONTROLS ADOPTED BY THE FIRM TO ASSURE EXCHANGE FOR PHYSICAL TRANSACTIONS ARE NOT IN VIOLATION OF NYFE REGULATIONS. Sanction Details: SEE ABOVE.

i Disclosure 123 of 359 Reporting Source: Firm Current Status: Final Allegations: THE BOARD OF GOVERNORS OF THE NASD AFFIRMED THE AUGUST 14TH, 1988 DECISION OF NASD DBCC FOR DISTRICT NO. 10 WHICH FOUND THAT A BRANCH MANAGER AND SHEARSON LEHMAN BROTHERS HAD FAILED TO SUPERVISE TWO REGISTERED REPRESENTATIVES WHO HAD EXERCISED DISCRETIONARY POWER TO EFFECTE TRANSACTIONS IN THE ACCOUNT OF A CUSTOMER WITHOUT REDUCING SAID POWER TO WRITING, WHICH TRANSACTIONS WERE EXCESSIVE IN FREQUENCY. Initiated By: NASD Date Initiated: 08/14/1987 Docket/Case Number: WA-478

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Decision Resolution Date: 11/15/1987 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: SHEARSON LEHMAN BROTHERS AND THE BRANCH MANAGER WERE CENSURED AND FINED $3,000.00. i Disclosure 124 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT E.F.HUTTON HAD FAIL TO SUPERVISE ONE OF ITS FORMER REGISTERED REPRESENTATIVES BY ALLOWING THAT REPRESENTATIVE TO EFFECT EXCESSIVE TRADES IN TWO CUSTOMER ACCOUNTS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 236 www.finra.org/brokercheck User Guidance IT WAS ALLEGED THAT E.F.HUTTON HAD FAIL TO SUPERVISE ONE OF ITS FORMER REGISTERED REPRESENTATIVES BY ALLOWING THAT REPRESENTATIVE TO EFFECT EXCESSIVE TRADES IN TWO CUSTOMER ACCOUNTS. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 04/13/1988 Docket/Case Number: 87-0104(A)

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 04/13/1988 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, HUTTON AGREED TO THE CBOE'S FINDINGS; THE FIRM AGREED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $5,000.00. i Disclosure 125 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS FOUND THAT E.F.HUTTON HAD CODED THE TRADES OF A BROKER FOR HIS OWN ACCOUNT AS CUSTOMER TRADES FOR A PERIOD OF SIX MONTHS, THIS IN VIOLATION OF NYFE RULE 425. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 04/19/1988 Docket/Case Number: F88-23

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 237 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Stipulation and Consent Resolution Date: 04/19/1988 Sanctions Ordered: Monetary/Fine $750.00 Other Sanctions Ordered: Sanction Details: A DISCIPLINARY PANEL OF THE NYFE ACCEPTED A STIPULATION OF FACTS AND CONSENT TO PENALTY ENTERED INTO BETWEEN THE NYFE'S TRADING SURVEILLANCE DEPARTMENT AND HUTTON. WITHOUT ADMITTING OR DENYING GUILT, HUTTON CONSENTED TO THE ABOVE- REFERENCED FINDING AND TO THE IMPOSITION OF A $750.00 FINE. i Disclosure 126 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT E.F.HUTTON AND OF ITS BRANCH MANAGERS VIOLATED SECTIONS 1, 27 AND 33 OF ARTICLE III OF THE NASD'S RULES OF FAIR PRACTICE. Initiated By: NASD Date Initiated: 04/25/1988 Docket/Case Number: NEW-523

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 04/25/1988 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, E.F.HUTTON AND THE BRANCH MANAGER AGREED TO THE FINDING BY THE NASD; THEY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 238 CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE OF $20,000.00 (JOINT AND SEVERAL). THEY ALSO AGREED TO IMPLEMENT CERTAIN REMEDIAL UNDERTAKINGS IN THE BRANCH MANAGER'S OFFICE. www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, E.F.HUTTON AND THE BRANCH MANAGER AGREED TO THE FINDING BY THE NASD; THEY CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE OF $20,000.00 (JOINT AND SEVERAL). THEY ALSO AGREED TO IMPLEMENT CERTAIN REMEDIAL UNDERTAKINGS IN THE BRANCH MANAGER'S OFFICE. i Disclosure 127 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED A FORMER E.F.HUTTON FLOOR BROKER VIOLATED COMEX RULES 3.13(A) (MISCONDUCT); 4.21 (NONCOMPETITIVE TRADING); 4.22 (DISCLOSURE OF ORDERS); 4.81 (IMPROPER ENTRIES ON TRADING CARDS) AND 4.88 (FAILURE TO MAINTAIN RECORDS); WITH RESPECT TO THE FIRM, IT WAS ALLEGED THAT IT VIOLATED COMEX RULES 3.13(A) (FAILURE TO SUPERVISE) AND 4.88 (FAILURE TO MAINTAIN RECORDS). Initiated By: COMMODITY EXCHANGE, INC. Date Initiated: 04/27/1988 Docket/Case Number: 64/286/86; 63/286/86

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATIONS; FINE. Sought:

Resolution: Consent Resolution Date: 04/27/1988 Sanctions Ordered: Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: THE COMEX ACCEPTED A JOINT OFFER OF SETTLEMENT SUBMITTED BY THE FIRM AND THE FORMER FLOOR BROKER. WITHOUT ADMITTING OR DENYING THE VIOLATIONS ALLEGED, THE FIRM AND THE FORMER FLOOR BROKER CONSENTED TO THE IMPOSITION OF A FINE IN THE AMOUNT OF $15,000.00. i Disclosure 128 of 359 Reporting Source: Firm ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 239 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: E.F.HUTTON MADE A VIOLATION OF THE EXCHANGE'S SPECULATIVE LIMIT RULE. THE VIOLATION OCCURRED WHEN HUTTON INADVERTENTLY FAILED TO AGGREGATE CERTAIN RELATED ACCOUNTS. Initiated By: COFFEE, SUGAR & COCOA EXCHANGE, INC. Date Initiated: 05/02/1988 Docket/Case Number: NOT GIVEN

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Settled Resolution Date: 05/02/1988 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: THE FIRM AGREED TO A FINE OF $500.00 FOR THE VIOLATION OF THE EXCHANGE RULE. i Disclosure 129 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON MAINTAINED FCOJ FUTURES CONTRACTS FOR ANOTHER INDIVIDUAL IN EXCESS OF THE SPECULATIVE POSITION LIMITS OF THE NEW YORK COTTON EXCHANGE. Initiated By: NEW YORK COTTON EXCHANGE (CITRUS ASSOC.) Date Initiated: 08/01/1988 Docket/Case Number: 88-002

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 240 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Stipulation and Consent Resolution Date: 08/01/1988 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: THE CITRUS ASSOCIATES OF THE NEW YORK MERCANTILE EXCHANGE ACCEPTED THE STIPULATION AND CONSENT ENTERED INTO BY SHEARSON LEHMAN HUTTON AND THE BUSINESS CONDUCT COMMITTEE OF THE CITRUS ASSOCIATES WHEREBY THE FIRM, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AGREED TO PAY A FINE OF $5,000. i Disclosure 130 of 359 Reporting Source: Firm Current Status: Final Allegations: THE NEW YORK MERCANTILE EXCHANGE ENTERED AN ORDER FINDING A REASONABLE BASIS TO BELIEVE THAT E.F.HUTTON & CO. HAD VIOLATED NYME RULES 6.21(D) AND 150.14(D). Initiated By: NEW YORK MERCANTILE EXCHANGE Date Initiated: 08/17/1988 Docket/Case Number: 88-05

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Settled Resolution Date: 08/17/1988 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ABOVE-REFERENCED RULE VIOLATIONS, E.F.HUTTON CONSENTED TO THE ENTRY OF AN ORDER BY THE NYME. THE NYME ORDERED THE FIRM TO PAY A $1,000.00 FINE. i Disclosure 131 of 359 Reporting Source: Firm Current Status: Final Allegations: SHEARSON LEHMAN HUTTON RESOLVED CHARGES PROPOSED BY THE NYFE THROUGH AN OFFER OF SETTLEMENT WHICH AGREED TO FINDINGS CONCERNING THE ACCURACY OF THE FIRM'S REPORTING ON THE EXCHANGE'S POSITION/TRANSFER ADJUSTMENT REPORT ON SEVERAL DAYS IN JUNE 1988. Initiated By: NEW YORK FUTURES EXCHANGE Date Initiated: 09/30/1988 Docket/Case Number: F88-40

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Settled Resolution Date: 09/30/1988 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM AGREED TO FINDINGS CONCERNING THE ACCURACY OF THE REPORTING IN QUESTION AND AGREED TO THE IMPOSITION OF A $2,000.00 FINE. i Disclosure 132 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED SHEARSON LEHMAN HUTTON VIOLATED CBT REGULATION 403.07 AND CBT CAPITAL RULE 250 B(7) IN THAT THE FIRM ©2021 FINRA. All rights reserved. Report aboutFAILED LEHMAN TO OBTAINBROTHERS PRIOR INC. WRITTEN APPROVAL FROM THE COMMITTEE TO 242 PREPAY SUBORDINATED DEBT. www.finra.org/brokercheck User Guidance

Allegations: IT WAS ALLEGED SHEARSON LEHMAN HUTTON VIOLATED CBT REGULATION 403.07 AND CBT CAPITAL RULE 250 B(7) IN THAT THE FIRM FAILED TO OBTAIN PRIOR WRITTEN APPROVAL FROM THE COMMITTEE TO PREPAY SUBORDINATED DEBT. Initiated By: CHICAGO BOARD OF TRADE Date Initiated: 10/03/1988 Docket/Case Number: 88-FIN-105

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Settled Resolution Date: 10/03/1988 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO PAY A FINE OF $1,000.00. i Disclosure 133 of 359 Reporting Source: Firm Current Status: Final Allegations: AN AMEX DISCIPLINARY COMMITTEE "MAY CONCLUDE" THAT SHEARSON LEHMAN HUTTON VIOLATED ARTICLE V, SECTION 4(K) OF THE EXCHANGE CONSTITUTION. Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 10/07/1988 Docket/Case Number: NOT GIVEN

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 243 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief FINE Sought:

Resolution: Settled Resolution Date: 10/07/1988 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHEARSON LEHMAN HUTTON AGREED TO A FINE OF $2,000.00. i Disclosure 134 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT, IN 1984, E.F.HUTTON & CO. INC. FAILED TO ADEQUATELY SUPERVISE ONE OF ITS AGENTS BY ALLOWING THE AGENT TO EFFECT UNSUITABLE OPTIONS TRANSACTIONS FOR ONE CUSTOMER AND ALLOWING THE AGENT TO EFFECT TRANSACTIONS FOR WHICH ACCOUNTS HAD NOT BEEN APPROVED. IT WAS ALSO ALLEGED THAT THE FIRM FAILED TO PROPERLY UPDATE THE AGENT'S FORM U-5. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 10/17/1988 Docket/Case Number: 87-0138

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Settled Resolution Date: 10/17/1988 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO ACCEPT THE PENALTY OF A CENSURE AND A $5,000.00 FINE. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 244 www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO ACCEPT THE PENALTY OF A CENSURE AND A $5,000.00 FINE. i Disclosure 135 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON VIOLATED 1) CBT REGULATION 2442.01 IN THAT THE FIRM FAILED TO HAVE IN ACCEPTABLE DELIVERY FORM A THE BANK CONTRACT-GRADE US T-NOTES BY 10AM ON DELIVERY DAY JUNE 30TH, 1988 AND 2) CBT RULE 504.00 IN THAT THE FIRM ENGAGED IN ACTS DETRIMENTAL TO THE INTEREST AND WELFARE OF THE CBT. Initiated By: CHICAGO BOARD OF TRADE Date Initiated: 10/31/1988 Docket/Case Number: 88 MSI-11

Principal Product Type: Futures - Financial Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Settled Resolution Date: 10/31/1988 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OUTLINED ABOVE, SHEARSON LEHMAN HUTTON AGREED TO THE IMPOSITION OF A FINE OF $10,000.00. i Disclosure 136 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT E.F.HUTTON, DURING THE PERIOD 1983 TO 1984, HAD FAILED TO ADEQUATELY SUPERVISE ONE OF ITS AGENTS BY ALLOWING THE AGENT TO EFFECT UNSUITABLE OPTIONS TRANSACTIONS ©2021 FINRA. All rights reserved. Report aboutFOR LEHMAN ONE CUSTOMER BROTHERS INC. AND ALLOWING THE AGENT TO EFFECT 245 TRANSACTIONS FOR WHICH THE ACCOUNT HAD NOT BEEN APPROVED; IT WAS ALSO ALLEGED THE FIRM HAD NOT FULLY DELINEATED THE DIVISION OF RESPONSIBILITIES FOR TWO OF ITS BRANCH MANAGERS. www.finra.org/brokercheck User Guidance IT WAS ALLEGED THAT E.F.HUTTON, DURING THE PERIOD 1983 TO 1984, HAD FAILED TO ADEQUATELY SUPERVISE ONE OF ITS AGENTS BY ALLOWING THE AGENT TO EFFECT UNSUITABLE OPTIONS TRANSACTIONS FOR ONE CUSTOMER AND ALLOWING THE AGENT TO EFFECT TRANSACTIONS FOR WHICH THE ACCOUNT HAD NOT BEEN APPROVED; IT WAS ALSO ALLEGED THE FIRM HAD NOT FULLY DELINEATED THE DIVISION OF RESPONSIBILITIES FOR TWO OF ITS BRANCH MANAGERS. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 11/21/1988 Docket/Case Number: 87-0105(C)

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 11/21/1988 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO ACCEPT THE PENALTY OF A CENSURE AND THE IMPOSITION OF A $5,000.00 FINE. i Disclosure 137 of 359 Reporting Source: Firm Current Status: Final Allegations: TENNESSEE FOUND THAT AN AGENT IN ONE OF E.F.HUTTON'S OFFICES HAD FAILED TO DISCLOSE A MATERIAL FACT ON HIS FORM U-4 AS A RESULT OF ERRONEOUS ADVICE FROM HIS MANAGER AND HUTTON'S REGISTRATION DEPARTMENT, WHICH CAUSED THE AGENT TO BE ELIGIBLE FOR THE TEMPORARY AGENT TRANSFER ("TAT") PROGRAM WHEN HE SHOULD NOT HAVE BEEN. THE FORM U-4 WAS CORRECTED BY AMENDMENT WITHIN THIRTY DAYS OF ITS FILING. Initiated By: STATE OF TENNESSEE Date Initiated: 05/02/1988 Docket/Case Number: 88-MISC-06 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 246 www.finra.org/brokercheck User Guidance

Docket/Case Number: 88-MISC-06

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 05/02/1988 Sanctions Ordered: Monetary/Fine $3,500.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, E.F.HUTTON CONSENTED TO THE ENTRY OF AN ORDER WHICH FOUND THE ABOVE VIOLATION. FIRM AGREED TO CEASE AND DESIST FROM ANY FURTHER VIOLATIONS, TO PAY A FINE OF $3,500.00, AND TO PROVIDE TO REGISTRATION PERSONNEL AND BRANCH OFFICE MANAGERS (AND REQUIRE THEM TO READ) THE ORDER AND THE TAT UNDERTAKING AGREEMENT. i Disclosure 138 of 359 Reporting Source: Firm Current Status: Final Allegations: E.F.HUTTON AGREED TO CEASE AND DESIST FROM ACTIVITIES ALLEGED IN A NOTICE REGARDING AN ADVERTISEMENT AND AGREED TO PAY THE DIVISION'S ADMINISTRATIVE COSTS IN THE AMOUNT OF $150.00. Initiated By: STATE OF IOWA Date Initiated: 05/03/1988 Docket/Case Number: NOT GIVEN

Principal Product Type: Insurance Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 247 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 05/03/1988 Sanctions Ordered: Monetary/Fine $150.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: HUTTON CONSENTED TO THE ENTRY OF AN ORDER BY THE INSURANCE DIVISION OF IOWA IN WHICH IT AGREED TO CEASE AND DESIST FROM THE ACTIVITIES ALLEGED IN THE NOTICE REGARDING AN ADVERTISEMENT; FIRM AGREED TO PAY THE DIVISION'S ADMINISTRATIVE COSTS IN THE AMOUNT OF $150.00. i Disclosure 139 of 359 Reporting Source: Firm Current Status: Final Allegations: ALLEGATIONS CONCERNED THE SUPERVISION OF ONE OF E.F.HUTTON'S AGENTS BY THE AGENT'S MANAGER. Initiated By: STATE OF WISCONSIN Date Initiated: 06/23/1988 Docket/Case Number: X-87162(L)

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Stipulation and Consent Resolution Date: 06/23/1988 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: SUSPENDED MANAGER FROM SUPERVISORY DUTIES FOR A PERIOD. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, E.F.HUTTON AND ONE OF ITS BRANCH MANAGERS ENTERED INTO A STIPULATION AND ©2021 FINRA. All rights reserved. Report aboutCONSENTED LEHMAN BROTHERS TO THE INC. ENTRY OF ORDERS BY THE WISCONSIN 248 COMMISSIONER OF SECURITIES REGARDING THEIR SUPERVISION OF AN AGENT IN THAT OFFICE. HUTTON CONSENTED TO A CENSURE AND AGREED TO PAY AN ADMINISTRATIVE ASSESSMENT OF $15,000.00 AND TO SUSPEND THE BRANCH MANAGER FROM SUPERVISORY DUTIES FROM AUGUST 1ST THROUGH AUGUST 30TH, 1988. www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, E.F.HUTTON AND ONE OF ITS BRANCH MANAGERS ENTERED INTO A STIPULATION AND CONSENTED TO THE ENTRY OF ORDERS BY THE WISCONSIN COMMISSIONER OF SECURITIES REGARDING THEIR SUPERVISION OF AN AGENT IN THAT OFFICE. HUTTON CONSENTED TO A CENSURE AND AGREED TO PAY AN ADMINISTRATIVE ASSESSMENT OF $15,000.00 AND TO SUSPEND THE BRANCH MANAGER FROM SUPERVISORY DUTIES FROM AUGUST 1ST THROUGH AUGUST 30TH, 1988. i Disclosure 140 of 359 Reporting Source: Firm Current Status: Final Allegations: NONE. Initiated By: SEC Date Initiated: 07/25/1988 Docket/Case Number: 3-6490

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief DENIAL OF PETITION FOR REHEARING SEC'S JULY 6TH, 1988 AFFIRMANCE Sought: OF AN NASD FINDING.

Resolution: Settled Resolution Date: 07/25/1988 Sanctions Ordered: Other Sanctions Ordered: Sanction Details: SEC ORALLY DENIED E.F. HUTTON'S PETITION FOR REHEARING OF THE SEC'S JULY 6TH, 1988 AFFIRMANCE OF THE FINDINGS OF THE NASD THAT HUTTON HAD VIOLATED THE NASD'S RULES OF FAIR PRACTICE IN THAT HUTTON HAD FAILED TO EXECUTE A CUSTOMER'S LIMIT ORDER FOR THE SALE OF STOCK ALTHOUGH IT SOLD SHARES OF THAT SECURITY FOR ITS OWN ACCOUNT AT PRICES ABOVE THE CUSTOMERS'S LIMIT PRICE. THE NASD ISSUED A LETTER OF CAUTION IN THE UNDERLYING CASE. HUTTON HAS DISCONTINUED ITS APPEAL OF THE SEC'S DECISION i Disclosure 141 of 359

Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON HAD VIOLATED CRUDE OIL POSITION LIMITS. Initiated By: NEW YORK MERCANTILE EXCHANGE Date Initiated: 05/16/1989 Docket/Case Number: 89-05

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE; RULE VIOLATION. Sought:

Resolution: Consent Resolution Date: 05/16/1989 Sanctions Ordered: Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED AN OFFER OF SETTLEMENT FROM THE NYME WHEREIN IT CONSENTED THAT A REASONABLE BASIS EXISTED TO BELIEVE THAT SUCH VIOLATIONS OCCURRED, AGREED TO THE IMPOSITION OF A FINE AND A PENALTY TOTALLING $25,000.00, AND AGREED TO ENFORCE PROCEDURES TO PREVENT A REOCCURRENCE OF THE SITUATION. i Disclosure 142 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS FOUND THAT SHEARSON LEHMAN HUTTON HAD FAILED TO PROPERLY TIME-STAMP CUSTOMER ORDERS AND FAILED TO KEEP ACCURATE BOOKS AND RECORDS IN THE MANNER PRESCRIBED. Initiated By: CHICAGO BOARD OF TRADE Date Initiated: 06/05/1989 Docket/Case Number: 88-EX-34

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 06/05/1989 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: THE BUSINESS CONDUCT COMMITTEE OF THE CBT ISSUED A DECISION FINDING THE ABOVE VIOLATIONS; A FINE OF $1,000.00 WAS IMPOSED. i Disclosure 143 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS FOUND THAT A CUSTOMER OF SHEARSON LEHMAN HUTTON HAD FAILED TO MAKE A TIMELY DELIVERY OF CERTAIN GASOLINE FUTURES CONTRACTS. Initiated By: NEW YORK MERCANTILE EXCHANGE Date Initiated: 06/09/1989 Docket/Case Number: MATTER OF TN #14

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Settled Resolution Date: 06/09/1989 Sanctions Ordered: Monetary/Fine $17,500.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 251 www.finra.org/brokercheck User Guidance

Sanction Details: THE NYME IMPOSED AN AUTOMATIC FINE OF $17,500.00 AGAINST SHEARSON LEHMAN HUTTON. i Disclosure 144 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT E.F.HUTTON HAD FAILED TO SUPERVISE A FORMER EMPLOYEE IN 1984. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 09/20/1989 Docket/Case Number: 88-0014(A)

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 09/20/1989 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS THAT IT HAD FAILED TO SUPERVISE THE FORMER EMPLOYEE, E.F.HUTTON CONSENTED TO A FINING, A CENSURE AND A $7,500.00 FINE. i Disclosure 145 of 359 Reporting Source: Firm Current Status: Final Allegations: THE NYSE FOUND THAT SHEARSON LEHMAN HUTTON HAD FILED PROGRAM TRADING REPORTS TWO DAYS LATE WITH THE EXCHANGE. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 09/28/1989 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 252 www.finra.org/brokercheck User Guidance

Date Initiated: 09/28/1989 Docket/Case Number: NO NUMBER

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Consent Resolution Date: 09/28/1989 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM CONSENTED TO THE IMPOSITION OF A $1,000.00 FINE. i Disclosure 146 of 359 Reporting Source: Firm Current Status: Final Allegations: THE CME CHARGED THAT SHEARSON LEHMAN HUTTON HAD VIOLATED CME RULE 817 (REPORTS OF LARGE POSITIONS). THESE REPORTS, DUE BY 7AM, ARE FILED BY COMPUTER TAPE A THE CME BY THE FIRM'S CHICAGO-BASED COMMODITY OPERATIONS DEPARTMENT AND, DURING A TWELVE MONTH PERIOD, WERE FILED LATE, BUT NOT MORE THAN THREE HOURS, ON SIX OCCASIONS. Initiated By: CHICAGO MERCANTILE EXCHANGE Date Initiated: 09/28/1989 Docket/Case Number: MS-89-28

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Consent Resolution Date: 09/28/1989 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO FINDS, TO THE ABOVE-MENTIONED FINE, AND ADVISED THE CME THAT IT HAS TAKEN STEPS TO AVOID FUTURE LATE SUBMISSIONS. i Disclosure 147 of 359 Reporting Source: Firm Current Status: Final Allegations: NONE. SEE ITEM #2 ABOVE. Initiated By: DISTRICT OF COLUMBIA Date Initiated: 06/30/1988 Docket/Case Number: 872F

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief REVIEW OF STIPULATION AND AGREEMENT SUBMITTED BY E.F.HUTTON & Sought: CO. RELATING TO HUTTON'S 1985 CONVICTION FOR WIRE AND MAIL FRAUD.

Resolution: Stipulation and Consent Resolution Date: 03/23/1989 Sanctions Ordered: Monetary/Fine $17,500.00 Other Sanctions Ordered: Sanction Details: THE PUBLIC SERVICE COMMISSION OF THE DISTRICT OF COLUMBIA ENTERED ORDER NO. 9247 ACCEPTING THE STIPULATION AND AGREEMENT SUBMITTED BY E.F.HUTTON WHEREIN HUTTON PAID $17,500.00 REPRESENTING THE COSTS OF THE COMMISSION'S INVESTIGATION INTO THE MATTERS SURROUNDING HUTTON'S GUILTY PLEA IN 1985.

i Disclosure 148 of 359 Reporting Source: Firm Current Status: Final Allegations: THE CFTC'S COMPLAINT ALLEGED THAT E.F.HUTTON & CO. FAILED TO DILIGENTLY SUPERVISE MOGENS M. WASSERMAN, A REGISTERED ACCOUNT EXECUTIVE EMPLOYED BY THE FIRM. WASSERMAN IS ALLEGED TO HAVE AIDED AND ABETTED THE FRAUDULENT CONDUCT OF MARK ROSS WEINBERG. WEINBERG, WHO WAS NEVER EMPLOYED BY E.F.HUTTON, OPENED ACCOUNTS AT THE FIRM, WHICH ACCOUNTS WERE SERVICED BY WASSERMAN. WEINBERG IS ALLEGED TO HAVE USED THESE ACCOUNTS IN AN ELABORATE SCHEME TO TO STEAL MONEY FROM PUBLIC INVESTORS. E.F.HUTTON WAS NOT ALLEGED TO HAVE BEEN INVOLVED IN WEINBERG'S SCHEME. IOYRTTAOISHELGSGBWEA,CIEEWYMGENMOPRERO Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 09/21/1989 Docket/Case Number: NOT GIVEN

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 09/21/1989 Sanctions Ordered: Monetary/Fine $50,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: THE CFTC ENTERED AN OPINION AND ORDER ACCEPTING E.F.HUTTON'S OFFER OF SETTLEMENT. THE FIRM WAS ORDERED TO CEASE AND DESIST FROM FURTHER VIOLATIONS AND PAY A CIVIL PENALTY OF $50,000.00. i Disclosure 149 of 359 Reporting Source: Firm

Current Status: Final Allegations: THE STATEMENT OF CHARGES ALLEGED THAT E.F.HUTTON & CO. HAD FAILED TO ADEQUATELY SUPERVISE THE SALES ACTIVITIES OF FIVE ACCOUNT EXECUTIVES. STATEMENT ALSO ALLEGED HUTTON FAILED TO ADEQUATELY SUPERVISE SIX INDIVIDUALS BY ALLOWING THEM TO ACT IN THE CAPACITY OF A REGISTERED OPTION PRINCIPAL WHILE SUCH INDIVIDUALS WERE NOT REGISTERED WITH THE CBOE. FINALLY, THE STATEMENT ALLEGED HUTTON FAILED TO RETAIN ALL DOCUMENTS WHICH WOULD VERIFY THAT THREE PUBLIC CUSTOMER ACCOUNTS WERE PROPERLY APPROVED FOR DISCRETIONARY TRADING. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 11/16/1989 Docket/Case Number: 88-0058(G)

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 11/16/1989 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE VIOLATIONS ALLEGED IN THE CBOE'S STATEMENT OF CHARGES, E.F.HUTTON CONSENTED TO THE ENTRY OF THE ORDER AND A PENALTY OF A CENSURE AND A $7,500.00 FINE. i Disclosure 150 of 359 Reporting Source: Firm Current Status: Final Allegations: THE NASD FOUND THAT E.F.HUTTON & CO. HAD VIOLATED NASD RULES BY EMPLOYING "COLD CALLERS" WHO MADE TELEPHONE CALLS TO MEMBERS OF THE PUBLIC UTILIZING PREPARED SCRIPTS FOR THE PURPOSE OF SOLICITING TRANSACTIONS IN SECURITIES, AT TIMES WHEN ©2021 FINRA. All rights reserved. Report aboutSUCH LEHMAN CALLERS BROTHERS WERE INC. NOT NASD-REGISTERED. THE COMPLAINT 256 INITIALLY NAMED E.F.HUTTON, SHEARSON LEHMAN HUTTON AND BRANCH MANAGER S. PAUL POWERS II. www.finra.org/brokercheck User Guidance THE NASD FOUND THAT E.F.HUTTON & CO. HAD VIOLATED NASD RULES BY EMPLOYING "COLD CALLERS" WHO MADE TELEPHONE CALLS TO MEMBERS OF THE PUBLIC UTILIZING PREPARED SCRIPTS FOR THE PURPOSE OF SOLICITING TRANSACTIONS IN SECURITIES, AT TIMES WHEN SUCH CALLERS WERE NOT NASD-REGISTERED. THE COMPLAINT INITIALLY NAMED E.F.HUTTON, SHEARSON LEHMAN HUTTON AND BRANCH MANAGER S. PAUL POWERS II. Initiated By: NASD - DBCC FOR DISTRICT NO. 10 Date Initiated: 06/07/1989 Docket/Case Number: WA-613

Principal Product Type: Other Other Product Type(s): NONE SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 12/28/1989 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: THE NASD DISMISSED THE COMPLAINT AGAINST THE BRANCH MANAGER AND SHEARSON LEHMAN HUTTON. THE NASD FOUND THAT E.F.HUTTON HAD VIOLATED NASD BY-LAWS AND RULES. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, E.F. HUTTON CONSENTED TO THE ENTRY OF AN ORDER OF CENSURE AND THE IMPOSITION OF A $15,000.00 FINE. i Disclosure 151 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON MAINTAINED FCOJ FUTURES IN EXCESS OF THE SPECULATIVE POSITION LIMITS IMPOSED BY THE CITRUS ASSOCIATES OF THE NYCE. Initiated By: NEW YORK COTTON EXCHANGE (CITRUS ASSOC.) Date Initiated: 01/11/1989 Docket/Case Number: 88-128

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Consent Resolution Date: 01/11/1989 Sanctions Ordered: Monetary/Fine $1,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATION OUTLINED ABOVE, SLH CONSENTED TO THE IMPOSITION OF A FINE IN THE AMOUNT OF $1,500.00. i Disclosure 152 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON HAD FAILED TO PROPERLY TIME-STAMP ORDERS ON ONE DAY IN AUGUST 1988. Initiated By: NEW YORK MERCANTILE EXCHANGE Date Initiated: 01/27/1989 Docket/Case Number: 88-11

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 01/27/1989 Sanctions Ordered: Monetary/Fine $20,000.00 Other Sanctions Ordered: SUBMIT STATEMENT DESCRIBING PROCEDURES ADOPTED TO PREVENT THE REOCCURRENCE OF THE ALLEGATIONS.

©2021Sanction FINRA. Details: All rights reserved. Report aboutWITHOUT LEHMAN ADMITTING BROTHERS INC. OR DENYING THE ALLEGATIONS OUTLINED ABOVE, 258 SLH CONSENTED TO FINDINGS THAT A REASONABLE BASIS EXISTED TO BELIEVE THAT SUCH ALLEGATIONS HAD OCCURRED, CONSENTED TO THE IMPOSITION OF A $20,000.00 FINE, AND AGREED TO SUBMIT A STATEMENT DESCRIBING PROCEDURES ADOPTED TO PREVENT THE REOCCURRENCE OF THE ALLEGATIONS. www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OUTLINED ABOVE, SLH CONSENTED TO FINDINGS THAT A REASONABLE BASIS EXISTED TO BELIEVE THAT SUCH ALLEGATIONS HAD OCCURRED, CONSENTED TO THE IMPOSITION OF A $20,000.00 FINE, AND AGREED TO SUBMIT A STATEMENT DESCRIBING PROCEDURES ADOPTED TO PREVENT THE REOCCURRENCE OF THE ALLEGATIONS. i Disclosure 153 of 359 Reporting Source: Firm Current Status: Final Allegations: SHEARSON LEHMAN HUTTON ALLEGEDLY FAILED TO FURNISH INFORMATION TO THE EXCHANGE ON CUSTOMER COMPLAINTS WITHIN SPECIFIED TIME PERIODS. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 01/30/1989 Docket/Case Number: NOT NUMBERED

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Settled Resolution Date: 01/30/1989 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: SLH CONSENTED TO THE IMPOSITION OF A $1,000.00 FINE FOR THE ALLEGED VIOLATION. i Disclosure 154 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT E.F. HUTTON & CO., INC. FAILED TO FILE IN A TIMELY AND ACCURATE MANNER THE REQUIRED LIQUIDATION REPORTS AND ©2021 FINRA. All rights reserved. Report aboutCORRECTIONS LEHMAN BROTHERS TO THE INC. COMMODITY CLEARING CORPORATIONS'S DAILY 259 GROSS POSITION REPORT FOR OPTIONS CONTRACTS OPEN ON ITS BOOKS. www.finra.org/brokercheck User Guidance

IT WAS ALLEGED THAT E.F. HUTTON & CO., INC. FAILED TO FILE IN A TIMELY AND ACCURATE MANNER THE REQUIRED LIQUIDATION REPORTS AND CORRECTIONS TO THE COMMODITY CLEARING CORPORATIONS'S DAILY GROSS POSITION REPORT FOR OPTIONS CONTRACTS OPEN ON ITS BOOKS. Initiated By: NEW YORK COTTON EXCHANGE Date Initiated: 01/04/1989 Docket/Case Number: C-88-1

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 02/13/1989 Sanctions Ordered: Monetary/Fine $4,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OUTLINED ABOVE, E.F. HUTTON AGREED TO THE IMPOSITION OF A $4,000.00 FINE. i Disclosure 155 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON IMPROPERLY CLASSIFIED ACCOUNTS TO BE MARGINED AS HEDGED RATHER THAN SPECULATIVE. Initiated By: NEW YORK COTTON EXCHANGE (CITRUS ASSOC.) Date Initiated: 04/24/1989 Docket/Case Number: 88-061A

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 260 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief FINE Sought:

Resolution: Stipulation and Consent Resolution Date: 04/24/1989 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SLH CONSENTED TO A $2,000.00 FINE. i Disclosure 156 of 359 Reporting Source: Firm Current Status: Final Allegations: THE NYCE ACCEPTED SHEARSON LEHMAN HUTTON'S STIPULATION AND CONSENT IN RELATION TO ITS SUBMISSION OF SPEC HEDGE REPORTS ALLEGED TO BE INACCURATE. Initiated By: NEW YORK COTTON EXCHANGE (CITRUS ASSOC.) Date Initiated: 04/24/1989 Docket/Case Number: 88-061

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Stipulation and Consent Resolution Date: 04/24/1989 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: SUPERVISION OF FIRM'S SPEC/HEDGE REPORTS. Sanction Details: WITHOUT ADMITTING OR DENYING ALLEGATIONS THAT THE FIRM HAD SUBMITTED INACCURATE SPEC/HEDGE REPORTS, SHEARSON LEHMAN HUTTON CONSENTED TO A $10,000.00 FINE AND SIX MONTHS FURTHER SUPERVISION OF ITS SPEC/HEDGE REPORT.

i Disclosure 157 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON HAD VIOLATED EXCHANGE RULES BY FAILING TO PROVIDE RECORDS AND INFORMATION TO THE EXCHANGE IN A TIMELY MANNER. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 04/25/1989 Docket/Case Number: 89-44

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Stipulation and Consent Resolution Date: 04/25/1989 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: THE NYSE ACCEPTED THE STIPULATION OF FACTS AND CONSENT TO PENALTY ENTERED INTO BY SLH AND THE EXCHANGE'S DIVISION OF ENFORCEMENT WHEREIN, WITHOUT ADMITTING OR DENYING ALLEGATIONS THAT IT HAD VIOLATED EXCHANGE RULES, SLH CONSENTED TO THE IMPOSITION OF A CENSURE AND A $50,000.00 FINE. i Disclosure 158 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS FOUND THAT E.F.HUTTON AND ONE OF ITS BRANCH MANAGERS HAD FAILED TO SUPERVISE ONE OF THE FIRM'S AGENTS FROM 1982 THROUGH 1984. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 262 www.finra.org/brokercheck User Guidance

Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 10/12/1988 Docket/Case Number: 88-0100(B);88-0100(C)

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 10/12/1989 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM AND THE MANAGER CONSENTED TO THE FINDINGS AND AGREED TO THE IMPOSITION OF A JOINT AND SEVERAL FINE IN THE AMOUNT OF $5,000.00. i Disclosure 159 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS FOUND THAT E.F. HUTTON & CO., INC. FAILED TO SUPERVISE ONE OF ITS AGENTS IN THAT IT HAD ALLOWED THE AGENT TO EFFECT TRANSACTIONS IN FOUR PUBLIC CUSTOMER ACCOUNTS WHICH WERE EXCESSIVE IN FREQUENCY, AND THAT IT HAD FAILED TO REPORT INTERNAL DISCIPLINE IMPOSED ON THE AGENT. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 10/12/1988 Docket/Case Number: 88-0021

Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 10/12/1988 Sanctions Ordered: Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: E.F.HUTTON CONSENTED TO THE FINDINGS AND AGREED TO THE IMPOSITION OF A $7,500.00 FINE. i Disclosure 160 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED SHEARSON LEHMAN HUTTON FAILED TO FILE REPORTS OF FYTR R OPTIONS REPORTABLE ACCOUNTS IN A TIMELY MANNER AS REQUIRED BY THE NYCE IN JUNE, JULY AND OCTOBER 1988. Initiated By: NEW YORK COTTON EXCHANGE Date Initiated: 01/11/1989 Docket/Case Number: 88-111;88-171

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Settled Resolution Date: 01/11/1989 Sanctions Ordered: Monetary/Fine $1,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING NOR DENYING THE ALLEGATIONS THAT IT HAD FAILED TO DO SO, THE FIRM CONSENTED TO THE IMPOSITION OF A FINE IN THE AMOUNT OF $1,500.00. i Disclosure 161 of 359

Reporting Source: Firm Current Status: Final Allegations: ORDER BY MICHIGAN CORPORATION AND SECURITIES BUREAU ALLEGED THAT E.F. HUTTON & CO. INC., THROUGH ONE OF ITS FORMER REPRESENTATIVES, EXECUTED TWO ORDERS ON BEHALF OF A CUSTOMER WITHOUT THE CUSTOMER'S AUTHORIZATION. Initiated By: STATE OF MICHIGAN Date Initiated: 01/12/1989 Docket/Case Number: BD-8023

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 07/14/1989 Sanctions Ordered: Censure Monetary/Fine $12,500.00 Other Sanctions Ordered: Sanction Details: E.F. HUTTON & CO., INC., WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, CONSENTED TO THE ENTRY OF A CONSENT FINAL ORDER BY THE DIRECTOR OF THE CORPORATION & SECURITIES BUREAU OF MICHIGAN. THE FIRM WAS CENSURED, AGREED TO PAY A CIVIL PENALTY OF $5,000.00, AND AGREED TO REIMBURSE THE BUREAU IN THE AMOUNT OF $7,500.00 FOR ITS INVESTIGATIVE COSTS. i Disclosure 162 of 359 Reporting Source: Firm Current Status: Final Allegations: STATEMENT OF CHARGES AGAINST E.F. HUTTON & CO. INC. ALLEGED THAT, DURING THE PERIOD JANUARY 1983 THROUGH JUNE 1986, HUTTON VIOLATED EXCHANGE RULES BY FAILING TO ADEQUATELY SUPERVISE A REGISTERED REPRESENTATIVE AND BY ALLOWING THE REPRESENTATIVE TO EFFECT NUMEROUS STOCK AND OPTION TRANSACTIONS THAT WERE ©2021 FINRA. All rights reserved. Report aboutEXCESSIVE LEHMAN BROTHERS IN SIZE AND/OR INC. FREQUENCY. 265 STATEMENT OF CHARGES AGAINST E.F. HUTTON & CO. INC. ALLEGED www.finra.org/brokercheck THAT, DURING THE PERIOD JANUARY 1983 THROUGH JUNE 1986, HUTTON User Guidance VIOLATED EXCHANGE RULES BY FAILING TO ADEQUATELY SUPERVISE A REGISTERED REPRESENTATIVE AND BY ALLOWING THE REPRESENTATIVE TO EFFECT NUMEROUS STOCK AND OPTION TRANSACTIONS THAT WERE EXCESSIVE IN SIZE AND/OR FREQUENCY. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 02/16/1990 Docket/Case Number: 89-0136

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 06/20/1990 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE VIOLATIONS ALLEGED IN THE CBOE'S STATEMENT OF CHARGES, HUTTON AND CARL SETTE CONSENTED TO A CENSURE AND A JOINT AND SEVERAL FINE OF $15,000.00. IN ADDITION, SETTE WILL RETAKE AND MUST SUCCESSFULLY COMPLETE THE SERIES 4 EXAMINATION AND SUBMIT PROOF THAT HE PASSED THE EXAM TO THE CBOE. i Disclosure 163 of 359 Reporting Source: Firm Current Status: Final Allegations: NYME FOUND THAT SHEARSON LEHMAN BROTHERS, ON BEHALF OF A CUSTOMER, WAS LATE IN PERFORMANCE OF A SHORT DELIVERY OBLIGATION UNDER TENDER NUMBER 6 OF THE OCTOBER 1989 UNLEADED GASOLINE FUTURES COMTRACT ("TN6"). THE NYME FOUND THAT THE FIRM WAS LATE IN PERFORMANCE FOR ONE DAY IN THE DELIVERY OF EIGHTY FIVE CONTRACTS IN SATISFACTION OF TN6. Initiated By: NEW YORK MERCANTILE EXCHANGE Date Initiated: 10/11/1990 Docket/Case Number: N/A

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief NOTICE OF ASSESSMENT Sought:

Resolution: Stipulation and Consent Resolution Date: 05/07/1990 Sanctions Ordered: Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: FIRM WAS ASSESSED A PENALTY OF $25,000.00. i Disclosure 164 of 359 Reporting Source: Firm Current Status: Final Allegations: NOT SPECIFIED. Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 09/25/1990 Docket/Case Number: N/A

Principal Product Type: Other Other Product Type(s): FUTURES. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 09/25/1990 Sanctions Ordered: Monetary/Fine $220,000.00 Other Sanctions Ordered: Sanction Details: THE CFTC ACCEPTED AN OFFER OF SETTLEMENT MADE BY SHEARSON LEHMAN BROTHERS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE CFTC'S COMPLAINT, THE FIRM CONSENTED TO THE ©2021 FINRA. All rights reserved. Report aboutPAYMENT LEHMAN OF BROTHERS A FINE INC.IN THE AMOUNT OF $220,000.00 AND AGREED TO 267 CERTAIN OTHER UNDERTAKINGS AS LISTED IN THE OPINION AND ORDER ACCEPTING OFFER OF SETTLEMENT. www.finra.org/brokercheck User Guidance

THE CFTC ACCEPTED AN OFFER OF SETTLEMENT MADE BY SHEARSON LEHMAN BROTHERS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE CFTC'S COMPLAINT, THE FIRM CONSENTED TO THE PAYMENT OF A FINE IN THE AMOUNT OF $220,000.00 AND AGREED TO CERTAIN OTHER UNDERTAKINGS AS LISTED IN THE OPINION AND ORDER ACCEPTING OFFER OF SETTLEMENT. i Disclosure 165 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON, IN 1989, EMPLOYED, APPOINTED OR AUTHORIZED NUMEROUS INDIVIDUALS TO ACT AS INVESTMENT ADVISOR AGENTS IN CONNECTICUT WITHOUT BEING REGISTERED AS SUCH WITH THE STATE. Initiated By: STATE OF CONNECTICUT Date Initiated: 07/05/1990 Docket/Case Number: N/A

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief UNREGISTERED PERSONNEL. Sought:

Resolution: Stipulation and Consent Resolution Date: 01/08/1991 Sanctions Ordered: Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: FIRM AND STATE ENTERED INTO A STIPULATION AND AGREEMENT IN WHICH FIRM AGREED, FOR PURPOSES OF SETTLING THE ACTIONS AND IN LIEU OF ANY PROCEEDING OR ACTION, TO 1) PAY TO THE STATE $250,000.00 (ALLOCATED AS $175,000.00 CIVIL PENALTY AND $75,000.00 CONTRIBUTED TO THE STATE'S INVESTOR EDUCATION FUND); 2) TO ISSUE A "COMPLIANCE ALERT" WITHIN ONE HUNDRED TWENTY DAYS OF THE DAY OF THE STIPULATION AND AGREEMENT; 3) TO REVISE ITS POLICIES, REGULATIONS AND PROCEDURES MANUAL TO MAKE FIRM PERSONNEL AWARE OF THE STATE'S REGISTRATION REQUIREMENTS; 4) WITHIN ONE HUNDRED TWENTY DAYS, PROVIDE A WRITTEN REPORT TO THE STATE REGARDING THESE MEASURES. THE STIPULATION AND AGREEMENT ALSO NOTES THE FIRM'S CONTRIBUTION OF $75,000.00 TO CONNECTICUT- ©2021 FINRA. All rights reserved. Report aboutBASED LEHMAN CHARITABLE BROTHERS INC.ORGANIZATIONS. 268 FIRM AND STATE ENTERED INTO A STIPULATION AND AGREEMENT IN WHICH FIRM AGREED, FOR PURPOSES OF SETTLING THE ACTIONS AND IN LIEU OF ANY PROCEEDING OR ACTION, TO 1) PAY TO THE STATE $250,000.00 (ALLOCATED AS $175,000.00 CIVIL PENALTY AND $75,000.00 CONTRIBUTED TO THE STATE'S INVESTOR EDUCATION FUND); 2) TO ISSUE A "COMPLIANCE ALERT" WITHIN ONE HUNDRED TWENTY DAYS OF THE DAY OF THE STIPULATION AND AGREEMENT; 3) TO REVISE ITS POLICIES, www.finra.org/brokercheck REGULATIONS AND PROCEDURES MANUAL TO MAKE FIRM PERSONNEL User Guidance AWARE OF THE STATE'S REGISTRATION REQUIREMENTS; 4) WITHIN ONE HUNDRED TWENTY DAYS, PROVIDE A WRITTEN REPORT TO THE STATE REGARDING THESE MEASURES. THE STIPULATION AND AGREEMENT ALSO NOTES THE FIRM'S CONTRIBUTION OF $75,000.00 TO CONNECTICUT- BASED CHARITABLE ORGANIZATIONS. i Disclosure 166 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS AND THE FORMER BRANCH MANAGER OF ITS CLEVELAND, OH OFFICE, STEPHEN J. WEINBERG, FAILED TO ADEQUATELY SUPERVISE THE ACTIVITIES OF SHELDON STRAUSS, A REPRESENTATIVE IN THIS OFFICE. MR. STRAUSS WAS ALLEGED TO HAVE, AMONG OTHER THINGS, ENGAGED IN UNSUITABLE TRANSACTIONS, UNAUTHORIZED TRANSACTIONS, UNAUTHORIZED USE OF MARGIN AND THE EXERCISE OF DISCRETION WITHOUT WRITTEN AUTHORITY IN A NUMBER OF CUSTOMER ACCOUNTS. Initiated By: NASD DBCC FOR DISTRICT NO. 9 Date Initiated: 03/16/1989 Docket/Case Number: CLE-344

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 01/14/1991 Sanctions Ordered: Censure Monetary/Fine $60,000.00 Other Sanctions Ordered: Sanction Details: FIRM, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE NASD'S COMPLAINT, CONSENTED TO THE IMPOSITION OF THE SANCTIONS OF A CENSURE AND A $60,000.00 FINE. THE NASD'S BOARD OF GOVERNORS ALSO ACCEPTED AN OFFER OF SETTLEMENT FROM WEINBERG IN WHICH, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE COMPLAINT, HE CONSENTED TO THE IMPOSITION OF A CENSURE, A TEN DAY SUSPENSION FROM ASSOCIATION WITH ANY NASD MEMBER FIRM AND A $10,000.00 FINE.

i Disclosure 167 of 359 Reporting Source: Firm Current Status: Final Allegations: SHEARSON LEHMAN BROTHERS WAS CITED FOR TEN POSSIBLE VIOLATIONS OF SPECULATIVE POSITION LIMIT RULE 13.02(B). Initiated By: COFFEE, SUGAR AND COCOA EXCHANGE Date Initiated: 12/27/1990 Docket/Case Number: N/A

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief POSSIBLE RULE VIOLATIONS Sought:

Resolution: Settled Resolution Date: 12/27/1990 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: FIRM ENTERED INTO A SETTLEMENT AGREEMENT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THAT AGREEMENT, THE FIRM AGREED TO THE IMPOSITION OF A $5,000.00 FINE FOR THE POSSIBLE RULE VIOLATIONS. i Disclosure 168 of 359 Reporting Source: Firm Current Status: Final Allegations: COMPLAINT BY CBT CHARGED THAT SHEARSON LEHMAN BROTHERS VIOLATED CERTAIN OF ITS RULES STEMMING FROM THE ALLEGED FAILURE OF A SHEARSON BROKER TO EXECUTE A CUSTOMER ORDER TO SELL 200 MARCH 1990 U.S. TREASURY BOND FUTURES CONTRACTS AT 100.10. Initiated By: CHICAGO BOARD OF TRADE

Date Initiated: 05/31/1990 Docket/Case Number: 90-MAV-02

Principal Product Type: Futures - Financial Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Consent Resolution Date: 12/06/1990 Sanctions Ordered: Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT, SHEARSON CONSENTED TO THE PAYMENT OF A FINE IN THE AMOUNT OF $15,000.00. i Disclosure 169 of 359 Reporting Source: Firm Current Status: Final Allegations: THE PSE FOUND THAT THE MANNER IN WHICH THE ORDERS IN QUESTION WERE REPRESENTED ON THE PSE OPTIONS FLOOR CONSTITUTED A VIOLATION OF PSE RULE 6.47 BY SHEARSON LEHMAN BROTHERS. Initiated By: PACIFIC STOCK EXCHANGE Date Initiated: 12/01/1990 Docket/Case Number: C-80912-1

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Settled

Resolution Date: 12/01/1990 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ANY FINDINGS OF FACT, SHEARSON AGREED TO PAY A FINE OF $2,500.00 FOR THIS VIOLATION. ALL CHARGES AGAINST REGISTERED REPRESENTATIVE AND ALL OTHER CHARGES AGAINST SHEARSON WERE DISMISSED. i Disclosure 170 of 359 Reporting Source: Firm Current Status: Final Allegations: THE NYSE FOUND THAT SHEARSON LEHMAN BROTHERS HAD VIOLATED RULE 351(A) BY FAILING TO FILE AN AMENDED FORM U-5 NOTIFYING THE NYSE THAT A CUSTOMER COMPLAINT HAD BEEN FILED AGAINST ONE OF SHEARSON'S FORMER REGISTERED REPRESENTATIVES. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 11/27/1990 Docket/Case Number: NONE

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION Sought:

Resolution: Settled Resolution Date: 11/27/1999 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: SHEARSON DECIDED NOT TO CONTEST THE MATTER AND AGREED TO PAY A FINE OF $1,000.00. i Disclosure 171 of 359 Reporting Source: Firm

Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS VIOLATED CERTAIN NYCE RULES BY FAILING TO SUPERVISE THE EXECUTION OF NUMEROUS ORDERS AND FAILING TO PREPARE AND/OR MAINTAIN BRANCH ORDER TICKETS CORRESPONDING TO ORDERS RECEIVED BETWEEN APRIL 20-27, 1988. Initiated By: NEW YORK COTTON EXCHANGE CITRUS ASSOCIATES Date Initiated: 10/01/1990 Docket/Case Number: 90-028

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION Sought:

Resolution: Settled Resolution Date: 10/01/1990 Sanctions Ordered: Monetary/Fine $17,500.00 Other Sanctions Ordered: Sanction Details: SHEARSON WAS FINED $17,500.00. i Disclosure 172 of 359 Reporting Source: Firm Current Status: Final Allegations: SUIT BROUGHT BY US DEPARTMENT OF LABOR AGAINST SHEARSON LEHMAN HUTTON INC. AND OTHERS REGARDING THEIR HANDLING OF CERTAIN NEW YORK STATE TEAMSTERS BENEFIT PLAN ACCOUNTS. Initiated By: US DEPARTMENT OF LABOR Date Initiated: 05/01/1989 Docket/Case Number: 89-CV-547

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED

Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 09/10/1990 Sanctions Ordered: Monetary/Fine $2,000,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE DEPARTMENT'S COMPLAINT, SHEARSON CONSENTED TO THE PAYMENT IN THE AMOUNT OF $2,000,000.00 TO THE NEW YORK STATE TEAMSTERS CONFERENCE PENSION & RETIREMENT FUND, THE UPSTATE TEAMSTERS PENSION & RETIREMENT FUND AND THE NEW YORK STATE TEAMSTERS JOINT COUNCIL 18 HEALTH AND HOSPITAL FUND AND AGREED TO CERTAIN OTHER UNDERTAKINGS AS LISTED IN THE CONSENT ORDER. i Disclosure 173 of 359 Reporting Source: Firm Current Status: Final Allegations: THE OFFER OF SETTLEMENT (THAT SHEARSON LEHMAN BROTHERS AND ITS REPRESENTATIVE BRUCE BERKOWITZ ENTERED INTO) AGREED TO FINDINGS OF FACT THAT ON OCTOBER 18TH, 1989, SHEARSON AND BERKOWITZ FAILED TO PROPERLY TALLY A CUSTOMER'S ORDERS AND CONSEQUENTLY ALLOWED THAT CUSTOMER TO ENTER ORDERS RESULTING IN THE CUSTOMER EXCEEDING THE APPLICABLE POSITION LIMIT IN STOCK OPTIONS FOR ONE DAY. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 03/06/1991 Docket/Case Number: 90-0080

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION Sought:

Resolution: Settled Resolution Date: 03/06/1991 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE VIOLATIONS ALLEGED, THE SETTLEMENT AGREED TO THE ABOVE FINDINGS OF FACT; SHEARSON AND BERKOWITZ ALSO AGREED TO THE PAYMENT OF A $1,000.00 FINE. i Disclosure 174 of 359 Reporting Source: Firm Current Status: Final Allegations: ALLEGATIONS WERE RELATIVE TO THE EXCHANGE'S APPROXIMATELY THREE YEAR INVESTIGATION CONCERNING THE SALES PRACTICES AND RELATED ACTIVITIES IN SHEARSON LEHMAN BROTHERS' OFFICE LOCATED AT 55 WATER STREET, NEW YORK, NY. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 04/01/1988 Docket/Case Number: 91-69

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 05/14/1991 Sanctions Ordered: Censure Monetary/Fine $750,000.00 Other Sanctions Ordered: UNDERTAKING BY FIRM TO REVIEW POLICIES, PROCEDURES AND SYSTEMS OF ITS MARGIN DEPARTMENT TO ENSURE COMPLIANCE WITH REGULATION T. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS ARISING FROM THE EXCHANGE'S INVESTIGATION, SHEARSON CONSENTED TO CERTAIN FINDINGS OF FACT AND THE AFOREMENTIONED CENSURE, FINE AND UNDERTAKING. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 275 www.finra.org/brokercheck User Guidance WITHOUT ADMITTING OR DENYING THE ALLEGATIONS ARISING FROM THE EXCHANGE'S INVESTIGATION, SHEARSON CONSENTED TO CERTAIN FINDINGS OF FACT AND THE AFOREMENTIONED CENSURE, FINE AND UNDERTAKING. i Disclosure 175 of 359 Reporting Source: Firm Current Status: Final Allegations: ALLEGATIONS IN THE COMMONWEALTH'S SECURITIES DIVISION'S COMPLAINT AROSE FROM E F HUTTON'S DELAY IN REGISTRATION AS AN INVESTMENT ADVISOR IN THE COMMONWEALTH IN JULY 1987. HUTTON'S REGISTRATION FORMS FOR THE FIRM AND ITS BROKERS WHO WERE ACTING AS I/A REPS WERE FILED 27 DAYS LATE. Initiated By: COMMONWEALTH OF VIRGINIA Date Initiated: 04/15/1991 Docket/Case Number: SEC900098

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Stipulation and Consent Resolution Date: 04/15/1991 Sanctions Ordered: Monetary/Fine $25,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE COMMONWEALTH'S SECURITIES DIVISION ENTERED AN ORDER ACCEPTING THE OFFER OF SETTLEMENT OF E F HUTTON. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, HUTTON AGREED TO THE FOLLOWING TERMS: 1) HUTTON WOULD MAKE A WRITTEN OFFER TO ONE CUSTOMER TO RESCIND ALL SECURITIES TRANSACTIONS EFFECTED IN THE CUSTOMER'S ACCOUNT BETWEEN THE PERIOD JULY 1, 1987 THROUGH JULY 27, 1987, INCLUSIVE, AS A RESULT OF THE INVESTMENT ADVISORY CONTRACT ENTERED INTO AND ADVICE RENDERED DURING SUCH PERIOD. THE FIRM ALSO AGREED TO A PAY A PENALTY OF $25,000.00. i Disclosure 176 of 359 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 276 www.finra.org/brokercheck User Guidance

Disclosure 176 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT, FROM APPROXIMATELY DECEMBER 1986 THROUGH APRIL 1987, E F HUTTON & COMPANY MAINTAINED A SECURITIES ACCOUNT FOR THE MONEY MAKERS OPTIO INVESTMENT CLUB, HUTTON REPRESENTATIVE CHARLES S GREENBERG BEING ITS ACCOUNT EXECUTIVE. THE STATE ALLEGED THAT THE INTERESTS IN THE CLUB WERE SECURITIES THAT WERE REQUIRED TO BE REGISTERED PURSUANT TO THE ILLINOIS ACT. CONSEQUENTLY, THE SECURITIES DEPARTMENT ALLEGED THAT HUTTON AND MR. GREENBERG OFFERED AND SOLD UNREGISTERED SECURITIES IN VIOLATION OF ILLINOIS SECURITIES LAW. Initiated By: STATE OF ILLINOIS Date Initiated: 10/23/1989 Docket/Case Number: 87-00092

Principal Product Type: Other Other Product Type(s): SECURITIES Principal Sanction(s)/Relief Prohibition Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/19/1991 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: HUTTON ENTERED INTO A STIPULATION AND CONSENT WITHOUT ADMITTING OR DENYING THE CHARGES. HUTTON AND GREENBERG CONSENTED TO THE ENTRY OF AN ORDER OF PROHIBITION AND EACH AGREED TO PAY A FINE OF $1,000.00. i Disclosure 177 of 359 Reporting Source: Firm Current Status: Final Allegations: THE CME ALLEGED THAT SHEARSON, DURING THE PERIOD APRIL 1988 THROUGH DECEMBER 1989, 1) FAILED TO SUBMIT ACCURATE CUSTOMER ©2021 FINRA. All rights reserved. Report aboutACCOUNT LEHMAN DESIGNATION BROTHERS INC. FOR CERTAIN OF ITS TRADE SUBMISSIONS; 277 2)FAILED TO RECORD CUSTOMER ACCOUNT DESIGNATIONS FOR FLOOR ORDERS; 3) FAILED TO TIME-STAMP, UPON RECEIPT, SOME CUSTOMER ORDER TICKETS; AND 4) TOOK LONGER THAN THIRTY DAYS TO PROVIDE CERTAIN REQUESTED DOCUMENTS TO THE CME. THE CME FOUND THAT THIS CONDUCT CONSTITUTED VIOLATIONS OF CME RULES 432.Q, 536.E AND 810. www.finra.org/brokercheck User Guidance

Allegations: THE CME ALLEGED THAT SHEARSON, DURING THE PERIOD APRIL 1988 THROUGH DECEMBER 1989, 1) FAILED TO SUBMIT ACCURATE CUSTOMER ACCOUNT DESIGNATION FOR CERTAIN OF ITS TRADE SUBMISSIONS; 2)FAILED TO RECORD CUSTOMER ACCOUNT DESIGNATIONS FOR FLOOR ORDERS; 3) FAILED TO TIME-STAMP, UPON RECEIPT, SOME CUSTOMER ORDER TICKETS; AND 4) TOOK LONGER THAN THIRTY DAYS TO PROVIDE CERTAIN REQUESTED DOCUMENTS TO THE CME. THE CME FOUND THAT THIS CONDUCT CONSTITUTED VIOLATIONS OF CME RULES 432.Q, 536.E AND 810. Initiated By: CHICAGO MERCANTILE EXCHANGE Date Initiated: 09/23/1991 Docket/Case Number: 91-353-BC

Principal Product Type: Other Other Product Type(s): FUTURES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATIONS; FINE Sought:

Resolution: Settled Resolution Date: 09/23/1991 Sanctions Ordered: Monetary/Fine $65,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHEARSON AGREED TO PAY A FINE OF $65,000.00. IN ACCEPTING THE OFFER OF SETTLEMENT, THE CME TOOK INTO CONSIDERATION THAT SHEARSON HAD AGREED TO REIMBURSE IT FOR A PORTION OF THE COST OF ITS INVESTIGATION. i Disclosure 178 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON 1) FAILED TO TIME-STAMP FLOOR ORDERS PROPERLY; 2) MADE INSUFFICIENT MARGIN CALLS AND IMPROPERLY REDUCED OR ELIMINATED MARGIN CALLS; 3) FAILED TO INDICATE THAT THE ACCOUNTS WERE DISCRETIONARY ON MONTHLY CUSTOMER ACCOUNT STATEMENTS FOR CERTAIN ACCOUNTS OVER WHICH SHEARSON EMPLOYEES EXERCISED DISCRETION; 4) FAILED TO SUBMIT OPTION PROMOTIONAL MATERIAL TO OIA; 5) FAILED TO NOTIFY ©2021 FINRA. All rights reserved. Report aboutOIA LEHMANOF THE BROTHERS OPENING INC. OR CLOSING OF CERTAIN OMNIBUS ACCOUNTS; 6) 278 FAILED TO SEND COPIES OF CERTAIN OPTION CUSTOMER COMPLAINTS TO OIA; AND 7) FAILED TO MAINTAIN ACCURATE BOOKS AND RECORDS. IT WAS ALLEGED THAT SHEARSON 1) FAILED TO TIME-STAMP FLOOR ORDERS PROPERLY; 2) MADE INSUFFICIENT MARGIN CALLS AND www.finra.org/brokercheck IMPROPERLY REDUCED OR ELIMINATED MARGIN CALLS; 3) FAILED TO User Guidance INDICATE THAT THE ACCOUNTS WERE DISCRETIONARY ON MONTHLY CUSTOMER ACCOUNT STATEMENTS FOR CERTAIN ACCOUNTS OVER WHICH SHEARSON EMPLOYEES EXERCISED DISCRETION; 4) FAILED TO SUBMIT OPTION PROMOTIONAL MATERIAL TO OIA; 5) FAILED TO NOTIFY OIA OF THE OPENING OR CLOSING OF CERTAIN OMNIBUS ACCOUNTS; 6) FAILED TO SEND COPIES OF CERTAIN OPTION CUSTOMER COMPLAINTS TO OIA; AND 7) FAILED TO MAINTAIN ACCURATE BOOKS AND RECORDS. Initiated By: CHICAGO BOARD OF TRADE Date Initiated: 08/26/1991 Docket/Case Number: 90-EX-32

Principal Product Type: Other Other Product Type(s): FUTURES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 08/26/1991 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHEARSON CONSENTED TO THE ORDER AND IMPOSITION OF PENALTY. i Disclosure 179 of 359 Reporting Source: Firm Current Status: Final Allegations: THE CBT ALLEGED THAT SHEARSON TRANSFERRED MISCLEARED TRADES UTILIZING AN INCORRECT EXCHANGE DESIGNATION. Initiated By: CHICAGO BOARD OF TRADE Date Initiated: 08/26/1991 Docket/Case Number: 90-MSI-75

Principal Product Type: Other Other Product Type(s): FUTURES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 279 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 08/26/1991 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE CBT'S ALLEGATION, SHEARSON CONSENTED TO THE ENTRY OF THE DECISION AND PENALTY. i Disclosure 180 of 359 Reporting Source: Firm Current Status: Final Allegations: THE EXCHANGE ALLEGED THAT SHEARSON FAILED TO PROMPTLY REPORT TO THE EXCHANGE TWO ARBITRATION AWARDS INVOLVING PUBLIC CUSTOMERS, ONE ALLEGEDLY NOT REPORTED TO THE EXCHANGE, THE OTHER REPORTED ON MAY 10, 1991. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 07/03/1991 Docket/Case Number: "UNNUMBERED"

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE Sought:

Resolution: Settled Resolution Date: 07/03/1991 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING DENYING THE VIOLATION, SHEARSON CONSENTED TO THE IMPOSITION OF A $2,500.00 FINE. i Disclosure 181 of 359 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 280 www.finra.org/brokercheck User Guidance

Disclosure 181 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT A SHEARSON PHONE CLERK FAILED TO PLACE FUTURES CONTRACTS FROM A PARTIALLY-EXECUTED CUSTOMER ORDER INTO AN ERROR ACCOUNT; AND THAT ANOTHER SHEARSON EMPLOYEE FAILED TO WRITE UP A FLOOR ORDER TICKET ON RECEIPT OF A CUSTOMER ORDER, IN VIOLATION OF CBT REGULATIONS 350.04, REGULATION INTERPRETATION 350.04A(3) AND REGULATION 465.01. Initiated By: CHICAGO BOARD OF TRADE Date Initiated: 06/24/1991 Docket/Case Number: 90-INV-98

Principal Product Type: Other Other Product Type(s): FUTURES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION AND FINE Sought:

Resolution: Consent Resolution Date: 06/24/1991 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, SHEARSON CONSENTED TO THE IMPOSITION OF A FINE OF 10K. i Disclosure 182 of 359 Reporting Source: Firm Current Status: Final Allegations: NOT AVAILABLE Initiated By: STATE OF INDIANA Date Initiated: 11/21/1991 Docket/Case Number: 91-0214 CA

Principal Product Type: Other Other Product Type(s): NOT INDICATED Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief RESTITUTION Sought:

Resolution: Consent Resolution Date: 11/21/1991 Sanctions Ordered: Monetary/Fine $5,000.00 Disgorgement/Restitution Other Sanctions Ordered: ADDITIONAL FINES/REINBURSEMENTS: $30,000.00 RESTITUTION TO CLIENT; $1,500.00 TO STATE TO COVER COSTS OF INVESTIGATION. Sanction Details: SHEARSON LEHMAN BROTHERS AND WILSON RONDINI ENTERED INTO A CONSENT AGREEMENT WITH THE INDIANA SECURITIES DIVISION. RESTITUTION/FINES/COSTS ARE OUTLINED ABOVE. i Disclosure 183 of 359 Reporting Source: Firm Current Status: Final Allegations: E F HUTTON & COMPANY, INC., JEFFREY MACKEVICH AND EUGENE MACKEVICH ALLEGEDLY OFFERED AND SOLD (BETWEEN APRIL 1986 AND DECEMBER 1987) SHARES IN THE HUTTON INVESTMENT GOVERNMENT SECURITIES SERIES (A MUTUAL FUND) TO THREE INVESTORS. MACKEVICH AND MACKEVICH WERE ALLEGED TO HAVE FAILED TO FULLY INFORM THE THREE INVESTORS OF ALL THE POTENTIAL RISKS AND ALL OF THE CONTINGENT SALES CHARGES PRIOR TO THEIR INVESTMENT IN THE FUND. Initiated By: STATE OF ILLINOIS SECURITIES DEPT Date Initiated: 05/06/1991 Docket/Case Number: 9100060

Principal Product Type: Mutual Fund(s) Other Product Type(s): GOVTS Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 282 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 08/28/1991 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: MACKEVICH AND MACKEVICH CONSENTED TO AN ORDER PROHIBITING THEM FROM OFFERING FOR SALE OR SELLING ANY SECURITIES IN THE STATE IN VIOLATION OF THE ILLINOIS SECURITIES ACT. E F HUTTON WAS FINED 10K (WHILE SHEARSON LEHMAN HUTTON HAD BEEN NAMED IN THE NOTICE OF HEARING, THE SANCTION WAS ASSESSED AGAINST E F HUTTON). i Disclosure 184 of 359 Reporting Source: Firm Current Status: Final Allegations: THE EXCHANGE ALLEGED THAT SHEARSON FAILED TO PROMPTLY REPORT TO THE EXCHANGE FOUR ARBITRATION AWARDS INVOLVING PUBLIC CUSTOMERS, IN VIOLATION OF RULE 351(A)(7). Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 10/29/1991 Docket/Case Number: "UNNUMBERED"

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Settled Resolution Date: 10/29/1991 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE VIOLATION, SHEARSON CONSENTED TO THE IMPOSITION OF A 5K FINE. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 283 www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE VIOLATION, SHEARSON CONSENTED TO THE IMPOSITION OF A 5K FINE. i Disclosure 185 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON AND ONE OF ITS FINANCIAL CONSULTANTS IN ITS CARMEL, IN OFFICE MADE MISREPRESENTATIONS TO INVESTORS, EFFECTED A TRANSACTION IN A CUSTOMER'S ACCOUNT WITHOUT AUTHORIZATION AND RECOMMENDED UNSUITABLE TRANSACTIONS. SHEARSON WAS ALLEGED TO HAVE IMPROPERLY SUPERVISED THE FINANCIAL CONSULTANT. Initiated By: STATE OF INDIANA Date Initiated: 12/06/1991 Docket/Case Number: 91-0099 SC

Principal Product Type: Direct Investment(s) - DPP & LP Interest(s) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/06/1991 Sanctions Ordered: Monetary/Fine $30,000.00 Other Sanctions Ordered: ALLOW CUSTOMER TO MAINTAIN OWNERSHIP IN LP INVESTMENT; FIRM HAD PREVIOUSLY REIMBURSED A SECOND CUSTOMER THE AMOUNT OF 70K; CONDUCT COMPLIANCE AND LEGAL ED MEETINGS SO THAT ALL REG REPS AND BOMS OF SHEARSON BRANCH OFFICES LOCATED IN INDIANA ATTEND AT LEAST ONE MEETING; IMPLEMENTATION OF NEW PROCESSES AND GUIDELINES FOR REVIEW OF CERTAIN CLIENT COMPLIANTS RECEIVED BY SHEARSON FROM INDIANA CLIENTS. Sanction Details: INDIANA SECURITIES DIVISION FILED ITS MOTION TO DISMISS ADMINISTRATIVE COMPLAINT AND TO VACATE THE ORDER TO SHOW CAUSE WITH RESPECT TO SHEARSON. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE ADMINISTRATIVE COMPLAINT, SHEARSON AGREED TO UNDERTAKINGS OUTLINED ABOVE AND PAID THE DIVISION'S COSTS OF INVESTIGATION AND A CIVIL PENALTY IN THE TOTAL AMOUNT OF 30K. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 284 INDIANA SECURITIES DIVISION FILED ITS MOTION TO DISMISS ADMINISTRATIVE COMPLAINT AND TO VACATE THE ORDER TO SHOW www.finra.org/brokercheck CAUSE WITH RESPECT TO SHEARSON. WITHOUT ADMITTING OR DENYING User Guidance THE ALLEGATIONS CONTAINED IN THE ADMINISTRATIVE COMPLAINT, SHEARSON AGREED TO UNDERTAKINGS OUTLINED ABOVE AND PAID THE DIVISION'S COSTS OF INVESTIGATION AND A CIVIL PENALTY IN THE TOTAL AMOUNT OF 30K. i Disclosure 186 of 359 Reporting Source: Firm Current Status: Final Allegations: THE CSCE ALLEGED THAT A VIOLATION MAY HAVE OCCURRED OF MEMBERSHIP RULE 1.12(C)(2)--FAILURE TO HAVE AN OFFICE TICKET TIMESTAMPED UPON RECEIPT--ON THREE OCCASIONS. Initiated By: COFFEE, SUGAR AND COCOA EXCHANGE Date Initiated: 07/28/1992 Docket/Case Number: NO. 192-20

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION Sought:

Resolution: Settled Resolution Date: 07/28/1992 Sanctions Ordered: Monetary/Fine $300.00 Other Sanctions Ordered: Sanction Details: SHEARSON LEHMAN BROTHERS, WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, ENTERED INTO A SETTLEMENT AGREEMENT AND AGREED TO PAY A $300.00 PENALTY. i Disclosure 187 of 359 Reporting Source: Firm Current Status: Final Allegations: SHEARSON WAS ALLEGED TO HAVE FAILED TO ADVISE ONE OF ITS FINANCIAL CONSULTANTS OF ADDITIONAL REGISTRATION REQUIREMENTS NEEDED TO BE A QUALIFIER. Initiated By: STATE OF SOUTH CAROLINA Date Initiated: 09/15/1992 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 285 www.finra.org/brokercheck User Guidance

Date Initiated: 09/15/1992 Docket/Case Number: N/A

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/15/1992 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: SHEARSON CONSENTED TO THE ENTRY OF AN ORDER IMPOSING ADMINISTRATIVE FINE AND CONSENT TO ORDER BY SOUTH CAROLINA SECURITIES DIVISION FOR VIOLATING THEIR CODE 35-1-410(1976). AN ADMINSTRATIVE FINE IN THE AMOUNT OF $2,500.00 WAS IMPOSED. i Disclosure 188 of 359 Reporting Source: Firm Current Status: Final Allegations: STATE OF FLORIDA ALLEGED THAT SHEARSON FAILED TO FULLY DISCLOSE FORMER SHEARSON REGISTERED REPRESENTATIVE MARK W. MCLAUGHLIN'S PRIOR DISCIPLINARY HISTORY ON FORM U-4. Initiated By: STATE OF FLORIDA DIVISION OF SECURITIES Date Initiated: 07/27/1992 Docket/Case Number: NO. 1607A-S-12/91

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution Date: 07/27/1992 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: SHEARSON, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, ENTERED INTO A STIPULATION WITH AND CONSENTED TO THE ENTRY OF A FINAL ORDER BY THE STATE OF FLORIDA, DEPARTMENT OF BANKING AND FINANCE, DIVISION OF SECURITIES AND INVESTOR PROTECTION. FIRM AGREED TO PAY A FINE OF $5,000.00. i Disclosure 189 of 359 Reporting Source: Firm Current Status: Final Allegations: ON APRIL 24, MAY 5 AND JULY 14, SHEARSON ACCEPTED FROM A CUSTOMER CONTEMPORANEOUS BUYING AND SELLING ORDERS. THE CME HEARING PANEL ALLEGED THAT THIS CONDUCT VIOLATED CME RULE 433.B. Initiated By: CHICAGO MERCANTILE EXCHANGE COMPLIANCE DEPT Date Initiated: 10/01/1992 Docket/Case Number: 92-1175-FP

Principal Product Type: Other Other Product Type(s): FUTURES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION Sought:

Resolution: Settled Resolution Date: 10/19/1992 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: SHEARSON PAID A $10,000.00 FINE. i Disclosure 190 of 359 Reporting Source: Firm

Current Status: Final Allegations: A REGISTERED SALES ASSISTANT TRANSACTED BUSINESS WITH A PENNSYLVANIA RESIDENT BEFORE BEING REGISTERED IN THAT STATE. Initiated By: COMMONWEALTH OF PENNSYLVANIA Date Initiated: 02/11/1993 Docket/Case Number: N/A

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief UNREGISTERED EMPLOYEE Sought:

Resolution: Settled Resolution Date: 04/27/1993 Sanctions Ordered: Monetary/Fine $3,500.00 Other Sanctions Ordered: Sanction Details: SHEARSON HAS PAID RETROACTIVE REGISTRATION FEES AND $3,500.00 TOWARD THE COSTS INCURRED BY THE STATE. Firm Statement JEFFREY CLARK, WHILE A REGISTERED SALES ASSISTANT, TRANSACTED BUSINESS WITH ONE PENNSYLVANIA RESIDENT PRIOR TO HIS REGISTRATION IN THAT STATE. i Disclosure 191 of 359 Reporting Source: Firm Current Status: Final Allegations: SHEARSON DID NOT REGISTER AN INVESTMENT ADVISOR AGENT IN THE STATE OF RHODE ISLAND. THE AGENT WAS HANDLING THE MANAGED ACCOUNT OF HIS MOTHER WHO HAD RESIDENCES IN CALIFORNIA AND RHODE ISLAND. SHEARSON ENTERED INTO A CONSENT AGREEMENT AND PAID RETROACTIVE REGISTRATION FEES OF $100.00. Initiated By: STATE OF RHODE ISLAND Date Initiated: 06/30/1993 Docket/Case Number: CA-93-17

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CONSENT AGREEMENT/FINE Sought:

Resolution: Consent Resolution Date: 07/07/1993 Sanctions Ordered: Monetary/Fine $100.00 Other Sanctions Ordered: Sanction Details: SHEARSON ENTERED INTO A CONSENT AGREEMENT WITH THE STATE AND PAID REGISTRATION FEE OF $100.00. i Disclosure 192 of 359 Reporting Source: Firm Current Status: Final Allegations: VIOLATION OF ARTICLE III, SECTION I OF THE RULES OF FAIR PRACTICE - AESC, ACTING THROUGH RAMESH SHAH, CONDUCTED A SECURITIES BUSINESS WHILE IT FAILED TO MAINTAIN ITS MINIMUM NET CAPITAL. Initiated By: NASD DBCC FOR DISTRICT NO. 12 Date Initiated: 03/14/1989 Docket/Case Number: NY - 7020 - AWC

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/14/1989 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 289 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: ON MARCH 14, 1989, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT SUBMITTED BY AESC AND RAMESH SHAH WAS ACCEPTED. THEY WERE CENSORED AND FINED $1,000.00. i Disclosure 193 of 359 Reporting Source: Firm Current Status: Final Allegations: THE CBT ALLEGED THAT A BRANCH OFFICE OF LEHMAN BROTHERS FAILED TO PREPARE A WRITTEN RECORD OF ORDERS WHEN THEY WERE RECEIVED, A VIOLATION OF REGULATION 465.01. Initiated By: CHICAGO BOARD OF TRADE Date Initiated: 08/30/1993 Docket/Case Number: 93-EX-102

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION AND FINE. Sought:

Resolution: Settled Resolution Date: 12/14/1993 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS AGREED TO PAY A FINE OF $1,000.00. i Disclosure 194 of 359 Reporting Source: Firm Current Status: Final Allegations: SHEARSON LEHMAN BROTHERS INC., PREDECESSOR FIRM, THROUGH BRANCH MANAGER ALLEGEDLY FAILED AND NEGLECTED TO ADEQUATELY FOLLOW AND ENFORCE SUPERVISORY PROCEDURES FOR DISBURSEMENT OF CHECKS FROM CLIENT ACCOUNTS BY PERSONNEL IN ©2021 FINRA. All rights reserved. Report aboutSHEARSON'S LEHMAN BROTHERS TULSA, INC. OKLAHOMA BRANCH. 290 www.finra.org/brokercheck User Guidance SHEARSON LEHMAN BROTHERS INC., PREDECESSOR FIRM, THROUGH BRANCH MANAGER ALLEGEDLY FAILED AND NEGLECTED TO ADEQUATELY FOLLOW AND ENFORCE SUPERVISORY PROCEDURES FOR DISBURSEMENT OF CHECKS FROM CLIENT ACCOUNTS BY PERSONNEL IN SHEARSON'S TULSA, OKLAHOMA BRANCH. Initiated By: STATE OF OKLAHOMA SECURITIES DIVISION Date Initiated: 07/11/1994 Docket/Case Number: N/A

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 07/11/1994 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: LEHMAN BROTHERS INC. ACCEPTED A CENSURE AND PAID A FINE OF $10,000.00. Firm Statement THIS MATTER INVOLVED MISAPPROPRIATION BY FORMER BROKER JERRY N. WOOD. THE SANCTIONS ARE LARGELY IDENTICAL TO THOSE IMPOSED BY THE NASD IN THIS MATTER. i Disclosure 195 of 359 Reporting Source: Firm Current Status: Final Allegations: AMERICAN STOCK EXCHANGE, ARTICLE V, SECTIONS 4(H) AND (J); FAILURE TO SUBMIT ACCURATE AUDIT TRAIL DATA. Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 11/18/1994 Docket/Case Number: N/A

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 291 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FAILURE TO SUBMIT ACCURATE AUDIT TRAIL DATA Sought:

Resolution: Consent Resolution Date: 11/18/1994 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: $5,000.00 FINE. i Disclosure 196 of 359 Reporting Source: Firm Current Status: Final Allegations: MAINE ALLEGED THAT A REGISTERED REPRESENTATIVE IN SHEARSON'S CORAL SPRINGS, FLORIDA OFFICE CONDUCTED BUSINESS IN MAINE PRIOR TO BEING PROPERLY REGISTERED. Initiated By: STATE OF MAINE SECURITIES DIVISION Date Initiated: 11/30/1994 Docket/Case Number: N/A

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 11/30/1994 Sanctions Ordered: Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: SHEARSON LEHMAN BROTHERS INC., WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, ENTERED INTO A CONSENT AGREEMENT AND PAID A PENALTY OF $3,000.00.

i Disclosure 197 of 359 Reporting Source: Firm Current Status: Final Allegations: THE OFFICE OF INVESTIGATIONS ALLEGED THAT LEHMAN BROTHERS INC. VIOLATED CBT REGULATIONS 332.02 AND 332.08 IN THAT IT HAD, ON SEVERAL OCCASIONS, INCORRECTLY KEYPUNCHED INFORMATION RELATING TO TIME BRACKET AND ORDER ENTRY TIMES INTO THE CLEARING SYSTEM. Initiated By: CHICAGO BOARD OF TRADE Date Initiated: 03/27/1995 Docket/Case Number: 94-RRR-405

Principal Product Type: Other Other Product Type(s): FUTURES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 04/10/1995 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING TO OR DENYING THAT IT HAD VIOLATED ANY REGULATIONS, THE FIRM AGREED TO PAY A FINE OF $500.00. i Disclosure 198 of 359 Reporting Source: Firm Current Status: Final Allegations: THE NEW YORK STOCK EXCHANGE ISSUED A "NOTICE OF FINE FOR MINOR VIOLATION(S) OF RULES" BY LEHMAN BROTHERS AND ITS CORPORATE PREDECESSOR, SHEARSON LEHMAN BROTHERS INC. Initiated By: NEW YORK STOCK EXCHANGE INC. Date Initiated: 12/06/1995 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 293 www.finra.org/brokercheck User Guidance

Date Initiated: 12/06/1995 Docket/Case Number: N/A

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/21/1995 Sanctions Ordered: Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: LEHMAN BROTHERS CONSENTED TO THE IMPOSITION OF THE FINE IN THE AMOUNT OF $3,000.00. Firm Statement THE MINOR VIOLATIONS RELATE TO 1) THE FIRM'S FAILURE TO TIMELY RESPOND TO AN INVESTIGATIVE REQUEST MADE TO IT CONCERNING IDENTIFICATION OF CERTAIN CUSTOMER COMPLAINTS, IN VIOLATION OF RULE 476(A)(11) AND 2) THE FIRM'S FAILURE TO INCLUDE ON A FORM U-5 FILED FOR A FORMER REGISTERED REPRESENTATIVE CERTAIN REPORTABLE CUSTOMER COMPLAINTS, WHICH THE FIRM REPORTED ON A AMENDED FORM U-5 FILED IN SEPTEMBER 1995, IN VIOLATION OF RULE 345.17. i Disclosure 199 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS INC. VIOLATED REGULATIONS UNDER THE INDIANA SECURITIES ACT REGARDING THE OFFER AND SALE OF SECURITIES. Initiated By: STATE OF INDIANA Date Initiated: 05/10/1991 Docket/Case Number: N/A

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Other ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 294 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 02/14/1994 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: ALTHOUGH SHEARSON LEHMAN BROTHERS INC. DENIED THE ALLEGATIONS, IT AGREED TO PAY THE COST OF THE INVESTIGATION IN THE AMOUNT OF $1,000.00. i Disclosure 200 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS VIOLATED CBOT REGULATIONS 332.02 AND 332.08 IN THAT IT HAD, ON SEVERAL OCCASIONS, INCORRECTLY KEYPUNCHED INFORMATION RELATING TO TIME BRACKET, ORDER TYPE AND ORDER ENTRY TIMES INTO THE CLEARING SYSTEM. Initiated By: CHICAGO BOARD OF TRADE Date Initiated: 05/06/1996 Docket/Case Number: 95-RRR-271

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Settled Resolution Date: 06/21/1996 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THAT IT HAD VIOLATED ANY REGULATIONS, THE FIRM AGREED TO PAY A FINE OF $250.00. i Disclosure 201 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN VIOLATED CBT REGULATIONS 332.02 AND 332.08 IN THAT IT HAD, ON SEVERAL OCCASIONS, INCORRECTLY KEYPUNCHED INFORMATION RELATING TO TIME BRACKET, ORDER TYPE, CONFIRMATION TIME AND ORDER ENTRY TIMES INTO THE CLEARING SYSTEM, AS WELL AS FAILED TO ENTER A FLASHED ORDER INDICATOR AND THE UDDATED ORDER ENTRY TIME FOR CANCEL/REPLACE ORDERS. Initiated By: CHICAGO BOARD OF TRADE - BUSINESS CONDUCT COMMITTEE Date Initiated: 01/31/1997 Docket/Case Number: 96-RRR-268

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Other Resolution Date: 02/14/1997 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING TO OR DENYING THAT IT HAD VIOLATED ANY REGULATIONS, LEHMAN AGREED TO PAY A FINE OF $250.00. i Disclosure 202 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT AT VARIOUS TIME DURING THE PERIOD AUGUST 31, 1995 THROUGH OCTOBER 8, 1996, LEHMAN VIOLATED RULE 11AC1-1(C) OF THE SECURITIES EXCHANGE ACT OF 1934, MARKETPLACE RULE 4613(B) ©2021 FINRA. All rights reserved. Report aboutAND LEHMAN CONDUCT BROTHERS RULES INC. 2110, 3320 AND 3010. 296 www.finra.org/brokercheck User Guidance

IT WAS ALLEGED THAT AT VARIOUS TIME DURING THE PERIOD AUGUST 31, 1995 THROUGH OCTOBER 8, 1996, LEHMAN VIOLATED RULE 11AC1-1(C) OF THE SECURITIES EXCHANGE ACT OF 1934, MARKETPLACE RULE 4613(B) AND CONDUCT RULES 2110, 3320 AND 3010. Initiated By: NASD REGULATION, INC. - MARKET REGULATION COMMITTEE Date Initiated: 07/03/1997 Docket/Case Number: CMS970020

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 06/30/1998 Sanctions Ordered: Censure Monetary/Fine $9,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS ALLEGED IN THE COMPLAINT, LEHMAN CONSENTED TO A CENSURE AND A FINE OF $9,000.00. Firm Statement CHARGES WERE ISSUED AGAINST LEHMAN BROTHERS ALLEGING THAT IT FAILED TO HONOR THE QUOTATIONS IT CAUSED TO BE DISSEMINATED THROUGH THE NASDAQ SYSTEM AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATE SUPERVISORY PROCEDURES. i Disclosure 203 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN VIOLATED THE FOLLOWING: 1) REGULATION 444.01 IN THAT LEHMAN EXECUTED EXCHANGE OF FUTURES FOR PHYSICALS TRANSACTIONS IN WHICH QUANTITIES OF T-BOND AND FIVE-YEAR T-NOTE FUTURES EXCHANGED FOR THEIR UNDERLYING CASH GOVERNMENT SECURITIES WERE NOT EQUIVALENT; AND 2) REGULATION 480.10, IN THAT LEHMAN FAILED TO ENSURE COMPLIANCE WITH REGULATION 444.01. Initiated By: CHICAGO BOARD OF TRADE - BUSINESS CONDUCT COMMITTEE

Date Initiated: 05/21/1997 Docket/Case Number: 95-MSR-09B

Principal Product Type: Debt - Government Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 10/15/1997 Sanctions Ordered: Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ANY VIOLATION OF REGULATION 444.01, LEHMAN AGREED TO PAY A FINE OF $20,000.00 IN SETTLEMENT OF THIS MATTER. THE ALLEGED VIOLATION OF REGULATION 480.10 WAS DISMISSED. i Disclosure 204 of 359 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN VIOLATED ARTICLE V, SECTION 4(H) OF THE EXCHANGE CONSTITUTION AND EXCHANGE RULES 320 AND 342(F). Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 09/14/1998 Docket/Case Number: 98-14

Principal Product Type: Other Other Product Type(s): JAPANESE BEAR WARRANTS Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled

Resolution Date: 11/12/1998 Sanctions Ordered: Censure Monetary/Fine $225,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE EXCHANGE'S ALLEGATIONS, LEHMAN CONSENTED TO A CENSURE AND A FINE IN THE AMOUNT OF $225,000.00. Firm Statement ALLEGATIONS RELATED TO PRICING OF JAPANESE BEAR WARRANTS (A LEHMAN BROTHERS HOLDINGS INC. PRODUCT LISTED ON THE AMERICAN STOCK EXCHANGE). i Disclosure 205 of 359 Reporting Source: Regulator Current Status: Final Allegations: THE SEC'S ORDERS ALLEGE AS FOLLOWS: FROM 1990 THROUGH 1994, EACH OF THE TEN BROKERAGE FIRMS CHARGED ISSUERS OF MUNICIPAL REFUNDING BONDS EXCESSIVE, UNDISCLOSED MARKUPS ON TREASURY SECURITIES. THE FIRMS ALSO CERTIFIED THAT THE PRICES THEY CHARGED DID NOT EXCEED THE SECURITIES' FAIR MARKET VALUE UNDER THE FEDERAL TAX LAWS, EVEN THOUGH THEY KNEW OR SHOULD HAVE KNOWN THAT THEY WERE CHARGING PRICES ABOVE FAIR MARKET VALUE. THE FALSE REPRESENTATIONS BY THE FIRMS ABOUT THE FAIR MARKET VALUE OF THE SECURITIES WERE CRITICAL TO ESTABLISHING THE TAX-EXEMPT STATUS OF THE ASSOCIATED MUNICIPAL REFUNDING BONDS. THAT TAX-EXEMPT STATUS WAS THE BONDS' ESSENTIAL INVESTMENT FEATURE. IN SOME CASES, A BROKERAGE FIRM'S OVERCHARGING DIVERTED MONEY FROM THE U.S. TREASURY TO THE FIRM. IN THE REMAINING CASES, OVERCHARGING BY THE BROKERAGE FIRM TOOK MONEY AWAY FROM THE MUNICIPALITY BY REDUCING, DOLLAR FOR DOLLAR, THE SAVINGS THAT THE MUNICIPALITY RECEIVED FROM THE REFUNDING. THEREFORE, EACH OF THE FIRMS VIOLATED THE FEDERAL SECURITIES LAWS BY SELLING SECURITIES TO MUNICIPALITIES AT INFLATED PRICES AND JEOPARDIZING THE TAX-EXEMPT STATUS OF THE MUNICIPALITIES' REFUNDING BONDS. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 04/06/2000 Docket/Case Number: RELS. 33-7835; 34-42638; FILE #3-10179

Other Product Type(s): MUNICIPAL BONDS - "YIELD BURNING" Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief (1) CENSURE AND (2) DISGORGEMENT Sought:

Resolution: Consent Resolution Date: 04/06/2000 Sanctions Ordered: Censure Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: (1) A CENSURE; (2) A CEASE AND DESIST ORDER PROHIBITING FROM FUTURE VIOLATIONS OF THE SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT OF 1933; AND (3) DISGORGEMENT OF $4.95 MILLION ($4.5 MILLION TO THE TREASURY AND $450,000 TO MUNICIPAL ISSUERS). Regulator Statement +04/09/2000+ SEC NEWS DIGEST, ISSUE NO. 2000-65, DATED 04/06/2000, ENFORCEMENT PROCEEDINGS DISCLOSES: THE SEC TODAY BROUGHT AND SETTLED CIVIL ADMINISTRATIVE FRAUD CHARGES AGAINST TEN WALL STREET AND REGIONAL BROKERAGE FIRMS FOR OVERCHARGING MUNICIPALITIES FOR GOVERNMENT SECURITIES IN A PRACTICE COMMONLY KNOWN AS "YIELD BURNING." THE SETTLEMENTS ANNOUNCED TODAY ARE PART OF A GLOBAL RESOLUTION OF ALL YIELD BURNING CLAIMS WITH A TOTAL OF SEVENTEEN BROKERAGE FIRMS BY THE SEC, NASD REGULATION, INC., THE U.S. ATTORNEY FOR THE SOUTHERN DISTRICT OF NEW YORK, AND THE DEPARTMENT OF THE TREASURY. THIS GLOBAL RESOLUTION REQUIRES THE FIRMS TO PAY A TOTAL OF MORE THAN $139 MILLION. INCLUDING THE ACTIONS ANNOUNCED TODAY, MORE THAN $172 MILLION WILL HAVE BEEN PAID BY 21 FIRMS TO RESOLVE CHARGES OF YIELD BURNING AND RELATED CLAIMS. YIELD BURNING INVOLVES OVERCHARGES BY BROKERAGE FIRMS ON TREASURY SECURITIES PURCHASED WITH PROCEEDS FROM THE SALE OF MUNICIPAL BONDS. YIELD BURNING BY BROKERAGE FIRMS JEOPARDIZED THE TAX-EXEMPT STATUS OF INTEREST PAID TO HOLDERS OF THOSE BONDS. WITHOUT ADMITTING OR DENYING THE FINDINGS, EACH FIRM INCLUDING LEHMAN BROTHERS INC. CONSENTED TO A CENSURE, A CEASE AND DESIST ORDER PROHIBITING FUTURE VIOLATIONS, AND AGREED TO DISGORGE THE ILL-GOTTEN GAINS IT RECEIVED FROM THE OVERCHARGING. (RELS. 33-7835; 34-42638; FILE NO. 3-10179) i

Reporting Source: Firm Current Status: Final Allegations: IN AN ACTION BROUGHT AGAINST 10 BROKERAGE FIRMS, THE SEC ALLEGED THAT FROM 1990 THROUGHT 1994 THESE 10 FIRMS, INCLUDING LEHMAN BROTHERS, VIOLATED THE FEDERAL SECURITIES LAWS BY SELLING U.S. TREASURY SECURITIES TO MUNICIPALITIES AT PRICES NOT REASONABLY RELATED TO THE CURRENT WHOLESALE MARKET PRICES FOR THE SECURITIES UNDER THE PARTICULAR FACTS AND CIRCUMSTANCES, INCLUDING PERTINENT TAX REGULATIONS. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 04/06/2000 Docket/Case Number: FILE #3-10179

Principal Product Type: Debt - Government Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CENSURE Sought: DISGORGEMENT

Resolution: Settled Resolution Date: 04/06/2000 Sanctions Ordered: Censure Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: (1) A CENSURE; (2) A CEASE AND DESIST ORDER, PROHIBITING FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT OF 1933; AND (3) DISGORGEMENT OF $4,971,008.91 ($4,520,857.29 TO THE U.S. TREASURY AND $450,151.62 TO MUNICIPAL ISSUERS). Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS AGREED TO A CENSURE AND A DISGORGEMENT TO THE U.S. TREASURY AND THE MUNICIPAL ISSUERS. IN ADDITION, LEHMAN AGREED TO A CEASE AND DESIST ORDER. i Disclosure 206 of 359 Reporting Source: Regulator

Current Status: Final Allegations: 01-04-00, SEC RULES 10B-10 AND 11AC1 - RESPONDENT MEMBER FAILED TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS WHEN THE ORDERS WERE AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SECURITY RELATED TO THOSE ORDERS, OR WHEN THE FULL SIZE OF THE ORDERS WERE PRICED EQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER AND THE ORDERS REPRESENTED MORE THAN A DE MINIMUS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SECURITY. THE FIRM, WHEN IT ACTED AS PRINCIPAL FOR ITS OWN ACCOUNT, FAILED TO PROVIDE WRITTEN NOTIFICATION TO THE CUSTOMER THAT THE PRICE TO THE CUSTOMER WAS AN AVERAGE OF THE TRADE PRICES REPORTED TO ACT. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/24/1999 Docket/Case Number: CMS990151

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/24/1999 Sanctions Ordered: Censure Monetary/Fine $7,000.00 Other Sanctions Ordered: Sanction Details: FINED $7,000 Regulator Statement 05-25-00,$7,000 PAID ON 1/14/00, INVOICE #99-MS-1038 i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC. ("LEHMAN") WAS IN VIOLATION OF SECURITIES EXCHANGE ACT RULES 11AC1-4 AND 10B-10 Initiated By: NASD REGULATION, INC. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 302 www.finra.org/brokercheck User Guidance

Initiated By: NASD REGULATION, INC. Date Initiated: 11/23/1999 Docket/Case Number: CMS990151 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/23/1999 Sanctions Ordered: Censure Monetary/Fine $7,000.00 Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $7,000.00. PURSUANT TO NASD REGULATION, INC.'S PROCEDURES, LEHMAN WILL PAY THE FINE AS SOON AS AN INVOICE IS SENT BY NASD REGULATION, INC.'S DEPARTMENT OF FINANCE. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS. LEHMAN ACCEPTED AND CONSENTED TO THE ENTRY OF THE FOLLOWING FINDINGS: 1) ON DECEMBER 30, 1997, IN TWENTY INSTANCES, LEHMAN FAILED TO DISPLAY IMMEDIATELY THIRTEEN CUSTOMER LIMIT ORDERS, IN VIOLATION OF SECURITIES EXCHANGE ACT RULE 11AC1-4; AND 2) ON SEVEN OCCASIONS WHEN LEHMAN ACTED AS A PRINCIPAL FOR ITS OWN ACCOUNT, IT FAILED TO PROVIDE WRITTEN NOTIFICATION TO THE CUSTOMER THAT THE PRICE TO THE CUSTOMER WAS AN AVERAGE OF THE TRADE PRICES REPORTED BY LEHMAN TO ACT, IN VIOLATION OF SECURITIES EXCHANGE ACT RULE 10B-10. i Disclosure 207 of 359 Reporting Source: Regulator Current Status: Final Allegations: 12-15-99, DECEMBER 16, 1999, THE DEPARTMENT OF ENFORCEMENT ACCEPTED THE LETTER OF ACCEPTANCE,WAIVER AND CONSENT SUBMITTED BY LEHMAN BROTHERS, INC.WHEREBY THE FIRM FAILED TO REPORT MUNICIPAL SECURITIES TRADES ON A TIMELY AND ACCURATE BASIS DURING THE PERIOD JANUARY THROUGH JUNE 1999 IN VIOLATION OF MUNICIPAL SECURITIES RULEMAKING BOARD RULES ©2021 FINRA. All rights reserved. Report aboutG-12 LEHMAN AND G-14. BROTHERS INC. 303 12-15-99, DECEMBER 16, 1999, THE DEPARTMENT OF ENFORCEMENT www.finra.org/brokercheck ACCEPTED THE LETTER OF ACCEPTANCE,WAIVER AND CONSENT User Guidance SUBMITTED BY LEHMAN BROTHERS, INC.WHEREBY THE FIRM FAILED TO REPORT MUNICIPAL SECURITIES TRADES ON A TIMELY AND ACCURATE BASIS DURING THE PERIOD JANUARY THROUGH JUNE 1999 IN VIOLATION OF MUNICIPAL SECURITIES RULEMAKING BOARD RULES G-12 AND G-14. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 12/16/1999 Docket/Case Number: CAF990027

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/16/1999 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: FINED $1,000 Regulator Statement 05-22-00, $1,000 PAID ON 1/07/00, INVOICE #99-AF-1048 i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS INC.("LEHMAN") WAS IN VIOLATION OF MSRB RULES G-12 AND G-14. Initiated By: NASD REGULATION,INC. Date Initiated: 12/16/1999 Docket/Case Number: CAF990027

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/16/1999 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: THE AMOUNT OF THE FINE IS $1,000.00. THE FINE WAS PAID ON JANUARY 4TH, 2000. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, LEHMAN ACCEPTED AND CONSENTED TO THE ENTRY OF THE FOLLOWING FINDINGS: 1) DURING THE FIRST HALF OF 1999, LEHMAN'S T-INPUT PERCENTAGE WAS BELOW THE INDUSTRY T-INPUT PERCENTAGE; AND 2) BY VIRTUE OF ITS FAILURE TO PROVIDE ACCURATE AND TIMELY INFORMATION REGARDING MUNICIPAL SECURITIES TRADES TO THE NSCC DURING THE FIRST HALF OF 1999, LEHMAN VIOLATED MSRB RULES G-12 AND G-14. i Disclosure 208 of 359 Reporting Source: Regulator Current Status: Final Allegations: 6/24/99GS: ON JUNE 18, 1999, DISTRICT NO. 3 NOTIFIED RESPONDENT LEHMAN BROTHERS INC. THAT THE LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. C3B990021 WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $100,000 - (NASD RULES 2110, 2830(N), 3010, 3350(A), 6130(D)(6), AND IM 2110-1) - RESPONDENT MEMBER EXECUTED SHORT SALES AT BID PRICES LOWER THAN THE PREVIOUS INSIDE BID AND FAILED TO APPEND A SHORT SALE MODIFIER ON ELIGIBLE TRANSACTIONS THAT WERE REPORTED THROUGH "ACT"; FAILED TO INCLUDE REQUIRED DISCLOSURE LANGUAGE ON APPROXIMATELY 4,100 CONFIRMATIONS MAILED TO PUBLIC CUSTOMERS WHO HAD PURCHASED APPROXIMATELY $165 MILLION IN INVESTMENT COMPANY SHARES WHICH WERE SUBJECT TO A SALES CHARGE UPON REDEMPTION OF SHARES; FILED INACCURATE FREE RIDING QUESTIONNAIRES WITH THE NASD IN CONNECTION WITH INITIAL PUBLIC OFFERINGS IN THAT THE FIRM DID NOT DISCLOSE SALES OF THE HOT ISSUE TO CERTAIN OFFICERS AND DIRECTORS OF A BANK, SAVINGS AND LOAN, OR OTHER INSTITUTIONAL TYPE ACCOUNTS, OTHER DOMESTIC BROKER-DEALERS, DOMESTIC BANKS, TRUST COMPANIES, OR OTHER CONDUITS FOR UNDISCLOSED PRINCIPALS, AND FOREIGN BANKS, AND UNDERSTATED THE ©2021 FINRA. All rights reserved. Report aboutNUMBER LEHMAN OF BROTHERS INVESTMENT INC. PARTNERSHIPS AND CORPORATIONS THAT 305 PURCHASED SHARES OF THE HOT ISSUE; SOLD SHARES IN INITIAL PUBLIC OFFERINGS THAT TRADED AT A PREMIUM IN THE SECONDARY MARKET EITHER TO PERSONS OR ENTITIES WITHOUT OBTAINING PROPER ASSURANCES IN WRITING THAT SUCH PURCHASES WOULD BE MADE TO FILL ORDERS FOR BONA FIDE PUBLIC CUSTOMERS OR WOULD BE MADE TO UNRESTRICTED PERSONS OR ACCOUNTS; AND, FAILED TO TAKE REASONABLE STEPS TO ENSURE THAT ADEQUATE SUPERVISION IN EACH OF THESE AREAS WAS BEING CARRIED OUT, AND THAT FAILURES IN THESE AREAS WERE NOTED AND ADDRESSED IN A TIMELY MANNER). 6/24/99GS: ON JUNE 18, 1999, DISTRICT NO. 3 NOTIFIED RESPONDENT LEHMAN BROTHERS INC. THAT THE LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. C3B990021 WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $100,000 - (NASD RULES 2110, 2830(N), 3010, 3350(A), 6130(D)(6), AND IM 2110-1) - RESPONDENT MEMBER EXECUTED SHORT SALES AT BID PRICES LOWER THAN THE PREVIOUS INSIDE BID AND FAILED TO APPEND A SHORT SALE MODIFIER ON ELIGIBLE TRANSACTIONS THAT WERE REPORTED THROUGH "ACT"; FAILED TO INCLUDE REQUIRED DISCLOSURE LANGUAGE ON APPROXIMATELY 4,100 CONFIRMATIONS MAILED TO PUBLIC CUSTOMERS WHO HAD PURCHASED APPROXIMATELY $165 MILLION IN INVESTMENT COMPANY SHARES WHICH WERE SUBJECT TO A SALES CHARGE UPON REDEMPTION OF SHARES; FILED INACCURATE FREE RIDING QUESTIONNAIRES WITH THE NASD IN CONNECTION WITH INITIAL PUBLIC OFFERINGS IN THAT THE FIRM DID NOT DISCLOSE SALES OF THE HOT ISSUE TO CERTAIN www.finra.org/brokercheck OFFICERS AND DIRECTORS OF A BANK, SAVINGS AND LOAN, OR OTHER User Guidance INSTITUTIONAL TYPE ACCOUNTS, OTHER DOMESTIC BROKER-DEALERS, DOMESTIC BANKS, TRUST COMPANIES, OR OTHER CONDUITS FOR UNDISCLOSED PRINCIPALS, AND FOREIGN BANKS, AND UNDERSTATED THE NUMBER OF INVESTMENT PARTNERSHIPS AND CORPORATIONS THAT PURCHASED SHARES OF THE HOT ISSUE; SOLD SHARES IN INITIAL PUBLIC OFFERINGS THAT TRADED AT A PREMIUM IN THE SECONDARY MARKET EITHER TO PERSONS OR ENTITIES WITHOUT OBTAINING PROPER ASSURANCES IN WRITING THAT SUCH PURCHASES WOULD BE MADE TO FILL ORDERS FOR BONA FIDE PUBLIC CUSTOMERS OR WOULD BE MADE TO UNRESTRICTED PERSONS OR ACCOUNTS; AND, FAILED TO TAKE REASONABLE STEPS TO ENSURE THAT ADEQUATE SUPERVISION IN EACH OF THESE AREAS WAS BEING CARRIED OUT, AND THAT FAILURES IN THESE AREAS WERE NOTED AND ADDRESSED IN A TIMELY MANNER). Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/18/1999 Docket/Case Number: C3B990021

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/18/1999 Sanctions Ordered: Censure Monetary/Fine $100,000.00 Other Sanctions Ordered: Sanction Details: FINED Regulator Statement 10-28-99, $100,000 PAID ON 7/14/99, INVOICE #99-3B-533 i Reporting Source: Firm Current Status: Final Allegations: LEHMAN FAILED, AT VARIOUS POINTS FROM 2/95 TO 2/97, TO COMPLY WITH NASD RULES RELATING TO THE EXECUTION AND REPORTING OF SHORT SALES, CONFIRMATION REQUIREMENTS, AND FREE-RIDING AND WITHHOLDING REQUIREMENTS, AND FAILED TO MAINTAIN AND ENFORCE ©2021 FINRA. All rights reserved. Report aboutREASONABLE LEHMAN BROTHERS SUPERVISORY INC. PROCEDURES IN THESE AREAS. 306 www.finra.org/brokercheck User Guidance LEHMAN FAILED, AT VARIOUS POINTS FROM 2/95 TO 2/97, TO COMPLY WITH NASD RULES RELATING TO THE EXECUTION AND REPORTING OF SHORT SALES, CONFIRMATION REQUIREMENTS, AND FREE-RIDING AND WITHHOLDING REQUIREMENTS, AND FAILED TO MAINTAIN AND ENFORCE REASONABLE SUPERVISORY PROCEDURES IN THESE AREAS. Initiated By: NASD REGULATION, INC. Date Initiated: 06/15/1999 Docket/Case Number: AWC C3B990021

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/15/1999 Sanctions Ordered: Censure Monetary/Fine $100,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, LEHMAN CONSENTED TO THE FINDINGS AND TO A CENSURE AND FINE IN THE AMOUNT OF $100,000. i Disclosure 209 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/23/1998 Docket/Case Number: CMS980094 AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 307 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

ON OCTOBER 23, 1998, LEHMAN BROTHERS INC. (LEHM) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED WAS ACCEPTED BY NASD REGULATION INC.'S DEPARTMENT OF ENFORCEMENT AND THE NATIONAL ADJUDICATORY COUNCIL. THE AWC ALLEGES THAT THE FOLLOWING ACTIVITY OCCURRED:

LEHM FAILED TO REPORT THE CONTRA SIDE EXECUTING BROKER TO ACT IN 66 INSTANCES; AND FAILED TO ACCEPT OR DECLINE IN ACT FIVE TRANSACTIONS IN ELIGIBLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION OF SUCH TRANSACTIONS. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD MARKETPLACE RULES 6130(b) AND 6130(d).

LEHM FAILED TO ESTABLISH WRITTEN SUPERVISORY PROCEDURES RELATING TO TRADES REPORTED VIA PAPER FORM T AND FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES RELATING TO COMPLIANCE WITH THE ACT RULES. THE ABOVE CONDUCT CONSTITUTES A VIOLATION OF NASD CONDUCT RULES 2110 AND 3010.

LEHM WAS CENSURED AND FINED $7,500.

04-13-99, $7,500 PAID ON 12/11/98, INVOICE #98-MS-931 i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS WAS IN VIOLATION OF NASDR MARKETPLACE RULES 6130(B) AND 6130(D), AND NASDR CONDUCT RULES 2110 AND 3010. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 308 www.finra.org/brokercheck User Guidance

IT WAS ALLEGED THAT LEHMAN BROTHERS WAS IN VIOLATION OF NASDR MARKETPLACE RULES 6130(B) AND 6130(D), AND NASDR CONDUCT RULES 2110 AND 3010. Initiated By: NASD REGULATION, INC. Date Initiated: 10/21/1998 Docket/Case Number: CMS980094 AWC

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/23/1998 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF VIOLATIONS, LEHMAN CONSENTED TO THE ENTRY OF FINDINGS AND CONSENTED TO A CENSURE AND TO A $7,500 FINE. Firm Statement IT WAS ALLEGED THAT LEHMAN 1) FAILED TO REPORT THE CONTRA SIDE EXECUTING BROKER TO ACT, 2) FAILED TO ACCEPT OR DECLINE IN ACT TRANSACTIONS IN ELIGIBLE SECURITIES WITHIN TWENTY MINUTES AFTER EXECUTION OF SUCH TRANSACTIONS AND 3) FAILED TO ESTABLISH WRITTEN SUPERVISORY PROCEDURES RELATING TO TRADES REPORTED VIA PAPER FORM T AND FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES RELATING TO COMPLIANCE WITH THE ACT RULES. i Disclosure 210 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 07/17/1978 Docket/Case Number: R 77-209

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 07/17/1978 Regulator Statement CFTC DOCKET NO R 77-209 ORDERED TO PAY REPARATIONS, INTEREST AND FEES. i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 07/17/1978 Docket/Case Number: R77-209

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief REPARATION. Sought:

Resolution: Order Resolution Date: 07/17/1978 Sanctions Ordered: Other Sanctions Ordered: ORDERED TO PAY REPARATIONS, INTEREST AND FEES. Sanction Details: UNKNOWN (CONVERSION). i Disclosure 211 of 359 Reporting Source: Regulator

Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 05/12/1978 Docket/Case Number: R 77-167

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 05/12/1978 Regulator Statement CFTC DOCKET NO. R-77-167 5/12/78 ORDERED TO PAY REPARATIONS, INTEREST, FILING FEE AND ATTORNEY'S FEE. i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 05/12/1978 Docket/Case Number: R77-167

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief REPARATION. Sought:

Resolution Date: 05/12/1978 Sanctions Ordered: Other Sanctions Ordered: ORDERED TO PAY REPARATIONS, INTEREST, FILING FEE AND ATTORNEY'S FEE. Sanction Details: UNKNOWN (CONVERSION). i Disclosure 212 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 01/11/1979 Docket/Case Number: R 77-219

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 01/11/1979 Regulator Statement CFTC DOCKET NO. R 77-219 1/11/79 ORDERED TO PAY REPARATIONS, INTEREST AND FILING FEE J&S i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 01/11/1979 Docket/Case Number: R77-219

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief REPARATION. Sought:

Resolution: Order Resolution Date: 01/11/1979 Sanctions Ordered: Other Sanctions Ordered: ORDERED TO PAY REPARATIONS, INTEREST AND FILING FEE. Sanction Details: UNKNOWN (CONVERSION). i Disclosure 213 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 01/18/1980 Docket/Case Number: R 77-315

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 01/18/1980 Regulator Statement CFTC DOCKET NO R 77-315 1/18/80 ORDERED TO PAY REPARATIONS IN THE AMOUNT OF $29,256.25, PLUS INTEREST AT 6 PERCENT. J&S i Reporting Source: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 313 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 01/18/1980 Docket/Case Number: R77-315

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief REPARATION. Sought:

Resolution: Order Resolution Date: 01/18/1980 Sanctions Ordered: Monetary/Fine $29,256.25 Other Sanctions Ordered: ORDERED TO PAY REPARATIONS IN ABOVE AMOUNT PLUS INTEREST AT 6%. Sanction Details: SEE ABOVE. i Disclosure 214 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 11/19/1982 Docket/Case Number: 84-R29

Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 08/29/1985 Regulator Statement 9/19/85, CFTC DOCKET NO. 84-R29, THOMAS PLUNK V. SHEARSON/AMERICAN EXPRESS, INC. ON AUGUST 29, 1985, THE COMMISSION ISSUED AN ORDER OF SUMMARY AFFIRMANCE. i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 09/19/1985 Docket/Case Number: 84-R29

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief UNKNOWN (CONVERSION). Sought:

Resolution: Order Resolution Date: 08/29/1985 Sanctions Ordered: Other Sanctions Ordered: CFTC ISSUED ORDER OF SUMMARY AFFIRMANCE. Sanction Details: UNKNOWN (CONVERSION). i Disclosure 215 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 315 www.finra.org/brokercheck User Guidance

Date Initiated: 03/06/1974 Docket/Case Number: ND 74-45

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Stipulation and Consent Resolution Date: 03/06/1974 Sanctions Ordered: Suspension Other Sanctions Ordered: Sanction Details: Regulator Statement ND 73-219 11/13/73 LR-6145 COMPLAINT FILED SEEKING TO ENJOIN REGISTRANT, AND PERMANENTLY ENJOINED, BY CONSENT, FROM VIOLATIONS OF ANTI-FRAUD PROVISIONS IN PUBLIC OFFERINGS AND PRIVATE PLACEMENTS. ND 74-45 03/06/74 LR-6269 INJUNCTIVE ACTION FILED AND STIPULATION AND CONSENT ENTERED WHEREIN RESPONDENT IS SUSPENDED FROM MANAGING UNDERWRITINGS FOR 60 DAYS AND REGISTRANT AGREES TO ESTABLISH A FUND OF $300,000.00 TO BE REMITTED TO PURCHASERS OF UNDERWRITING. REGISTRANT VIOLATED ANTIFRAUD PROVISIONS IN THE OFFERING OF SECURITIES. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF ANTI-FRAUD PROVISIONS IN PUBLIC OFFERINGS AND PRIVATE PLACEMENTS. COMPLAINT FILED SEEKING TO ENJOIN REGISTRANT, AND PERMANANTLY ENJOINED, BY CONSENT, FROM VIOLATIONS OF ANTI-FRAUD PROVISIONS AS OUTLINED PREVIOUSLY.

Initiated By: NASD Date Initiated: 03/06/1974 Docket/Case Number: ND 74-45

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief VIOLATIONS OF ANTI-FRAUD PROVISIONS IN PUBLIC OFFERINGS AND Sought: PRIVATE PLACEMENTS.

Resolution: Stipulation and Consent Resolution Date: 03/06/1974 Sanctions Ordered: Suspension Other Sanctions Ordered: INJUNCTIVE ACTION FILED AND STIPULATION AND CONSENT ENTERED WHEREIN RESPONDENT WAS SUSPENDED FROM MANAGING UNDERWRITINGS FOR SIXTY DAYS AND REGISTRANT AGREED TO ESTABLISH A FUND OF $300,000.00 TO BE REMITTED TO PURCHASERS OF UNDERWRITING. REGISTRANT VIOLATED ANTI-FRAUD PROVISIONS IN THE OFFERING OF SECURITIES. Sanction Details: SEE ABOVE. i Disclosure 216 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 11/30/1983 Docket/Case Number: R 79-795-80-123

Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 11/30/1983 Sanctions Ordered: Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: Regulator Statement CFTC DOCKET NO. R 79-795-80-123; RICHARD AND RUTH PARCIASEPE, complainants, vs. SHEARSON, HAYDEN, STONE, INC., JONATHAN MUSHER AND LEONARD MERKOWITZ, respondents. ON NOVEMBER 30, 1983, THE COURT GRANTED A REVIEW OF THE ABOVE CASE. THE COURT HAD FOUND THE RESPONDENTS VIOLATED COMMODITY ANTIFRAUD PROVISIONS ON AUGUST 18, 1982 AND HAD ORDERED THE RESPONDENTS TO PAY REPARATIONS TO THE COMPLAINANTS. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATION BY SHEARSON HAYDEN STONE, JONATHAN MUSHER AND LEONARD MERKOWITZ OF COMMODITY ANTI-FRAUD PROVISIONS. Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 11/30/1983 Docket/Case Number: R 79-795-80-123

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief VIOLATION OF COMMODITY ANTI-FRAUD PROVISIONS. Sought:

Resolution: Decision Resolution Date: 11/30/1983 Sanctions Ordered: Disgorgement/Restitution Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 318 www.finra.org/brokercheck User Guidance

Sanction Details: FINDINGS OF VIOLATION OF COMMODITY ANTI-FRAUD PROVISIONS ON AUGUST 18TH, 1982; ORDERED RESPONDENTS TO PAY REPARATIONS TO COMPLAINTANTS. i Disclosure 217 of 359 Reporting Source: Regulator Current Status: Final Allegations: CFTC ORDER RECD 11/12/84: SUBSEQUENT TO AN INITIAL DECISION RENDERED JUNE 19, 1984 IN THE MATTER OF CFTC DOCKET NO. 82 R-678, WHICH WAS DEEMED TO BE AN ORDER AWARDED BY VIRTUE OF DEFAULT AGAINST THE RESPONDENT FOR FAILURE TO FILE A TIMELY RESPONSE, THE RESPONDENT FILED FOR ACCEPTANCE OF NOTICE OF APPEAL. Initiated By: COMMODITY FUTURES TRADE COMMISSION ("CFTC") Date Initiated: 06/19/1984 Docket/Case Number: 82 R-678

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 10/11/1984 Sanctions Ordered: Other Sanctions Ordered: Sanction Details: ON OCTOBER 11, 1984, THE CFTC ORDERED THAT THE INITIAL DECISION RENDERED WAS SUPPORTED BY FACT AND SUBSEQUENTLY DENIED THE RESPONDENT'S MOTION FOR APPEAL. i Reporting Source: Firm Current Status: Final Allegations: HARROLD P. BOWEN VS. KIM B. KETCHUM AND SHEARSON/AMERICAN EXPRESS. ALLEGATIONS UNKNOWN (CONVERSION), BUT APPARENT ©2021 FINRA. All rights reserved. Report aboutFAILURE LEHMAN TO BROTHERS FILE A TIMELY INC. RESPONSE (TO?). 319 www.finra.org/brokercheck User Guidance

Allegations: HARROLD P. BOWEN VS. KIM B. KETCHUM AND SHEARSON/AMERICAN EXPRESS. ALLEGATIONS UNKNOWN (CONVERSION), BUT APPARENT FAILURE TO FILE A TIMELY RESPONSE (TO?). Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 06/19/1984 Docket/Case Number: 82 R-678

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief UNKNOWN (CONVERSION). Sought:

Resolution: Decision Resolution Date: 10/11/1984 Sanctions Ordered: Other Sanctions Ordered: RESPONDENTS FILED FOR ACCEPTANCE OF NOTICE OF APPEAL. CFTC ORDERED THAT INITIAL DECISION WAS SUPPORTED BY FACT AND SUBSEQUENTLY DENIED THE RESPONDENT'S MOTION FOR APPEAL. Sanction Details: SEE ABOVE. i Disclosure 218 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 01/17/1985 Docket/Case Number: 83-R692

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 01/17/1985 Regulator Statement CFTC DOCKET NO. 83-R692, THOMAS F. RIDDICK, COMPLAINANT V. SHEARSON LEHMAN/AMERICAN EXPRESS, INC., AND BRUCE A. DREZNER, RESPONDENTS. THE COMPLAINANT ALLEGES MISREPRESENTATIONS BY RESPONDENTS AND SEEKS DAMAGES IN THE AMOUNT OF $2,273.47. THE COURT FOUND THAT DREZNER MADE MATERIAL MISREPRESENTATIONS WHICH CONSTITUTES A VIOLATION OF SECTION 4b OF THE COMMODITY EXCHANGE ACT. IN ADDITION, IT WAS CONCLUDED THAT SHEARSON IS RESPONSIBLE FOR VIOLATIONS OF THE ACT COMMITTED BY ITS AGENT, DREZNER UNDER SECTION 2(a)(1)(A) OF THE ACT. SHEARSON IS INDEPENDENTLY LIABLE FOR FAILING TO SUPERVISE ITS EMPLOYEE UNDER REGULATION 166.3 OF THE ACT. THE COURT ORDERED THAT RESPONDENTS PAY DAMAGES TO THE COMPLAINANT IN THE AMOUNT OF $2,273.47, PLUS INTEREST AND FILING FEE. LIABILITY IS JOINT AND SEVERAL. ORDER DATED 1/17/85. i Reporting Source: Firm Current Status: Final Allegations: COMPLAINTANT ALLEGED MISREPRESENTATION BY SHEARSON/AMERICAN EXPRESS AND ONE OF ITS REPRESENTATIVES. Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 01/17/1985 Docket/Case Number: 83-R692

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATIONS; FINE; FAIL TO SUPERVISE. Sought:

Other Sanctions Ordered: ABOVE AMOUNT TO COMPLAINTANT PLUS INTEREST AND FILING FEE (LIABILITY IS JOINT AND SEVERAL). Sanction Details: IT WAS FOUND THAT REPRESENTATIVE MADE MATERIAL MISREPRESENTATIONS WHICH CONSTITUTED A VIOLATION OF SECTION 4B OF THE COMMODITY EXCHANGE ACT. ALSO, IT WAS CONCLUDED SHEARSON/AMERICAN EXPRESS WAS RESPONSIBLE FOR VIOLATIONS OF THE ACT COMMITTED BY ITS REPRESENTATIVE, UNDER SECTION 2(A)(1)(A) OF THE ACT. FIRM WAS HELD INDEPENDENTLY LIABLE FOR FAILING TO SUPERVISE ITS REPRESENTATIVE UNDER REGULATION 166.3 OF THE ACT. THE COURT ORDERED RESPONDENTS TO PAY DAMAGES TO COMPLAINTANT IN THE ABOVE-INDICATED AMOUNT. i Disclosure 219 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 01/28/1983 Docket/Case Number: R 81-226-81-516

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 01/28/1983 Regulator Statement CFTC DOCKET R 81-226-81-516 AUSTIN F. MENZIES COMPLAINANT, VS. SHEARSON LOEB RHOADES, INC., RESPONDENT. DECISION RENDERED JAN. 28, 1983. THE COMPLAINANT ALLEGES THAT THE RESPONDENT PURCHASED TWO DEC. 1980 COTTON CONTRACTS THAT WERE NOT AUTHORIZED BY THE CUSTOMER. THE COURT HELD THAT THE FIRM WAS IN VIOLATION OF THE COMMISSION'S REGULATIONS RELATED TO SUPERVISION AND ORDERED THE ©2021 FINRA. All rights reserved. Report aboutFIRM LEHMAN TO PAY BROTHERS DAMAGES INC. IN THE AMOUNT OF $3,124, PLUS INTEREST AND 322 FILING FEES TO THE COMPLAINANT TO SUSTAIN THE LOSS TO THE COMPLAINANT'S ACCOUNT WHEN THE TWO DECEMBER 1980 COTTON CONTRACTS WERE SOLD BY THE RESPONDENT FIRM. CFTC DOCKET R 81-226-81-516 AUSTIN F. MENZIES COMPLAINANT, VS. SHEARSON LOEB RHOADES, INC., RESPONDENT. DECISION RENDERED JAN. 28, 1983. THE COMPLAINANT ALLEGES THAT THE RESPONDENT PURCHASED www.finra.org/brokercheck TWO DEC. 1980 COTTON CONTRACTS THAT WERE NOT AUTHORIZED BY User Guidance THE CUSTOMER. THE COURT HELD THAT THE FIRM WAS IN VIOLATION OF THE COMMISSION'S REGULATIONS RELATED TO SUPERVISION AND ORDERED THE FIRM TO PAY DAMAGES IN THE AMOUNT OF $3,124, PLUS INTEREST AND FILING FEES TO THE COMPLAINANT TO SUSTAIN THE LOSS TO THE COMPLAINANT'S ACCOUNT WHEN THE TWO DECEMBER 1980 COTTON CONTRACTS WERE SOLD BY THE RESPONDENT FIRM. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LOEB RHOADES PURCHASED TWO FUTURES CONTRACTS THAT WERE NOT AUTHORIZED BY THE CUSTOMER. Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 01/28/1983 Docket/Case Number: R81-226-81-516

Principal Product Type: Futures - Commodity Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Decision Resolution Date: 01/28/1983 Sanctions Ordered: Monetary/Fine $3,124.00 Other Sanctions Ordered: ABOVE AMOUNT OF DAMAGES TO BE PAID BY FIRM PLUS INTEREST AND FILING FEES TO COMPLAINTANT. Sanction Details: THE COMMISSION HELD THAT THE FIRM WAS IN VIOLATION OF THE COMMISSION'S REGULATIONS RELATED TO SUPERVISION AND ORDERED THE FIRM TO PAY DAMAGES AS OUTLINED ABOVE TO SUSTAIN THE LOSS TO THE COMPLAINTANT'S ACCOUNT WHEN THE TWO FUTURES CONTRACTS WERE SOLD BY THE FIRM. i Disclosure 220 of 359 Reporting Source: Regulator Current Status: Final Allegations: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 323 www.finra.org/brokercheck User Guidance

Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 06/26/1981 Docket/Case Number: R 79-359-80-45

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 06/26/1981 Sanctions Ordered: Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: Regulator Statement CFTC DOCKET NO. R 79-359-80-45: JUNE 26, 1981 COMPLAINT WAS FILED WITH THE REPARATIONS UNIT, CFTC ON OR ABOUT MARCH 27, 1979. COMPLAINT ALLEGES THAT RESPONDENT ENTERED OR CAUSED TO BE ENTERED UNAUTHORIZED TRADES IN THEIR ACCOUNT, FAILED TO PROPERLY MONITOR THE ACCOUNT AND BY REASON OF THESE ALLEGED VIOLATIONS OF THE COMMODITY EXCHANGE ACT CAUSED COMPLAINANTS TO SUSTAIN MONETARY DAMAGES IN THE AMOUNT OF APPROXIMATELY $20,000.00 PLUS THE COSTS OF THIS PROCEEDING. RESPONDENT WAS FOUND TO HAVE VIOLATED SECTIONS 4g AND 4b(C) 4g OF THE COMMODITY EXCHANGE ACT AND CAUSED COMPLAINANTS TO SUSTAIN MONETARY DAMAGES AS A RESULT OF VIOLATIONS COMMITTED BY RESPONDENT IN THE AMOUNT OF $17,974.20. RESPONDENT WAS ORDERED TO PAY COMPLAINANTS WITHIN 30 DAYS FROM THE DATE OF THIS DECISION $17,974.20, PLUS THE $25.00 FILING FEE PLUS INTEREST AT THE RATE OF 12% PER ANNUM FROM THE DATE THE ACCOUNT WAS OPENED. i ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 324 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: ALLEGED THAT RESPONDENT ENTERED OR CAUSED TO BE ENTERED UNAUTHORIZED TRADES IN COMPLAINTANT'S ACCOUNT, FAILED TO PROPERLY MONITOR ACCOUNT AND BY REASON OF THESE ALLEGED VIOLATIONS OF THE COMMODITY EXCHANGE ACT CAUSED DAMAGES OF APPROXIMATELY $20,000.00. Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 03/27/1979 Docket/Case Number: R79-359-80-45

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Decision Resolution Date: 06/26/1981 Sanctions Ordered: Monetary/Fine $17,974.20 Disgorgement/Restitution Other Sanctions Ordered: PAY ABOVE AMOUNT PLUS $25.00 FILING FEE PLUS INTEREST AT THE RATE OF 12% PER ANNUM FROM THE DATE THE ACCOUNT WAS OPENED. Sanction Details: RESPONDENT WAS FOUND TO HAVE VIOLATED SECTIONS OF THE COMMODITY EXCHANGE ACT; RESPONDENT ORDERED TO PAY CLAIMANT $17,974.20 AND OTHER AMOUNTS AS OUTLINED ABOVE. i Disclosure 221 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 04/20/1981 Docket/Case Number: R 76-22

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 04/20/1981 Sanctions Ordered: Monetary/Fine $675.50 Other Sanctions Ordered: Sanction Details: Regulator Statement CFTC DOCKET R 76-22 11/1/77: ALLEGED VIOLATION OF SECTION 4b(B) OF THE COMMODITY EXCHANGE ACT. 4/20/81: IT IS ORDERED THAT RESPONDENT SHALL PAY $675.50 PLUS INTEREST AT A RATE OF 12 PERCENT PER ANNUM AND THE $25.00 FILING FEE. J&S. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATION OF SECTION 4B(B) OF THE COMMODITY EXCHANGE ACT. Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 04/20/1981 Docket/Case Number: R76-22

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution Date: 04/20/1981 Sanctions Ordered: Monetary/Fine $675.50 Other Sanctions Ordered: PAY ABOVE FINE PLUS INTEREST AT A RATE OF 12% PER ANNUM AND $25.00 FILING FEE. Sanction Details: RESPONDENT PAID FINE AND FEE AS INDICATED ABOVE. i Disclosure 222 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 06/11/1981 Docket/Case Number: R 77-354-7821

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 07/07/1982 Sanctions Ordered: Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: Regulator Statement CFTC DOCKET NO. R 77-354-7821, JUNE 11, 1981; DECISION RELEASED JULY 7, 1982 - REPARATION PROCEEDING INSTITUTED PURSUANT TO A COMPLAINT AGAINST SHEARSON HAYDEN STONE, INC., MORRIS STEINBERG AND MARVIN KOENIG, FOR ALLEGED VIOLATIONS OF THE COMMODITY EXCHANGE ACT. COMPLAINANT ASSERTS DAMAGES IN THE AMOUNT OF $23,358.64. IN AN INITIAL DECISION AND ORDER THE COMMISSION ORDERED THAT COMPLAINANT'S ACCOUNT WITH RESPONDENTS SHALL BE CREDITED WITH THE AMOUNT OF $2,626.50 FROM RESPONDENT UNAUTHORIZED TRADE IN COMPLAINANT'S ACCOUNT IN ©2021 FINRA. All rights reserved. Report aboutVIOLATION LEHMAN BROTHERSOF THE ACT. INC. IN ALL OTHER RESPECTS, THE REMAINING 327 AVERMENTS IN THE COMPLAINT ARE DETERMINED TO BE WITHOUT MERIT AND ARE DISMISSED. CFTC DOCKET NO. R 77-354-7821, JUNE 11, 1981; DECISION RELEASED JULY 7, 1982 - REPARATION PROCEEDING INSTITUTED PURSUANT TO A COMPLAINT AGAINST SHEARSON HAYDEN STONE, INC., MORRIS STEINBERG AND MARVIN KOENIG, FOR ALLEGED VIOLATIONS OF THE COMMODITY EXCHANGE ACT. COMPLAINANT ASSERTS DAMAGES IN THE AMOUNT OF $23,358.64. IN AN INITIAL DECISION AND ORDER THE www.finra.org/brokercheck COMMISSION ORDERED THAT COMPLAINANT'S ACCOUNT WITH User Guidance RESPONDENTS SHALL BE CREDITED WITH THE AMOUNT OF $2,626.50 FROM RESPONDENT UNAUTHORIZED TRADE IN COMPLAINANT'S ACCOUNT IN VIOLATION OF THE ACT. IN ALL OTHER RESPECTS, THE REMAINING AVERMENTS IN THE COMPLAINT ARE DETERMINED TO BE WITHOUT MERIT AND ARE DISMISSED. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF COMMODITY EXCHANGE ACT BY SHEARSON HAYDEN STONE, MORRIS STEINBERG AND MARVIN KOENIG. DAMAGES OF $23,358.64 ALLEGED--REPARATION PROCEEDING. Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 06/11/1981 Docket/Case Number: R77-354-7821

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION (UNAUTHORIZED TRADE). Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 07/07/1982 Sanctions Ordered: Disgorgement/Restitution Other Sanctions Ordered: COMPLAINTANT'S ACCOUNT CREDITED $2,626.50. Sanction Details: IN A DECISION AND ORDER THE CFTC ORDERED COMPLAINTANT'S ACCOUNT BE CREDITED $2,626.50 DUE TO UNAUTHORIZED TRADE. IN ALL OTHER RESPECTS, REMAINING AVERMENTS IN COMPLAINT WERE DEEMED TO BE WITHOUT MERIT AND WERE DISMISSED. i Disclosure 223 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/13/1954 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 328 www.finra.org/brokercheck User Guidance

Date Initiated: 10/13/1954 Docket/Case Number: 34

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Other Resolution Date: 12/08/1954 Regulator Statement COMPLAINT #34 (HOLLLYWOOD, CA OFFICE) 10/13/54 CLOSED 12/8/54 i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION) Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC Date Initiated: 10/13/1954 Docket/Case Number: 34

Principal Product Type: Other Other Product Type(s): UNKNOWN Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief UNKNOWN Sought:

Resolution: Other Resolution Date: 12/08/1954 Sanctions Ordered: Monetary/Fine $0.00 Other Sanctions Ordered: UNKNOWN (CONVERSION). DUE TO THE AGE OF THIS EVENT THERE ARE NO DOCUMENTS AVAILABLE. Sanction Details: UNKNOWN (CONVERSION)

i Disclosure 224 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 01/30/1981 Docket/Case Number: R77-296

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 01/30/1981 Sanctions Ordered: Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: Regulator Statement CFTC - DOCKET NO. R 77-296 1/30/81 - RESPONDENT SHALL PAY TO COMPLAINANT A REPARATION AWARD IN THE AMOUNT OF $74.19. RESPONDENT SHALL PAY TO COMPLAINANT INTEREST AT THE RATE OF TWELVE PERCENT PER ANNUM ON THE AMOUNT OF THE REPARATION AWARD FROM THE DATE THIS INITIAL DECISION IS FILED TO THE DATE OF PAYMENT. RESPONDENT SHALL PAY TO COMPLAINANT, AS COSTS $25.00 FOR REIMBURSEMENT OF THE FILING FEE IN THIS CASE. THIS AWARD MUST BE SATISFIED WITHIN 15 DAYS FROM THE DATE ON WHICH THIS ORDER BECOMES FINAL, AS INDICATED BY A NOTICE OF SERVED PURSUANT TO RULE 12.84(e), UNLESS AN APPEAL IS FILED IN COURT WITHIN 15 DAYS FOLLOWING SUCH NOTICE. i Reporting Source: Firm

Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 01/30/1981 Docket/Case Number: R77-296

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief REPARATION. Sought:

Resolution: Order Resolution Date: 01/30/1981 Sanctions Ordered: Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: RESPONDENT PAID COMPLAINTANT A REPARATION AWARD OF $74.19. RESPONDENT PAID COMPLAINTANT INTEREST A RATE OF 12% PER ANNUM ON AMOUNT OF REPARATION AWARD FROM DATE THIS DECISION FILED TO DATE OF PAYMENT. RESPONDENT PAID $25.00 FILING FEE. i Disclosure 225 of 359 Reporting Source: Regulator Current Status: Final Allegations: REPRESENTING ITS AGENTS TO BE IN THE BUSINESS OF FINANCIAL PLANNING WITHOUT PROVIDING REQUIRED DISCLOSURE TO CLIENTS Initiated By: MN DEPT OF COMMERCE Date Initiated: 05/22/1990 Docket/Case Number: SE9001271/TMF URL for Regulatory Action: Principal Product Type: Other Product Type(s): ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 331 www.finra.org/brokercheck User Guidance

Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 05/22/1990 Sanctions Ordered: Monetary/Fine $30,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CONSENT TO CENSURE OF BD LICENSE AND FINE OF $30,000 Regulator Statement SHEARSON CONSENTED TO A CENSURE OF ITS BROKER/DEALER LICENSE AND CIVIL FINE OF $30,000 BASED UPON ALLEGATIONS THAT SHEARSON, THROUGH ITS AGENTS, USED THE TITLE "FINANCIAL CONSULTANT" WITHOUT PROVIDING DISCLOSURE OF THE AGENTS REMUNERATION AND LICENSING AS REQUIRED BY MINN RULE 2875.1051. i Reporting Source: Firm Current Status: Final Allegations: SHEARSON LEHMAN BROTHERS' REPRESENTATIVES WERE FOUND TO HAVE USED THE TITLE "FINANCIAL CONSULTANT" WITHOUT COMPLYING WITH MINNESOTA RULE PART 2875.10851 (1989); FIRM WAS FOUND ALSO TO HAVE FAILED TO ADEQUATELY SUPERVISE ITS BROKERS TO ENSURE COMPLIANCE (THE RULE REQUIRES THOSE WHO USE THE TITLE "FINANCIAL CONSULTANT"--OR SIMILAR TITLES--TO SEND A DISCLOSURE STATEMENT TO CUSTOMERS SETTING FORTH, AMONG OTHER THINGS, THE BASIS FOR THE FINANCIAL CONSULTANT'S COMPENSATION, THE PRODUCTS THAT THE FINANCIAL CONSULTANT IS AUTHORIZED TO OFFER FOR SALES AND THE LICENSES HELD BY THE FINANCIAL CONSULTANT. Initiated By: STATE OF MINNESOTA Date Initiated: 05/21/1990 Docket/Case Number: SE9001271/TMF

Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 05/21/1990 Sanctions Ordered: Censure Monetary/Fine $30,000.00 Other Sanctions Ordered: Sanction Details: FIRM CONSENTED TO THE ENTRY OF THE ORDER; IN DOING SO, IT AGREED TO 1) A CENSURE; 2) A FINE OF $30,000.00; AND 3) IMMEDIATELY COMPLY WITH THE RULE. i Disclosure 226 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/25/1989 Docket/Case Number: BOS-588

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 01/16/1990 Sanctions Ordered: Censure Monetary/Fine $1,500.00 Other Sanctions Ordered: Sanction Details: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 333 www.finra.org/brokercheck User Guidance

Sanction Details: Regulator Statement COMPLAINT NO. BOS-588 FILED APRIL 25, 1989 BY DISTRICT NO. 13 AGAINST RESPONDENTS SHEARSON LEHMAN HUTTON INC., WILLIAM ARVID ULLMARK, RONALD ALAN FURMAN AND EDWARD ANTHONY OKON ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2 AND 27(b) AND (c) OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT OKON WHILE ACTING IN THE CAPACITY OF A GENERAL SECURITIES REPRESENTATIVE FOR THE ACOCUNT OF A CUSTOMER ENGAGED IN A COURSE OF CONDUCT INVOLVING THE RECOMMENDATION, PURCHASE AND SALE OF VARIOUS SECURITIES WHICH WERE EXCESSIVE AND UNSUITABLE IN RELATION TO THE CUSTOMER'S INVESTMENT OBJECTIVES AND FINANCIAL SITUATION AND NEEDS; AND RESPONDENT MEMBER AND RESPONDENTS ULLMARK AND FURMAN FAILED TO SUPERVISE THE ACTIVITIES OF OKON.

DECISION RENDERED JANUARY 16, 1990, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BY RESPONDENTS MEMBER, ULLMARK AND OKON WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED, FINED $15,000; RESPONDENT ULLMARK IS CENSURED AND FINED $5,000 AND RESPONDENT OKON IS CENSURED, FINED $10,000 AND SUSPENDED FROM ASSOCIATION WITH ANY MEMBER OF THE NASD IN ANY CAPACITY FOR TEN (10) BUSINESS DAYS. FURTHERMORE, WITHIN SIXTY (60) DAYS AFTER OKON'S SUSPENSION, IN ORDER TO MAINTAIN HIS REGISTRATION WITH THE NASD AS A REGISTERED REPRESENTATIVE, HE MUST TAKE AND SUCCESSFULLY PASS THE SERIES 7 QUALIFICATION EXAMINATION. THE ALLEGATIONS WERE DISMISSED AS TO RESPONDENT FURMAN. ***$15,000.00 PAID ON 2/27/90 INVOICE #90-13-105*** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON FAILED TO SUPERVISE REGISTERED REPRESENTATIVE EDWARD ANTHONY OKON. OKON HAD ALLEGEDLY ENGAGED IN A COURSE OF CONDUCT INVOLVING THE RECOMMENDATION, PURCHASE AND SALE OF VARIOUS SECURITIES WHICH WERE EXCESSIVE AND UNSUITABLE. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 334 www.finra.org/brokercheck IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON FAILED TO User Guidance SUPERVISE REGISTERED REPRESENTATIVE EDWARD ANTHONY OKON. OKON HAD ALLEGEDLY ENGAGED IN A COURSE OF CONDUCT INVOLVING THE RECOMMENDATION, PURCHASE AND SALE OF VARIOUS SECURITIES WHICH WERE EXCESSIVE AND UNSUITABLE. Initiated By: NASD - DBCC FOR DISTRICT NO. 13 Date Initiated: 04/25/1989 Docket/Case Number: BOS-588

Principal Product Type: Other Other Product Type(s): "VARIOUS SECURITIES" Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 01/04/1990 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE COMPLAINT, SLH CONSENTED TO THE ENTRY OF AN ORDER OF CENSURE AND AGREED TO PAY A $15,000.00 FINE. i Disclosure 227 of 359 Reporting Source: Regulator Current Status: Final Allegations: VIOLATION OF, SECTIONS 15(C)(1) AND (2) OF THE EXCHANGE ACT, AND RULES 15C1-2 AND 15C2-7 THEREUNDER Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 01/11/1999 Docket/Case Number:

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 335 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 01/11/1999 Sanctions Ordered: Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CIVIL PENALTY OF $212,500; DISGORGEMENT OF $7,813 Regulator Statement [TOP] +02/11/99+ SEC NEWS DIGEST, ISSUE NO. 99-6, 01/11/1999, ENFORCEMENT PROCEEDINGS DISCLOSES: SEC TODAY ANNOUNCED THE INSTITUTION OF ADMINISTRATIVE PROCEEDINGS AGAINST 28 NASDAQ MARKET MAKING FIRMS AND 51 INDIVIDUALS ASSOCIATED WITH SUCH FIRMS PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AND, AS TO ONE FIRM, PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940. SIMULTANEOUSLY WITH THAT FILING, ALL OF THE RESPONDENTS CONSENTED, WITHOUT ADMITTING OR DENYING SEC?S FINDINGS, TO THE ENTRY OF ORDERS WHICH IMPOSE CIVIL PENALTIES TOTALING $26,302,500, DISGORGEMENT OF WRONGFUL GAINS TOTALING $791,525, SUSPENSIONS OR BARS, CEASE AND DESIST ORDERS AND OTHER SANCTIONS. SEC FOUND THAT THE RESPONDENTS COMMITTED VARIOUS VIOLATIONS ARISING FROM MARKET MAKING ACTIVITIES IN THE NASDAQ STOCK MARKET, INCLUDING THE COORDINATION OF QUOTATIONS AND TRANSACTIONS BY TRADERS MAKING MARKETS IN NASDAQ STOCKS IN VIOLATION OF ANTIFRAUD AND FICTITIOUS QUOTATION RULES, AND OTHER FORMS OF MARKET MANIPULATION. 2/11/99+ SEC ADMINISTRATIVE PROCEEDING FILE NO. 3- 9803 01/11/1999 DISCLOSES: SEC ACCEPTED AN OFFER OF SETTLEMENT FROM LEHMAN BROTHERS INC. ("RESPONDENT"), WITH FINDING THAT RESPONDENT TRADED NASDAQ STOCKS FOR ITS OWN ACCOUNTS AND FOR THE ACCOUNTS OF INSTITUTIONAL AND RETAIL INVESTORS, AND, AS A NASDAQ MARKET MAKER, ENGAGED IN THE FOLLOWING ACTIVITIES. (1) THE FRAUDULENT COORDINATION OF QUOTE MOVEMENTS; (2) UNDISCLOSED ARRANGEMENTS TO COORDINATE QUOTATIONS; (3) BEST EXECUTION VIOLATIONS; (4) FAILURE TO REASONABLY SUPERVISE NASDAQ TRADING; (5) UNLAWFUL PROFITS AND OTHER GAINS. SEC ORDERED THAT: (1) LEHMAN BROTHERS INC. SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATION OF, AND COMMITTING OR CAUSING ANY FUTURE VIOLATION OF, SECTIONS 15(C)(1) AND (2) OF THE EXCHANGE ACT, AND RULES 15C1-2 AND 15C2-7 THEREUNDER; (2) SHALL, PAY A CIVIL PENALTY OF $212,500 WITHIN 10 BUSINESS DAYS; (3) SHALL, PAY DISGORGEMENT OF $7,813 WITHIN 10 BUSINESS DAYS.

i Reporting Source: Firm Current Status: Final Allegations: IN AN ACTION BROUGHT AGAINST ALMOST ALL OF THE MAJOR NASDAQ MARKET MAKERS, THE SEC ALLEGED THAT IN 1994 MARKET MAKERS, INCLUDING LEHMAN BROTHERS, VIOLATED PROVISIONS OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH THEIR MARKETING MAKING ACTIVITIES IN NASDAQ SECURITIES. Initiated By: SEC Date Initiated: 01/11/1999 Docket/Case Number: FILE NO. 3-9803 (REL.40913, 40900)

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 01/11/1999 Sanctions Ordered: Monetary/Fine $212,500.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS AGREED TO PAY A CIVIL PENALTY OF $212,500 AND DISGORGEMENT OF $7,813 TO SETTLE THE MATTER. IN ADDITION, IT AGREED TO A CEASE AND DESIST ORDER. i Disclosure 228 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/19/1999 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 337 www.finra.org/brokercheck User Guidance

Date Initiated: 01/19/1999 Docket/Case Number: C10980152

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/19/1999 Sanctions Ordered: Censure Monetary/Fine $9,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 01/21/99GK: ON JANAURY 19, 1999, DISTRICT NO. 10 NOTIFIED RESPONDENT LEHMAN BROTHERS INC. THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C10980152 WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $9,000 - (MSRB RULES G-36 AND G-8 - RESPONDENT MEMBER SERVED AS SOLE OR MANAGING UNDERWRITER IN A SUBSTANTIAL NUMBER OF PRIMARY OFFERINGS OF MUNICIPAL SECURITIES AND, IN CONNECTION WITH THOSE OFFERINGS, FAILED TO SUBMIT ADVANCE REFUNDING DOCUMENTATION TO THE MSRB; FAILED TO TIMELY SUBMIT OFFICIAL STATEMENTS AND/OR OTHER DOCUMENTS TO THE MSRB; FAILED TO SEND REQUIRED DOCUMENTS TO THE MSRB BY CERTIFIED OR REGISTERED MAIL, OR SOME OTHER EQUALLY PROMPT MEANS THAT PROVIDES A RECORD OF SENDING; AND, FAILED TO MAINTAIN RECORDS AS REQUIRED BY MSRB RULE G-8(a)(xv)).

**** $9,000 PAID ON 2/12/99 - INVOICE NO. 99-10-76 **** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT IN ONE OR MORE INSTANCES DURING THE PERIODS 9/1/95 THROUGH 9/30/96 AND 1/1/97 THROUGH 3/31/97 LEHMAN'S FILINGS OF OFFICIAL STATEMENTS AND ADVANCE REFUNDINGS WERE IN ©2021 FINRA. All rights reserved. Report aboutVIOLATION LEHMAN BROTHERSOF MSRB INC. RULES G-36 AND G-8. 338 www.finra.org/brokercheck User Guidance

IT WAS ALLEGED THAT IN ONE OR MORE INSTANCES DURING THE PERIODS 9/1/95 THROUGH 9/30/96 AND 1/1/97 THROUGH 3/31/97 LEHMAN'S FILINGS OF OFFICIAL STATEMENTS AND ADVANCE REFUNDINGS WERE IN VIOLATION OF MSRB RULES G-36 AND G-8. Initiated By: NASD REGULATION, INC. Date Initiated: 01/19/1999 Docket/Case Number: AWC C10980152

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/19/1999 Sanctions Ordered: Censure Monetary/Fine $9,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, LEHMAN CONSENTED TO THE FINDINGS AND ALSO CONSENTED TO A CENSURE AND A $9,000 FINE. i Disclosure 229 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/07/1998 Docket/Case Number: CMS980059 AWC

Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 07/07/1998 Sanctions Ordered: Monetary/Fine $9,500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS980059 AWC.

ON JULY 7, 1998, LEHMAN BROTHERS INC. (LEHM) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) THAT IT SUBMITTED WAS ACCEPTED BY NASD REGULATION, INC.'S DEPARTMENT OF ENFORCEMENT AND THE NATIONAL ADJUDICATORY COUNCIL. THE AWC ALLEGES THAT THE FOLLOWING VIOLATIONS OCCURRED:

LEHM INCORRECTLY REPORTED SHORT POSITIONS FOR THREE SECURITIES DURING THE MONTHS OF NOVEMBER 1996, FEBRUARY 1997 AND JUNE 1997. THIS CONDUCT CONSTITUTES VIOLATIONS OF NASD CONDUCT RULE 3360. DURING THE PERIOD NOVEMBER 1996 THROUGH JUNE 1997, LEHM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADQUATE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE OCMPLIANCE WITH NASD CONDUCT RULES 3360. THIS CONSTITUTES A VIOLATION OF NASD CONDUCT RULES 2110 AND 3010.

LEHM WAS FINED $9,500.

****** $9,500 PAID ON 9/16/98, INVOICE NO. 98-MS-709 **** i Reporting Source: Firm Current Status: Final Allegations: IN THREE INSTANCES FROM NOVEMBER 1996 TO JUNE 1997, LEHMAN ALLEGEDLY VIOLATED NASD CONDUCT RULE ("RULE") 3360 BY INCORRECTLY REPORTING ITS SHORT INTEREST POSITION AND ALLEGEDLY VIOLATED RULES 2110 AND 3010 BY HAVE SUPERVISORY PROCEDURES INSUFFICIENT TO SECURE COMPLIANCE WITH RULE 3360.

Initiated By: NASD REGULATION, INC. Date Initiated: 07/07/1998 Docket/Case Number: CMS980059 AWC

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 07/07/1998 Sanctions Ordered: Monetary/Fine $9,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ALLEGATIONS, LEHMAN CONSENTED TO ENTRY OF FINDINGS AND A $9,500.00 FINE, AND AGREED TO IMMEDIATELY REVISE WRITTEN PROCEDURES FOR RULE 3360. i Disclosure 230 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/28/1997 Docket/Case Number: CMS970044 AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution Date: 10/28/1997 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS970044 AWC.

ON OCTOBER 28,1997, LEHMAN BROTHERS INC. (LEHM) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED WAS ACCEPTED BY THE MARKET REGULATION AND THE NATIONAL BUSINESS CONDUCT COMMITTEES. THE AWC ALLEGES THAT THE FOLLOWING ACTIVITY OCCURRED:

LEHM IMPROPERLY USED FORM T FOR 16 TRANSACTIONS IN LISTED SECURITIES, 12 TRANSACTIONS IN NASDAQ NATIONAL MARKET SECURITIES, AND ONE TRANSACTION IN AN OTC EQUITY SECURITY. LEHM FAILED TO IDENTIFY TO THE AUTOMATED CONFIRMATION TRANSACTION SERVICE ("ACT") ONE AGGREGATED TRANSACTION REPORT IN A NASDAQ NATIONAL MARKET SECURITY IN A MANNER DIRECTED BY THE ASSOCIATION; IMPROPERLY DESIGNATED AS LATE TO ACT ONE TRANSACTION IN A NASDAQ NATIONAL MARKET SECURITY; AND FAILED TO ACCEPT OR DECLINE IN ACT THREE TRANSACTIONS IN ELIGIBLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD MARKETPLACE RULES 4632(a), 4632(a)(5), 4632(f), 6130(b), 6420(a)(3) AND 6620(a)(4).

LEHM FAILED TO PROVIDE, ON NINE OCCASIONS, WRITTEN NOTIFICATION DISCLOSING THAT THE PRICE TO EACH OF ITS CUSTOMERS WAS AN AVERAGE PRICE. THIS CONSTITUTES VIOLATIONS OF SEC RULE 10b-10(a)(2).

LEHM WAS FINED $2,000.

****** $2,000 PAID ON 12/16/97, INVOICE NO. 97-MS-979 ***** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN WAS IN VIOLATION OF MARKETPLACE RULES 4632(A), (A)(5), (F); 6130(B), 6420(A)(3), 6620(A)(4) AND SEC RULE 10B-10(A)(2). ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 342 www.finra.org/brokercheck User Guidance IT WAS ALLEGED THAT LEHMAN WAS IN VIOLATION OF MARKETPLACE RULES 4632(A), (A)(5), (F); 6130(B), 6420(A)(3), 6620(A)(4) AND SEC RULE 10B-10(A)(2). Initiated By: NASD REGULATION, INC. Date Initiated: 10/28/1997 Docket/Case Number: CMS970044 AWC

Principal Product Type: Other Other Product Type(s): TRADE REPORTING/ORDER LIMIT Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/28/1997 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF VIOLATIONS, LEHMAN CONSENTED TO THE ENTRY OF FINDINGS AND CONSENTED TO A $2,000 FINE. THE FIRM IS REQUIRED TO IMPLEMENT REVISED WRITTEN SUPERVISORY PROCEDURES CONCERNING TRADE REPORTING AND THE LIMIT ORDER PROTECTION INTERPRETATION. i Disclosure 231 of 359 Reporting Source: Regulator Current Status: Final Allegations: SEE SUMMARY Initiated By: CBOE Date Initiated: 12/11/1997 Docket/Case Number: 97-0061

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 12/11/1997 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: LEHMAN BROTHERS, INC., AN EXCHANGE MEMBER ORGANIZATION, WAS CENSURED AND FINED $7,500. Regulator Statement LEHMAN BROTHERS, INC., AN EXCHANGE MEMBER ORGANIZATION, WAS CENSURED AND FINED $7,500 FOR THE FOLLOWING CONDUCT. ON FEBRUARY 27, 1997, A LEHMAN FIRM TRADER ("FIRM TRADER") RECEIVED A CUSTOMER ORDER TO BUY 1950 PAIRGAIN TECHNOLOGIES, INC. ("PQG") MAR 35 PUT OPTION CONTRACTS AT 2 3/4 AND SELL 1950 PQG JUL 45 CALL OPTION CONTRACTS AT 2 3/4 ("ORIGINAL ORDER"). AT APPROXIMATELY 12:47 P.M., FIRM TRADER ENTERED AN ORDER TO SELL 80,000 SHARES OF PAIRGAIN TECHNOLOGIES, INC. COMMON STOCK ("PAIR") WITH LEHMAN'S OVER-THE-COUNTER BROKER TO HEDGE THE FIRM'S ANTICIPATED FACILITATION OF THE ORIGINAL ORDER PRIOR TO DISCLOSING THE ORIGINAL ORDER TO THE PQG TRADING CROWD. (CBOE RULES 4.1 AND 6.9(e)). i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN WAS IN VIOLATION OF EXCHANGE RULE 4.1 IN THAT LEHMAN ENTERED A PAIRGAIN COMMON STOCK ORDER PRIOR TO DISCLOSING THE TERMS AND CONDITIONS OF AN ORIGINAL CUSTOMER OPTION ORDER TO THE PAIRGAIN OPTION TRADING CROWD AS REQUIRED BY EXCHANGE RULE 6.9(E) Initiated By: CHICAGO BOARD OF OPTIONS EXCHANGE, INC. Date Initiated: 12/11/1997 Docket/Case Number: 97-0061

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 344 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 01/09/1998 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN AGREED TO A CENSURE AND A PAYMENT OF A $7,500.00 FINE IN SETTLEMENT OF THIS MATTER. i Disclosure 232 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/23/1997 Docket/Case Number: CMS960196

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/23/1997 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement LETTER OF ACCEPTANCE, WAIVER & CONSENT NO. CMS960196 AWC.

ON APRIL 23, 1997, LEHMAN BROTHERS INC. (LEHM) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT ©2021 FINRA. All rights reserved. Report aboutSUBMITTED LEHMAN BROTHERS WAS ACCEPTED INC. BY THE MARKET REGULATION AND THE 345 NATIONAL BUSINESS CONDUCT COMMITTEES. THE AWC ALLEGES THAT LEHM, A PASSIVE MARKET MAKER IN THE COMMON STOCK OF OXHP, VIOLATED SEC RULE 10b-6A FOR ENTERING A BID FOR OXHP WHICH WAS ABOVE THE HIGHEST INDEPENDENT BID FOR THAT SECURITY.

LEHM WAS FINED $2,000.

***$2,000.00 PAID ON 6/11/97, INVOICE #97-MS-428*** www.finra.org/brokercheck User Guidance LETTER OF ACCEPTANCE, WAIVER & CONSENT NO. CMS960196 AWC.

ON APRIL 23, 1997, LEHMAN BROTHERS INC. (LEHM) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED WAS ACCEPTED BY THE MARKET REGULATION AND THE NATIONAL BUSINESS CONDUCT COMMITTEES. THE AWC ALLEGES THAT LEHM, A PASSIVE MARKET MAKER IN THE COMMON STOCK OF OXHP, VIOLATED SEC RULE 10b-6A FOR ENTERING A BID FOR OXHP WHICH WAS ABOVE THE HIGHEST INDEPENDENT BID FOR THAT SECURITY.

LEHM WAS FINED $2,000.

***$2,000.00 PAID ON 6/11/97, INVOICE #97-MS-428*** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT IN ONE INSTANCE ON APRIL 2ND, 1996, LEHMAN ENGAGED IN PASSIVE MARKET-MAKING IN VIOLATION OF SEC RULE 10B- 6A. Initiated By: NASD INC. - MARKET SURVEILLANCE COMMITTEE Date Initiated: 04/23/1997 Docket/Case Number: CMS960196

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/23/1997 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE AWC, LEHMAN CONSENTED TO THE ENTRY OF FINDINGS BY THE ASSOCIATION AND CONSENTED TO PAY A FINE IN THE AMOUNT OF $2,000.00. i Disclosure 233 of 359 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 346 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/11/1997 Docket/Case Number: CMS960062 AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/11/1997 Sanctions Ordered: Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement LETTER OF ACCEPTANCE, WAIVER & CONSENT NO. CMS960062 AWC.

ON JULY 11, 1997, LEHMAN BROTHERS, INC. (LEHM) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED WAS ACCEPTED BY THE MARKET REGULATION AND THE NATIONAL BUSINESS CONDUCT COMMITTEES. THE AWC ALLEGES THAT LEHM VIOLATED MARKETPLACE RULE 4613(d) FOR ENTERING QUOTATIONS INTO THE NASDAQ SYSTEM THAT EXCEEDED THE PARAMETERS FOR THE MAXIMUM ALLOWABLE SPREADS.

LEHM WAS FINED $3,000.

**$3,000.00 PAID ON 8/20/97, INVOICE #97-MS-672** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT ON JANUARY 15TH AND 16TH, 1996 AND ON ©2021 FINRA. All rights reserved. Report aboutFEBRUARY LEHMAN BROTHERS7TH, 1996, INC. LEHMAN ENTERED INTO THE NASDAQ SYSTEM 347 QUOTATIONS WHICH CONTAINED SPREADS IN EXCESS OF THE MAXIMUM ALLOWABLE SPREADS. www.finra.org/brokercheck User Guidance

Allegations: IT WAS ALLEGED THAT ON JANUARY 15TH AND 16TH, 1996 AND ON FEBRUARY 7TH, 1996, LEHMAN ENTERED INTO THE NASDAQ SYSTEM QUOTATIONS WHICH CONTAINED SPREADS IN EXCESS OF THE MAXIMUM ALLOWABLE SPREADS. Initiated By: NASD INC.- MARKET SURVEILLANCE COMMITTEE Date Initiated: 07/11/1997 Docket/Case Number: CMS960062

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 07/11/1997 Sanctions Ordered: Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO THE ENTRY OF FINDINGS THAT IT VIOLATED PART V, SECTION 2(D) OF SCHEDULE D OF THE ASSOCIATION'S BYLAWS. IN ADDITION, LEHMAN CONSENTED TO A FINE IN THE AMOUNT OF $3,000.00. i Disclosure 234 of 359 Reporting Source: Regulator Current Status: Final Allegations: FAILURE TO SUPERVISE Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/13/1996 Docket/Case Number:

Principal Product Type: Debt - Government Other Product Type(s): Principal Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 348 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/12/1996 Sanctions Ordered: Censure Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CIVIL PENALTY OF $50,000. Regulator Statement [TOP] 09-16-96, SEC NEWS DIGEST ISSUE NO. 96-175, DATED 09/13/1996, ENFORCEMENT PROCEEDINGS DISCLOSE: SEC TODAY ANNOUNCED THE INSTITUTION AND SETTLEMENT OF A PUBLIC ADMINISTRATIVE PROCEEDING AGAINST LEHMAN BROTHERS INC. (LEHMAN), AS SUCCESSOR TO SHEARSON LEHMAN BROTHERS INC. (SHEARSON). IN THIS MATTER, LEHMAN, WITHOUT ADMITTING OR DENYING THE FINDINGS IN THE ORDER, CONSENTED TO THE ISSUANCE OF THE ORDER. SEC?S ORDER FOUND THAT SHEARSON FAILED REASONABLY TO SUPERVISE A FORMER STOCKBROKER WITH THE FIRM, STANLEY J. FEMINELLA, WHO OVER A TWO-YEAR PERIOD CAUSED TWO CUSTOMERS -- CONSUMERS UNION OF UNITED STATES, INC. AND ITS EMPLOYEE PENSION FUND (COLLECTIVELY CU) -- TO PAY AT LEAST $1 MILLION IN UNDISCLOSED, EXCESSIVE MARKUPS ON THEIR PURCHASES OF GOVERNMENT SECURITIES. THE ORDER MAKES FINDINGS THAT SHEARSON'S SUPERVISORY FAILURE STEMMED FROM ITS LACK OF SUFFICIENT FIRM- WIDE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT AND DETECT FEMINELLA'S CHARGING OF EXCESSIVE MARKUPS. FROM NOVEMBER 1988 THROUGH FEBRUARY 1991, CU PURCHASED THROUGH FEMINELLA $38.5 MILLION IN GOVERNMENT SECURITIES, IN THIRTY-THREE TRANSACTIONS. ON THESE TRANSACTIONS, RANGING IN AMOUNTS FROM $107,000 TO MORE THAN $3,000,000, CU WAS CHARGED MARKUPS THAT RANGED FROM 3.5 PERCENT TO 4.7 PERCENT. CU PAID A TOTAL OF AT LEAST $1,390,000 IN MARKUPS, OF WHICH FEMINELLA RECEIVED AT LEAST $904,000. BASED ON THE ABOVE AND OTHER FINDINGS IN THE ORDER, SEC CENSURED LEHMAN, REQUIRED LEHMAN TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS, AND COMMITTING OR CAUSING ANY FUTURE VIOLATIONS, OF THE CUSTOMER CONFIRMATION AND BOOKS AND RECORDS PROVISIONS OF THE SECURITIES EXCHANGE ACT OF 1934, AND REQUIRED LEHMAN TO PAY A CIVIL PENALTY OF $50,000. 62 SEC DOCKET 2324, DATED 10/08/1996, DISCLOSES: SEC CEASE AND DESIST ORDER IS DATED 09/12/1996.

i Reporting Source: Firm Current Status: Final Allegations: THE SEC ALLEGED THAT SHEARSON 1) FAILED REASONABLY TO SUPERVISE A REGISTERED REPRESENTATIVE, WHO WAS SUBJECT TO ITS SUPERVISION, WITH A VIEW TO PREVENTING HIS CHARGING TWO CLIENTS EXCESSIVE MARKUPS ON FIXED INCOME SECURITIES; 2) SENT ERRONEOUS CUSTOMER CONFIRMATIONS IN VIOLATION OF SECTION 10(B)OF THE EXCHANGE ACT AND RULE 10B-10B; AND 3) FAILED TO MAINTAIN CERTAIN REQUIRED BOOKS AND RECORDS IN VIOLATION OF SECTION 17(A)OF THE EXCHANGE ACT AND RULES 17A-3 AND 17A-4. Initiated By: SEC Date Initiated: 09/12/1996 Docket/Case Number: FILE NO. 3-9079

Principal Product Type: Other Other Product Type(s): FIXED INCOME SECURITIES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CENSURE; CEASE AND DESIST FROM FUTURE VIOLATIONS OF RELEVANT Sought: EXCHANGE ACT PROVISIONS; CIVIL PENALTY

Resolution: Other Resolution Date: 09/12/1996 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO 1) A CENSURE, 2) A REQUIREMENT TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF THE RELEVANT EXCHANGE ACT PROVISIONS AND 3) PAYMENT OF A CIVIL PENALTY OF $50,000.00. Firm Statement SIMULTANEOUSLY WITH THE ENTRY OF THE ORDER, THE COMMISSION GRANTED RELIEF FROM THE DISQUALIFYING PROVISIONS OF REGULATIONS A,D AND E. i Disclosure 235 of 359 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 350 www.finra.org/brokercheck User Guidance

Disclosure 235 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/05/1997 Docket/Case Number: C10970025

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/05/1997 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: Regulator Statement ON MARCH 5, 1997, DISTRICT NO. 10 NOTIFIED RESPONDENT LEHMAN BROTHERS, INC. THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C10970025 WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED, FINED $250,000, AND MUST COMPLY WITH THE FOLLOWING UNDERTAKING: (A) WITHIN 180 DAYS FROM THE DATE THIS AWC IS ACCEPTED AND ISSUED BY NASDR, RESPONDENT MEMBER MUST, IF IT HAS NOT ALREADY DONE SO, DISGORGE TO THE RETAIL CUSTOMERS $2,923,482.61. UPON APPLICATION BY RESPONDENT MEMBER, AND A REASONABLE SHOWING THAT IT HAS BEEN UNABLE TO LOCATE, AFTER EXERCISING ALL DILIGENT MEANS, A SIGNIFICANT NUMBER OF CUSTOMERS DURING THE INITIAL 180 DAY PERIOD, NASDR MAY EXTEND THE DISGORGEMENT PERIOD AN ADDITIONAL 90 DAYS. (B) THE CUSTOMER PAYMENTS MUST BE ACCOMPANIED BY A LETTER ACCEPTABLE TO NASDR WHICH DESCRIBES THE PURPOSE OF THE PAYMENT. (C) ONCE THE FIRM HAS MADE THE PAYMENTS TO THE RETAIL CUSTOMERS IT WILL PROVIDE ©2021 FINRA. All rights reserved. Report aboutTHE LEHMAN DISTRICT BROTHERS NO. 10 INC. OFFICE OF NASDR WITH SATISFACTORY PROOF OF 351 SUCH PAYMENTS. IN THE EVENT THE FIRM, AFTER USING ALL DILIGENT MEANS, IS UNABLE TO MAKE PAYMENT TO ANY CUSTOMER IDENTIFIED, THOSE MONIES SHALL BE PAID TO NASDR AS AN ADDITIONAL FINE. RESPONDENT MEMBER SHALL PAY THE ADDITIONAL FINE WITHIN 60 DAYS OF THE EXPIRATION OF THE DISGORGEMENT PERIOD. PAYMENT OF THE ADDITIONAL FINE SHALL SATISFY RESPONDENT MEMBER'S DISGORGEMENT OBLIGATIONS WITH RESPECT TO THOSE CUSTOMERS TO WHOM THE FIRM IS UNABLE TO MAKE PAYMENT. - (NASD RULES 2110 AND 2830(j) - RESPONDENT MEMBER IMPROPERLY CHARGED ITS RETAIL CUSTOMERS EXCESSIVE FEES/COMMISSIONS FOR EXECUTING NON-PROPRIETARY MUTUAL FUND REDEMPTION TRANSACTIONS ON THEIR BEHALF).

***$250,000.00 PAID ON 3/24/97, INVOICE #97-10-172***

***RESTITUTION COMPLETED AS OF 4/98** ON MARCH 5, 1997, DISTRICT NO. 10 NOTIFIED RESPONDENT LEHMAN BROTHERS, INC. THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C10970025 WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED, FINED $250,000, AND MUST COMPLY WITH THE FOLLOWING UNDERTAKING: (A) WITHIN 180 DAYS FROM THE DATE THIS AWC IS ACCEPTED AND ISSUED BY NASDR, RESPONDENT MEMBER MUST, IF IT HAS NOT ALREADY DONE SO, DISGORGE TO THE RETAIL CUSTOMERS $2,923,482.61. UPON APPLICATION BY RESPONDENT MEMBER, AND A REASONABLE SHOWING THAT IT HAS BEEN UNABLE TO LOCATE, AFTER EXERCISING ALL DILIGENT MEANS, A SIGNIFICANT NUMBER OF CUSTOMERS DURING THE INITIAL 180 DAY PERIOD, NASDR MAY EXTEND www.finra.org/brokercheck THE DISGORGEMENT PERIOD AN ADDITIONAL 90 DAYS. (B) THE User Guidance CUSTOMER PAYMENTS MUST BE ACCOMPANIED BY A LETTER ACCEPTABLE TO NASDR WHICH DESCRIBES THE PURPOSE OF THE PAYMENT. (C) ONCE THE FIRM HAS MADE THE PAYMENTS TO THE RETAIL CUSTOMERS IT WILL PROVIDE THE DISTRICT NO. 10 OFFICE OF NASDR WITH SATISFACTORY PROOF OF SUCH PAYMENTS. IN THE EVENT THE FIRM, AFTER USING ALL DILIGENT MEANS, IS UNABLE TO MAKE PAYMENT TO ANY CUSTOMER IDENTIFIED, THOSE MONIES SHALL BE PAID TO NASDR AS AN ADDITIONAL FINE. RESPONDENT MEMBER SHALL PAY THE ADDITIONAL FINE WITHIN 60 DAYS OF THE EXPIRATION OF THE DISGORGEMENT PERIOD. PAYMENT OF THE ADDITIONAL FINE SHALL SATISFY RESPONDENT MEMBER'S DISGORGEMENT OBLIGATIONS WITH RESPECT TO THOSE CUSTOMERS TO WHOM THE FIRM IS UNABLE TO MAKE PAYMENT. - (NASD RULES 2110 AND 2830(j) - RESPONDENT MEMBER IMPROPERLY CHARGED ITS RETAIL CUSTOMERS EXCESSIVE FEES/COMMISSIONS FOR EXECUTING NON-PROPRIETARY MUTUAL FUND REDEMPTION TRANSACTIONS ON THEIR BEHALF).

***$250,000.00 PAID ON 3/24/97, INVOICE #97-10-172***

***RESTITUTION COMPLETED AS OF 4/98** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT DURING THE PERIOD BETWEEN OCTOBER 1ST, 1990 AND FEBRUARY 16TH, 1995, LEHMAN, IN CERTAIN INSTANCES, CHARGED EXCESSIVE FEES/COMMISSIONS FOR EXECUTING NON- PROPRIETARY MUTUAL FUND TRANSACTIONS. LEHMAN CHARGED THESE FEES IN 13,310 TRANSACTIONS, AGGREGATING TO $1,963,485.70 IN EXCESS FEES/COMMISSIONS. AS SUCH, THIS WAS IN VIOLATION OF NASD CONDUCT RULES 2830(J)AND 2110. Initiated By: NASD REGULATION INC. - DBCC FOR DISTRICT 10 Date Initiated: 03/05/1997 Docket/Case Number: C10970025

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/05/1997 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN CONSENTED TO THE ENTRY OF FINDINS AND CONSENTED TO A CENSURE, A FINE IN THE AMOUNT OF $250,000.00 AND A DISGORGEMENT TO THE RETAIL CUSTOMERS OF $2,923,482.61, INCLUDING PRE-JUDGEMENT INTEREST. i Disclosure 236 of 359 Reporting Source: Regulator Current Status: Final Allegations: see summary Initiated By: CBOE Date Initiated: 02/23/1996 Docket/Case Number: 96-0003

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 10/08/1996 Sanctions Ordered: Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: fined in the amount of $25,000 Regulator Statement On September 15, 1994, Lehman exercised 900 OEX Sep 410 call option contracts, 1700 OEX Sep 415 call option contracts, 2000 OEX Sep 420 call option contracts, and 200 OEX Sep 430 call option contracts, respectively, without submitting ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 353 an advice to the Exchange indicating the intent to exercise the aforementioned option contracts. On September 15, 1994, the Exchange received an advice submitted via C/MACS at 3:12 p.m. (CT) indicating that Lehman intended to exercise 500 OEX Sep 425 call option contracts. Lehman subsequently exercised a total of 2900 OEX Sep 425 call option contracts, 2400 option contracts in excess of the 500 contracts that Lehmann previously indicated that it intended to exercise (CBOE Rule 11.1) www.finra.org/brokercheck User Guidance On September 15, 1994, Lehman exercised 900 OEX Sep 410 call option contracts, 1700 OEX Sep 415 call option contracts, 2000 OEX Sep 420 call option contracts, and 200 OEX Sep 430 call option contracts, respectively, without submitting an advice to the Exchange indicating the intent to exercise the aforementioned option contracts. On September 15, 1994, the Exchange received an advice submitted via C/MACS at 3:12 p.m. (CT) indicating that Lehman intended to exercise 500 OEX Sep 425 call option contracts. Lehman subsequently exercised a total of 2900 OEX Sep 425 call option contracts, 2400 option contracts in excess of the 500 contracts that Lehmann previously indicated that it intended to exercise (CBOE Rule 11.1) i Reporting Source: Firm Current Status: Final Allegations: A STATEMENT OF CHARGES WAS ISSUED AGAINST LEHMAN BROTHERS ALLEGING THAT LEHMAN WAS IN VIOLATION OF EXCHANGE RULE 11.1. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE - BUSINESS CONDUCT COMMITTEE Date Initiated: 02/23/1996 Docket/Case Number: 96-0003

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 10/08/1996 Sanctions Ordered: Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE VIOLATIONS ALLEGED IN THE STATEMENT OF CHARGES, LEHMAN BROTHERS CONSENTED TO A FINE OF $25,000.00. Firm Statement THE CHARGES STEM FROM LEHMAN BROTHERS' ALLEGED FAILURE, ON SEPTEMBER 15, 1994, TO FILE EXERCISE ADVICES WITH THE CBOE PRIOR TO EXERCISING 4800 CONTRACTS OF VARIOUS OEX CALLS, AS WELL AS FROM LEHMAN'S EXERCISE, ON SEPTEMBER 15TH, 1994, OF 2400 MORE CONTRACTS OF OEX CALLS, THAN THE EXERCISE ADVICE IT FILED WITH ©2021 FINRA. All rights reserved. Report aboutTHE LEHMAN CBOE INDICATEDBROTHERS INC. IT INTENDED TO EXERCISE 354 www.finra.org/brokercheck THE CHARGES STEM FROM LEHMAN BROTHERS' ALLEGED FAILURE, ON User Guidance SEPTEMBER 15, 1994, TO FILE EXERCISE ADVICES WITH THE CBOE PRIOR TO EXERCISING 4800 CONTRACTS OF VARIOUS OEX CALLS, AS WELL AS FROM LEHMAN'S EXERCISE, ON SEPTEMBER 15TH, 1994, OF 2400 MORE CONTRACTS OF OEX CALLS, THAN THE EXERCISE ADVICE IT FILED WITH THE CBOE INDICATED IT INTENDED TO EXERCISE i Disclosure 237 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/15/1996 Docket/Case Number: CMS960023

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/15/1996 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS960023 AWC

ON JULY 15, 1996, LEHMAN BROTHERS, INC. (LEHM) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED WAS ACCEPTED BY THE MARKET SURVEILLANCE AND THE NATIONAL BUSINESS CONDUCT COMMITTEES. UNDER THE AWC, LEHM IS ALLEGEDLY IN VIOLATION OF SEC RULE 10b-6A IN THAT ON THREE OCCASIONS, LEHM ENTERED BIDS WHICH WERE ABOVE THE LEVEL OF THE HIGHEST INDEPENDENT BIDS. LEHM FAILED TO ENFORCE SUPERVISORY PROCEDURES TO PREVENT THE VIOLATION(S) DESCRIBED ABOVE AS REQUIRED BY ARTICLE III, SECTIONS 1 AND 27 OF THE NASD'S RULES OF FAIR PRACTICE. LEHMAN IS HEREBY FINED $2,000. THE AWC BECAME FINAL ON JULY 15, 1996. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 355 ***$2,000.00 PAID ON 09/10/96, INVOICE #96-MS-551*** LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS960023 AWC

ON JULY 15, 1996, LEHMAN BROTHERS, INC. (LEHM) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED WAS ACCEPTED BY THE MARKET SURVEILLANCE AND THE NATIONAL BUSINESS CONDUCT COMMITTEES. UNDER THE AWC, LEHM IS ALLEGEDLY IN VIOLATION OF SEC RULE 10b-6A IN THAT ON THREE OCCASIONS, LEHM ENTERED BIDS WHICH WERE ABOVE THE LEVEL OF THE HIGHEST INDEPENDENT BIDS. LEHM FAILED TO ENFORCE SUPERVISORY www.finra.org/brokercheck PROCEDURES TO PREVENT THE VIOLATION(S) DESCRIBED ABOVE AS User Guidance REQUIRED BY ARTICLE III, SECTIONS 1 AND 27 OF THE NASD'S RULES OF FAIR PRACTICE. LEHMAN IS HEREBY FINED $2,000. THE AWC BECAME FINAL ON JULY 15, 1996.

***$2,000.00 PAID ON 09/10/96, INVOICE #96-MS-551*** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT IN THREE INSTANCES IN 1995, LEHMAN BROTHERS ENGAGED IN PASSIVE MARKET MAKING CONDUCT THAT WAS IN VIOLATION OF SEC RULE 10B-6A AND FAILED TO ENFORCE SUPERVISORY PROCEDURES TO PREVENT THESE VIOLATIONS AS REQUIRED BY ARTICLE III SECTIONS 1 AND 27 OF THE NASD'S RULES OF FAIR PRACTICE. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 07/15/1996 Docket/Case Number: CMS960023 AWC

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/15/1996 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE AWC, LEHMAN BROTHERS CONSENTED TO THE ENTRY OF FINDINGS BY THE ASSOCIATION AND CONSENTED TO A FINE IN THE AMOUNT OF $2,000.00. i Disclosure 238 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Date Initiated: 10/06/1995 Docket/Case Number: CMS950075

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED ON OCTOBER 6, 1995 AGAINST LEHMAN BROTHERS, INC. (LEHM) ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 27 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE FOR FAILING TO ENFORCE SUPERVISORY PROCEDURES TO PREVENT THE VIOLATIONS AND SEC RULE 10b-6A IN THAT RESPONDENT LEHM ENTERED A BID OF 17 1/2 WHICH WAS ABOVE THE HIGHEST INDEPENDENT BID OF 17 3/8 AND PURCHASED 1000 SHARES AT A PRICE OF 18 1/8 WHICH WAS 1/4 POINT ABOVE THE HIGHEST INDEPENDENT BID OF 17/78.

AS SANCTIONS, RESPONDENT LEHM WAS CENSURED AND FINED $1,000. THE AWC BECAME FINAL ON FEBRUARY 2, 1996. **$1,000.00 PAID ON 02/27/96, INVOICE # 96-MS-123** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT IN TWO INSTANCES ON JANUARY 31, 1995, LHEMAN BROTHERS ENGAGED IN PASSIVE MARKET MAKING CONDUCT THAT WAS IN VIOLATION OF SEC RULE 10B-6A AND FAILED TO ENFORCE ©2021 FINRA. All rights reserved. Report aboutSUPERVISORY LEHMAN BROTHERS PROCEDURES INC. TO PREVENT THESE VIOLATIONS AS 357 REQUIRED BY ARTICLE III SECTIONS 1 AND 27 OF THE NASD'S RULES OF FAIR PRACTICE. www.finra.org/brokercheck User Guidance

IT WAS ALLEGED THAT IN TWO INSTANCES ON JANUARY 31, 1995, LHEMAN BROTHERS ENGAGED IN PASSIVE MARKET MAKING CONDUCT THAT WAS IN VIOLATION OF SEC RULE 10B-6A AND FAILED TO ENFORCE SUPERVISORY PROCEDURES TO PREVENT THESE VIOLATIONS AS REQUIRED BY ARTICLE III SECTIONS 1 AND 27 OF THE NASD'S RULES OF FAIR PRACTICE. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 02/02/1996 Docket/Case Number: CMS950075

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/02/1996 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE AWC, LEHMAN BROTHERS CONSENTED TO THE ENTRY OF FINDINGS BY THE ASSOCIATION AND CONSENTED TO A CENSURE AND A FINE IN THE AMOUNT OF $1,000.00. i Disclosure 239 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/24/1995 Docket/Case Number: CMS950007

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/31/1995 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS950007 AWC (AWC) FILED BY THE MARKET SURVEILLANCE COMMITTEE AGAINST LEHMAN BROTHERS, INC. (LEHM) ON FEBRUARY 24, 1995 AND ACCEPTED BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON OCTOBER 31, 1995. IN THE AWC, LEHM IS ALLEGED TO BE IN VIOLATION OF SEC RULE 10B-6 FOR FAILING TO REMOVE ITS QUOTES IN A TIMELY MANNER, PURCHASING SHARES ABOVE THE PREVAILING HIGHEST INDEPENDENT MARKET MAKER BID, FAILING TO LOWER ITS BID PRIOR TO MARKET'S OPEN THEREBY ESTABLISHING THE INSIDE BID AT THE OPEN AND ARTICLE III, SECTIONS 1 AND 27 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE FOR FAILING TO ENFORCE SUPERVISORY PROCEDURES TO PREVENT THE PASSIVE MARKET MAKING VIOLATIONS. AS SANCTIONS, LEHM WAS CENSURED AND FINED $1,000. THE AWC BECAME FINAL ON OCTOBER 31, 1995. ************************************************************* *****$1,000.00 PAID ON 11/16/95, INVOICE #95-MS-724***** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT IN THREE INSTANCES IN 1994, LEHMAN BROTHERS ENGAGED IN PASSIVE MARKET MAKING CONDUCT THAT WAS IN VIOLATION OF SEC RULE 10B-6A AND FAILED TO ENFORCE SUPERVISORY PROCEDURES TO PREVENT THESE VIOLATIONS AS REQUIRED BY ARTICLE III SECTIONS 1 AND 27 OF THE NASD'S RULES OF FAIR PRACTICE. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 10/31/1995 Docket/Case Number: CMS950007 AWC ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 359 www.finra.org/brokercheck User Guidance

Docket/Case Number: CMS950007 AWC

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/31/1995 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: WITHOT ADMITTING OR DENYING THE ALLEGATIONS IN THE AWC, LEHMAN BROTHERS CONSENTED TO THE ENTRY OF FINDINGS BY THE ASSOCIATION AND CONSENTED TO A CENSURE AND A FINE OF $1,000.00. i Disclosure 240 of 359 Reporting Source: Regulator Current Status: Final Allegations: Not Provided Initiated By: NYSE DIVISION OF ENFORCEMENT Date Initiated: 05/30/1996 Docket/Case Number: HPD 96-81

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/20/1996 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine LEHMAN BROTHERS $125,000.00 INC. 360 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $125,000.00 Other Sanctions Ordered: Sanction Details: Not Provided Regulator Statement **9/20/96** THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY. CONTACT: PEGGY L. GERMINO (212)656-8450 i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS FAILED TO MEET CERTAIN REQUIREMENTS CONCERNING OPERATIONS, REPORTING, RECORDKEEPING AND SUPERVISION IN AUGUST 1993. Initiated By: NEW YORK STOCK EXCHANGE INC. Date Initiated: 09/09/1996 Docket/Case Number: DECISION 96-81

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 09/09/1996 Sanctions Ordered: Censure Monetary/Fine $125,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTED TO THE FINDINGS BY AN NYSE HEARING PANEL AND CONSENTED TO A CENSURE AND A FINE OF $125,000.00. i Disclosure 241 of 359 Reporting Source: Regulator Current Status: Final Allegations: VIOLATIONS OF THE ANTIFRAUD AND RECORDKEEPING PROVISIONS OF ©2021 FINRA. All rights reserved. Report aboutTHE LEHMAN SECURITIES BROTHERS EXCHANGE INC. ACT OF 1934. 361 www.finra.org/brokercheck User Guidance

Allegations: VIOLATIONS OF THE ANTIFRAUD AND RECORDKEEPING PROVISIONS OF THE SECURITIES EXCHANGE ACT OF 1934. Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 08/15/1995 Docket/Case Number:

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 08/15/1995 Sanctions Ordered: Censure Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CIVIL MONEY PENALTY OF $850,000,00 Regulator Statement TOP] 8/23/95 SEC NEWS DIGEST, ISSUE NO. 95-158, DATED 8/16/95, ENFORCEMENT PROCEEDINGS DISCLOSE: THE COMMISSION TODAY ANNOUNCED THE INSTITUTION AND SETTLEMENT OF AN ADMINSTRATIVE PROCEEDING AGAINST LEHMAN BROTHERS INC., WITHOUT ADMITTING OR DENYING THE FINDINGS, LEHMAN BROTHERS CONSENTED TO THE ENTRY OF AN ORDER CENSURING THE FIRM, REQUIRING IT TO PAY A CIVIL MONEY PENALTY OF $850,000, AND REQUIRING IT TO PERMANENTLY CEASE AND DESIST FROM COMMITTING FUTURE VIOLATIONS OF THE ANTIFRAUD AND RECORDKEEPING PROVISIONS OF THE SECURITIES EXCHANGE ACT OF 1934. THE VIOLATIONS ARISE FROM CONDUCT OF LEHMAN BROTHERS IN AUCTIONS OF AMERICAN EXPRESS COMPANY MONEY MARKET PREFERRED STOCK (MMP). AMERICAN EXPRESS' REGISTRATION STATEMENT FOR THE MMP OFFERINGS STATED THAT LEHMAN, BECAUSE OF ITS AFFILIATION WITH AMERICAN EXPRESS, COULD NOT SUBMIT BIDS IN THE AUCTIONS FOR ITS OWN ACCOUNT. THE COMMISSION FOUND, HOWEVER, THAT LEHMAN HAD SUBMITTED BIDS IN CERTAIN MMP AUCTIONS THAT RESULTED IN THE PURCHASE OF SHARES FOR ITS OWN ACCOUNT. ACCORDING TO THE ORDER, IN THIRTEEN AUCTIONS BETWEEN 1988 AND 1990, LEHMAN'S BIDS HAD THE EFFECT OF LOWERING THE DIVIDEND RATE OTHERWISE ESTABLISHED THROUGH THE AUCTION AND PREVENTED TWO AUCTIONS FROM FAILING, WHICH WOULD HAVE RESULTED IN THE IMPOSITION OF A PENALTY DIVIDEND RATE. THE ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 362 ORDER FINDS THAT LEHMAN REDUCED THE AGGREGATE AMOUNT OF DIVIDENDS PAID BY AMERICAN EXPRESS TO HOLDERS OF MMP BY APPROXIMATELY $585,000. (REL. 34-36104) 08/14/96 SEC DOCKET, VOLUME 59, NO. 20, DATED 9/12/95, PAGE 3135, DISCLOSES; THE COMMISSION ORDERED RESPONDENT FIRM TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR FUTURE VIOLATIONS OF SECTION 10(B) AND 17(A) OF THE EXCHANGE ACT AND RULES 10B-5, 17A-3 AND 17A-4 THEREUNDER. THE ORDER CONTAINING THE CEASE AND DESIST ORDER AND THE ORDER CENSURING RESPONDENT FIRM IS DATED 8/15/95. (REL. 36104) TOP] 8/23/95 SEC NEWS DIGEST, ISSUE NO. 95-158, DATED 8/16/95, ENFORCEMENT PROCEEDINGS DISCLOSE: THE COMMISSION TODAY ANNOUNCED THE INSTITUTION AND SETTLEMENT OF AN ADMINSTRATIVE PROCEEDING AGAINST LEHMAN BROTHERS INC., WITHOUT ADMITTING OR DENYING THE FINDINGS, LEHMAN BROTHERS CONSENTED TO THE ENTRY OF AN ORDER CENSURING THE FIRM, REQUIRING IT TO PAY A CIVIL MONEY PENALTY OF $850,000, AND REQUIRING IT TO PERMANENTLY CEASE AND DESIST FROM COMMITTING FUTURE VIOLATIONS OF THE ANTIFRAUD AND RECORDKEEPING PROVISIONS OF THE SECURITIES EXCHANGE ACT OF 1934. THE VIOLATIONS ARISE FROM CONDUCT OF LEHMAN BROTHERS IN AUCTIONS OF AMERICAN EXPRESS COMPANY MONEY MARKET PREFERRED STOCK (MMP). AMERICAN EXPRESS' REGISTRATION STATEMENT FOR THE MMP OFFERINGS STATED THAT LEHMAN, BECAUSE OF ITS AFFILIATION WITH AMERICAN EXPRESS, COULD NOT SUBMIT BIDS IN THE AUCTIONS FOR ITS OWN ACCOUNT. THE COMMISSION FOUND, HOWEVER, THAT LEHMAN HAD SUBMITTED BIDS IN CERTAIN MMP AUCTIONS THAT RESULTED IN THE PURCHASE OF SHARES www.finra.org/brokercheck FOR ITS OWN ACCOUNT. ACCORDING TO THE ORDER, IN THIRTEEN User Guidance AUCTIONS BETWEEN 1988 AND 1990, LEHMAN'S BIDS HAD THE EFFECT OF LOWERING THE DIVIDEND RATE OTHERWISE ESTABLISHED THROUGH THE AUCTION AND PREVENTED TWO AUCTIONS FROM FAILING, WHICH WOULD HAVE RESULTED IN THE IMPOSITION OF A PENALTY DIVIDEND RATE. THE ORDER FINDS THAT LEHMAN REDUCED THE AGGREGATE AMOUNT OF DIVIDENDS PAID BY AMERICAN EXPRESS TO HOLDERS OF MMP BY APPROXIMATELY $585,000. (REL. 34-36104) 08/14/96 SEC DOCKET, VOLUME 59, NO. 20, DATED 9/12/95, PAGE 3135, DISCLOSES; THE COMMISSION ORDERED RESPONDENT FIRM TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR FUTURE VIOLATIONS OF SECTION 10(B) AND 17(A) OF THE EXCHANGE ACT AND RULES 10B-5, 17A-3 AND 17A-4 THEREUNDER. THE ORDER CONTAINING THE CEASE AND DESIST ORDER AND THE ORDER CENSURING RESPONDENT FIRM IS DATED 8/15/95. (REL. 36104) i Reporting Source: Firm Current Status: Final Allegations: THE SEC ALLEGED THAT THE FIRM VIOLATED SECTIONS 10(B) AND 17 (A) OF THE EXCHANGE ACT AND RULES THEREUNDER, BY ENGAGING IN BIDDING PRACTICES IN THE AUCTION OF AMERICAN EXPRESS MONEY MARKET PREFERRED STOCK THAT RESULTED IN CERTAIN REGISTRATION STATEMENT DISCLOSURES BECOMING INACCURATE, AND BY FAILING TO MAINTAIN CERTAIN REQUIRED BOOKS AND RECORDS. Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 08/15/1995 Docket/Case Number: FILE NO. 3-8782

Resolution: Consent Resolution Date: 08/15/1995 Sanctions Ordered: Censure Monetary/Fine $850,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO FINDINGS OF VIOLATIONS, CENSURE, AN ORDER TO ©2021 FINRA. All rights reserved. Report aboutCEASE LEHMAN AND BROTHERS DESIST FROMINC. FUTURE VIOLATIONS OF THE RELEVANT 363 EXCHANGE ACT PROVISIONS, AND TO PAY AN $850,000.00 CIVIL MONETARY PENALTY. www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO FINDINGS OF VIOLATIONS, CENSURE, AN ORDER TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF THE RELEVANT EXCHANGE ACT PROVISIONS, AND TO PAY AN $850,000.00 CIVIL MONETARY PENALTY. i Disclosure 242 of 359 Reporting Source: Regulator Current Status: Final Allegations: UNLICENSED SALESPERSON ACTIVITY. Initiated By: STATE OF OREGON, DEPARTMENT OF INSURANCE AND FINANC*See FAQ #1* Date Initiated: 12/12/1991 Docket/Case Number: 0-91-0019 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/12/1991 Sanctions Ordered: Monetary/Fine $25,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CONSENT TO CEASE AND DESIST ORDER, $25,000 FINE, REQUIRED TO FILE QUARTERLY SALESPERSON RECONCILIATION REPORTS. Regulator Statement UNLICENSED SALESPERSONS TRANSACTED BUSINESS IN OREGON. SHEARSON AGREED TO ENHANCE INTERNAL CONTROLS AND WILL SUBMIT QUARTERLY SALESPERSON LICENSING EXCEPTION REPORTS TO THE DEPARTMENT THROUGH 1993.

i Reporting Source: Firm Current Status: Final Allegations: INVESTIGATION BY OREGON CONCERNED A CLERICAL ERROR RESULTING IN AN OREGON SALESPERSON NOT BEING REGISTERED IN THE STATE FOR A PERIOD OF TIME AND THE FIRM ALLOWING SEVERAL NON-OREGON REGISTERED RESIDENT SALESPERSONS UNREGISTERED IN OREGON CONDUCT TRANSACTIONS WITH OREGON RESIDENTS. Initiated By: STATE OF OREGON Date Initiated: 12/06/1991 Docket/Case Number: 0-91-0019

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/06/1991 Sanctions Ordered: Monetary/Fine $25,000.00 Other Sanctions Ordered: FIRM AGREED TO FILE QUARTERLY REPORTS TO STATE REGARDING REGISTRATION FOR A PERIOD OF TWO YEARS. Sanction Details: FIRM ENTERED INTO A CONSENT AGREEMENT WITH THE STATE'S SECURITIES DIVISION TO SETTLE THE INVESTIGATION, PAID A 25K FINE AND AGREED TO FILE REPORTS AS OUTLINED ABOVE. i Disclosure 243 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/21/1987 Docket/Case Number: MS-577-AWC ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 365 www.finra.org/brokercheck User Guidance

Docket/Case Number: MS-577-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/07/1987 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-577-AWC:

LETTER OF ACCEPTANCE, WAIVER & CONSENT (AWC) ALLEGES VIOLATIONS OF PART VI, SECTION 2(d) OF SCHEDULE D FOR ENTERING NASDAQ QUOTATIONS CONTAINING EXCESS SPREADS. THE AWC WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON 8/25/87 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON 9/7/87. $1,000 FINE

$1,000 FINE PAID 7/29/87 i Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT SHEARSON LEHMAN BROTHERS VIOLATED PART VI, SECTION 2(D) OF SCHEDULE D FOR ENTERING NASD QUOTATIONS CONTAINING EXCESSIVE SPREADS. Initiated By: NASD Date Initiated: 08/25/1987 Docket/Case Number: MS-577-AWC

Principal Product Type: Equity - OTC Other Product Type(s):

Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/07/1987 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO PAY A FINE OF $1,000.00. i Disclosure 244 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 09/30/1985 Docket/Case Number:

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 09/30/1985 Sanctions Ordered: Monetary/Fine $90,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: Regulator Statement 12/9/85, SECURITIES VIOLATORS PRINTOUT DISCLOSES: THE COMMISSION FOUND THAT SHEARSON LEHMAN VIOLATED SECTION 4K(1) ©2021 FINRA. All rights reserved. Report aboutOF THE LEHMAN COMMODITY BROTHERS INC. EXCHANGE ACT AND SECTION 3.12 OF THE 367 REGULATION THEREUNDER. SHEARSON WAS ORDERED TO CEASE AND DESIST CERTAIN VIOLATIONS; COMPLY WITH THE UNDERTAKINGS SET FORTH IN THE OFFER OF SETTLEMENT; AND ASSESSED A PENALTY OF $90,000. www.finra.org/brokercheck User Guidance

12/9/85, SECURITIES VIOLATORS PRINTOUT DISCLOSES: THE COMMISSION FOUND THAT SHEARSON LEHMAN VIOLATED SECTION 4K(1) OF THE COMMODITY EXCHANGE ACT AND SECTION 3.12 OF THE REGULATION THEREUNDER. SHEARSON WAS ORDERED TO CEASE AND DESIST CERTAIN VIOLATIONS; COMPLY WITH THE UNDERTAKINGS SET FORTH IN THE OFFER OF SETTLEMENT; AND ASSESSED A PENALTY OF $90,000. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS BY SHEARSON LEHMAN OF SECTION 4K(1) OF THE COMMODITY EXCHANGE ACT AND SECTION 3.12 OF THE REGULATION THEREUNDER. Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 09/30/1985 Docket/Case Number: 85-49

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 12/09/1985 Sanctions Ordered: Monetary/Fine $90,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CFTC FOUND THAT SHEARSON LEHMAN WAS IN VIOLATION OF THE ACT AS SPECIFIED ABOVE. FIRM WAS ORDERED TO CEASE AND DESIST FROM COMMITTING FUTURE VIOLATIONS, WAS ORDERED TO COMPLY WITH THE UNDERTAKINGS SET FORTH IN THE OFFER OF SETTLEMENT AND WAS ASSESSED A PENALTY OF $90,000.00. i Disclosure 245 of 359 Reporting Source: Regulator

Current Status: Final Allegations: Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/08/1970 Docket/Case Number:

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 09/08/1970 Sanctions Ordered: Suspension Other Sanctions Ordered: Sanction Details: Regulator Statement OTC TRADING OF BRANCH OFFICE SUSPENDED BY THE SEC FOR 30 DAYS, COMMENCING 9/8/70 AND FOR AN ADDITIONAL 10 DAYS THE BRANCH MAY NOT PARTICIPATE IN ANY PRIMARY OR SECONDARY OFFERINGS OF SECURITIES. (SEE SEA RELEASE # 34-8973) i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: SEC Date Initiated: 09/08/1970 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought:

Other Sanction(s)/Relief UNKNOWN (CONVERSION). Sought:

Resolution: Decision Resolution Date: 09/08/1970 Sanctions Ordered: Suspension Other Sanctions Ordered: Sanction Details: OTC TRADING OF BRANCH OFFICE SUSPENDED BY THE SEC FOR THIRTY DAYS, COMMENCING ON SEPTEMBER 8TH, 1970 AND (FOR AN ADDITIONAL TEN DAYS) THE BRANCH MAY NOT PARTICIPATE IN ANY PRIMARY OR SECONDARY OFFERINGS OF SECURITIES (SEA RELEASE # 34-8973). i Disclosure 246 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/01/1991 Docket/Case Number: NEW-822-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/01/1991 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON MAY 1, 1991, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT C05910023 (NEW-822-AWC) (DISTRICT NO. 5) SUBMITTED BY RESPONDENT SHEARSON LEHMAN BROTHERS INC. AND CHARLES W. ©2021 FINRA. All rights reserved. Report aboutGLADNEY LEHMAN BROTHERS INC. 370 WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $50,000 AND RESPONDENT GLADNEY IS CENSURED, FINED $5,000, SUSPENDED FROM ASSOCIATION WITH ANY MEMBER OF THE NASD IN ANY PRINCIPAL CAPACITY FOR SIX (6) MONTHS AND REQUIRED TO REQUALIFY AS A PRINCIPAL BEFORE SERVING AGAIN IN ANY PRINCIPAL CAPACITY - (ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF FAIR PRACTICE - RESPONDENT MEMBER, ACTING THROUGH RESPONDENT GLADNEY, FAILED TO ESTABLISH, MAINTAIN AND/OR ENFORCE WRITTEN SUPERVISORY PROCEDURES WHICH WOULD HAVE ENABLED IT TO REASONABLY AND PROPERLY SUPERVISE AN INDIVIDUAL). ***$50,000.00 PAID ON 5/22/91 INVOICE #91-05-568*** www.finra.org/brokercheck User Guidance

ON MAY 1, 1991, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT C05910023 (NEW-822-AWC) (DISTRICT NO. 5) SUBMITTED BY RESPONDENT SHEARSON LEHMAN BROTHERS INC. AND CHARLES W. GLADNEY WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $50,000 AND RESPONDENT GLADNEY IS CENSURED, FINED $5,000, SUSPENDED FROM ASSOCIATION WITH ANY MEMBER OF THE NASD IN ANY PRINCIPAL CAPACITY FOR SIX (6) MONTHS AND REQUIRED TO REQUALIFY AS A PRINCIPAL BEFORE SERVING AGAIN IN ANY PRINCIPAL CAPACITY - (ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF FAIR PRACTICE - RESPONDENT MEMBER, ACTING THROUGH RESPONDENT GLADNEY, FAILED TO ESTABLISH, MAINTAIN AND/OR ENFORCE WRITTEN SUPERVISORY PROCEDURES WHICH WOULD HAVE ENABLED IT TO REASONABLY AND PROPERLY SUPERVISE AN INDIVIDUAL). ***$50,000.00 PAID ON 5/22/91 INVOICE #91-05-568*** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS AND ONE OF ITS PRINCIPALS, C. WALLACE GLADNEY (FORMERLY THE MANAGER OF SHEARSON'S BATON ROUGE, LA OFFICE) FAILED TO ADEQUATELY SUPERVISE JOHN W. GRIFFITH, A FORMER REPRESENTATIVE. GRIFFITH WAS ALLEGED TO HAVE, AMONG OTHER THINGS AND DURING THE PERIOD 1986 THROUGH 1988 ENGAGED IN UNAUTHORIZED TRADING, FAILED TO HAVE FOLLOWED CUSTOMER INSTRUCTIONS, ALTERED AND DISTRIBUTED CONFIRMATIONS TO CUSTOMERS, AND PREPARED AND DISTRIBUTED INACCURATE ACCOUNT SUMMARIES TO CUSTOMERS. Initiated By: NASD - DBCC FOR DISTRICT NO. 5 Date Initiated: 05/01/1991 Docket/Case Number: NEW-822-AWC

Principal Product Type: Other Other Product Type(s): NONE SPECIFIED Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution Date: 05/01/1991 Sanctions Ordered: Censure Monetary/Fine $55,000.00 Other Sanctions Ordered: GLADNEY AGREED TO REQUALIFY AS A PRINCIPAL BY TAKING AND PASSING THE SERIES 24 EXAM BEFORE AGAIN SERVING IN A SUPERVISORY CAPACITY.

FINE: 50K LEVIED AGAINST SHEARSON; 5K, AGAINST GLADNEY. Sanction Details: WITHOUT ADMITTING OR DENYING THE NASD'S ALLEGATIONS, SHEARSON AND GLADNEY CONSENTED TO THE IMPOSITIONS OF A CENSURE AND FINES AS OUTLINED ABOVE. i Disclosure 247 of 359 Reporting Source: Regulator Current Status: Final Allegations: COMPLAINT INITIATED BY LLOYD E. AND DOREAN ELLIOTT, JTWROS DATED 12/19/91 ALLEGING UNSUITABLE SECURITIES RECOMMENDATIONS AND UNTRUE STATEMENTS ON NEW ACCOUNT CARD. Initiated By: NORTH DAKOTA SECURITIES COMMISSIONER Date Initiated: 12/11/1992 Docket/Case Number: URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/11/1992 Sanctions Ordered: Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: CONSENT ORDER EXECUTED 12/11/92 TO TERMINATE AND AVOID FURTHER ADMINISTRATIVE PROCEEDING ONLY AND DOES NOT CONSTITUTE AN ADMISSION BY THE RESPONDENTS OF ANY VIOLATION ©2021 FINRA. All rights reserved. Report aboutOF LEHMAN BROTHERS INC. 372 THE NORTH DAKOTA SECURITIES ACT OR THE RULES AND REGULATIONS PROMULGATED THEREUNDER. RESPONDENTS REPAID $40,535.07 to COMPLAINANTS AND ALSO PAID $5,000 IN ADMINISTRATIVE COSTS TO THE STATE. www.finra.org/brokercheck User Guidance

CONSENT ORDER EXECUTED 12/11/92 TO TERMINATE AND AVOID FURTHER ADMINISTRATIVE PROCEEDING ONLY AND DOES NOT CONSTITUTE AN ADMISSION BY THE RESPONDENTS OF ANY VIOLATION OF THE NORTH DAKOTA SECURITIES ACT OR THE RULES AND REGULATIONS PROMULGATED THEREUNDER. RESPONDENTS REPAID $40,535.07 to COMPLAINANTS AND ALSO PAID $5,000 IN ADMINISTRATIVE COSTS TO THE STATE. Regulator Statement COMPLAINT INITIATED BY LLOYD E. AND DOREAN ELLIOTT, JTWROS DATED 12/19/91 ALLEGING UNSUITABLE SECURITIES RECOMMENDATIONS AND UNTRUE STATEMENTS ON NEW ACCOUNT CARD. RESULTS: CONSENT ORDER EXECUTED 12/11/92 TO TERMINATE AND AVOID FURTHER ADMINISTRATIVE PROCEEDING ONLY AND DOES NOT CONSTITUTE AN ADMISSION BY THE RESPONDENTS OF ANY VIOLATION OF THE NORTH DAKOTA SECURITIES ACT OR THE RULES PROMULGATED THEREUNDER. RESPONDENTS REPAID $40,535.07 TO COMPLAINANTS AND ALSO PAID $5,000 IN ADMINISTRATIVE COSTS TO THE STATE. i Reporting Source: Firm Current Status: Final Allegations: THE NORTH DAKOTA SECURITIES COMMISSIONER ALLEGED VIOLATIONS OF SECTIONS 10-04-04 AND 10-04-11 OF THE NORTH DAKOTA SECURITIES ACT IN THE HANDLING OF A CUSTOMER ACCOUNT. Initiated By: STATE OF NORTH DAKOTA Date Initiated: 12/11/1992 Docket/Case Number: N/A

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE; CONSENT ORDER Sought:

Resolution: Consent Resolution Date: 12/11/1992 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: SETTLEMENT WITH CLIENT OF $40,535.01. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 373 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: SETTLEMENT WITH CLIENT OF $40,535.01. Sanction Details: RESPONDENTS SHEARSON LEHMAN BROTHERS AND JOHN DONALDSON AGREED TO SETTLE WITH THE CLIENT IN THE AMOUNT OF $40,535.01 AND TO PAY ADMINISTRATIVE COSTS OF $5,000.00 TO THE SECURITIES COMMISSIONER. i Disclosure 248 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NEW YORK Date Initiated: 01/03/1978 Docket/Case Number: Unknown URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 01/03/1978 Sanctions Ordered: Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: Regulator Statement 1/3/78 STATE OF NY: THREE ASSURANCES OF DISCONTINUANCES TO CEASE AND DESIST FROM FURTHER VIOLATIONS. COSTS: $5,000 PAID. i Reporting Source: Firm Current Status: Final Allegations: RULE VIOLATION (NOT SPECIFIED; CONVERSION). Initiated By: STATE OF NEW YORK ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 374 www.finra.org/brokercheck User Guidance

Initiated By: STATE OF NEW YORK Date Initiated: 01/03/1978 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Decision Resolution Date: 01/03/1978 Sanctions Ordered: Monetary/Fine $5,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: THREE ASSURANCES OF DISCONTINUANCES TO CEASE AND DESIST FROM FURTHER VIOLATIONS. COSTS: $5,000.00. i Disclosure 249 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 07/06/1978 Docket/Case Number: Unknown

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution Date: 07/06/1978 Sanctions Ordered: Suspension Other Sanctions Ordered: Sanction Details: Regulator Statement ND 78-130 7/6/78 REL 34-14917 AND 14918 ADMINISTRATIVE PROCEEDINGS INSTITUTED. PURSUANT TO OFFER OF SETTLEMENT, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, ORDER ENTERED SUSPENDING ALL OPTION TRADING FOR PERIODS OF 30 AND 60 DAYS RESPECTIVELY IN RESPONDENT'S ATLANTA, GA AND SHERMAN OAKS, CA, BRANCH OFFICES AS TO ACCOUNTS FOR WHICH AN OPTION SUITABILITY FORM HAS NOT BEEN SUBMITTED PRIOR TO THE ENTRY OF THE ORDER. i Reporting Source: Firm Current Status: Final Allegations: FINDING OF WILLFUL VIOLATIONS OF SECTIONS 17(A) AND 10(B) OF THE '34 ACT IN OPTIONS TRADING. Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 07/06/1978 Docket/Case Number: 3-5378

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION. Sought:

Resolution: Settled Resolution Date: 07/06/1978 Sanctions Ordered: Suspension Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: FINDING OF WILLFUL VIOLATIONS AS DESCRIBED ABOVE.

i Disclosure 250 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: CHICAGO BOARD OF OPTION EXCHANGE Date Initiated: 06/23/1977 Docket/Case Number: Unknown

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 06/23/1977 Sanctions Ordered: Censure Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 6/23/77, CBOE: FAILURE TO PROPERLY SUPERVISE. WITHOUT ADMITTING OR DENYING CHARGES, CONSENTED TO A CENSURE AND FINE IN THE AMOUNT OF $2,500. i Reporting Source: Firm Current Status: Final Allegations: FAILURE TO PROPERLY SUPERVISE. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 06/23/1977 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 06/23/1977 Sanctions Ordered: Censure Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING CHARGES, FIRM CONSENTED TO A CENSURE AND A FINE IN THE AMOUNT OF $2,500.00. i Disclosure 251 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: CHICAGO BOARD OF OPTION EXCHANGE Date Initiated: 02/12/1976 Docket/Case Number: Unknown

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 02/12/1976 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 378 www.finra.org/brokercheck User Guidance

Sanction Details: Regulator Statement 2/12/76, CBOE: PURSUANT TO AN OFFER OF SETTLEMENT, FINED $10,000. i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 02/12/1976 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 02/12/1976 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: PURSUANT TO OFFER OF SETTLEMENT, FIRM FINED $10,000.00. i Disclosure 252 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/16/1973 Docket/Case Number: 464

Principal Product Type:

Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 01/24/1974 Sanctions Ordered: Monetary/Fine Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #464 FILED 3-16-73 1-24-74: RIGHTS WAIVED: FINAL 3-21-74: PAID (FC# 5544) i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 03/16/1973 Docket/Case Number: 464

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 01/24/1974 Sanctions Ordered: Other Sanctions Ordered: FINE (UNKNOWN AMOUNT; CONVERSION). Sanction Details: RIGHTS WAIVED: FINAL MARCH 21ST, 1974. PAID.

i Disclosure 253 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/21/1976 Docket/Case Number: AWC-63

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 05/21/1976 Sanctions Ordered: Censure Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #AWC-63 FILED 05/21/76 DIST. #2N DECISION 05/21/76: CENSURED; FINED $500. 05/21/76: FINAL FINES & COSTS 06/11/76, FC# 6531 PD. i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD - DBCC FOR DISTRICT NO. 2N Date Initiated: 05/21/1976 Docket/Case Number: AWC-63 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 381 www.finra.org/brokercheck User Guidance

Docket/Case Number: AWC-63

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 05/21/1976 Sanctions Ordered: Censure Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: DECISION MAY 21ST, 1976: CENSURED; FINED $500.00. i Disclosure 254 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/13/1973 Docket/Case Number: ND 73-219

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 11/13/1973 Sanctions Ordered: Cease and Desist/Injunction Other Sanctions Ordered:

Sanction Details: Regulator Statement ND 73-219 11/13/73 LR-6145 COMPLAINT FILED SEEKING TO ENJOIN REGISTRANT, AND PERMANENTLY ENJOINED, BY CONSENT, FROM VIOLATIONS OF ANTI-FRAUD PROVISIONS IN PUBLIC OFFERINGS AND PRIVATE PLACEMENTS. ND 74-45 03/06/74 LR-6269 INJUNCTIVE ACTION FILED AND STIPULATION AND CONSENT ENTERED WHEREIN RESPONDENT IS SUSPENDED FROM MANAGING UNDERWRITINGS FOR 60 DAYS AND REGISTRANT AGREES TO ESTABLISH A FUND OF $300,000.00 TO BE REMITTED TO PURCHASERS OF UNDERWRITING. REGISTRANT VIOLATED ANTIFRAUD PROVISIONS IN THE OFFERING OF SECURITIES. i Reporting Source: Firm Current Status: Final Allegations: COMPLAINT SOUGHT TO ENJOIN REGISTRANT, AND PERMANENTLY ENJOIN, BY CONSENT, FROM VIOLATIONS OF ANTI-FRAUD PROVISIONS IN PUBLIC OFFERINGS AND PRIVATE PLACEMENTS. Initiated By: NASD Date Initiated: 11/13/1973 Docket/Case Number: ND 73-219

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION. Sought:

Resolution: Consent Resolution Date: 11/13/1973 Sanctions Ordered: Cease and Desist/Injunction Other Sanctions Ordered:

Sanction Details: INJUNCTIVE ACTION FILED AN STIPULATION AND CONSENT ENTERED WHEREIN RESPONDENT IS SUSPENDED FROM MANAGING UNDERWRITINGS FOR A PERIOD OF SIXTY DAYS; REGISTRANT AGREES TO ESTABLISH A FUND OF $300,000.00 TO BE REMITTED TO PURCHASERS OF UNDERWRITING. REGISTRANT VIOLATED ANTIFRAUD PROVISIONS IN THE OFFERING OF SECURITIES. i Disclosure 255 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/07/1971 Docket/Case Number: NY-SC-84

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 05/19/1971 Sanctions Ordered: Censure Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement #NY-SC-84 FILED 04/07/71 - SC ACCEPTED 04/19/71 WHEREIN RESPS. MEMBER IS CENSURED & FINED FINED $500.00 TO BE FINAL 05/19/71 FINAL FINED 04/22/71 i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION).

Initiated By: NASD Date Initiated: 04/07/1971 Docket/Case Number: NY-SC-84

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 05/19/1971 Sanctions Ordered: Censure Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: RESPONDENT WAS CENSURED AND FINED IN THE AMOUNT OF $500.00. i Disclosure 256 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/14/1985 Docket/Case Number: KC-332

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/16/1985

Sanctions Ordered: Censure Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMP# KC-332, DISTRICT NO. 4, FILED JUNE 14, 1985; ALLEGING VIOLATIONS OF ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS JOSEPH A. DEL DUCA AND PETER J. RENALDO, FAILED TO RESPOND TO THE ASSOCIATION'S FORMAL WRITTEN REQUESTS FOR INFORMATION MADE PURSUANT TO ARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE.

ENTERED 1/21/86:

DECISION RENDERED DECEMBER 16, 1985, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BY THE RESPONDENTS WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $2,500.00, AND RESPONDENT RENALDO IS ISSUED A LETTER OF CAUTION FOR WHICH THE DECISION WILL SERVE.

FC #9301 $2,500 PAID IN FULL 1/22/86 i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS BY SHEARSON LEHMAN BROTHERS OF ARTICLE III, SECTION 1 OF THE NASD'S RULES OF FAIR PRACTICE. Initiated By: NASD - DBCC FOR DISTRICT NO. 4 Date Initiated: 12/16/1985 Docket/Case Number: KC-332

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 386 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 12/16/1985 Sanctions Ordered: Censure Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND A $2,500.00 FINE. i Disclosure 257 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 08/27/1970 Docket/Case Number: NY-1271

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 11/25/1970 Sanctions Ordered: Censure Monetary/Fine Other Sanctions Ordered: Sanction Details: Regulator Statement #NY-1271 FILED 08/27/70 11/25/70 CENSURED FINED PD.

i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 08/27/1970 Docket/Case Number: NY-1271

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 11/25/1970 Sanctions Ordered: Censure Other Sanctions Ordered: FINE (UNKNOWN AMOUNT; CONVERSION). Sanction Details: FIRM CENSURED AND FINED. i Disclosure 258 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: ARKANSAS Date Initiated: 05/29/1985 Docket/Case Number: 85-45-S URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 388 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 05/29/1985 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Regulator Statement FORM U-6 RECEIVED 6/20/85 DISCLOSES: SHEARSON WILFULLY VIOLATED SECTION 3(b) OF THE AR SEC. ACT BY EMPLOYING AN AGENT, TERRY WAIN BISHOP, CRD# 500054, WITHOUT REGISTRATION IN ARKANSAS. SHEARSON CONSENTS TO FINDING, UNDERTAKES TO ABIDE BY PROVISIONS OF ACT AND IS CENSURED. CASE NO. 85-45-S. i Reporting Source: Firm Current Status: Final Allegations: IT WAS FOUND THAT SHEARSON LEHMAN BROTHERS HAD VIOLATED THE ARKANSAS ACT BY EMPLOYING AN AGENT WITHOUT REGISTRATION IN THE STATE. Initiated By: STATE OF ARKANSAS Date Initiated: 05/29/1985 Docket/Case Number: 85-45-S

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief VIOLATION (EMPLOYED UNREGISTERED AGENT) Sought:

Other Sanctions Ordered: Sanction Details: THE FIRM CONSENTED TO THE STATE'S FINDINGS, AGREED TO THE IMPOSITION OF A CENSURE AND UNDERSTOOD TO ABIDE BY THE PROVISIONS OF THE ACT. i Disclosure 259 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/30/1995 Docket/Case Number: CMS940116 AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/25/1995 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS940116 AWC

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED BY THE MSC ON MAY 30, 1995 AGAINST LEHMAN BROTHERS, INC. ALLEGING VIOLATIONS OF RULE 11Ac1-1(c) OF THE SECURITIES EXCHANGE ACT OF 1934, PART V, SECTION 2(b) OF SCHEDULE D TO THE ASSOCIATION'S BY-LAWS AND ARTICLE III, SECTIONS 1 AND 6 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE IN THAT LEHM FAILED TO HONOR THE QUOTATIONS IT CAUSED TO BE DISSEMINATED THROUGH THE NASDAQ SYSTEM. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 390 THE AWC WAS ACCEPTED BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON SEPTEMBER 25, 1995 WHEREIN LEHM WAS CENSURED AND FINED $15,000. THE AWC BECAME FINAL ON SEPTEMBER 25, 1995. *********************************************************** ***$15,000.00 PAID ON 11/10/95, INVOICE #95-MS-656*** MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS940116 AWC

THE AWC WAS ACCEPTED BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON SEPTEMBER 25, 1995 WHEREIN LEHM WAS CENSURED AND FINED $15,000. THE AWC BECAME FINAL ON SEPTEMBER 25, 1995. *********************************************************** ***$15,000.00 PAID ON 11/10/95, INVOICE #95-MS-656*** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT IN SIX INSTANCES IN 1994, LEHMAN BROTHERS FAILED TO HONOR THE QUOTATIONS IT CAUSED TO BE DISSEMINATED THROUGH THE NASDAQ SYSTEM, IN VIOLATION OF RULE 11AC1-1(C) OF THE SECURITIES EXCHANGE ACT OF 1934, PART V, SECTION 2(B)OF SCHEDULE D TO THE ASSOCIATION'S BY-LAWS, AND ARTICLE III, SECTIONS 1 AND 6 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 09/25/1995 Docket/Case Number: CMS940116 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/25/1995 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE AWC, LEHMAN BROTHERS INC. CONSENTED TO THE ENTRY OF FINDINGS BY THE ASSOCIATION AND CONSENTED TO CENSURE AND FINE IN THE AMOUNT OF $15,000.00. i Disclosure 260 of 359 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 391 www.finra.org/brokercheck User Guidance

Disclosure 260 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/01/1995 Docket/Case Number: CMS950046 AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/25/1995 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS950046 AWC

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED BY THE MSC ON MAY 1, 1995 AGAINST LEHMAN BROTHERS, INC. (LEHM) ALLEGING VIOLATIONS OF PART X, SECTION 2(a)(8) AND PART XI, SECTION 2(a)(8) OF THE SCHEDULE D TO THE ASSOCIATION'S BY-LAWS AND THE INTERPRETATION OF THE BOARD OF GOVERNORS CONCERNING THE OBLIGATION OF MEMBERS TO REPORT TRANSACTIONS WITHIN 90 SECONDS OF EXECUTION.

THIS AWC WAS ACCEPTED BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON SEPTEMBER 25, 1995 WHEREIN LEHM WAS FINED $1,000 AND SHALL UNDERTAKE TO IMPLEMENT ITS SUPERVISORY PROCEDURES TO PREVENT SUCH A PATTERN OR PRACTICE OF LATE TRADE REPORTING. THE AWC BECAME FINAL ON SEPTEMBER 25, 1995. ©2021 FINRA. All rights reserved. Report about********************************************************* LEHMAN BROTHERS INC. 392 ****$1,000.00 PAID ON 11/10/95, INVOICE #95-MS-659**** MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS950046 AWC

THIS AWC WAS ACCEPTED BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON SEPTEMBER 25, 1995 WHEREIN LEHM WAS FINED $1,000 www.finra.org/brokercheck AND SHALL UNDERTAKE TO IMPLEMENT ITS SUPERVISORY PROCEDURES User Guidance TO PREVENT SUCH A PATTERN OR PRACTICE OF LATE TRADE REPORTING. THE AWC BECAME FINAL ON SEPTEMBER 25, 1995. ********************************************************* ****$1,000.00 PAID ON 11/10/95, INVOICE #95-MS-659**** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT DURING THE WEEKS ENDING DECEMBER 16, 1994 AND MARCH 10, 1995 LEHMAN BROTHERS REPORTED TRANSACTIONS LATE AND IN EXCESS OF NINETY SECONDS OF EXECUTION, IN VIOLATION OF ARTICLE III, SECTION 1 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE AND CONTRARY TO THE PROVISIONS OF SCHEDULE D TO THE ASSOCIATION'S BY-LAWS (PART X, SECTION 2(A)(8), PART XI, SECTION 2(A)(8) AND THE INTERPRETATION OF THE BOARD OF GOVERNORS. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 09/25/1995 Docket/Case Number: CMS950046 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/25/1995 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE AWC, LEHMAN BROTHERS CONSENTED TO THE ENTRY OF FINDINGS BY THE ASSOCIATION AND CONSENTED TO A FINE IN THE AMOUNT OF $1,000.00. i Disclosure 261 of 359 Reporting Source: Regulator Current Status: Final

©2021Allegations: FINRA. All rights reserved. Report aboutBASED LEHMAN ON FINDINGSBROTHERS INC. THAT AGENT GEORGE PREBOLA 393 ENGAGED IN UNSUITABLE TRANSACTIONS IN THE ACCOUNT OF A 90 YEAR OLD WIDOW AND FALSIFYING HER NEW ACCOUNT FORMS AND THAT SHEARSON FAILED REASONABLY TO SUPERVISE. www.finra.org/brokercheck User Guidance

Allegations: BASED ON FINDINGS THAT AGENT GEORGE PREBOLA ENGAGED IN UNSUITABLE TRANSACTIONS IN THE ACCOUNT OF A 90 YEAR OLD WIDOW AND FALSIFYING HER NEW ACCOUNT FORMS AND THAT SHEARSON FAILED REASONABLY TO SUPERVISE. Initiated By: MASSACHUSETTS SECURITIES DIVISION Date Initiated: 10/26/1990 Docket/Case Number: E-88-396 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 11/26/1990 Sanctions Ordered: Other Sanctions Ordered: Sanction Details: THE DIVISION ORDERED SHEARSON TO PAY $50,000.00 AS THE COST OF SETTING UP A PROGRAM THROUGH MASSACHUSETTS HOME CARE ASSOCIATION TO ASSIST THE ELDERLY IN MANAGING THEIR FINANCIAL AFFAIRS. Regulator Statement Not Provided i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON VIOLATED SECTION 101 OF THE MASSACHUSETTS UNIFORM SECURITIES ACT BY A FORMER REPRESENTATIVE CONDUCTING UNSUITABLE TRADES IN A CUSTOMER ACCOUNT; BY FAILING TO ACT IN ACCORDANCE WITH SAID CUSTOMER'S INVESTMENT OBJECTIVES; BY ALTERING ACCOUNT DOCUMENTATION OF SAID CUSTOMER; BY CONDUCTING EXCESSIVE SPECULATIVE TRADING IN THE CUSTOMER ACCOUNT; BY RR FAILING TO COMPLY WITH SHEARSON'S OWN INTERNAL COMPLIANCE PROCEDURES AND GUIDELINES; AND BY FAILING TO FULFILL THE FIDUCIARY RESPONSIBILITY TO CUSTOMER. IT ©2021 FINRA. All rights reserved. Report aboutWAS LEHMAN ALSO BROTHERSALLEGED INC.THAT SHEARSON FAILED TO PROPERLY SUPERVISE 394 THE REPRESENTATIVE. IT WAS ALLEGED THAT SHEARSON VIOLATED SECTION 101 OF THE MASSACHUSETTS UNIFORM SECURITIES ACT BY A FORMER REPRESENTATIVE CONDUCTING UNSUITABLE TRADES IN A CUSTOMER ACCOUNT; BY FAILING TO ACT IN ACCORDANCE WITH SAID CUSTOMER'S www.finra.org/brokercheck INVESTMENT OBJECTIVES; BY ALTERING ACCOUNT DOCUMENTATION OF User Guidance SAID CUSTOMER; BY CONDUCTING EXCESSIVE SPECULATIVE TRADING IN THE CUSTOMER ACCOUNT; BY RR FAILING TO COMPLY WITH SHEARSON'S OWN INTERNAL COMPLIANCE PROCEDURES AND GUIDELINES; AND BY FAILING TO FULFILL THE FIDUCIARY RESPONSIBILITY TO CUSTOMER. IT WAS ALSO ALLEGED THAT SHEARSON FAILED TO PROPERLY SUPERVISE THE REPRESENTATIVE. Initiated By: COMMONWEALTH OF MASSACHUSETTS Date Initiated: 08/06/1990 Docket/Case Number: E-88-396

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 10/26/1990 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: COMPLY WITH ACT, REVIEW RRS ACCOUNTS FOR PERIOD OF ONE YEAR, ISSUE STATEMENT TO CLARIFY SUITABILITY GUIDELINES, ASSIST ELDERLY IN MASSACHUSETTS WITH FINANCIAL MANAGEMENT THROUGH A PROGRAM FUNDED WITH ABOVE FINE; CENSURE OF RR. Sanction Details: WITHOUT ADMITTING OR DENYING ANY VIOLATION OF THE MASSACHUSETTS ACT, SHEARSON AND THE RR CONSENTED TO IMPOSITION OF FOLLOWING SANCTIONS: 1) BOTH SHEARSON AND REPRESENTATIVE AGREE TO COMPLY WITH ALL PROVISIONS OF THE ACT, 2) SHEARSON SHALL APPOINT AN INDIVIDUAL TO REVIEW ACCOUNTS OF THE REPRESENTATIVE FOR A PERIOD OF ONE YEAR FROM DATE OF ENTRY OF ORDER, 3) SHEARSON SHALL ISSUE STATEMENT TO ALL OF ITS REGISTERED REPRESENTATIVES SETTING FORTH SUITABILITY GUIDELINES, 4) SHEARSON SHALL AGREE TO PROVIDE THROUGH THE MASSACHUSETTS HOME CARE ASSOCIATION, A PROGRAM TO ASSIST THE ELDER IN THE MANAGEMENT OF THEIR FINANCIAL AFFAIRS, 5) COST OF MONEY MANAGEMENT PROGRAM SHALL AMOUNT TO 50K AND 6) THE REGISTERED REPRESENTATIVE SHALL BE CENSURED. i Disclosure 262 of 359 Reporting Source: Regulator Current Status: Final ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 395 www.finra.org/brokercheck User Guidance

Allegations: Not Provided Initiated By: MASSACHUSETTS SECURITIES DIVISION Date Initiated: 09/24/1981 Docket/Case Number: E-81-08 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 09/24/1981 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Not Provided Regulator Statement SHEARSON LOEB RHOADES WAS CENSURED FOR FAILURE TO SUPERVISE, IN ALLOWING AN UNLICENSED AGENT TO MAKE TRADES WITH TWO CUSTOMERS. i Reporting Source: Firm Current Status: Final Allegations: SHEARSON LOEB RHOADES WAS ALLEGED TO HAVE FAILED TO SUPERVISE IN THAT IT ALLEGEDLY ALLOWED AN UNLICENSED AGENT TO EFFECT TWO TRANSACTIONS. Initiated By: COMMONWEALTH OF MASSACHUSETTS Date Initiated: 09/24/1981 Docket/Case Number: E-81-08

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 396 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 09/24/1981 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED FOR THE ALLEGED VIOLATION. i Disclosure 263 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/22/1962 Docket/Case Number: A-187

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 02/15/1963 Sanctions Ordered: Monetary/Fine $25,000.00 Suspension Other Sanctions Ordered: Sanction Details: Regulator Statement #A-187 FILED 06/22/62 02/15/63 SUSPENDED 5 DAYS. FINED $25,000 ASSESSED $20,000 ©2021 FINRA. All rights reserved. Report aboutPD. LEHMAN03/07/63 BROTHERS INC. 397 www.finra.org/brokercheck User Guidance #A-187 FILED 06/22/62 02/15/63 SUSPENDED 5 DAYS. FINED $25,000 ASSESSED $20,000 PD. 03/07/63 i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 06/22/1962 Docket/Case Number: A-187

Principal Product Type: Other Other Product Type(s): UNKNOWN (IF APPLICABLE; CONVERSION). Principal Sanction(s)/Relief Suspension Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 02/15/1963 Sanctions Ordered: Monetary/Fine $25,000.00 Suspension Other Sanctions Ordered: Sanction Details: SUSPENDED FIVE DAYS. FINED $25,000.00; ASSESSED $20,000.00. i Disclosure 264 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 08/03/1994 Docket/Case Number: C04940012

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 08/03/1994 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON AUGUST 3, 1994, DISTRICT NO. 4 NOTIFIED SHEARSON LEHMAN BROTHERS, INC. (n/k/a LEHMAN BROTHERS INC.) THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C04940012 WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $10,000 - (ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF FAIR PRACTICE - RESPONDENT MEMBER FAILED TO ADEQUATLY AND PROPERLY SUPERVISE AN ACCOUNT EXECUTIVE OF THE FIRM).

***$10,000 PAID ON 9/26/94 INVOICE #94-04-538*** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS INC. VIOLATED ARTICLE III, SECTIONS 1 AND 27 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE WHEN IT FAILED TO ADEQUATELY AND PROPERLY SUPERVISE AN ACCOUNT REPRESENTATIVE BY A)NEGLECTING TO SET FORTH WRITTEN PROCEDURES DETAILING THE APPROVAL EXCEPTIONS FOR ACCOUNT REPRESENTATIVES ACTING AS FIDUCIARIES FOR ACCOUNTS THEY SERVICE AND B) FAILING TO FOLLOW UP TO DETERMINE WHETHER APPROPRIATE SUPERVISORY ACTION WAS TAKEN WITH RESPECT TO AN ACCOUNT REPRESENTATIVE'S HANDLING OF A TRUST ACCOUNT. Initiated By: NASD DBCC FOR DISTRICT NO. 4 Date Initiated: 08/03/1994 Docket/Case Number: C04940012

Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 08/03/1994 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHEARSON LEHMAN BROTHERS INC. CONSENTED TO THE FINDINGS AND AGREED TO A CENSURE AND A FINE IN THE AMOUNT OF $10,000.00. i Disclosure 265 of 359 Reporting Source: Regulator Current Status: Final Allegations: FIRM VIOLATED RULE 300 OF THE COMMISSION' SECURITIES ACT RULES PERTAINING TO NOTICE OF CIVIL, CRIMINAL AND ADMINISTRATIVE ACTION. SPECIFICALLY, RULE 303A.1, 300A.2, 300A.3 AND 300B. Initiated By: VIRGINIA - STATE CORPORATION COMMISSION DIVISION OF SECURITIES Date Initiated: 05/11/1994 Docket/Case Number: SEC940047 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution Date: 05/11/1994 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: FIRM FINED $1,000.00 FOR ALLEGED VIOLATIONS OF RULE 300 AND ASSESSED $250.00 FOR INVESTIGATION COSTS. Regulator Statement CONTACT HAZEL C. STEWART, SENIOR BROKER-DEALER EXAMINER, 804-371-9685. i Reporting Source: Firm Current Status: Final Allegations: THE ORDER ALLEGED THAT SHEARSON LEHMAN BROTHERS INC. FAILED TO TIMELY NOTIFY THE STATE CORPORATION COMMISSION OF A CIVIL COMPLAINT FILED AGAINST THE FIRM. Initiated By: COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION Date Initiated: 05/02/1994 Docket/Case Number: SEC940047

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FAILURE TO TIMELY NOTIFY VIRGINIA OF A CIVIL COMPLAINT FILED Sought: AGAINST FIRM.

Resolution: Consent Resolution Date: 05/02/1994 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: $250.00 PAID TO STATE TO COVER COST OF INVESTIGATION. Sanction Details: ORDER OF SETTLEMENT ENTERED. SHEARSON LEHMAN BROTHERS INC. CONSENTED TO UNDERTAKING TO PAY A CIVIL PENALTY OF $1,000.00 AND TO REIMBURSE THE STATE $250.00 FOR THE COSTS OF ITS INVESTIGATION. Firm Statement THE ORDER OF SETTLEMENT NOTED THAT "LEHMAN BROTHERS DID NOT PARTICIPATE IN, NOR HAVE ANY RESPONSIBILITY FOR, ANY OF THE CONDUCT DISCUSSED IN THIS ORDER." i ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 401 www.finra.org/brokercheck User Guidance

Disclosure 266 of 359 Reporting Source: Regulator Current Status: Final Allegations: A STIPULTATION OF FACTS AND CONSENTS TO PENALTY WAS SUBSEQUENTLY ENTERED INTO BETWEEN THE EXCHANGE, SHEARSON AND WAS ACCEPTED BY AN EXCHANGE DISCIPLINARY PANEL AT A HEARING HELD ON DECEMBER 15, 1994. RESPONDENT SHEARSON CONSENTED TO A FINDING THAT IT VIOLATED EXCHANGE RULE 320 AND 411 IN THAT THE FIRM FAILED TO DILIGENTLY SUPERVISE PEYTON, SALYER, GYEVARA AND SALYER'S CUSTOMER ACCOUNTS BY NOT PREVENTING GUEVARA FROM a) ENTERING ORDERS FOR SALYER'S CUSTOMERS FOR THE PURCHASE OF LFT SHARES AT OR NEAR THE CLOSE OF TRADING WHICH HAD THE EFFECT OF UNDULY INFLUENCING THE PRICE OF THAT SECURITY; AND b) IMPROPERLY RECORDING THE TIME WHEN ORDERS IN LFT WERE TRANSMITTED FOR EXECUTION. Initiated By: AMEX Date Initiated: 09/03/1992 Docket/Case Number: 92-D-20

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 02/16/1994 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: SHEARSON WAS CENSURED AND FINED $50,000. Regulator Statement Not Provided i Reporting Source: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 402 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS INC. FAILED TO SUPERVISE RANDOLPH PEYTON, RONALD SALYER, MARIE GUEVARA, AND SALYER'S CUSTOMER ACCOUNTS. Initiated By: AMERICAN STOCK EXCHANGE INC. Date Initiated: 09/03/1992 Docket/Case Number: N/A

Principal Product Type: Other Other Product Type(s): NOT INDICATED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 10/12/1993 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHEARSON LEHMAN BROTHERS INC. AGREED TO A CENSURE AND FINE IN THE AMOUNT OF $50,000.00. i Disclosure 267 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/08/1994 Docket/Case Number: C05930076

Principal Product Type: Other Product Type(s):

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/08/1994 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON MARCH 8, 1994, DISTRICT NO. 5 NOTIFIED SHEARSON LEHMAN BROTHERS INC. (n/k/a LEHMAN BROTHERS INC.) AND RICHARD A. STROUD THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C05930076 WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $10,000; AND RESPONDENT STROUD IS CENSURED AND AGREES TO REQUALIFY AS A GENERAL SECURITIES PRINCIPAL BY TAKING AND PASSING THE SERIES 24 EXAMINATION WITHIN 90 DAYS OF THE ACCEPTANCE OF THIS AWC. IF RESPONDENT STROUD FAILS TO COMPLETE AND PASS THE SERIES 24 EXAMINATION WITHIN THAT TIME PERIOD, HE SHALL BE SUSPENDED FROM ACTING IN ANY PRINCIPAL, SUPERVISORY, OR BRANCH MANAGER CAPACITY UNTIL SUCH TIME AS HE DOES COMPLETE AND PASS THE SERIES 24 EXAMINATION. FURTHER RESPONDENT STROUD, MUST TAKE AND COMPLETE THE NEXT AVAILABLE IN-HOUSE TRAINING PROGRAM GIVEN BY HIS CURRENT MEMBER FIRM (SMITH BARNEY SHEARSON INC.) FOR ALL NEW BRANCH MANAGERS. IF THERE IS NO FIRM-WIDE TRAINING PROGRAM OFFERED ON OR BEFORE MARCH 31, 1994, HIS MEMBER FIRM WILL PROVIDE INDIVIDUAL TRAINING TO RESPONDENT STROUD BEFORE SUCH DATE, IN A MANNER SATISFACTORY TO THE NASD. - (ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF FAIR PRACTICE - RESPONDENT MEMBER, ACTING THROUGH RESPONDENT STROUD, FAILED AND NEGLECTED TO EXERCISE REASONABLE AND PROPER SUPERVISION OVER A REGISTERED REPRESENTATIVE OF THE FIRM IN CONNECTION WITH THE FIRM'S POLICY FOR CHECK DISBURSEMENT. SPECIFICAILLY, RESPONDENT MEMBER, ACTING THROUGH RESPONDENT STROUD, FAILED TO ADEQUATELY FOLLOW AND ENFORCE THE SUPERVISORY PROCEDURES IN PLACE FOR THE DISBURSEMENT OF CHECKS ©2021 FINRA. All rights reserved. Report aboutOUT LEHMAN OF CLIENT BROTHERS ACCOUNTS INC. BY PERSONNEL IN A BRANCH OFFICE OF 404 RESPONDENT MEMBER).

***$10,000.00 PAID ON 4/14/94, INVOICE #94-05-186. ON MARCH 8, 1994, DISTRICT NO. 5 NOTIFIED SHEARSON LEHMAN BROTHERS INC. (n/k/a LEHMAN BROTHERS INC.) AND RICHARD A. STROUD THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C05930076 WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $10,000; AND RESPONDENT STROUD IS CENSURED AND AGREES TO REQUALIFY AS A GENERAL SECURITIES PRINCIPAL BY TAKING AND PASSING THE SERIES 24 EXAMINATION WITHIN 90 DAYS OF THE ACCEPTANCE OF THIS AWC. IF RESPONDENT STROUD FAILS TO COMPLETE AND PASS THE SERIES 24 EXAMINATION WITHIN THAT TIME PERIOD, HE SHALL BE SUSPENDED FROM ACTING IN ANY PRINCIPAL, SUPERVISORY, OR BRANCH MANAGER CAPACITY UNTIL SUCH TIME AS HE DOES COMPLETE AND PASS THE SERIES 24 EXAMINATION. FURTHER RESPONDENT STROUD, MUST TAKE AND COMPLETE THE NEXT AVAILABLE IN-HOUSE TRAINING PROGRAM GIVEN BY HIS CURRENT MEMBER FIRM (SMITH BARNEY SHEARSON INC.) FOR ALL NEW BRANCH MANAGERS. IF THERE IS NO FIRM-WIDE TRAINING PROGRAM OFFERED ON OR BEFORE MARCH 31, 1994, HIS MEMBER FIRM WILL PROVIDE INDIVIDUAL TRAINING TO RESPONDENT STROUD BEFORE SUCH DATE, IN A MANNER SATISFACTORY TO THE NASD. - (ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF FAIR PRACTICE - RESPONDENT MEMBER, ACTING THROUGH RESPONDENT STROUD, FAILED AND NEGLECTED TO EXERCISE REASONABLE AND PROPER SUPERVISION OVER A REGISTERED REPRESENTATIVE OF THE FIRM IN CONNECTION WITH THE FIRM'S POLICY FOR CHECK DISBURSEMENT. SPECIFICAILLY, RESPONDENT MEMBER, ACTING www.finra.org/brokercheck THROUGH User Guidance RESPONDENT STROUD, FAILED TO ADEQUATELY FOLLOW AND ENFORCE THE SUPERVISORY PROCEDURES IN PLACE FOR THE DISBURSEMENT OF CHECKS OUT OF CLIENT ACCOUNTS BY PERSONNEL IN A BRANCH OFFICE OF RESPONDENT MEMBER).

***$10,000.00 PAID ON 4/14/94, INVOICE #94-05-186. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS INC. FAILED TO FOLLOW AND ENFORCE THE SUPERVISORY PROCEDURES IN PLACE FOR DISBURSEMENT OF CHECKS FROM CLIENT ACCOUNTS IN ITS TULSA, OKLAHOMA OFFICE. Initiated By: NASD DBCC FOR DISTRICT NO. 5 Date Initiated: 10/12/1993 Docket/Case Number: C05930076

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 10/12/1993 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHEARSON LEHMAN BROTHERS INC. CONSENTED TO A CENSURE AND FINE IN THE AMOUNT OF $10,000.00. i Disclosure 268 of 359 Reporting Source: Regulator Current Status: Final Allegations: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 405 www.finra.org/brokercheck User Guidance

Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/23/1993 Docket/Case Number: CMS930091 AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/09/1994 Sanctions Ordered: Monetary/Fine $6,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 3/10/94: MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS930091 AWC (A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED NOVEMBER 23, 1993 AGAINST RESPONDENT MEMBER LEHMAN BROTHERS, INC. ALLEGING VIOLATIONS OF PART V, SECTION 2(d) OF SCHEDULE D FOR ENTERING NASDAQ QUOTATIONS CONTAINING EXCESS SPREADS.

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON JAMUARY 31, 1994 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON MARCH 9, 1994. **$6,000.00 FINE.

***$6,000.00 PAID ON 4/11/94, INVOICE #MS93-0091. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT, ON OCTOBER 5, 8 AND 11, 1993, LEHMAN BROTHERS INC. ENTERED INTO THE NASDAQ SYSTEM QUOTATIONS WHICH CONTAINED SPREADS IN EXCESS OF THE MAXIMUM ALLOWABLE ©2021 FINRA. All rights reserved. Report aboutSPREADS. LEHMAN BROTHERS INC. 406 www.finra.org/brokercheck User Guidance

IT WAS ALLEGED THAT, ON OCTOBER 5, 8 AND 11, 1993, LEHMAN BROTHERS INC. ENTERED INTO THE NASDAQ SYSTEM QUOTATIONS WHICH CONTAINED SPREADS IN EXCESS OF THE MAXIMUM ALLOWABLE SPREADS. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 03/09/1994 Docket/Case Number: CMS 930091 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/09/1994 Sanctions Ordered: Monetary/Fine $6,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS INC. CONSENTED TO THE ENTRY OF FINDINGS THAT IT VIOLATED PART V, SECTION 2(D) OF SCHEDULE D OF THE ASSOCIATION'S BY-LAWS. IN ADDITION, LEHMAN BROTHERS CONSENTED TO A FINE IN THE AMOUNT OF $250.00. i Disclosure 269 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/23/1993 Docket/Case Number: CMS930089 AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 407 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/09/1994 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 3/10/94: MARKET SURVILLANCE COMMITTEE COMPLAINT #CMS930089 AWC (A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED NOVEMBER 23, 1993 AGAINST RESPONDENT MEMBER LEHMAN BROTHERS, INC. ALLEGING VIOLATIONS OF ARTICLE III, SECTION 1 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE IN THAT THAT RESPONDENTS UPDATED QUOTATIONS IN THE BULLETIN BOARD SYSTEM OUTSIDE THE ALLOWABLE TIME FOR UPDATING FOREIGN OR ADR SECURITIES ON THE BULLETIN BOARD.

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON JANUARY 31, 1994 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON MARCH 9, 1994. **$250.00 FINE.

***$250.00 PAID ON 4/05/94, INVOICE #MS93-0089. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT, ON NOVEMBER 15, 1993, LEHMAN BROTHERS UPDATED QUOTATIONS ON THE BULLETIN BOARD SYSTEM IN THE SECURITY LONRHO LTD ADR (US)(LNRHY) OUTSIDE OF THE ALLOWABLE TIME FOR UPDATING FOREIGN OR ADR SECURITIES ON THE BULLETIN BOARD. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 03/09/1994 Docket/Case Number: CMS930089 AWC

Other Product Type(s): ADR Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 03/09/1994 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS INC. CONSENTED TO AN ENTRY OF FINDINGS THAT IT VIOLATED ARTICLE III, SECTION 1 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE. IN ADDITION, LEHMAN BROTHERS CONSENTED TO A FINE IN THE AMOUNT OF $250.00. i Disclosure 270 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/23/1994 Docket/Case Number: C06940007

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 07/17/1995 Sanctions Ordered: Censure Monetary/Fine $3,390.00 Disgorgement/Restitution

Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT NO. C06940007 FILED FEBRUARY 23, 1994 BY DISTRICT NO. 6 AGAINST SHEARSON LEHMAN BROTHERS, INC. (k/n/a - LEHMAN BROTHERS, INC.), FRANCIS M. MAGGIO AND PAUL C. DAVY ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 18 AND 27 OF THE RULES OF FAIR PRACTICE CONCERNING SUITABILITY IN THAT RESPONDENT DAVY EFFECTED TRANSACTIONS IN THE ACCOUNT OF A PUBLIC CUSTOMER WITHOUT HAVING REASONABLE GROUNDS FOR BELIEVING THAT SUCH TRANSACTIONS WERE SUITABLE FOR THE CUSTOMER BASED ON FACTS, IF ANY, DISCLOSED BY SUCH CUSTOMER AS TO HIS OTHER SECURITY HOLDINGS, FINANCIAL SITUTATION AND NEEDS; EFFECTED EXCESSIVE AND UNWARRANTED TRANSACTIONS IN THE ACCOUNT OF A PUBLIC CUSTOMER AT A LOSS IN EXCESS OF $8,000; MADE FALSE AND MISLEADING STATEMENTS TO A PUBLIC CUSTOMER; AND, RESPONDENTS MEMBER AND MAGGIO FAILED TO ADEQUATELY SUPERVISE THE ACTIVITIES OF RESPONDENT DAVY.

DECISION RENDERED APRIL 17, 1995, WHEREIN THE COMPLAINT AGAINST RESPONDENT MAGGIO IS DISMISSED IN THAT THE DBCC DOES NOT BELIEVE THAT RESPONDENT MAGGIO FAILED TO SUPERVISE THE ACTIVITIES OF RESPONDENT DAVY AS ALLEGED IN THE COMPLAINT. THE DBCC BELIEVES THAT RESPONDENT MAGGIO ACTED IN ACCORDANCE WITH RESPONDENT MEMBER PROCEDURES IN EFFECT AT THE TIME OF THE ALLEGED VIOLATION. IF NO FURTHER ACTION, DECISION IS FINAL JUNE 2, 1995. ON JULY 17, 1995, THE DECISION AND ORDER OF ACCEPTANCE OF OFFER OF SETTLEMENT SUBMITTED BY RESPONDENTS MEMBER AND DAVY WAS ISSUED: THEREFORE, RESPONDENT DAVY IS CENSURED, FINED AND $5,000, ORDERED TO DISGORGE $4,786 IN COMMISSIONS; AND, RESPONDENT MEMBER IS CENSURED AND FINED $10,000, WHICH INCLUDES DISGORGEMENT OF $6,610 IN COMMISSIONS.

**$10,000.00 PAID ON 8/4/95, INVOICE #95-06-445** i Reporting Source: Firm Current Status: Final

©2021Allegations: FINRA. All rights reserved. Report aboutDISTRICT LEHMAN NO. BROTHERS 6 ISSUED INC. A COMPLAINT ALLEGING THAT SHEARSON 410 LEHMAN BROTHERS INC., K/N/A LEHMAN BROTHERS INC., FAILED TO SUPERVISE A REGISTERED REPRESENTATIVE'S HANDLING OF A CUSTOMER ACCOUNT (SEE ITEM 13 BELOW). www.finra.org/brokercheck User Guidance

Allegations: DISTRICT NO. 6 ISSUED A COMPLAINT ALLEGING THAT SHEARSON LEHMAN BROTHERS INC., K/N/A LEHMAN BROTHERS INC., FAILED TO SUPERVISE A REGISTERED REPRESENTATIVE'S HANDLING OF A CUSTOMER ACCOUNT (SEE ITEM 13 BELOW). Initiated By: NASD DBCC FOR DISTRICT NO. 6 Date Initiated: 02/23/1994 Docket/Case Number: C06940007

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 07/17/1995 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: AN OFFER OF SETTLEMENT WAS ACCEPTED BY THE DBCC FOR DISTRICT NO. 6 AND THE NATIONAL BUSINESS CONDUCT COMMITTEE. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT, LEHMAN BROTHERS CONSENTED TO AN ENTRY OF FINDINGS THAT IT VIOLATED ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE. LEHMAN BROTHERS CONSENTED TO CENSURE AND A FINE IN THE AMOUNT OF $10,000.00. Firm Statement DISTRICT NO. 6 ALLEGED THAT DURING THE PERIOD JUNE 1987 THROUGH ABOUT DECEMBER 1988, A REGISTERED REPRESENTATIVE OF SHEARSON LEHMAN BROTHERS INC. EFFECTED UNAUTHORIZED AND EXCESSIVE TRADES WHICH WERE UNSUITABLE FOR THE CUSTOMER'S ACCOUNT AND THAT SHEARSON LEHMAN BROTHERS INC. FAILED TO SUPERVISE THE REGISTERED REPRESENTATIVE. i Disclosure 271 of 359 Reporting Source: Regulator Current Status: Final Allegations: VIOLATED EXCHANGE RULE 390(a) BY EFFECTING AS ©2021 FINRA. All rights reserved. Report aboutPRINCIPAL LEHMAN BROTHERSTRANSACTIONS INC. IN THE DOMESTIC OVER-THE-COUNTER 411 MARKET BASKETS OF STOCKS WHICH INCLUDED EXCHANGE LISTED SECURITIES NOT ELIGIBLE FOR SUCH TRADING; VIOLATED EXCHANGE RULE 476(a)(11) BY FILING INCOMPLETE DAILY PROGRAM TRADING REPORTS WITH THE EXCHANGE; AND VIOLATED SEC REG. 240.17A-4(b)(1) BY FAILING TO PRESERVE RECORDS OF ORDERS. www.finra.org/brokercheck User Guidance

Allegations: VIOLATED EXCHANGE RULE 390(a) BY EFFECTING AS PRINCIPAL TRANSACTIONS IN THE DOMESTIC OVER-THE-COUNTER MARKET BASKETS OF STOCKS WHICH INCLUDED EXCHANGE LISTED SECURITIES NOT ELIGIBLE FOR SUCH TRADING; VIOLATED EXCHANGE RULE 476(a)(11) BY FILING INCOMPLETE DAILY PROGRAM TRADING REPORTS WITH THE EXCHANGE; AND VIOLATED SEC REG. 240.17A-4(b)(1) BY FAILING TO PRESERVE RECORDS OF ORDERS. Initiated By: HEARING PANEL Date Initiated: 12/20/1993 Docket/Case Number: 93-137

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/20/1993 Sanctions Ordered: Censure Monetary/Fine $35,000.00 Other Sanctions Ordered: Sanction Details: CONSENT TO CENSURE AND $35,000 FINE. Regulator Statement THE FINE MUST BE PAID WITHIN 45 DAYS. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS INC. VIOLATED NYSE RULES BY EFFECTING AS PRINCIPAL TRANSACTIONS IN THE DOMESTIC OTC MARKET BASKETS OF STOCKS WHICH INCLUDED EXCHANGE-LISTED SECURITIES NOT ELIGIBLE FOR SUCH TRADING, AND BY FILING INCOMPLETE DAILY PROGRAM TRADING REPORTS WITH THE EXCHANGE. IT WAS ALSO ALLEGED THAT SHEARSON LEHMAN BROTHERS VIOLATED SEC REGULATIONS BY FAILING TO PRESERVE RECORDS OF ORDERS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 412 IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS INC. VIOLATED NYSE RULES BY EFFECTING AS PRINCIPAL TRANSACTIONS IN THE DOMESTIC OTC MARKET BASKETS OF STOCKS WHICH INCLUDED www.finra.org/brokercheck EXCHANGE-LISTED SECURITIES NOT ELIGIBLE FOR SUCH TRADING, AND User Guidance BY FILING INCOMPLETE DAILY PROGRAM TRADING REPORTS WITH THE EXCHANGE. IT WAS ALSO ALLEGED THAT SHEARSON LEHMAN BROTHERS VIOLATED SEC REGULATIONS BY FAILING TO PRESERVE RECORDS OF ORDERS. Initiated By: NEW YORK STOCK EXCHANGE INC. - DIVISION OF ENFORCEMENT Date Initiated: 11/01/1993 Docket/Case Number: 93-137

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 12/20/1993 Sanctions Ordered: Censure Monetary/Fine $35,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LEHMAN BROTHERS INC. CONSENTED TO THE FINDINGS OF THE NYSE AND AGREED TO A CENSURE AND A FINE IN THE AMOUNT OF $35,000.00. i Disclosure 272 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/20/1993 Docket/Case Number: CMS930033 AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/21/1993 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMPLAINT NO. CMS930033 AWC:

THE FOLLOWING LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED BY MSC ON 7/20/93, ALLEGES VIOLATIONS OF SECTION (c) 2(D) OF THE ASSOCIATION'S SOES RULES BY RESPONDENTS WAS ACCEPTED BY MSC ON 8/13/93 AND BY NBCC 9/21/93. FINE $5,000. **$5,000.00 PAID ON 11/17/93 INVOICE #93-MS-767** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT, DURING THE PERIOD OF MARCH 4 THROUGH JUNE 14, 1993, SHEARSON LEHMAN BROTHERS INC. ENTERED ORDERS ON AN AGENCY BASIS INTO SOES FOR SECURITIES FOR WHICH SHEARSON LEHMAN BROTHERS WAS A MARKET MAKER. AS SUCH, IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS VIOLATED C)2(D) OF THE RULES AND PROCEDURES FOR SOES AND ARTICLE III, SECTION 1 OF THE ASSOCIATIONS RULES OF FAIR PRACTICE. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 07/20/1993 Docket/Case Number: CMS930033 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 09/22/1993 Sanctions Ordered: Monetary/Fine $5,000.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 414 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: SHEARSON LEHMAN BROTHERS INC. CONSENTED TO A FINE IN THE AMOUNT OF $5,000.00. i Disclosure 273 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 08/27/1993 Docket/Case Number: C06930026

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 07/17/1995 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT NO. C06930026 FILED AUGUST 27, 1993 BY DISTRICT NO. 6 AGAINST LEHMAN BROTHERS INC., FRANK GERALD SARAN AND MARK JAMES STEVENSON ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 18 AND 27 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT SARAN EXECUTED SECURITIES TRANSACTIONS FOR THE ACCOUNTS OF PUBLIC CUSTOMERS WITHOUT THE KNOWLEDGE OR CONSENT OF THE CUSTOMERS, AND IN THE ABSENCE OF WRITTEN OR ORAL AUTHORIZATION TO EXERCISE DISCRETION IN THE ACCOUNTS; AND, RESPONDENT MEMBER, ACTING ©2021 FINRA. All rights reserved. Report aboutTHROUGH LEHMAN RESPONDENTBROTHERS INC. STEVENSON, FAILED TO ESTABLISH, MAINTIAN 415 AND ENFORCE A SUPERVISORY SYSTEM WHICH REQUIRED THE REVIEW OF CUSTOMER ACCOUNTS TO DETECT UNAUTHORIZED TRADING. ON DECEMBER 2, 1994, THE COMBINED (C06930026/C06940016) DECISION AND ORDER OF ACCEPTANCE OF OFFER OF SETTLEMENT SUBMITTED BY RESPONDENT SARAN WAS ACCEPTED; THEREFORE, HE IS CENSURED AND FINED $10,000.

ON JULY 17, 1995, INC. THE DECISION AND ORDER OF ACCEPTANCE OF OFFER OF SETTLEMENT SUBMITTED BY RESPONDENT MEMBER WAS ISSUED: THERFORE, RESPONDENT MEMBER IS CENSURED AND FINED $10,000. THE COMMITTEE DETERMINED TO DISMISS THE COMPLIANT AGAINST RESPONDENT STEVENSON IN THAT THEY CONCLUDED THAT ANY SUPERVISORY DEFICIENCIES WHICH MAY HAVE EXISTED IN THE BRANCH OFFICE OF RESPONDENT MEMBER PROBABLY STEMMED FROM RESPONDENT MEMBER, RATHER THAN THE ACTIONS OR INACTIONS OF RESPONDENT STEVENSON.

**$10,000.00 PAID ON 8/4/95, INVOICE #95-06-443** COMPLAINT NO. C06930026 FILED AUGUST 27, 1993 BY DISTRICT NO. 6 AGAINST LEHMAN BROTHERS INC., FRANK GERALD SARAN AND MARK JAMES STEVENSON ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 18 AND 27 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT SARAN EXECUTED SECURITIES TRANSACTIONS FOR THE ACCOUNTS OF PUBLIC www.finra.org/brokercheck CUSTOMERS WITHOUT THE KNOWLEDGE OR CONSENT OF THE User Guidance CUSTOMERS, AND IN THE ABSENCE OF WRITTEN OR ORAL AUTHORIZATION TO EXERCISE DISCRETION IN THE ACCOUNTS; AND, RESPONDENT MEMBER, ACTING THROUGH RESPONDENT STEVENSON, FAILED TO ESTABLISH, MAINTIAN AND ENFORCE A SUPERVISORY SYSTEM WHICH REQUIRED THE REVIEW OF CUSTOMER ACCOUNTS TO DETECT UNAUTHORIZED TRADING. ON DECEMBER 2, 1994, THE COMBINED (C06930026/C06940016) DECISION AND ORDER OF ACCEPTANCE OF OFFER OF SETTLEMENT SUBMITTED BY RESPONDENT SARAN WAS ACCEPTED; THEREFORE, HE IS CENSURED AND FINED $10,000.

**$10,000.00 PAID ON 8/4/95, INVOICE #95-06-443** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS FAILED TO SUPERVISE THE ACTIVITY OF AGENT SARAN, SPECIFICALLY WITH REGARD TO REVIEW OF CUSTOMER ACCOUNTS TO DETECT UNAUTHORIZED TRADING. Initiated By: NASD DBCC FOR DISTRICT NO. 6 Date Initiated: 08/27/1993 Docket/Case Number: C06930026

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 08/26/1993 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMPLAINT NO. CMS930027 AWC: THE FOLLOWING LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED ON 4/28/93, ALLEGE VIOLATIONS OF ARTICLE III, SECTION 1 OF THE ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 417 ASSOCIATION'S RULES OF FAIR PRACTICE IN THAT THE RESPONDENTS UPDATED QUOTATIONS IN THE BULLETIN BOARD SYSTEM OUTSIDE THE ALLOWABLE TIME FOR UPDATING FOREIGN OR ADR SECURITIES ON THE BULLETIN BOARD. ACCEPTED BY MSC ON 7/19/93 AND BY NBCC ON 8/26/93. FINE $250. **$250.00 PAID ON 9/30/93 INVOICE #93-MS-679** www.finra.org/brokercheck User Guidance MARKET SURVEILLANCE COMPLAINT NO. CMS930027 AWC: THE FOLLOWING LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED ON 4/28/93, ALLEGE VIOLATIONS OF ARTICLE III, SECTION 1 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE IN THAT THE RESPONDENTS UPDATED QUOTATIONS IN THE BULLETIN BOARD SYSTEM OUTSIDE THE ALLOWABLE TIME FOR UPDATING FOREIGN OR ADR SECURITIES ON THE BULLETIN BOARD. ACCEPTED BY MSC ON 7/19/93 AND BY NBCC ON 8/26/93. FINE $250. **$250.00 PAID ON 9/30/93 INVOICE #93-MS-679** i Reporting Source: Firm Current Status: Final Allegations: SHEARSON LEHMAN BROTHERS ALLEGEDLY VIOLATED ARTICLE III, SECTION 1 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE BY UPDATING QUOTATIONS OF CERTAIN SECURITIES IN THE BULLETIN BOARD SYSTEM OUTSIDE OF THE ALLOWABLE TIME FOR UPDATING FOREIGN OR ADR SECURITIES ON THE BULLETIN BOARD. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 06/10/1993 Docket/Case Number: CMS930027 AWC

Principal Product Type: Other Other Product Type(s): FOREIGN/ADR SECURITIES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/26/1993 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: SHEARSON LEHMAN BROTHERS CONSENTED TO A FINE IN THE AMOUNT OF $250.00. i Disclosure 275 of 359 Reporting Source: Regulator Current Status: Final

©2021Allegations: FINRA. All rights reserved. Report aboutALLEGED LEHMAN THAT BROTHERS SHEARSON INC. LEHMAN BROTHERS 418 VIOLATED THE VIRGINIA SECURITIES ACT RULE 305A.6 IN THAT THE FIRM THROUGH ITS AGENT EXECUTED A TRANSACTION OR TRANSACTIONS IN A MARGIN ACCOUNT WITHOUT SECURING FROM THE CUSTOMER A PROPERLY EXECUTED MARGIN AGREEMENT PROMPTLY AFTER THE INITIAL TRANSACTION IN THE ACCOUNT. www.finra.org/brokercheck User Guidance

Allegations: ALLEGED THAT SHEARSON LEHMAN BROTHERS VIOLATED THE VIRGINIA SECURITIES ACT RULE 305A.6 IN THAT THE FIRM THROUGH ITS AGENT EXECUTED A TRANSACTION OR TRANSACTIONS IN A MARGIN ACCOUNT WITHOUT SECURING FROM THE CUSTOMER A PROPERLY EXECUTED MARGIN AGREEMENT PROMPTLY AFTER THE INITIAL TRANSACTION IN THE ACCOUNT. Initiated By: VIRGINIA - STATE CORPORATION COMMISSION DIVISION OF SECURITIES Date Initiated: 08/18/1993 Docket/Case Number: SEC930034 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 08/18/1993 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ALLEGATIONS, SHEARSON LEHMAN BROTHERS, AGREED TO A PENALTY TO THE COMMONWEALTH OF VIRGINIA IN THE AMOUNT OF $5,000, REIMBURSE CUSTOMER FOR MARGIN INTEREST CHARGED ACCOUNT AND PAY COSTS OF THE DIVISION'S INVESTIGATION. Regulator Statement CONTACT: CONTACT BRIAN SILVERMAN, BROKER-DEALER EXAMINER, 804-371-9415. i Reporting Source: Firm Current Status: Final Allegations: THE COMMONWEALTH OF VIRGINIA ALLEGED THAT SHEARSON EXECUTED SECURITIES TRANSACTIONS IN MARGIN IN A CUSTOMER ACCOUNT ©2021 FINRA. All rights reserved. Report aboutWITHOUT LEHMAN A BROTHERS PROPERLY INC. EXECUTED CLIENT AGREEMENT. 419 www.finra.org/brokercheck User Guidance

Allegations: THE COMMONWEALTH OF VIRGINIA ALLEGED THAT SHEARSON EXECUTED SECURITIES TRANSACTIONS IN MARGIN IN A CUSTOMER ACCOUNT WITHOUT A PROPERLY EXECUTED CLIENT AGREEMENT. Initiated By: COMMONWEALTH OF VIRGINIA Date Initiated: 09/01/1993 Docket/Case Number: SEC930034

Principal Product Type: Other Other Product Type(s): UNKNOWN Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE; MARGIN VIOLATION Sought:

Resolution: Settled Resolution Date: 09/01/1993 Sanctions Ordered: Monetary/Fine $6,000.00 Disgorgement/Restitution Other Sanctions Ordered: RESTITUTION TO CUSTOMER OF $3,532.69. Sanction Details: $6,000.00 TO VIRGINIA (REPRESENTING A 5K FINE AND 1K IN INVESTIGATION COST); $3,532.69 TO CUSTOMER (REPRESENTING MARGIN INTEREST CHARGED). i Disclosure 276 of 359 Reporting Source: Regulator Current Status: Final Allegations: CONSENT ORDER TO CENSURE, TO C&D, TO IMPOSE CIVIL PENALTY AND IMPOSE SANCTIONS--204 (a) (1) (T), 204 (a) (1) (T), 204 (a) (2) ETC--- RESPONDENT PAID $50,000 PENALTY GS-----NT Initiated By: CORP AND SECURITIES BUREAU, STATE OF MICHIGAN Date Initiated: 03/11/1991 Docket/Case Number: BD 8089 URL for Regulatory Action: Principal Product Type: Other Product Type(s): ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 420 www.finra.org/brokercheck User Guidance

Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/11/1991 Sanctions Ordered: Censure Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: SEE ABOVE Regulator Statement SEE ABOVE CONTACT: 517-334-6215 i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED SHEARSON LEHMAN BROTHERS INC VIOLATED CERTAIN MARGIN RULES AND RULES PERTAINING TO EXTENSION OF CREDIT DURING THE PERIOD MAY 9, 1986 THROUGH APPROXIMATELY MAY 27, 1987. Initiated By: STATE OF MICHIGAN Date Initiated: 02/19/1991 Docket/Case Number: BD 8089

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 02/19/1991 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Cease and Desist/Injunction ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 421 www.finra.org/brokercheck User Guidance

Censure Monetary/Fine $50,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: FIRM AGREED TO THE ENTRY OF A CONSENT ORDER TO CENSURE, TO CEASE AND DESIST, TO IMPOSE CIVIL PENALTY AND IMPOSE SANCTIONS PURSUANT TO THE MICHIGAN ACT BY THE MICHIGAN SECURITIES BUREAU. PRIOR TO THE ENTRY OF THE CONSENT ORDER, SHEARSON, OF ITS OWN VOLITION, INSTITUTED NEW POLICIES AND PROCEDURES TO RECTIFY THE VIOLATIONS ALLEGED IN THE CONSENT DECREE. AS A SETTLEMENT, SHEARSON HAS BEEN CENSURED, AGREED TO CEASE AND DESIST FROM ANY PRACTICE OR ACT CONSTITUTING A VIOLATION OF THE ACT DURING THE PERIOD MAY 9, 1986 TO ON OR ABOUT MAY 27, 1987 AND AGREED TO PAY A CIVIL PENALTY AND COSTS OF INVESTIGATION TOTALLING $50,000.00. i Disclosure 277 of 359 Reporting Source: Regulator Current Status: Final Allegations: THE DEPARTMENT ALLEGES RESPONDENT SHEARSON LEHMAN BROTHERS, INC. ALLOWED UNREGISTERED SALES ASSISTANTS TO ENGAGE IN ACTIVITIES REQUIRING REGISTRATION. Initiated By: FLORIDA DIVISION OF SECURITIES AND INVESTOR PROTECT*See FAQ #1* Date Initiated: 02/03/1993 Docket/Case Number: 1805-S-12/92 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 02/03/1993 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 422 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: ON FEBRUARY 3, 1993, THE FLORIDA DEPARTMENT OF BANKING AND FINANCE ENTERED INTO A FINAL ORDER AND STIPULATION AND CONSENT AGREEMENT WITH RESPONDENT SHEARSON LEHMAN BROTHERS, INC. RESPONDENT AGREES TO ENGAGE IN ACTIVITIES WHICH WOULD REQUIRE REGISTRATION; TO PAY AN ADMINISTRATIVE FINE OF $5,000 AND TO PAY ANOTHER $5,000 TO THE FLORIDA COUNCIL ON ECONOMIC EDUCATION. Regulator Statement Not Provided i Reporting Source: Firm Current Status: Final Allegations: THE STATE ALLEGED THAT IN 1987 AND 1988, SHEARSON LEHMAN BROTHERS UTILIZED, IN TWO BRANCH OFFICES IN FLORIDA, UNREGISTERED SALES ASSISTANTS, WHOSE DUTIES WERE MORE THAN JUST CLERICAL AND MINISTERIAL. Initiated By: STATE OF FLORIDA DIV OF SECURITIES AND INVESTOR PROTECTION Date Initiated: 11/12/1990 Docket/Case Number: 1805-S-12/92

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief STIPULATION; FINE Sought:

Resolution: Stipulation and Consent Resolution Date: 01/04/1993 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: ADDITIONAL $5,000.00 CONTRIBUTION TO THE FLORIDA COUNCIL ON ECONOMIC EDUCATION. Sanction Details: SHEARSON LEHMAN BROTHERS CONSENTED TO THE STIPULATION AND AGREED TO PAY A $5,000.00 ADMINISTRATIVE FINE AND MAKE A $5,000.00 CONTRIBUTION TO THE FLORIDA COUNCIL ON ECONOMIC EDUCATION.

i Disclosure 278 of 359 Reporting Source: Regulator Current Status: Final Allegations: THE MARYLAND SECURITIES COMMISSIONER ALLEGED THAT SHEARSON VIOLATED THE MARYLAND SECURITIES ACT BY FAILING TO AMEND CERTAIN FORM U-4 FILINGS IN A TIMELY AND EXPEDITIOUS MANNER. Initiated By: MARYLAND DIVISION OF SECURITIES Date Initiated: 04/07/1993 Docket/Case Number: BD-93-0128 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 04/07/1993 Sanctions Ordered: Other Sanctions Ordered: Sanction Details: SHEARSON HAS NOW IMPLEMENTED PROCEDURES DESIGNED TO AVOID SUCH FUTURE VIOLATIONS AND IN SETTLEMENT OF THIS PROCEEDING, THE COMMISSIONER ACCEPTED A CONSENT ORDER WHEREIN SHEARSON AGREED TO COMPLY WITH THE ACT IN THE FUTURE AND PAYMENT OF ADMINISTRATIVE COSTS IN THE AMOUNT OF $30,000.00. Regulator Statement N/A i Reporting Source: Firm Current Status: Final Allegations: FAILURE TO PROMPTLY AMEND CERTAIN FORM U-4 FILINGS PRIOR TO 1992. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 424 www.finra.org/brokercheck User Guidance

Allegations: FAILURE TO PROMPTLY AMEND CERTAIN FORM U-4 FILINGS PRIOR TO 1992. Initiated By: STATE OF MARYLAND DIVISION OF SECURITIES Date Initiated: 04/05/1993 Docket/Case Number: BD-93-0128

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Settled Resolution Date: 04/07/1993 Sanctions Ordered: Monetary/Fine $30,000.00 Other Sanctions Ordered: Sanction Details: PAYMENT OF $30,000.00 IN ADMINISTRATIVE COSTS. i Disclosure 279 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/17/1993 Docket/Case Number: C04920071

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution Date: 03/17/1993 Sanctions Ordered: Censure Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON MARCH 17, 1993, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C04920071 (DISTRICT NO. 4) SUBMITTED BY SHEARSON LEHMAN BROTHERS INC. WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $2,500 - (ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF FAIR PRACTICE - RESPONDENT MEMBER FAILED TO ADEQUATELY AND PROPERLY SUPERVISE A FORMER REGISTERED REPRESENTATIVE IN THAT IT FAILED TO ENSURE THAT PUBLIC CUSTOMERS RECEIVED ACTIVITY LETTERS AND FAILED TO ENSURE THAT A BRANCH OFFICE WAS ADEQUATELY STAFFED WITH SUPERVISORY PERSONNEL SO THAT REGISTERED REPRESENTATIVES AT THAT BRANCH OFFICE COULD BE PROPERLY SUPERVISED). **$2.500.00 PAID ON 4/12/93 INVOICE #93-04-338** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS INC., FROM APRIL 1988 TO DECEMBER 1988, FAILED TO ADEQUATELY AND PROPERLY SUPERVISE AN INVESTMENT REPRESENTATIVE'S SALES ACTIVITIES. Initiated By: NASD DBCC NO. 4 Date Initiated: 01/30/1993 Docket/Case Number: C04920071

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CONSENT AND FINE. Sought:

Resolution: Consent

Resolution Date: 03/17/1993 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ANY VIOLATIVE ACTIVITY, SHEARSON LEHMAN BROTHERS INC. CONSENTED TO THE NASD'S FINDINGS AND AGREED TO A CENSURE AND FINE OF $2,500.00. i Disclosure 280 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/13/1992 Docket/Case Number: C8A920084

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 05/18/1993 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT NO. C8A920084 (DISTRICT NO. 8) FILED NOVEMBER 13, 1992 AGAINST RESPONDENTS SHEARSON LEHMAN BROTHERS, INC., WILLARD S. STAWSKI AND DAVID S. WILLIAMS ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2 AND 27 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT STAWSKI RECOMMENDED TO 16 PUBLIC CUSTOMERS THAT THEY LIQUIDATE THEIR HOLDINGS IN CERTAIN SECURITIES AND PURCHASE ANOTHER SECURITY WITHOUT HAVING A REASONABLE BASIS ©2021 FINRA. All rights reserved. Report aboutFOR LEHMAN BROTHERS INC. 427 BELIEVING THAT SUCH RECOMMENDATIONS WERE SUITABLE FOR THE CUSTOMERS IN VIEW OF THEIR FINANCIAL SITUATIONS AND NEEDS AND INVESTMENT OBJECTIVES; AND, IN CONNECTION WITH THE ABOVE ACTIVITIES, RESPONDENT MEMBER, ACTING THROUGH RESPONDENT WILLIAMS, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES OR TO OTHERWISE SUPERVISE RESPONDENT STAWSKI PROPERLY TO PREVENT OCCURRENCE OF SUCH VIOLATIONS.

DECISION RENDERED MAY 18, 1993 WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BY RESPONDENTS WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $5,000, AND RESPONDENT STAWSKI IS CENSURED, FINED $7,500 AND REQUIRED TO REQUALIFY BY EXAMINATION AS A GENERAL SECURITIES REPRESENTATIVE WITHIN 90 DAYS OF THE DATE OF THIS DECISION OR CEASE ACTING IN SUCH A CAPACITY UNTIL HE HAS SO REQUALIFIED. THIS DECISION SHALL SERVE AS A LETTER OF CAUTION AS TO RESPONDENT WILLIAMS.

***$5,000.00 PAID ON 6/15/93 INVOICE #93-8A-425*** COMPLAINT NO. C8A920084 (DISTRICT NO. 8) FILED NOVEMBER 13, 1992 AGAINST RESPONDENTS SHEARSON LEHMAN BROTHERS, INC., WILLARD S. STAWSKI AND DAVID S. WILLIAMS ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2 AND 27 OF THE RULES OF FAIR PRACTICE www.finra.org/brokercheck IN THAT RESPONDENT STAWSKI RECOMMENDED TO 16 PUBLIC User Guidance CUSTOMERS THAT THEY LIQUIDATE THEIR HOLDINGS IN CERTAIN SECURITIES AND PURCHASE ANOTHER SECURITY WITHOUT HAVING A REASONABLE BASIS FOR BELIEVING THAT SUCH RECOMMENDATIONS WERE SUITABLE FOR THE CUSTOMERS IN VIEW OF THEIR FINANCIAL SITUATIONS AND NEEDS AND INVESTMENT OBJECTIVES; AND, IN CONNECTION WITH THE ABOVE ACTIVITIES, RESPONDENT MEMBER, ACTING THROUGH RESPONDENT WILLIAMS, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES OR TO OTHERWISE SUPERVISE RESPONDENT STAWSKI PROPERLY TO PREVENT OCCURRENCE OF SUCH VIOLATIONS.

***$5,000.00 PAID ON 6/15/93 INVOICE #93-8A-425*** i Reporting Source: Firm Current Status: Final Allegations: ALLEGED TO HAVE FAILED TO SUPERVISE A REGISTERED REPRESENTATIVE WHO IS ALLEGED TO HAVE MADE UNSUITABLE RECOMMENDATIONS TO CLIENTS CONCERNING THE PURCHASE OF MUTUAL FUND SHARES. Initiated By: NASD DISTRICT NO. 8 (CHICAGO) Date Initiated: 11/13/1992 Docket/Case Number: C8A920084

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 05/19/1993 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: CONSENTED TO A PENALTY OF A CENSURE AND A $5,000.00 FINE. Firm Statement SETTLED THIS MATTER BY CONSENTING TO THE SANCTIONS WITHOUT ADMITTING OR DENYING THE NASD'S FINDINGS. i Disclosure 281 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/18/1992 Docket/Case Number:

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/18/1992 Sanctions Ordered: Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: Regulator Statement +10/6/92+ SEC NEWS DIGEST, ISSUE 92-182, DATED SEPTEMBER 18, 1992 ADMINISTRATIVE PROCEEDINGS DISCLOSES; "ORDER INSTITUTING PROCEEDINGS, MAKING FINDINGS AND IMPOSING SANCTIONS AGAINST SHEARSON LEHMAN BROTHERS, INC."; THE COMMISSION INSTITUTED PUBLIC ADMINISTRATIVE PROCEEDINGS AGAINST SHEARSON LEHMAN BROTHERS, INC., PURSUANT TO SECTIN 21C OF THE SECURITIES ©2021 FINRA. All rights reserved. Report aboutEXCHANGE LEHMAN BROTHERS ACT OF 1934. INC. THE COMMISSION SIMULTANEOUSLY ACCEPTED 429 SHEARSON'S OFFER OF SETTLEMENT WHEREBY, WITHOUT ADMITTING OR DENYING THE CONTENTS THEREOF, SHEARSON CONSENTED TO ENTRY OF AN ORDER FINDING THAT SHEARSON VIOLATED SECTIONS 7(c), 8(a), AND 17(a) OF THE EXCHANGE ACT, AND REGULATION T PROMULGATED BY THE FEDERAL RESERVE BOARD. THE ORDER REQUIRES SHEARSON TO CEASE AND DESIST FROM COMMITTING OR CAUSING SUCH VIOLATIONS, AND TO ADOPT AND MAINTAIN MEASURES TO ASSURE COMPLAINCE WITH THOSE PROVISIONS. THE COMMISSION FOUND THAT, BETWEEN JANUARY 1986 AND OCTOBER 1988, SHEARSON BORROWED SECURITIES TO CAPTURE STOCK DIVIDENDS AT A DISCOUNT PURSUANT TO DIVIDEND REINVESTMENT PLANS (DRIPS) OFFERED BY VARIOUS ISSUERS. SHEARSON CONCURRENTLY MAINTAINED A PROFIT-SHARING ARRANGMENT WITH ITS CUSTOMERS, PRINCETON NEWPORT PARTNERS, L.P., PURSUANT TO WHICH SHEARSON EFFECTED A SERIES OF PURPORTED TRADES WITH PRINCETON DESIGNED TO RENDER SHEARSON THE RECORD OWNER OF THE SECURITIES FOR DIVIDEND ELECTION PURPOSES WITHOUT EXPOSING THE PARTIES TO NORMAL MARKET RISK. PARTICIPATION IN DRIPS DOES NOT GIVE RISE TO A PERMITTED PURPOSE TO BORROW SECURITIES UNDER SECTION 16 OF REGULATION T. (REL. 34-31196) +10/6/92+ SEC NEWS DIGEST, ISSUE 92-182, DATED SEPTEMBER 18, 1992 ADMINISTRATIVE PROCEEDINGS DISCLOSES; "ORDER INSTITUTING www.finra.org/brokercheck PROCEEDINGS, MAKING FINDINGS AND IMPOSING SANCTIONS AGAINST User Guidance SHEARSON LEHMAN BROTHERS, INC."; THE COMMISSION INSTITUTED PUBLIC ADMINISTRATIVE PROCEEDINGS AGAINST SHEARSON LEHMAN BROTHERS, INC., PURSUANT TO SECTIN 21C OF THE SECURITIES EXCHANGE ACT OF 1934. THE COMMISSION SIMULTANEOUSLY ACCEPTED SHEARSON'S OFFER OF SETTLEMENT WHEREBY, WITHOUT ADMITTING OR DENYING THE CONTENTS THEREOF, SHEARSON CONSENTED TO ENTRY OF AN ORDER FINDING THAT SHEARSON VIOLATED SECTIONS 7(c), 8(a), AND 17(a) OF THE EXCHANGE ACT, AND REGULATION T PROMULGATED BY THE FEDERAL RESERVE BOARD. THE ORDER REQUIRES SHEARSON TO CEASE AND DESIST FROM COMMITTING OR CAUSING SUCH VIOLATIONS, AND TO ADOPT AND MAINTAIN MEASURES TO ASSURE COMPLAINCE WITH THOSE PROVISIONS. THE COMMISSION FOUND THAT, BETWEEN JANUARY 1986 AND OCTOBER 1988, SHEARSON BORROWED SECURITIES TO CAPTURE STOCK DIVIDENDS AT A DISCOUNT PURSUANT TO DIVIDEND REINVESTMENT PLANS (DRIPS) OFFERED BY VARIOUS ISSUERS. SHEARSON CONCURRENTLY MAINTAINED A PROFIT-SHARING ARRANGMENT WITH ITS CUSTOMERS, PRINCETON NEWPORT PARTNERS, L.P., PURSUANT TO WHICH SHEARSON EFFECTED A SERIES OF PURPORTED TRADES WITH PRINCETON DESIGNED TO RENDER SHEARSON THE RECORD OWNER OF THE SECURITIES FOR DIVIDEND ELECTION PURPOSES WITHOUT EXPOSING THE PARTIES TO NORMAL MARKET RISK. PARTICIPATION IN DRIPS DOES NOT GIVE RISE TO A PERMITTED PURPOSE TO BORROW SECURITIES UNDER SECTION 16 OF REGULATION T. (REL. 34-31196) i Reporting Source: Firm Current Status: Final Allegations: PROCEEDING INVOLVED CERTAIN PURCHASE AND SALE TRANSACTIONS WHICH RESULTED IN THE BORROWING OF SECURITIES BY SHEARSON IN ORDER TO TAKE ADVANTAGE OF REDUCED STOCK PRICES AVAILABLE UNDER DIVIDEND REINVESTMENT PLANS OFFERED BY VARIOUS ISSUERS. PURSUANT TO THESE PLANS, COMMONLY REFERRED TO AS AS "DRIPS", SHAREHOLDERS OF RECORD MAY ELECT TO RECEIVE DIVIDENDS IN THE FORM OF ADDITIONAL STOCK AT A DISCOUNT TO MARKET PRICE DIRECTLY FROM THE ISSUER IN LIEU OF CASH. SHEARSON WAS ALLEGED TO HAVE FAILED TO GIVE RISE TO A "PERMITTED PURPOSE" TO BORROW SECURITIES UNDER REGULATION T AND HAD THE EFFECT OF ACCOMPLISHING INDIRECTLY WHAT WAS PROHIBITED BY THE FEDERAL RESERVE BULLETINS DURING THE PERIOD JANUARY 1986 AND OCTOBER 1988.

Initiated By: SEC Date Initiated: 09/17/1992 Docket/Case Number: FILE NO. 3-7853

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief ORDER Sought:

Resolution: Consent Resolution Date: 09/17/1992 Sanctions Ordered: Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: SEC ACCEPTED ORDER OF SETTLEMENT SUBMITTED BY SHEARSON. WITHOUT ADMITTING OR DENYING THE MATTERS SET FORTH THEREIN, SHEARSON CONSENTED TO THE ISSUANCE BY THE SEC OF THE ORDER WHICH 1) MADE FINDINGS THAT SHEARSON VIOLATED SECTIONS 7(C), 8(A) AND 17(A) OF THE EXCHANGE ACT, RULES 17A-3 AND 17A-4 THEREUNDER AND SECTION 16 OF REGULATION T, 2) ORDERED THAT SHEARSON (I) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATION, AND COMMITTING ANY FUTURE VIOLATIONS OF ABOVE, AND (II) ADOPT, IMPLEMENT AND MAINTAIN INTERNAL PROCEDURES, POLICIES AND CONTROLS WHICH ARE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH ABOVE RULES AND REG T. i Disclosure 282 of 359 Reporting Source: Regulator Current Status: Final Allegations: UNLICENSED SALESPERSONS, VIOLATION OF PREVIOUS CEASE AND DESIST ORDER. Initiated By: STATE OF OREGON, DEPARTMENT OF INSURANCE AND FINANC*See FAQ #1* Date Initiated: 08/10/1992 Docket/Case Number: 0-92-0025 URL for Regulatory Action: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 431 www.finra.org/brokercheck User Guidance

URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 08/10/1992 Sanctions Ordered: Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: SHEARSON CONSENTED TO THE ENTRY OF A CEASE AND DESIST ORDER, PAID A CIVIL PENALTY OF $105,000 AND CONTRIBUTED $35,000 TO THE OREGON INVESTOR EDUCATION ACCOUNT. Regulator Statement SHEARSON TRANSACTED BROKER-DEALER BUSINESS IN OREGON THROUGH UNLICENSED SALESPERSONS, VIOLATING ADMINISTRATIVE ORDER 0-91-0019 ISSUED 12-6-91. i Reporting Source: Firm Current Status: Final Allegations: SHEARSON ENGAGED IN SECURITIES TRANSACTIONS VIOLATIVE OF OREGON SECURITIES AGENT REGISTRATION PROVISION. MATTER INVOLVED SECURITIES TRANSACTIONS EFFECTED FOR OREGON CUSTOMERS DURING PERIOD NOV 1991 THROUGH MARCH 1992 BY SHEARSON FINANCIAL CONSULTANTS WHO WERE NOT ROKER-DEALER AGENT-LICENSED IN OREGON WHEN THEY EFFECTED THE TRANSACTIONS. THESE TRANSACTIONS WERE EFFECTED IN VIOLATION OF A DECEMBER 1991 CONSENT ORDER ENTERED INTO BY SHEARSON WITH THE DIVISION (PREVIOUSLY REPORTED ON SHEARSON'S JANUARY 28, 1992 AMENDMENT TO FORM BD) AND WERE REPORTED TO THE DIVISION PURSUANT TO THE REQUIREMENTS OF THAT ORDER. Initiated By: STATE OF OREGON Date Initiated: 08/10/1992 Docket/Case Number: 0-92-0025

Principal Product Type: Other

Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 08/10/1992 Sanctions Ordered: Monetary/Fine $105,000.00 Cease and Desist/Injunction Other Sanctions Ordered: COMPLY WITH UNDERTAKINGS Sanction Details: SHEARSON CONSENTED TO THE FINDING THAT IT ENGAGED IN SECURITIES TRANSACTIONS VIOLATIVE OF OREGON SECURITIES AGENT REGISTRATION PROVISIONS. SHEARSON ALSO CONSENTED TO BEING ORDERED TO 1) CEASE AND DESIST FROM FURTHER VIOLATIONS OF OREGON'S REGISTRATION PROVISIONS; 2) TO PAY $105,000.00 IN CIVIL PENALTIES; AND 3) COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING ISSUING A MORE STRINGENT COMPLIANCE ALERT INVOLVING REGISTRATION REQUIREMENTS, RESTRUCTURING EDUCATION EFFORTS CONCERNING REGISTRATION AND CONTINUING TO REPORT TO THE DIVISION, ON A QUARTERLY BASIS, ALL TRANSACTIONS EFFECTED FOR OREGON CUSTOMERS BY UNREGISTERED FINANCIAL CONSULTANTS. Firm Statement IN IMPOSING PENALTIES, THE DIVISION CONSIDERED EFFORTS SHEARSON HAD MADE TO CURB VIOLATIVE TRANSACTIONS AND A CONTRIBUTION IN THE AMOUNT OF $35,000.00 THAT SHEARSON HAD MADE TO THE OREGON INVESTOR EDUCATION ACCOUNT. i Disclosure 283 of 359 Reporting Source: Regulator Current Status: Final Allegations: EFFECTED AND/OR CAUSED TO BE EFFECTED A TRANSACTION FOR THE PURPOSE OF IMPROPERLY INFLUENCING THE CLOSING PRICE OF A STOCK, WHICH PRICE WAS ALSO USED TO DETERMINE THE OFFERING PRICE OF AN UNDERWRITING; VIOLATED EXCHANGE RULE 342 IN THAT THE FIRM EMPLOYED PROCEDURES WHICH FAILED TO CONTROL ADEQUATELY INFORMATION AS TO RESEARCH RATINGS CHANGES AND THEIR USE AND FAILED TO SUPERVISE ADEQUATELY ASPECTS OF ITS "CHINESE WALL" PROCEDURE Initiated By: NYSE HEARING PANEL ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 433 www.finra.org/brokercheck User Guidance

Initiated By: NYSE HEARING PANEL Date Initiated: 07/13/1992 Docket/Case Number: 92-84

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 07/13/1992 Sanctions Ordered: Censure Monetary/Fine $500,000.00 Other Sanctions Ordered: Sanction Details: CONSENT TO A CENSURE, A FINE OF $500,000 AND AN UNDERTAKING TO REVIEW CERTAIN PROCEDURES AND IMPLEMENT RECOMMENDATIONS. Regulator Statement THE FIRM SHALL UNDERTAKE TO COMPLETE A REVIEW UNDER THE SUPERVISION OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS OF THE FIRM OF ITS PROCEDURES RELATING TO THE INTENDED DISSEMINATION OF EQUITIES TRADING RESEARCH INFORMATION, CHINESE WALL AND SURVEILLANCE PROCEDURES WHICH REVIEW WILL BE IN ADDITION TO ANY REGULARLY SCHEDULED AUDIT, AND A WRITTEN REPORT OF THE FINDINGS AND RECOMMENDATIONS OF SUCH REVIEW WILL BE SUBMITTED TO THE AUDIT COMMITTEE. THE FIRM FURTHER UNDERTAKES TO IMPLEMENT ALL RECOMMENDATIONS OF THE AUDIT COMMITTEE RESULTING FROM THE AFOREMENTIONED REPORT, AND SUBMIT TO THE DIVISION OF ENFORCEMENT A COPY OF SUCH REPORT AND THE AUDIT COMM ITTEE RESULTING FROM THE AFOREMENTIONED REPORT, AND SUBMIT TO THE DIVISION OF ENFORCEMENT A COPY OF SUCH REPORT AND THE AUDIT COMMITTEE RECOMMENDATIONS. THE FIRM FURTHER UNDERTAKES TO PROVIDE THE DIVISION WITH A WRITTEN REPRESENTATION THAT ALL RECOMMENDATIONS HAVE BEEN IMPLEMENTED BY DECEMBER 22, 1992. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 434 THE FIRM SHALL UNDERTAKE TO COMPLETE A REVIEW UNDER THE SUPERVISION OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS OF THE FIRM OF ITS PROCEDURES RELATING TO THE INTENDED DISSEMINATION OF EQUITIES TRADING RESEARCH INFORMATION, CHINESE WALL AND SURVEILLANCE PROCEDURES WHICH REVIEW WILL BE IN ADDITION TO ANY REGULARLY SCHEDULED AUDIT, AND A WRITTEN REPORT OF THE FINDINGS AND RECOMMENDATIONS OF SUCH REVIEW WILL BE SUBMITTED TO THE AUDIT COMMITTEE. THE FIRM FURTHER UNDERTAKES TO IMPLEMENT ALL RECOMMENDATIONS OF THE AUDIT COMMITTEE RESULTING FROM THE AFOREMENTIONED REPORT, AND SUBMIT TO THE DIVISION OF ENFORCEMENT A COPY OF SUCH REPORT AND THE AUDIT COMM ITTEE RESULTING FROM THE AFOREMENTIONED REPORT, AND SUBMIT TO THE DIVISION OF ENFORCEMENT A COPY OF SUCH REPORT www.finra.org/brokercheck AND THE AUDIT COMMITTEE RECOMMENDATIONS. THE FIRM FURTHER User Guidance UNDERTAKES TO PROVIDE THE DIVISION WITH A WRITTEN REPRESENTATION THAT ALL RECOMMENDATIONS HAVE BEEN IMPLEMENTED BY DECEMBER 22, 1992. i Reporting Source: Firm Current Status: Final Allegations: NYSE'S INVESTIGATION INVOLVED PRICING BY LEHMAN BROTHERS, A DIVISION OF SHEARSON LEHMAN BROTHERS INC, OF CONAGRA'S NOVEMBER 1990 PUBLIC OFFERING. THE NYSE ALLEGED THAT SHEARSON, THROUGH CERTAIN EMPLOYEES, EFFECTED A TRANSACTION FOR THE PURPOSE OF IMPROPERLY INFLUENCING THE CLOSING PRICE OF AN UNDERWRITING, WHEREIN LEHMAN WAS THE SOLE UNDERWRITER. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 07/13/1992 Docket/Case Number: DECISION 92-84

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 07/13/1992 Sanctions Ordered: Censure Monetary/Fine $500,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHEARSON CONSENTED TO FINDINGS THAT IT VIOLATED NYSE RULES 342 AND 401, AND TO THE IMPOSITION OF CENSURE AND A FINE OF $500,000.00. SHEARSON ALSO AGREED TO REVIEW, UNDER SUPERVISION OF ITS AUDIT COMMITTEE, INTERNAL POLICIES AND PROCEDURES AND RELATED SURVEILLANCE OF TRADES EXECUTED IN PROPRIETARY ACCOUNTS. i Disclosure 284 of 359 Reporting Source: Regulator Current Status: Final

Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/07/1992 Docket/Case Number: C10910218

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 07/07/1992 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON JULY 7, 1992, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C10910218 (DISTRICT NO. 10) SUBMITTED BY SHEARSON LEHMAN BROTHERS, INC. WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $20,000 - (ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE AND SCHEDULE E OF THE NASD BY-LAWS - IN CONTRAVENTION OF THE FREE-RIDING AND WITHHOLDING INTERPRETATION, RESPONDENT MEMBER EFFECTED THE SALES OF SIX HOT ISSUES TO THREE INVESTMENT PARTNERSHIPS/HEDGE FUNDS WITHOUT OBTAINING THE NAMES AND/OR BUSINESS CONNECTIONS OF ALL INDIVIDUALS HAVING A BENFICIAL INTEREST IN THE ACCOUNTS; EFFECTED SALES IN DISCRETIONARY ACCOUNTS WITHOUT OBTAINING PRIOR SPECIFIC WRITTEN APPROVAL OF THE CUSTOMERS; AND, FAILED TO DISCLOSE ON CONFIRMATIONS OF PRINCIPAL RETAIL TRANSACTIONS THE PRICE REPORTED TO NASDAQ AND DID NOT DISCLOSE MARK-UP/MARK-DOWN TO CUSTOMERS). **$20,000.00 PAID ON 8/18/92 INVOICE #92-10-677** i Reporting Source: Firm Current Status: Final

Allegations: NASD'S ACTIONS AROSE OUT OF AN AUDIT CONDUCTED BETWEEN DECEMBER 19, 1990 AND APRIL 8, 1991. THE FIRM ALLEGEDLY VIOLATED THE FREERIDING AND WITHHOLDING INTERPRETATION IN THAT IT DID NOT HAVE REQUIRED DOCUMENTS ON FILE FOR THREE ACCOUNTS WHICH PURCHASED "HOT ISSUES". FURTHER, THE NASD ALLEGED THAT, IN NINETEEN INSTANCES, THE FIRM VIOLATED SCHEDULE E, SECTION 16 OF THE NASD'S BYLAWS BY ALLOWING DISCRETIONARY ACCOUNTS TO PURCHASE NEWLY-ISSUED AMERICAN EXPRESS STOCK WITHOUT OBTAINING THE PRIOR CONSENT OF THE CUSTOMERS IN WRITING. FINALLY, THE NASD ALLEGED THAT THE FIRM'S DISCLOSURE ON CONFIRMATIONS OF TRANSACTIONS IN PREFERRED SECURITIES TRADED OVER-THE-COUNTER WAS INADEQUATE. Initiated By: NASD DISTRICT NO. 10 Date Initiated: 07/07/1992 Docket/Case Number: C-10910218 AWC

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/07/1992 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTED TO THE NASD'S FINDINGS AND WAS FINED $20,000.00. i Disclosure 285 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/11/1992 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 437 www.finra.org/brokercheck User Guidance

Docket/Case Number: CMS920024 AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 04/07/1992 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS920024 AWC (A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED FEBRUARY 11, 1992 AGAINST RESPONDENT MEMBER LEHMAN BROTHERS ALLEGING VIOLATIONS OF PART VI, SECTION 5(a) OF SCHEDULE D IN THAT THE FOLLOWING RESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME:

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON MARCH 18, 1992 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON APRIL 7, 1992. ***$250.00 FINE*** ***$250.00 PAID ON 5/5/92 INVOICE #92-MS-402*** i Reporting Source: Firm Current Status: Final Allegations: FIRM ALLEGEDLY VIOLATED PART VI, SECTION 5(A) OF SCHEDULE D OF NASD BY-LAWS IN THAT IT FAILED TO REPORT ITS NASDAQ VOLUME. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 02/11/1992 Docket/Case Number: CMS920024 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 438 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/07/1992 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: FINE WAS FINED $250.00. i Disclosure 286 of 359 Reporting Source: Regulator Current Status: Final Allegations: SHEARSON CONSENTED TO A CEASE AND DESIST ORDER AGAINST IT FOR FAILURE TO SUPERVISE ONE OF ITS EMPLOYEES. Initiated By: THE OHIO DIVISION OF SECURITIES, 77 S HIGH ST, 22ND*See FAQ #1* Date Initiated: 05/20/1991 Docket/Case Number: 90-144 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 05/20/1991 Sanctions Ordered: Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CEASE AND DESIST ORDER ISSUED. Regulator Statement Not Provided ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 439 www.finra.org/brokercheck User Guidance

Regulator Statement Not Provided i Reporting Source: Firm Current Status: Final Allegations: MATTER AROSE FROM THE ACTIVITIES OF FORMER REPRESENTATIVE SHELDON STRAUSS, AS A RESULT OF WHOSE ACTIVITIES NUMEROUS SETTLEMENTS WERE ENTERED INTO, AS WELL AS AN AWC WITH THE NATIONAL ASSOCIATION OF SECURITIES DEALERS. Initiated By: STATE OF OHIO Date Initiated: 05/20/1991 Docket/Case Number: 90-144

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 05/20/1991 Sanctions Ordered: Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: SHEARSON LEHMAN BROTHERS ENTERED INTO A CONSENT AGREEMENT BY WHICH THE STATE ISSUED A CEASE AND DESIST ORDER AGAINST THE FIRM. SIMULTANEOUSLY, WITH THE ISSUANCE OF THAT ORDER, THE STATE ALSO GRANTED SHERSON A WAIVER OF THE DISQUALIFICATIONS PROVISION OF THE OHIO REVISED CODE. Firm Statement ACTIVITIES OF STRAUSS RELATE TO THE TIME PERIOD 1986 THROUGH NOVEMBER 1987. AS A PART OF THE CONSENT AGREEMENT, SHEARSON ALSO AGREED TO CERTAIN REVISED PROCEDURES WHICH HAVE ALL BEEN MET. i Disclosure 287 of 359 Reporting Source: Regulator Current Status: Final Allegations: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 440 www.finra.org/brokercheck User Guidance

Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/31/1991 Docket/Case Number: MS-1117-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 11/08/1991 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-1117-AWC: (A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED MAY 31, 1991 AGAINST RESPONDENT MEMBER LEHMAN BROTHERS ALLEGING VIOLATIONS OF PART VI, SECTION 5(a) OF SCHEDULE D IN THAT RESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME:

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON SEPTEMBER 6, 1991 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON NOVEMBER 8, 1991. ***$250.00 FINE*** ***$250.00 PAID ON 3/9/92 INVOICE #91-MS-1332*** i Reporting Source: Firm Current Status: Final Allegations: FIRM ALLEGEDLY FAILED TO REPORT ITS NASDAQ VOLUME, IN VIOLATION OF PART VI, SECTION 5(A) OF SCHEDULE D OF THE NASD'S BY-LAWS. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 05/31/1991

Docket/Case Number: MS-1117-AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/08/1991 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS FINED $250.00. i Disclosure 288 of 359 Reporting Source: Regulator Current Status: Final Allegations: SEE SUMMARY Initiated By: NYSE Date Initiated: 07/01/1991 Docket/Case Number: 91-69

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 07/01/1991 Sanctions Ordered: Censure Monetary/Fine $750,000.00 Other Sanctions Ordered:

Sanction Details: SEE SUMMARY Regulator Statement SHEARSON LEHMAN BROTHERS, INC. (THE "FIRM"), A MEMBER ORGANIZATION , VIOLATED SECTION 220.8 OF REGULATION T OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("REGULATION T") BY FAILING TO PROMPTLY CANCEL PURCHASE TRANSACTIONS IN CUSTOMER CASH ACCOUNTS WHICH WERE ON A 90 DAY RESTRICTION; VIOLATED SECTION 220.8(b) OF REGULATION T BY FAILING TO PROMPTLY CANCEL OR OTHERWISE LIQUIDATE CERTAIN PURCHASE TRANSACTIONS IN CUSTOMER CASH ACCOUNTS OR OBTAIN EXTENSIONS OF TIME WHEN PAYMENT WAS NOT RECEIVED WITHIN THE REQUIRED TIME; VIOLATED SECTION 220.8(c) OF REGULATION T BY FAILING TO RESTRICT FOR 90 DAYS CUSTOMER CASH ACCOUNTS THAT HAD PURCHASED AND SOLD SECURITIES WITHOUT FULL PAYMENT BEING MADE FOR SUCH PURCHASES; VIOLATED FORMER EXCHANGE RULE 431(d)(9) BY PERMITTING CUSTOMERS TO MAKE A PRACTICE OF FREE RIDING; VIOLATED REGULATION 240.10b-10, PROMULGATED PURSUANT TO THE SECURITIES EXCHANGE ACT OF 1934 (THE "SEA"), BY FAILING TO DISCLOSE MARKUPS CHARGED ON CERTAIN PURCHASE TRANSACTIONS ON WRITTEN CONFIRMATIONS TO CUSTOMERS; VIOLATED SEA REGULATIONS 240.15c3-3(m) and (n) BY FAILING TO PURCHASE SECURITIES OF A LIKE KIND AND QUANTITY THAT WERE SOLD FOR CUSTOMERS IN "RETAIL" AND "RECEIVE VERSUS PAYMENT" ACCOUNTS AND WHICH HAD NOT BEEN RECEIVED WITHIN TEN BUSINESS DAYS AFTER THE SETTLEMENT DATE OF THE TRANSACTION, OR OBTAINING AN EXTENSION OF TIME WITHIN WHICH SUCH SECURITIES HAD TO BE PURCHASED; VIOLATED EXCHANGE RULE 342(a) BY FAILING TO REASONABLY DISCHARGE ITS DUTIES AND OBLIGATIONS IN CONNECTION WITH SUPERVISON AND CONTROL OF CERTAIN OF ITS BUSINESS ACTIVITIES BY: PERMITTING A REGISTERED REPRESENTATIVE TO PLACE SECURITIES, WHICH IT WAS DISTRIBUTING TO THE PUBLIC, IN THREE INACTIVE CUSTOMER ACCOUNTS WITHOUT ANY AUTHORIZATION TO DO SO, WHICH SECURITIES WERE THEREAFTER TRANSFERRED TO THIRTEEN OTHER CUSTOMER ACCOUNTS; EFFECTING TRADE CORRECTIONS IN CUSTOMER ACCOUNTS WHICH WERE NOT APPROVED BY A BRANCH OFFICE MANAGER; AND PERMITTI*See FAQ #1* i Reporting Source: Firm Current Status: Final Allegations: THE NYSE INVESTIGATION OF THE SALES PRACTICES AND RELATED ©2021 FINRA. All rights reserved. Report aboutACTIVITIES LEHMAN BROTHERSIN SHEARSON INC. LEHMAN BROTHERS' 55 WATER STREET, NEW 443 YORK, NY OFFICE ALLEGED NUMEROUS SALES PRACTICE VIOLATIONS. www.finra.org/brokercheck User Guidance

Allegations: THE NYSE INVESTIGATION OF THE SALES PRACTICES AND RELATED ACTIVITIES IN SHEARSON LEHMAN BROTHERS' 55 WATER STREET, NEW YORK, NY OFFICE ALLEGED NUMEROUS SALES PRACTICE VIOLATIONS. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 07/01/1991 Docket/Case Number: 91-69

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 07/01/1991 Sanctions Ordered: Censure Monetary/Fine $750,000.00 Other Sanctions Ordered: UNDERTAKING BY FIRM TO REVIEW POLICIES, PROCEDURES AND SYSTEMS OF ITS MARGIN DEPARTMENT TO ENSURE REG T COMPLIANCE. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS ARISING FROM THE EXCHANGE'S INVESTIGATION, SHEARSON CONSENTED TO CERTAIN FINDINGS OF FACT AND TO THE IMPOSITION OF PENALTIES AS OUTLINED ABOVE. i Disclosure 289 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 09/18/1990 Docket/Case Number: MS-991-AWC

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/24/1990 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-991-AWC (A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED SEPTEMBER 18, 1990 AGAINST RESPONDENT MEMBER LEHMAN BROTHERS ALLEGES VIOLATIONS OF PART VI, SECTIONS 2(d) OF SCHEDULE D FOR ENTERING NASDAQ QUOTATIONS CONTAINING EXCESS SPREADS.

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON OCTOBER 31, 1990 AND BY THE BUSINESS CONDUCT COMMITTEE ON DECEMBER 24, 1990. $1,000 FINE. **$1,000.00 PAID ON 3/26/91 INVOICE #91-MS-162*** i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS INC. ENTERED NASDAQ QUOTATIONS ON AUGUST 6, 1991 FOR GAMBRO THAT WERE NOT REASONABLY RELATED TO THE PREVAILING MARKET FOR THOSE SECURITIES (SUCH QUOTATIONS CONTAINED SPREADS WHICH WERE IN EXCESS OF THE MAXIMUM ALLOWABLE SPREAD); IT WAS DETERMINED THAT SHEARSON HAD BEEN CAUTIONED, WITHIN A TWELVE MONTH PERIOD PRIOR TO AUGUST 6TH, 1990 (ON MARCH 23RD, 1990), OF A SIMILAR VIOLATION THAT OCCURRED ON MARCH 5TH, 1990. Initiated By: NASD - NBCC Date Initiated: 01/24/1991 Docket/Case Number: MS-991 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CENSURE AND FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/24/1991 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE TRUTH OF THE ALLEGATIONS OR FINDINGS, SHEARSON AGREED TO ACCEPT THE AWC AND CONSENTED TO A FINE OF $1,000.00. i Disclosure 290 of 359 Reporting Source: Regulator Current Status: Final Allegations: VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 15(A) AND 27(A) OF THE RULES OF FAIR PRACTICE Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/17/1988 Docket/Case Number: C9A880040

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 08/22/1991 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 446 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: DBCC COSTS OF $3,112.50 Regulator Statement [TOP] COMPLAINT NO. PHL-664 FILED 3/17/88 BY DISTRICT NO. 11 AGAINST RESPONDENTS E. F. HUTTON & COMPANY, INC., ALLEN G.GELB, MELVIN ACKERMAN, ALAN WIENER AND WILLIAM E. HUFFMAN ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 15(A) AND 27(A) OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT GELB USED DISCRETIONARY POWER TO EFFECT OPTIONS TRANSACTIONS IN THE ACCOUNTS OF CUSTOMERS WHICH WERE EXCESSIVE IN FREQUENCY AND WHICH WERE EFFECTED WITHOUT HAVING REASONABLE GROUNDS TO BELIEVE THAT THEY WERE SUITABLE; E. F. HUTTON & COMPANY, INC., ACTING THROUGH MELVIN ACKERMAN, FAILED TO ADEQUATELY ENFORCE ITS SUPERVISORY PROCEDURES PERTAINING TO OPTIONS TRANSACTIONS AND ACCOUNTS; E. F. HUTTON & COMPANY, INC., ACTING THROUGH ALAN WIENER, DID NOT TAKE REASONABLE STEPS TO REVIEW THE TRANSACTIONS FOR EXCESSIVE TRADING AND SUITABILITY; AND E. F. HUTTON & COMPANY, INC., ACTING THROUGH WILLIAM E. HUFFMAN, FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF ALLEN G. GELB. DECISION RENDERED 11/30/90, WHEREIN RESPONDENT MEMBER IS CENSURED AND FINED $50,000; FURTHERMORE, RESPONDENTS MEMBER AND GELB ARE ASSESSED COSTS OF $3,112.50, JOINTLY AND SEVERALLY.12/12/90 - APPEALED TO THE BOARD OF GOVERNORS. BOARD OF GOVERNORS DECISION RENDERED 7/23/91, C9A880040 (PHL-664) WHEREIN THE FINDINGS MADE AND SANCTIONS IMPOSED ARE MODIFIED; THEREFORE, RESPONDENT MEMBER IS CENSURED, FINED $5,000 AND ASSESSED DBCC COSTS OF $3,112.50., THE EIGHTH CAUSE OF COMPLAINT REGARDING RESPONDENTS MEMBER AND WIENER'S SUPERVISION OF GELB WAS DISMISSED IN THAT THE BOARD DETERMINED THAT WIENER FOLLOWED FIRM PROCEDURES TO PERFORM HIS MANAGERIAL FUNCTIONS.8/22/91 - DECISION IS FINAL. ***$8,112.50 PAID ON 9/3/91 INVOICE #91-9A-922*** i Reporting Source: Firm Current Status: Final Allegations: NONE SPECIFICALLY FOR THIS ACTION. THE NATIONAL BUSINESS CONDUCT COMMITTEE REDUCED THE FINE IMPOSED ON E F HUTTON & COMPANY FROM $50,000.00 TO $5,000.00 AND DISMISSED FINDINGS AGAINST ALL INDIVIDUALS. THESE MATTERS ORIGINALLY STEMMED FROM A COMPLAINT INITIATED BY DBCC FOR DISTRICT NO. 11, THE DECISION OF WHICH WAS APPEALED. Initiated By: NASD - NBCC

Date Initiated: 07/23/1991 Docket/Case Number: C9A880040 (PHL 664)

Principal Product Type: Futures - Financial Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief REDUCTION IN FINE Sought:

Resolution: Decision Resolution Date: 07/23/1991 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: FINE REDUCED AS SPECIFIED ABOVE. i Disclosure 291 of 359 Reporting Source: Regulator Current Status: Final Allegations: VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 19 AND 27 OF THE RULES OF FAIR PRACTICE. FAILED TO RESPOND TO NASD REQUESTS FOR INFORMATION MADE PURSUANT TO ARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/19/1990 Docket/Case Number: C05910011

Principal Product Type: Mutual Fund(s) Other Product Type(s): GOVERNMENT TRUST DEBT GOVERNMENT Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision & Order of Offer of Settlement

Resolution Date: 06/17/1991 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: $10,000.00 PAID ON 7/31/91 INVOICE #91-05-732 Regulator Statement [TOP] COMPLAINT NO. NEW-803 FILED 11/19/90 BY DISTRICT NO. 5 AGAINST SHEARSON LEHMAN BROTHERS INC.,ET.AL.,ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 19 AND 27 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT LANDRUM EXECUTED 37 UNAUTHORIZED MUTUAL FUND TRANSACTIONS AND ONE UNAUTHORIZED LIQUIDATION OF A CERTIFICATE OF DEPOSIT IN THE ACCOUNTS OF 13 PUBLIC CUSTOMERS; RECOMMENDED AND EXECUTED THE SALE OF VARIOUS MUTUAL FUNDS AND PURCHASE OF OTHER MUTUAL FUNDS WITH SIMILAR INVESTMENT GOALS IN 14 ACCOUNTS OF PUBLIC CUSTOMERS WITHOUT HAVING REASONABLE GROUNDS FOR BELEIVING THAT THESE MUTUAL FUND SWITCHES WERE SUITABLE FOR THE CUSTOMERS; SENT WRITTEN CORRESPONDENCE TO PUBLIC CUSTOMERS WITHOUT OBTAINING PRIOR APPROVAL FROM RESPONDENT MEMBER; PURCHASED MUTUAL FUNDS ON MARGIN IN THE ACCOUNT OF PUBLIC CUSTOMERS WITHOUT HAVING REASONABLE GROUNDS FOR BELEIVING THAT SUCH TRANSACTION WAS SUITABLE IN VIEW OF THEIR FINANCIAL SITUATION, INVESTMENT EXPERIENCE AND INVESTMENT OBJECTIVES; RECOMMENDED AND EXECUTED THE PURCHASE OF A GOVERNMENT TRUST AND A GOVERNMENT FUND IN THE ACCOUNT OF A PUBLIC CUSTOMER, BUT FAILED TO DISCLOSE THE AVAILABILITY OF A BREAKPOINT IF THE CUSTOMER INVESTED $50,000 IN THE GOVERNMENT TRUST; MADE A DEPOSIT IN THE ACCOUNT OF A PUBLIC CUSTOMER WITHOUT THE KNOWLEDGE OR CONSENT OF THE CUSTOMER OR RESPONDENT MEMBER; FAILED TO RESPOND TO NASD REQUESTS FOR INFORMATION MADE PURSUANT TO ARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE. DECISION RENDERED 6/17/91, CASE ID. C05910011 (NEW-803), WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BY RESPONDENTS MEMBER AND HINES WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $10,000 ***$10,000.00 PAID ON 7/31/91 INVOICE #91-05-732*** i Reporting Source: Firm Current Status: Final Allegations: COMPLAINT ALLEGED VIOLATIONS OF NASD'S RULES OF FAIR PRACTICE BY BOTH SHEARSON LEHMAN HUTTON INC. AND W. JACKSON HINES, JR., A SHEARSON BRANCH MANAGER, IN THAT SHEARSON, ACTING THROUGH ©2021 FINRA. All rights reserved. Report aboutHINES, LEHMAN FAILED BROTHERS TO REASONABLY INC. AND PROPERLY SUPERVISE FORMER 449 REPRESENTATIVE AUDREY W. LANDRUM IN CONNECTION WITH THE ACTIVITY OF THIRTEEN CUSTOMERS. www.finra.org/brokercheck User Guidance COMPLAINT ALLEGED VIOLATIONS OF NASD'S RULES OF FAIR PRACTICE BY BOTH SHEARSON LEHMAN HUTTON INC. AND W. JACKSON HINES, JR., A SHEARSON BRANCH MANAGER, IN THAT SHEARSON, ACTING THROUGH HINES, FAILED TO REASONABLY AND PROPERLY SUPERVISE FORMER REPRESENTATIVE AUDREY W. LANDRUM IN CONNECTION WITH THE ACTIVITY OF THIRTEEN CUSTOMERS. Initiated By: NASD - DBCC FOR DISTRICT NO. 5 Date Initiated: 11/19/1990 Docket/Case Number: C05910011 (NEW-803)

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 06/17/1991 Sanctions Ordered: Censure Monetary/Fine $12,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE COMPLAINT, SHEARSON AND MR. HINES CONSENTED TO THE IMPOSITION OF A CENSURE AND A $10,000.00 FINE. MR. HINES WAS CENSURED AND FINED $2,500.00. i Disclosure 292 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/29/1990 Docket/Case Number: NY-8078-AWC

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 05/29/1990 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON MAY 29, 1990, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. NY-8078-AWC (DISTRICT NO. 12) SUBMITTED BY RESPONDENT SHEARSON LEHMAN HUTTON, INC. WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $15,000 (ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE AND SECTION 66 OF THE UNIFORM PRACTICE CODE AND MSRB RULES G-8, G-9 AND G-32 - IN CONTRAVENTION OF THE BOARD OF GOVERNORS FREE-RIDING AND WITHHOLDING INTERPRETATION, RESPONDENT MEMBER SOLD SHARES OF A NEW ISSUE THAT TRADED AT A PREMIUM IN THE IMMEDIATE AFTERMARKET TO RESTRICTED PERSONS; FAILED TO OBTAIN PERTINENT INFORMATION FROM CERTAIN INDIVIDUALS WHO PARTICIPATED IN HOT ISSUES; FAILED TO EFFECT FINAL SETTLEMENT WITHIN THE 90 DAY TIMEFRAME IN FIVE CORPORATE UNDERWRITINGS; DUE TO DEFICIT POSITIONS IN CUSTOMER ACCOUNTS CAUSED BY FAILS TO RECEIVE MORE THAN 30 CALENDAR DAYS OLD, IT WAS DETERMINED THAT RESPONDENT DID NOT PROPERLY EFFECT BUY-IN PROCEDURES OR REQUEST EXTENSIONS OF TIME; OUT OF 588 CUSTOMERS WHO PURCHASED CERTAIN SECURITIES, RESPONDENT FAILED TO DELIVER THE FINAL OFFICIAL STATEMENT TO 555, AND OF THE 33 THAT DID RECEIVE THE FINAL OFFICIAL STATEMENT, EIGHT WERE SENT ONE TO 21 DAYS AFTER SETTLEMENT). ***$15,000.00 PAID ON 10/3/90 INVOICE #90-12-753*** i Reporting Source: Firm Current Status: Final Allegations: THE AWC AGREED TO ACCEPT NASD FINDINGS THAT INVOLVED SHEARSON'S ALLEGED FAILURE TO 1) COMPLY WITH NASD FREE-RIDING AND WITHHOLDING INTERPRETATION IN CONNECTION WITH TWO ©2021 FINRA. All rights reserved. Report aboutUNDERWRITINGS, LEHMAN BROTHERS 2) INC.EFFECT FINAL SETTLEMENT, IN FIVE CORPORATE 451 UNDERWRITINGS, WITH THE SYNDICATE WITHIN NINETY DAYS FOLLOWING SECURITIES DELIVERY TO THE SYNDICATE MEMBER, AND 3) PROPERLY EFFECT, IN EIGHTEEN INSTANCES, BUY-IN PROCEDURES OR REQUEST EXTENSIONS OF TIME IN CONNECTION WITH FAILS TO RECEIVE OVER THIRTY CALENDER DAYS OLD AND 4) PROVE THAT A NUMBER OF CUSTOMERS, IN CONNECTION WITH SEVEN MUNICIPAL UNDERWRITINGS, WERE DELIVERED A COPY OF THE FINAL OFFICIAL STATEMENT, AND TO TIME-DELIVER TO CUSTOMERS A COPY OF THE FINAL OFFICIAL STATEMENT, IN VIOLATION OF MSRB RULES G-8, G-9 AND G-32. www.finra.org/brokercheck User Guidance

THE AWC AGREED TO ACCEPT NASD FINDINGS THAT INVOLVED SHEARSON'S ALLEGED FAILURE TO 1) COMPLY WITH NASD FREE-RIDING AND WITHHOLDING INTERPRETATION IN CONNECTION WITH TWO UNDERWRITINGS, 2) EFFECT FINAL SETTLEMENT, IN FIVE CORPORATE UNDERWRITINGS, WITH THE SYNDICATE WITHIN NINETY DAYS FOLLOWING SECURITIES DELIVERY TO THE SYNDICATE MEMBER, AND 3) PROPERLY EFFECT, IN EIGHTEEN INSTANCES, BUY-IN PROCEDURES OR REQUEST EXTENSIONS OF TIME IN CONNECTION WITH FAILS TO RECEIVE OVER THIRTY CALENDER DAYS OLD AND 4) PROVE THAT A NUMBER OF CUSTOMERS, IN CONNECTION WITH SEVEN MUNICIPAL UNDERWRITINGS, WERE DELIVERED A COPY OF THE FINAL OFFICIAL STATEMENT, AND TO TIME-DELIVER TO CUSTOMERS A COPY OF THE FINAL OFFICIAL STATEMENT, IN VIOLATION OF MSRB RULES G-8, G-9 AND G-32. Initiated By: NASD - NBCC Date Initiated: 02/09/1990 Docket/Case Number: NY-8078-AWC

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED, BUT CERTAIN UNDERWRITINGS Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/29/1990 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: THE AWC AGREED TO ACCEPT, WITHOUT ADMITTING OR DENYING THE TRUTH OF THE ALLEGATIONS, THE NASD'S FINDINGS CONCERNING THE AFOREMENTIONED FAILURE OF THE FIRM IN THE FOUR CITED INSTANCES. THE FIRM CONSENTED TO A CENSURE AND A $15,000.00 FINE. FIRM TO MAINTAIN CONTACT WITH NASD STAFF IN AN EFFORT TO IMPROVE REGULATORY ADHERENCE. i Disclosure 293 of 359 Reporting Source: Regulator Current Status: Final Allegations: AMENDED ORDER OF PROHIBITION WAS ENTERED AUGUST 21, 1990. ORDER OF PROHIBITION WAS AMENDED TO NEGATE ©2021 FINRA. All rights reserved. Report aboutEFFECT LEHMAN OF BROTHERS STATUTORY INC. DISQUALIFICATIONS FROM THE USE OF 452 REGULATION D AT THE FEDERAL LEVEL AND THE LIKE. www.finra.org/brokercheck User Guidance

Allegations: AMENDED ORDER OF PROHIBITION WAS ENTERED AUGUST 21, 1990. ORDER OF PROHIBITION WAS AMENDED TO NEGATE EFFECT OF STATUTORY DISQUALIFICATIONS FROM THE USE OF REGULATION D AT THE FEDERAL LEVEL AND THE LIKE. Initiated By: ILLINOIS SECURITIES DEPARTMENT Date Initiated: 07/19/1990 Docket/Case Number: 8900584 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 08/21/1990 Sanctions Ordered: Monetary/Fine $200.00 Other Sanctions Ordered: Sanction Details: Not Provided Regulator Statement Not Provided i Reporting Source: Firm Current Status: Final Allegations: SHEARSON LEHMAN BROTHERS WAS FOUND TO HAVE VIOLATED SECTIONS 8.E(1)(C) AND 12.A OF THE ILLINOIS ACT WHEN IT FAILED TO ACCOUNT TO A CUSTOMER AS TO THE STATUS OF A DELAYED TRANSACTION DURING THE PERIOD FEBRUARY 15TH, 1989 THROUGH MARCH 1ST, 1989. Initiated By: STATE OF ILLINOIS Date Initiated: 07/19/1990 Docket/Case Number: 8900584

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Prohibition ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 453 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Prohibition Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 07/19/1990 Sanctions Ordered: Monetary/Fine $200.00 Other Sanctions Ordered: Sanction Details: SECURITIES DEPARTMENT OF STATE OF ILLINOIS ENTERED AN ORDER OF PROHIBITION AGAINST FIRM; SUBSEQUENTLY, IT FILED AN AMENDED ORDER OF PROHIBITION AGAINST FIRM PROHIBITING IT FROM THE OFFER AND SALE OF ANY SECURITIES IN ILLINOIS EXCEPT IN COMPLIANCE WITH THE ILLINOIS ACT. FIRM WAS FURTHER ORDERED TO PAY A $200.00 FINE. AMENDED ORDER FURTHER STATED THAT SAID ORDER SHOULD NOT BE CONSTRUED AS AN INJUNCTION ORDER, JUDGMENT OR DECREE WHICH WOULD CAUSE ANY STATUTORY DISQUALIFICATION OF FIRM OR ANY OF IT AFFILIATES IN ILLINOIS. SPECIFICALLY, THE ORDER IS NOT MEANT TO TRIGGER THE STATUTORY DISQUALIFICATIONS FROM THE USE OF REGULATION D AT THE FEDERAL LEVEL OR ANY DISQUALIFICATION FOR RESALE OF SECURITIES AND/OR DISQUALIFICATION FROM RELIANCE UPON ILLINOIS REV. STAT. CH 121 1/2, SEC.3 CAUSED BY THIS ORDER IS WAIVED. i Disclosure 294 of 359 Reporting Source: Regulator Current Status: Final Allegations: VIOLATIONS OF VARIOUS NYSE AND SEC RULES AND REGULATIONS WITH RESPECT TO THE SALE OF STOCK AND EXECUTION OF PURCHASE ORDERS ON THE NYSE. Initiated By: NYSE Date Initiated: 07/03/1990 Docket/Case Number: 90-126

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 07/03/1990 Sanctions Ordered: Censure Monetary/Fine $500,000.00 Other Sanctions Ordered: Sanction Details: SEE SUMMARY Regulator Statement SHEARSON LEHMAN BROTHERS INC., NOW KNOWN AS SHEARSON LEHMAN HUTTON INC., A MEMBER ORGANIZATION, ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE AND/OR ENGAGED IN ACTS DETRIMENTAL TO THE INTEREST OR WELFARE OF THE EXCHANGE AS A RESULT OF ITS ACTIVTIES IN CONNECTION WITH THE SALE OF HUTTON STOCK; VIOLATED EXCHANGE RULE 410(b) THAT IT DIRECTED ORDERS FOR THE PURCHASE OF STOCK TO BE TRANSMITTED TO THE FLOOR OF THE EXCHANGE WHICH ORDERS SHOULD HAVE BEEN EXECUTED PURSUANT TO SECTION 11(a)(1)(G) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND RULE 11a1-1(T) PROMULGATED THEREUNDER, BUT WERE NOT IDENTIFIED IN A MANNER WHICH ENABLED THE EXECUTING MEMBER TO DISCLOSE TO OTHER MEMBERS THAT THE ORDERS WERE SUBJECT TO THE AFOREMENTIONED PROVISIONS OF THE FEDERAL REGULATIONS; CAUSED AND/OR ALLOWED ITS EXCHANGE MEMBER(S) TO VIOLATE SECTION 11(a)(1)(G) OF THE EXCHANGE AND RULE 11a1-1(T)(a) PROMULGATED THEREUNDER, IN THAT IT CAUSED AND/OR ALLOWED PURCHASE ORDERS FOR ITS PROPRIETARY ACCOUNT TO BE COMMUNICATED TO OTHERS PARTICIPATING IN EFFECTING THE ORDERS WITHOUT DISCLOSING THAT THE ORDERS WERE FOR ITS PROPRIETARY ACCOUNT; CAUSED AND/OR ALLOWED ITS EXCHANGE MEMBER(S) TO VIOLATE SECTION 11(a)(1)(G) OF THE EXCHANGE ACT AND RULE 11a1-1(T)(a) PROMULGATED THEREUNDER, IN THAT IT CAUSED AND/OR ALLOWED PURCHASE ORDERS IN CERTAIN COMMON STOCK FOR ITS PROPRIETARY ACCOUNT TO BE EFFECTED ON THE FLOOR OF THE EXCHANGE BY SUCH EXCHANGE MEMBER(S), WHICH ORDERS WERE NOT IDENTIFIED TO THE OTHER MEMBERS ON THE FLOOR BEFORE EXECUTION AS ORDERS FOR THE MEMBER ORGANIZATION'S ©2021 FINRA. All rights reserved. Report aboutACCOUNT; LEHMAN BROTHERSAND CAUSED INC. AND/OR ALLOWED ITS EXCHANGE MEMBER(S) TO 455 VIOLATE SECTION 11(a)(1)(G) OF THE EXCHANGE ACT AND RULE 11a1-1(T)(a) PROMULGATED THEREUNDER, IN THAT IT CAUSED AND/OR ALLOWED PURCHASE ORDERS IN CERTAIN COMMON STOCK FOR ITS PROPRIETARY ACCOUNT TO BE EFFECTED ON THE FLOOR OF THE EXCHANGE BY SUCH EXCHANGE MEMBER(S), WHICH ORDERS, WHEN E*See FAQ #1* SHEARSON LEHMAN BROTHERS INC., NOW KNOWN AS SHEARSON LEHMAN HUTTON INC., A MEMBER ORGANIZATION, ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE AND/OR ENGAGED IN ACTS DETRIMENTAL TO THE INTEREST OR WELFARE OF THE EXCHANGE AS A RESULT OF ITS ACTIVTIES IN CONNECTION WITH THE SALE OF HUTTON STOCK; VIOLATED EXCHANGE RULE 410(b) THAT IT DIRECTED ORDERS FOR THE PURCHASE OF STOCK TO BE TRANSMITTED TO THE FLOOR OF THE EXCHANGE WHICH ORDERS SHOULD HAVE BEEN EXECUTED PURSUANT TO SECTION 11(a)(1)(G) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND RULE 11a1-1(T) PROMULGATED THEREUNDER, BUT WERE NOT IDENTIFIED IN A MANNER WHICH ENABLED THE EXECUTING MEMBER TO DISCLOSE TO OTHER MEMBERS THAT THE ORDERS WERE SUBJECT TO THE AFOREMENTIONED PROVISIONS OF THE FEDERAL REGULATIONS; CAUSED AND/OR ALLOWED ITS EXCHANGE MEMBER(S) TO VIOLATE SECTION 11(a)(1)(G) OF THE EXCHANGE AND RULE 11a1-1(T)(a) PROMULGATED THEREUNDER, IN THAT IT CAUSED AND/OR ALLOWED PURCHASE ORDERS FOR ITS PROPRIETARY ACCOUNT TO BE COMMUNICATED TO OTHERS PARTICIPATING IN EFFECTING THE ORDERS WITHOUT DISCLOSING THAT THE ORDERS WERE FOR ITS PROPRIETARY ACCOUNT; CAUSED AND/OR ALLOWED ITS EXCHANGE MEMBER(S) TO VIOLATE SECTION 11(a)(1)(G) OF THE EXCHANGE ACT AND RULE 11a1-1(T)(a) PROMULGATED THEREUNDER, IN THAT IT CAUSED AND/OR ALLOWED PURCHASE ORDERS IN CERTAIN COMMON STOCK FOR ITS PROPRIETARY ACCOUNT TO BE www.finra.org/brokercheck EFFECTED User Guidance ON THE FLOOR OF THE EXCHANGE BY SUCH EXCHANGE MEMBER(S), WHICH ORDERS WERE NOT IDENTIFIED TO THE OTHER MEMBERS ON THE FLOOR BEFORE EXECUTION AS ORDERS FOR THE MEMBER ORGANIZATION'S ACCOUNT; AND CAUSED AND/OR ALLOWED ITS EXCHANGE MEMBER(S) TO VIOLATE SECTION 11(a)(1)(G) OF THE EXCHANGE ACT AND RULE 11a1-1(T)(a) PROMULGATED THEREUNDER, IN THAT IT CAUSED AND/OR ALLOWED PURCHASE ORDERS IN CERTAIN COMMON STOCK FOR ITS PROPRIETARY ACCOUNT TO BE EFFECTED ON THE FLOOR OF THE EXCHANGE BY SUCH EXCHANGE MEMBER(S), WHICH ORDERS, WHEN E*See FAQ #1* i Reporting Source: Firm Current Status: Final Allegations: THE NYSE FOUND THAT SHEARSON LEHMAN BROTHERS 1) ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPALS OF TRADE AND/OR ENGAGED IN ACTS DETRIMENTAL TO THE INTEREST OF THE EXCHANGE; 2) VIOLATED RULE 410(B); AND 3) CAUSED AND/OR ALLOWED ITS EXCHANGE MEMBER(S) TO VIOLATE SECTION 11(A)(1)(G) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 11A1-1(T)(A). Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 05/07/1990 Docket/Case Number: 90-126

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 07/03/1990 Sanctions Ordered: Censure Monetary/Fine $500,000.00 Other Sanctions Ordered: UNDERTAKING THAT FIRM HIRE SPECIAL COUNSEL. Sanction Details: THE NYSE IMPOSED A PENALTY OF CENSURE, A FINE OF $500,000.00 AND AN UNDERTAKING THAT THE FIRM HIRE SPECIAL COUNSEL. i Disclosure 295 of 359

Reporting Source: Regulator Current Status: Final Allegations: Initiated By: WISCONSIN Date Initiated: 06/30/1987 Docket/Case Number: Unknown URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 06/30/1987 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Regulator Statement #6/12/90# SEC LITIGATION, ACTIONS AND PROCEEDINGS BULLETIN FOR THE QUARTER ENDING 6/30/87 (VOLUME 53 NO. 3 PAGE 298) DISCLOSES: SHEARSON LEHMAN HUTTON INC. FAILED TO EXECUTE A SELL ORDER. SHEARSON LEHMAN HUTTON INC. WAS CENSURED. i Reporting Source: Firm Current Status: Final Allegations: FAIL TO EXECUTE A SELL ORDER. Initiated By: STATE OF WISCONSIN Date Initiated: 06/30/1987 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED.

Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 06/30/1987 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: SHEARSON LEHMAN HUTTON WAS CENSURED BY THE STATE. i Disclosure 296 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: ARKANSAS Date Initiated: 02/04/1988 Docket/Case Number: Unknown URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 02/04/1988 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 6/4/90: PER S.E.C. LITIGATION, ACTIONS AND PROCEEDINGS BULLETIN (VOL. 54, BULL NO. 1, PG 23), RESPONDENT MEMBER SHEARSON LEHMAN BROTHERS INC. IS FINED $10,000.00 BY THE ARKANSAS SECURITIES ©2021 FINRA. All rights reserved. Report aboutCOMMISSION. LEHMAN BROTHERS THE ACTION INC. WAS TAKEN BASED ON COMMISSION'S FINDING 458 FO THE SALE OF UNREGISTERED & NON-EXEMPT SECURITIES AND FAILURE TO REASONABLY SUPERVISE. (LKA: NEW YORK, NY) www.finra.org/brokercheck User Guidance

6/4/90: PER S.E.C. LITIGATION, ACTIONS AND PROCEEDINGS BULLETIN (VOL. 54, BULL NO. 1, PG 23), RESPONDENT MEMBER SHEARSON LEHMAN BROTHERS INC. IS FINED $10,000.00 BY THE ARKANSAS SECURITIES COMMISSION. THE ACTION WAS TAKEN BASED ON COMMISSION'S FINDING FO THE SALE OF UNREGISTERED & NON-EXEMPT SECURITIES AND FAILURE TO REASONABLY SUPERVISE. (LKA: NEW YORK, NY) i Reporting Source: Firm Current Status: Final Allegations: ALLEGATIONS CONCERNED SHEARSON LEHMAN BROTHERS SUPERVISORY ROLE IN RELATION TO THE ALLEGED MISCONDUCT OF A FORMER REGISTERED REPRESENTATIVE OF SHEARSON LEHMAN BROTHERS' FORT SMITH, ARKANSAS OFFICE, AND A BRANCH MANAGER. Initiated By: STATE OF ARKANSAS Date Initiated: 02/04/1988 Docket/Case Number: NOT GIVEN

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Settled Resolution Date: 02/04/1988 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: THE ARKANSAS SECURITIES DEPARTMENT ISSUED A LETTER OF CAUTION TO SHEARSON LEHMAN BROTHERS INC. IN CONNECTION WITH THE DEPARTMENT'S EXAMINATION OF THE FIRM'S SUPERVISORY ROLE IN RELATION TO THE ALLEGED MISCONDUCT OF A FORMER REGISTERED REPRESENTATIVE OF THE FIRM'S FORT SMITH, ARKANSAS OFFICE, AND A BRANCH MANAGER. FIRM AGREED TO PAY A FINE OF $10,000.00 IN CONNECTION WITH THE DEPARTMENT'S EXAMINATION. i Disclosure 297 of 359 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 459 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 27 OF THE ASSOCIATIONS'S RULES OF FAIR PRACTICE WITH RESPECT TO SAXP AND LATTUGA IN THAT THEY FAILED TO ESTABLISH, MAINTAIN AND REASONABLY ENFORCE SUPERVISORY PROCEDURES TO ASSURE COMPLIANCE WITH APPLICABLE SECURITIES RULES AND REGULATIONS. CAUSE TEN (10) ALLEGES VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 27 OF THE ASSOCIATIONS'S RULES OF FAIR PRACTICE WITH RESPECT TO SAXP AND LATTUGA IN THAT THEY FAILED TO ESTABLISH, MAINTAIN AND REASONABLY ENFORCE SUPERVISORY PROCEDURES TO ASSURE COMPLIANCE WITH APPLICABLE SECURITIES RULES AND REGULATIONS. CAUSE ELEVEN (11) ALLEGES VIOLATIONS OF SCHEDULE C OF THE ASSOCIATION'S RULES OF FAIR PRACTICE WITH RESPECT TO SAXP IN THAT DURING THE PERIOD FROM 1984 TO THE PRESENT, SAXP FAILED TO HAVE LATTUGA QUALIFIED AND REGISTERED AS A GENERAL SECURITIES PRINCIPAL NOTWITHSTANDING THAT LATTUGA WAS A SENIOR VICE PRESIDENT OF SAXP AND WAS ACTIVELY ENGAGED IN THE SUPERVISION AND TRAINING OF ASSOCIATED PERSONS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/16/1988 Docket/Case Number: MS-659

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 10/28/1988 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Suspension Other Sanctions Ordered: Sanction Details: LATTUGA IS CENSURED AND FINED $7,500; ANDNORTON IS CENSURED, FINED $10,000 AND SUSPENDED FROM ASSOCIATION WITH ANY MEMBER IN ANY CAPACITY FOR THIRY (30) CALENDAR DAYS; SAXP IS CENSURED, FINED $25,000 AND SUSPENDED AS A MARKET MARKER IN BPAO, BOCB, MDIN, NBSC, POLY, TMBR AND TELE FOR TEN (10) BUSINESS DAYS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 460 LATTUGA IS CENSURED AND FINED $7,500; ANDNORTON IS CENSURED, www.finra.org/brokercheck FINED $10,000 AND SUSPENDED FROM ASSOCIATION WITH ANY MEMBER User Guidance IN ANY CAPACITY FOR THIRY (30) CALENDAR DAYS; SAXP IS CENSURED, FINED $25,000 AND SUSPENDED AS A MARKET MARKER IN BPAO, BOCB, MDIN, NBSC, POLY, TMBR AND TELE FOR TEN (10) BUSINESS DAYS. Regulator Statement [TOP] MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-659: THIS COMPLAINT WAS FILED ON 2/16/88 BY THE MARKET SURVEILLANCE COMMITTEE (MSC) NAMING AS RESPONDENTS SHEARSON LEHMAN HUTTON INC. (SAXP), ET AL. CAUSE TEN (10) ALLEGES VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 27 OF THE ASSOCIATIONS'S RULES OF FAIR PRACTICE WITH RESPECT TO SAXP AND LATTUGA IN THAT THEY FAILED TO ESTABLISH, MAINTAIN AND REASONABLY ENFORCE SUPERVISORY PROCEDURES TO ASSURE COMPLIANCE WITH APPLICABLE SECURITIES RULES AND REGULATIONS. CAUSE ELEVEN (11) ALLEGES VIOLATIONS OF SCHEDULE C OF THE ASSOCIATION'S RULES OF FAIR PRACTICE WITH RESPECT TO SAXP IN THAT DURING THE PERIOD FROM 1984 TO THE PRESENT, SAXP FAILED TO HAVE LATTUGA QUALIFIED AND REGISTERED AS A GENERAL SECURITIES PRINCIPAL NOTWITHSTANDING THAT LATTUGA WAS A SENIOR VICE PRESIDENT OF SAXP AND WAS ACTIVELY ENGAGED IN THE SUPERVISION AND TRAINING OF ASSOCIATED PERSONS. RESPONDENTS SAXP, LATTUGA AND NORTON SUBMITTED AN OFFER OF SETTLEMENT ON 6/29/88 WHICH WAS ACCEPTED BY THE MSC ON 6/30/88 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON 10/28/88. THE COMMITTEE DETERMINED THAT SAXP VIOLATED ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF FAIR PRACTICE AS ALLEGED IN THE TENTH CAUSE OF COMPLAINT AND VIOLATED SCHEDULE C OF THE BY-LAWS AS ALLEGED IN THE ELEVENTH CAUSE OF COMPLAINT. BASED ON THE COMMITTEE'S ACCEPTANCE OF THE RESPONDENTS' OFFER OF SETTLEMENT, THE COMMITTEE IMPOSED THE FOLLOWING SANCTIONS; LATTUGA IS CENSURED AND FINED $7,500; ANDNORTON IS CENSURED, FINED $10,000 AND SUSPENDED FROM ASSOCIATION WITH ANY MEMBER IN ANY CAPACITY FOR THIRY (30) CALENDAR DAYS; SAXP IS CENSURED, FINED $25,000 AND SUSPENDED AS A MARKET MARKER IN BPAO, BOCB, MDIN, NBSC, POLY, TMBR AND TELE FOR TEN (10) BUSINESS DAYS.

i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON 1) FAILED TO ESTABLISH, MAINTAIN AND ENFORCE PROCEDURES DESIGNED TO DETER AND DETECT THE REPORTING OF FICTITIOUS TRADES TO THE NASDAQ SYSTEM; AND 2) FAILED TO REGISTER AN INDIVIDUAL WHO HAD SUBSTANTIAL SUPERVISORY RESPONSIBILITIES AS A GENERAL SECURITIES PRINCIPAL. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE

Date Initiated: 02/16/1988 Docket/Case Number: MS-659

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE AND SUSPENSION AS A MARKET MAKER FOR TEN BUSINESS DAYS IN Sought: SEVEN NASDAQ NATIONAL MARKET SYSTEM SECURITIES.

Resolution: Consent Resolution Date: 11/30/1988 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Suspension Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE NASD'S ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A PENALTY OF $25,000.00 FINE AND A SUSPENSION AS A MARKET MAKER FOR TEN BUSINESS DAYS IN SEVEN NASDAQ NATIONAL MARKET SYSTEM SECURITIES. IN ADDITION, FIRM AGREED TO ADOPT SPECIFIC SUPERVISORY PROCEDURES RELATING TO THE CLOSE OF THE MARKET AND RELATED ACTIVITY AND TO PERIODICALLY REVIEW TRADE REPORTS TO DETECT THIS CONDUCT. i Disclosure 298 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/19/1990 Docket/Case Number: NY-8071-AWC

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/19/1990 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON MARCH 19, 1990, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. NY-8071-AWC (DISTRICT NO. 12) SUBMITTED BY RESPONDENT SHEARSON LEHMAN HUTTON INC. WAS ACCEPTED; THEREFORE, THE FIRM IS CENSURED AND FINED $25,000.00 (ARTICLE III, SECTIONS 1 AND 35 OF THE RULES OF FAIR PRACTICE - MADE USE OF ADVERTISMENTS OR PIECES OF SALES LITERATURE IN CONTRAVENTION OF CERTAIN NASD AND SEC RULES). ***$25,000.00 PAID ON 5/29/90 INVOICE #90-12-379*** i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF NASD AND SEC RULES CONCERNING THE USE OF TWENTY TWO ADVERTISEMENTS OR PIECES OF SALES LITERATURE BY SHEARSON LEHMAN HUTTON. Initiated By: NASD - DBCC FOR DISTRICT NO. 12 Date Initiated: 03/19/1990 Docket/Case Number: NY-8071-AWC

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/19/1990 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FIRM CONSENTED TO A CENSURE AND A $25,000.00 FINE FOR FINDINGS REGARDING COMMUNICATIONS WITH THE PUBLIC AND RELATED FILING REQUIREMENTS AND REVIEW PROCEDURES. i Disclosure 299 of 359 Reporting Source: Regulator Current Status: Final Allegations: RESPONDENT DEALER PERMITTED EMPLOYEE TO SUPERVISE WITHOUT PROPER REGISTRATION RESPONDENT EMPLOYED PERSONS CLASSIFIED AS PROSPECTING CLERKS WHOSE PURPOSE AND ASSIGNMENTS WERE TO ASSIST A PARTICULAR REGISTERED REPRESENTATIVE BY STAFFING HIS CORPORATION AND WORKING UNDER HIS SUPERVISION. THE REGISTERED REPRESENTATIVE HAD NOT TAKEN SERIES 8 EXAM REQUIRED BEFORE SUPERVISION. NOTICE OF HEARING INCLUDED A FAILURE TO SUPERVISE COUNT RELATING TO TO UNSUITABILITY OF CERTAIN INVESTMENTS IN A PARTICULAR ACCOUNT HANDLED BY SAME REGISTERED REPRESENTATIVE REFERRED TO ABOVE. Initiated By: ILLINOIS SECURITIES DEPARTMENT Date Initiated: 01/18/1991 Docket/Case Number: 9000075 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 01/18/1991 Sanctions Ordered: Monetary/Fine $4,000.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 464 Bar www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $4,000.00 Bar Other Sanctions Ordered: Sanction Details: CONSENT ORDER OF PROHIBITION ENTER 1/18/91 SUBSEQUENT TO ENTRY OF STIPULATION AND CONSENT TO ENTER ORDER OF PROHIBITION. RESPONDENT ADMITTED CERTAIN FACTS, NEITHER ADMITTED OR DENIED OTHERS. ORDER INCLUDES PAYMENT OF 4,000 FINE. Regulator Statement Not Provided i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON INC. 1) PERMITTED AN EMPLOYEE TO SUPERVISE WITHOUT PROPER REGISTRATION AND 2) FAILED TO SUPERVISE THE SECURITIES ACTIVITIES OF ITS REPRESENTATIVE. Initiated By: STATE OF ILLINOIS Date Initiated: 03/23/1990 Docket/Case Number: 90-00075

Principal Product Type: Other Other Product Type(s): SECURITIES Principal Sanction(s)/Relief Prohibition Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 01/14/1991 Sanctions Ordered: Monetary/Fine $4,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS MADE BY THE STATE, SHEARSON CONSENTED TO THE ENTRY OF AN ORDER PROHIBITING IT FROM OFFERING FOR SALE OR SELLING ANY SECURITIES IN ILLINOIS OR TO ILLINOIS RESIDENTS OR IN ANY WAY ENGAGE IN THE SECURITIES BUSINESS OTHER THAN IN COMPLIANCE WITH THE ©2021 FINRA. All rights reserved. Report aboutAPPLICABLE LEHMAN BROTHERS PROVISIONS INC. AND REGULATIONS OF ILLINOIS' SECURITIES 465 LAW. SHEARSON FURTHER CONSENTED TO THE PAYMENT OF A $4,000.00 FINE. www.finra.org/brokercheck WITHOUT ADMITTING OR DENYING THE ALLEGATIONS MADE BY THE User Guidance STATE, SHEARSON CONSENTED TO THE ENTRY OF AN ORDER PROHIBITING IT FROM OFFERING FOR SALE OR SELLING ANY SECURITIES IN ILLINOIS OR TO ILLINOIS RESIDENTS OR IN ANY WAY ENGAGE IN THE SECURITIES BUSINESS OTHER THAN IN COMPLIANCE WITH THE APPLICABLE PROVISIONS AND REGULATIONS OF ILLINOIS' SECURITIES LAW. SHEARSON FURTHER CONSENTED TO THE PAYMENT OF A $4,000.00 FINE. i Disclosure 300 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: CHICAGO BOARD OF OPTION EXCHANGE Date Initiated: 12/20/1989 Docket/Case Number: 89-0125

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/06/1990 Sanctions Ordered: Censure Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement FORM BD FILED BY BD# 10890 WITH JDS 10135-09990 DISCLOSED ON 12/20/89, IN CASE NO. 89-0125, THE BUSINESS CONDUCT COMMITTEE OF THE CHICAGO BOARD OPTIONS EXCHANGE ("CBOE") INITIATED CHARGES AGAINST SHEARSON LEHMAN HUTTON INC. ("SLH"). THE CHARGES AROSE FROM THE CBOE'S MOST RECENT AUDIT OF THE FIRM AND ALLEGE THAT: (1) THREE SLH OFFICES WITH MORE THAN THREE REGISTERED REPRESENTATIVES TRANSACTING AN OPTIONS BUSINESS WITH THE PUBLIC DID NOT HAVE A BRANCH MANAGER ON THE PREMISES WHO WAS A REGISTERED OPTIONS PRINCIPAL; AND (2) 19 CUSTOMER OPTIONS COMPLAINTS WERE NOT RECORDED AS OPTIONS-RELATED. *************************************************************** ©2021 FINRA. All rights reserved. Report about#4/20/90 LEHMAN FORM BROTHERS U6 (8059-10190) INC. DISCLOSES; THIS CASE WAS RESOLVED 466 BY AN OFFER OF SETTLEMENT WHEREBY SLH DID NOT ADMIT OR DENY THAT CBOE RULES HAD BEEN VIOLATED. SLH, AN EXCHANGE MEMBER ORGANIZATION, FAILED TO RECORD AT LEAST 19 OPTIONS- RELATED CUSTOMER COMPLAINTS ON ITS CENTRAL OPTION COMPLAINT FILE. AT LEAST THREE BRANCH OFFICES OF SLH, WHICH HAD MORE THAN THREE REGISTERED REPRESENTATIVES TRANSACTED AN OPTIONS BUSINESS WITH THE PUBLIC WHEN THE BRANCH OFFICE MANAGER OF EACH OFFICE WAS NOT QUALIFIED OR REGISTERED WITH THE EXCHANGE AS A REGISTERED OPTIONS PRINCIPAL. ******SANCTION: A CENSURE AND $2,500 FINE. DOCKET/CASE NO. 89-0125, DATED 3/6/90. FORM BD FILED BY BD# 10890 WITH JDS 10135-09990 DISCLOSED ON 12/20/89, IN CASE NO. 89-0125, THE BUSINESS CONDUCT COMMITTEE OF THE CHICAGO BOARD OPTIONS EXCHANGE ("CBOE") INITIATED CHARGES AGAINST SHEARSON LEHMAN HUTTON INC. ("SLH"). THE CHARGES AROSE FROM THE CBOE'S MOST RECENT AUDIT OF THE FIRM AND ALLEGE THAT: (1) THREE SLH OFFICES WITH MORE THAN THREE REGISTERED REPRESENTATIVES TRANSACTING AN OPTIONS BUSINESS WITH THE www.finra.org/brokercheck PUBLIC User Guidance DID NOT HAVE A BRANCH MANAGER ON THE PREMISES WHO WAS A REGISTERED OPTIONS PRINCIPAL; AND (2) 19 CUSTOMER OPTIONS COMPLAINTS WERE NOT RECORDED AS OPTIONS-RELATED. *************************************************************** #4/20/90 FORM U6 (8059-10190) DISCLOSES; THIS CASE WAS RESOLVED BY AN OFFER OF SETTLEMENT WHEREBY SLH DID NOT ADMIT OR DENY THAT CBOE RULES HAD BEEN VIOLATED. SLH, AN EXCHANGE MEMBER ORGANIZATION, FAILED TO RECORD AT LEAST 19 OPTIONS- RELATED CUSTOMER COMPLAINTS ON ITS CENTRAL OPTION COMPLAINT FILE. AT LEAST THREE BRANCH OFFICES OF SLH, WHICH HAD MORE THAN THREE REGISTERED REPRESENTATIVES TRANSACTED AN OPTIONS BUSINESS WITH THE PUBLIC WHEN THE BRANCH OFFICE MANAGER OF EACH OFFICE WAS NOT QUALIFIED OR REGISTERED WITH THE EXCHANGE AS A REGISTERED OPTIONS PRINCIPAL. ******SANCTION: A CENSURE AND $2,500 FINE. DOCKET/CASE NO. 89-0125, DATED 3/6/90. i Reporting Source: Firm Current Status: Final Allegations: STATEMENT OF CHARGES BY CBOE ALLEGED 1) THAT THREE SHEARSON LEHMAN HUTTON OFFICES WITH MORE THAN THREE REPRESENTATIVES TRANSACTING AN OPTIONS BUSINESS WITH THE PUBLIC DID NOT HAVE A BRANCH MANAGER ON THE PREMISES WHO WAS A REGISTERED OPTIONS PRINCIPAL; AND 2) NINETEEN CUSTOMER OPTIONS COMPLAINTS WERE NOT RECORDED AS OPTIONS-RELATED. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 12/20/1989 Docket/Case Number: 89-0125

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 03/06/1990 Sanctions Ordered: Censure Monetary/Fine $2,500.00

Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE CHARGES, THE FIRM CONSENTED TO A PENALTY OF A CENSURE AND A $2,500.00 FINE. i Disclosure 301 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: IOWA Date Initiated: 09/13/1989 Docket/Case Number: C89-10-088 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/13/1989 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 10/14/89-FORM U6 (8056-26989) DISCLOSES: SHEARSON CONSENTED TO AN ORDER IN WHICH THE SUPERINTENDENT OF SECURITIES REQUIRED THEM TO PAY A $500.00 FINE. THE SUPERINTENDENT ALLEGED THAT SHEARSONS' AGENT SOLD AN UNREGISTERED SECURITY TO AT LEAST 14 RESIDENTS. THE SUPERINTENDENT ALSO ALLEGED THAT SHEARSON HAD FAILED TO PROPERLY SUPERVISE ITS' AGENTS. SHEARSON CONSENTED TO THE ORDER WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. DOCKET/CASE NO. C89-10-088, DATED SEPTEMBER 13, 1989. i ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 468 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON SOLD SHARES OF ADT PLC TO AT LEAST FOURTEEN IOWA RESIDENTS AT A TIME WHEN THE SECURITY WAS NOT QUALIFIED FOR SALE IN THE STATE. Initiated By: STATE OF IOWA Date Initiated: 07/17/1989 Docket/Case Number: C89-10-088

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 07/17/1989 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: THE FIRM CONSENTED TO A FINE OF $500.00. i Disclosure 302 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: WISCONSIN Date Initiated: 06/28/1989 Docket/Case Number: 89029(L) URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 469 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 06/28/1989 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Regulator Statement 9-16-89 FORM U6 (8193-24189) DISCLOSES: ON 6/28/89, SHEARSON LEHMAN HUTTON INC. CONSENTED TO THE ISSUANCE OF AN ORDER OF CENSURE BY THE COMMISSIONER OF SECURITIES, STATE OF WISCONSIN FOR ITS FAILURE TO EXECUTE A SELL ORDER PLACED BY A SECURITIES CUSTOMER IN WISCONSIN WHICH CONSTITUTES A VIOLATION BY SHEARSON OF NASD RULES OF FAIR PRACTICE ARTICLE III, SECTION 1, AND THEREFORE A GROUND PURSUANT TO SECTION 4.06(q), WIS. ADM. CODE AND SEC. 551.34(1)(g), WIS. STATS., FOR THE CENSURE OF SHEARSON LEHMAN HUTTON INC. DOCKET/CASE NO. 89029(L), DATED 6/28/89. (COPY OF STIPULATION FOR ORDER OF CENSURE ATTACHED). i Reporting Source: Firm Current Status: Final Allegations: SHEARSON LEHMAN HUTTON ALLEGEDLY FAILED TO EXECUTE A SELL ORDER PLACED BY A CUSTOMER ON OCTOBER 21ST, 1987, WHICH ORDER WAS NOT EXECUTED UNTIL OCTOBER 26TH, 1987, THREE BUSINESS DAYS LATER. THE FAILURE TO EXECUTE THE SELL ORDER WAS DEEMED BY THE WISCONSIN SECURITIES COMMISSIONER TO BE A VIOLATION BY THE FIRM OF THE NASD RULES OF FAIR PRACTICE, AND THEREFORE A GROUND, PURSUANT TO WISCONSIN STATUTE, FOR THE CENSURE OF THE FIRM. Initiated By: STATE OF WISCONSIN Date Initiated: 06/26/1989 Docket/Case Number: X-89029(L)

Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Stipulation and Consent Resolution Date: 06/26/1989 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED BY THE STATE FOR THE ALLEGED VIOLATION. i Disclosure 303 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/28/1989 Docket/Case Number: KC-455

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 06/01/1990 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT NO. KC-455 FILED JULY 28, 1989 BY DISTRICT NO. 4 AGAINST RESPONDENTS SHEARSON LEHMAN HUTTON INC., JOSEPH A. DEL ©2021 FINRA. All rights reserved. Report aboutDUCA, LEHMAN THOMAS BROTHERS E. HOMMEL INC. AND T. CLARK OCTIGAN ALLEGING 471 VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT OCTIGAN FAILED TO PROPERLY SUPERVISE AN ASSOCIATED PERSON; AND RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS HOMMEL AND DEL DUCA FAILED TO RESPOND TO THE ASSOCIATION'S NUMEROUS REQUESTS FOR INFORMATION MADE PURSUANT TO ARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE. DECISION RENDERED JUNE 1, 1990, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BY RESPONDENTS SHEARSON LEHMAN HUTTON, INC., DEL DUCA, HOMMEL AND OCTIGAN WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER AND RESPONDENT OCTIGAN ARE CENSURED AND FINED $10,000, JOINTLY AND SEVERALLY; RESPONDENT MEMBER IS FINED AN ADDITIONAL $10,000; RESPONDENT OCTIGAN IS REQUIRED TO WORK IN RESPONDENT MEMBER'S NEW YORK COMPLIANCE DEPARTMENT FOR A PERIOD OF TWO WEEKS AND WRITE A WRITTEN REPORT ON HIS ACTIVITIES AND SUBMIT TO THE COMMITTEE; AND RESPONDENT HOMMEL IS ISSUED A LETTER OF CAUTION. THE ALLEGATIONS OF HE SECOND CAUSE OF COMPLAINT WITH RESPECT TO RESPONDENT DEL DUCA WERE DISMISSE D IN THAT THE COMMITTEE DETERMINED THAT RESPONDENT DEL DUCA DELEGATED THE NASD 'S LETTER REQUESTING INFORMATION TO HIS MEMBER FIRM'S LEGAL DEPARTMENT, THEREF E ENDING ANY RESPONSIBILITY ON HIS PART TO RESPOND TO NASD REQUESTS FOR INFORM ATION. www.finra.org/brokercheck User Guidance COMPLAINT NO. KC-455 FILED JULY 28, 1989 BY DISTRICT NO. 4 AGAINST RESPONDENTS SHEARSON LEHMAN HUTTON INC., JOSEPH A. DEL DUCA, THOMAS E. HOMMEL AND T. CLARK OCTIGAN ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT OCTIGAN FAILED TO PROPERLY SUPERVISE AN ASSOCIATED PERSON; AND RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS HOMMEL AND DEL DUCA FAILED TO RESPOND TO THE ASSOCIATION'S NUMEROUS REQUESTS FOR INFORMATION MADE PURSUANT TO ARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE. DECISION RENDERED JUNE 1, 1990, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BY RESPONDENTS SHEARSON LEHMAN HUTTON, INC., DEL DUCA, HOMMEL AND OCTIGAN WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER AND RESPONDENT OCTIGAN ARE CENSURED AND FINED $10,000, JOINTLY AND SEVERALLY; RESPONDENT MEMBER IS FINED AN ADDITIONAL $10,000; RESPONDENT OCTIGAN IS REQUIRED TO WORK IN RESPONDENT MEMBER'S NEW YORK COMPLIANCE DEPARTMENT FOR A PERIOD OF TWO WEEKS AND WRITE A WRITTEN REPORT ON HIS ACTIVITIES AND SUBMIT TO THE COMMITTEE; AND RESPONDENT HOMMEL IS ISSUED A LETTER OF CAUTION. THE ALLEGATIONS OF HE SECOND CAUSE OF COMPLAINT WITH RESPECT TO RESPONDENT DEL DUCA WERE DISMISSE D IN THAT THE COMMITTEE DETERMINED THAT RESPONDENT DEL DUCA DELEGATED THE NASD 'S LETTER REQUESTING INFORMATION TO HIS MEMBER FIRM'S LEGAL DEPARTMENT, THEREF E ENDING ANY RESPONSIBILITY ON HIS PART TO RESPOND TO NASD REQUESTS FOR INFORM ATION. i Reporting Source: Firm Current Status: Final Allegations: 1) T. CLARKE OCTIGAN, THE MANAGER OF SHEARSON LEHMAN BROTHERS' CLAYTON, MISSOURI OFFICE, WAS CHARGED WITH FAILING TO PROPERLY SUPERVISE THE ACTIVITIES OF A BROKER IN HIM OFFICE DURING THE PERIOD 1982-1985. THE BROKER IS NOW DECEASED. SHEARSON WAS ALLEGED TO HAVE FAILED TO SUPERVISE OCTIGAN; 2) SHEARSON AND THOMAS E. HOMMEL WERE ALLEGED TO HAVE FAILED TO RESPOND TO NASD REQUESTS FOR INFORMATION IN A TIMELY AND COMPLETE MANNER. Initiated By: NASD DBCC FOR DISTRICT NO. 4 Date Initiated: 07/28/1989 Docket/Case Number: KC-455 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 472 www.finra.org/brokercheck User Guidance

Docket/Case Number: KC-455

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 06/01/1990 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: FIRST CAUSE OF COMPLAINT: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE NASD'S COMPLAINT, RESPONDENTS SHEARSON, OCTIGAN AND HOMMEL CONSENTED TO THE IMPOSITION OF CERTAIN SANCTIONS. SPECIFICALLY, SHEARSON AND OCTIGAN CONSENTED TO A CENSURE AND A JOINT AND SEVERAL FINE OF $10,000.00. IN ADDITION, OCTIGAN AGREED TO WORK IN SHEARSON'S NEW YORK COMPLIANCE DEPARTMENT FOR A TWO WEEK PERIOD, DURING WHICH TIME HE WILL BE ASSIGNED TASKS RELATIVE TO THE MONITORING OF "ACTIVE" CUSTOMER ACCOUNTS. SECOND CAUSE OF COMPLAINT: SHEARSON CONSENTED TO A CENSURE AND FINE OF $10,000.00. HOMMEL CONSENTED TO THE ISSUANCE OF A LETTER OF CAUTION. i Disclosure 304 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 01/10/1989 Docket/Case Number:

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 01/10/1989 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 6/23/89< AMERICAN STOCK EXCHANGE WEEKLY BULLETIN DATED JUNE 2, 1989 DISCLOSES: SHEARSON LEHMAN HUTTON, INC., A REGULAR MEMBER ORGANIZATION, WAS DISCIPLINED BY A DISCIPLINARY COMMITTEE FOR VIOLATING ARTICLE V, SECTION 4(k) OF THE EXCHANGE CONSTITUTION DURING THE PERIOD FROM JULY 23, 1987 THROUGH FEBRUARY 25, 1988 BY FAILING TO PRODUCE BOOKS AND RECORDS REQUESTED BY THE EXCHANGE IN CONNECTION WITH AN EXCHANGE INVESTIGATION. SHEARSON WAS FINED $2,000. THE FIRM SETTLED THE CHARGED WITHOUT ADMITTING OR DENYING THE EXCHANGE'S ALLEGATIONS.******** PER THE EXCHANGE, THIS SANCTION WAS IMPOSED JANUARY 10, 1989. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATION OF AMEX CONSTITUTION BY SHEARSON LEHMAN HUTTON FROM PERIOD JULY 23RD, 1987 THROUGH FEBRUARY 25TH, 1988 (ALLEGED FAILURE TO PRODUCE BOOKS AND RECORDS REQUESTED BY AMEX IN CONNECTION WITH AN EXCHANGE INVESTIGATION). Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 01/10/1989 Docket/Case Number: UNKNOWN

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 474 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Settled Resolution Date: 01/10/1989 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: THE FIRM SETTLED WITH THE AMEX WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AND PAID A FINE OF $2,000.00. Sanction Details: THE FIRM SETTLED WITH THE AMEX WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. THE FIRM PAID A FINE OF $2,000.00. i Disclosure 305 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: CONNECTICUT Date Initiated: 01/11/1989 Docket/Case Number: Unknown URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 01/11/1989 Sanctions Ordered: Monetary/Fine $10,500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 3/22/89-FORM U6 (8103-04489) DISCLOSES: THE SECURITIES AND ©2021 FINRA. All rights reserved. Report aboutBUSINESS LEHMAN INVESTMENTSBROTHERS INC. DIVISION, DEPARTMENT OF BANKING ALLEGED 475 THAT SHEARSON LEHMAN HUTTON, INC. VIOLATED SECTION 36-474(b) OF THE CONNECTICUT UNIFORM SECURITIES ACT IN THAT DURING 1988, THE FIRM ALLEGED UNREGISTERED AGENTS TO EFFECT SECURITY TRANSACTIONS IN CONNECTICUT. ON JANUARY 11, 1989 SHEARSON ENTERED INTO A STIPULATION AGREEMENT WITH THE CONNECTICUT SECURITIES DIVISION IN WHICH SHEARSON STIPULATED TO THE FOLLOWING: [1]. SHEARSON WILL REQUIRE EACH UNREGISTERED AGENT (EUGENE F. FORD, GLENN. W. LEBOEUF AND LINDA L. ROMAN) AND THEIR RESPECTIVE MANAGERS TO COMPLETE ADDITIONAL TRAINING PURSUANT TO THIS STATE'S REGULATORY REQUIREMENTS.

[2]. SHEARSON OFFERED TO RESCIND ALL SOLICITED PURCHASES, TOGETHER WITH 6% INTEREST, TO THOSE CONNECTICUT RESIDENTS REPRESENTED BY FORD, LEBOEUF AND ROMAN.

[3]. SHEARSON AGREED TO PAY A FINE IN THE AMOUNT OF $10,500.00

Regulator Statement 3/22/89-FORM U6 (8103-04489) DISCLOSES: THE SECURITIES AND BUSINESS INVESTMENTS DIVISION, DEPARTMENT OF BANKING ALLEGED THAT SHEARSON LEHMAN HUTTON, INC. VIOLATED SECTION 36-474(b) OF THE CONNECTICUT UNIFORM SECURITIES ACT IN THAT DURING 1988, THE FIRM ALLEGED UNREGISTERED AGENTS TO EFFECT SECURITY TRANSACTIONS IN CONNECTICUT. ON JANUARY 11, 1989 SHEARSON ENTERED INTO A STIPULATION AGREEMENT WITH THE CONNECTICUT SECURITIES DIVISION IN WHICH SHEARSON STIPULATED TO THE FOLLOWING: [1]. SHEARSON WILL REQUIRE EACH UNREGISTERED AGENT (EUGENE F. FORD, GLENN. W. LEBOEUF AND LINDA L. ROMAN) AND THEIR RESPECTIVE MANAGERS TO COMPLETE ADDITIONAL TRAINING PURSUANT TO THIS STATE'S REGULATORY REQUIREMENTS.

[2]. SHEARSON OFFERED TO RESCIND ALL SOLICITED PURCHASES, TOGETHER WITH 6% INTEREST, TO THOSE CONNECTICUT RESIDENTS REPRESENTED BY FORD, LEBOEUF AND ROMAN.

[3]. SHEARSON AGREED TO PAY A FINE IN THE AMOUNT OF $10,500.00

[4]. SHEARSON SHALL REVISE IT'S SUPERVISORY PROCEDURES TO PREVENT AND DETECT FUTURE VIOLATIONS OF CONNECTICUT'S ACT AND REGULATIONS. DOCKET/CASE NUMBER NOT PROVIDED, DATED JANUARY 11, 1989. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON INC. VIOLATED THE CONNECTICUT ACT BY ALLOWING UNREGISTERED AGENTS TO EFFECT SECURITIES TRANSACTIONS IN THE STATE. Initiated By: STATE OF CONNECTICUT Date Initiated: 01/03/1989 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE ©2021Sought: FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 476 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief FINE Sought:

Resolution: Consent Resolution Date: 01/03/1989 Sanctions Ordered: Monetary/Fine $10,500.00 Disgorgement/Restitution Other Sanctions Ordered: RETRAINING; UNDERTAKE TO IMPLEMENT POLICIES/PROCEDURES TO PREVENT REOCCURRENCE. Sanction Details: WITHOUT ADMITTING OR DENYING THAT IT HAD VIOLATED ANY LAWS, SHEARSON LEHMAN HUTTON CONSENTED TO THE IMPOSITION OF A $10,000.00 FINE, A RETRAINING OF CERTAIN EMPLOYEES REGARDING REGISTRATION REQUIREMENTS, TO OFFER RESCISSION PLUS INTEREST TO CT RESIDENT CUSTOMERS WHO PURCHASED OR SOLD SECURITIES THROUGH SUCH EMPLOYEES, AND TO UNDERTAKE TO IMPLEMENT POLICIES AND PROCEDURES TO PREVENT A REOCCURRENCE OF THE SITUATION. i Disclosure 306 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 12/09/1988 Docket/Case Number: SF-1276

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/07/1989 Sanctions Ordered: Censure Monetary/Fine $10,000.00

Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT NUMBER SF-1276 (DISTRICT NO. 2N) FILED DECEMBER 9, 1988 AGAINST RESPONDENTS SHEARSON LEHMAN HUTTON INC., PETER JOHN RENALDO AND GINA ANDREA VASSELL ALLEGING VIOLATIONS OF ARTICLE III, SECTION 1 AND ARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENTS MEMBER, RENALDO AND VASSELL FAILED TO TIMELY RESPOND TO THE ASSOCIATION'S REQUESTS FOR INFORMATION MADE PURSUANT TO ARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE; AND, IN THE RESPONSES TO REQUESTS FOR INFORMATION THAT THE ASSOCIATION DID RECEIVE, FAILED TO FULLY RESPOND TO THESE REQUESTS.

DECISION RENDERED SEPTEMBER 7, 1989, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BY RESPONDENTS WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $10,000. THE COMPLAINT IS DISMISSED AS TO RESPONDENTS RENALDO AND VASSELL BASED ON THE PROBLEMS EXPERIENCED BY THE FIRM ARISING FROM THE 1987 MARKET BREAK AND THE MERGER WITH ANOTHER MEMBER AND THE FACT THAT RESPONDENT VASSELL IS NO LONGER IN THE SECURITIES INDUSTRY. *** $10,000 PAID ON 10/2/89 - INVOICE NO. 89-2N-626. i Reporting Source: Firm Current Status: Final Allegations: A COMPLAINT HAD ALLEGED THAT SHEARSON LEHMAN HUTTON HAD FAILED TO TIMELY RESPOND TO AN NASD REQUEST FOR INFORMATION. Initiated By: NASD - DBCC FOR DISTRICT NO. 2 Date Initiated: 12/09/1988 Docket/Case Number: SF-1276

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/07/1989 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: THE DBCC ACCEPTED SHEARSON LEHMAN HUTTON'S OFFER OF SETTLEMENT. THE COMPLAINT WAS DISMISSED AS TO THE EMPLOYEES PREVIOUSLY CHARGED.

THE FIRM, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE COMPLAINT, CONSENTED TO THE ENTRY OF AN ORDER OF CENSURE AND AGREED TO PAY A FINE OF $10,000.00. i Disclosure 307 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/31/1989 Docket/Case Number: NY-6089-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 01/31/1989 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON JANUARY 31, 1989, THE LETTER OF ACCEPTANCE, WAIVER AND ©2021 FINRA. All rights reserved. Report aboutCONSENT LEHMAN NO. BROTHERS NY-6089-AWC INC. (DISTRICT NO. 12) SUBMITTED BY 479 RESPONDENT SHEARSON LEHMAN HUTTON, INC. WAS ACCEPTED; THEREFORE, SHEARSON LEHMAN IS CENSURED AND FINED $3,000.00 (MSRB RULES G-12(j), G-12(K) AND A-13(c) - FAILED TO COMPLY WITH MSRB RULE G-12(j), IN THAT AS LEAD MANAGER OF FOUR (4) NEW OFFERINGS FAILED TO SETTLE THREE (3) OF THE SYNDICATE ACCOUNTS WITHIN SIXTY (60) DAYS; FAILED TO PAY DESIGNATED CREDITS FOR THREE (3) OF THE OFFERINGS WITHIN THIRTY (30) DAYS; AND, FAILED TO PAY THE ASSESSMENT FEES FOR THREE (3) OF THE OFFERINGS WITHIN THIRTY (30) DAYS.

$3,000 PAID 6/1/89 www.finra.org/brokercheck User Guidance

Regulator Statement ON JANUARY 31, 1989, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. NY-6089-AWC (DISTRICT NO. 12) SUBMITTED BY RESPONDENT SHEARSON LEHMAN HUTTON, INC. WAS ACCEPTED; THEREFORE, SHEARSON LEHMAN IS CENSURED AND FINED $3,000.00 (MSRB RULES G-12(j), G-12(K) AND A-13(c) - FAILED TO COMPLY WITH MSRB RULE G-12(j), IN THAT AS LEAD MANAGER OF FOUR (4) NEW OFFERINGS FAILED TO SETTLE THREE (3) OF THE SYNDICATE ACCOUNTS WITHIN SIXTY (60) DAYS; FAILED TO PAY DESIGNATED CREDITS FOR THREE (3) OF THE OFFERINGS WITHIN THIRTY (30) DAYS; AND, FAILED TO PAY THE ASSESSMENT FEES FOR THREE (3) OF THE OFFERINGS WITHIN THIRTY (30) DAYS.

$3,000 PAID 6/1/89 i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON HAD FAILED TO SETTLE ACCOUNTS, PAY DESIGNATED CREDITS AND ASSESSMENT FEES WITHIN THE TIME PERIODS REQUIRED. Initiated By: NASD - NBCC Date Initiated: 01/31/1989 Docket/Case Number: NY-6089 AWC

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE; RULE VIOLATIONS Sought:

Resolution: Consent Resolution Date: 01/31/1989 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SLH CONSENTED TO FINDINGS THAT IT HAD FAILED TO COMPLY WITH MSRB RULES G-12(J), G-12(K) AND A-13(C); THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A $3,000.00 FINE.

i Disclosure 308 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: VIRGINIA Date Initiated: 09/02/1988 Docket/Case Number: SEC880067 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/02/1988 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 9/19/88-FORM U6 (8059-25388) DISCLOSES SHEARSON LEHMAN HUTTON, INC. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE DIVISION OF SECURITIES THAT IT EMPLOYED AN UNREGISTERED AGENT, FAILED TO DILIGENTLY SUPERVISE THIS AGENT, HOWARD B. GOLDSTEIN, AND FAILED TO PRESERVE CERTAIN RECORDS PROPERLY, HAS AGREED TO SETTLE THESE MATTERS BY MAKING AN OFFER OF RESCISSION TO THE INVESTOR, BY PAYING A PENALTY OF $1,000 FOR FAILURE TO SUPERVISE, AND BY PAYING A PENALTY OF $1,000 FOR FAILURE TO PROPERLY KEEP RECORDS. DOCKET/CASE NO. SEC880067, DATED SEPTEMBER 2, 1988. i Reporting Source: Firm

Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON EMPLOYED AN UNREGISTERED AGENT WHO OFFERED AND SOLD SECURITIES IN THE COMMONWEALTH, FAILED TO PRESERVE RECORDS FOR A PERIOD OF NOT LESS THAN THREE YEARS, AND FAILED TO DILIGENTLY SUPERVISE ITS AGENT. Initiated By: COMMONWEALTH OF VIRGINIA Date Initiated: 08/25/1988 Docket/Case Number: SEC880067

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief UNREGISTERED AGENT, FAIL TO PRESERVE RECORDS AND FAIL TO Sought: SUPERVISE.

Resolution: Settled Resolution Date: 08/25/1988 Sanctions Ordered: Monetary/Fine $2,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO THE IMPOSITION OF A FINE OF $2,000.00 AND AGREED TO OFFER RESCISSION TO THE VIRGINIA CUSTOMER FOR ALL PURCHASES EXECUTED PRIOR TO MARCH 20TH, 1987, THE DATE ON WHICH THE AGENT BECAME REGISTERED WITH THE COMMONWEALTH. i Disclosure 309 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/05/1988 Docket/Case Number: CHI-1035

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/30/1988 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT NO. CHI-1035 FILED MAY 5, 1988 BY DISTRICT NO. 8 AGAINST RESPONDENTS SHEARSON LEHMAN HUTTON, INC., JOSEPH DEL DUCA AND JOSHUA JEDWAB ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF FAIR PRACTICE IN THAT RE SPONDENTS FAILED TO RESPOND TO THE ASSOCIATION'S REQUESTS FOR INFORMATION MADE PURSUANT TO ARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE; AND, RESPONDENT MEMBER, ACTING THROUGH RESPONDENT DEL DUCA, FAILED TO PROPERLY SUPERVISE RESPONDENT JEDWAB.

DECISION RENDERED NOVEMBER 30, 1988, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BY RESPONDENTS WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $5,000.00 AND RESPONDENT JEDWAB IS CENSURED. THE COMMITTEE DETERMINED THAT RESPONDENT DEL DUCA DID NOT RECEIVE EITHER OF THE ASSOCIATION'S REQUESTS FOR INFORMATION AND THAT, CONTRARY TO THE FIRM'S PROCEDURES, THE LETTERS WERE ROUTED DIRECTLY TO RESPONDENT JEDWAB AND THEREFORE DISMISS THE ALLEGATIONS IN THE FIRST CAUSE AS TO RESPONDENT DEL DUCA AND DISMISS THE SECOND CAUSE IN ITS ENTIRETY; THEREFORE, THE COMPLAINT IS DISMISSED WITH REGARD TO RESPONDENT DEL DUCA.

$5,000 PAID 12/30/88 - DEPOSIT #420

i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN HUTTON AND ONE OF ITS EMPLOYEES HAD FAILED TO RESPOND TO A NASD REQUEST FOR INFORMATION. Initiated By: NASD - DBCC FOR DISTRICT NO. 8 Date Initiated: 11/30/1988 Docket/Case Number: CHI-1035

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 11/30/1988 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: THE DISTRICT ACCEPTED OFFERS OF SETTLEMENT FROM THE FIRM AND ONE ITS EMPLOYEES WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATION OUTLINE ABOVE, THE FIRM CONSENTED TO CENSURE AND THE IMPOSITION OF A $5,000.00 FINE. i Disclosure 310 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/05/1987 Docket/Case Number: MS-624-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 01/26/1988 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-624-AWC:

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED OCTOBER 5, 1987 ALLEGES VIOLATIONS OF PART VI, SECTION 2(d) OF SCHEDULE D FOR ENTERING NASDAQ QUOTATIONS CONTAINING EXCESS SPREADS. THE AWC WAS ACCPETED BY THE MARKET SURVEILLANCE COMMITTEE ON 1/7/88 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON 1/26/88. FINE $500. ******* $500 FINE PAID 11/5/87 i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT THE FIRM VIOLATED PART VI, SECTION 2(D) OF SCHEDULE D OF THE NASD BYLAWS IN THAT IT ENTERED NASDAQ QUOTATIONS CONTAINING EXCESSIVE SPREADS. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 10/05/1987 Docket/Case Number: MS-624-AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/26/1988 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: THE FIRM PAID A $500.00 FINE FOR THE ALLEGED VIOLATION. i Disclosure 311 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/10/1987 Docket/Case Number: LA-4148

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 01/28/1989 Sanctions Ordered: Censure Monetary/Fine $30,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT NO. LA-4148 FILED NOVEMBER 10, 1987 BY DISTRICT NO. 2S AGAINST RESPONDENTS SHEARSON LEHMAN BROTHERS INC., WILLIAM SCOTT DOOLITTLE AND VAN DUYN RIDGEWAY ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF F AIR PRACTICE IN THAT RESPONDENT DOOLITLE ARRANGED FOR THE EXTENSION OR MAINTENANCE OF CREDIT TO A CUSTOMER UPON TERMS AND CONDITIONS ©2021 FINRA. All rights reserved. Report aboutOTHER LEHMAN THAN BROTHERS THOSE INC. UPON WHICH RESPONDENT SHEARSON COULD 486 ITSELF EXTEND OR MAINTAIN UNDER REGULATION T AND, RESPONDENTS SHEARSON AND RIDGWAY FAILED TO SUPERVISE PROPERLY AND ADEQUATELY THE ACTIVITIES OF RESPONDENT DOOLITTLE.

DECISION RENDERED JULY 26, 1988, WHEREIN RESPONDENT DOOTLITTLE IS CENSURED, FINED $15,000.00 AND BARRED FROM ASSOCIATION WITH ANY MEMBER OF THE ASSOCIATION IN ANY CAPACITY, ASSESSED COSTS OF $483.78; RESPONDENT SHEARSON LEHMAN BROTHERS INC. IS CENSURED, FINED $30,000.00 AND ASSESSED $483.78 AND THE DECISION IS TO ACT AS A LETTER OF CAUTION TO RESPONDENT RIDGWAY. IF NO FURTHER ACTION, DECISION IS FINAL SEPTEMBER 9, 1988.

AUGUST 10, 1988 - APPEALED TO THE BOARD OF GOVERNORS.

BOARD OF GOVERNORS DECISION RENDERED DECEMBER 30, 1988, WHEREIN THE FINDINGS MADE ARE AFFIRMED AND THE SANCTIONS ARE MODIFIED. THE SANCTIONS ARE AFFIRMED AS TO RESPONDENTS MEMBER AND RIDGWAY; HOWEVER, RESPONDENT DOOLITTLE'S FINE IS REDUCED TO $5,000.00, HE IS SUSPENDED FROM ASSOCIATION WITH ANY MEMBER OF THE ASSOCIATION IN ANY CAPACITY FOR ONE (1) YEAR AND IS ASSESSED COSTS OF $483.78. IF NO FURTHER ACTION, DECISION IS FINAL JANUARY 28, 1989.

JANUARY 28, 1989 - DECISION IS FINAL. ***$30,483.78 FULLY PAID AS OF 12/11/89 INVOICE #89-2S-162.*** COMPLAINT NO. LA-4148 FILED NOVEMBER 10, 1987 BY DISTRICT NO. 2S AGAINST RESPONDENTS SHEARSON LEHMAN BROTHERS INC., WILLIAM SCOTT DOOLITTLE AND VAN DUYN RIDGEWAY ALLEGING VIOLATIONS OF www.finra.org/brokercheck ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OF F AIR PRACTICE User Guidance IN THAT RESPONDENT DOOLITLE ARRANGED FOR THE EXTENSION OR MAINTENANCE OF CREDIT TO A CUSTOMER UPON TERMS AND CONDITIONS OTHER THAN THOSE UPON WHICH RESPONDENT SHEARSON COULD ITSELF EXTEND OR MAINTAIN UNDER REGULATION T AND, RESPONDENTS SHEARSON AND RIDGWAY FAILED TO SUPERVISE PROPERLY AND ADEQUATELY THE ACTIVITIES OF RESPONDENT DOOLITTLE.

AUGUST 10, 1988 - APPEALED TO THE BOARD OF GOVERNORS.

JANUARY 28, 1989 - DECISION IS FINAL. ***$30,483.78 FULLY PAID AS OF 12/11/89 INVOICE #89-2S-162.*** i Reporting Source: Firm Current Status: Final Allegations: THE NASD FOUND THAT SHEARSON LEHMAN BROTHERS HAD FAILED TO SUPERVISE ONE OF ITS REGISTERED REPRESENTATIVES AND HAD ARRANGED FOR CREDIT FOR A CUSTOMER IN CONTRAVENTION OF REGULATION T OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM. Initiated By: NASD - DBCC FOR DISTRICT NO. 2S Date Initiated: 07/26/1988 Docket/Case Number: LA-4148 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 487 www.finra.org/brokercheck User Guidance

Docket/Case Number: LA-4148

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Settled Resolution Date: 07/26/1988 Sanctions Ordered: Censure Monetary/Fine $30,000.00 Other Sanctions Ordered: Sanction Details: THE DBCC ISSUED A DECISION IN WHICH SHEARSON LEHMAN BROTHERS WAS CENSURED. THE FIRM ALSO PAID A FINE OF $30,000.00. i Disclosure 312 of 359 Reporting Source: Regulator Current Status: Final Allegations: NOT PROVIDED Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 08/23/1961 Docket/Case Number: NY-469

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Decision Resolution Date: 05/21/1962 Sanctions Ordered: Censure Monetary/Fine $100.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 488 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: N/A Sanction Details: N/A Regulator Statement COMPLAINT #NY-469 FILED 8/23/61 5/16/62 CENSURD, FINED $100.00 FINAL - 5/21/62 PAID i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 08/23/1961 Docket/Case Number: NY-469

Principal Product Type: Other Other Product Type(s): UNKNOWN. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 05/16/1962 Sanctions Ordered: Censure Monetary/Fine $100.00 Other Sanctions Ordered: Sanction Details: FIRM CENSURED AND FINED $100.00. i Disclosure 313 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 06/15/1987 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 489 www.finra.org/brokercheck User Guidance

Date Initiated: 06/15/1987 Docket/Case Number: Unknown

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 06/15/1987 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Regulator Statement 6/29/87-SEC NEWS DIGEST ISSUE 87-117 DATED JUNE 23, 1987, ADMINISTRATIVE PROCEEDNGS DISCLOSES: 'PROCEEDINGS INSTITUTED AGAINST, AND OFFER OF SETTLEMENT ACCEPTED FROM, SHEARSON LEHMAN BROTHERS, INC.'; THE COMMISSION ORDERED PUBLIC ADMINISTRATIVE PROCEEDINGS UNDER THE SECURITIES EXCHANGE ACT OF 1934 AGAINST SHEARSON LEHMAN BROTHERS INC. (REGISTRANT), A REGISTERED BROKER-DEALER. THE COMMISSION SIMULTANEOUSLY ACCPETED REGISTRANT'S OFFER OF SETTLEMENT. BY ITS OFFER, REGISTRANT, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, ALLOWED THE COMMISSION TO FIND THAT FROM ABOUT NOVEMBER 1, 1985 TO ABOUT NOVEMBER 8, 1985 WHILE IT TRANSACTED BUSINESS WITH ITS PUBLIC CUSTOMERS, REGISTRANT WILFULLY VIOLATED THE CUSTOMER PROTECTION RULE (RULE 15c3-3) IN THAT IT FAILED TO: (1) OBTAIN OR MAINTAIN THE PHYSICAL POSSESSION OR CONTROL OF CUSTOMERS' FULLY-PAID AND EXCESS MARGIN SECRITIES (CUSTOMERS' SECURITIES). THE LARGEST IMPROPER USE OF CUSTOMERS' SECURITIES OCCURRED ON NOVEMBER 1, 1985 WHEN REGISTRANT USED APPROXIMATELY $69 MILLION OF SUCH SECURITIES; AND (2) REDUCE TO ITS PHYSICAL POSSESSION AND CONTROL WITHIN THE PRESCRIBED TIME PERIOD, CUSTOMERS' SECURITIES WHICH ALLOCATED TO OPEN STOCK LOAN POSITIONS. REGISTRANT CONSENTED TO A CENSURE AND AGREED TO COMPLY WITH CERTAIN UNDERTAKINGS DESIGNED TO PREVENT THE RECURRENCE OF SIMILAR ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 490 VIOLATIONS. REGISTRANT WILL ALSO RETAIN AN INDEPENDENT PUBLIC ACCOUNTANT TO REVIEW ITS PROCEDURES, AND THEREAFTER FILE FOUR REPORTS WITH THE COMMISSION'S NEW YORK REGIONAL OFFICE. (REL. 35-24595) (ORDER DATED 6-15-87) 6/29/87-SEC NEWS DIGEST ISSUE 87-117 DATED JUNE 23, 1987, ADMINISTRATIVE PROCEEDNGS DISCLOSES: 'PROCEEDINGS INSTITUTED AGAINST, AND OFFER OF SETTLEMENT ACCEPTED FROM, SHEARSON LEHMAN BROTHERS, INC.'; THE COMMISSION ORDERED PUBLIC ADMINISTRATIVE PROCEEDINGS UNDER THE SECURITIES EXCHANGE ACT OF 1934 AGAINST SHEARSON LEHMAN BROTHERS INC. (REGISTRANT), A REGISTERED BROKER-DEALER. THE COMMISSION SIMULTANEOUSLY ACCPETED REGISTRANT'S OFFER OF SETTLEMENT. BY ITS OFFER, REGISTRANT, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, ALLOWED THE COMMISSION TO FIND THAT FROM ABOUT NOVEMBER 1, 1985 TO ABOUT NOVEMBER 8, 1985 WHILE IT TRANSACTED BUSINESS WITH ITS PUBLIC CUSTOMERS, REGISTRANT WILFULLY VIOLATED THE CUSTOMER PROTECTION RULE (RULE 15c3-3) IN THAT IT FAILED TO: (1) OBTAIN OR MAINTAIN THE PHYSICAL POSSESSION OR CONTROL OF CUSTOMERS' FULLY-PAID AND EXCESS MARGIN SECRITIES (CUSTOMERS' SECURITIES). THE LARGEST IMPROPER USE OF CUSTOMERS' SECURITIES OCCURRED ON NOVEMBER 1, 1985 WHEN REGISTRANT USED APPROXIMATELY $69 MILLION OF SUCH SECURITIES; AND (2) REDUCE TO ITS PHYSICAL POSSESSION AND www.finra.org/brokercheck CONTROL WITHIN THE PRESCRIBED TIME PERIOD, CUSTOMERS' User Guidance SECURITIES WHICH ALLOCATED TO OPEN STOCK LOAN POSITIONS. REGISTRANT CONSENTED TO A CENSURE AND AGREED TO COMPLY WITH CERTAIN UNDERTAKINGS DESIGNED TO PREVENT THE RECURRENCE OF SIMILAR VIOLATIONS. REGISTRANT WILL ALSO RETAIN AN INDEPENDENT PUBLIC ACCOUNTANT TO REVIEW ITS PROCEDURES, AND THEREAFTER FILE FOUR REPORTS WITH THE COMMISSION'S NEW YORK REGIONAL OFFICE. (REL. 35-24595) (ORDER DATED 6-15-87) i Reporting Source: Firm Current Status: Final Allegations: IT WAS FOUND BY THE SEC THAT SHEARSON HAD FAILED TO OBTAIN OR MAINTAIN THE PHYSICAL POSSESSION OR CONTROL OF ALL ITS CUSTOMERS' FULLY-PAID AND/OR EXCESS MARGIN SECURITIES IN VIOLATION OF SECTION 15(C)(3) OF THE EXCHANGE ACT AND RULE 15C3- 3(B)(1). SHEARSON ALSO CONSENTED TO A FINDING THAT IT FAILED TO REDUCE TO ITS POSSESSION OR CONTROL WITHIN THE PRESCRIBED TIME PERIOD CUSTOMERS' SECURITIES WHICH HAD BEEN ALLOCATED TO OPEN STOCK LOAN POSITIONS IN VIOLATION OF RULE 15C3-3(D)(1). Initiated By: SEC Date Initiated: 06/15/1987 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 06/15/1987 Sanctions Ordered: Censure Other Sanctions Ordered: FIRM REQUIRED TO IMPLEMENT CERTAIN SPECIFIC UNDERTAKINGS RELATING TO POSSESSION AND CONTROL OF SECURITIES AND TO ENGAGE AN INDEPENDENT CONSULTANT TO REVIEW CERTAIN CONDUIT ACTIVITY OVER A TWO-YEAR PERIOD. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHEARSON CONSENTED TO THE FINDINGS; THE FIRM WAS CENSURED AND SANCTIONS AS OUTLINED ABOVE WERE AGREED TO.

i Disclosure 314 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/19/1987 Docket/Case Number: WA-506-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/19/1987 Sanctions Ordered: Censure Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON MARCH 19, 1987, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. WA-506-AWC (DISTRICT NO. 10) SUBMITTED BY RESPONDENT SHEARSON LEHMAN BROTHERS, INC. WAS ACCEPTED; THEREFORE, THE FIRM IS CENSURED AND FINED $500.00 AND CONSENTS TO FILINGS OF ALL ADVERTISEMENTS INITIATED BY ITS BETHESDA, MARYLAND BRANCH OFFICE TO THE ASSOCIATION'S ADVERTISING DEPARTMENT AT LEAST 10 DAYS PRIOR TO USE FOR A PERIOD OF ONE (1) YEAR FROM THE DATE OF THIS LETTER OF ACCEPTANCE, WAIVER AND CONSENT (ARTICLE III, SECTIONS 1 AND 35 OF THE RULES OF FAIR PRACTICE - UTILIZED AN ADVERTISEMENT RELATING TO A PUBLIC REAL ESTATE LIMITED PARTNERSHIP WHICH WAS NOT IN CONFORMANCE WITH SEC RULE 134 IN ORDER TO BE A WRITTEN COMMUNICATION NOT DEEMED A PROSPECTUS; AND ©2021 FINRA. All rights reserved. Report aboutAN ADVERTISEMENT LEHMAN BROTHERS INC. FOR GNMA CERTIFICATES CONTAINED MISLEADING 492 STATEMENTS). ****** $500 PAID 8-17-87. ON MARCH 19, 1987, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. WA-506-AWC (DISTRICT NO. 10) SUBMITTED BY RESPONDENT SHEARSON LEHMAN BROTHERS, INC. WAS ACCEPTED; THEREFORE, THE FIRM IS CENSURED AND FINED $500.00 AND CONSENTS TO FILINGS OF ALL ADVERTISEMENTS INITIATED BY ITS BETHESDA, MARYLAND BRANCH OFFICE TO THE ASSOCIATION'S ADVERTISING DEPARTMENT AT LEAST 10 DAYS PRIOR TO USE FOR A PERIOD OF ONE (1) YEAR FROM THE DATE OF THIS LETTER OF ACCEPTANCE, WAIVER AND CONSENT (ARTICLE III, SECTIONS 1 AND 35 OF THE RULES OF FAIR PRACTICE - UTILIZED AN www.finra.org/brokercheck ADVERTISEMENT RELATING TO A PUBLIC REAL ESTATE LIMITED User Guidance PARTNERSHIP WHICH WAS NOT IN CONFORMANCE WITH SEC RULE 134 IN ORDER TO BE A WRITTEN COMMUNICATION NOT DEEMED A PROSPECTUS; AND AN ADVERTISEMENT FOR GNMA CERTIFICATES CONTAINED MISLEADING STATEMENTS). ****** $500 PAID 8-17-87. i Reporting Source: Firm Current Status: Final Allegations: ADVERTISING ISSUE--SHEARSON LEHMAN BROTHERS AGREED TO FILE ALL ADVERTISEMENTS INITIATED BY ITS BETHESDA, MD BRANCH OFFICE TO THE NASD'S ADVERTISING DEPARTMENT AT LEAST TEN DAYS PRIOR TO USE FOR A PERIOD OF ONE YEAR FROM THE DATE OF THE AWC LETTER. Initiated By: NASD - DBCC FOR DISTRICT NO. 10 Date Initiated: 03/19/1987 Docket/Case Number: WA-506-AWC

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/19/1987 Sanctions Ordered: Censure Monetary/Fine $500.00 Other Sanctions Ordered: SEE ABOVE. Sanction Details: THE FIRM WAS CENSURED AND FINED $500; FIRM AGREED TO SUBMIT ADVERTISEMENTS FOR NASD REVIEW AS OUTLINED ABOVE. i Disclosure 315 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 12/08/1986 Docket/Case Number: MS-451-AWC ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 493 www.finra.org/brokercheck User Guidance

Docket/Case Number: MS-451-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 04/03/1987 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-451-AWC:

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WAS FILED ON DECEMBER 8, 1986, ALLEGING VIOLATIONS OF PART I, SECTION C.3.(c) OF SCHEDULE D OF THE ASSOCIATION'S BY-LAWS IN THAT RESPONDENT (SHEARSON LEHMAN BROTHERS INC.) FAILED TO REPORT ITS NASDAQ VOLUME IN ONE SECURITY ON 10/8/86. THE AWC WAS ACCEPTED BY THE MARKET SURVEILLANCE COMITTEE ON MARCH 2, 1987 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON APRIL 3, 1987. $250 FINE RECEIVED 12/31/86

$250 FINE PAID 3/24/87 i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED SHEARSON LEHMAN BROTHERS VIOLATED PART 1, SECTION C3(C) OF SCHEDULE D OF THE ASSOCIATION'S BYLAWS RELATING TO FAILURE TO REPORT ITS NASDAQ VOLUME IN ONE SECURITY ON OCTOBER 8TH, 1986. Initiated By: NASD - NBCC Date Initiated: 04/03/1987 Docket/Case Number: MS-451-AWC ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 494 www.finra.org/brokercheck User Guidance

Docket/Case Number: MS-451-AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/03/1987 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A $250.00 FINE. i Disclosure 316 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 08/19/1986 Docket/Case Number: MS-399-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/08/1996 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered:

Sanction Details: Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-399-AWC:

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WAS FILED ON AUGUST 19, 1986, ALLEGING VIOLATIONS OF PART I, SECTION C.3.(c) OF SCHEDULE D OF THE ASSOCIATION'S BY-LAWS IN THAT RESPONDENT (SHEARSON LEHMAN BROTHERS INC.) FAILED TO REPORTS ITS NASDAQ VOLUME IN TWO SECURITIES ON 4/25/86. THE AWC WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON NOVEMBER 13, 1986 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON DECEMBER 8,1 986. $250 FINE RECEIVED 10/21/86 i Reporting Source: Firm Current Status: Final Allegations: SHEARSON LEHMAN BROTHERS ALLEGEDLY FAILED TO REPORT ITS NASDAQ VOLUME IN TWO SECURITIES ON APRIL 24TH, 1986, IN VIOLATION OF PART I, SECTION C.3.(C) OF SCHEDULE D OF THE ASSOCIATION'S BYLAWS. Initiated By: NASD - NBCC Date Initiated: 12/08/1986 Docket/Case Number: MS-399-AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/08/1986 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A $250.00 FINE. i Disclosure 317 of 359 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 496 www.finra.org/brokercheck User Guidance

Disclosure 317 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/25/1986 Docket/Case Number: MS-362-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 10/08/1986 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 10/28/86: MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-362-AWC:

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WAS FILED ON 7/25/86, ALLEGING VIOLATIONS OF PART I, SECTION C.3.(a) OF SCHEDULE D OF THE ASSOCATION'S BY-LAWS IN THAT ON 5/2/86 AND 5/12/86, THE RESPONDENT ENTERED QUOTATIONS INTO THE NASDAQ SYSTEM THAT WERE NOT REASONABLE RELATED TO THE PREVAILING MARKET. THE AWC WAS ACCEPTED BY THE MSC ON 9/8/86 AND BY THE NBCC ON 10/8/86. $1,000 FINE RECEIVED 8/18/86. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS VIOLATED PART 1, SECTION C.3(A) OF SCHEDULE D OF THE ASSOCIATION'S BYLAWS RELATING TO QUOTATIONS INTO THE NASDAQ SYSTEM THAT WERE NOT REASONABLE RELATED TO THE PREVAILING MARKET ON MAY 2ND, 1986 AND MAY 12TH, 1986. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 497 www.finra.org/brokercheck IT WAS ALLEGED THAT SHEARSON LEHMAN BROTHERS VIOLATED PART 1, User Guidance SECTION C.3(A) OF SCHEDULE D OF THE ASSOCIATION'S BYLAWS RELATING TO QUOTATIONS INTO THE NASDAQ SYSTEM THAT WERE NOT REASONABLE RELATED TO THE PREVAILING MARKET ON MAY 2ND, 1986 AND MAY 12TH, 1986. Initiated By: NASD - NBCC Date Initiated: 10/08/1986 Docket/Case Number: MS-362-AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/08/1986 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A $1,000.00 FINE. i Disclosure 318 of 359 Reporting Source: Regulator Current Status: Final Allegations: SHEARSON SOLD PARTNERSHIPS UNITS IN VIOLATION OF SECTION 301. Initiated By: MASSACHUSETTS SECURITIES DIVISION Date Initiated: 07/07/1986 Docket/Case Number: E-86-10 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 07/07/1986 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: THE DIVISION CENSURED SHEARSON AND REQUIRED IT TO PAY THE COMMONWEALTH $1,000.00. Regulator Statement Not Provided i Reporting Source: Firm Current Status: Final Allegations: BLUE SKY VIOLATION (ALLEGED OFFER/SALE OF UNREGISTERED SECURITIES). Initiated By: COMMONWEALTH OF MASSACHUSETTS Date Initiated: 07/09/1986 Docket/Case Number: E-86-10

Principal Product Type: Direct Investment(s) - DPP & LP Interest(s) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE (OFFER/SALE OF UNREGISTERED SECURITIES). Sought:

Resolution: Settled Resolution Date: 07/09/1986 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: FIRM WAS CENSURED A MADE A VOLUNTARY PAYMENT OF $1,000.00. i Disclosure 319 of 359 Reporting Source: Regulator Current Status: Final

Allegations: Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 10/08/1986 Docket/Case Number: Unknown

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 10/08/1986 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Regulator Statement 10/8/86: SEC NEWS DIGEST ISSUE-86-186: THE COMMISION INSTITUTED PUBLIC ADMINISTRATIVE PROCEEDINGS AGAINST SHEARSON LEHMAN BROTHERS, INC., A REGISTERED BROKER/DEALER, AND STEIN ROE & FARNHAM, A REGISTERED INVESTMENT ADVISER. THE ORDER ALLEGES THAT SHEARSON AND STEIN ROE FAILED TO REASONABLY SUPERVISE GEORGE AND JOHN INSERRA, NICHOLAS J. GENTILE, AND JOHN GIURA, RESPECTIVELY, WITH A REIVEW TO PREVENTING VIOLATIONS OF THE ANTIFRAUD PROVISIONS OF THE INVESTMENT ADVISERS ACT OF 1940 AND THE SECURITIES EXCHANGE ACT OF 1934. IN SEPARATE PROCEEDING, WHICH ARE BEING CONTESTED, THE COMMISSION ALLEGED THAT GIURA, THE INSERRAS AND GENTILE ENGAGED IN VARIOUS SCHEMES TO DEFRAUD CLIENTS OF SHEARSON AND STEIN ROE, INCLUDING UNION PENSION AND WELFARE FUNDS. THE ORDER HEREIN ALLEGES THAT SHEARSON'S PROCEDURES WERE NOT SUFFICIENT TO PREVENT THE VIOLATIONS BY GENTILE AND THE INSERRAS, AND THE STEIN ROE HAD NO PROCEDURES IN PLACE THAT WOULD HAVE REASONABLY PREVENTED GIURA'S VIOLATIONS. SIMULTANEOUS WITH THE INSTITUTION OF PROCEEDINGS, SHEARSON AND STEIN ROE, WITHOUT ADMITTING OR DENYING THE COMMISSION'S ©2021 FINRA. All rights reserved. Report aboutALLEGATIONS, LEHMAN BROTHERS CONSENTED INC. TO THE ORDER, A CENSURE, AND THE 500 APPOINTMENT OF INDEPENDENT CONSULTANTS TO REVIEW AND REPORT UPON THEIR PROCEDURES. BOTH SHEARSON AND STEIN ROE CONSENTED TO IMPLEMENT ANY RECOMMENDATIONS RESULTING THEREFROM. (REL. 34-23640) 10/8/86: SEC NEWS DIGEST ISSUE-86-186: THE COMMISION INSTITUTED PUBLIC ADMINISTRATIVE PROCEEDINGS AGAINST SHEARSON LEHMAN BROTHERS, INC., A REGISTERED BROKER/DEALER, AND STEIN ROE & FARNHAM, A REGISTERED INVESTMENT ADVISER. THE ORDER ALLEGES THAT SHEARSON AND STEIN ROE FAILED TO REASONABLY SUPERVISE GEORGE AND JOHN INSERRA, NICHOLAS J. GENTILE, AND JOHN GIURA, RESPECTIVELY, WITH A REIVEW TO PREVENTING VIOLATIONS OF THE ANTIFRAUD PROVISIONS OF THE INVESTMENT ADVISERS ACT OF 1940 AND THE SECURITIES EXCHANGE ACT OF 1934. IN SEPARATE PROCEEDING, WHICH ARE BEING CONTESTED, THE COMMISSION ALLEGED THAT GIURA, THE INSERRAS AND GENTILE ENGAGED IN VARIOUS SCHEMES TO DEFRAUD CLIENTS OF SHEARSON AND STEIN ROE, INCLUDING UNION PENSION AND WELFARE FUNDS. THE ORDER HEREIN ALLEGES THAT SHEARSON'S PROCEDURES WERE NOT SUFFICIENT TO PREVENT THE VIOLATIONS BY GENTILE AND THE INSERRAS, AND THE STEIN ROE HAD NO PROCEDURES IN PLACE THAT WOULD HAVE REASONABLY PREVENTED GIURA'S www.finra.org/brokercheck VIOLATIONS. User Guidance SIMULTANEOUS WITH THE INSTITUTION OF PROCEEDINGS, SHEARSON AND STEIN ROE, WITHOUT ADMITTING OR DENYING THE COMMISSION'S ALLEGATIONS, CONSENTED TO THE ORDER, A CENSURE, AND THE APPOINTMENT OF INDEPENDENT CONSULTANTS TO REVIEW AND REPORT UPON THEIR PROCEDURES. BOTH SHEARSON AND STEIN ROE CONSENTED TO IMPLEMENT ANY RECOMMENDATIONS RESULTING THEREFROM. (REL. 34-23640) i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED SHEARSON FAILED TO REASONABLY SUPERVISE G. INSERRA, J. INSERRA AND N. GENTILE WITH A VIEW TO PREVENTING VIOLATIONS OF SECTION 206 OF THE ADVISORS ACT AND SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER, THEREBY VIOLATING SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. Initiated By: SEC Date Initiated: 09/24/1986 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/24/1986 Sanctions Ordered: Censure Other Sanctions Ordered: FIRM REQUIRED TO ENGAGE A CONSULTANT TO REVIEW CERTAIN CORRECTION AND COMPLIANCE FOLLOW-UP PROCEDURES. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE ABOVE FINDINGS; THE FIRM AGREED TO A CENSURE AND THE ENGAGEMENT OF A CONSULTANT AS DESCRIBED ABOVE. i Disclosure 320 of 359 Reporting Source: Regulator

Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/11/1986 Docket/Case Number: MS-347-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/10/1986 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 9/24/86: MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-347-AWC:

LETTER OF ACCEPTNCE, WAIVER AND CONSENT (AWC) WAS FILED ON 6/11/86, ALLEGING VIOLATIONS OF PART I, SECTION C.3.(c) OF SCHEDULE D OF THE ASSOCIATION'S BY-LAWS IN THAT RESPONDENT (SHEARSON LEHMAN BROTHERS INC.) FAILED TO REPORT ITS NASDAQ VOLUME IN TWO SECURITIES ON 12/18/85, ONE SECURITY ON 3/25/86, AND IN FIVE SECURITIES ON 4/10/86. THE AWC WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON 8/6/86 AND BY THE NBCC ON 9/10/86.

11/18/86: $250 FINE PAID 7/16/86 i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT THE FIRM VIOLATED PART I, SECTION C.3(C) OF SCHEDULE D OF THE NASD'S BYLAWS IN THAT IT FAILED TO REPORT ITS NASDAQ VOLUME IN TWO SECURITIES ON DECEMBER 18TH, 1985, ONE SECURITY ON MARCH 25TH, 1986 AND IN FIVE SECURITIES ON APRIL 10TH, ©2021 FINRA. All rights reserved. Report about1986. LEHMAN BROTHERS INC. 502 www.finra.org/brokercheck User Guidance IT WAS ALLEGED THAT THE FIRM VIOLATED PART I, SECTION C.3(C) OF SCHEDULE D OF THE NASD'S BYLAWS IN THAT IT FAILED TO REPORT ITS NASDAQ VOLUME IN TWO SECURITIES ON DECEMBER 18TH, 1985, ONE SECURITY ON MARCH 25TH, 1986 AND IN FIVE SECURITIES ON APRIL 10TH, 1986. Initiated By: NASD - MARKET SURVEILLANCE COMMITTEE Date Initiated: 06/11/1986 Docket/Case Number: MS-347-AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/10/1986 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS FINED $250.00 FOR THE ALLEGED VIOLATIONS. i Disclosure 321 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 08/19/1975 Docket/Case Number: N-VS-158

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision

Resolution Date: 10/30/1975 Sanctions Ordered: Monetary/Fine $25.00 Other Sanctions Ordered: Sanction Details: Regulator Statement NASDAQ COMPLAINT #N-VS-158 FILED 8-19-75 FINAL: 8-25-75, PAID $25.00 DECISION FINAL: 10-30-75 i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 08/19/1975 Docket/Case Number: N-VS-158

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 10/30/1975 Sanctions Ordered: Monetary/Fine $25.00 Other Sanctions Ordered: Sanction Details: FIRM PAID $25.00 FINE. i Disclosure 322 of 359 Reporting Source: Regulator Current Status: Final Allegations:

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/27/1972 Docket/Case Number: N-V-221

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 11/20/1972 Sanctions Ordered: Monetary/Fine $25.00 Other Sanctions Ordered: Sanction Details: Regulator Statement NASDAQ COMPLAINT N-V-221 FILED 7/27/72 10/27/72 - FINED $25.00 11/20/72 - PAID, FINAL i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 07/27/1972 Docket/Case Number: N-V-221

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision

Resolution Date: 11/20/1972 Sanctions Ordered: Monetary/Fine $25.00 Other Sanctions Ordered: Sanction Details: FIRM WAS FINED $25.00. i Disclosure 323 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 12/03/1965 Docket/Case Number: SC-6

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 01/06/1966 Sanctions Ordered: Censure Monetary/Fine $100.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #SC-6 FILED 12/3/65 12/7/65 - CENSURED, FINED $100.00 1/6/66 - TO BE FINAL FINAL - FINE PAID i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 506 www.finra.org/brokercheck User Guidance

Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 12/03/1965 Docket/Case Number: SC-6

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 01/06/1966 Sanctions Ordered: Censure Monetary/Fine $100.00 Other Sanctions Ordered: Sanction Details: FIRM CENSURED AND FINED $100.00. i Disclosure 324 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/27/1964 Docket/Case Number: MV-5

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision

Resolution Date: 02/19/1964 Sanctions Ordered: Monetary/Fine $50.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MV-5 FILED 1/27/64 2/19/64: FINED $50 3/20/64: FINAL FINE PAID i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 01/27/1964 Docket/Case Number: MV-5

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 02/19/1964 Sanctions Ordered: Monetary/Fine $50.00 Other Sanctions Ordered: Sanction Details: FIRM FINED $50.00. i Disclosure 325 of 359 Reporting Source: Regulator Current Status: Final Allegations:

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/15/1963 Docket/Case Number: A-241

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 05/16/1964 Sanctions Ordered: Monetary/Fine $300.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #A-241 FILED 10/15/63 BEVERLY HILLS OFFICE 4/16/64: FINED $300, ASSESSED $42 5/16/64: FINAL 4/28/64: PAID i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 10/15/1963 Docket/Case Number: A-241

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 05/16/1964 Sanctions Ordered: Monetary/Fine $300.00 Other Sanctions Ordered: Sanction Details: BEVERLY HILLS CA OFFICE. FINE $300.00; ASSESSED $42.00. i Disclosure 326 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 08/28/1963 Docket/Case Number: A-236

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 08/28/1964 Sanctions Ordered: Censure Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #A-236 FILED 8/28/63 BEVERLY HILLS OFFICE 2/28/64 - CENSURED 3/27/64 - B/G CALLED FOR REVIEW 8/10/64 - CENSURED, FINED $2,000 8/28/64 - FINAL, PAID i Reporting Source: Firm ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 510 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 08/28/1963 Docket/Case Number: A-236

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 08/28/1964 Sanctions Ordered: Censure Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: BEVERLY HILLS, CALIFORNIA OFFICE.

CENSURE AND FINE. i Disclosure 327 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 08/20/1963 Docket/Case Number: B-186

Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 04/17/1964 Sanctions Ordered: Monetary/Fine $200.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #B-186 FILED 8/20/63 BOSTON OFFICE 4/17/64: FINED $200 ASSESSED $30.50 FINAL 4/1/64 - PAID i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 08/20/1963 Docket/Case Number: B-186

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 04/17/1964 Sanctions Ordered: Monetary/Fine $200.00 Other Sanctions Ordered: Sanction Details: BOSTON, MASSACHUSETTS OFFICE.

FINED $200.00; ASSESSED $30.50.

i Disclosure 328 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/16/1982 Docket/Case Number: ATL-666-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 11/16/1982 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #ATL-666-AWC FILED 11/16/82 DIST. #7 DECISION CENSURED. i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 11/16/1982 Docket/Case Number: ATL-666-AWC

Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/16/1982 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: FIRM WAS CENSURED. DISTRICT NO. 7. i Disclosure 329 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/12/1963 Docket/Case Number: NY-772

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 12/11/1964 Sanctions Ordered: Censure Monetary/Fine Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #NY-772 FILED 4/12/63 8/21/63 - CENSURED ©2021 FINRA. All rights reserved. Report about9/29/63 LEHMAN - TO BROTHERS BE FINAL INC. 514 6/24/64 - B/G CALLED FOR REVIEW 12/11/64 - CENSURED AND FINED www.finra.org/brokercheck User Guidance

Regulator Statement COMPLAINT #NY-772 FILED 4/12/63 8/21/63 - CENSURED 9/29/63 - TO BE FINAL 6/24/64 - B/G CALLED FOR REVIEW 12/11/64 - CENSURED AND FINED i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 04/12/1963 Docket/Case Number: NY-772

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 12/11/1964 Sanctions Ordered: Censure Other Sanctions Ordered: FINE OF UNKNOWN AMOUNT (CONVERSION). Sanction Details: FIRM WAS CENSURED AND FINED. i Disclosure 330 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/08/1973 Docket/Case Number: NY-1755

Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Dismissed Resolution Date: 11/02/1974 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Other Sanctions Ordered: Sanction Details: BOARD OF GOVERNORS AFFIRMED APPEALED DBCC DECISION RENDERED OCTOBER 3, 1974, WHEREIN DBCC DISMISSED ALLEGATIONS THAT RESPONDENT FAILED TO PAY PROFITS OF $2,356.58 TO THE COMPLAINANT RESULTING FROM A BUY-IN SHARES FOR THE ACCOUNT OF COMPLAINANT. DECISION BECAME FINAL NOVEMBER 2, 1974 Regulator Statement COMPLAINT #NY-1755 FILED 5/8/73 i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION) Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC Date Initiated: 05/08/1973 Docket/Case Number: NY-1755

Principal Product Type: Other Other Product Type(s): UNKNOWN Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief UNKNOWN (CONVERSION) Sought:

Resolution: Order Resolution Date: 05/08/1973 Sanctions Ordered: Other Sanctions Ordered: Sanction Details: UNKNOWN Firm Statement UNKNOWN (CONVERSION). NO INFORMATION OR DOCUMENTS AVAILABLE. i Disclosure 331 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/03/1972 Docket/Case Number: N-V-250

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 02/13/1973 Sanctions Ordered: Monetary/Fine $25.00 Other Sanctions Ordered: Sanction Details: Regulator Statement NASDAQ COMPLAINT N-V-250 FILED 10/3/72 11/15/72 - FINED $25.00 2/13/73 - FINAL 3/14/73 - PAID i Reporting Source: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 517 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 10/03/1972 Docket/Case Number: N-V-250

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 02/13/1973 Sanctions Ordered: Monetary/Fine $25.00 Other Sanctions Ordered: Sanction Details: FIRM WAS FINED $25.00. i Disclosure 332 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 08/01/1961 Docket/Case Number: NY-442

Resolution: Decision Resolution Date: 01/28/1962 Sanctions Ordered: Censure Monetary/Fine $100.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #NY-442 FILED 8/1/61 DECISION RENDERED 12/29/61, CENSURED AND FINED $100 FINAL 1/28/62 CHECK IN THE AMOUNT OF $100.00 RECEIVED RE MEMO 1/8/62 i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 08/01/1961 Docket/Case Number: NY-442

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 01/28/1962 Sanctions Ordered: Censure Monetary/Fine $100.00 Other Sanctions Ordered: Sanction Details: FIRM WAS CENSURED AND FINED. i Disclosure 333 of 359

Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/07/1977 Docket/Case Number: CA-613

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 07/29/1981 Sanctions Ordered: Censure Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #CA-613 FILED 04/07/77 DIST. #2S DECISION 11/18/77: CENSURED: FINED $2,500: ASSESSED COSTS OF $410 01/01/78: TO BE FINAL FINES & COSTS 07/29/81 FC 7932 PD APPEAL ACTION 12/02/77: CALLED FOR REVIEW i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 04/07/1977 Docket/Case Number: CA-613

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 07/29/1981 Sanctions Ordered: Censure Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: FIRM CENSURED AND FINED; ASSESSED COSTS OF $410.00. i Disclosure 334 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/20/1973 Docket/Case Number: N-V-321

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 11/15/1973 Sanctions Ordered: Monetary/Fine $25.00 Other Sanctions Ordered: Sanction Details: Regulator Statement NASDAQ COMPLAINT N-V-321 FILED 7/20/73 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 521 10-1-73: FINED $25.00 11-15-73: FINAL www.finra.org/brokercheck User Guidance

Regulator Statement NASDAQ COMPLAINT N-V-321 FILED 7/20/73 10-1-73: FINED $25.00 11-15-73: FINAL i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 07/20/1973 Docket/Case Number: N-V-321

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 11/15/1973 Sanctions Ordered: Monetary/Fine $25.00 Other Sanctions Ordered: Sanction Details: FIRM WAS FINED $25.00. i Disclosure 335 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/09/1973 Docket/Case Number: N-V-275

Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 07/20/1973 Sanctions Ordered: Monetary/Fine $25.00 Other Sanctions Ordered: Sanction Details: Regulator Statement NASDAQ COMPLAINT #N-V-275 FILED 4-9-73 6-5-73: FINED $25.00 7-3-73: PAID 7-20-73: FINAL i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 04/09/1973 Docket/Case Number: N-V-275

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 07/20/1973 Sanctions Ordered: Monetary/Fine $25.00 Other Sanctions Ordered: Sanction Details: FIRM WAS FINED $25.00. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 523 www.finra.org/brokercheck User Guidance

Sanction Details: FIRM WAS FINED $25.00. i Disclosure 336 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/30/1967 Docket/Case Number: NY-1071

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 01/03/1969 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #NY-1071 FILED 11/30/67 DECISION 12/4/68 - FINED $1,000.00 AND ASSESSED $40.95 1/3/69 DEC. FINAL - FINES AND COSTS PAID. (TRANSFERRED FROM KUHN LOEB INCORPORATED) i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 11/30/1967 Docket/Case Number: NY-1071

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 01/03/1969 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: FIRM FINED $1,000.00 AND ASSESSED $40.95. i Disclosure 337 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/18/1962 Docket/Case Number: NY-515

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 08/09/1962 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details:

©2021Regulator FINRA. Statement All rights reserved. Report aboutCOMPLAINT LEHMAN BROTHERS #NY-515 INC. FILED 10/12/61 525 AMENDED - COMP. FILED 1/18/62 DEC. 7/9/62 - CENSURED AND FINED $3,000.00 TO BE FINAL 8/9/62 CHECK FOR $3,000.00 REC'D RE MEMO 7/30/62 FINE PAID RE MEMO 8/6/62 www.finra.org/brokercheck User Guidance

Regulator Statement COMPLAINT #NY-515 FILED 10/12/61 AMENDED - COMP. FILED 1/18/62 DEC. 7/9/62 - CENSURED AND FINED $3,000.00 TO BE FINAL 8/9/62 CHECK FOR $3,000.00 REC'D RE MEMO 7/30/62 FINE PAID RE MEMO 8/6/62 i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 01/18/1962 Docket/Case Number: NY-515

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 08/09/1962 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: FIRM CENSURED AND FINED $3,000.00. i Disclosure 338 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: CHICAGO BOARD OF OPTION EXCHANGE Date Initiated: 10/25/1979

Docket/Case Number: 79-0100

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 10/25/1979 Sanctions Ordered: Monetary/Fine $4,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement CBOE (FILE NO. 79-0100) 10/25/79 CONSENTS TO BEING FINED $4,000 (TRANSFERRED FROM LEHMAN BROTHERS KUHN LOEB INC.) i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 10/25/1979 Docket/Case Number: 70-0100

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 10/25/1979 Sanctions Ordered: Monetary/Fine $4,000.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 527 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: FIRM CONSENTED TO A $4,000.00 FINE. i Disclosure 339 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: CHICAGO BOARD OF OPTION EXCHANGE Date Initiated: 12/24/1981 Docket/Case Number: 81-0047

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/24/1981 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement CHICAGO BOARD OPTIONS EXCHANGE, INC. FILE NO. 81-0047, ISSUED DECEMBER 24, 1981. THE BUSINESS CONDUCT COMMITTEE OF THE CBOE AGREED TO ACCEPT THE OFFER OF SETTLEMENT SUBMITTED BY LEHMAN BROTHERS KUHN LOEB INC. IN WHICH THE FIRM NEITHER ADMITTED OR DENIED THE ALLEGATIONS BROUGHT BY THE EXCHANGE'S STAFF. THE EXCHANGE'S STAFF HAD ALLEGED THAT LEHMAN BROTHERS ENTERED INTO OPENING PURCHASE TRANSACTIONS IN THE GENERAL ELECTRIC COMPANY CLASS OF CALL OPTION CONTRACTS ON NOVEMBER 28, 1980, IN WHICH LEHMAN BROTHERS CAUSED TO HOLD, CONTROL OR BE OBLIGATED WITH RESPECT TO AN AGGREGATED LONG POSITION OF 2,112 GE CALL OPTION CONTRACTS. THE COMMITTEE DETERMINED THAT THE FIRM'S ACTION CONSTITUTED A VIOLATION OF EXCHANGE RULE 4.11 AND ACCEPTED THE ©2021 FINRA. All rights reserved. Report aboutFIRM'S LEHMAN OFFER BROTHERS OF SETTLEMENT INC. IN WHICH LEHMAN BROTHERS 528 CONSENTED TO A $2,000 FINE. CHICAGO BOARD OPTIONS EXCHANGE, INC. FILE NO. 81-0047, ISSUED DECEMBER 24, 1981. THE BUSINESS CONDUCT COMMITTEE OF THE CBOE AGREED TO ACCEPT THE OFFER OF SETTLEMENT SUBMITTED BY LEHMAN BROTHERS KUHN LOEB INC. IN WHICH THE FIRM NEITHER ADMITTED OR DENIED THE ALLEGATIONS BROUGHT BY THE EXCHANGE'S STAFF. THE EXCHANGE'S STAFF HAD ALLEGED THAT LEHMAN BROTHERS ENTERED INTO OPENING PURCHASE TRANSACTIONS IN THE GENERAL ELECTRIC COMPANY CLASS OF CALL OPTION CONTRACTS ON NOVEMBER 28, 1980, IN WHICH www.finra.org/brokercheck LEHMAN BROTHERS CAUSED TO HOLD, CONTROL OR BE OBLIGATED WITH User Guidance RESPECT TO AN AGGREGATED LONG POSITION OF 2,112 GE CALL OPTION CONTRACTS. THE COMMITTEE DETERMINED THAT THE FIRM'S ACTION CONSTITUTED A VIOLATION OF EXCHANGE RULE 4.11 AND ACCEPTED THE FIRM'S OFFER OF SETTLEMENT IN WHICH LEHMAN BROTHERS CONSENTED TO A $2,000 FINE. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT LEHMAN BROTHERS HAD ENTERED INTO OPENING PURCHASE TRANSACTIONS IN THE GENERAL ELECTRIC COMPANY CLASS OF CALL OPTION CONTRACTS ON NOVEMBER 28TH, 1980 IN WHICH THE FIRM CAUSED TO HOLD, CONTROL OR BE OBLIGATED WITH RESPECT TO AN AGGREGATED LONG POSITION OF 2112 GENERAL ELECTRIC CALL OPTION CONTRACTS. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 12/24/1981 Docket/Case Number: 81-0047

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION; FINE. Sought:

Resolution: Consent Resolution Date: 12/24/1981 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: THE CBOE DETERMINED THAT THE FIRM'S ACTION CONSTITUTED A VIOLATION OF EXCHANGE RULE 4.11; THE CBOE ACCEPTED THE FIRM'S OFFER OF SETTLEMENT IN WHICH LEHMAN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, CONSENTED TO A $2,000.00 FINE. i Disclosure 340 of 359 Reporting Source: Regulator Current Status: Final Allegations: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 529 www.finra.org/brokercheck User Guidance

Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/05/1973 Docket/Case Number: N-BA-39

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought:

Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 01/31/1974 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: ASSESSED $58.50. Sanction Details: FIRM WAS FINED AND ASSESSED AS INDICATED ABOVE. COMBINED WITH N-BA-38; JOINT DECISION. i Disclosure 341 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/31/1973 Docket/Case Number: N-BA-38

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 01/31/1974 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement TRANSFERRED FROM LEHMAN BROTHERS INCORPORATED NASDAQ COMPLAINT N-BA-38 FILED 5/31/73 NASDAQ COMPLAINT N-BA-39 FILED 7/5/73 JOINT DECISION 12/17/73: FINED $500 ASSESSED $58.50 1/31/74: FINAL ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 531 TRANSFERRED FROM LEHMAN BROTHERS INCORPORATED www.finra.org/brokercheck NASDAQ COMPLAINT N-BA-38 FILED 5/31/73 User Guidance NASDAQ COMPLAINT N-BA-39 FILED 7/5/73 JOINT DECISION 12/17/73: FINED $500 ASSESSED $58.50 1/31/74: FINAL i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 05/31/1973 Docket/Case Number: N-BA-38

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 01/31/1974 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: ASSESSED $58.50. Sanction Details: FINED AND ASSESSED AS INDICATED ABOVE. COMBINED WITH N-BA-39; JOINT DECISION. i Disclosure 342 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 07/19/1977 Docket/Case Number:

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 07/19/1977 Regulator Statement TRANSFERRED FROM LEHMAN BROTHERS INCORPORATED ND 77-138 7/19/77 REL. 34-13770, 13769 PUBLIC ADMINISTRATIVE PROCEEDINGS ORDERED. FIRM CONSENTED WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, TO FINDINGS THAT IT VIOLATED THE BOOKS AND RECORDS PROVISIONS OF THE SECURITIES EXCHANGE ACT OF 1934 AND HAS BEEN ORDERED BY THE COMMISSION TO INSTITUTE CERTAIN RECORD-KEEPING PROCEDURE TO AVOID A REPETITION OF THIS TYPE OF SITUATION. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF BOOKS AND RECORDS PROVISIONS OF THE SECURITIES EXCHANGE ACT OF 1934. Initiated By: SEC Date Initiated: 07/19/1977 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RULE VIOLATION. Sought:

Resolution: Consent Resolution Date: 07/19/1977 Sanctions Ordered: Other Sanctions Ordered: ORDER BY SEC FOR FIRM TO INSTITUTE CERTAIN RECORDKEEPING PROCEDURES TO AVOID A REPETITION OF SITUATION. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 533 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: ORDER BY SEC FOR FIRM TO INSTITUTE CERTAIN RECORDKEEPING PROCEDURES TO AVOID A REPETITION OF SITUATION. Sanction Details: SEE ABOVE. i Disclosure 343 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 12/31/1981 Docket/Case Number: Unknown

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/31/1981 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Regulator Statement SEC NEWS DIGEST: DECEMBER 31, 1981 ISSUE 81-250 THE COMMISSION HAS ACCEPTED THE OFFERS OF SETTLEMENT MADE BY SHEARSON/AMERICAN EXPRESS INC., ROBERT W. HOPE, AND K. JAMES POND IN ITS ORDER FOR PUBLIC PROCEEDINGS ON DEC. 31, 1981. THE DEFENDANTS, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, CONSENTED TO THE COMMISSION FINDINGS THAT HOPE AND POND, FORMER REGISTERED REPRESENTATIVES WITH SHEARSON/AMERICAN EXPRESS, VIOLATED SECTIONS 5 (a), 5 (c), 17(a)(3) OF THE SEC ACT OF 1933 AND SHEARSON FAILED TO SUPERVISE HOPE AND POND WITH A VIEW TO PREVENTING SUCH VIOLATIONS. THE COMPLAINT CENTERED ON THE ACCURACY OF CERTAIN REPRESENTATIONS MADE TO CUSTOMERS OF HOPE AND POND IN CONNECTION WITH THE SALE OF INTERESTS IN A LIMITED PARTNERSHIP ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 534 CALLED COMMODITY ARBITRAGE. THE TWO AGENTS AND SHEARSON FAILED TO PROVIDE A REGISTRATION STATEMENT AS REQUIRED BY THE SEC ACT. THE COMMISSION HAS SUSPENDED HOPE AND POND FROM ASSOCIATION WITH ANY BROKER-DEALER, INVESTMENT ADVISER, INVESTMENT COMPANY, OR MUNICIPAL SECURITIES DEALER FOR A PERIOD OF TWO WEEKS. THE COMMISSION CENSURED SHEARSON AND ORDERED IT TO COMPLY WITH THE UNDERTAKINGS DESCRIBED IN ITS OFFER OF SETTLEMENT. (REL. 34-18354) SEC NEWS DIGEST: DECEMBER 31, 1981 ISSUE 81-250 THE COMMISSION HAS ACCEPTED THE OFFERS OF SETTLEMENT MADE BY SHEARSON/AMERICAN EXPRESS INC., ROBERT W. HOPE, AND K. JAMES POND IN ITS ORDER FOR PUBLIC PROCEEDINGS ON DEC. 31, 1981. THE DEFENDANTS, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, CONSENTED TO THE COMMISSION FINDINGS THAT HOPE AND POND, FORMER REGISTERED REPRESENTATIVES WITH SHEARSON/AMERICAN EXPRESS, VIOLATED SECTIONS 5 (a), www.finra.org/brokercheck 5 (c), 17(a)(3) OF THE SEC ACT OF 1933 AND SHEARSON FAILED TO User Guidance SUPERVISE HOPE AND POND WITH A VIEW TO PREVENTING SUCH VIOLATIONS. THE COMPLAINT CENTERED ON THE ACCURACY OF CERTAIN REPRESENTATIONS MADE TO CUSTOMERS OF HOPE AND POND IN CONNECTION WITH THE SALE OF INTERESTS IN A LIMITED PARTNERSHIP CALLED COMMODITY ARBITRAGE. THE TWO AGENTS AND SHEARSON FAILED TO PROVIDE A REGISTRATION STATEMENT AS REQUIRED BY THE SEC ACT. THE COMMISSION HAS SUSPENDED HOPE AND POND FROM ASSOCIATION WITH ANY BROKER-DEALER, INVESTMENT ADVISER, INVESTMENT COMPANY, OR MUNICIPAL SECURITIES DEALER FOR A PERIOD OF TWO WEEKS. THE COMMISSION CENSURED SHEARSON AND ORDERED IT TO COMPLY WITH THE UNDERTAKINGS DESCRIBED IN ITS OFFER OF SETTLEMENT. (REL. 34-18354) i Reporting Source: Firm Current Status: Final Allegations: ALLEGED FAILURE BY SHEARSON/AMERICAN EXPRESS INC. TO REASONABLY SUPERVISE FORMER EMPLOYEES IN CONNECTION WITH A LLP CALLED COMMODITY ARBITRAGE. Initiated By: SEC Date Initiated: 12/31/1981 Docket/Case Number: 3-6083 (REL. 34-18354)

Principal Product Type: Direct Investment(s) - DPP & LP Interest(s) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/31/1981 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: FIRM WAS CENSURED FOR ALLEGED FAILURE TO REASONABLY SUPERVISE AS DESCRIBED ABOVE. i Disclosure 344 of 359 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 535 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: Initiated By: COMMODITY FUTURES TRADE COMMISSION Date Initiated: 12/22/1977 Docket/Case Number: 78-11

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/19/1981 Sanctions Ordered: Monetary/Fine Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: Regulator Statement CFTC DOCKET NO. 78-11 MARCH 19, 1981 ADMINISTRATIVE PROCEEDING COMMENCED ON DEC. 22, 1977, BY THE FILING OF A COMPLAINT AND NOTICE OF HEARING PURSUANT TO SECTION 6(b), 6(c), AND 8a(3) OF THE COMMODITY EXCHANGE ACT, AS AMENDED 7 U.S.C. 19, 13b, AND 12a(3). PURSUANT TO SECTION 10.108 OF THE COMMISSION'S RULES OF PRACTICE, 17 CFR 10.108, THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT IN WHICH THE FIRM SOLELY FOR THE PURPOSE OF THE INSTANT PROCEEDING, EXCEPT THAT OFFICIAL NOTICE HERE OF MAY BE TAKEN IN ANY SUBSEQUENT REGULATORY PROCEEDING TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT AND NOTICE OF HEARING HAS CONSENTED TO ENTRY OF AN OPINION AND ORDER MAKING FINDINGS OF VIOLATIONS AND IMPOSING SANCTIONS AS SPECIFIED IN THE FIRM'S OFFER OF SETTLEMENT.THE COMMISSION HAS DETERMINED TO ACCEPT THE FIRM'S OFFER OF SETTLEMENT. IT IS ORDERED ON MARCH 19, 1981 THE FIRM WILL CEASE AND DESIST FROM ANY AND ALL VIOLATIONS OF SECTIONS 4d(2),4g(1) AND 4i OF THE ACT, 7 U.S.C. 6d(2), 6g(1) and 6i AND REGULATIONS 1.20(a), 1.21, 1.22, 1.23, 1.32, 1.46(a) AND (b), 17.00(a) AND 18.00; AND WITHIN 30 DAYS FROM THE ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 536 EFFECTIVE DATE OF THIS ORDER THE FIRM WILL PAY A CIVIL MONETARY PENALTY TO THE TREASURY OF THE UNITED STATES OF AMERICA. A VIOLATION OF ANY OF THE PROVISIONS OF THIS ORDER MAY RESULT IN FURTHER PROCEEDINGS UNDER SECTIONS 6(b), 6(c), and 8a(3) OF THE ACT, 7 U.S.C. 9, 13b AND 12a-3. CFTC DOCKET NO. 78-11 MARCH 19, 1981 ADMINISTRATIVE PROCEEDING COMMENCED ON DEC. 22, 1977, BY THE FILING OF A COMPLAINT AND NOTICE OF HEARING PURSUANT TO SECTION 6(b), 6(c), AND 8a(3) OF THE COMMODITY EXCHANGE ACT, AS AMENDED 7 U.S.C. 19, 13b, AND 12a(3). PURSUANT TO SECTION 10.108 OF THE COMMISSION'S RULES OF PRACTICE, 17 CFR 10.108, THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT IN WHICH THE FIRM SOLELY FOR THE PURPOSE OF THE INSTANT PROCEEDING, EXCEPT THAT OFFICIAL NOTICE HERE OF MAY BE TAKEN IN ANY SUBSEQUENT REGULATORY PROCEEDING TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT AND NOTICE OF HEARING HAS CONSENTED TO ENTRY OF AN OPINION AND ORDER MAKING FINDINGS OF VIOLATIONS AND IMPOSING SANCTIONS AS SPECIFIED IN THE FIRM'S OFFER OF SETTLEMENT.THE COMMISSION HAS DETERMINED TO ACCEPT THE www.finra.org/brokercheck FIRM'S OFFER OF SETTLEMENT. IT IS ORDERED ON MARCH 19, 1981 THE User Guidance FIRM WILL CEASE AND DESIST FROM ANY AND ALL VIOLATIONS OF SECTIONS 4d(2),4g(1) AND 4i OF THE ACT, 7 U.S.C. 6d(2), 6g(1) and 6i AND REGULATIONS 1.20(a), 1.21, 1.22, 1.23, 1.32, 1.46(a) AND (b), 17.00(a) AND 18.00; AND WITHIN 30 DAYS FROM THE EFFECTIVE DATE OF THIS ORDER THE FIRM WILL PAY A CIVIL MONETARY PENALTY TO THE TREASURY OF THE UNITED STATES OF AMERICA. A VIOLATION OF ANY OF THE PROVISIONS OF THIS ORDER MAY RESULT IN FURTHER PROCEEDINGS UNDER SECTIONS 6(b), 6(c), and 8a(3) OF THE ACT, 7 U.S.C. 9, 13b AND 12a-3. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATION OF SECTIONS 4D(2), 4G(1) AND 4I OF THE COMMODITY EXCHANGE ACT AND REGULATIONS THEREUNDER. Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 12/22/1977 Docket/Case Number: 78-11

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 03/19/1981 Sanctions Ordered: Cease and Desist/Injunction Other Sanctions Ordered: MONETARY FINE IN UNKNOWN AMOUNT (CONVERSION). Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN OPINION AND ORDER MAKING FINDINGS OF VIOLATIONS AND IMPOSING SANCTIONS. FIRM TO CEASE AND DESIST FROM MAKING FUTURE VIOLATIONS; FIRM TO PAY MONETARY PENALTY. i Disclosure 345 of 359 Reporting Source: Regulator Current Status: Final Allegations: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 537 www.finra.org/brokercheck User Guidance

Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/11/1976 Docket/Case Number: 562

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 05/17/1977 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #562 FILED 03/11/76 DIST. #8 DECISION 05/17/77: CENSURED; FINED $1,000 ALL RIGHTS WAIVED. 05/17/77: FINAL FINES & COSTS 06/20/77: FC# 6820 PD i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 03/11/1976 Docket/Case Number: 562

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 538 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 05/17/1977 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: FIRM WAS CENSURED AND FINED $1,000.00. i Disclosure 346 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: MISSOURI Date Initiated: 05/19/1983 Docket/Case Number: AO-83-33 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 05/19/1983 Regulator Statement CONSENT ORDER FILE NO. AO-83-33 ON MAY 19, 1983 THE COMMISSIONER OF SECURITIES ENTERED INTO A CONSENT ORDER WITH RESPONDENT WHEREBY RESPONDENT AGREED TO SUBMIT A SUM TO THE DIRECTOR OF REVENUE EQUAL TO THE AMOUNT OF SHEARSON'S SHARE OF THE COMMISSIONS EARNED ON THE NINE TRANSACTIONS THAT WERE EFFECTED BY EXPIRED AGENTS. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 539 CONSENT ORDER FILE NO. AO-83-33 ON MAY 19, 1983 THE COMMISSIONER OF SECURITIES ENTERED INTO A www.finra.org/brokercheck CONSENT ORDER WITH RESPONDENT WHEREBY RESPONDENT AGREED User Guidance TO SUBMIT A SUM TO THE DIRECTOR OF REVENUE EQUAL TO THE AMOUNT OF SHEARSON'S SHARE OF THE COMMISSIONS EARNED ON THE NINE TRANSACTIONS THAT WERE EFFECTED BY EXPIRED AGENTS. i Reporting Source: Firm Current Status: Final Allegations: IT WAS FOUND THAT THE LICENSES OF FOUR SHEARSON/AMERICAN EXPRESS AGENTS WERE ALLOWED TO EXPIRE AND THAT NINE TRANSACTIONS WERE EFFECTED BY THESE AGENTS AFTER SHEARSON WAS NOTIFIED OF THE EXPIRATIONS. Initiated By: STATE OF MISSOURI Date Initiated: 05/19/1983 Docket/Case Number: A0-83-33

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Disgorgement Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 05/19/1983 Sanctions Ordered: Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHEARSON/AMERICAN EXPRESS CONSENTED TO THE FINDING; THE FIRM CONSENTED TO A FINDING THAT IT HAD FAILED TO REASONABLY SUPERVISE ITS AGENTS AND AGREED TO SUBMIT $2,286.79 TO THE DIRECTOR OF REVENUE (AN AMOUNT EQUAL TO THE AMOUNT OF THE FIRM'S SHARE OF THE COMMISSIONS EARNED ON THE NINE TRANSACTIONS). i Disclosure 347 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: SECURITIES AND EXCHANGE COMMISSION ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 540 www.finra.org/brokercheck User Guidance

Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/30/1980 Docket/Case Number: Unknown

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/30/1980 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Regulator Statement ND - 80-196 - 10/8/80 - (REL 34-17180, 34-17181, 34-17182) 9/30/80 - COMMISSION INSTITUTED PUBLIC ADMINISTRATIVE PROCEEDINGS AND ACCEPTED OFFER OF SETTLEMENT. RESPONDENT CONSENTED TO OFFER OF SETTLEMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. RESPONDENT CENSURED. i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: SEC Date Initiated: 09/30/1980 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/30/1980 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: COMMISSION INSTITUTED PUBLIC ADMINISTRATIVE PROCEEDINGS AND ACCEPTED OFFER OF SETTLEMENT. RESPONDENT CONSENTED TO OFFER OF SETTLEMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS; RESPONDENT CONSENTED TO THE PENALTY OF CENSURE i Disclosure 348 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 12/01/1980 Docket/Case Number: Unknown

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 12/01/1980 Sanctions Ordered: Monetary/Fine $200.00 Other Sanctions Ordered: Sanction Details: Regulator Statement 12/1/80: ASE FINED RESPONDENT MEMBER $200. 12/1/80: DECISION FINAL i Reporting Source: Firm

Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 12/01/1980 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 12/01/1980 Sanctions Ordered: Monetary/Fine $200.00 Other Sanctions Ordered: Sanction Details: FIRM WAS FINED $200.00. i Disclosure 349 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 08/05/1981 Docket/Case Number: NY-2041

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 09/14/1982 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #NY-2041 FILED 8/5/81 DISTRICT 12 9/14/82: CENSURED i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 08/05/1981 Docket/Case Number: NY-2041

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 09/14/1982 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: FIRM WAS CENSURED. i Disclosure 350 of 359 Reporting Source: Regulator Current Status: Final Allegations: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 544 www.finra.org/brokercheck User Guidance

Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/18/1977 Docket/Case Number: AWC-224

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 04/18/1977 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #AWC-224 FILED 04/18/77 DIST. #12 DECISION 04/18/77: CENSURED; FINED $7,500 04/18/77: FINAL FINES & COSTS 05/04/77: FC# 6804 PD i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 04/18/1977 Docket/Case Number: AWC-224

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought:

Other Sanction(s)/Relief FINE. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/18/1977 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: FIRM WAS CENSURED AND FINE $7,500.00. i Disclosure 351 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: WISCONSIN Date Initiated: 01/20/1983 Docket/Case Number: X-1682 URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 01/20/1983 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Regulator Statement CENSURED BY THE COMMISSIONER IN A CONSENT ORDER ISSUED ON JAN. 20, 1983. THE ORDER WAS BASED ON STAFF ALLEGATIONS THAT RESPONDENT WILFULLY OFFERED AND SOLD TO THREE PERSONS IN WISCONSIN, IN THE FORM OF SHARES OF COMMON STOCK, THAT WERE ©2021 FINRA. All rights reserved. Report aboutNOT LEHMAN BROTHERS INC. 546 REGISTERED; FAILED TO FILE THE APPROPRIATE FORM WITH THE COMMISSIONER TO REPORT THE SALES OF THE COMMON STOCK; EFFECTED AT LEAST 164 SECURITIES TRANSACTIONS IN THE ACCOUNTS OF AT LEAST TWO PERSONS IN WISCONSIN THROUGH 2 SECURITIES AGENTS EMPLOYED BY RESPONDENT WHO WERE NOT LICENSED AS SECURITIES AGENTS IN WISCONSIN; AND FAILED TO REASONABLY SUPERVISE ITS AGENTS. WISCONSIN SECURITIES BULLETIN VOL 11, NO. 2. www.finra.org/brokercheck CENSURED BY THE COMMISSIONER IN A CONSENT ORDER ISSUED ON User Guidance JAN. 20, 1983. THE ORDER WAS BASED ON STAFF ALLEGATIONS THAT RESPONDENT WILFULLY OFFERED AND SOLD TO THREE PERSONS IN WISCONSIN, IN THE FORM OF SHARES OF COMMON STOCK, THAT WERE NOT REGISTERED; FAILED TO FILE THE APPROPRIATE FORM WITH THE COMMISSIONER TO REPORT THE SALES OF THE COMMON STOCK; EFFECTED AT LEAST 164 SECURITIES TRANSACTIONS IN THE ACCOUNTS OF AT LEAST TWO PERSONS IN WISCONSIN THROUGH 2 SECURITIES AGENTS EMPLOYED BY RESPONDENT WHO WERE NOT LICENSED AS SECURITIES AGENTS IN WISCONSIN; AND FAILED TO REASONABLY SUPERVISE ITS AGENTS. WISCONSIN SECURITIES BULLETIN VOL 11, NO. 2. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED SHEARSON/AMERICAN EXPRESS SOLD UNREGISTERED SECURITIES BY UNREGISTERED AGENTS IN VIOLATION OF WISCONSIN STATUTES. Initiated By: STATE OF WISCONSIN Date Initiated: 01/20/1983 Docket/Case Number: X-1682

Principal Product Type: Other Other Product Type(s): NOT SPECIFIED. Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 01/20/1983 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS MADE BY THE STATE, SHEARSON/AMERICAN EXPRESS CONSENTED TO A FINDING THAT IT FAILED TO COMPLY WITH THE RELEVANT STATUTES; THE FIRM WAS CENSURED.

i Disclosure 352 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/10/1980 Docket/Case Number: ATL-625

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 03/18/1982 Sanctions Ordered: Monetary/Fine Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #ATL-625 FILED 6-10-80 DISTRICT #7 PAID FC# 8157 3/18/82 i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 06/10/1980 Docket/Case Number: ATL-625

Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 03/18/1982 Sanctions Ordered: Other Sanctions Ordered: FINE OF UNKNOWN AMOUNT (CONVERSION). Sanction Details: FIRM WAS FINED AN UNKNOWN AMOUNT (CONVERSION). i Disclosure 353 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: FLORIDA Date Initiated: 06/12/1979 Docket/Case Number: Unknown URL for Regulatory Action: Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 06/12/1979 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: Regulator Statement FLORIDA CRIMINAL ACTION REPORT 6/12/79 PAGE 69 ©2021 FINRA. All rights reserved. Report aboutDEALER LEHMAN CENSURED BROTHERS INC.LETTER. 549 www.finra.org/brokercheck User Guidance

Regulator Statement FLORIDA CRIMINAL ACTION REPORT 6/12/79 PAGE 69 DEALER CENSURED LETTER. i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: STATE OF FLORIDA Date Initiated: 06/12/1979 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 06/12/1979 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: FLORIDA CRIMINAL ACTION REPORT JUNE 12TH, 1979.

FIRM WAS CENSURED. i Disclosure 354 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/31/1976 Docket/Case Number: 564

Principal Product Type:

Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 04/16/1977 Sanctions Ordered: Censure Monetary/Fine Other Sanctions Ordered: Sanction Details: Regulator Statement COMPLAINT #564 FILED 03/31/76 DIST. #8 DECISION 03/02/77: CENSURED: ASSESSED COSTS $830.25 04/16/77: TO BE FINAL 04/16/77: FINAL FINES & COSTS 05/02/77: FC# 6800 PAID. i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 03/31/1976 Docket/Case Number: 564

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Sanctions Ordered: Censure Other Sanctions Ordered: ASSESSED COSTS OF $830.25; FINE OF UNKNOWN AMOUNT (CONVERSION). Sanction Details: FIRM WAS CENSURED AND FINED. i Disclosure 355 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: CHICAGO BOARD OF OPTION EXCHANGE Date Initiated: 04/23/1979 Docket/Case Number: 79-0010

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 04/23/1979 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement CBOE FILE NO. 79-0010 4/23/79 CONSENTS TO BEING FINED $1,000 i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: CHICAGO BOARD OPTIONS EXCHANGE

Date Initiated: 04/23/1979 Docket/Case Number: 79-0010

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 04/23/1979 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: FIRM WAS CENSURED AND FINED $1,000.00. i Disclosure 356 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 04/23/1979 Docket/Case Number: 78-0154

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 04/23/1979 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 553 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: Regulator Statement CBOE FILE NOS. 78-0118 AND 78-0154 4/23/79 CONSENTS TO BEING ADMONISHED AND FINED $500 i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 04/23/1979 Docket/Case Number: 78-0154

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE; ADMONISHMENT. Sought:

Resolution: Consent Resolution Date: 04/23/1979 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: FIRM CONSENTED TO BEING FINED $500.00 AND ADMONISHED. i Disclosure 357 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 04/23/1979 Docket/Case Number: 78-0118 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 554 www.finra.org/brokercheck User Guidance

Docket/Case Number: 78-0118

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 04/23/1979 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement CBOE FILE NOS. 78-0118 AND 78-0154 4/23/79 CONSENTS TO BEING ADMONISHED AND FINED $500 i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 04/23/1979 Docket/Case Number: 78-0118

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE; ADMONISHMENT. Sought:

Resolution: Consent Resolution Date: 04/23/1979 Sanctions Ordered: Monetary/Fine $500.00

Other Sanctions Ordered: Sanction Details: FIRM CONSENTED TO BEING ADMONISHED AND FINED $500.00. i Disclosure 358 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: Docket/Case Number:

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: Sanctions Ordered: Monetary/Fine $4,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement NO DATE, NYSE: (03/18/77 BULLETIN) FINED $4,000 BY CONSENT. (DEC. 76-61) i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 03/18/1977 Docket/Case Number: UNKNOWN

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Consent Resolution Date: 03/18/1977 Sanctions Ordered: Monetary/Fine $4,000.00 Other Sanctions Ordered: Sanction Details: FIRM WAS FINED $4,000.00. i Disclosure 359 of 359 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/17/1960 Docket/Case Number: NY-386

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 03/06/1962 Sanctions Ordered: Censure Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement NY-386 FILED 10/17/60 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 557 03/06/62 CENSURED, FINED $500 03/15/62 PD. www.finra.org/brokercheck User Guidance

Regulator Statement NY-386 FILED 10/17/60 03/06/62 CENSURED, FINED $500 03/15/62 PD. i Reporting Source: Firm Current Status: Final Allegations: UNKNOWN (CONVERSION). Initiated By: NASD Date Initiated: 10/17/1960 Docket/Case Number: NY-386

Principal Product Type: Other Other Product Type(s): UNKNOWN (CONVERSION). Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE. Sought:

Resolution: Decision Resolution Date: 03/06/1962 Sanctions Ordered: Censure Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: FIRM WAS CENSURED AND FINED $500.00.

Civil - Final This type of disclosure event involves (1) an injunction issued by a foreign or domestic court within the last 10 years in connection with investment-related activity, (2) a finding by a court of a violation of any investment-related statute or regulation, or (3) an action dismissed by a court pursuant to a settlement agreement. Disclosure 1 of 1 Reporting Source: Regulator Current Status: Final Allegations: SEC LITIGATION RELEASE 18116, APRIL 28, 2003: THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT IT HAS SETTLED CHARGES AGAINST LEHMAN BROTHERS INC., A NEW YORK-BASED BROKERAGE FIRM AND INVESTMENT BANK, ARISING FROM AN INVESTIGATION OF RESEARCH ANALYST CONFLICTS OF INTEREST. THIS SETTLEMENT, AND SETTLEMENTS WITH NINE OTHER BROKERAGE FIRMS, ARE PART OF THE GLOBAL SETTLEMENT THE FIRMS HAVE REACHED WITH THE COMMISSION, NASD, INC., THE NEW YORK STOCK EXCHANGE, INC. ("NYSE"), THE NEW YORK ATTORNEY GENERAL, AND OTHER STATE REGULATORS. IN CONNECTION WITH THIS MATTER, THE COMMISSION FILED A COMPLAINT AGAINST LEHMAN IN THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, ALLEGING VIOLATIONS OF NASD AND NYSE RULES. ACCORDING TO THE COMMISSION'S COMPLAINT, FROM AT LEAST JULY 1999 THROUGH JUNE 2001, RESEARCH ANALYSTS AT LEHMAN WERE SUBJECT TO INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING AT THE FIRM. THE COMPLAINT ALSO ALLEGES THAT LEHMAN PUBLISHED EXAGGERATED OR UNWARRANTED RESEARCH OR RESEARCH THAT LACKED A REASONABLE BASIS AND FAILED TO MAINTAIN APPROPRIATE SUPERVISION OVER ITS RESEARCH AND INVESTMENT BANKING OPERATIONS. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Court Details: UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, CIVIL ACTION NO. 03 CV 2940 (WHP) Date Court Action Filed: 04/28/2003 Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Types: Relief Sought: Injunction Other Relief Sought: CIVIL MONETARY PENALTY;DISGORGEMENT Resolution: Judgment Rendered Resolution Date: 10/31/2003 Sanctions Ordered or Relief Monetary/Fine $25,000,000.00 ©2021Granted: FINRA. All rights reserved. Report aboutDisgorgement/Restitution LEHMAN BROTHERS INC. 559 Cease and Desist/Injunction www.finra.org/brokercheck User Guidance

Sanctions Ordered or Relief Monetary/Fine $25,000,000.00 Granted: Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions: $25,000,000 - PROCUREMENT OF INDEPENDENT RESEARCH $5,000,000 - INVESTOR EDUCATION UNDERTAKINGS Sanction Details: SEC LITIGATION RELEASE 18438, OCTOBER 31, 2003: THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT THE UNITED STATES DISTRICT JUDGE FOR THE SOUTHERN DISTRICT OF NEW YORK, ISSUED AN ORDER ON OCTOBER 31, 2003 WHEREBY LEHMAN IS PERMANENTLY ENJOINED FROM VIOLATING NASD RULES 2110, 2210, 3010, NYSE RULES 342,401, 472, 476; WILL PAY $25,000,000 AS A PENALTY; $25,000,000 AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES; $25,000,000 FOR PROCUREMENT OF INDEPENDENT RESEARCH; $5,000,000 FOR INVESTOR EDUCATION; AND AGREED TO UNDERTAKINGS REGARDING SEPARATION OF RESEARCH AND INVESTMENT BANKING,DISCLOSURE/TRANSPARENCY AND OTHER ISSUES, AND INDEPENDENT, THIRD-PARTY RESEARCH. Regulator Statement AS PART OF THE SETTLEMENT, LEHMAN HAS AGREED TO PAY $25 MILLION AS DISGORGEMENT AND AN ADDITIONAL $25 MILLION IN PENALTIES. ONE- HALF OF THE TOTAL OF THESE PAYMENTS -- $25 MILLION -- WILL BE PAID IN CONNECTION WITH THE SEC ACTION AND RELATED PROCEEDINGS BY THE NASD AND NYSE AND WILL BE PLACED INTO A DISTRIBUTION FUND FOR THE BENEFIT OF CUSTOMERS OF THE FIRM. THE REMAINDER WILL BE PAID TO RESOLVE RELATED PROCEEDINGS BY STATE REGULATORS. IN THE SEC ACTION, LEHMAN HAS AGREED TO A FEDERAL COURT ORDER THAT WILL ENJOIN THE FIRM FROM FUTURE VIOLATIONS OF NASD AND NYSE RULES AND REQUIRE THE FIRM TO MAKE CHANGES IN THE OPERATIONS OF ITS EQUITY RESEARCH AND INVESTMENT BANKING DEPARTMENTS. IN ADDITION, LEHMAN WILL PAY, OVER FIVE YEARS, $25 MILLION TO PROVIDE THE FIRM'S CLIENTS WITH INDEPENDENT RESEARCH, AND $5 MILLION TO BE USED FOR INVESTOR EDUCATION.

SEC LITIGATION RELEASE 21457, MARCH 19, 2010: THE HONORABLE JUDGE OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ISSUED AN ORDER ON MARCH 15, 2010 APPROVING MODIFICATIONS TO THE FINAL JUDGMENTS ENTERED AGAINST THE DEFENDANT AND OTHERS. THE FINAL JUDGMENTS CONTAINED AN EXTENSIVE ADDENDUM WITH PROVISIONS MANDATING STRUCTURAL AND OTHER REFORMS THAT ADDRESSED POTENTIAL CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. THE SETTLEMENT PROVIDED THAT WITH RESPECT TO ANY PROVISION THAT HAD NOT BEEN EXPRESSLY SUPERSEDED BY SUBSEQUENT RULEMAKING WITHIN FIVE YEARS, THE SEC WOULD AGREE TO AN AMENDMENT/MODIFICATION OF SUCH TERM, SUBJECT TO COURT APPROVAL, UNLESS THE SEC BELIEVES IT WOULD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 560 NOT BE IN THE PUBLIC INTEREST. THE COURT APPROVED REMOVING A NUMBER OF PROVISIONS. THE ADDENDUM NO LONGER INCLUDES PROHIBITIONS AGAINST INVESTMENT BANKING INPUT INTO RESEARCH ANALYST COMPENSATION AND THE BAR AGAINST RESEARCH ANALYSTS PARTICIPATING IN EFFORTS TO SOLICIT INVESTMENT BANKING BUSINESS, AMONG OTHER THINGS. THE MODIFIED ADDENDUM AS ORDERED BY THE COURT AND SUPPORTED BY THE SEC MAINTAINED THE REQUIREMENT THAT A CHAPERONE FROM LEGAL OR COMPLIANCE BE PRESENT WHEN INVESTMENT BANKING SEEKS THE VIEWS OF RESEARCH ANALYSTS CONCERNING A PROPOSED TRANSACTION OR A POTENTIAL CANDIDATE FOR A TRANSACTION. ONE PROPOSED MODIFICATION WOULD HAVE ALLOWED INVESTMENT BANKING TO SEEK THE VIEWS OF RESEARCH ANALYSTS REGARDING MARKET OR INDUSTRY TRENDS, CONDITIONS, OR DEVELOPMENTS WITHOUT THE REQUIREMENT OF A CHAPERONE, SUBJECT TO CERTAIN LIMITATIONS INCLUDING THE IMPLEMENTATION OF CONTROLS AND TRAINING AS DESCRIBED IN THE NOVEMBER 30, 2009 LETTER TO THE COURT FROM THE SETTLING FIRMS. IN HIS MARCH 15, 2010 ORDER, THE HONORABLE JUDGE DID NOT APPROVE THIS PROPOSED MODIFICATION. AS A RESULT OF THE COURT'S ORDER, THE DEFENDANT REMAINS SUBJECT TO A NUMBER OF IMPORTANT RESTRICTIONS THAT APPLY ONLY TO IT AND OTHER FIRMS AFFECTED BY THE FINAL JUDGMENTS AND SETTLEMENT. TOGETHER WITH THE REST OF THE INDUSTRY, THEY ALSO REMAIN SUBJECT TO ALL OF THE PROVISIONS OF NASD RULE 2711, NYSE RULE 472, AND THE SEC'S REGULATION AC THAT ADDRESS RESEARCH ANALYST CONFLICTS OF INTEREST. AS PART OF THE SETTLEMENT, LEHMAN HAS AGREED TO PAY $25 MILLION AS DISGORGEMENT AND AN ADDITIONAL $25 MILLION IN PENALTIES. ONE- HALF OF THE TOTAL OF THESE PAYMENTS -- $25 MILLION -- WILL BE PAID IN CONNECTION WITH THE SEC ACTION AND RELATED PROCEEDINGS BY THE NASD AND NYSE AND WILL BE PLACED INTO A DISTRIBUTION FUND FOR THE BENEFIT OF CUSTOMERS OF THE FIRM. THE REMAINDER WILL BE PAID TO RESOLVE RELATED PROCEEDINGS BY STATE REGULATORS. IN THE SEC ACTION, LEHMAN HAS AGREED TO A FEDERAL COURT ORDER THAT WILL ENJOIN THE FIRM FROM FUTURE VIOLATIONS OF NASD AND NYSE RULES AND REQUIRE THE FIRM TO MAKE CHANGES IN THE OPERATIONS OF ITS EQUITY RESEARCH AND INVESTMENT BANKING DEPARTMENTS. IN ADDITION, LEHMAN WILL PAY, OVER FIVE YEARS, $25 MILLION TO PROVIDE THE FIRM'S CLIENTS WITH INDEPENDENT RESEARCH, AND $5 MILLION TO BE USED FOR INVESTOR EDUCATION.

SEC LITIGATION RELEASE 21457, MARCH 19, 2010: THE HONORABLE JUDGE OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ISSUED AN ORDER ON MARCH 15, 2010 APPROVING MODIFICATIONS TO THE FINAL JUDGMENTS ENTERED AGAINST THE DEFENDANT AND OTHERS. THE FINAL JUDGMENTS CONTAINED AN EXTENSIVE ADDENDUM WITH PROVISIONS MANDATING STRUCTURAL AND OTHER REFORMS THAT ADDRESSED POTENTIAL CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND www.finra.org/brokercheck INVESTMENT BANKING. THE SETTLEMENT PROVIDED THAT WITH User Guidance RESPECT TO ANY PROVISION THAT HAD NOT BEEN EXPRESSLY SUPERSEDED BY SUBSEQUENT RULEMAKING WITHIN FIVE YEARS, THE SEC WOULD AGREE TO AN AMENDMENT/MODIFICATION OF SUCH TERM, SUBJECT TO COURT APPROVAL, UNLESS THE SEC BELIEVES IT WOULD NOT BE IN THE PUBLIC INTEREST. THE COURT APPROVED REMOVING A NUMBER OF PROVISIONS. THE ADDENDUM NO LONGER INCLUDES PROHIBITIONS AGAINST INVESTMENT BANKING INPUT INTO RESEARCH ANALYST COMPENSATION AND THE BAR AGAINST RESEARCH ANALYSTS PARTICIPATING IN EFFORTS TO SOLICIT INVESTMENT BANKING BUSINESS, AMONG OTHER THINGS. THE MODIFIED ADDENDUM AS ORDERED BY THE COURT AND SUPPORTED BY THE SEC MAINTAINED THE REQUIREMENT THAT A CHAPERONE FROM LEGAL OR COMPLIANCE BE PRESENT WHEN INVESTMENT BANKING SEEKS THE VIEWS OF RESEARCH ANALYSTS CONCERNING A PROPOSED TRANSACTION OR A POTENTIAL CANDIDATE FOR A TRANSACTION. ONE PROPOSED MODIFICATION WOULD HAVE ALLOWED INVESTMENT BANKING TO SEEK THE VIEWS OF RESEARCH ANALYSTS REGARDING MARKET OR INDUSTRY TRENDS, CONDITIONS, OR DEVELOPMENTS WITHOUT THE REQUIREMENT OF A CHAPERONE, SUBJECT TO CERTAIN LIMITATIONS INCLUDING THE IMPLEMENTATION OF CONTROLS AND TRAINING AS DESCRIBED IN THE NOVEMBER 30, 2009 LETTER TO THE COURT FROM THE SETTLING FIRMS. IN HIS MARCH 15, 2010 ORDER, THE HONORABLE JUDGE DID NOT APPROVE THIS PROPOSED MODIFICATION. AS A RESULT OF THE COURT'S ORDER, THE DEFENDANT REMAINS SUBJECT TO A NUMBER OF IMPORTANT RESTRICTIONS THAT APPLY ONLY TO IT AND OTHER FIRMS AFFECTED BY THE FINAL JUDGMENTS AND SETTLEMENT. TOGETHER WITH THE REST OF THE INDUSTRY, THEY ALSO REMAIN SUBJECT TO ALL OF THE PROVISIONS OF NASD RULE 2711, NYSE RULE 472, AND THE SEC'S REGULATION AC THAT ADDRESS RESEARCH ANALYST CONFLICTS OF INTEREST. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH THE GLOBAL REGULATORY SETTLEMENT INVOLVING SEVERAL OF THE LEADING SECURITIES FIRMS IN THE UNITED STATES ("SECURITIES FIRMS"), INCLUDING LEHMAN BROTHERS INC., AND VARIOUS FEDERAL AND STATE REGULATORS AND SELF-REGULATORY ORGANIZATIONS RELATING TO INVESTMENT RESEARCH ACTIVITIES, THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT LEHMAN BROTHERS VIOLATED CERTAIN NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. ("NASD") AND NEW YORK STOCK EXCHANGE, INC. ("NYSE") RULES RESULTING FROM ALLEGED CONFLICTS OF INTEREST BETWEEN LEHMAN BROTHERS' RESEARCH AND INVESTMENT BANKING DEPARTMENTS. Initiated By: SECURITIES AND EXCHANGE COMMISSION Court Details: SOUTHERN DISTRICT OF NEW YORK; DOCKET NUMBER 03 CV 2940 (WHP) ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 561 www.finra.org/brokercheck User Guidance

Court Details: SOUTHERN DISTRICT OF NEW YORK; DOCKET NUMBER 03 CV 2940 (WHP) Date Court Action Filed: 04/28/2003 Principal Product Type: Other Other Product Types: EQUITY RESEARCH Relief Sought: Civil Penalty(ies)/Fine(s) Other Relief Sought: DISGORGEMENT, ALLOCATION OF FUNDS FOR PROCUREMENT OF INDEPENDENT RESEARCH AND INVESTOR EDUCATION, INJUNCTION Resolution: Consent Resolution Date: 10/31/2003 Sanctions Ordered or Relief Monetary/Fine $25,000,000.00 Granted: Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions: ALLOCATION OF FUNDS FOR PROCUREMENT OF INDEPENDENT RESEARCH AND INVESTOR EDUCATION. Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS OR FINDINGS, LEHMAN BROTHERS ENTERED INTO A CONSENT WITH THE SEC (THE "CONSENT") IN WHICH LEHMAN BROTHERS CONSENTED: (I) TO PAY $25 MILLION AS A PENALTY, (II) TO PAY $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, (III) TO CONTRIBUTE A TOTAL OF $25 MILLION OVER FIVE YEARS TO PROVIDE THIRD-PARTY INDEPENDENT RESEARCH TO CLIENTS, (IV) TO CONTRIBUTE A TOTAL OF $5 MILLION OVER FIVE YEARS TOWARDS INVESTOR EDUCATION, (V) TO ADOPT INTERNAL STRUCTURAL AND OPERATIONAL REFORMS THAT WILL FURTHER AUGMENT THE STEPS IT HAS ALREADY TAKEN TO PROMOTE RESEARCH ANALYST INDEPENDENCE AND (VI) TO BE ENJOINED FROM THE ALLEGED VIOLATIONS OF NASD AND NYSE RULES. Firm Statement WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS OR FINDINGS, LEHMAN BROTHERS ENTERED INTO A CONSENT WITH THE SEC (THE "CONSENT") IN WHICH LEHMAN BROTHERS CONSENTED: (I) TO PAY $25 MILLION AS A PENALTY, (II) TO PAY $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, (III) TO CONTRIBUTE A TOTAL OF $25 MILLION OVER FIVE YEARS TO PROVIDE THIRD-PARTY INDEPENDENT RESEARCH TO CLIENTS, (IV) TO CONTRIBUTE A TOTAL OF $5 MILLION OVER FIVE YEARS TOWARDS INVESTOR EDUCATION, (V) TO ADOPT INTERNAL STRUCTURAL AND OPERATIONAL REFORMS THAT WILL FURTHER AUGMENT THE STEPS IT HAS ALREADY TAKEN TO PROMOTE RESEARCH ANALYST INDEPENDENCE AND (VI) TO BE ENJOINED FROM THE ALLEGED VIOLATIONS OF NASD AND NYSE RULES.

TO EFFECTUATE THE FINAL GLOBAL SETTLEMENT, ON APRIL 28, 2003, THE ©2021 FINRA. All rights reserved. Report aboutSEC LEHMAN FILED INDIVIDUALBROTHERS INC. COMPLAINTS AND FINAL JUDGMENTS IN THE 562 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK AGAINST THE SECURITIES FIRMS, INCLUDING LEHMAN BROTHERS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS IN THE COMPLAINT, LEHMAN BROTHERS ENTERED INTO THE CONSENT, WHICH INCLUDES LEHMAN BROTHERS' CONSENT TO THE ENTRY OF THE FINAL JUDGMENT. THE FINAL JUDGMENT WAS ENTERED BY THE COURT ON OCTOBER 31, 2003. WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS OR FINDINGS, LEHMAN BROTHERS ENTERED INTO A CONSENT WITH THE SEC (THE "CONSENT") IN WHICH LEHMAN BROTHERS CONSENTED: (I) TO PAY $25 MILLION AS A PENALTY, (II) TO PAY $25 MILLION AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, (III) TO CONTRIBUTE A TOTAL OF $25 MILLION OVER FIVE YEARS TO PROVIDE THIRD-PARTY INDEPENDENT RESEARCH TO CLIENTS, (IV) TO CONTRIBUTE A TOTAL OF $5 MILLION OVER FIVE YEARS TOWARDS INVESTOR EDUCATION, (V) TO ADOPT INTERNAL STRUCTURAL AND OPERATIONAL REFORMS THAT WILL www.finra.org/brokercheck FURTHER AUGMENT THE STEPS IT HAS ALREADY TAKEN TO PROMOTE User Guidance RESEARCH ANALYST INDEPENDENCE AND (VI) TO BE ENJOINED FROM THE ALLEGED VIOLATIONS OF NASD AND NYSE RULES.

TO EFFECTUATE THE FINAL GLOBAL SETTLEMENT, ON APRIL 28, 2003, THE SEC FILED INDIVIDUAL COMPLAINTS AND FINAL JUDGMENTS IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK AGAINST THE SECURITIES FIRMS, INCLUDING LEHMAN BROTHERS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS IN THE COMPLAINT, LEHMAN BROTHERS ENTERED INTO THE CONSENT, WHICH INCLUDES LEHMAN BROTHERS' CONSENT TO THE ENTRY OF THE FINAL JUDGMENT. THE FINAL JUDGMENT WAS ENTERED BY THE COURT ON OCTOBER 31, 2003.

Arbitration Award - Award / Judgment Brokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheck provides summary information regarding FINRA arbitration awards involving securities and commodities disputes between public customers and registered securities firms in this section of the report. The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.

Disclosure 1 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/10/2000 Case Number: 00-00734 Disputed Product Type: UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/03/2005 Sum of All Relief Awarded: $48,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 2 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 11/09/2001 Case Number: 01-05789 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 564 www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $486,563.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/16/2004 Sum of All Relief Awarded: $300,129.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 3 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 01/09/2002 Case Number: 01-06972 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 07/15/2003 Sum of All Relief Awarded: $80,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 4 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 565 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 02/21/2002 Case Number: 02-00896 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $22,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/09/2004 Sum of All Relief Awarded: $2,810,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 5 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 11/07/2003 Case Number: 03-07606 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $30,900,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/21/2005 Sum of All Relief Awarded: $10,419,782.04 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 6 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 05/18/2004 Case Number: 04-03481 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS Sum of All Relief Requested: $2,600,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/30/2008 Sum of All Relief Awarded: $2,500,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 7 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/01/2004 Case Number: 04-04636 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $351,192.21 Disposition: AWARD AGAINST PARTY Disposition Date: 12/12/2005 Sum of All Relief Awarded: $266,846.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 8 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: Case Number: 87-00321 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $564,536.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/12/1989 Sum of All Relief Awarded: $21,998.93 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 9 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/27/1987 Case Number: 87-01738 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $134,010.94 Disposition: AWARD AGAINST PARTY Disposition Date: 09/26/1990 Sum of All Relief Awarded: $91,992.66 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 568 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $91,992.66 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 10 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 01/01/1987 Case Number: 87-01787 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $253,717.83 Disposition: AWARD AGAINST PARTY Disposition Date: 10/12/1989 Sum of All Relief Awarded: $66,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 11 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/09/1988 Case Number: 87-02041 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $5,925.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 569 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 10/28/1990 Sum of All Relief Awarded: $2,100.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 12 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 01/01/1987 Case Number: 87-02090 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $144,831.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/12/1989 Sum of All Relief Awarded: $8,990.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 13 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1987 Case Number: 87-02507 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF ©2021 FINRA. All rights reserved. Report aboutSECURITIES LEHMAN BROTHERS INC. 570 www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $250,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/30/1989 Sum of All Relief Awarded: $251,402.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 14 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1987 Case Number: 87-02657 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $2,236,996.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/20/1989 Sum of All Relief Awarded: $71,757.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 15 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/11/1988 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 571 www.finra.org/brokercheck User Guidance

Case Initiated: 02/11/1988 Case Number: 88-00097 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $215,894.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/26/1990 Sum of All Relief Awarded: $146,943.67 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 16 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/24/1988 Case Number: 88-00129 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/02/1992 Sum of All Relief Awarded: $214,810.70 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 17 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- FAILURE TO SUPERVISE ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 572 www.finra.org/brokercheck User Guidance ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-00138 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $4,358,155.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/23/1989 Sum of All Relief Awarded: $2,340,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 18 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-00214 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/19/1989 Sum of All Relief Awarded: $109,390.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 19 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/31/1988 Case Number: 88-00448 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $2,120,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/05/1991 Sum of All Relief Awarded: $170,798.91 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 20 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-00533 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; OPTIONS Sum of All Relief Requested: $441,323.16 Disposition: AWARD AGAINST PARTY Disposition Date: 09/12/1989 Sum of All Relief Awarded: $67,503.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 21 of 527 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 574 www.finra.org/brokercheck User Guidance

Disclosure 21 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-00559 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/23/1989 Sum of All Relief Awarded: $17,526.93 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 22 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE- NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-00814 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/05/1989 Sum of All Relief Awarded: $200,000.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 23 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-00861 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS Sum of All Relief Requested: $20,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/16/1990 Sum of All Relief Awarded: $7,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 24 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-MARGIN CALLS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-00997 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $85,600.00 Disposition: AWARD AGAINST PARTY

Disposition Date: 08/17/1989 Sum of All Relief Awarded: $3,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 25 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01010 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $2,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/18/1989 Sum of All Relief Awarded: $2,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 26 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01115 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $405,095.95 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 577 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $405,095.95 Disposition: AWARD AGAINST PARTY Disposition Date: 05/17/1990 Sum of All Relief Awarded: $138,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 27 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01308 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $39,337.02 Disposition: AWARD AGAINST PARTY Disposition Date: 04/04/1990 Sum of All Relief Awarded: $39,337.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 28 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988

Case Number: 88-01359 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/27/1990 Sum of All Relief Awarded: $181,125.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 29 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01400 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $219,766.23 Disposition: AWARD AGAINST PARTY Disposition Date: 08/28/1989 Sum of All Relief Awarded: $88,434.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 30 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-MARGIN CALLS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 579 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT RELATED-MARGIN CALLS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/09/1988 Case Number: 88-01489 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $561,632.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/26/1991 Sum of All Relief Awarded: $408,719.18 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 31 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01553 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $545,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/25/1990 Sum of All Relief Awarded: $23,422.52 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 32 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01569 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $852,773.42 Disposition: AWARD AGAINST PARTY Disposition Date: 04/03/1990 Sum of All Relief Awarded: $307,440.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 33 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01590 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $141,830.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/23/1989 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 581 www.finra.org/brokercheck User Guidance

i Disclosure 34 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01605 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $631,156.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/01/1989 Sum of All Relief Awarded: $132,982.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 35 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01667 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $129,977.50 Disposition: AWARD AGAINST PARTY Disposition Date: 08/01/1989 Sum of All Relief Awarded: $11,200.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 36 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01727 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $2,491.09 Disposition: AWARD AGAINST PARTY Disposition Date: 05/22/1989 Sum of All Relief Awarded: $2,241.09 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 37 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01823 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $37,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/30/1990 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 583 www.finra.org/brokercheck User Guidance

Disposition Date: 03/30/1990 Sum of All Relief Awarded: $24,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 38 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01869 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $108,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/06/1989 Sum of All Relief Awarded: $43,593.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 39 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-01888 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 584 www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS Sum of All Relief Requested: $51,312.50 Disposition: AWARD AGAINST PARTY Disposition Date: 02/01/1990 Sum of All Relief Awarded: $25,656.25 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 40 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02074 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $80,187.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/14/1990 Sum of All Relief Awarded: $4,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 41 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02075 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 585 www.finra.org/brokercheck User Guidance

Case Number: 88-02075 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $7,446.74 Disposition: AWARD AGAINST PARTY Disposition Date: 05/31/1989 Sum of All Relief Awarded: $4,235.66 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 42 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02081 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $280,829.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/29/1989 Sum of All Relief Awarded: $21,380.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 43 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 07/07/1988 Case Number: 88-02096 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $125,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/01/1990 Sum of All Relief Awarded: $32,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 44 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02108 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $838,725.11 Disposition: AWARD AGAINST PARTY Disposition Date: 09/11/1989 Sum of All Relief Awarded: $63,860.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 45 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02179 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $5,765.09 Disposition: AWARD AGAINST PARTY Disposition Date: 07/06/1989 Sum of All Relief Awarded: $5,765.09 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 46 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02197 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $74,848.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/09/1989 Sum of All Relief Awarded: $52,445.95 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 47 of 527 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 588 www.finra.org/brokercheck User Guidance

Disclosure 47 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02210 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $410,900.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/30/1990 Sum of All Relief Awarded: $8,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 48 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02250 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $167,800.66 Disposition: AWARD AGAINST PARTY Disposition Date: 08/23/1989 Sum of All Relief Awarded: $53,000.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 589 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $53,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 49 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/19/1988 Case Number: 88-02290 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $48,249.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/20/1990 Sum of All Relief Awarded: $23,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 50 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02293 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $129,670.83 Disposition: AWARD AGAINST PARTY Disposition Date: 08/29/1989 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 590 www.finra.org/brokercheck User Guidance

Disposition Date: 08/29/1989 Sum of All Relief Awarded: $10,682.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 51 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02306 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $30,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/23/1990 Sum of All Relief Awarded: $30,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 52 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02307 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF ©2021 FINRA. All rights reserved. Report aboutSECURITIES LEHMAN BROTHERS INC. 591 www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/23/1990 Sum of All Relief Awarded: $275,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 53 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/25/1988 Case Number: 88-02311 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $407,384.67 Disposition: AWARD AGAINST PARTY Disposition Date: 01/30/1991 Sum of All Relief Awarded: $63,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 54 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 592 www.finra.org/brokercheck User Guidance

Case Initiated: 01/01/1988 Case Number: 88-02357 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $560,860.20 Disposition: AWARD AGAINST PARTY Disposition Date: 01/03/1990 Sum of All Relief Awarded: $510.81 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 55 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02375 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GINNIE MAES Sum of All Relief Requested: $25,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/18/1989 Sum of All Relief Awarded: $18,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 56 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD

Case Initiated: 08/29/1988 Case Number: 88-02391 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,371,884.70 Disposition: AWARD AGAINST PARTY Disposition Date: 08/31/1990 Sum of All Relief Awarded: $125,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 57 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02461 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $608,624.96 Disposition: AWARD AGAINST PARTY Disposition Date: 02/20/1990 Sum of All Relief Awarded: $1,249,326.90 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 58 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 594 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 08/18/1988 Case Number: 88-02483 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,300,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/25/1991 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 59 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02640 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $101,641.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/16/1990 Sum of All Relief Awarded: $90,684.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 60 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-EXECUTIONS- ©2021 FINRA. All rights reserved. Report aboutFAILURE LEHMAN TO BROTHERS EXECUTE; INC. DO NOT USE-NO OTHER CONTROVERSY INVOLVED 595 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-EXECUTIONS- FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02654 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $2,250.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/25/1989 Sum of All Relief Awarded: $1,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 61 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02665 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $5,000.01 Disposition: AWARD AGAINST PARTY Disposition Date: 08/01/1989 Sum of All Relief Awarded: $4,191.85 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 62 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02765 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $5,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/03/1989 Sum of All Relief Awarded: $1,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 63 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02799 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $66,488.70 Disposition: AWARD AGAINST PARTY Disposition Date: 10/13/1989 Sum of All Relief Awarded: $5,250.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 597 www.finra.org/brokercheck User Guidance

i Disclosure 64 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02829 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/16/1989 Sum of All Relief Awarded: $8,321.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 65 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/15/1988 Case Number: 88-02866 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $42,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/20/1990 Sum of All Relief Awarded: $3,400.00 There may be a non-monetary award associated with this arbitration.

Please select the Case Number above to view more detailed information. i Disclosure 66 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02870 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $30,449.20 Disposition: AWARD AGAINST PARTY Disposition Date: 07/19/1989 Sum of All Relief Awarded: $11,375.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 67 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE- EXECUTIONS-OTHER Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-02958 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $64,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/20/1990 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 599 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $15,930.14 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 68 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03003 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $20,620.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/28/1989 Sum of All Relief Awarded: $10,907.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 69 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03006 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $5,000.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 600 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $5,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/31/1989 Sum of All Relief Awarded: $5,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 70 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03129 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $3,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/25/1989 Sum of All Relief Awarded: $100,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 71 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 01/01/1988 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 601 www.finra.org/brokercheck User Guidance

Case Initiated: 01/01/1988 Case Number: 88-03133 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $93,750.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/10/1990 Sum of All Relief Awarded: $58,691.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 72 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03269 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $9,171.12 Disposition: AWARD AGAINST PARTY Disposition Date: 11/30/1989 Sum of All Relief Awarded: $2,960.56 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 73 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report aboutUNAUTHORIZED LEHMAN BROTHERS TRADING; INC. ACCOUNT RELATED-FAILURE TO SUPERVISE; 602 DO NOT USE-NO OTHER CONTROVERSY INVOLVED www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03275 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $4,999.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/18/1989 Sum of All Relief Awarded: $2,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 74 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-EXECUTIONS- FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03306 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS; OPTIONS Sum of All Relief Requested: $66,486.85 Disposition: AWARD AGAINST PARTY Disposition Date: 10/25/1989 Sum of All Relief Awarded: $42,200.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 75 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03440 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $5,790.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/28/1989 Sum of All Relief Awarded: $5,790.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 76 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; DO NOT USE-EXECUTIONS- FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03448 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $56,805.88 Disposition: AWARD AGAINST PARTY Disposition Date: 09/19/1989 Sum of All Relief Awarded: $21,533.06 There may be a non-monetary award associated with this arbitration. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 604 www.finra.org/brokercheck User Guidance

Please select the Case Number above to view more detailed information. i Disclosure 77 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03462 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $156,488.48 Disposition: AWARD AGAINST PARTY Disposition Date: 12/06/1989 Sum of All Relief Awarded: $42,475.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 78 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03509 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $794,545.95 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 605 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 05/08/1990 Sum of All Relief Awarded: $31,106.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 79 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03517 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $137,926.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/18/1989 Sum of All Relief Awarded: $74,802.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 80 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03523

Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/30/1990 Sum of All Relief Awarded: $3,800.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 81 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03551 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $40,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/14/1989 Sum of All Relief Awarded: $46,576.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 82 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 607 www.finra.org/brokercheck User Guidance

Case Initiated: 01/01/1988 Case Number: 88-03574 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $636,939.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/11/1989 Sum of All Relief Awarded: $66,439.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 83 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03610 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $188,521.81 Disposition: AWARD AGAINST PARTY Disposition Date: 11/30/1989 Sum of All Relief Awarded: $30,371.93 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 84 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION ©2021 FINRA. All rights reserved. Report aboutOF FACTS; LEHMAN BROTHERSACCOUNT INC. ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER 608 CONTROVERSY INVOLVED www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03718 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $110,550.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/18/1989 Sum of All Relief Awarded: $137,190.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 85 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03758 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $3,850.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/18/1989 Sum of All Relief Awarded: $3,850.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 86 of 527 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 609 www.finra.org/brokercheck User Guidance

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03798 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $87,450.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/17/1990 Sum of All Relief Awarded: $64,218.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 87 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/05/1989 Case Number: 88-03830 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $407,218.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/29/1990 Sum of All Relief Awarded: $7,218.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 88 of 527 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 610 www.finra.org/brokercheck User Guidance

Disclosure 88 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1988 Case Number: 88-03854 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES Sum of All Relief Requested: $2,370.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/25/1989 Sum of All Relief Awarded: $2,030.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 89 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: Case Number: 88-03955 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $300,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/13/1989 Sum of All Relief Awarded: $7,500.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 90 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/17/1989 Case Number: 89-00002 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $124,897.63 Disposition: AWARD AGAINST PARTY Disposition Date: 11/29/1990 Sum of All Relief Awarded: $95,750.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 91 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00039 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $25,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/17/1990 Sum of All Relief Awarded: $5,000.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 92 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY- SUITABILITY Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00095 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/16/1990 Sum of All Relief Awarded: $17,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 93 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00255 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $9,999.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 613 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 09/26/1989 Sum of All Relief Awarded: $8,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 94 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00326 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $75,461.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/30/1990 Sum of All Relief Awarded: $16,931.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 95 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00416

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/18/1990 Sum of All Relief Awarded: $29,312.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 96 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/07/1989 Case Number: 89-00599 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $46,121.50 Disposition: AWARD AGAINST PARTY Disposition Date: 08/17/1990 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 97 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00607

Disputed Product Type: COMMODITIES FUTURES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $9,802.72 Disposition: AWARD AGAINST PARTY Disposition Date: 03/22/1990 Sum of All Relief Awarded: $1,050.03 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 98 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00642 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $30,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/23/1990 Sum of All Relief Awarded: $7,959.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 99 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 616 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00670 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $5,600,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/07/1990 Sum of All Relief Awarded: $233,635.52 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 100 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00727 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $82,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/25/1990 Sum of All Relief Awarded: $57,293.68 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 101 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00730 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $5,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/28/1989 Sum of All Relief Awarded: $187.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 102 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/24/1989 Case Number: 89-00777 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $181,200.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/06/1991 Sum of All Relief Awarded: $15,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 103 of 527 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 618 www.finra.org/brokercheck User Guidance

Disclosure 103 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00798 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $2,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/26/1989 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 104 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00904 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $6,935.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/26/1989 Sum of All Relief Awarded: $6,935.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 105 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-00965 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $33,113.83 Disposition: AWARD AGAINST PARTY Disposition Date: 05/17/1990 Sum of All Relief Awarded: $5,870.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 106 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- OMISSION OF FACTS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01073 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $12,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/23/1990 Sum of All Relief Awarded: $12,705.83 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 620 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $12,705.83 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 107 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/20/1989 Case Number: 89-01092 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $191,665.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/30/1990 Sum of All Relief Awarded: $79,729.63 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 108 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/24/1989 Case Number: 89-01112 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/17/1990

Sum of All Relief Awarded: $160,896.89 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 109 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/24/1989 Case Number: 89-01113 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/17/1990 Sum of All Relief Awarded: $10,230.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 110 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/24/1989 Case Number: 89-01114 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/17/1990 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 622 www.finra.org/brokercheck User Guidance

Disposition Date: 10/17/1990 Sum of All Relief Awarded: $91,833.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 111 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/24/1989 Case Number: 89-01115 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/17/1990 Sum of All Relief Awarded: $221,321.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 112 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01135 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES

Sum of All Relief Requested: $30,642,347.60 Disposition: AWARD AGAINST PARTY Disposition Date: 05/16/1990 Sum of All Relief Awarded: $298,200.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 113 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01149 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $250,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/05/1990 Sum of All Relief Awarded: $5,968.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 114 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989

Case Number: 89-01165 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $8,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/18/1989 Sum of All Relief Awarded: $4,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 115 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/09/1989 Case Number: 89-01171 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $130,671.70 Disposition: AWARD AGAINST PARTY Disposition Date: 01/02/1991 Sum of All Relief Awarded: $16,596.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 116 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/09/1989

Case Number: 89-01177 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $136,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/02/1991 Sum of All Relief Awarded: $60,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 117 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-EXECUTIONS- FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01215 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $103,304.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/30/1990 Sum of All Relief Awarded: $40,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 118 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 05/30/1989 Case Number: 89-01264 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $31,421.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/06/1991 Sum of All Relief Awarded: $6,024.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 119 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01316 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $2,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/26/1989 Sum of All Relief Awarded: $500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 120 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report aboutMISREPRESENTATION; LEHMAN BROTHERS INC. ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT 627 RELATED-FAILURE TO SUPERVISE www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01358 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $25,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/18/1990 Sum of All Relief Awarded: $21,669.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 121 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/21/1989 Case Number: 89-01383 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 09/05/1990 Sum of All Relief Awarded: $113,524.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 122 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01480 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $20,120.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/21/1990 Sum of All Relief Awarded: $5,046.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 123 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/15/1989 Case Number: 89-01589 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $60,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/16/1990 Sum of All Relief Awarded: $15,976.64 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i

Disclosure 124 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01662 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $56,575.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/05/1990 Sum of All Relief Awarded: $15,510.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 125 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01696 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,200.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/10/1989 Sum of All Relief Awarded: $1,200.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 126 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01731 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS Sum of All Relief Requested: $4,675.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/31/1990 Sum of All Relief Awarded: $4,675.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 127 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/28/1989 Case Number: 89-01770 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $480,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/12/1990 Sum of All Relief Awarded: $55,000.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 128 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01821 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $925.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/10/1989 Sum of All Relief Awarded: $300.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 129 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-01843 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $103,870.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/20/1990 Sum of All Relief Awarded: $35,000.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 632 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $35,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 130 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-02093 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $6,252.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/18/1990 Sum of All Relief Awarded: $4,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 131 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-02200 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $16,000.00

Disposition: AWARD AGAINST PARTY Disposition Date: 05/29/1990 Sum of All Relief Awarded: $6,156.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 132 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-02206 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $2,770.11 Disposition: AWARD AGAINST PARTY Disposition Date: 02/14/1990 Sum of All Relief Awarded: $2,770.11 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 133 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/19/1989 Case Number: 89-02215 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 634 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $488,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/12/1990 Sum of All Relief Awarded: $11,473.38 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 134 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/30/1989 Case Number: 89-02298 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $175,675.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/10/1990 Sum of All Relief Awarded: $8,995.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 135 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/27/1989 Case Number: 89-02313 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $824,875.65 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 635 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $824,875.65 Disposition: AWARD AGAINST PARTY Disposition Date: 01/02/1991 Sum of All Relief Awarded: $15,751.41 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 136 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/17/1989 Case Number: 89-02323 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $95,206.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/12/1990 Sum of All Relief Awarded: $5,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 137 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-02367 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF ©2021 FINRA. All rights reserved. Report aboutSECURITIES LEHMAN BROTHERS INC. 636 www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $74,750.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/28/1990 Sum of All Relief Awarded: $32,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 138 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-02464 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $85,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/31/1990 Sum of All Relief Awarded: $10,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 139 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD

Case Initiated: 01/01/1989 Case Number: 89-02513 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $18,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/19/1990 Sum of All Relief Awarded: $21,970.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 140 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/30/1989 Case Number: 89-02529 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $430,127.22 Disposition: AWARD AGAINST PARTY Disposition Date: 11/06/1990 Sum of All Relief Awarded: $150,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 141 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD

Case Initiated: 01/01/1989 Case Number: 89-02540 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,218.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/27/1990 Sum of All Relief Awarded: $1,218.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 142 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/25/1989 Case Number: 89-02566 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $212,892.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/15/1991 Sum of All Relief Awarded: $28,640.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 143 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD

Case Initiated: 11/08/1989 Case Number: 89-02580 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $524,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/07/1991 Sum of All Relief Awarded: $285,846.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 144 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/01/1989 Case Number: 89-02581 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/25/1991 Sum of All Relief Awarded: $245,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 145 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/01/1989 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 640 www.finra.org/brokercheck User Guidance

Case Initiated: 11/01/1989 Case Number: 89-02582 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/30/1991 Sum of All Relief Awarded: $27,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 146 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/01/1989 Case Number: 89-02583 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/25/1991 Sum of All Relief Awarded: $28,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 147 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 641 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-02598 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/27/1990 Sum of All Relief Awarded: $125,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 148 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/29/1989 Case Number: 89-02679 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $30,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/25/1991 Sum of All Relief Awarded: $7,969.17 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 149 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 11/14/1989 Case Number: 89-02778 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $5,464,690.95 Disposition: AWARD AGAINST PARTY Disposition Date: 02/25/1991 Sum of All Relief Awarded: $300,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 150 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; TRADING DISPUTES-OTHER Arbitration Forum: NASD Case Initiated: 11/21/1989 Case Number: 89-02875 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $580,394.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/04/1991 Sum of All Relief Awarded: $1,032,193.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 151 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 12/28/1989 Case Number: 89-02885 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $75,343.91 Disposition: AWARD AGAINST PARTY Disposition Date: 09/18/1990 Sum of All Relief Awarded: $38,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 152 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/04/1990 Case Number: 89-02916 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $150,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/10/1991 Sum of All Relief Awarded: $36,786.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 153 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 11/10/1989 Case Number: 89-02929 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $750,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/03/1991 Sum of All Relief Awarded: $108,733.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 154 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/21/1989 Case Number: 89-02945 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $2,082,720.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/20/1992 Sum of All Relief Awarded: $559,327.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 155 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 645 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 12/13/1989 Case Number: 89-02987 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $805,781.61 Disposition: AWARD AGAINST PARTY Disposition Date: 07/31/1991 Sum of All Relief Awarded: $87,189.86 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 156 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/22/1989 Case Number: 89-03029 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $34,608.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/22/1990 Sum of All Relief Awarded: $34,608.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 157 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 646 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 11/06/1989 Case Number: 89-03055 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $129,662.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/31/1990 Sum of All Relief Awarded: $92,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 158 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/21/1989 Case Number: 89-03074 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $30,431.68 Disposition: AWARD AGAINST PARTY Disposition Date: 09/15/1990 Sum of All Relief Awarded: $5,082.82 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 159 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 647 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 11/21/1989 Case Number: 89-03104 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $27,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/26/1991 Sum of All Relief Awarded: $17,190.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 160 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/06/1989 Case Number: 89-03194 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $31,225.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/29/1991 Sum of All Relief Awarded: $10,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 161 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-03213 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,411.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/23/1990 Sum of All Relief Awarded: $1,411.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 162 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/22/1989 Case Number: 89-03220 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,936,092.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/17/1991 Sum of All Relief Awarded: $70,200.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 163 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 12/13/1989 Case Number: 89-03291 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/16/1990 Sum of All Relief Awarded: $81,332.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 164 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/21/1989 Case Number: 89-03320 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $32,182.52 Disposition: AWARD AGAINST PARTY Disposition Date: 01/18/1991 Sum of All Relief Awarded: $15,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 165 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 650 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 12/26/1989 Case Number: 89-03326 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $34,283.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/05/1990 Sum of All Relief Awarded: $11,428.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 166 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/22/1989 Case Number: 89-03389 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $122,583.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/17/1990 Sum of All Relief Awarded: $34,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 167 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 651 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 12/27/1989 Case Number: 89-03429 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $70,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/19/1990 Sum of All Relief Awarded: $39,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 168 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/18/1989 Case Number: 89-03459 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $61,411.49 Disposition: AWARD AGAINST PARTY Disposition Date: 04/30/1991 Sum of All Relief Awarded: $6,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 169 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 652 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 12/27/1989 Case Number: 89-03468 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $42,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/05/1990 Sum of All Relief Awarded: $500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 170 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/18/1989 Case Number: 89-03469 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $182,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/19/1991 Sum of All Relief Awarded: $140,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 171 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 653 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 01/23/1990 Case Number: 89-03478 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $350,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/10/1990 Sum of All Relief Awarded: $144,480.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 172 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/27/1989 Case Number: 89-03485 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $413,588.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/17/1991 Sum of All Relief Awarded: $6,879.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 173 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 08/02/1990 Case Number: 89-03529 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $76,716.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/13/1991 Sum of All Relief Awarded: $15,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 174 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/28/1989 Case Number: 89-03546 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $40,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/17/1991 Sum of All Relief Awarded: $15,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 175 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 655 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 12/29/1989 Case Number: 89-03595 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $190,160.41 Disposition: AWARD AGAINST PARTY Disposition Date: 12/18/1990 Sum of All Relief Awarded: $38,216.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 176 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; EMPLOYMENT-TRAINING CONTRACTS Arbitration Forum: NASD Case Initiated: 01/01/1989 Case Number: 89-99904 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $8,686.05 Disposition: AWARD AGAINST PARTY Disposition Date: 04/25/1990 Sum of All Relief Awarded: $5,968.56 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 177 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 11/08/1990 Case Number: 89-99908 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $5,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/29/1991 Sum of All Relief Awarded: $4,963.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 178 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/26/1990 Case Number: 90-00024 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/15/1990 Sum of All Relief Awarded: $8,366.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 179 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 657 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 01/08/1990 Case Number: 90-00037 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $335,795.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/26/1990 Sum of All Relief Awarded: $10,541.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 180 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/26/1990 Case Number: 90-00040 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $59,059.12 Disposition: AWARD AGAINST PARTY Disposition Date: 11/06/1990 Sum of All Relief Awarded: $20,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 181 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 658 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 01/26/1990 Case Number: 90-00047 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $18,343.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/15/1991 Sum of All Relief Awarded: $2,991.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 182 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/11/1990 Case Number: 90-00080 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $60,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/19/1990 Sum of All Relief Awarded: $34,633.62 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 183 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 01/01/1990 Case Number: 90-00092 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $3,640.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/12/1990 Sum of All Relief Awarded: $1,580.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 184 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/18/1990 Case Number: 90-00129 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $30,629.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/25/1991 Sum of All Relief Awarded: $30,629.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 185 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER ©2021 FINRA. All rights reserved. Report aboutCONTROVERSY LEHMAN BROTHERS INVOLVED INC. 660 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1990 Case Number: 90-00132 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $2,315.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/23/1990 Sum of All Relief Awarded: $2,315.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 186 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/30/1990 Case Number: 90-00188 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $800.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/15/1990 Sum of All Relief Awarded: $800.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 187 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/09/1990 Case Number: 90-00280 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $757,986.11 Disposition: AWARD AGAINST PARTY Disposition Date: 07/08/1991 Sum of All Relief Awarded: $128,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 188 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/17/1990 Case Number: 90-00296 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $250,702.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/05/1991 Sum of All Relief Awarded: $27,669.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 189 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/06/1990 Case Number: 90-00325 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $501,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/29/1991 Sum of All Relief Awarded: $19,727.49 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 190 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/15/1990 Case Number: 90-00376 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $18,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/04/1992 Sum of All Relief Awarded: $668,475.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 191 of 527 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 663 www.finra.org/brokercheck User Guidance

Disclosure 191 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/20/1990 Case Number: 90-00389 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $21,842.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/13/1990 Sum of All Relief Awarded: $1,180.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 192 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/16/1990 Case Number: 90-00435 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $345,784.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/17/1991 Sum of All Relief Awarded: $10,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 193 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/28/1990 Case Number: 90-00469 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $60,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/15/1991 Sum of All Relief Awarded: $25,479.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 194 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1990 Case Number: 90-00480 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $5,001.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/28/1990 Sum of All Relief Awarded: $5,101.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 195 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/02/1990 Case Number: 90-00510 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $175,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/01/1991 Sum of All Relief Awarded: $76,107.99 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 196 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/09/1990 Case Number: 90-00587 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/01/1991 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration.

Please select the Case Number above to view more detailed information. i Disclosure 197 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/26/1990 Case Number: 90-00598 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $3,282,896.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/25/1991 Sum of All Relief Awarded: $707,435.12 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 198 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/28/1990 Case Number: 90-00619 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,412,254.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/16/1991 Sum of All Relief Awarded: $93,050.00 There may be a non-monetary award associated with this arbitration.

Please select the Case Number above to view more detailed information. i Disclosure 199 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/09/1990 Case Number: 90-00647 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $81,542.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/20/1991 Sum of All Relief Awarded: $20,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 200 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/05/1990 Case Number: 90-00654 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $7,443,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/20/1991 Sum of All Relief Awarded: $443,000.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 201 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/29/1990 Case Number: 90-00724 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $75,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/05/1991 Sum of All Relief Awarded: $9,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 202 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/22/1990 Case Number: 90-00751 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $639,147.90 Disposition: AWARD AGAINST PARTY Disposition Date: 02/20/1991 Sum of All Relief Awarded: $245,517.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 669 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $245,517.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 203 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/09/1990 Case Number: 90-00761 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $134,817.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/17/1991 Sum of All Relief Awarded: $6,800.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 204 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/03/1990 Case Number: 90-00879 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $490,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/15/1991 Sum of All Relief Awarded: $237,000.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 670 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $237,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 205 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/11/1990 Case Number: 90-00907 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $1,650,772.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/24/1991 Sum of All Relief Awarded: $63,480.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 206 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/20/1990 Case Number: 90-01066 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/05/1991 Sum of All Relief Awarded: $25,000.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 671 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $25,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 207 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/24/1990 Case Number: 90-01132 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $37,714.38 Disposition: AWARD AGAINST PARTY Disposition Date: 12/31/1990 Sum of All Relief Awarded: $5,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 208 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/23/1990 Case Number: 90-01167 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $4,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/29/1990 Sum of All Relief Awarded: $3,000.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 672 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $3,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 209 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/01/1990 Case Number: 90-01185 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES; MUTUAL FUNDS Sum of All Relief Requested: $23,800.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/30/1991 Sum of All Relief Awarded: $20,741.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 210 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/22/1990 Case Number: 90-01186 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,169,198.72

Disposition: AWARD AGAINST PARTY Disposition Date: 10/30/1991 Sum of All Relief Awarded: $147,661.26 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 211 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/07/1990 Case Number: 90-01208 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $781.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/26/1990 Sum of All Relief Awarded: $55.39 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 212 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/03/1990 Case Number: 90-01218 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $2,125,000.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 674 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 06/10/1992 Sum of All Relief Awarded: $45,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 213 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/14/1990 Case Number: 90-01222 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/10/1991 Sum of All Relief Awarded: $3,361.51 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 214 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/04/1990 Case Number: 90-01241 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 675 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $12,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/16/1991 Sum of All Relief Awarded: $20,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 215 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/10/1990 Case Number: 90-01279 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $386,250.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/18/1991 Sum of All Relief Awarded: $72,421.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 216 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/16/1990 Case Number: 90-01331 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 676 www.finra.org/brokercheck User Guidance

Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $35,204.01 Disposition: AWARD AGAINST PARTY Disposition Date: 03/04/1991 Sum of All Relief Awarded: $34,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 217 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/16/1990 Case Number: 90-01341 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $30,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/12/1991 Sum of All Relief Awarded: $23,756.12 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 218 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED- OTHER Arbitration Forum: NASD Case Initiated: 05/18/1990 Case Number: 90-01350 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 677 www.finra.org/brokercheck User Guidance

Case Number: 90-01350 Disputed Product Type: COMMON STOCK; MUNICIPAL BONDS; OPTIONS; STOCK INDEX FUTURES Sum of All Relief Requested: $551,224.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/05/1991 Sum of All Relief Awarded: $66,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 219 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 06/29/1990 Case Number: 90-01379 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,270,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/25/1991 Sum of All Relief Awarded: $592,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 220 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/18/1990 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 678 www.finra.org/brokercheck User Guidance

Case Initiated: 05/18/1990 Case Number: 90-01395 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/30/1991 Sum of All Relief Awarded: $16,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 221 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/30/1990 Case Number: 90-01401 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $26,555.80 Disposition: AWARD AGAINST PARTY Disposition Date: 01/24/1992 Sum of All Relief Awarded: $21,245.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 222 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD

Case Initiated: 05/29/1990 Case Number: 90-01412 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $60,263.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/22/1991 Sum of All Relief Awarded: $2,784.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 223 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/14/1990 Case Number: 90-01418 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $460,965.28 Disposition: AWARD AGAINST PARTY Disposition Date: 07/12/1991 Sum of All Relief Awarded: $30,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 224 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 680 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 05/30/1990 Case Number: 90-01459 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS Sum of All Relief Requested: $1,098,618.05 Disposition: AWARD AGAINST PARTY Disposition Date: 10/30/1991 Sum of All Relief Awarded: $173,618.05 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 225 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/04/1990 Case Number: 90-01485 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $6,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/16/1991 Sum of All Relief Awarded: $371,400.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 226 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 06/04/1990 Case Number: 90-01486 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $260,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/06/1991 Sum of All Relief Awarded: $58,615.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 227 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/18/1990 Case Number: 90-01551 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $13,593.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/27/1991 Sum of All Relief Awarded: $13,313.88 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 228 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 682 www.finra.org/brokercheck User Guidance

Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/12/1990 Case Number: 90-01555 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/29/1990 Sum of All Relief Awarded: $8,750.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 229 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/08/1990 Case Number: 90-01589 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $390,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/07/1992 Sum of All Relief Awarded: $300,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 230 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 683 www.finra.org/brokercheck User Guidance

Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/08/1990 Case Number: 90-01590 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $34,621.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/15/1991 Sum of All Relief Awarded: $14,320.79 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 231 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; DO NOT USE-OTHER-OTHER Arbitration Forum: NASD Case Initiated: 10/09/1990 Case Number: 90-01593 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $1,110,952.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/15/1992 Sum of All Relief Awarded: $274,343.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 232 of 527 Reporting Source: Regulator Type of Event: ARBITRATION

Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/08/1991 Case Number: 90-01599 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $18,418.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/07/1991 Sum of All Relief Awarded: $11,960.52 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 233 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE- NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/19/1990 Case Number: 90-01641 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/25/1991 Sum of All Relief Awarded: $86,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 234 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/18/1990 Case Number: 90-01664 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $35,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/25/1991 Sum of All Relief Awarded: $11,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 235 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/10/1990 Case Number: 90-01709 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS Sum of All Relief Requested: $45,465.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/26/1991 Sum of All Relief Awarded: $6,339.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i

Disclosure 236 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-MARGIN CALLS Arbitration Forum: NASD Case Initiated: 03/14/1991 Case Number: 90-01788 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/20/1993 Sum of All Relief Awarded: $2,540.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 237 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 09/13/1990 Case Number: 90-01813 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS Sum of All Relief Requested: $1,832,466.16 Disposition: AWARD AGAINST PARTY Disposition Date: 02/25/1992 Sum of All Relief Awarded: $67,200.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 238 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-OTHER Arbitration Forum: NASD Case Initiated: 07/19/1990 Case Number: 90-01816 Disputed Product Type: COMMON STOCK; LIMITED PARTNERSHIPS; MUTUAL FUNDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/11/1991 Sum of All Relief Awarded: $13,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 239 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- ERRORS-CHARGES; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE- EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 09/10/1990 Case Number: 90-01828 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,791.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 688 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 08/30/1991 Sum of All Relief Awarded: $1,564.15 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 240 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-EXCHANGES Arbitration Forum: NASD Case Initiated: 11/26/1990 Case Number: 90-01958 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS; WARRANTS/RIGHTS Sum of All Relief Requested: $9,048.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/30/1991 Sum of All Relief Awarded: $2,050.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 241 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/12/1990 Case Number: 90-01987

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $45,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/17/1991 Sum of All Relief Awarded: $45,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 242 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-OTHER Arbitration Forum: NASD Case Initiated: 10/15/1990 Case Number: 90-02073 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES; OPTIONS Sum of All Relief Requested: $631,840.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/22/1991 Sum of All Relief Awarded: $11,505.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 243 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER Arbitration Forum: NASD Case Initiated: 10/13/1990 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 690 www.finra.org/brokercheck User Guidance

Case Number: 90-02075 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GINNIE MAES Sum of All Relief Requested: $610,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/23/1991 Sum of All Relief Awarded: $40,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 244 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/17/1990 Case Number: 90-02091 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $416,528.75 Disposition: AWARD AGAINST PARTY Disposition Date: 07/02/1991 Sum of All Relief Awarded: $66,736.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 245 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 10/15/1990 Case Number: 90-02168 Disputed Product Type: OPTIONS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/09/1991 Sum of All Relief Awarded: $5,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 246 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/13/1990 Case Number: 90-02223 Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,681.26 Disposition: AWARD AGAINST PARTY Disposition Date: 03/19/1991 Sum of All Relief Awarded: $1,181.26 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 247 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 692 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/08/1990 Case Number: 90-02305 Disputed Product Type: OPTIONS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $20,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/01/1991 Sum of All Relief Awarded: $28,680.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 248 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/13/1990 Case Number: 90-02308 Disputed Product Type: FANNIE MAE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/26/1991 Sum of All Relief Awarded: $1,187.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 249 of 527 Reporting Source: Regulator Type of Event: ARBITRATION

©2021Allegations: FINRA. All rights reserved. Report aboutACCOUNT LEHMAN ACTIVITY-MISREPRESENTATION; BROTHERS INC. ACCOUNT ACTIVITY-OTHER; 693 ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/05/1990 Case Number: 90-02334 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $100,688.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/30/1991 Sum of All Relief Awarded: $13,620.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 250 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/01/1990 Case Number: 90-02389 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; OPTIONS Sum of All Relief Requested: $48,201.80 Disposition: AWARD AGAINST PARTY Disposition Date: 11/22/1991 Sum of All Relief Awarded: $15,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 251 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/12/1990 Case Number: 90-02393 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; MUTUAL FUNDS Sum of All Relief Requested: $9,426.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/21/1991 Sum of All Relief Awarded: $13,300.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 252 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/01/1990 Case Number: 90-02445 Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,250.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/26/1991 Sum of All Relief Awarded: $250.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 695 www.finra.org/brokercheck User Guidance

i Disclosure 253 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 10/29/1990 Case Number: 90-02467 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $49,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/01/1991 Sum of All Relief Awarded: $15,867.33 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 254 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 11/19/1990 Case Number: 90-02477 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,350,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/02/1991 Sum of All Relief Awarded: $70,521.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 696 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $70,521.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 255 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-OTHER Arbitration Forum: NASD Case Initiated: 11/01/1990 Case Number: 90-02493 Disputed Product Type: COMMON STOCK; GOVERNMENT SECURITIES; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $30,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/18/1991 Sum of All Relief Awarded: $15,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 256 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 10/29/1990 Case Number: 90-02532 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $500,000.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 697 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/31/1992 Sum of All Relief Awarded: $20,750.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 257 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 05/20/1991 Case Number: 90-02547 Disputed Product Type: MUTUAL FUNDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $14,308.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/11/1992 Sum of All Relief Awarded: $2,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 258 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE- EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 01/15/1991

Case Number: 90-02573 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $148,800.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/02/1992 Sum of All Relief Awarded: $78,425.30 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 259 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 11/14/1990 Case Number: 90-02614 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $400,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/03/1991 Sum of All Relief Awarded: $45,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 260 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/12/1990 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 699 www.finra.org/brokercheck User Guidance

Case Initiated: 11/12/1990 Case Number: 90-02712 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $250,933.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/15/1993 Sum of All Relief Awarded: $100,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 261 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/05/1990 Case Number: 90-02937 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; MUNICIPAL BONDS; MUTUAL FUNDS Sum of All Relief Requested: $1,462,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/03/1992 Sum of All Relief Awarded: $339,249.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 262 of 527 Reporting Source: Regulator Type of Event: ARBITRATION

©2021Allegations: FINRA. All rights reserved. Report aboutACCOUNT LEHMAN ACTIVITY-MISREPRESENTATION; BROTHERS INC. ACCOUNT ACTIVITY-OTHER; 700 ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/18/1991 Case Number: 90-03052 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $44,693.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/17/1991 Sum of All Relief Awarded: $10,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 263 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: NASD Case Initiated: 11/06/1990 Case Number: 90-03064 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $118,912.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/11/1991 Sum of All Relief Awarded: $24,104.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 264 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-EXECUTIONS-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/08/1991 Case Number: 90-03091 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $250,200.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/15/1991 Sum of All Relief Awarded: $38,720.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 265 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-OTHER Arbitration Forum: NASD Case Initiated: 04/30/1991 Case Number: 90-03103 Disputed Product Type: COMMON STOCK; MUNICIPAL BOND FUNDS; MUTUAL FUNDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/12/1992 Sum of All Relief Awarded: $20,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 702 www.finra.org/brokercheck User Guidance

i Disclosure 266 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/26/1990 Case Number: 90-03107 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $655,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/11/1991 Sum of All Relief Awarded: $20,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 267 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/02/1991 Case Number: 90-03151 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $18,967.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/09/1991 Sum of All Relief Awarded: $15,550.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 268 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/19/1990 Case Number: 90-03220 Disputed Product Type: MUNICIPAL BONDS; OPTIONS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $22,821,094.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/14/1992 Sum of All Relief Awarded: $657,800.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 269 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 02/07/1991 Case Number: 90-03245 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $175,216.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 704 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 04/06/1992 Sum of All Relief Awarded: $71,069.12 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 270 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 03/25/1991 Case Number: 90-03303 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK Sum of All Relief Requested: $24,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/10/1992 Sum of All Relief Awarded: $13,350.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 271 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/27/1990 Case Number: 90-03305 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 705 www.finra.org/brokercheck User Guidance

Case Number: 90-03305 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $8,594.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/22/1991 Sum of All Relief Awarded: $5,050.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 272 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/03/1990 Case Number: 90-03310 Disputed Product Type: OTHER TYPES OF SECURITIES; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/23/1991 Sum of All Relief Awarded: $10,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 273 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-COLLECTION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/14/1990 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 706 www.finra.org/brokercheck User Guidance

Case Initiated: 12/14/1990 Case Number: 90-03375 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/01/1991 Sum of All Relief Awarded: $238,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 274 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/07/1990 Case Number: 90-03426 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,462.80 Disposition: AWARD AGAINST PARTY Disposition Date: 05/06/1991 Sum of All Relief Awarded: $1,462.80 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 275 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE- NO OTHER CONTROVERSY INVOLVED ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 707 www.finra.org/brokercheck User Guidance ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE- NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/12/1991 Case Number: 90-03441 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $432,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/16/1992 Sum of All Relief Awarded: $333,091.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 276 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED- NEGLIGENCE; ACCOUNT RELATED-OTHER; DO NOT USE-EXECUTIONS- FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 01/24/1991 Case Number: 90-03553 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,632,151.78 Disposition: AWARD AGAINST PARTY Disposition Date: 06/11/1992 Sum of All Relief Awarded: $55,048.78 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 277 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/18/1991 Case Number: 90-03590 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $24,050.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/24/1991 Sum of All Relief Awarded: $12,125.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 278 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/31/1990 Case Number: 90-03594 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $16,946.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/01/1991 Sum of All Relief Awarded: $13,442.72 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 279 of 527 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 709 www.finra.org/brokercheck User Guidance

Disclosure 279 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/14/1991 Case Number: 90-03667 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $120,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/31/1991 Sum of All Relief Awarded: $45,613.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 280 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/24/1991 Case Number: 91-00003 Disputed Product Type: COMMON STOCK; LIMITED PARTNERSHIPS; OPTIONS; PREFERRED STOCK Sum of All Relief Requested: $2,200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/18/1991 Sum of All Relief Awarded: $370,000.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 281 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/22/1991 Case Number: 91-00049 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $8,559.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/30/1991 Sum of All Relief Awarded: $2,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 282 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/08/1991 Case Number: 91-00084 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $46,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/06/1992 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 711 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 283 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/25/1991 Case Number: 91-00114 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $7,835.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/30/1991 Sum of All Relief Awarded: $500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 284 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/17/1991 Case Number: 91-00120 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $36,487.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 712 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 11/22/1991 Sum of All Relief Awarded: $17,977.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 285 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 01/17/1991 Case Number: 91-00135 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS; PREFERRED STOCK Sum of All Relief Requested: $308,168.04 Disposition: AWARD AGAINST PARTY Disposition Date: 11/25/1991 Sum of All Relief Awarded: $154,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 286 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/23/1991 Case Number: 91-00152 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 713 www.finra.org/brokercheck User Guidance

Case Number: 91-00152 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $5,444.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/20/1991 Sum of All Relief Awarded: $1,375.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 287 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/17/1991 Case Number: 91-00199 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $29,636.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/16/1992 Sum of All Relief Awarded: $3,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 288 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 714 www.finra.org/brokercheck User Guidance

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 02/01/1991 Case Number: 91-00202 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $63,159.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/21/1992 Sum of All Relief Awarded: $27,231.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 289 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/25/1991 Case Number: 91-00231 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $250,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/09/1991 Sum of All Relief Awarded: $190,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 290 of 527 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 715 www.finra.org/brokercheck User Guidance

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/21/1991 Case Number: 91-00238 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $33,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/19/1991 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 291 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 05/17/1991 Case Number: 91-00267 Disputed Product Type: COMMON STOCK; MUNICIPAL BONDS; MUTUAL FUNDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $352,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/13/1992 Sum of All Relief Awarded: $30,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 292 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 02/06/1991 Case Number: 91-00268 Disputed Product Type: COMMODITIES FUTURES; COMMON STOCK; OPTIONS; PREFERRED STOCK Sum of All Relief Requested: $119,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/31/1992 Sum of All Relief Awarded: $81,253.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 293 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/23/1991 Case Number: 91-00273 Disputed Product Type: COMMODITIES FUTURES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; OPTIONS Sum of All Relief Requested: $100,669.09 Disposition: AWARD AGAINST PARTY Disposition Date: 09/10/1992 Sum of All Relief Awarded: $34,500.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 294 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/06/1991 Case Number: 91-00277 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $126,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/26/1992 Sum of All Relief Awarded: $71,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 295 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; TRADING DISPUTES- OTHER Arbitration Forum: NASD Case Initiated: 01/31/1991 Case Number: 91-00301 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; MUNICIPAL BOND FUNDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $87,000.00

Disposition: AWARD AGAINST PARTY Disposition Date: 12/13/1991 Sum of All Relief Awarded: $24,156.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 296 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 03/27/1991 Case Number: 91-00317 Disputed Product Type: LIMITED PARTNERSHIPS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $40,169.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/26/1991 Sum of All Relief Awarded: $20,755.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 297 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/12/1991 Case Number: 91-00438 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $42,238.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 719 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $42,238.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/23/1991 Sum of All Relief Awarded: $21,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 298 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 02/25/1991 Case Number: 91-00481 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $28,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/18/1991 Sum of All Relief Awarded: $2,677.02 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 299 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 03/04/1991 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 720 www.finra.org/brokercheck User Guidance

Case Initiated: 03/04/1991 Case Number: 91-00508 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; OPTIONS Sum of All Relief Requested: $5,094,940.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/26/1992 Sum of All Relief Awarded: $83,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 300 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 03/13/1991 Case Number: 91-00588 Disputed Product Type: COMMON STOCK; GINNIE MAES; OPTIONS; WARRANTS/RIGHTS Sum of All Relief Requested: $287,848.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/09/1992 Sum of All Relief Awarded: $47,738.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 301 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report aboutMISREPRESENTATION; LEHMAN BROTHERS INC. ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT 721 ACTIVITY-UNAUTHORIZED TRADING www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 05/17/1991 Case Number: 91-00593 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $99,900.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/08/1993 Sum of All Relief Awarded: $96,036.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 302 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 02/28/1991 Case Number: 91-00665 Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $15,075.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/24/1991 Sum of All Relief Awarded: $5,400.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 303 of 527 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 722 www.finra.org/brokercheck User Guidance

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 03/14/1991 Case Number: 91-00705 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $480,248.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/30/1991 Sum of All Relief Awarded: $150,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 304 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/17/1991 Case Number: 91-00706 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $1,950,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/25/1992 Sum of All Relief Awarded: $335,360.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 305 of 527 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 723 www.finra.org/brokercheck User Guidance

Disclosure 305 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 04/16/1991 Case Number: 91-00725 Disputed Product Type: COMMON STOCK; OPTIONS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $25,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/26/1992 Sum of All Relief Awarded: $12,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 306 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 03/13/1991 Case Number: 91-00732 Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $7,933.15 Disposition: AWARD AGAINST PARTY Disposition Date: 02/05/1993 Sum of All Relief Awarded: $7,933.15 There may be a non-monetary award associated with this arbitration.

Please select the Case Number above to view more detailed information. i Disclosure 307 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY- SUITABILITY Arbitration Forum: NASD Case Initiated: 04/17/1991 Case Number: 91-00745 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; OPTIONS Sum of All Relief Requested: $260,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/13/1992 Sum of All Relief Awarded: $9,800.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 308 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 03/15/1991 Case Number: 91-00769 Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/13/1992 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 725 www.finra.org/brokercheck User Guidance

Disposition Date: 05/13/1992 Sum of All Relief Awarded: $74,263.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 309 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-MARGIN CALLS; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 05/15/1991 Case Number: 91-00818 Disputed Product Type: UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $600,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/20/1992 Sum of All Relief Awarded: $34,521.92 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 310 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 04/01/1991 Case Number: 91-00824 Disputed Product Type: LIMITED PARTNERSHIPS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $232,636.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 726 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $232,636.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/14/1992 Sum of All Relief Awarded: $88,836.98 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 311 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/20/1991 Case Number: 91-00858 Disputed Product Type: CORPORATE BONDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $81,413.63 Disposition: AWARD AGAINST PARTY Disposition Date: 10/04/1991 Sum of All Relief Awarded: $75,404.37 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 312 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/18/1991 Case Number: 91-00913 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 727 www.finra.org/brokercheck User Guidance

Case Number: 91-00913 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; LIMITED PARTNERSHIPS; MUNICIPAL BOND FUNDS Sum of All Relief Requested: $750,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/29/1992 Sum of All Relief Awarded: $52,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 313 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 04/22/1991 Case Number: 91-01007 Disputed Product Type: CORPORATE BONDS; LIMITED PARTNERSHIPS; OPTIONS; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $151,056.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/31/1992 Sum of All Relief Awarded: $13,190.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 314 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 728 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/16/1991 Case Number: 91-01033 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $59,812.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/03/1992 Sum of All Relief Awarded: $2,200.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 315 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE- NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/01/1991 Case Number: 91-01049 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $20,206.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/15/1991 Sum of All Relief Awarded: $8,135.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 316 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/17/1991 Case Number: 91-01097 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $3,963.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/07/1991 Sum of All Relief Awarded: $3,125.54 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 317 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/22/1991 Case Number: 91-01098 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $126,952.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/25/1992 Sum of All Relief Awarded: $45,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 318 of 527 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 730 www.finra.org/brokercheck User Guidance

Disclosure 318 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/03/1991 Case Number: 91-01099 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; MUTUAL FUNDS; OPTIONS Sum of All Relief Requested: $628,755.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/26/1993 Sum of All Relief Awarded: $12,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 319 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 05/21/1991 Case Number: 91-01156 Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $89,400.51 Disposition: AWARD AGAINST PARTY Disposition Date: 05/29/1992 Sum of All Relief Awarded: $22,767.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 320 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/08/1991 Case Number: 91-01186 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $110,521.85 Disposition: AWARD AGAINST PARTY Disposition Date: 03/31/1992 Sum of All Relief Awarded: $32,422.71 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 321 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/03/1991 Case Number: 91-01304 Disputed Product Type: UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $55,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/03/1992 Sum of All Relief Awarded: $48,060.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 732 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $48,060.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 322 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/10/1991 Case Number: 91-01314 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $7,392.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/03/1992 Sum of All Relief Awarded: $1,050.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 323 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/21/1991 Case Number: 91-01335 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $81,724.00

Disposition: AWARD AGAINST PARTY Disposition Date: 03/12/1992 Sum of All Relief Awarded: $21,995.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 324 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/08/1991 Case Number: 91-01342 Disputed Product Type: COMMODITIES FUTURES; COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $232,425.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/16/1992 Sum of All Relief Awarded: $21,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 325 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 05/14/1991 Case Number: 91-01386 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 734 www.finra.org/brokercheck User Guidance

Case Number: 91-01386 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $980,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/04/1992 Sum of All Relief Awarded: $89,334.33 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 326 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 07/03/1991 Case Number: 91-01387 Disputed Product Type: COMMODITIES FUTURES; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $12,800,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/05/1993 Sum of All Relief Awarded: $904,249.17 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 327 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 735 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 05/10/1991 Case Number: 91-01397 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $47,679.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/22/1993 Sum of All Relief Awarded: $15,247.70 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 328 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/10/1991 Case Number: 91-01402 Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $74,725.60 Disposition: AWARD AGAINST PARTY Disposition Date: 11/18/1993 Sum of All Relief Awarded: $52,050.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 329 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; DO NOT USE-NO OTHER ©2021 FINRA. All rights reserved. Report aboutCONTROVERSY LEHMAN BROTHERS INVOLVED; INC. EMPLOYMENT-COMMISSIONS 736 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; EMPLOYMENT-COMMISSIONS Arbitration Forum: NASD Case Initiated: 01/13/1992 Case Number: 91-01423 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $546,032.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/16/1994 Sum of All Relief Awarded: $160,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 330 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 09/27/1991 Case Number: 91-01484 Disputed Product Type: COMMON STOCK; OPTIONS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $8,100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/31/1994 Sum of All Relief Awarded: $236,159.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 331 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 05/28/1991 Case Number: 91-01521 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $70,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/20/1992 Sum of All Relief Awarded: $6,770.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 332 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-MARGIN CALLS Arbitration Forum: NASD Case Initiated: 06/03/1991 Case Number: 91-01526 Disputed Product Type: COMMON STOCK; LIMITED PARTNERSHIPS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $40,909.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/23/1993 Sum of All Relief Awarded: $20,000.00 There may be a non-monetary award associated with this arbitration. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 738 www.finra.org/brokercheck User Guidance

Please select the Case Number above to view more detailed information. i Disclosure 333 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/06/1991 Case Number: 91-01552 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $390,468.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/12/1992 Sum of All Relief Awarded: $43,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 334 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 05/30/1991 Case Number: 91-01595 Disputed Product Type: OPTIONS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,057,784.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/06/1993 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 739 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $180,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 335 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 06/07/1991 Case Number: 91-01624 Disputed Product Type: CORPORATE BONDS; MUTUAL FUNDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $477,394.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/18/1992 Sum of All Relief Awarded: $70,027.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 336 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 07/15/1991 Case Number: 91-01644 Disputed Product Type: COMMON STOCK; LIMITED PARTNERSHIPS; MUNICIPAL BONDS; MUTUAL FUNDS Sum of All Relief Requested: $24,500,000.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 740 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $24,500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/30/1996 Sum of All Relief Awarded: $558,300.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 337 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-COLLECTION; ACCOUNT RELATED-ERRORS- CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/10/1991 Case Number: 91-01740 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES Sum of All Relief Requested: $25,443.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/25/1991 Sum of All Relief Awarded: $7,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 338 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED- OTHER Arbitration Forum: NASD Case Initiated: 07/09/1991

Case Number: 91-01855 Disputed Product Type: COMMON STOCK; LIMITED PARTNERSHIPS; OPTIONS; PREFERRED STOCK Sum of All Relief Requested: $2,278,299.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/04/1992 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 339 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/28/1991 Case Number: 91-01868 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $562.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/27/1992 Sum of All Relief Awarded: $562.10 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 340 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- ERRORS-CHARGES; DO NOT USE-EXECUTIONS-OTHER; TRADING DISPUTES-SELL OUTS Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 742 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 09/20/1991 Case Number: 91-01887 Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $2,430.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/27/1993 Sum of All Relief Awarded: $1,625.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 341 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-OTHER Arbitration Forum: NASD Case Initiated: 07/11/1991 Case Number: 91-01903 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $465,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/12/1992 Sum of All Relief Awarded: $33,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 342 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report aboutMISREPRESENTATION; LEHMAN BROTHERS INC. ACCOUNT RELATED-BREACH OF CONTRACT; 743 ACCOUNT RELATED-NEGLIGENCE www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 06/28/1991 Case Number: 91-01916 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $72,032.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/10/1992 Sum of All Relief Awarded: $17,342.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 343 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 07/31/1991 Case Number: 91-01949 Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $5,200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/09/1992 Sum of All Relief Awarded: $233,318.16 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 344 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/16/1991 Case Number: 91-01974 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $600,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/26/1993 Sum of All Relief Awarded: $300,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 345 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 07/09/1991 Case Number: 91-02007 Disputed Product Type: UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $103,515.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/12/1992 Sum of All Relief Awarded: $61,680.00 There may be a non-monetary award associated with this arbitration.

Please select the Case Number above to view more detailed information. i Disclosure 346 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 07/02/1991 Case Number: 91-02009 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $347,935.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/25/1992 Sum of All Relief Awarded: $63,502.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 347 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 08/20/1991 Case Number: 91-02306 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $1,250,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/25/1993 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 746 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $65,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 348 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 08/12/1991 Case Number: 91-02314 Disputed Product Type: COMMON STOCK; OPTIONS; PREFERRED STOCK; WARRANTS/RIGHTS Sum of All Relief Requested: $1,788,288.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/19/1992 Sum of All Relief Awarded: $28,875.05 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 349 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 08/02/1991 Case Number: 91-02322 Disputed Product Type: CORPORATE BONDS; GINNIE MAES; LIMITED PARTNERSHIPS; MUTUAL FUNDS Sum of All Relief Requested: $2,079,468.96 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 747 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $2,079,468.96 Disposition: AWARD AGAINST PARTY Disposition Date: 04/20/1992 Sum of All Relief Awarded: $8,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 350 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 08/02/1991 Case Number: 91-02343 Disputed Product Type: COMMON STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $24,892.55 Disposition: AWARD AGAINST PARTY Disposition Date: 08/03/1992 Sum of All Relief Awarded: $331,364.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 351 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 08/09/1991 Case Number: 91-02435 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 748 www.finra.org/brokercheck User Guidance

Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $40,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/12/1992 Sum of All Relief Awarded: $19,388.71 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 352 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 09/04/1991 Case Number: 91-02437 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $220,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/16/1992 Sum of All Relief Awarded: $47,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 353 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD

Case Initiated: 09/04/1991 Case Number: 91-02535 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $4,612.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/22/1992 Sum of All Relief Awarded: $1,537.33 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 354 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- ERRORS-CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/09/1991 Case Number: 91-02656 Disputed Product Type: OPTIONS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/30/1992 Sum of All Relief Awarded: $2,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 355 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED- ERRORS-CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 750 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 11/08/1991 Case Number: 91-02674 Disputed Product Type: UNKNOWN TYPE OF SECURITIES; WARRANTS/RIGHTS Sum of All Relief Requested: $126,100.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/31/1992 Sum of All Relief Awarded: $26,100.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 356 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE- NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/06/1991 Case Number: 91-02766 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS Sum of All Relief Requested: $9,888.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/24/1992 Sum of All Relief Awarded: $2,881.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 357 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED; EMPLOYMENT- COMMISSIONS; EMPLOYMENT-OTHER Arbitration Forum: NASD Case Initiated: 10/31/1991 Case Number: 91-02789 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $628,260.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/05/1992 Sum of All Relief Awarded: $161,350.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 358 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/05/1991 Case Number: 91-02804 Disputed Product Type: CORPORATE BONDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $36,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/11/1992 Sum of All Relief Awarded: $4,460.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 359 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/24/1992 Case Number: 91-02938 Disputed Product Type: LIMITED PARTNERSHIPS; PREFERRED STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $4,593.03 Disposition: AWARD AGAINST PARTY Disposition Date: 09/24/1992 Sum of All Relief Awarded: $3,087.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 360 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/09/1991 Case Number: 91-02947 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $7,742.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/23/1992 Sum of All Relief Awarded: $3,375.00 There may be a non-monetary award associated with this arbitration. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 753 www.finra.org/brokercheck User Guidance

Please select the Case Number above to view more detailed information. i Disclosure 361 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 10/04/1991 Case Number: 91-02966 Disputed Product Type: COMMON STOCK; LIMITED PARTNERSHIPS; OPTIONS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $93,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/27/1992 Sum of All Relief Awarded: $10,389.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 362 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 10/10/1991 Case Number: 91-03006 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/10/1992 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 754 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $6,480.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 363 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 02/24/1992 Case Number: 91-03022 Disputed Product Type: MUTUAL FUNDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $8,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/17/1992 Sum of All Relief Awarded: $6,026.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 364 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/07/1991 Case Number: 91-03048 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK Sum of All Relief Requested: $25,200.00

Disposition: AWARD AGAINST PARTY Disposition Date: 08/28/1992 Sum of All Relief Awarded: $28,553.85 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 365 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 10/08/1991 Case Number: 91-03060 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GINNIE MAES; MUTUAL FUNDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $3,146,280.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/08/1992 Sum of All Relief Awarded: $8,156.25 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 366 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 11/01/1991 Case Number: 91-03073

Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $1,190,653.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/01/1992 Sum of All Relief Awarded: $1,250.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 367 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED- TRANSFER Arbitration Forum: NASD Case Initiated: 10/25/1991 Case Number: 91-03106 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $110,277.50 Disposition: AWARD AGAINST PARTY Disposition Date: 09/03/1992 Sum of All Relief Awarded: $3,570.62 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 368 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 757 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 10/14/1991 Case Number: 91-03151 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES Sum of All Relief Requested: $5,446.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/22/1992 Sum of All Relief Awarded: $2,624.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 369 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/04/1991 Case Number: 91-03206 Disputed Product Type: CORPORATE BONDS; LIMITED PARTNERSHIPS; MUNICIPAL BOND FUNDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $48,794.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/12/1992 Sum of All Relief Awarded: $14,124.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 370 of 527 Reporting Source: Regulator Type of Event: ARBITRATION ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 758 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE- EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 11/08/1991 Case Number: 91-03273 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES; MUTUAL FUNDS Sum of All Relief Requested: $308,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/13/1992 Sum of All Relief Awarded: $5,827.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 371 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 12/13/1991 Case Number: 91-03299 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/19/1993 Sum of All Relief Awarded: $7,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i

Disclosure 372 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/03/1991 Case Number: 91-03398 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $22,394.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/30/1992 Sum of All Relief Awarded: $5,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 373 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/12/1991 Case Number: 91-03523 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $60,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/12/1992 Sum of All Relief Awarded: $15,937.50

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 374 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY- SUITABILITY Arbitration Forum: NASD Case Initiated: 11/21/1991 Case Number: 91-03553 Disputed Product Type: GOVERNMENT SECURITIES; LIMITED PARTNERSHIPS; MUTUAL FUNDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,660,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/09/1993 Sum of All Relief Awarded: $300,450.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 375 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 11/19/1991 Case Number: 91-03581 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $799,972.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 761 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 09/09/1992 Sum of All Relief Awarded: $84,166.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 376 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 11/22/1991 Case Number: 91-03677 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $149,681.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/15/1992 Sum of All Relief Awarded: $16,761.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 377 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/10/1991 Case Number: 91-03807 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; LIMITED PARTNERSHIPS; OPTIONS ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 762 www.finra.org/brokercheck User Guidance

Disputed Product Type: COMMON STOCK; CORPORATE BONDS; LIMITED PARTNERSHIPS; OPTIONS Sum of All Relief Requested: $46,732.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/22/1993 Sum of All Relief Awarded: $12,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 378 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 12/11/1991 Case Number: 91-03851 Disputed Product Type: GINNIE MAES; LIMITED PARTNERSHIPS; OPTIONS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $180,344.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/24/1993 Sum of All Relief Awarded: $70,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 379 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 763 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 01/27/1992 Case Number: 91-03925 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $75,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/30/1992 Sum of All Relief Awarded: $37,700.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 380 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/06/1992 Case Number: 91-03992 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $60,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/05/1993 Sum of All Relief Awarded: $96,508.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 381 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER ©2021 FINRA. All rights reserved. Report aboutCONTROVERSY LEHMAN BROTHERS INVOLVED INC. 764 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/24/1991 Case Number: 91-03998 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $450,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/18/1992 Sum of All Relief Awarded: $2,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 382 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/27/1992 Case Number: 91-04034 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $19,519.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/20/1992 Sum of All Relief Awarded: $19,519.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 383 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/14/1992 Case Number: 91-04043 Disputed Product Type: COMMON STOCK; OPTIONS; UNKNOWN TYPE OF SECURITIES; WARRANTS/RIGHTS Sum of All Relief Requested: $210,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/10/1993 Sum of All Relief Awarded: $10,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 384 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 01/08/1992 Case Number: 91-04052 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES; MUTUAL FUNDS Sum of All Relief Requested: $224,344.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/18/1992 Sum of All Relief Awarded: $45,000.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 385 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/07/1992 Case Number: 91-04059 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $310,177.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/19/1993 Sum of All Relief Awarded: $55,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 386 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/27/1991 Case Number: 91-04080 Disputed Product Type: COMMON STOCK; GOVERNMENT SECURITIES; LIMITED PARTNERSHIPS; MUTUAL FUNDS Sum of All Relief Requested: $400,000.00

Disposition: AWARD AGAINST PARTY Disposition Date: 09/21/1992 Sum of All Relief Awarded: $27,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 387 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 01/24/1992 Case Number: 91-04084 Disputed Product Type: GINNIE MAES; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $7,344.11 Disposition: AWARD AGAINST PARTY Disposition Date: 10/29/1992 Sum of All Relief Awarded: $7,344.11 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 388 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 01/09/1992 Case Number: 91-04099 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF ©2021 FINRA. All rights reserved. Report aboutSEC LEHMAN INVOLVE; BROTHERS PREFERRED INC. STOCK 768 www.finra.org/brokercheck User Guidance

Disputed Product Type: COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/07/1992 Sum of All Relief Awarded: $456,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 389 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/29/1992 Case Number: 91-04104 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,969.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/24/1992 Sum of All Relief Awarded: $1,926.75 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 390 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 03/13/1992 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 769 www.finra.org/brokercheck User Guidance

Case Number: 92-00029 Disputed Product Type: CORPORATE BONDS; OPTIONS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/20/1994 Sum of All Relief Awarded: $25,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 391 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 03/17/1992 Case Number: 92-00147 Disputed Product Type: UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,375,802.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/31/1994 Sum of All Relief Awarded: $112,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 392 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 04/22/1992 Case Number: 92-00197 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $25,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/20/1993 Sum of All Relief Awarded: $17,757.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 393 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/27/1992 Case Number: 92-00243 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $5,125.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/04/1992 Sum of All Relief Awarded: $125.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 394 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report aboutMISREPRESENTATION; LEHMAN BROTHERS INC. ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT 771 ACTIVITY-UNAUTHORIZED TRADING www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 03/03/1992 Case Number: 92-00282 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 12/21/1993 Sum of All Relief Awarded: $119,137.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 395 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/13/1992 Case Number: 92-00336 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $111,384.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/13/1993 Sum of All Relief Awarded: $3,129.29 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 396 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/14/1992 Case Number: 92-00427 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $50,824.40 Disposition: AWARD AGAINST PARTY Disposition Date: 02/22/1993 Sum of All Relief Awarded: $18,612.20 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 397 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 03/13/1992 Case Number: 92-00458 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $122,331.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/23/1992 Sum of All Relief Awarded: $40,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 773 www.finra.org/brokercheck User Guidance

i Disclosure 398 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 03/03/1992 Case Number: 92-00492 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $5,254,750.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/11/1992 Sum of All Relief Awarded: $3,400.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 399 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 02/21/1992 Case Number: 92-00517 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK Sum of All Relief Requested: $445,887.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/14/1993 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 774 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $224,680.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 400 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 02/18/1992 Case Number: 92-00544 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $75,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/22/1992 Sum of All Relief Awarded: $20,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 401 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 02/21/1992 Case Number: 92-00545 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $380,000.00

Disposition: AWARD AGAINST PARTY Disposition Date: 06/02/1993 Sum of All Relief Awarded: $25,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 402 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/09/1992 Case Number: 92-00573 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $35,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/02/1992 Sum of All Relief Awarded: $10,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 403 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 02/26/1992 Case Number: 92-00577 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GINNIE ©2021 FINRA. All rights reserved. Report aboutMAES LEHMAN BROTHERS INC. 776 www.finra.org/brokercheck User Guidance

Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GINNIE MAES Sum of All Relief Requested: $123,688.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/19/1992 Sum of All Relief Awarded: $4,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 404 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 03/04/1992 Case Number: 92-00670 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; WARRANTS/RIGHTS Sum of All Relief Requested: $30,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/14/1995 Sum of All Relief Awarded: $90,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 405 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- FAILURE TO SUPERVISE Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 777 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 04/06/1992 Case Number: 92-00761 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 07/19/1993 Sum of All Relief Awarded: $44,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 406 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT RELATED-TRANSFER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/30/1992 Case Number: 92-00793 Disputed Product Type: COMMODITIES FUTURES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/02/1992 Sum of All Relief Awarded: $2,073.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 407 of 527 Reporting Source: Regulator Type of Event: ARBITRATION ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 778 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT RELATED-EXCHANGES; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/10/1992 Case Number: 92-00797 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $6,412.50 Disposition: AWARD AGAINST PARTY Disposition Date: 09/10/1992 Sum of All Relief Awarded: $1,971.75 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 408 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE- EXECUTIONS-LIMIT V MRKT ORDR Arbitration Forum: NASD Case Initiated: 04/01/1992 Case Number: 92-00834 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $8,190.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/05/1992 Sum of All Relief Awarded: $7,050.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 409 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 03/25/1992 Case Number: 92-00862 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $40,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/08/1993 Sum of All Relief Awarded: $24,844.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 410 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/15/1992 Case Number: 92-00948 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS Sum of All Relief Requested: $5,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/28/1992 Sum of All Relief Awarded: $5,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 411 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 04/08/1992 Case Number: 92-01011 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $203,711.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/06/1993 Sum of All Relief Awarded: $25,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 412 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 04/15/1992 Case Number: 92-01177 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS; WARRANTS/RIGHTS Sum of All Relief Requested: $9,372.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/24/1992 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 781 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $2,050.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 413 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 04/08/1992 Case Number: 92-01183 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $68,190.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/24/1993 Sum of All Relief Awarded: $46,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 414 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/04/1992 Case Number: 92-01233 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $3,194.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 782 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 01/11/1993 Sum of All Relief Awarded: $2,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 415 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 04/27/1992 Case Number: 92-01402 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $57,224.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/09/1993 Sum of All Relief Awarded: $15,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 416 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 06/19/1992 Case Number: 92-01433

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $30,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/31/1994 Sum of All Relief Awarded: $24,200.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 417 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/14/1992 Case Number: 92-01451 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $308,603.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/02/1993 Sum of All Relief Awarded: $230,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 418 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD

Case Initiated: 05/05/1992 Case Number: 92-01543 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $83,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/02/1993 Sum of All Relief Awarded: $73,185.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 419 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 05/15/1992 Case Number: 92-01565 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS; MUTUAL FUNDS Sum of All Relief Requested: $700,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/16/1994 Sum of All Relief Awarded: $100,130.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 420 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHER ©2021 FINRA. All rights reserved. Report aboutCONTROVERSY LEHMAN BROTHERS INVOLVED INC. 785 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/20/1992 Case Number: 92-01611 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $26,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/20/1993 Sum of All Relief Awarded: $16,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 421 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 06/08/1992 Case Number: 92-01654 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $8,220.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/19/1993 Sum of All Relief Awarded: $2,443.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 422 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 06/19/1992 Case Number: 92-01656 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $37,841.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/14/1993 Sum of All Relief Awarded: $3,068.75 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 423 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 07/08/1992 Case Number: 92-01804 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS Sum of All Relief Requested: $11,400,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/14/1993 Sum of All Relief Awarded: $2,660,781.10 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 424 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 06/03/1992 Case Number: 92-01842 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $97,200.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/09/1993 Sum of All Relief Awarded: $16,537.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 425 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 08/04/1992 Case Number: 92-01962 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $4,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/25/1994 Sum of All Relief Awarded: $59,163.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 788 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $59,163.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 426 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 07/31/1992 Case Number: 92-01976 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $4,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/13/1994 Sum of All Relief Awarded: $111,284.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 427 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 07/17/1992 Case Number: 92-02040 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $811,341.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 789 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $811,341.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/19/1993 Sum of All Relief Awarded: $57,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 428 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 07/17/1992 Case Number: 92-02042 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $961,455.42 Disposition: AWARD AGAINST PARTY Disposition Date: 02/02/1994 Sum of All Relief Awarded: $55,045.21 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 429 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/09/1992

Case Number: 92-02048 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $87,828.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/16/1993 Sum of All Relief Awarded: $61,805.92 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 430 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 08/06/1992 Case Number: 92-02163 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $224,550.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/19/1995 Sum of All Relief Awarded: $100,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 431 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 791 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 08/27/1992 Case Number: 92-02247 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $39,577.28 Disposition: AWARD AGAINST PARTY Disposition Date: 04/16/1993 Sum of All Relief Awarded: $23,050.68 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 432 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 07/13/1992 Case Number: 92-02257 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $52,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/31/1993 Sum of All Relief Awarded: $35,750.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 433 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/13/1992 Case Number: 92-02300 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $7,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/08/1993 Sum of All Relief Awarded: $250.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 434 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED- FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 07/21/1992 Case Number: 92-02411 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS; MUNICIPAL BONDS Sum of All Relief Requested: $36,729.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/26/1993 Sum of All Relief Awarded: $8,422.33 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 793 www.finra.org/brokercheck User Guidance

i Disclosure 435 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 09/23/1992 Case Number: 92-02452 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 09/13/1993 Sum of All Relief Awarded: $3,343,516.96 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 436 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 08/25/1992 Case Number: 92-02660 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS; PREFERRED STOCK Sum of All Relief Requested: $271,460.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/28/1993 Sum of All Relief Awarded: $145,962.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 794 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $145,962.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 437 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/09/1992 Case Number: 92-02792 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/12/1993 Sum of All Relief Awarded: $5,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 438 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/20/1992 Case Number: 92-02958 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $6,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/02/1994 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 795 www.finra.org/brokercheck User Guidance

Disposition Date: 02/02/1994 Sum of All Relief Awarded: $6,064.60 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 439 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 09/21/1992 Case Number: 92-02965 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $11,896.04 Disposition: AWARD AGAINST PARTY Disposition Date: 07/22/1994 Sum of All Relief Awarded: $7,800.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 440 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/02/1992 Case Number: 92-03141 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

Sum of All Relief Requested: $2,762.50 Disposition: AWARD AGAINST PARTY Disposition Date: 07/16/1993 Sum of All Relief Awarded: $1,893.89 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 441 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 09/22/1992 Case Number: 92-03161 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $24,981.60 Disposition: AWARD AGAINST PARTY Disposition Date: 07/25/1994 Sum of All Relief Awarded: $10,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 442 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/19/1992 Case Number: 92-03194 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 797 www.finra.org/brokercheck User Guidance

Case Number: 92-03194 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $30,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/13/1993 Sum of All Relief Awarded: $5,700.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 443 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE- NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/28/1993 Case Number: 92-03199 Disputed Product Type: ANNUITIES; COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK Sum of All Relief Requested: $90,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/13/1994 Sum of All Relief Awarded: $26,663.91 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 444 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 798 www.finra.org/brokercheck User Guidance

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/09/1992 Case Number: 92-03241 Disputed Product Type: COMMODITIES FUTURES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $145,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/27/1995 Sum of All Relief Awarded: $15,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 445 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/21/1992 Case Number: 92-03432 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $16,698.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/14/1993 Sum of All Relief Awarded: $6,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 446 of 527 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 799 www.finra.org/brokercheck User Guidance

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 11/11/1992 Case Number: 92-03681 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FANNIE MAE; GINNIE MAES Sum of All Relief Requested: $3,224,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/24/1994 Sum of All Relief Awarded: $73,200.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 447 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/04/1992 Case Number: 92-03859 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/18/1993 Sum of All Relief Awarded: $2,437.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 800 www.finra.org/brokercheck User Guidance

i Disclosure 448 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/01/1992 Case Number: 92-03956 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $14,250.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/18/1993 Sum of All Relief Awarded: $14,250.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 449 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/08/1993 Case Number: 92-03965 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $3,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/28/1994 Sum of All Relief Awarded: $1,260,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 450 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 02/12/1993 Case Number: 92-04198 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $139,012.12 Disposition: AWARD AGAINST PARTY Disposition Date: 06/10/1994 Sum of All Relief Awarded: $13,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 451 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/30/1992 Case Number: 92-04214 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK Sum of All Relief Requested: $400,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/10/1994 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 802 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $139,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 452 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/14/1993 Case Number: 92-04235 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $10,150.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/26/1993 Sum of All Relief Awarded: $8,950.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 453 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/07/1993 Case Number: 92-04311 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 803 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 12/09/1993 Sum of All Relief Awarded: $16,586.69 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 454 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/29/1993 Case Number: 93-00127 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK Sum of All Relief Requested: $133.85 Disposition: AWARD AGAINST PARTY Disposition Date: 06/23/1993 Sum of All Relief Awarded: $133.85 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 455 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/02/1993 Case Number: 93-00252 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $9,595.00 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 804 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $9,595.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/10/1993 Sum of All Relief Awarded: $7,217.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 456 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/19/1993 Case Number: 93-00585 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $4,854.87 Disposition: AWARD AGAINST PARTY Disposition Date: 08/19/1993 Sum of All Relief Awarded: $3,364.20 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 457 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/16/1993 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 805 www.finra.org/brokercheck User Guidance

Case Initiated: 03/16/1993 Case Number: 93-00702 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $137,442.93 Disposition: AWARD AGAINST PARTY Disposition Date: 03/24/1994 Sum of All Relief Awarded: $65,316.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 458 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/23/1993 Case Number: 93-00796 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; OPTIONS Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/18/1994 Sum of All Relief Awarded: $75,950.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 459 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT ©2021 FINRA. All rights reserved. Report aboutRELATED-NEGLIGENCE LEHMAN BROTHERS INC. 806 www.finra.org/brokercheck User Guidance

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 03/11/1993 Case Number: 93-00866 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 06/20/1994 Sum of All Relief Awarded: $20,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 460 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 04/29/1993 Case Number: 93-00971 Disputed Product Type: ANNUITIES; COMMON STOCK; CORPORATE BONDS; MUNICIPAL BOND FUNDS Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/20/1994 Sum of All Relief Awarded: $98,159.63 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 461 of 527

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 03/30/1993 Case Number: 93-01027 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $235,900.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/27/1994 Sum of All Relief Awarded: $60,113.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 462 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 04/06/1993 Case Number: 93-01043 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $44,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/23/1994 Sum of All Relief Awarded: $4,000.00 There may be a non-monetary award associated with this arbitration.

Please select the Case Number above to view more detailed information. i Disclosure 463 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 04/16/1993 Case Number: 93-01218 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,444,390.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/10/1994 Sum of All Relief Awarded: $220,900.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 464 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 06/17/1993 Case Number: 93-01240 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $775,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/25/1994 Sum of All Relief Awarded: $151,056.32 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 809 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $151,056.32 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 465 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 04/27/1993 Case Number: 93-01283 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; LIMITED PARTNERSHIPS; OPTIONS Sum of All Relief Requested: $4,500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/03/1994 Sum of All Relief Awarded: $98,427.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 466 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: NASD Case Initiated: 04/05/1993 Case Number: 93-01343 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $10,150.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 810 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 08/31/1993 Sum of All Relief Awarded: $5,029.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 467 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/24/1993 Case Number: 93-01365 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS Sum of All Relief Requested: $7,527.20 Disposition: AWARD AGAINST PARTY Disposition Date: 09/27/1993 Sum of All Relief Awarded: $1,325.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 468 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/14/1993 Case Number: 93-01399 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 811 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $1,934.22 Disposition: AWARD AGAINST PARTY Disposition Date: 12/14/1993 Sum of All Relief Awarded: $895.40 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 469 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 04/22/1993 Case Number: 93-01418 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $30,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/21/1994 Sum of All Relief Awarded: $37,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 470 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/23/1993 Case Number: 93-01465 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 812 www.finra.org/brokercheck User Guidance

Case Number: 93-01465 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $15,300.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/10/1994 Sum of All Relief Awarded: $15,300.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 471 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 05/11/1993 Case Number: 93-01547 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/20/1995 Sum of All Relief Awarded: $116,065.19 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 472 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 813 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 05/11/1993 Case Number: 93-01661 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/13/1994 Sum of All Relief Awarded: $2,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 473 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/15/1993 Case Number: 93-01842 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $4,728.64 Disposition: AWARD AGAINST PARTY Disposition Date: 12/28/1993 Sum of All Relief Awarded: $2,426.82 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 474 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ©2021 FINRA. All rights reserved. Report aboutRELATED-NEGLIGENCE LEHMAN BROTHERS INC. 814 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 07/20/1993 Case Number: 93-01866 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $84,309.41 Disposition: AWARD AGAINST PARTY Disposition Date: 08/24/1994 Sum of All Relief Awarded: $17,320.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 475 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 07/29/1993 Case Number: 93-02157 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $430,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/21/1995 Sum of All Relief Awarded: $50,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 476 of 527 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 815 www.finra.org/brokercheck User Guidance

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/29/1993 Case Number: 93-02227 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FANNIE MAE; MUTUAL FUNDS Sum of All Relief Requested: $6,636.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/24/1994 Sum of All Relief Awarded: $1,545.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 477 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/22/1993 Case Number: 93-02300 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS Sum of All Relief Requested: $2,105.30 Disposition: AWARD AGAINST PARTY Disposition Date: 12/08/1993 Sum of All Relief Awarded: $2,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 478 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE- EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 08/02/1993 Case Number: 93-02526 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $75,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/21/1994 Sum of All Relief Awarded: $33,649.98 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 479 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/19/1993 Case Number: 93-02638 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $25,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/14/1994 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 817 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $1,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 480 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 08/02/1993 Case Number: 93-02851 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $73,687.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/12/1994 Sum of All Relief Awarded: $50,119.24 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 481 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/27/1993 Case Number: 93-03240 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; REAL ESTATE INVESTMENT TRUST ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 818 www.finra.org/brokercheck User Guidance

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $27,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/09/1994 Sum of All Relief Awarded: $2,100.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 482 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 09/01/1993 Case Number: 93-03411 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FANNIE MAE Sum of All Relief Requested: $2,555,940.16 Disposition: AWARD AGAINST PARTY Disposition Date: 12/05/1994 Sum of All Relief Awarded: $1,387,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 483 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 10/21/1993 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 819 www.finra.org/brokercheck User Guidance

Case Number: 93-03843 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; OPTIONS; WARRANTS/RIGHTS Sum of All Relief Requested: $130,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/28/1994 Sum of All Relief Awarded: $121,309.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 484 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/14/1993 Case Number: 93-04019 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $20,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/17/1995 Sum of All Relief Awarded: $3,550.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 485 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 820 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 11/04/1993 Case Number: 93-04050 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $23,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/22/1995 Sum of All Relief Awarded: $500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 486 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 10/15/1993 Case Number: 93-04061 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $800,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/07/1995 Sum of All Relief Awarded: $310,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 487 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 10/22/1993 Case Number: 93-04157 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $94,933.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/05/1995 Sum of All Relief Awarded: $18,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 488 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/16/1993 Case Number: 93-04254 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES; MUTUAL FUNDS Sum of All Relief Requested: $5,682.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/30/1994 Sum of All Relief Awarded: $6,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 489 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/29/1993 Case Number: 93-04289 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $4,979.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/29/1994 Sum of All Relief Awarded: $2,806.73 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 490 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/22/1993 Case Number: 93-04335 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,277,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/16/1996 Sum of All Relief Awarded: $90,000.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 491 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/04/1994 Case Number: 93-04616 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; OPTIONS Sum of All Relief Requested: $145,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/22/1996 Sum of All Relief Awarded: $29,849.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 492 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/07/1994 Case Number: 93-04684 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $988,955.07 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 824 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 06/27/1995 Sum of All Relief Awarded: $112,547.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 493 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/02/1994 Case Number: 93-04740 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $71,191.19 Disposition: AWARD AGAINST PARTY Disposition Date: 02/21/1995 Sum of All Relief Awarded: $14,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 494 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 02/10/1994 Case Number: 93-05015

©2021Disputed FINRA. Product All rights Type:reserved. Report aboutCOMMODITIES LEHMAN BROTHERS FUTURES; INC. DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; 825 OPTIONS www.finra.org/brokercheck User Guidance

Disputed Product Type: COMMODITIES FUTURES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $150,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/09/1995 Sum of All Relief Awarded: $49,915.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 495 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/09/1994 Case Number: 93-05147 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $9,656.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/09/1995 Sum of All Relief Awarded: $1,690.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 496 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/14/1994 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 826 www.finra.org/brokercheck User Guidance

Case Number: 94-00128 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $9,662.06 Disposition: AWARD AGAINST PARTY Disposition Date: 11/01/1994 Sum of All Relief Awarded: $6,662.06 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 497 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/21/1994 Case Number: 94-00188 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS; MUNICIPAL BONDS; MUTUAL FUNDS Sum of All Relief Requested: $20,173.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/27/1994 Sum of All Relief Awarded: $14,202.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 498 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE- NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 04/06/1994 Case Number: 94-00401 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $679,721.59 Disposition: AWARD AGAINST PARTY Disposition Date: 07/21/1998 Sum of All Relief Awarded: $259,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 499 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/01/1994 Case Number: 94-00441 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; LIMITED PARTNERSHIPS; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 06/11/1996 Sum of All Relief Awarded: $358,810.49 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 500 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ©2021 FINRA. All rights reserved. Report aboutDO NOTLEHMAN USE-NO BROTHERS OTHER INC. CONTROVERSY INVOLVED 828 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/01/1994 Case Number: 94-00443 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $114,779.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/21/1997 Sum of All Relief Awarded: $16,900.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 501 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/09/1994 Case Number: 94-00474 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $3,832.28 Disposition: AWARD AGAINST PARTY Disposition Date: 10/31/1994 Sum of All Relief Awarded: $1,610.46 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 502 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 04/15/1994 Case Number: 94-00648 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK Sum of All Relief Requested: $167,438.85 Disposition: AWARD AGAINST PARTY Disposition Date: 08/28/1996 Sum of All Relief Awarded: $12,602.47 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 503 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/19/1994 Case Number: 94-00786 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $10,001.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/24/1995 Sum of All Relief Awarded: $4,250.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 830 www.finra.org/brokercheck User Guidance

i Disclosure 504 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/20/1994 Case Number: 94-01646 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $5,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/25/1995 Sum of All Relief Awarded: $5,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 505 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/15/1994 Case Number: 94-01664 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $28,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/27/1995 Sum of All Relief Awarded: $22,680.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 506 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/18/1994 Case Number: 94-01692 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $3,110.46 Disposition: AWARD AGAINST PARTY Disposition Date: 12/28/1995 Sum of All Relief Awarded: $1,670.44 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 507 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/12/1994 Case Number: 94-01693 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $3,634.59 Disposition: AWARD AGAINST PARTY Disposition Date: 12/28/1995 Sum of All Relief Awarded: $1,943.73

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 508 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/18/1994 Case Number: 94-01729 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $9,109.04 Disposition: AWARD AGAINST PARTY Disposition Date: 12/28/1995 Sum of All Relief Awarded: $4,872.12 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 509 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 07/08/1994 Case Number: 94-01778 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,050.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/31/1995 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 833 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $1,030.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 510 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/22/1994 Case Number: 94-01802 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $974.76 Disposition: AWARD AGAINST PARTY Disposition Date: 12/28/1995 Sum of All Relief Awarded: $521.38 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 511 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/01/1994 Case Number: 94-01955 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,768.99 Disposition: AWARD AGAINST PARTY

Disposition Date: 12/28/1995 Sum of All Relief Awarded: $946.21 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 512 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 09/14/1994 Case Number: 94-02347 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES; MUNICIPAL BOND FUNDS Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 07/21/1995 Sum of All Relief Awarded: $75,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 513 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/21/1994 Case Number: 94-03107 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

Sum of All Relief Requested: $27,048.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/30/1995 Sum of All Relief Awarded: $8,287.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 514 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/22/1994 Case Number: 94-04369 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,541.63 Disposition: AWARD AGAINST PARTY Disposition Date: 01/31/1996 Sum of All Relief Awarded: $725.67 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 515 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/29/1995 Case Number: 94-05559 ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 836 www.finra.org/brokercheck User Guidance

Case Number: 94-05559 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $41,088.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/14/1996 Sum of All Relief Awarded: $1,108.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 516 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 04/12/1995 Case Number: 95-01573 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/15/1996 Sum of All Relief Awarded: $53,704.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 517 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 837 www.finra.org/brokercheck User Guidance

Case Initiated: 07/17/1995 Case Number: 95-03042 Disputed Product Type: COMMON STOCK; MUNICIPAL BOND FUNDS; OPTIONS; WARRANTS/RIGHTS Sum of All Relief Requested: $116,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/14/1996 Sum of All Relief Awarded: $20,785.49 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 518 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 11/10/1995 Case Number: 95-05280 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/21/1997 Sum of All Relief Awarded: $25,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 519 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-TRANSFER; DO NOT USE-EXECUTIONS-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; TRADING DISPUTES- ©2021 FINRA. All rights reserved. Report aboutTRANSFERS LEHMAN BROTHERS INC. 838 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT RELATED-TRANSFER; DO NOT USE-EXECUTIONS-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; TRADING DISPUTES- TRANSFERS Arbitration Forum: NASD Case Initiated: 07/02/1996 Case Number: 96-02782 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $15,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/16/1997 Sum of All Relief Awarded: $7,551.20 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 520 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/24/1996 Case Number: 96-03069 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $53,133.10 Disposition: AWARD AGAINST PARTY Disposition Date: 05/14/1997 Sum of All Relief Awarded: $35,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 521 of 527 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/03/1996 Case Number: 96-04735 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $3,277,062.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/17/1998 Sum of All Relief Awarded: $1,100,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 522 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/20/1997 Case Number: 96-05596 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $267,672.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/17/1998 Sum of All Relief Awarded: $109,768.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 523 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 03/26/1997 Case Number: 97-00385 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $150,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/20/1999 Sum of All Relief Awarded: $45,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 524 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/21/1997 Case Number: 97-05002 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $5,554.47 Disposition: AWARD AGAINST PARTY Disposition Date: 04/20/1998 Sum of All Relief Awarded: $2,827.92

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 525 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 12/02/1997 Case Number: 97-05431 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 11/04/1998 Sum of All Relief Awarded: $109,225.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 526 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 07/27/1999 Case Number: 99-03294 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $51,000.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about LEHMAN BROTHERS INC. 842 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 07/05/2000 Sum of All Relief Awarded: $12,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 527 of 527 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/09/1999 Case Number: 99-04665 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/29/2001 Sum of All Relief Awarded: $90,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

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