Brokercheck Report RBC CAPITAL MARKETS, LLC CRD# 31194

BrokerCheck Report RBC CAPITAL MARKETS, LLC CRD# 31194

Section Title Page(s) Report Summary 1

Firm Profile 2 - 10

Firm History 11

Firm Operations 12 - 33

Disclosure Events 34

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BrokerCheck offers information on all current, and many former, registered securities brokers, and all current and former registered securities firms. FINRA strongly encourages investors to use BrokerCheck to check the background of securities brokers and brokerage firms before deciding to conduct, or continue to conduct, business with them. · What is included in a BrokerCheck report? · BrokerCheck reports for individual brokers include information such as employment history, professional qualifications, disciplinary actions, criminal convictions, civil judgments and arbitration awards. BrokerCheck reports for brokerage firms include information on a firm’s profile, history, and operations, as well as many of the Using this site/information means same disclosure events mentioned above. that you accept the FINRA · Please note that the information contained in a BrokerCheck report may include pending actions or BrokerCheck Terms and allegations that may be contested, unresolved or unproven. In the end, these actions or allegations may be Conditions. A complete list of resolved in favor of the broker or brokerage firm, or concluded through a negotiated settlement with no Terms and Conditions can be admission or finding of wrongdoing. found at · Where did this information come from? brokercheck.finra.org · The information contained in BrokerCheck comes from FINRA’s Central Registration Depository, or CRD® and is a combination of: o information FINRA and/or the Securities and Exchange Commission (SEC) require brokers and brokerage firms to submit as part of the registration and licensing process, and For additional information about o information that regulators report regarding disciplinary actions or allegations against firms or brokers. the contents of this report, please · How current is this information? refer to the User Guidance or · Generally, active brokerage firms and brokers are required to update their professional and disciplinary www.finra.org/brokercheck. It information in CRD within 30 days. Under most circumstances, information reported by brokerage firms, brokers provides a glossary of terms and a and regulators is available in BrokerCheck the next business day. list of frequently asked questions, · What if I want to check the background of an investment adviser firm or investment adviser as well as additional resources. representative? For more information about · To check the background of an investment adviser firm or representative, you can search for the firm or FINRA, visit www.finra.org. individual in BrokerCheck. If your search is successful, click on the link provided to view the available licensing and registration information in the SEC's Investment Adviser Public Disclosure (IAPD) website at https://www.adviserinfo.sec.gov. In the alternative, you may search the IAPD website directly or contact your state securities regulator at http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/P455414. · Are there other resources I can use to check the background of investment professionals? · FINRA recommends that you learn as much as possible about an investment professional before deciding to work with them. Your state securities regulator can help you research brokers and investment adviser representatives doing business in your state. · Thank you for using FINRA BrokerCheck. www.finra.org/brokercheck User Guidance RBC CAPITAL MARKETS, LLC Report Summary for this Firm CRD# 31194 SEC# 8-45411 This report summary provides an overview of the brokerage firm. Additional information for this firm can be found in the detailed report. Main Office Location Firm Profile Disclosure Events 3 WORLD FINANCIAL CENTER This firm is classified as a limited liability company. 200 VESEY ST. This firm was formed in Minnesota on 11/01/2010. Brokerage firms are required to disclose certain NEW YORK, NY 10281 criminal matters, regulatory actions, civil judicial Regulated by FINRA New York Office Its fiscal year ends in October. proceedings and financial matters in which the firm or Mailing Address Firm History one of its control affiliates has been involved. 60 S. 6TH STREET Information relating to the brokerage firm's history Are there events disclosed about this firm? Yes 14TH FLOOR such as other business names and successions MINNEAPOLIS, MN 55402-4400 (e.g., mergers, acquisitions) can be found in the Business Telephone Number detailed report. The following types of disclosures have been reported: 212-858-7000 Firm Operations Type Count This firm is registered with: Regulatory Event 336 This firm is a brokerage firm and an investment • the SEC Civil Event 2 adviser firm. For more information about • 22 Self-Regulatory Organizations Arbitration 114 investment adviser firms, visit the SEC's • 53 U.S. states and territories Investment Adviser Public Disclosure website at: Bond 7 Is this brokerage firm currently suspended with any https://www.adviserinfo.sec.gov regulator? No

This firm conducts 21 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 limited liability company. This firm was formed in Minnesota on 11/01/2010. Its fiscal year ends in October.

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.

RBC CAPITAL MARKETS, LLC Doing business as RBC CAPITAL MARKETS, LLC CRD# 31194 SEC# 8-45411

Main Office Location 3 WORLD FINANCIAL CENTER 200 VESEY ST. NEW YORK, NY 10281 Regulated by FINRA New York Office

Mailing Address 60 S. 6TH STREET 14TH FLOOR MINNEAPOLIS, MN 55402-4400

Business Telephone Number 212-858-7000

Other Names of this Firm

Name Where is it used RBC ADVISOR SERVICES 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, VI, VT, WA, ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC WI, 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, VI, VT, WA, WI, WV, WY RBC CORRESPONDENT SERVICES 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, VI, VT, WA, WI, WV, WY RBC WEALTH MANAGEMENT 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, VI, VT, WA, WI, WV, WY

©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 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): RBC USA HOLDCO CORPORATION Is this a domestic or foreign Domestic Entity entity or an individual?

Position DIRECT OWNER Position Start Date 11/2010 Percentage of Ownership 75% or more Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): ABRUSCI, MATTHEW DAMIEN 4820950 Is this a domestic or foreign Individual entity or an individual?

Position HEAD OF U.S. CAPITAL MARKETS LAW GROUP Position Start Date 01/2020 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): GIEGERICH, ROBERT ARTHUR 5736294 Is this a domestic or foreign Individual entity or an individual?

Position PRINCIPAL FINANCIAL OFFICER Position Start Date 04/2020 Percentage of Ownership Less than 5% ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 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 No company?

Legal Name & CRD# (if any): KACHENOURA, AHMED 4825331 Is this a domestic or foreign Individual entity or an individual?

Position HEAD, GLOBAL EQUITIES, RBC CAPITAL MARKETS Position Start Date 08/2016 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): MURPHY, THOMAS N 4519183 Is this a domestic or foreign Individual entity or an individual?

Position HEAD, US CM OPERATIONS Position Start Date 10/2016 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): SAGISSOR, THOMAS STEVEN

Direct Owners and Executive Officers (continued) 2429425 Is this a domestic or foreign Individual entity or an individual?

Position PRESIDENT OF RBC WEALTH MANAGEMENT Position Start Date 04/2016 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): SMALL, ANDREW CHRISTOPHER 3068715 Is this a domestic or foreign Individual entity or an individual?

Position SVP, CHIEF COMPLIANCE OFFICER, RBC WEALTH MANAGEMENT - U.S. Position Start Date 02/2019 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): STOPNIK, MATTHEW ROSS 2580834 Is this a domestic or foreign Individual entity or an individual?

Position CO-HEAD, US INVESTMENT BANKING Position Start Date 11/2018 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 RBC CAPITAL MARKETS, LLC 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?

Legal Name & CRD# (if any): TAYLOR, RYAN JOSEPH 4570484 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF COMPLIANCE OFFICER, RBC CAPITAL MARKETS - U.S. Position Start Date 02/2019 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): THONG, MONA 5680908 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF RISK OFFICER, USA Position Start Date 03/2021 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): THORNE, BRETT LANE 2523268

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

Position HEAD, CORRESPONDENT AND ADVISOR SERVICES Position Start Date 08/2016 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): THURLOW, JOHN J 5726613 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF OPERATING OFFICER & CHAIRMAN OF THE BOARD Position Start Date 05/2015 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): YU, JONATHAN TSUN YIN 7074967 Is this a domestic or foreign Individual entity or an individual?

Position NON-EMPLOYEE BOARD MEMBER Position Start Date 01/2019 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm? ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 8 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 RBC CAPITAL MARKETS, LLC 9 www.finra.org/brokercheck User Guidance Firm Profile This section provides information relating to any indirect owners of the brokerage firm. Indirect Owners

Legal Name & CRD# (if any): RBC US GROUP HOLDINGS LLC Is this a domestic or foreign Domestic Entity entity or an individual?

Company through which RBC USA HOLDCO CORPORATION indirect ownership is established Relationship to Direct Owner INDIRECT OWNER Relationship Established 06/2018 Percentage of Ownership 75% or more Does this owner direct the Yes management or policies of the firm? Is this a public reporting No company?

Legal Name & CRD# (if any): ROYAL BANK OF CANADA Is this a domestic or foreign Foreign Entity entity or an individual?

Company through which RBC US GROUP HOLDINGS LLC indirect ownership is established Relationship to Direct Owner ULTIMATE OWNER Relationship Established 11/2010 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?

©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 10 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 the SEC, 22 SROs and 53 U.S. states and territories. Federal Regulator Status Date Effective SEC Approved 12/30/1992

SEC Registration Questions This firm is registered with the SEC as: A broker-dealer: Yes A broker-dealer and government securities broker or dealer: Yes A government securities broker or dealer only: No This firm has ceased activity as a government securities broker or dealer: No

Self-Regulatory Organization Status Date Effective FINRA Approved 03/19/1993 BOX Exchange LLC Approved 05/07/2012 Cboe BYX Exchange, Inc. Approved 10/14/2010 Cboe BZX Exchange, Inc. Approved 09/18/2008 Cboe C2 Exchange, Inc. Approved 10/19/2010 Cboe EDGA Exchange, Inc. Approved 05/14/2010 Cboe EDGX Exchange, Inc. Approved 05/14/2010 Cboe Exchange, Inc. Approved 11/24/1993 Investors' Exchange LLC Approved 08/12/2016 Long-Term Stock Exchange, Inc. Approved 07/20/2020 MEMX LLC Approved 09/18/2020 MIAX PEARL, LLC Approved 09/28/2020 NYSE American LLC Approved 04/08/1993 NYSE Arca, Inc. Approved 12/11/2002 NYSE Chicago, Inc. Approved 03/16/1993 NYSE National, Inc. Approved 05/18/2018

©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 12 www.finra.org/brokercheck User Guidance Nasdaq BX, Inc. Approved 01/12/2009 Nasdaq GEMX, LLC Approved 02/14/2018 Nasdaq ISE, LLC Approved 02/29/2008 Nasdaq PHLX LLC Approved 02/29/2008 Nasdaq Stock Market Approved 07/12/2006 New York Stock Exchange Approved 04/08/1993

Registrations (continued) U.S. States & Status Date Effective U.S. States & Status Date Effective Territories Territories Alabama Approved 03/24/1993 North Carolina Approved 03/23/1993 Alaska Approved 11/12/1997 North Dakota Approved 12/05/1997 Arizona Approved 11/13/1997 Ohio Approved 03/03/1993 Arkansas Approved 12/04/1997 Oklahoma Approved 04/06/1993 California Approved 03/31/1993 Oregon Approved 11/07/1997 Colorado Approved 04/05/1993 Pennsylvania Approved 11/12/1997 Connecticut Approved 03/22/1993 Puerto Rico Approved 05/16/1997 Delaware Approved 10/31/1997 Rhode Island Approved 11/19/1997 District of Columbia Approved 03/10/1993 South Carolina Approved 04/06/1993 Florida Approved 04/07/1993 South Dakota Approved 10/29/1997 Georgia Approved 10/31/1997 Tennessee Approved 03/22/1993 Hawaii Approved 01/02/1998 Texas Approved 01/20/1998 Idaho Approved 11/07/1997 Utah Approved 03/01/1993 Illinois Approved 03/22/1993 Vermont Approved 04/01/1993 Indiana Approved 11/21/1997 Virgin Islands Approved 10/08/2008 Iowa Approved 11/10/1997 Virginia Approved 03/03/1993 Kansas Approved 01/02/1998 Washington Approved 03/19/1993 Kentucky Approved 11/03/1997 West Virginia Approved 10/30/1997 Louisiana Approved 03/31/1993 Wisconsin Approved 03/29/1993 Maine Approved 03/19/1993 Wyoming Approved 11/05/1997 Maryland Approved 11/07/1997 Massachusetts Approved 11/12/1997 Michigan Approved 02/12/1993 Minnesota Approved 03/22/1993 Mississippi Approved 12/18/1997 Missouri Approved 03/29/1993 Montana Approved 03/24/1993 Nebraska Approved 03/19/1993 Nevada Approved 11/03/1997 New Hampshire Approved 01/22/1998 New Jersey Approved 03/19/1993 New Mexico Approved 03/25/1993 New York Approved 03/08/1993

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 21 types of businesses. Types of Business

Exchange member engaged in exchange commission business other than 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 retailer U S. government securities dealer U S. government securities broker Municipal securities dealer Municipal securities broker Broker or dealer selling variable life insurance or annuities 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 Broker or dealer selling tax shelters or limited partnerships in the secondary market Trading securities for own account Private placements of securities Broker or dealer selling interests in mortgages or other receivables Broker or dealer involved in a networking, kiosk or similar arrangment with a: bank, savings bank or association, or credit union Other - THE APPLICANT INTENDS TO ENGAGE IN TRADE SETTLEMENT AND SECURITIES CLEARANCE, OPERATIONS AND CORRESPONDENT CLEARING ACTIVITIES. ADDITIONALLY, WE INTEND TO ACT AS AN AGENT FOR AN AFFILIATE WHO WILL ENGAGE IN PROPRIETARY TRADING, INDEX ARBITRAGE AND STATISTICAL ARBITRAGE THROUGH TRADING IN THE UNITED STATES OF EXCHANGE TRADED STOCK, STOCK OPTIONS AND STOCK INDEX FUTURES CONTRACTS.

Other Types of Business ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 15 www.finra.org/brokercheckOther Types of Business User Guidance This firm does effect transactions in commodities, commodity futures, or commodity options. This firm does engage in other non-securities business. Non-Securities Business Description: THE APPLICANT MAINTAINS CORPORATE INSURANCE LICENSES IN VARIOUS STATES AND IS INVOLVED IN THE SALE OF LIFE INSURANCE, HEALTH INSURANCE, AND OTHER INSURANCE PRODUCTS THROUGH ITS SECURITIES AGENTS WHO ARE SPONSORED BY VARIOUS INSURANCE COMPANIES. THE APPLICANT IS A FEDERALLY REGISTERED INVESTMENT ADVISER. THE APPLICANT HAS A CONTROLLING INTEREST IN A COMPANY, TCA TRUST CORP AMERICA, WHICH IS A WASHINGTON, DC CHARTERED TRUST COMPANY.

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 have books or records maintained by a third party. Name: DOCUPACE TECHNOLOGIES, LLC Business Address: 11766 WILSHIRE BLVD SUITE 1120 LOS ANGELES, CA 90025 Effective Date: 06/30/2020 Description: RBC HAS ENGAGED DOCUPACE FOR PROFESSIONAL SERVICES WHICH INCLUDE THE RETENTION OF CERTAIN RECORDS ON BEHALF OF RBC. Name: BROADRIDGE SECURITIES PROCESSING SOLUTIONS, LLC Business Address: 2 GATEWAY CENTER 283-299 MARKET STREET NEWARK, NJ 07102 Effective Date: 03/01/2008 Description: RBC HAS ENGAGED BROADRIDGE FOR BACK OFFICE SERVICES WHICH INCLUDE THE RETENTION OF CERTAIN RECORDS ON BEHALF OF RBC. Name: BLOOMBERG FINANCE L.P. Business Address: 731 LEXINGTON AVENUE NEW YORK, NY 10022 Effective Date: 01/08/2011 Description: RBC HAS ENGAGED BLOOMBERG FOR PROFESSIONAL SERVICES WHICH INCLUDE THE RETENTION OF CERTAIN RECORDS ON BEHALF OF RBC. 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. CONVERGENT WEALTH ADVISORS, LLC is under common control with the firm. CRD #: 143719 Business Address: 12505 PARK POTOMAC AVENUE SUITE 400 POTOMAC, MD 20854 Effective Date: 11/02/2015 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: CONVERGENT WEALTH ADVISORS, LLC AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC CAPITAL MARKETS (EUROPE) GMBH is under common control with the firm. Business Address: TAUNUSANLAGE 17 FRANKFURT AM MAIN, GERMANY 60325 Effective Date: 01/08/2018 Foreign Entity: Yes Country: GERMANY Securities Activities: Yes Investment Advisory No Activities: Description: RBC CAPITAL MARKETS (EUROPE) GMBH AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

Organization Affiliates (continued)

RBC INVESTEASE INC. is under common control with the firm. Business Address: 200 BAY STREET, 9TH FLOOR ROYAL BANK PLAZA, SOUTH TOWER TORONTO, CANADA M5J 2J5 Effective Date: 01/18/2017 Foreign Entity: Yes Country: CANADA Securities Activities: No Investment Advisory Yes Activities: Description: RBC INVESTEASE INC. AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

BLUEBAY ASSET MANAGEMENT AG is under common control with the firm. Business Address: LINTHENSCHERGASSE 15 ZURICH, SWITZERLAND 8001 Effective Date: 07/25/2014 Foreign Entity: Yes Country: SWITZERLAND Securities Activities: No Investment Advisory Yes Activities: Description: BLUEBAY ASSET MANAGEMENT AG AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC FINANCIAL ADVISORY (BEIJING) LIMITED is under common control with the firm. Business Address: SUITE 925A, WINLAND I.F.C., NO 7 FINANCIAL STREET XICHENG DISTRICT BEIJING, CHINA 100033 Effective Date: 10/22/2013 Foreign Entity: Yes Country: CHINA Securities Activities: No ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 20 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Securities Activities: No Investment Advisory Yes Activities: Description: RBC FINANCIAL ADVISORY (BEIJING) LIMITED AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

SYMPHONIC SECURITIES LLC is under common control with the firm. CRD #: 139512 Business Address: 570 LEXINGTON AVENUE NEW YORK, NY 10022 Effective Date: 11/02/2015 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: SYMPHONIC SECURITIES LLC AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

SYMPHONIC FINANCIAL ADVISORS LLC is under common control with the firm. CRD #: 135603 Business Address: 570 LEXINGTON AVENUE NEW YORK, NY 10022 Effective Date: 11/02/2015 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: SYMPHONIC FINANCIAL ADVISORS LLC AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

CNR SECURITIES, LLC is under common control with the firm.

Organization Affiliates (continued)

CRD #: 18466 Business Address: 570 LEXINGTON AVE 9TH FLOOR NEW YORK, NY 10022 Effective Date: 11/02/2015 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: CNR SECURITIES LLC AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

MID-CONTINENT CAPITAL LLC is under common control with the firm. CRD #: 107997 Business Address: 150 SOUTH WACKER DR. SUITE 400 CHICAGO, IL 60606 Effective Date: 11/02/2015 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: MIDCONTINENT CAPITAL LLC AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

LMCG INVESTMENTS, LLC is under common control with the firm. CRD #: 149936 Business Address: 200 S. CLARENDON ST. 28TH FLOOR BOSTON, MA 02116 Effective Date: 11/02/2015 Foreign Entity: No ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 22 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: LMCG INVESTMENTS, LLC AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

CITY NATIONAL SECURITIES, INC. is under common control with the firm. CRD #: 103705 Business Address: 555 S. FLOWER STREET 11TH FLOOR LOS ANGELES, CA 90071 Effective Date: 11/02/2015 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: CITY NATIONAL SECURITIES, INC. AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

CITY NATIONAL ROCHDALE is under common control with the firm. CRD #: 117198 Business Address: 570 LEXINGTON AVE NEW YORK, NY 10022 Effective Date: 11/02/2015 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: CITY NATIONAL ROCHDALE AND APPLICANT BOTH SHARE THE SAME ©2021 FINRA. All rights reserved. Report aboutULTIMATE RBC CAPITAL PARENT, MARKETS, ROYAL LLC BANK OF CANADA. 23 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Description: CITY NATIONAL ROCHDALE AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

BLUEBAY ASSET MANAGEMENT INTERNATIONAL LIMITED is under common control with the firm. Business Address: 77 GROSVENOR STREET LONDON, ENGLAND W1K 3JR Effective Date: 12/17/2010 Foreign Entity: Yes Country: ENGLAND Securities Activities: Yes Investment Advisory No Activities: Description: BLUEBAY ASSET MANAGEMENT INTERNATIONAL LIMITED AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

BLUEBAY ASSET MANAGEMENT USA LLC is under common control with the firm. CRD #: 164530 Business Address: 30 OLD KINGS HIGHWAY SOUTH SUITE 111 DARIEN, DE 06820 Effective Date: 12/17/2010 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: BLUEBAY ASSET MANAGEMENT USA LLC AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

BLUEBAY FUNDS MANAGEMENT COMPANY S.A. is under common control with the firm. Business Address: 24 RUE BEAUMONT L-1219, LUXEMBOURG L-1219 Effective Date: 12/17/2010 Foreign Entity: Yes

Organization Affiliates (continued)

Country: LUXEMBOURG Securities Activities: Yes Investment Advisory Yes Activities: Description: BLUEBAY FUNDS MANAGEMENT COMPANY S.A. AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC SECURITIES AUSTRALIA PTY LIMITED is under common control with the firm. Business Address: LEVEL 46 2 PARK STREET SYDNEY NSW, AUSTRALIA 2000 Effective Date: 05/07/2004 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: Yes Investment Advisory No Activities: Description: RBC SECURITIES AUSTRALIA PTY LIMITED AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

ROYAL BANK OF CANADA INVESTMENT MANAGEMENT (U.K.) LIMITED is under common control with the firm. Business Address: RIVERBANK HOUSE 2 SWAN LANE LONDON, ENGLAND EC4R 3BF Effective Date: 04/20/1990 Foreign Entity: Yes Country: ENGLAND Securities Activities: Yes Investment Advisory Yes Activities: Description: ROYAL BANK OF CANADA INVESTMENT MANAGEMENT (U.K.) LIMITED AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

Organization Affiliates (continued)

WEST INDIES STOCKBROKERS LIMITED is under common control with the firm. Business Address: ST. CLAIR PLACE 7-9 ST. CLAIR AVENUE PORT OF SPAIN, TRINIDAD AND TOBAGO N/A Effective Date: 09/10/2009 Foreign Entity: Yes Country: TRINIDAD AND TOBAGO Securities Activities: Yes Investment Advisory No Activities: Description: WEST INDIES STOCKBROKERS LIMITED AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC INVESTMENT SOLUTIONS (CI) LIMITED is under common control with the firm. Business Address: CANADA COURT UPLAND ROAD ST PETER PORT, GUERNSEY GY1 3BQ Effective Date: 08/21/1973 Foreign Entity: Yes Country: GUERNSEY Securities Activities: No Investment Advisory Yes Activities: Description: RBC INVESTMENT SOLUTIONS (CI) LIMITED AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC INVESTMENT SERVICES (ASIA) LIMITED is under common control with the firm. Business Address: 17/F CHEUNG KONG CENTER 2 QUEEN'S ROAD CENTRAL HONG KONG, CHINA Effective Date: 11/01/1996 Foreign Entity: Yes Country: HONG KONG Securities Activities: Yes ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 26 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Securities Activities: Yes Investment Advisory Yes Activities: Description: RBC INVESTMENT SERVICES (ASIA) LIMITED AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC INVESTMENT MANAGEMENT (CARIBBEAN) LIMITED is under common control with the firm. Business Address: ST. CLAIR PLACE 7-9 ST. CLAIR AVENUE PORT OF SPAIN, TRINIDAD AND TOBAGO Effective Date: 06/16/2008 Foreign Entity: Yes Country: TRINIDAD AND TOBAGO Securities Activities: Yes Investment Advisory Yes Activities: Description: RBC INVESTMENT MANAGEMENT (CARIBBEAN) LIMITED AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC GLOBAL ASSET MANAGEMENT INC. is under common control with the firm. Business Address: 200 BAY STREET ROYAL BANK PLAZA, 9TH FLOOR, SOUTH TOWER TORONTO, CANADA M5J 2J5 Effective Date: 11/01/2013 Foreign Entity: Yes Country: CANADA Securities Activities: No Investment Advisory Yes Activities: Description: RBC GLOBAL ASSET MANAGEMENT INC. AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC GLOBAL ASSET MANAGEMENT (UK) LIMITED is under common control with the firm. CRD #: 168551 Business Address: RIVERBANK HOUSE ©2021 FINRA. All rights reserved. Report about2 SWAN RBC CAPITALLANE MARKETS, LLC 27 LONDON, ENGLAND EC4R 3BF www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Business Address: RIVERBANK HOUSE 2 SWAN LANE LONDON, ENGLAND EC4R 3BF Effective Date: 10/09/1998 Foreign Entity: Yes Country: ENGLAND Securities Activities: No Investment Advisory Yes Activities: Description: RBC GLOBAL ASSET MANAGEMENT (UK) LIMITED AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA

RBC DOMINON SECURITIES GLOBAL LIMITED is under common control with the firm. Business Address: LYFORD CAY HOUSE, 3RD FLOOR WEST BAY ROAD LYFORD CAY, NEW PROVIDENCE, BAHAMAS N-3234 Effective Date: 11/01/2004 Foreign Entity: Yes Country: BARBADOS Securities Activities: Yes Investment Advisory Yes Activities: Description: RBC DOMINION SECURITIES GLOBAL LIMITED AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC CAPITAL MARKETS (JAPAN) LTD. is under common control with the firm. Business Address: TORANOMON TOWERS OFFICE 8F 4-2-28 MINATO-KU TOKYO, JAPAN 105-0001 Effective Date: 09/20/1999 Foreign Entity: Yes Country: JAPAN Securities Activities: Yes Investment Advisory No Activities:©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 28 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Investment Advisory No Activities: Description: RBC CAPITAL MARKETS (JAPAN) LTD. AND THE APPLICANT SHARE THE SAME ULTIMATE PARENT COMPANY ROYAL BANK OF CANADA

BLUEBAY ASSET MANAGEMENT LLP is under common control with the firm. CRD #: 122793 Business Address: 77 GROSVENOR STREET LONDON, ENGLAND W1K 3JR Effective Date: 12/17/2010 Foreign Entity: Yes Country: ENGLAND Securities Activities: No Investment Advisory Yes Activities: Description: BLUEBAY ASSET MANAGEMENT LLP AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC PHILLIPS, HAGER & NORTH INVESTMENT COUNSEL INC. is under common control with the firm. Business Address: ROYAL BANK PLAZA, SOUTH TOWER 200 BAY STREET TORONTO, ONTARIO, CANADA M5J 2J5 Effective Date: 05/01/2008 Foreign Entity: Yes Country: CANADA Securities Activities: No Investment Advisory Yes Activities: Description: RBC PHILLIPS, HAGER & NORTH INVESTMENT COUNSEL INC. AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC GLOBAL ASSET MANAGEMENT (ASIA) LIMITED is under common control with the firm. Business Address: 15/F, CHEUNG KONG CENTER 2 QUEEN'S ROAD CENTRAL HONG KONG, CHINA ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 29 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Effective Date: 11/01/2000 Foreign Entity: Yes Country: HONG KONG Securities Activities: No Investment Advisory Yes Activities: Description: RBC GLOBAL ASSET MANAGEMENT(ASIA) LIMITED (FORMERLY RBC INVESTMENT MANAGEMENT (ASIA) LIMITED) AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC CMA LLC is under common control with the firm. CRD #: 121263 Business Address: 3 WORLD FINANCIAL CENTER 200 VESEY STREET NEW YORK, NY 10281 Effective Date: 07/01/2002 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: RBC CMA LLC IS UNDER COMMON CONTROL WITH THE APPLICANT.

RBC PRIVATE COUNSEL (USA) INC. is under common control with the firm. CRD #: 109648 Business Address: 200 BAY STREET ROYAL BANK PLAZA, 9TH FLOOR TORONTO, ONTARIO, CANADA M5J 2J5 Effective Date: 01/10/2001 Foreign Entity: Yes Country: CANADA Securities Activities: No Investment Advisory Yes Activities:©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 30 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Investment Advisory Yes Activities: Description: RBC PRIVATE COUNSEL (USA) INC.,IS UNDER COMMON CONTROL WITH THE APPLICANT.

RBC GLOBAL ASSET MANAGEMENT (U.S.) INC. is under common control with the firm. CRD #: 107173 Business Address: 50 SOUTH SIXTH STREET SUITE 2350 MINNEAPOLIS, MN 55402 Effective Date: 03/22/2004 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: BOTH RBC GLOBAL ASSET MANAGEMENT (U.S.) INC. AND THE APPLICANT ARE UNDER DIRECT COMMON CONTROL OF RBC USA HOLDCO CORPORATION WHICH IS UNDER CONTROL OF THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC EUROPE LIMITED is under common control with the firm. Business Address: RIVERBANK HOUSE 2 SWAN LANE LONDON, ENGLAND EC4R 3BF Effective Date: 01/10/2001 Foreign Entity: Yes Country: ENGLAND Securities Activities: Yes Investment Advisory No Activities: Description: RBC EUROPE LIMITED AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC DIRECT INVESTING INC. is under common control with the firm. Business Address: ROYAL BANK PLAZA ©2021 FINRA. All rights reserved. Report about200 BAYRBC CAPITALSTREET MARKETS, LLC 31 TORONTO, ONTARIO, CANADA M5J 2J5 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Business Address: ROYAL BANK PLAZA 200 BAY STREET TORONTO, ONTARIO, CANADA M5J 2J5 Effective Date: 09/30/2006 Foreign Entity: Yes Country: CANADA Securities Activities: Yes Investment Advisory No Activities: Description: RBC DIRECT INVESTING INC. AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

RBC DOMINION SECURITES, INC. is under common control with the firm. Business Address: ROYAL BANK PLAZA 200 BAY STREET TORONTO, ONTARIO, CANADA M5J 2J5 Effective Date: 01/10/2001 Foreign Entity: Yes Country: CANADA Securities Activities: Yes Investment Advisory No Activities: Description: RBC DOMINION SECURITES, INC. AND APPLICANT BOTH SHARE THE SAME ULTIMATE PARENT, ROYAL BANK OF CANADA.

This firm is 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

RBC US GROUP HOLDINGS LLC is a Bank Holding Company and controls the firm. Business Address: 200 BAY STREET 9TH FLOOR, SOUTH TOWER ©2021 FINRA. All rights reserved. Report aboutTORONTO, RBC CAPITAL CANADA MARKETS, M5J LLC 2J5 32 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Business Address: 200 BAY STREET 9TH FLOOR, SOUTH TOWER TORONTO, CANADA M5J 2J5 Effective Date: 06/29/2018 Description: RBC US GROUP HOLDINGS LLC IS THE 100% OWNER OF RBC USA HOLDCO CORPORATION (DIRECT OWNER OF APPLICANT).

RBC USA HOLDCO CORPORATION is a Bank Holding Company and controls the firm. Business Address: 3 WORLD FINANCIAL CENTER 200 VESEY STREET NEW YORK, NY 10281 Effective Date: 11/01/2010 Description: RBC USA HOLDCO CORPORATION IS THE DIRECT OWNER OF THE APPLICANT.

ROYAL BANK OF CANADA is a Foreign Bank and controls the firm. Business Address: ROYAL BANK PLAZA 200 BAY STREET TORONTO, CANADA M5J 2J5 Effective Date: 10/31/2003 Description: ROYAL BANK OF CANADA (ULTIMATE OWNER OF APPLICANT) OWNS 100% OF RBC US GROUP HOLDINGS LLC WHICH OWNS 100% OF RBC USA HOLDCO CORPORATION (DIRECT OWNER OF APPLICANT), WHICH IN TURN OWNS 99% OF THE APPLICANT.

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 0 336 0 Civil Event 0 2 0 Arbitration N/A 114 N/A Bond N/A 7 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 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC VIOLATED THE ACT BY EMPLOYING AN ©2021 FINRA. All rights reserved. Report aboutUNREGISTERED RBC CAPITAL MARKETS, INVESTMENT LLC ADVISOR REPRESENTATIVE IN VIRGINIA 35 FROM DECEMBER 1, 2017 TO NOVEMBER 27, 2020. FURTHER, RBC CAPITAL MARKETS, LLC FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES BY ALLOWING AN UNREGISTERED INVESTMENT ADVISOR REPRESENTATIVE TO PERFORM ADVISORY FUNCTIONS WITHOUT BEING REGISTERED IN VIRGINIA. www.finra.org/brokercheck User Guidance

Allegations: RBC CAPITAL MARKETS, LLC VIOLATED THE ACT BY EMPLOYING AN UNREGISTERED INVESTMENT ADVISOR REPRESENTATIVE IN VIRGINIA FROM DECEMBER 1, 2017 TO NOVEMBER 27, 2020. FURTHER, RBC CAPITAL MARKETS, LLC FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES BY ALLOWING AN UNREGISTERED INVESTMENT ADVISOR REPRESENTATIVE TO PERFORM ADVISORY FUNCTIONS WITHOUT BEING REGISTERED IN VIRGINIA. Initiated By: VIRGINIA STATE CORPORATION COMMISSION Date Initiated: 06/04/2021 Docket/Case Number: SEC-2021-00027 URL for Regulatory Action: 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 $10,000 CIVIL PENALTY Sought:

Resolution: Settled Resolution Date: 09/08/2021 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 $10,000.00 Other Sanctions Ordered: WILL NOT VIOLATE THE ACT IN THE FUTURE. Sanction Details: $10,000 CIVIL PENALTY -- PAID BY CHECK ON 01/15/2021 i Disclosure 2 of 336 Reporting Source: Regulator Current Status: Final Allegations: 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), 15B(C) AND 21C ©2021 FINRA. All rights reserved. Report aboutOF THE RBC CAPITALSECURITIES MARKETS, EXCHANGE LLC ACT OF 1934 ("EXCHANGE ACT") AGAINST 36 RBC CAPITAL MARKETS, LLC ("RBC" OR "RESPONDENT") THE COMMISSION FINDS THAT THIS MATTER INVOLVES IMPROPER CONDUCT BY RBC IN CONNECTION WITH CERTAIN NEGOTIATED NEW ISSUE MUNICIPAL BOND OFFERINGS. BETWEEN JANUARY 2014 AND DECEMBER 2017 ("THE RELEVANT PERIOD"), RBC, WHEN ACTING AS SOLE UNDERWRITER OR SENIOR SYNDICATE MANAGER IN NEGOTIATED OFFERINGS, UNDERTOOK TO ALLOCATE BONDS ACCORDING TO AN INTERNAL "STANDARD METHODOLOGY," IN THE ABSENCE OF DIFFERENT INSTRUCTIONS FROM ISSUERS. THE FIRM'S STANDARD METHODOLOGY REQUIRED RBC TO FILL ALL ORDERS FOR CUSTOMERS AND ALL DEALER ORDERS FOR RBC, SYNDICATE MEMBERS AND OTHER BROKER-DEALERS BEFORE ALLOCATING BONDS TO UNREGISTERED BROKERS KNOWN AS "FLIPPERS." HOWEVER, RBC DID NOT ALWAYS FOLLOW THE STANDARD METHODOLOGY WHEN IT DID NOT HAVE PRIORITY INSTRUCTIONS FROM ISSUERS AND, IN FORTY-ONE INSTANCES WHEN ORDERS EXCEEDED THE BONDS AVAILABLE, IT FAILED TO PRIORITIZE INSTITUTIONAL CUSTOMER AND/OR DEALER ORDERS AHEAD OF FLIPPER ORDERS. FURTHER, IN THREE INSTANCES WHERE IT HAD ISSUER INSTRUCTIONS, RBC VIOLATED THOSE INSTRUCTIONS BY ALLOCATING BONDS TO FLIPPERS AHEAD OF ORDERS FOR RETAIL CUSTOMERS EVEN THOUGH IT KNEW THAT THE FLIPPERS' ORDERS DID NOT MEET THE ISSUER'S RETAIL ELIGIBILITY CRITERIA FOR THE OFFERING. MOREOVER, IN CERTAIN OFFERINGS IN WHICH IT WAS NOT A PARTICIPATING UNDERWRITER, RBC OBTAINED NEW ISSUE MUNICIPAL BONDS FOR THE FIRM'S OWN INVENTORY BY PLACING INDICATIONS OF INTEREST WITH FLIPPERS WHO THEN PLACED CUSTOMER ORDERS WITH UNDERWRITERS, INSTEAD OF RBC SUBMITTING DEALER ORDERS TO THE UNDERWRITERS. THROUGH THIS PRACTICE, RBC CAUSED THE FLIPPERS TO ACT AS UNREGISTERED BROKERS AND CIRCUMVENTED ISSUER ORDER PRIORITIES, IMPROPERLY RECEIVING HIGHER PRIORITY IN THOSE OFFERINGS. AS A RESULT OF THIS CONDUCT, RBC VIOLATED MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULES G-11(K) AND G-17. IN ADDITION, RBC VIOLATED MSRB RULE G-27, AND FAILED REASONABLY TO SUPERVISE, WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT WITH A VIEW TO PREVENTING AND DETECTING VIOLATIONS OF THE MSRB RULES G-11(K) AND G-17 BY CERTAIN REGISTERED REPRESENTATIVES. RBC ALSO VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT AND CAUSED VIOLATIONS OF SECTION 15(A)(1) OF THE EXCHANGE ACT. www.finra.org/brokercheck User Guidance 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), 15B(C) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST RBC CAPITAL MARKETS, LLC ("RBC" OR "RESPONDENT") THE COMMISSION FINDS THAT THIS MATTER INVOLVES IMPROPER CONDUCT BY RBC IN CONNECTION WITH CERTAIN NEGOTIATED NEW ISSUE MUNICIPAL BOND OFFERINGS. BETWEEN JANUARY 2014 AND DECEMBER 2017 ("THE RELEVANT PERIOD"), RBC, WHEN ACTING AS SOLE UNDERWRITER OR SENIOR SYNDICATE MANAGER IN NEGOTIATED OFFERINGS, UNDERTOOK TO ALLOCATE BONDS ACCORDING TO AN INTERNAL "STANDARD METHODOLOGY," IN THE ABSENCE OF DIFFERENT INSTRUCTIONS FROM ISSUERS. THE FIRM'S STANDARD METHODOLOGY REQUIRED RBC TO FILL ALL ORDERS FOR CUSTOMERS AND ALL DEALER ORDERS FOR RBC, SYNDICATE MEMBERS AND OTHER BROKER-DEALERS BEFORE ALLOCATING BONDS TO UNREGISTERED BROKERS KNOWN AS "FLIPPERS." HOWEVER, RBC DID NOT ALWAYS FOLLOW THE STANDARD METHODOLOGY WHEN IT DID NOT HAVE PRIORITY INSTRUCTIONS FROM ISSUERS AND, IN FORTY-ONE INSTANCES WHEN ORDERS EXCEEDED THE BONDS AVAILABLE, IT FAILED TO PRIORITIZE INSTITUTIONAL CUSTOMER AND/OR DEALER ORDERS AHEAD OF FLIPPER ORDERS. FURTHER, IN THREE INSTANCES WHERE IT HAD ISSUER INSTRUCTIONS, RBC VIOLATED THOSE INSTRUCTIONS BY ALLOCATING BONDS TO FLIPPERS AHEAD OF ORDERS FOR RETAIL CUSTOMERS EVEN THOUGH IT KNEW THAT THE FLIPPERS' ORDERS DID NOT MEET THE ISSUER'S RETAIL ELIGIBILITY CRITERIA FOR THE OFFERING. MOREOVER, IN CERTAIN OFFERINGS IN WHICH IT WAS NOT A PARTICIPATING UNDERWRITER, RBC OBTAINED NEW ISSUE MUNICIPAL BONDS FOR THE FIRM'S OWN INVENTORY BY PLACING INDICATIONS OF INTEREST WITH FLIPPERS WHO THEN PLACED CUSTOMER ORDERS WITH UNDERWRITERS, INSTEAD OF RBC SUBMITTING DEALER ORDERS TO THE UNDERWRITERS. THROUGH THIS PRACTICE, RBC CAUSED THE FLIPPERS TO ACT AS UNREGISTERED BROKERS AND CIRCUMVENTED ISSUER ORDER PRIORITIES, IMPROPERLY RECEIVING HIGHER PRIORITY IN THOSE OFFERINGS. AS A RESULT OF THIS CONDUCT, RBC VIOLATED MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULES G-11(K) AND G-17. IN ADDITION, RBC VIOLATED MSRB RULE G-27, AND FAILED REASONABLY TO SUPERVISE, WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT WITH A VIEW TO PREVENTING AND DETECTING VIOLATIONS OF THE MSRB RULES G-11(K) AND G-17 BY CERTAIN REGISTERED REPRESENTATIVES. RBC ALSO VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT AND CAUSED VIOLATIONS OF SECTION 15(A)(1) OF THE EXCHANGE ACT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/17/2021 Docket/Case Number: 3-20568

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

Resolution: Order Resolution Date: 09/17/2021 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: Censure Monetary/Fine $150,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: PREJUDGMENT INTEREST ON DISGORGEMENT Sanction Details: RBC IS CENSURED; ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 15(A)(1) AND 15B(C)(1) OF THE EXCHANGE ACT; AND SHALL PAY DISGORGEMENT OF $552,440, PREJUDGMENT INTEREST OF $160,886.97, AND A CIVIL MONEY PENALTY OF $150,000 TO THE COMMISSION. Regulator Statement RBC HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. RBC WILLFULLY VIOLATED MSRB RULES G-11(K), G-17, AND G-27. AS A RESULT OF THE NEGLIGENT CONDUCT AND ITS WILLFUL VIOLATIONS OF MSRB RULES G-11(K), G-17 AND G-27, RBC WILLFULLY VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT. RBC ALSO CAUSED VIOLATIONS OF SECTION 15(A)(1) OF THE EXCHANGE ACT. ACCORDINGLY, IT IS HEREBY ORDERED THAT THE RBC CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 15(A)(1) AND 15B(C)(1) OF THE EXCHANGE ACT; IS CENSURED; SHALL PAY DISGORGEMENT OF $552,440, PREJUDGMENT INTEREST OF $160,886.97 ON DISGORGEMENT, AND A CIVIL MONEY PENALTY OF $150,000 TO THE COMMISSION. i Disclosure 3 of 336

Reporting Source: Firm Current Status: Final Allegations: A PANEL OF THE NYMEX BUSINESS CONDUCT COMMITTEE ("BCC PANEL") FOUND THAT ON MULTIPLE OCCASIONS DURING MARCH 2020, RBC SUBMITTED BLOCK TRADES IN CRUDE OIL AND NATURAL GAS FUTURES TO THE EXCHANGE OUTSIDE THE REPORTING TIME REQUIREMENTS, SUBMITTED INACCURATE BLOCK TRADE EXECUTION TIMES TO THE EXCHANGE ON ONE OR MORE OCCASION, AND ALSO FAILED TO PROPERLY ADVISE AND TRAIN ITS BROKERS AS TO RELEVANT EXCHANGE RULES AND MARKET REGULATION ADVISORY NOTICES ("MRANS") IN A MANNER SUFFICIENT TO ENSURE COMPLIANCE WITH THE EXCHANGE'S BLOCK TRADE REPORTING RULES. Initiated By: NEW YORK MERCANTILE EXCHANGE Date Initiated: 07/26/2021 Docket/Case Number: NYMEX 20-1311-BC

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

Resolution: Settled Resolution Date: 07/26/2021 Sanctions Ordered: Monetary/Fine $45,000.00 Other Sanctions Ordered: Sanction Details: IN ACCORDANCE WITH THE SETTLEMENT OFFER, THE BCC PANEL ORDERED RBCCM TO PAY A FINE TO THE EXCHANGE IN THE AMOUNT OF $45,000. THE PROCEEDS FROM FINES AND DISGORGEMENT HAVE BEEN ASSIGNED TO THE CHICAGO MERCANTILE EXCHANGE TRUST. i Disclosure 4 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED ©2021 FINRA. All rights reserved. Report aboutTO THE RBC CAPITALSANCTIONS MARKETS, AND LLC TO THE ENTRY OF FINDINGS THAT IT VIOLATED 39 NYSE RULE 3110(A) AND (B) (SUPERVISION) BY FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT ERRORS IN MARKET ON CLOSE (MOC) ORDERS. THE FINDINGS STATED THAT ON APRIL 24, 2020, THE FIRM ENTERED A MOC BASKET ORDER ON BEHALF OF ITS U.S. BROKER-DEALER AFFILIATE THAT MISTAKENLY INCLUDED APPROXIMATELY 300,000 SHARES ACROSS 476 EXCHANGE TRADED FUND (ETF) COMPONENT SECURITIES. THE FIRM'S AFFILIATE BROKER-DEALER UTILIZES THE FIRM'S NYSE MEMBERSHIP AND CONNECTIVITY IN ORDER TO GAIN ACCESS TO THE NYSE EXCHANGE. IN CONNECTION WITH THEIR ETF MARKET MAKING RESPONSIBILITIES, TRADERS AT THE FIRM'S AFFILIATE MAY ROUTE MOC BASKET ORDERS TO HEDGE THEIR EXISTING EXPOSURE. ON THE REVIEW DATE, A TRADER MISTAKENLY INCLUDED AN ETF THAT THE FIRM DID NOT NEED TO HEDGE AGAINST WHEN MANUALLY ADDING COMPONENTS INTO AN EXCEL MACRO SCRIPT THAT IS USED TO IDENTIFY ALL UNDERLYING COMPONENT SECURITIES THAT NEEDED TO BE ENTERED FOR THAT DAY'S ORDER. AS A RESULT, THE FIRM ROUTED TO THE NYSE A BASKET CONTAINING INCORRECT ETF COMPONENT SECURITIES WHICH THE FIRM DID NOT INTEND TO EXECUTE DURING THE CLOSING AUCTION. THE DESK RESPONSIBLE FOR GENERATING THE MOC BASKET DID NOT RECOGNIZE THAT THE ETF COMPONENT SECURITIES WERE ERRONEOUSLY INCLUDED BEFORE ENTERING THE ORDER AND ROUTING IT TO MARKET. AFTER THE 3:50 PM CUT-OFF TIME SPECIFIED IN NYSE RULE 7.35B, BUT PRIOR TO THE CLOSING CROSS, THE DESK RECOGNIZED ITS ERROR AND CANCELLED THE BASKET. THE FIRM FAILED TO DETECT AND PREVENT THE ERROR IN THE UNDERLYING MOC BASKET. ALTHOUGH THE FIRM HAD THE ABILITY TO REVIEW THE COMPONENTS INPUT INTO THE FIRM'S EXCEL SCRIPT AND THE GENERATED MOC BASKET FOR ERRORS BEFORE RELEASING IT TO MARKET, THEY NONETHELESS WERE NOT ABLE TO CATCH THIS ERROR IN TIME, AND THERE WAS NO OTHER CHECK IN PLACE TO ALERT THE FIRM TO THE MANUAL ERROR. THE FIRM ALSO FAILED TO MAINTAIN UPDATED WRITTEN SUPERVISORY PROCEDURES (WSPS) THAT ACCURATELY REFLECTED THE APPROPRIATE CUT-OFF TIME OF 3:50 PM FOR THE CANCELLATION OF MOC ORDERS; INSTEAD, THE FIRM'S WSPS REFLECTED AN OUTDATED CUT-OFF TIME OF 3:45 PM. IN ADDITION, THE FIRM FAILED TO ENABLE APPROPRIATE RISK MANAGEMENT CONTROLS TO ENSURE AGAINST IMPROPER MOC ORDER CANCELLATIONS AFTER THE PRESCRIBED CUT-OFF TIME. DURING THE FIRM'S MIGRATION TO NYSE'S PILLAR PLATFORM, ITS SOFT WARNING AND HARD BLOCK FUNCTIONALITIES, WHICH WOULD ALERT THE FIRM TO POTENTIALLY IMPROPER MOC ORDER CANCELLATIONS, BECAME DISABLED FOR MORE THAN SIX MONTHS. FURTHER, THE FIRM FAILED TO DETECT ERRORS IN ITS SURVEILLANCE SYSTEM THAT PREVENTED THE FIRM FROM BEING ALERTED TO MOC ORDERS CANCELED AFTER THE APPLICABLE CUT-OFF TIME. DUE TO ERRORS IN AN OVERLAY FILE USED TO GENERATE ALERTS FOR THE FIRM'S SURVEILLANCE OF MOC ORDERS CANCELED AFTER THE APPLICABLE CUT-OFF TIME, WHICH WAS CAUSED BY AN INTERNAL SYSTEM UPDATE IN OCTOBER 2018, THE FIRM'S SURVEILLANCE SYSTEM WAS UNABLE TO GENERATE ALERTS FOR POTENTIALLY IMPROPER MOC CANCELLATIONS UNTIL THE ERROR WAS DISCOVERED AND CORRECTED IN JULY 2020, AND THE CANCELLATION OF THE MOC BASKET WAS NOT IDENTIFIED AS A POTENTIAL EXCEPTION FOR FURTHER REVIEW BY SUPERVISION DURING THE FIRM'S T+1 REVIEW PROCESS. www.finra.org/brokercheck User Guidance

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED NYSE RULE 3110(A) AND (B) (SUPERVISION) BY FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT ERRORS IN MARKET ON CLOSE (MOC) ORDERS. THE FINDINGS STATED THAT ON APRIL 24, 2020, THE FIRM ENTERED A MOC BASKET ORDER ON BEHALF OF ITS U.S. BROKER-DEALER AFFILIATE THAT MISTAKENLY INCLUDED APPROXIMATELY 300,000 SHARES ACROSS 476 EXCHANGE TRADED FUND (ETF) COMPONENT SECURITIES. THE FIRM'S AFFILIATE BROKER-DEALER UTILIZES THE FIRM'S NYSE MEMBERSHIP AND CONNECTIVITY IN ORDER TO GAIN ACCESS TO THE NYSE EXCHANGE. IN CONNECTION WITH THEIR ETF MARKET MAKING RESPONSIBILITIES, TRADERS AT THE FIRM'S AFFILIATE MAY ROUTE MOC BASKET ORDERS TO HEDGE THEIR EXISTING EXPOSURE. ON THE REVIEW DATE, A TRADER MISTAKENLY INCLUDED AN ETF THAT THE FIRM DID NOT NEED TO HEDGE AGAINST WHEN MANUALLY ADDING COMPONENTS INTO AN EXCEL MACRO SCRIPT THAT IS USED TO IDENTIFY ALL UNDERLYING COMPONENT SECURITIES THAT NEEDED TO BE ENTERED FOR THAT DAY'S ORDER. AS A RESULT, THE FIRM ROUTED TO THE NYSE A BASKET CONTAINING INCORRECT ETF COMPONENT SECURITIES WHICH THE FIRM DID NOT INTEND TO EXECUTE DURING THE CLOSING AUCTION. THE DESK RESPONSIBLE FOR GENERATING THE MOC BASKET DID NOT RECOGNIZE THAT THE ETF COMPONENT SECURITIES WERE ERRONEOUSLY INCLUDED BEFORE ENTERING THE ORDER AND ROUTING IT TO MARKET. AFTER THE 3:50 PM CUT-OFF TIME SPECIFIED IN NYSE RULE 7.35B, BUT PRIOR TO THE CLOSING CROSS, THE DESK RECOGNIZED ITS ERROR AND CANCELLED THE BASKET. THE FIRM FAILED TO DETECT AND PREVENT THE ERROR IN THE UNDERLYING MOC BASKET. ALTHOUGH THE FIRM HAD THE ABILITY TO REVIEW THE COMPONENTS INPUT INTO THE FIRM'S EXCEL SCRIPT AND THE GENERATED MOC BASKET FOR ERRORS BEFORE RELEASING IT TO MARKET, THEY NONETHELESS WERE NOT ABLE TO CATCH THIS ERROR IN TIME, AND THERE WAS NO OTHER CHECK IN PLACE TO ALERT THE FIRM TO THE MANUAL ERROR. THE FIRM ALSO FAILED TO MAINTAIN UPDATED WRITTEN SUPERVISORY PROCEDURES (WSPS) THAT ACCURATELY REFLECTED THE APPROPRIATE CUT-OFF TIME OF 3:50 PM FOR THE CANCELLATION OF MOC ORDERS; INSTEAD, THE FIRM'S WSPS REFLECTED AN OUTDATED CUT-OFF TIME OF 3:45 PM. IN ADDITION, THE FIRM FAILED TO ENABLE APPROPRIATE RISK MANAGEMENT CONTROLS TO ENSURE AGAINST IMPROPER MOC ORDER CANCELLATIONS AFTER THE PRESCRIBED CUT-OFF TIME. DURING THE FIRM'S MIGRATION TO NYSE'S PILLAR PLATFORM, ITS SOFT WARNING AND HARD BLOCK FUNCTIONALITIES, WHICH WOULD ALERT THE FIRM TO POTENTIALLY IMPROPER MOC ORDER CANCELLATIONS, BECAME DISABLED FOR MORE THAN SIX MONTHS. FURTHER, THE FIRM FAILED TO DETECT ERRORS IN ITS SURVEILLANCE SYSTEM THAT PREVENTED THE FIRM FROM BEING ALERTED TO MOC ORDERS CANCELED AFTER THE APPLICABLE CUT-OFF ©2021 FINRA. All rights reserved. Report aboutTIME. RBC DUE CAPITAL TO ERRORS MARKETS, INLLC AN OVERLAY FILE USED TO GENERATE ALERTS 40 FOR THE FIRM'S SURVEILLANCE OF MOC ORDERS CANCELED AFTER THE APPLICABLE CUT-OFF TIME, WHICH WAS CAUSED BY AN INTERNAL SYSTEM UPDATE IN OCTOBER 2018, THE FIRM'S SURVEILLANCE SYSTEM WAS UNABLE TO GENERATE ALERTS FOR POTENTIALLY IMPROPER MOC CANCELLATIONS UNTIL THE ERROR WAS DISCOVERED AND CORRECTED IN JULY 2020, AND THE CANCELLATION OF THE MOC BASKET WAS NOT IDENTIFIED AS A POTENTIAL EXCEPTION FOR FURTHER REVIEW BY SUPERVISION DURING THE FIRM'S T+1 REVIEW PROCESS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED NYSE RULE 3110(A) AND (B) (SUPERVISION) BY FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT ERRORS IN MARKET ON CLOSE (MOC) ORDERS. THE FINDINGS STATED THAT ON APRIL 24, 2020, THE FIRM ENTERED A MOC BASKET ORDER ON BEHALF OF ITS U.S. BROKER-DEALER AFFILIATE THAT MISTAKENLY INCLUDED APPROXIMATELY 300,000 SHARES ACROSS 476 EXCHANGE TRADED FUND (ETF) COMPONENT SECURITIES. THE FIRM'S AFFILIATE BROKER-DEALER UTILIZES THE FIRM'S NYSE MEMBERSHIP AND CONNECTIVITY IN ORDER TO GAIN ACCESS TO THE NYSE EXCHANGE. IN CONNECTION WITH THEIR ETF MARKET MAKING RESPONSIBILITIES, TRADERS AT THE FIRM'S AFFILIATE MAY ROUTE MOC BASKET ORDERS TO HEDGE THEIR EXISTING EXPOSURE. ON THE REVIEW DATE, A TRADER MISTAKENLY INCLUDED AN ETF THAT THE FIRM DID NOT NEED TO HEDGE AGAINST WHEN MANUALLY ADDING COMPONENTS INTO AN EXCEL MACRO SCRIPT THAT IS USED TO IDENTIFY ALL UNDERLYING COMPONENT SECURITIES THAT NEEDED TO BE ENTERED FOR THAT DAY'S ORDER. AS A RESULT, THE FIRM ROUTED TO THE NYSE A BASKET CONTAINING INCORRECT ETF COMPONENT SECURITIES WHICH THE FIRM DID NOT INTEND TO EXECUTE DURING THE CLOSING AUCTION. THE DESK RESPONSIBLE FOR GENERATING THE MOC BASKET DID NOT RECOGNIZE THAT THE ETF COMPONENT SECURITIES WERE ERRONEOUSLY INCLUDED BEFORE ENTERING THE ORDER AND ROUTING IT TO MARKET. AFTER THE 3:50 PM CUT-OFF TIME SPECIFIED IN NYSE RULE 7.35B, BUT PRIOR TO THE CLOSING CROSS, THE DESK RECOGNIZED ITS ERROR AND CANCELLED THE BASKET. THE FIRM FAILED TO DETECT AND PREVENT THE ERROR IN THE UNDERLYING MOC BASKET. ALTHOUGH THE FIRM HAD THE ABILITY TO REVIEW THE COMPONENTS INPUT INTO THE FIRM'S EXCEL SCRIPT AND THE GENERATED MOC BASKET FOR ERRORS BEFORE RELEASING IT TO MARKET, THEY NONETHELESS WERE NOT ABLE TO CATCH THIS ERROR IN TIME, AND THERE WAS NO OTHER CHECK IN PLACE TO ALERT THE FIRM TO THE MANUAL ERROR. THE FIRM ALSO FAILED TO MAINTAIN UPDATED WRITTEN SUPERVISORY PROCEDURES (WSPS) THAT ACCURATELY REFLECTED THE APPROPRIATE CUT-OFF TIME OF 3:50 PM FOR THE CANCELLATION OF MOC ORDERS; INSTEAD, THE FIRM'S WSPS REFLECTED AN OUTDATED CUT-OFF TIME OF 3:45 PM. IN ADDITION, THE FIRM FAILED TO ENABLE APPROPRIATE RISK MANAGEMENT CONTROLS TO ENSURE AGAINST IMPROPER MOC ORDER CANCELLATIONS AFTER THE PRESCRIBED CUT-OFF TIME. DURING THE FIRM'S MIGRATION TO NYSE'S PILLAR PLATFORM, ITS SOFT WARNING AND HARD BLOCK www.finra.org/brokercheck FUNCTIONALITIES, WHICH WOULD ALERT THE FIRM TO POTENTIALLY User Guidance IMPROPER MOC ORDER CANCELLATIONS, BECAME DISABLED FOR MORE THAN SIX MONTHS. FURTHER, THE FIRM FAILED TO DETECT ERRORS IN ITS SURVEILLANCE SYSTEM THAT PREVENTED THE FIRM FROM BEING ALERTED TO MOC ORDERS CANCELED AFTER THE APPLICABLE CUT-OFF TIME. DUE TO ERRORS IN AN OVERLAY FILE USED TO GENERATE ALERTS FOR THE FIRM'S SURVEILLANCE OF MOC ORDERS CANCELED AFTER THE APPLICABLE CUT-OFF TIME, WHICH WAS CAUSED BY AN INTERNAL SYSTEM UPDATE IN OCTOBER 2018, THE FIRM'S SURVEILLANCE SYSTEM WAS UNABLE TO GENERATE ALERTS FOR POTENTIALLY IMPROPER MOC CANCELLATIONS UNTIL THE ERROR WAS DISCOVERED AND CORRECTED IN JULY 2020, AND THE CANCELLATION OF THE MOC BASKET WAS NOT IDENTIFIED AS A POTENTIAL EXCEPTION FOR FURTHER REVIEW BY SUPERVISION DURING THE FIRM'S T+1 REVIEW PROCESS. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 06/23/2021 Docket/Case Number: 2020-04-00115

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/06/2021 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: Sanction Details: THE FIRM WAS CENSURED AND FINED $10,000. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED ©2021 FINRA. All rights reserved. Report aboutNYSE RBC RULE CAPITAL 3110(A) MARKETS, AND LLC (B) (SUPERVISION) BY FAILING TO ESTABLISH AND 41 MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT ERRORS IN MARKET ON CLOSE (MOC) ORDERS. THE FINDINGS STATED THAT ON APRIL 24, 2020, THE FIRM ENTERED A MOC BASKET ORDER ON BEHALF OF ITS U.S. BROKER-DEALER AFFILIATE THAT MISTAKENLY INCLUDED APPROXIMATELY 300,000 SHARES ACROSS 476 EXCHANGE TRADED FUND (ETF) COMPONENT SECURITIES. THE FIRM'S AFFILIATE BROKER-DEALER UTILIZES THE FIRM'S NYSE MEMBERSHIP AND CONNECTIVITY IN ORDER TO GAIN ACCESS TO THE NYSE EXCHANGE. IN CONNECTION WITH THEIR ETF MARKET MAKING RESPONSIBILITIES, TRADERS AT THE FIRM'S AFFILIATE MAY ROUTE MOC BASKET ORDERS TO HEDGE THEIR EXISTING EXPOSURE. ON THE REVIEW DATE, A TRADER MISTAKENLY INCLUDED AN ETF THAT THE FIRM DID NOT NEED TO HEDGE AGAINST WHEN MANUALLY ADDING COMPONENTS INTO AN EXCEL MACRO SCRIPT THAT IS USED TO IDENTIFY ALL UNDERLYING COMPONENT SECURITIES THAT NEEDED TO BE ENTERED FOR THAT DAY'S ORDER. AS A RESULT, THE FIRM ROUTED TO THE NYSE A BASKET CONTAINING INCORRECT ETF COMPONENT SECURITIES WHICH THE FIRM DID NOT INTEND TO EXECUTE DURING THE CLOSING AUCTION. THE DESK RESPONSIBLE FOR GENERATING THE MOC BASKET DID NOT RECOGNIZE THAT THE ETF COMPONENT SECURITIES WERE ERRONEOUSLY INCLUDED BEFORE ENTERING THE ORDER AND ROUTING IT TO MARKET. AFTER THE 3:50 PM CUT-OFF TIME SPECIFIED IN NYSE RULE 7.35B, BUT PRIOR TO THE CLOSING CROSS, THE DESK RECOGNIZED ITS ERROR AND CANCELLED THE BASKET. THE FIRM FAILED TO DETECT AND PREVENT THE ERROR IN THE UNDERLYING MOC BASKET. ALTHOUGH THE FIRM HAD THE ABILITY TO REVIEW THE COMPONENTS INPUT INTO THE FIRM'S EXCEL SCRIPT AND THE GENERATED MOC BASKET FOR ERRORS BEFORE RELEASING IT TO MARKET, THEY NONETHELESS WERE NOT ABLE TO CATCH THIS ERROR IN TIME, AND THERE WAS NO OTHER CHECK IN PLACE TO ALERT THE FIRM TO THE MANUAL ERROR. THE FIRM ALSO FAILED TO MAINTAIN UPDATED WRITTEN SUPERVISORY PROCEDURES (WSPS) THAT ACCURATELY REFLECTED THE APPROPRIATE CUT-OFF TIME OF 3:50 PM FOR THE CANCELLATION OF MOC ORDERS; INSTEAD, THE FIRM'S WSPS REFLECTED AN OUTDATED CUT-OFF TIME OF 3:45 PM. IN ADDITION, THE FIRM FAILED TO ENABLE APPROPRIATE RISK MANAGEMENT CONTROLS TO ENSURE AGAINST IMPROPER MOC ORDER CANCELLATIONS AFTER THE PRESCRIBED CUT-OFF TIME. DURING THE FIRM'S MIGRATION TO NYSE'S PILLAR PLATFORM, ITS SOFT WARNING AND HARD BLOCK FUNCTIONALITIES, WHICH WOULD ALERT THE FIRM TO POTENTIALLY IMPROPER MOC ORDER CANCELLATIONS, BECAME DISABLED FOR MORE THAN SIX MONTHS. FURTHER, THE FIRM FAILED TO DETECT ERRORS IN ITS SURVEILLANCE SYSTEM THAT PREVENTED THE FIRM FROM BEING ALERTED TO MOC ORDERS CANCELED AFTER THE APPLICABLE CUT-OFF TIME. DUE TO ERRORS IN AN OVERLAY FILE USED TO GENERATE ALERTS FOR THE FIRM'S SURVEILLANCE OF MOC ORDERS CANCELED AFTER THE APPLICABLE CUT-OFF TIME, WHICH WAS CAUSED BY AN INTERNAL SYSTEM UPDATE IN OCTOBER 2018, THE FIRM'S SURVEILLANCE SYSTEM WAS UNABLE TO GENERATE ALERTS FOR POTENTIALLY IMPROPER MOC CANCELLATIONS UNTIL THE ERROR WAS DISCOVERED AND CORRECTED IN JULY 2020, AND THE CANCELLATION OF THE MOC BASKET WAS NOT IDENTIFIED AS A POTENTIAL EXCEPTION FOR FURTHER REVIEW BY SUPERVISION DURING THE FIRM'S T+1 REVIEW PROCESS. www.finra.org/brokercheck User Guidance

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED NYSE RULE 3110(A) AND (B) (SUPERVISION) BY FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT ERRORS IN MARKET ON CLOSE (MOC) ORDERS. THE FINDINGS STATED THAT ON APRIL 24, 2020, THE FIRM ENTERED A MOC BASKET ORDER ON BEHALF OF ITS U.S. BROKER-DEALER AFFILIATE THAT MISTAKENLY INCLUDED APPROXIMATELY 300,000 SHARES ACROSS 476 EXCHANGE TRADED FUND (ETF) COMPONENT SECURITIES. THE FIRM'S AFFILIATE BROKER-DEALER UTILIZES THE FIRM'S NYSE MEMBERSHIP AND CONNECTIVITY IN ORDER TO GAIN ACCESS TO THE NYSE EXCHANGE. IN CONNECTION WITH THEIR ETF MARKET MAKING RESPONSIBILITIES, TRADERS AT THE FIRM'S AFFILIATE MAY ROUTE MOC BASKET ORDERS TO HEDGE THEIR EXISTING EXPOSURE. ON THE REVIEW DATE, A TRADER MISTAKENLY INCLUDED AN ETF THAT THE FIRM DID NOT NEED TO HEDGE AGAINST WHEN MANUALLY ADDING COMPONENTS INTO AN EXCEL MACRO SCRIPT THAT IS USED TO IDENTIFY ALL UNDERLYING COMPONENT SECURITIES THAT NEEDED TO BE ENTERED FOR THAT DAY'S ORDER. AS A RESULT, THE FIRM ROUTED TO THE NYSE A BASKET CONTAINING INCORRECT ETF COMPONENT SECURITIES WHICH THE FIRM DID NOT INTEND TO EXECUTE DURING THE CLOSING AUCTION. THE DESK RESPONSIBLE FOR GENERATING THE MOC BASKET DID NOT RECOGNIZE THAT THE ETF COMPONENT SECURITIES WERE ERRONEOUSLY INCLUDED BEFORE ENTERING THE ORDER AND ROUTING IT TO MARKET. AFTER THE 3:50 PM CUT-OFF TIME SPECIFIED IN NYSE RULE 7.35B, BUT PRIOR TO THE CLOSING CROSS, THE DESK RECOGNIZED ITS ERROR AND CANCELLED THE BASKET. THE FIRM FAILED TO DETECT AND PREVENT THE ERROR IN THE UNDERLYING MOC BASKET. ALTHOUGH THE FIRM HAD THE ABILITY TO REVIEW THE COMPONENTS INPUT INTO THE FIRM'S EXCEL SCRIPT AND THE GENERATED MOC BASKET FOR ERRORS BEFORE RELEASING IT TO MARKET, THEY NONETHELESS WERE NOT ABLE TO CATCH THIS ERROR IN TIME, AND THERE WAS NO OTHER CHECK IN PLACE TO ALERT THE FIRM TO THE MANUAL ERROR. THE FIRM ALSO FAILED TO MAINTAIN UPDATED WRITTEN SUPERVISORY PROCEDURES (WSPS) THAT ACCURATELY REFLECTED THE APPROPRIATE CUT-OFF TIME OF 3:50 PM FOR THE CANCELLATION OF MOC ORDERS; INSTEAD, THE FIRM'S WSPS REFLECTED AN OUTDATED CUT-OFF TIME OF 3:45 PM. IN ADDITION, THE FIRM FAILED TO ENABLE APPROPRIATE RISK MANAGEMENT CONTROLS TO ENSURE AGAINST IMPROPER MOC ORDER CANCELLATIONS AFTER THE PRESCRIBED CUT-OFF TIME. DURING THE FIRM'S MIGRATION TO NYSE'S PILLAR PLATFORM, ITS SOFT WARNING AND HARD BLOCK FUNCTIONALITIES, WHICH WOULD ALERT THE FIRM TO POTENTIALLY IMPROPER MOC ORDER CANCELLATIONS, BECAME DISABLED FOR MORE THAN SIX MONTHS. FURTHER, THE FIRM FAILED TO DETECT ERRORS IN ITS SURVEILLANCE SYSTEM THAT PREVENTED THE FIRM FROM BEING ALERTED TO MOC ORDERS CANCELED AFTER THE APPLICABLE CUT-OFF TIME. DUE TO ERRORS IN AN OVERLAY FILE USED TO GENERATE ALERTS ©2021 FINRA. All rights reserved. Report aboutFOR RBC THE CAPITAL FIRM'S MARKETS, SURVEILLANCE LLC OF MOC ORDERS CANCELED AFTER THE 42 APPLICABLE CUT-OFF TIME, WHICH WAS CAUSED BY AN INTERNAL SYSTEM UPDATE IN OCTOBER 2018, THE FIRM'S SURVEILLANCE SYSTEM WAS UNABLE TO GENERATE ALERTS FOR POTENTIALLY IMPROPER MOC CANCELLATIONS UNTIL THE ERROR WAS DISCOVERED AND CORRECTED IN JULY 2020, AND THE CANCELLATION OF THE MOC BASKET WAS NOT IDENTIFIED AS A POTENTIAL EXCEPTION FOR FURTHER REVIEW BY SUPERVISION DURING THE FIRM'S T+1 REVIEW PROCESS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED NYSE RULE 3110(A) AND (B) (SUPERVISION) BY FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT ERRORS IN MARKET ON CLOSE (MOC) ORDERS. THE FINDINGS STATED THAT ON APRIL 24, 2020, THE FIRM ENTERED A MOC BASKET ORDER ON BEHALF OF ITS U.S. BROKER-DEALER AFFILIATE THAT MISTAKENLY INCLUDED APPROXIMATELY 300,000 SHARES ACROSS 476 EXCHANGE TRADED FUND (ETF) COMPONENT SECURITIES. THE FIRM'S AFFILIATE BROKER-DEALER UTILIZES THE FIRM'S NYSE MEMBERSHIP AND CONNECTIVITY IN ORDER TO GAIN ACCESS TO THE NYSE EXCHANGE. IN CONNECTION WITH THEIR ETF MARKET MAKING RESPONSIBILITIES, TRADERS AT THE FIRM'S AFFILIATE MAY ROUTE MOC BASKET ORDERS TO HEDGE THEIR EXISTING EXPOSURE. ON THE REVIEW DATE, A TRADER MISTAKENLY INCLUDED AN ETF THAT THE FIRM DID NOT NEED TO HEDGE AGAINST WHEN MANUALLY ADDING COMPONENTS INTO AN EXCEL MACRO SCRIPT THAT IS USED TO IDENTIFY ALL UNDERLYING COMPONENT SECURITIES THAT NEEDED TO BE ENTERED FOR THAT DAY'S ORDER. AS A RESULT, THE FIRM ROUTED TO THE NYSE A BASKET CONTAINING INCORRECT ETF COMPONENT SECURITIES WHICH THE FIRM DID NOT INTEND TO EXECUTE DURING THE CLOSING AUCTION. THE DESK RESPONSIBLE FOR GENERATING THE MOC BASKET DID NOT RECOGNIZE THAT THE ETF COMPONENT SECURITIES WERE ERRONEOUSLY INCLUDED BEFORE ENTERING THE ORDER AND ROUTING IT TO MARKET. AFTER THE 3:50 PM CUT-OFF TIME SPECIFIED IN NYSE RULE 7.35B, BUT PRIOR TO THE CLOSING CROSS, THE DESK RECOGNIZED ITS ERROR AND CANCELLED THE BASKET. THE FIRM FAILED TO DETECT AND PREVENT THE ERROR IN THE UNDERLYING MOC BASKET. ALTHOUGH THE FIRM HAD THE ABILITY TO REVIEW THE COMPONENTS INPUT INTO THE FIRM'S EXCEL SCRIPT AND THE GENERATED MOC BASKET FOR ERRORS BEFORE RELEASING IT TO MARKET, THEY NONETHELESS WERE NOT ABLE TO CATCH THIS ERROR IN TIME, AND THERE WAS NO OTHER CHECK IN PLACE TO ALERT THE FIRM TO THE MANUAL ERROR. THE FIRM ALSO FAILED TO MAINTAIN UPDATED WRITTEN SUPERVISORY PROCEDURES (WSPS) THAT ACCURATELY REFLECTED THE APPROPRIATE CUT-OFF TIME OF 3:50 PM FOR THE CANCELLATION OF MOC ORDERS; INSTEAD, THE FIRM'S WSPS REFLECTED AN OUTDATED CUT-OFF TIME OF 3:45 PM. IN ADDITION, THE FIRM FAILED TO ENABLE APPROPRIATE RISK MANAGEMENT CONTROLS TO ENSURE AGAINST IMPROPER MOC ORDER CANCELLATIONS AFTER THE PRESCRIBED CUT-OFF TIME. DURING THE FIRM'S MIGRATION TO NYSE'S PILLAR PLATFORM, ITS SOFT WARNING AND HARD BLOCK FUNCTIONALITIES, WHICH WOULD ALERT THE FIRM TO POTENTIALLY www.finra.org/brokercheck IMPROPER MOC ORDER CANCELLATIONS, BECAME DISABLED FOR MORE User Guidance THAN SIX MONTHS. FURTHER, THE FIRM FAILED TO DETECT ERRORS IN ITS SURVEILLANCE SYSTEM THAT PREVENTED THE FIRM FROM BEING ALERTED TO MOC ORDERS CANCELED AFTER THE APPLICABLE CUT-OFF TIME. DUE TO ERRORS IN AN OVERLAY FILE USED TO GENERATE ALERTS FOR THE FIRM'S SURVEILLANCE OF MOC ORDERS CANCELED AFTER THE APPLICABLE CUT-OFF TIME, WHICH WAS CAUSED BY AN INTERNAL SYSTEM UPDATE IN OCTOBER 2018, THE FIRM'S SURVEILLANCE SYSTEM WAS UNABLE TO GENERATE ALERTS FOR POTENTIALLY IMPROPER MOC CANCELLATIONS UNTIL THE ERROR WAS DISCOVERED AND CORRECTED IN JULY 2020, AND THE CANCELLATION OF THE MOC BASKET WAS NOT IDENTIFIED AS A POTENTIAL EXCEPTION FOR FURTHER REVIEW BY SUPERVISION DURING THE FIRM'S T+1 REVIEW PROCESS. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 06/23/2021 Docket/Case Number: 2020-04-00115

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/06/2021 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $10,000. i Disclosure 5 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC VIOLATED RULE 15C3-5(B) AND (C)(1)(II) AND BZX RULES 3.2 AND 5.1 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS. Initiated By: CBOE BZX EXCHANGE, INC. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 43 www.finra.org/brokercheck User Guidance

Initiated By: CBOE BZX EXCHANGE, INC. Date Initiated: 02/22/2021 Docket/Case Number: STAR NO. 20170565048-02 / USRI-7375-05

Resolution: Consent Resolution Date: 03/30/2021 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: Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $45,000 i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC VIOLATED RULE 15C3-5(B) AND (C)(1)(II) AND BZX RULES 3.2 AND 5.1 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS. Initiated By: CBOE BZX EXCHANGE, INC. Date Initiated: 02/22/2021 Docket/Case Number: STAR NO. 20170565048-02, FILE NO. USRI-7375-05

Resolution: Consent Resolution Date: 03/30/2021

©2021Does FINRA.the order All rights constitute reserved. a Report aboutNo RBC CAPITAL MARKETS, LLC 45 final order based on 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 $45,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $45,000 i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC VIOLATED RULE 15C3-5(B) AND (C)(1)(II) AND EDGA RULES 3.2 AND 5.1 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS. Initiated By: CBOE EDGA EXCHANGE, INC. Date Initiated: 02/22/2021 Docket/Case Number: STAR NO. 20170565048-01, FILE NO. USRI-7375-08.

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: 03/30/2021 Sanctions Ordered: Censure Monetary/Fine $45,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $45,000. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 46 www.finra.org/brokercheck User Guidance

Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $45,000. i Disclosure 7 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC VIOLATED RULE 15C3-5(B) AND (C)(1)(II) AND BYX RULES 3.2 AND 5.1 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS. Initiated By: CBOE BYX EXCHANGE, INC. Date Initiated: 02/22/2021 Docket/Case Number: STAR NO. 20170565048-03 / USRI-7375-06

Current Status: Final Allegations: BC CAPITAL MARKETS, LLC VIOLATED RULE 15C3-5(B) AND (C)(1)(II) AND BYX RULES 3.2 AND 5.1 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS. Initiated By: CBOE BYX EXCHANGE, INC. Date Initiated: 02/22/2021 Docket/Case Number: STAR NO. 20170565048-03, FILE NO. USRI-7375-06

Resolution: Consent Resolution Date: 03/30/2021 Sanctions Ordered: Censure Monetary/Fine $70,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $70,000. i Disclosure 8 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC VIOLATED RULE 15C3-5(B) AND (C)(1)(II) AND EDGX RULES 3.2 AND 5.1 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS. Initiated By: CBOE EDGX EXCHANGE, INC. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 48 www.finra.org/brokercheck User Guidance

Initiated By: CBOE EDGX EXCHANGE, INC. Date Initiated: 02/22/2021 Docket/Case Number: STAR NO. 20170565048-04 / USRI-7375-07

Resolution: Consent Resolution Date: 03/30/2021 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: Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $45,000 i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC VIOLATED RULE 15C3-5(B) AND (C)(1)(II) AND EDGX RULES 3.2 AND 5.1 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS. Initiated By: CBOE EDGX EXCHANGE, INC. Date Initiated: 02/22/2021 Docket/Case Number: STAR NO. 20170565048-04, FILE NO. USRI-7375-07

Resolution: Consent Resolution Date: 03/30/2021 Sanctions Ordered: Censure Monetary/Fine $45,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $45,000. i Disclosure 9 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITS MARKET ACCESS RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO MANAGE THE FINANCIAL AND REGULATORY RISKS OF THE FIRM'S MARKET ACCESS BUSINESS ON THE EXCHANGE. THE FINDINGS STATED THAT THE FIRM FAILED TO IMPLEMENT MARKET ACCESS CONTROLS TO ITS CONVERTIBLES DESK'S ORDER FLOW ROUTED TO THE MARKET. THEREFORE, THE FIRM'S FINANCIAL AND REGULATORY RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES FOR THE CONVERTIBLES DESK WERE NOT REASONABLY DESIGNED TO ADDRESS THE RISKS PRESENTED BY THE DESK'S MARKET ACCESS BUSINESS ACTIVITY, IN VIOLATION OF SECURITIES EXCHANGE ACT RULE 15C3-5(B), (C)(1), AND (C)(2). THE FINDINGS ALSO STATED THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES FOR ITS CASH, ELECTRONIC SALES AND TRADING, AND EXCHANGE-TRADED FUND LEAD MARKET MAKING DESKS WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS, IN VIOLATION OF RULE 15C3-5(B) AND (C)(1)(II). THE FINDINGS ALSO INCLUDED THAT THE FIRM'S MARKET ACCESS RULE SUPERVISORY SYSTEM AND WSPS WERE ©2021 FINRA. All rights reserved. Report aboutUNREASONABLE. RBC CAPITAL MARKETS, AS A RESULT LLC OF THE DEFICIENCIES DESCRIBED ABOVE, 50 THE FIRM VIOLATED NASDAQ RULES 3010 AND 2010A. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITS MARKET ACCESS RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO MANAGE THE FINANCIAL AND REGULATORY RISKS OF THE FIRM'S MARKET ACCESS BUSINESS ON THE EXCHANGE. THE FINDINGS STATED THAT THE FIRM FAILED TO IMPLEMENT MARKET ACCESS CONTROLS TO ITS CONVERTIBLES DESK'S ORDER FLOW ROUTED TO THE MARKET. THEREFORE, THE FIRM'S FINANCIAL AND REGULATORY RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES FOR THE CONVERTIBLES DESK WERE NOT REASONABLY DESIGNED TO ADDRESS THE RISKS PRESENTED BY THE DESK'S MARKET ACCESS BUSINESS ACTIVITY, IN VIOLATION OF SECURITIES EXCHANGE ACT RULE 15C3-5(B), (C)(1), AND (C)(2). THE FINDINGS ALSO STATED THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES FOR ITS CASH, ELECTRONIC SALES AND TRADING, AND EXCHANGE-TRADED FUND LEAD MARKET MAKING DESKS WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS www.finra.org/brokercheck ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR User Guidance SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS, IN VIOLATION OF RULE 15C3-5(B) AND (C)(1)(II). THE FINDINGS ALSO INCLUDED THAT THE FIRM'S MARKET ACCESS RULE SUPERVISORY SYSTEM AND WSPS WERE UNREASONABLE. AS A RESULT OF THE DEFICIENCIES DESCRIBED ABOVE, THE FIRM VIOLATED NASDAQ RULES 3010 AND 2010A. Initiated By: NASDAQ STOCK MARKET Date Initiated: 03/05/2021 Docket/Case Number: 2015045017001

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: 03/05/2021 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 $145,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED A TOTAL OF $350,000, OF WHICH $145,000 IS PAYABLE TO NASDAQ WITH THE REMAINDER PAYABLE TO OTHER EXCHANGES, AND SHALL UNDERTAKE TO REVISE THE ITS SYSTEM OF RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITS MARKET ACCESS RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO MANAGE THE FINANCIAL AND REGULATORY RISKS OF THE FIRM'S MARKET ACCESS BUSINESS ON THE EXCHANGE. THE FINDINGS STATED THAT THE FIRM FAILED TO IMPLEMENT MARKET ACCESS CONTROLS TO ITS ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 51 CONVERTIBLES DESK'S ORDER FLOW ROUTED TO THE MARKET. THEREFORE, THE FIRM'S FINANCIAL AND REGULATORY RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES FOR THE CONVERTIBLES DESK WERE NOT REASONABLY DESIGNED TO ADDRESS THE RISKS PRESENTED BY THE DESK'S MARKET ACCESS BUSINESS ACTIVITY, IN VIOLATION OF SECURITIES EXCHANGE ACT RULE 15C3-5(B), (C)(1), AND (C)(2). THE FINDINGS ALSO STATED THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES FOR ITS CASH, ELECTRONIC SALES AND TRADING, AND EXCHANGE-TRADED FUND LEAD MARKET MAKING DESKS WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS, IN VIOLATION OF RULE 15C3-5(B) AND (C)(1)(II). THE FINDINGS ALSO INCLUDED THAT THE FIRM'S MARKET ACCESS RULE SUPERVISORY SYSTEM AND WSPS WERE UNREASONABLE. AS A RESULT OF THE DEFICIENCIES DESCRIBED ABOVE, THE FIRM VIOLATED NASDAQ RULES 3010 AND 2010A. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITS MARKET www.finra.org/brokercheck ACCESS RISK MANAGEMENT CONTROLS AND SUPERVISORY User Guidance PROCEDURES WERE NOT REASONABLY DESIGNED TO MANAGE THE FINANCIAL AND REGULATORY RISKS OF THE FIRM'S MARKET ACCESS BUSINESS ON THE EXCHANGE. THE FINDINGS STATED THAT THE FIRM FAILED TO IMPLEMENT MARKET ACCESS CONTROLS TO ITS CONVERTIBLES DESK'S ORDER FLOW ROUTED TO THE MARKET. THEREFORE, THE FIRM'S FINANCIAL AND REGULATORY RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES FOR THE CONVERTIBLES DESK WERE NOT REASONABLY DESIGNED TO ADDRESS THE RISKS PRESENTED BY THE DESK'S MARKET ACCESS BUSINESS ACTIVITY, IN VIOLATION OF SECURITIES EXCHANGE ACT RULE 15C3-5(B), (C)(1), AND (C)(2). THE FINDINGS ALSO STATED THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES FOR ITS CASH, ELECTRONIC SALES AND TRADING, AND EXCHANGE-TRADED FUND LEAD MARKET MAKING DESKS WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS, IN VIOLATION OF RULE 15C3-5(B) AND (C)(1)(II). THE FINDINGS ALSO INCLUDED THAT THE FIRM'S MARKET ACCESS RULE SUPERVISORY SYSTEM AND WSPS WERE UNREASONABLE. AS A RESULT OF THE DEFICIENCIES DESCRIBED ABOVE, THE FIRM VIOLATED NASDAQ RULES 3010 AND 2010A. Initiated By: NASDAQ STOCK MARKET Date Initiated: 03/05/2021 Docket/Case Number: 2015045017001

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/05/2021 Sanctions Ordered: Censure Monetary/Fine $145,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED A TOTAL OF $350,000, OF WHICH $145,000 IS PAYABLE TO NASDAQ WITH THE REMAINDER PAYABLE TO OTHER EXCHANGES, AND SHALL UNDERTAKE TO REVISE THE ITS SYSTEM OF RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES. i

Disclosure 10 of 336 Reporting Source: Firm Current Status: Final Allegations: THE CLEARING HOUSE RISK COMMITTEE OF THE CHICAGO MERCANTILE EXCHANGE ALLEGED THAT THE FIRM VIOLATED CME RULE 971.A.1. Initiated By: CHICAGO MERCANTILE EXCHANGE, INC. Date Initiated: 06/12/2020 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: Decision & Order of Offer of Settlement Resolution Date: 08/21/2020 Sanctions Ordered: 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, AND THEREFORE WAS FINED $50,0000. i Disclosure 11 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO SUPERVISE REPRESENTATIVES' RECOMMENDATIONS TO CUSTOMERS TO PURCHASE PARTICULAR SHARE CLASSES OF 529 COLLEGE SAVINGS PLANS. THE FINDINGS STATED THAT THE FIRM DID NOT PROVIDE ADEQUATE GUIDANCE TO REPRESENTATIVES REGARDING THE IMPORTANCE OF CONSIDERING SHARE-CLASS DIFFERENCES WHEN RECOMMENDING 529 PLANS. THE FIRM HAD NO PROCEDURES REQUIRING SUPERVISORS TO REVIEW 529 PLAN SHARE-CLASS RECOMMENDATIONS ©2021 FINRA. All rights reserved. Report aboutFOR RBC SUITABILITY. CAPITAL MARKETS, THE FIRM LLC UPDATED ITS PROCEDURES TO INCLUDE 53 SUCH A REQUIREMENT, BUT THE UPDATED PROCEDURES FAILED TO ADEQUATELY INSTRUCT SUPERVISORS TO CONSIDER EITHER THE AGE OF THE BENEFICIARY OR THE NUMBER OF YEARS UNTIL EXPECTED WITHDRAWALS, BOTH CRITICAL FACTORS IN DETERMINING THE SUITABILITY OF THE RECOMMENDED SHARE CLASS. ALSO, THE FIRM DID NOT CONSISTENTLY PROVIDE SUPERVISORS WITH THE INFORMATION NECESSARY TO REVIEW THE SUITABILITY OF 529 PLAN SHARE-CLASS RECOMMENDATIONS. LATER, THE FIRM ISSUED A COMPANY-WIDE COMPLIANCE ALERT THAT PROVIDED GUIDANCE TO REPRESENTATIVES REGARDING 529 PLAN SHARE-CLASS RECOMMENDATIONS. THE FIRM THEN UPDATED ITS SUPERVISORY SYSTEMS AND PROCEDURES WITH RESPECT TO 529 SHARE-CLASS RECOMMENDATIONS. AMONG OTHER THINGS, THE FIRM INSTRUCTED SUPERVISORS TO CONSIDER THE AGE OF THE BENEFICIARY WHEN ASSESSING THE SUITABILITY OF A REPRESENTATIVE'S 529 SHARE-CLASS RECOMMENDATION. THE FIRM HAS AGREED TO PAY RESTITUTION AND INTEREST RELATING TO THE SALE OF CLASS C SHARES TO CERTAIN 529 PLAN CUSTOMERS IN THE ESTIMATED AMOUNT OF $839,803. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO SUPERVISE REPRESENTATIVES' RECOMMENDATIONS TO CUSTOMERS TO PURCHASE PARTICULAR SHARE CLASSES OF 529 www.finra.org/brokercheck COLLEGE SAVINGS PLANS. THE FINDINGS STATED THAT THE FIRM DID User Guidance NOT PROVIDE ADEQUATE GUIDANCE TO REPRESENTATIVES REGARDING THE IMPORTANCE OF CONSIDERING SHARE-CLASS DIFFERENCES WHEN RECOMMENDING 529 PLANS. THE FIRM HAD NO PROCEDURES REQUIRING SUPERVISORS TO REVIEW 529 PLAN SHARE-CLASS RECOMMENDATIONS FOR SUITABILITY. THE FIRM UPDATED ITS PROCEDURES TO INCLUDE SUCH A REQUIREMENT, BUT THE UPDATED PROCEDURES FAILED TO ADEQUATELY INSTRUCT SUPERVISORS TO CONSIDER EITHER THE AGE OF THE BENEFICIARY OR THE NUMBER OF YEARS UNTIL EXPECTED WITHDRAWALS, BOTH CRITICAL FACTORS IN DETERMINING THE SUITABILITY OF THE RECOMMENDED SHARE CLASS. ALSO, THE FIRM DID NOT CONSISTENTLY PROVIDE SUPERVISORS WITH THE INFORMATION NECESSARY TO REVIEW THE SUITABILITY OF 529 PLAN SHARE-CLASS RECOMMENDATIONS. LATER, THE FIRM ISSUED A COMPANY-WIDE COMPLIANCE ALERT THAT PROVIDED GUIDANCE TO REPRESENTATIVES REGARDING 529 PLAN SHARE-CLASS RECOMMENDATIONS. THE FIRM THEN UPDATED ITS SUPERVISORY SYSTEMS AND PROCEDURES WITH RESPECT TO 529 SHARE-CLASS RECOMMENDATIONS. AMONG OTHER THINGS, THE FIRM INSTRUCTED SUPERVISORS TO CONSIDER THE AGE OF THE BENEFICIARY WHEN ASSESSING THE SUITABILITY OF A REPRESENTATIVE'S 529 SHARE-CLASS RECOMMENDATION. THE FIRM HAS AGREED TO PAY RESTITUTION AND INTEREST RELATING TO THE SALE OF CLASS C SHARES TO CERTAIN 529 PLAN CUSTOMERS IN THE ESTIMATED AMOUNT OF $839,803. Initiated By: FINRA Date Initiated: 12/15/2020 Docket/Case Number: 2016047696701

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: 12/15/2020 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 Disgorgement/Restitution Other Sanctions Ordered: PLUS INTEREST ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 54 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: PLUS INTEREST Sanction Details: THE FIRM WAS CENSURED AND ORDERED TO PAY $685,520, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS THAT INCURRED EXCESS FEES DUE TO THEIR INVESTMENTS IN CLASS C SHARES. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO SUPERVISE REPRESENTATIVES' RECOMMENDATIONS TO CUSTOMERS TO PURCHASE PARTICULAR SHARE CLASSES OF 529 COLLEGE SAVINGS PLANS. THE FINDINGS STATED THAT THE FIRM DID NOT PROVIDE ADEQUATE GUIDANCE TO REPRESENTATIVES REGARDING THE IMPORTANCE OF CONSIDERING SHARE-CLASS DIFFERENCES WHEN RECOMMENDING 529 PLANS. THE FIRM HAD NO PROCEDURES REQUIRING SUPERVISORS TO REVIEW 529 PLAN SHARE-CLASS RECOMMENDATIONS FOR SUITABILITY. THE FIRM UPDATED ITS PROCEDURES TO INCLUDE SUCH A REQUIREMENT, BUT THE UPDATED PROCEDURES FAILED TO ADEQUATELY INSTRUCT SUPERVISORS TO CONSIDER EITHER THE AGE OF THE BENEFICIARY OR THE NUMBER OF YEARS UNTIL EXPECTED WITHDRAWALS, BOTH CRITICAL FACTORS IN DETERMINING THE SUITABILITY OF THE RECOMMENDED SHARE CLASS. ALSO, THE FIRM DID NOT CONSISTENTLY PROVIDE SUPERVISORS WITH THE INFORMATION NECESSARY TO REVIEW THE SUITABILITY OF 529 PLAN SHARE-CLASS RECOMMENDATIONS. LATER, THE FIRM ISSUED A COMPANY-WIDE COMPLIANCE ALERT THAT PROVIDED GUIDANCE TO REPRESENTATIVES REGARDING 529 PLAN SHARE-CLASS RECOMMENDATIONS. THE FIRM THEN UPDATED ITS SUPERVISORY SYSTEMS AND PROCEDURES WITH RESPECT TO 529 SHARE-CLASS RECOMMENDATIONS. AMONG OTHER THINGS, THE FIRM INSTRUCTED SUPERVISORS TO CONSIDER THE AGE OF THE BENEFICIARY WHEN ASSESSING THE SUITABILITY OF A REPRESENTATIVE'S 529 SHARE-CLASS RECOMMENDATION. THE FIRM HAS AGREED TO PAY RESTITUTION AND INTEREST RELATING TO THE SALE OF CLASS C SHARES TO CERTAIN 529 PLAN CUSTOMERS IN THE ESTIMATED AMOUNT OF $839,803. Initiated By: FINRA Date Initiated: 12/15/2020 Docket/Case Number: 2016047696701

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/15/2020 Sanctions Ordered: Censure Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND ORDERED TO PAY $685,520, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS THAT INCURRED EXCESS FEES DUE TO THEIR INVESTMENTS IN CLASS C SHARES. i Disclosure 12 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC FAILED TO SUPERVISE AT LEAST TWO OF ITS REPRESENTATIVES IN CONNECTION WITH THE OVERCONCENTRATION OF MASSACHUSETTS CUSTOMER ACCOUNTS." Initiated By: MASSACHUSETTS SECURITIES DIVISION Date Initiated: 05/19/2020 Docket/Case Number: E-2019-0117 URL for Regulatory Action: HTTPS://WWW.SEC.STATE.MA.US/SCT/CURRENT/SCTRBC/2020-5-19-MSD- RBC-COMPLAINT-E-2019-0117.PDF Principal Product Type: Other Other Product Type(s): MASTER LIMITED PARTNERSHIPS - ENERGY SECTOR US EQUITIES Principal Sanction(s)/Relief Restitution Sought: Other Sanction(s)/Relief CEASE AND DESIST, CENSURE, REVIEW OF SUPERVISORY PROCEDURES, Sought: ENGAGEMENT OF INDEPENDENT COMPLIANCE CONSULTANT, DISGORGEMENT, ADMINISTRATIVE FINE

Resolution: Consent

Resolution Date: 02/02/2021 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 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: $200,000 ADMINISTRATIVE FINE, REIMBURSEMENT FOR NET REALIZED LOSSES TOTALING $86,283.84, AND DISGORGEMENT TOTALING $33,983.57 FOR COMMISSIONS PAID ON PURCHASES ON MLPS. i Reporting Source: Firm Current Status: Final Allegations: THE DIVISION ALLEGES THAT RBC FAILED TO ADEQUATELY SUPERVISE ITS REPRESENTATIVES WITH RESPECT TO CONCENTRATION AND SUITABILITY OF MLP AND TELECOM POSITIONS IN CERTAIN CLIENT ACCOUNTS. Initiated By: MASSACHUSETTS SECURITIES DIVISION Date Initiated: 05/19/2020 Docket/Case Number: E-2019-0117

Principal Product Type: Other Other Product Type(s): MASTER LIMITED PARTNERSHIPS - ENERGY SECTOR US EQUITIES AND TELECOM Principal Sanction(s)/Relief Restitution Sought: Other Sanction(s)/Relief CEASE AND DESIST, CENSURE, REVIEW OF SUPERVISORY PROCEDURES, Sought: ENGAGEMENT OF INDEPENDENT COMPLIANCE CONSULTANT, DISGORGEMENT, ADMINISTRATIVE FINE

Resolution: Consent Resolution Date: 02/02/2021 Sanctions Ordered: Censure Monetary/Fine $200,000.00 ©2021 FINRA. All rights reserved. Report aboutDisgorgement/Restitution RBC CAPITAL MARKETS, LLC 57 Cease and Desist/Injunction www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $200,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: $200,000 ADMINISTRATIVE FINE, REIMBURSEMENT FOR NET REALIZED LOSSES TOTALING $86,283.84, AND DISGORGEMENT TOTALING $33,983.57 FOR COMMISSIONS PAID ON PURCHASES ON MLPS. Firm Statement RBCCM NOTES THAT IN AGREEING TO THE ORDER RBCCM DID NOT ADMIT TO ANY SUPERVISORY DEFICIENCIES AND BELIEVE THAT THE CUSTOMERS' ACCOUNT INVESTMENTS WERE APPROPRIATELY SUPERVISED AND WERE CONSISTENT WITH THEIR STATED INVESTMENT GOALS AND FINANCIAL CIRCUMSTANCES AS WELL AS RBCCM'S POLICIES. THE CUSTOMER ACCOUNTS GENERATED SUBSTANTIAL INCOME FOR THE CUSTOMERS THAT EXCEED THE COMMISSIONS CHARGED. AFTER 50 YEARS IN THE FINANCIAL SERVICES INDUSTRY, THE REGISTERED REPRESENTATIVE VOLUNTARILY RETIRED IN 2020 HAVING BEEN THE SUBJECT OF ONLY ONE CUSTOMER COMPLAINT THROUGHOUT HIS 50 YEAR CAREER, NOR WAS HE THE SUBJECT OF ANY PRIOR REGULATORY DISCIPLINE. RBCCM AND THE REGISTERED REPRESENTATIVE SETTLED THIS MATTER IN THE INTERESTS OF CUSTOMER RELATIONS AND TO AVOID THE COSTS, UNCERTAINTIES AND DISTRACTIONS ASSOCIATED WITH LITIGATION. i Disclosure 13 of 336 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASE 33-10777; 34-88745; IA RELEASE 40-5487, APRIL 24, 2020: 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 SECTION 8A OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AGAINST RBC CAPITAL MARKETS LLC ("RBC" OR "RESPONDENT"). THE COMMISSION FINDS THAT FROM AT LEAST JULY 2012 THROUGH AUGUST 2017 (THE "RELEVANT PERIOD"), RBC DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION BROKERAGE CUSTOMERS WHO MAINTAINED ACCOUNTS AT RBC ("ELIGIBLE CUSTOMERS") BY FAILING TO ASCERTAIN THAT THEY WERE ELIGIBLE FOR A LESS EXPENSIVE SHARE CLASS, AND RECOMMENDING ©2021 FINRA. All rights reserved. Report aboutAND RBC SELLING CAPITAL THEM MARKETS, MORE LLC EXPENSIVE SHARE CLASSES IN CERTAIN 58 OPEN-END REGISTERED INVESTMENT COMPANIES ("MUTUAL FUNDS") WHEN LESS EXPENSIVE SHARE CLASSES WERE AVAILABLE. RBC DID SO WITHOUT DISCLOSING THAT IT WOULD RECEIVE GREATER COMPENSATION FROM THE ELIGIBLE CUSTOMERS' PURCHASES OF THE MORE EXPENSIVE SHARE CLASSES. ELIGIBLE CUSTOMERS DID NOT HAVE SUFFICIENT INFORMATION TO UNDERSTAND THAT RBC HAD A CONFLICT OF INTEREST RESULTING FROM COMPENSATION IT RECEIVED FOR SELLING THE MORE EXPENSIVE SHARE CLASSES. SPECIFICALLY, RBC RECOMMENDED AND SOLD THESE ELIGIBLE CUSTOMERS CLASS A SHARES WITH AN UP-FRONT SALES CHARGE, OR CLASS B OR CLASS C SHARES WITH A BACK-END CONTINGENT DEFERRED SALES CHARGE ("CDSC") (A DEFERRED SALES CHARGE THE PURCHASER PAYS IF THE PURCHASER SELLS THE SHARES DURING A SPECIFIED TIME PERIOD FOLLOWING THE PURCHASE) AND HIGHER ONGOING FEES AND EXPENSES, WHEN THESE ELIGIBLE CUSTOMERS WERE ELIGIBLE TO PURCHASE LOAD-WAIVED CLASS A AND/OR NO-LOAD CLASS R SHARES. RBC OMITTED MATERIAL INFORMATION CONCERNING ITS COMPENSATION WHEN IT RECOMMENDED THE MORE EXPENSIVE SHARE CLASSES. RBC ALSO DID NOT DISCLOSE THAT THE PURCHASE OF THE MORE EXPENSIVE SHARE CLASSES WOULD NEGATIVELY IMPACT THE OVERALL RETURN ON THE ELIGIBLE CUSTOMERS' INVESTMENTS, IN LIGHT OF THE DIFFERENT FEE STRUCTURES FOR THE DIFFERENT FUND SHARE CLASSES. IN MAKING THOSE RECOMMENDATIONS OF MORE EXPENSIVE SHARE CLASSES WHILE OMITTING MATERIAL FACTS, RBC VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. THESE PROVISIONS PROHIBIT, RESPECTIVELY, IN THE OFFER OR SALE OF SECURITIES, OBTAINING MONEY OR PROPERTY BY MEANS OF AN OMISSION TO STATE A MATERIAL FACT NECESSARY TO MAKE STATEMENTS MADE NOT MISLEADING, AND ENGAGING IN A COURSE OF BUSINESS WHICH OPERATES AS A FRAUD OR DECEIT ON THE PURCHASER. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, RBC WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. SEC ADMIN RELEASE 33-10777; 34-88745; IA RELEASE 40-5487, APRIL 24, 2020: 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 SECTION 8A OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AGAINST RBC CAPITAL MARKETS LLC ("RBC" OR "RESPONDENT"). THE COMMISSION FINDS THAT FROM AT LEAST JULY 2012 THROUGH AUGUST 2017 (THE "RELEVANT www.finra.org/brokercheck PERIOD"), RBC DISADVANTAGED CERTAIN RETIREMENT PLAN AND User Guidance CHARITABLE ORGANIZATION BROKERAGE CUSTOMERS WHO MAINTAINED ACCOUNTS AT RBC ("ELIGIBLE CUSTOMERS") BY FAILING TO ASCERTAIN THAT THEY WERE ELIGIBLE FOR A LESS EXPENSIVE SHARE CLASS, AND RECOMMENDING AND SELLING THEM MORE EXPENSIVE SHARE CLASSES IN CERTAIN OPEN-END REGISTERED INVESTMENT COMPANIES ("MUTUAL FUNDS") WHEN LESS EXPENSIVE SHARE CLASSES WERE AVAILABLE. RBC DID SO WITHOUT DISCLOSING THAT IT WOULD RECEIVE GREATER COMPENSATION FROM THE ELIGIBLE CUSTOMERS' PURCHASES OF THE MORE EXPENSIVE SHARE CLASSES. ELIGIBLE CUSTOMERS DID NOT HAVE SUFFICIENT INFORMATION TO UNDERSTAND THAT RBC HAD A CONFLICT OF INTEREST RESULTING FROM COMPENSATION IT RECEIVED FOR SELLING THE MORE EXPENSIVE SHARE CLASSES. SPECIFICALLY, RBC RECOMMENDED AND SOLD THESE ELIGIBLE CUSTOMERS CLASS A SHARES WITH AN UP-FRONT SALES CHARGE, OR CLASS B OR CLASS C SHARES WITH A BACK-END CONTINGENT DEFERRED SALES CHARGE ("CDSC") (A DEFERRED SALES CHARGE THE PURCHASER PAYS IF THE PURCHASER SELLS THE SHARES DURING A SPECIFIED TIME PERIOD FOLLOWING THE PURCHASE) AND HIGHER ONGOING FEES AND EXPENSES, WHEN THESE ELIGIBLE CUSTOMERS WERE ELIGIBLE TO PURCHASE LOAD-WAIVED CLASS A AND/OR NO-LOAD CLASS R SHARES. RBC OMITTED MATERIAL INFORMATION CONCERNING ITS COMPENSATION WHEN IT RECOMMENDED THE MORE EXPENSIVE SHARE CLASSES. RBC ALSO DID NOT DISCLOSE THAT THE PURCHASE OF THE MORE EXPENSIVE SHARE CLASSES WOULD NEGATIVELY IMPACT THE OVERALL RETURN ON THE ELIGIBLE CUSTOMERS' INVESTMENTS, IN LIGHT OF THE DIFFERENT FEE STRUCTURES FOR THE DIFFERENT FUND SHARE CLASSES. IN MAKING THOSE RECOMMENDATIONS OF MORE EXPENSIVE SHARE CLASSES WHILE OMITTING MATERIAL FACTS, RBC VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. THESE PROVISIONS PROHIBIT, RESPECTIVELY, IN THE OFFER OR SALE OF SECURITIES, OBTAINING MONEY OR PROPERTY BY MEANS OF AN OMISSION TO STATE A MATERIAL FACT NECESSARY TO MAKE STATEMENTS MADE NOT MISLEADING, AND ENGAGING IN A COURSE OF BUSINESS WHICH OPERATES AS A FRAUD OR DECEIT ON THE PURCHASER. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, RBC WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 04/24/2020 Docket/Case Number: 3-19769

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

Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 04/24/2020 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: Censure Monetary/Fine $650,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: PREJUDGMENT INTEREST ON DISGORGEMENT Sanction Details: RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. RESPONDENT IS CENSURED AND SHALL PAY DISGORGEMENT OF $2,607,676 WITH PREJUDGMENT INTEREST OF $631,331, PLUS A CIVIL MONETARY PENALTY OF $650,000. Regulator Statement RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. RESPONDENT WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. ACCORDINGLY, IT IS ORDERED THAT RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. RESPONDENT IS CENSURED AND SHALL PAY DISGORGEMENT OF $2,607,676 WITH PREJUDGMENT INTEREST OF $631,331, PLUS A CIVIL MONETARY PENALTY OF $650,000. i Reporting Source: Firm Current Status: Final Allegations: THE COMMISSION FINDS THAT FROM AT LEAST JULY 2012 THROUGH AUGUST 2017 (THE "RELEVANT PERIOD"), RBC DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION BROKERAGE CUSTOMERS WHO MAINTAINED ACCOUNTS AT RBC ("ELIGIBLE CUSTOMERS") BY FAILING TO ASCERTAIN THAT THEY WERE ELIGIBLE FOR A LESS EXPENSIVE SHARE CLASS, AND RECOMMENDING AND SELLING THEM MORE EXPENSIVE SHARE CLASSES IN CERTAIN OPEN-END ©2021 FINRA. All rights reserved. Report aboutREGISTERED RBC CAPITAL INVESTMENT MARKETS, LLC COMPANIES ("MUTUAL FUNDS") WHEN LESS 60 EXPENSIVE SHARE CLASSES WERE AVAILABLE. RBC DID SO WITHOUT DISCLOSING THAT IT WOULD RECEIVE GREATER COMPENSATION FROM THE ELIGIBLE CUSTOMERS' PURCHASES OF THE MORE EXPENSIVE SHARE CLASSES. ELIGIBLE CUSTOMERS DID NOT HAVE SUFFICIENT INFORMATION TO UNDERSTAND THAT RBC HAD A CONFLICT OF INTEREST RESULTING FROM COMPENSATION IT RECEIVED FOR SELLING THE MORE EXPENSIVE SHARE CLASSES. SPECIFICALLY, RBC RECOMMENDED AND SOLD THESE ELIGIBLE CUSTOMERS CLASS A SHARES WITH AN UP-FRONT SALES CHARGE, OR CLASS B OR CLASS C SHARES WITH A BACK-END CONTINGENT DEFERRED SALES CHARGE ("CDSC") (A DEFERRED SALES CHARGE THE PURCHASER PAYS IF THE PURCHASER SELLS THE SHARES DURING A SPECIFIED TIME PERIOD FOLLOWING THE PURCHASE) AND HIGHER ONGOING FEES AND EXPENSES, WHEN THESE ELIGIBLE CUSTOMERS WERE ELIGIBLE TO PURCHASE LOAD-WAIVED CLASS A AND/OR NO-LOAD CLASS R SHARES. RBC OMITTED MATERIAL INFORMATION CONCERNING ITS COMPENSATION WHEN IT RECOMMENDED THE MORE EXPENSIVE SHARE CLASSES. RBC ALSO DID NOT DISCLOSE THAT THE PURCHASE OF THE MORE EXPENSIVE SHARE CLASSES WOULD NEGATIVELY IMPACT THE OVERALL RETURN ON THE ELIGIBLE CUSTOMERS' INVESTMENTS, IN LIGHT OF THE DIFFERENT FEE STRUCTURES FOR THE DIFFERENT FUND SHARE CLASSES. IN MAKING THOSE RECOMMENDATIONS OF MORE EXPENSIVE SHARE CLASSES WHILE OMITTING MATERIAL FACTS, RBC VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. THESE PROVISIONS PROHIBIT, RESPECTIVELY, IN THE OFFER OR SALE OF SECURITIES, OBTAINING MONEY OR PROPERTY BY MEANS OF AN OMISSION TO STATE A MATERIAL FACT NECESSARY TO MAKE STATEMENTS MADE NOT MISLEADING, AND ENGAGING IN A COURSE OF BUSINESS WHICH OPERATES AS A FRAUD OR DECEIT ON THE PURCHASER. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, RBC WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. THE COMMISSION FINDS THAT FROM AT LEAST JULY 2012 THROUGH AUGUST 2017 (THE "RELEVANT PERIOD"), RBC DISADVANTAGED CERTAIN www.finra.org/brokercheck RETIREMENT PLAN AND CHARITABLE ORGANIZATION BROKERAGE User Guidance CUSTOMERS WHO MAINTAINED ACCOUNTS AT RBC ("ELIGIBLE CUSTOMERS") BY FAILING TO ASCERTAIN THAT THEY WERE ELIGIBLE FOR A LESS EXPENSIVE SHARE CLASS, AND RECOMMENDING AND SELLING THEM MORE EXPENSIVE SHARE CLASSES IN CERTAIN OPEN-END REGISTERED INVESTMENT COMPANIES ("MUTUAL FUNDS") WHEN LESS EXPENSIVE SHARE CLASSES WERE AVAILABLE. RBC DID SO WITHOUT DISCLOSING THAT IT WOULD RECEIVE GREATER COMPENSATION FROM THE ELIGIBLE CUSTOMERS' PURCHASES OF THE MORE EXPENSIVE SHARE CLASSES. ELIGIBLE CUSTOMERS DID NOT HAVE SUFFICIENT INFORMATION TO UNDERSTAND THAT RBC HAD A CONFLICT OF INTEREST RESULTING FROM COMPENSATION IT RECEIVED FOR SELLING THE MORE EXPENSIVE SHARE CLASSES. SPECIFICALLY, RBC RECOMMENDED AND SOLD THESE ELIGIBLE CUSTOMERS CLASS A SHARES WITH AN UP-FRONT SALES CHARGE, OR CLASS B OR CLASS C SHARES WITH A BACK-END CONTINGENT DEFERRED SALES CHARGE ("CDSC") (A DEFERRED SALES CHARGE THE PURCHASER PAYS IF THE PURCHASER SELLS THE SHARES DURING A SPECIFIED TIME PERIOD FOLLOWING THE PURCHASE) AND HIGHER ONGOING FEES AND EXPENSES, WHEN THESE ELIGIBLE CUSTOMERS WERE ELIGIBLE TO PURCHASE LOAD-WAIVED CLASS A AND/OR NO-LOAD CLASS R SHARES. RBC OMITTED MATERIAL INFORMATION CONCERNING ITS COMPENSATION WHEN IT RECOMMENDED THE MORE EXPENSIVE SHARE CLASSES. RBC ALSO DID NOT DISCLOSE THAT THE PURCHASE OF THE MORE EXPENSIVE SHARE CLASSES WOULD NEGATIVELY IMPACT THE OVERALL RETURN ON THE ELIGIBLE CUSTOMERS' INVESTMENTS, IN LIGHT OF THE DIFFERENT FEE STRUCTURES FOR THE DIFFERENT FUND SHARE CLASSES. IN MAKING THOSE RECOMMENDATIONS OF MORE EXPENSIVE SHARE CLASSES WHILE OMITTING MATERIAL FACTS, RBC VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. THESE PROVISIONS PROHIBIT, RESPECTIVELY, IN THE OFFER OR SALE OF SECURITIES, OBTAINING MONEY OR PROPERTY BY MEANS OF AN OMISSION TO STATE A MATERIAL FACT NECESSARY TO MAKE STATEMENTS MADE NOT MISLEADING, AND ENGAGING IN A COURSE OF BUSINESS WHICH OPERATES AS A FRAUD OR DECEIT ON THE PURCHASER. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, RBC WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 04/24/2020 Docket/Case Number: 3-19769

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 61 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 04/24/2020 Sanctions Ordered: Censure Monetary/Fine $650,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: PREJUDGMENT INTEREST ON DISGORGEMENT Sanction Details: RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. RESPONDENT IS CENSURED AND SHALL PAY DISGORGEMENT OF $2,607,676 WITH PREJUDGMENT INTEREST OF $631,331, PLUS A CIVIL MONETARY PENALTY OF $650,000. Firm Statement RBC HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. RBC WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. ACCORDINGLY, IT IS ORDERED THAT RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. RESPONDENT IS CENSURED AND SHALL PAY DISGORGEMENT OF $2,607,676 WITH PREJUDGMENT INTEREST OF $631,331, PLUS A CIVIL MONETARY PENALTY OF $650,000. i Disclosure 14 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED THE NASDAQ OPTIONS MARKET AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS) AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT ©2021 FINRA. All rights reserved. Report aboutIS, THEY RBC CAPITAL WERE MARKETS, NOT REASONABLY LLC DESIGNED TO ACHIEVE COMPLIANCE 62 WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED THE NASDAQ OPTIONS MARKET AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. www.finra.org/brokercheck THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY User Guidance PROCEDURES (WSPS) AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. Initiated By: NASDAQ STOCK MARKET - THE NASDAQ OPTIONS MARKET LLC Date Initiated: 12/02/2019 Docket/Case Number: 2016048771302

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/02/2019 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 $15,300.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $61,200, OF WHICH $15,300 IS PAYABLE TO THE EXCHANGE. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED THE NASDAQ OPTIONS MARKET AND VARIOUS ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 63 OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS)AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR www.finra.org/brokercheck "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF User Guidance FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED THE NASDAQ OPTIONS MARKET AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS)AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. Initiated By: NASDAQ STOCK MARKET - THE NASDAQ OPTIONS MARKET LLC Date Initiated: 12/02/2019 Docket/Case Number: 2016048771302

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/02/2019 Sanctions Ordered: Censure Monetary/Fine $15,300.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $61,200, OF WHICH $15,300 IS PAYABLE TO THE EXCHANGE. i Disclosure 15 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE ©2021 FINRA. All rights reserved. Report aboutSANCTIONS RBC CAPITAL AND MARKETS, TO THE LLC ENTRY OF FINDINGS THAT RBC FAILED TO 64 ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO FLOOR BROKERS AT THE EXCHANGE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS) AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. www.finra.org/brokercheck User Guidance

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO FLOOR BROKERS AT THE EXCHANGE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS) AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. Initiated By: NYSE AMERICAN LLC Date Initiated: 12/02/2019 Docket/Case Number: 2016048771303

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

i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO FLOOR BROKERS AT THE EXCHANGE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS)AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. Initiated By: NYSE AMERICAN LLC Date Initiated: 12/02/2019 Docket/Case Number: 2016048771303

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/02/2019 Sanctions Ordered: Censure Monetary/Fine $15,300.00 Other Sanctions Ordered:

©2021Sanction FINRA. Details: All rights reserved. Report aboutTHE RBC FIRM CAPITAL WAS MARKETS,CENSURED LLC AND FINED A TOTAL OF $61,200, OF WHICH 66 $15,300 IS PAYABLE TO THE EXCHANGE. www.finra.org/brokercheck User Guidance

Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $61,200, OF WHICH $15,300 IS PAYABLE TO THE EXCHANGE. i Disclosure 16 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO FLOOR BROKERS AT THE EXCHANGE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS) AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT, INSOFAR AS PRACTICABLE, VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. Initiated By: NYSE ARCA, INC. Date Initiated: 12/02/2019 Docket/Case Number: 2016048771304

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/02/2019 Does the order constitute a No final order based on violations of any laws or regulations that prohibit ©2021fraudulent, FINRA. Allmanipulative, rights reserved. or Report about RBC CAPITAL MARKETS, LLC 67 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 $15,300.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $61,200, OF WHICH $15,300 IS PAYABLE TO THE EXCHANGE. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO FLOOR BROKERS AT THE EXCHANGE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS)AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT, INSOFAR AS PRACTICABLE, VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. Initiated By: NYSE ARCA, INC. Date Initiated: 12/02/2019 Docket/Case Number: 2016048771304

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/02/2019 Sanctions Ordered: Censure Monetary/Fine $15,300.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $61,200, OF WHICH $15,300 IS PAYABLE TO THE EXCHANGE. i Disclosure 17 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO FLOOR BROKERS AT THE EXCHANGE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS) AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT, INSOFAR AS PRACTICABLE, VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. Initiated By: NASDAQ PHLX LLC Date Initiated: 12/02/2019 Docket/Case Number: 2016048771301

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/02/2019 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 $15,300.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $61,200, OF WHICH $15,300 IS PAYABLE TO THE EXCHANGE. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO FLOOR BROKERS AT THE EXCHANGE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS) AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT, INSOFAR AS PRACTICABLE, VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL ©2021 FINRA. All rights reserved. Report aboutSECURITIES RBC CAPITAL LAWS MARKETS, LLC 70 AND THE EXCHANGE RULES. WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO FLOOR BROKERS AT THE EXCHANGE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS) AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY www.finra.org/brokercheck ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT User Guidance REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT, INSOFAR AS PRACTICABLE, VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. Initiated By: NASDAQ PHLX LLC Date Initiated: 12/02/2019 Docket/Case Number: 2016048771301

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

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 CENSURE ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 71 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/29/2019 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 $37,500.00 Other Sanctions Ordered: N/A Sanction Details: TOTAL FINE WAS 37,500 AND WILL BE PAID BY DIRECT DEBIT IN THE NORMAL COURSE. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC (THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING THE PERIOD FEBRUARY 14, 2017 THROUGH DECEMBER 31, 2017, THE FIRM VIOLATED NASDAQ RULES 4613(A), 3010 AND 2010A. Initiated By: NASDAQ STOCK MARKET Date Initiated: 03/31/2019 Docket/Case Number: 2019.04.0041

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/29/2019

Sanctions Ordered: Censure Monetary/Fine $37,500.00 Other Sanctions Ordered: Sanction Details: TOTAL FINE WAS 37,500 AND WILL BE PAID BY DIRECT DEBIT IN THE NORMAL COURSE. i Disclosure 19 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC (I) VIOLATED EXCHANGE RULE 24.1, AND SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER; AND (II) VIOLATED EXCHANGE RULES 5.1 AND 3.2. SANCTION: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $9,000 Initiated By: CBOE BZX EXCHANGE, INC. Date Initiated: 10/16/2019 Docket/Case Number: STAR NO. 20160487713, FILE NO. USE-1710

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: 10/23/2019 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 $9,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $9,000

i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC", THE "FIRM", OR "RESPONDENT") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT RBC FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND/OR ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO FLOOR BROKERS AT THE EXCHANGE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. THE FINDINGS STATED THAT RBC'S WRITTEN SUPERVISORY PROCEDURES (WSPS)AND SUPERVISORY SYSTEM APPLICABLE TO THE HANDLING OF MANUAL OPTIONS ORDERS BY ITS GLOBAL EQUITY LINKED PRODUCTS DESK (THE GELP DESK) AND BY ITS WEALTH MANAGEMENT OPTIONS DESK (THE WM DESK) WERE NOT REASONABLY DESIGNED. THAT IS, THEY WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE EXCHANGE RULES. Initiated By: CBOE BZX EXCHANGE, INC. Date Initiated: 10/23/2019 Docket/Case Number: STAR NO. 20160487713, FILE NO. USE-1710

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: 10/23/2019 Sanctions Ordered: Censure Monetary/Fine $9,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $9,000 i Disclosure 20 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 74 www.finra.org/brokercheck User Guidance

Disclosure 20 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC (I) ENTERED PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. RBC ENTERED THE ORDERS IN AN ORDER MANAGEMENT SYSTEM THAT IT USED FOR PRINCIPAL ORDERS. THE ORDER MANAGEMENT SYSTEM WAS HARD-CODED TO PLACE THE "FIRM" ORIGIN CODE ON ORDERS TO INDICATE THAT THE ORDERS WERE PRINCIPAL ORDERS. THE FIRM ALSO USED A THIRD-PARTY SYSTEM TO ROUTE ORDERS, BUT DUE TO A MAPPING ERROR, THE THIRD-PARTY SYSTEM INCORRECTLY PLACED THE "CUSTOMER" ORIGIN CODE ON THE FIRM'S PRINCIPAL ORDERS, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. THESE ORDERS WERE ROUTED TO AND EXECUTED ON FOURTEEN EXCHANGES, RESULTING IN 7,032 EXECUTIONS WITH A VOLUME OF 118,871 CONTRACTS, OF WHICH 30,714 CONTRACTS, OR 25.84 PERCENT OF THE TOTAL, WERE TRADED ON BZX. EACH INSTANCE IN WHICH THE FIRM EXECUTED AN ORDER WITH AN INCORRECT ORIGIN CODE POTENTIALLY HAD ADVERSE CONSEQUENCES, SUCH AS CREATING INACCURATE RECORDS OF PURCHASES AND SALES, CREATING AN INACCURATE AUDIT TRAIL, REPORTING TRADES TO OCC WITH INACCURATE TRADE DETAILS, AND IMPEDING BZX'S ABILITY TO SURVEIL FOR AND DETECT POTENTIAL VIOLATIONS OF ITS RULES AND FEDERAL SECURITIES LAWS. BECAUSE THE FIRM ENTERED AND EXECUTED THESE ORDERS WITH THE WRONG ORIGIN CODE, THE TRADES CLEARED INCORRECTLY AS "CUSTOMER" TRADES AT OCC INSTEAD OF AS "FIRM" TRADES; (II) FAILED TO IDENTIFY THE PATTERN OF ORIGIN CODE ERRORS OR THE CAUSE OF SUCH ERRORS THAT OCCURED ON 34 SEPARATE DAYS FROM FEBRUARY 4 THROUGH APRIL 18, 2016. IN ADDITION, RBC SHOULD HAVE BEEN ALERTED TO THE ORIGIN CODE PROBLEM BY THE FACT THAT PROPRIETARY ORDERS ENTERED INTO A SYSTEM THAT WAS HARD-CODED TO APPLY THE "FIRM" ORIGIN CODE TO ORDERS NEVERTHELESS CLEARED AS "CUSTOMER" WITH OCC; AND (III) CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. THE FIRM CONDUCTED THESE REVIEWS FROM FIVE TO 53 DAYS AFTER THE DUE DATE FOR THE REVIEWS. Initiated By: CBOE BZX EXCHANGE, INC. Date Initiated: 08/22/2019 Docket/Case Number: STAR NO. 20160509336, FILE NO. USRI-7935

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: 10/02/2019 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 $28,271.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A TOTAL MONETARY FINE OF $100,000, OF WHICH $28, 271 IS PAYABLE TO BZX. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MAKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITON TO THE FOREGOING, FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. Initiated By: CBOE BZX EXCHANGE, INC. Date Initiated: 10/02/2019 Docket/Case Number: USRI-7935: STAR NO. 20160509336

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: 10/02/2019 Sanctions Ordered: Censure Monetary/Fine $28,271.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE OF $28,271 i Disclosure 21 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A REASONABLE SUPERVISORY SYSTEM GOVERNING THE DELIVERY OF PROSPECTUSES FOR EXCHANGE-TRADED FUNDS (ETFS), EXCHANGE-TRADED NOTES (ETNS), AND MUTUAL FUNDS AND FAILED TO ENFORCE ITS WSPS. THE FINDINGS STATED THAT THE FIRM'S PROSPECTUS DELIVERY PROCESS FOR ETFS AND ETNS INVOLVED MANUALLY INPUTTING CODING FOR INDIVIDUAL SECURITIES INTO THIRD-PARTY SOFTWARE TO TRIGGER THE DELIVERY OF A PROSPECTUS WHEN A CUSTOMER PURCHASED THE SECURITY. THE FIRM RELIED ON A SINGLE EMPLOYEE TO MANUALLY ASSIGN THE TRAILER CODES TO ETFS AND ETNS ON A SECURITY-BY-SECURITY BASIS, AND HAD NO SUPERVISORY SYSTEMS OR CONTROLS IN PLACE TO MONITOR OR SUPERVISE THE EMPLOYEE'S PERFORMANCE OF THESE DUTIES. AS A RESULT, THE FIRM DID NOT DETECT THAT THE EMPLOYEE HAD INADVERTENTLY CAUSED THE SYSTEM TO OVERWRITE THE TRAILER CODES THAT TRIGGERED PROSPECTUS DELIVERY AND FAILED TO IDENTIFY NEW ETFS AND ETNS REQUIRING A TRAILER CODE. EVEN AFTER DISCOVERING THE EXTENT OF THE CODING ERRORS, THE FIRM'S EFFORTS TO ADDRESS THE ISSUES WERE NOT EFFECTIVE. THE FIRM'S SUPERVISORY SYSTEM RELATED TO PROSPECTUS DELIVERY FOR MUTUAL FUNDS ALSO WAS NOT REASONABLY DESIGNED. THE FIRM MERGED WITH AN AFFILIATE, AND BEGAN USING A NEW AUTOMATED VENDOR SYSTEM TO IDENTIFY MUTUAL FUND PURCHASES REQUIRING PROSPECTUS DELIVERY. THE VENDOR SYSTEM DID NOT CORRECTLY DESIGNATE FOR PROSPECTUS DELIVERY CERTAIN CUSTOMER MUTUAL ©2021 FINRA. All rights reserved. Report aboutFUND RBC ORDERS CAPITAL MARKETS,PLACED LLCTHROUGH THE FIRM'S MANAGED ACCOUNTS 77 PLATFORM. THE FIRM'S SUPERVISORY SYSTEM INCLUDED A WRITTEN PROCEDURE OBLIGATING IT TO DESIGNATE AN EMPLOYEE TO CONDUCT PERIODIC SUPERVISORY REVIEWS TO DETERMINE WHETHER PRODUCTS WERE PROPERLY CODED FOR PROSPECTUS DELIVERY. HOWEVER, WITH RESPECT TO MUTUAL FUNDS, THE FIRM FAILED TO ASSIGN THESE SUPERVISORY DUTIES, THEREBY FAILING TO ENFORCE THIS PROCEDURE, AND THUS THESE DUTIES WERE NOT PERFORMED FOR MORE THAN EIGHT YEARS. AS A RESULT, THE ABSENCE OF APPROPRIATE CODING FOR AT LEAST HUNDREDS OF THOUSANDS OF MUTUAL FUND PURCHASES WAS NOT DISCOVERED UNTIL FINRA'S INVESTIGATION IN THIS MATTER. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN OR ENFORCE SUPERVISORY CONTROLS TO TEST AND VERIFY THAT IT WAS DELIVERING ETF, ETN AND MUTUAL FUND PROSPECTUSES WHERE REQUIRED. THE ABSENCE OF ANY TESTING BY THE FIRM IN THIS AREA WAS PARTICULARLY PROBLEMATIC GIVEN THE ITS PRIOR DISCIPLINARY HISTORY, THE FACT THAT IT ADDED A NEW VENDOR SYSTEM FOR MUTUAL FUND PROSPECTUS DELIVERY, AND ITS RELIANCE ON ONE INDIVIDUAL TO MANUALLY CODE ETFS AND ETNS WITH NO SUPERVISORY OVERSIGHT. THESE FAILURES PREVENTED THE FIRM FROM DETECTING THE SIGNIFICANT ETF, ETN, AND MUTUAL FUND PROSPECTUS DELIVERY FAILURES AND RELATED SUPERVISORY DEFICIENCIES. THE FIRM ALSO FAILED TO TEST THE SYSTEM MODIFICATIONS AND SURVEILLANCE PROCEDURES PUT IN PLACE TO ADDRESS THE ETF AND ETN CODING ERRORS THAT WERE PREVIOUSLY DISCOVERED. THIS LACK OF POST-IMPLEMENTATION TESTING PREVENTED THE FIRM FROM IDENTIFYING THE FAILURES THAT CAUSED THESE NEW PROCESSES NOT TO BE IMPLEMENTED PROPERLY. THE FINDINGS ALSO INCLUDED THAT DUE TO THE FIRM'S FAILURE TO HAVE REASONABLE SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, THE FIRM FAILED TO DELIVER PROSPECTUSES WHERE REQUIRED FOR ETF, ETN, AND MUTUAL FUND PURCHASES. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A REASONABLE SUPERVISORY SYSTEM GOVERNING THE DELIVERY OF PROSPECTUSES FOR EXCHANGE-TRADED FUNDS (ETFS), EXCHANGE-TRADED NOTES (ETNS), AND MUTUAL FUNDS AND FAILED TO ENFORCE ITS WSPS. THE FINDINGS STATED THAT THE FIRM'S PROSPECTUS DELIVERY PROCESS FOR ETFS AND ETNS INVOLVED MANUALLY INPUTTING CODING FOR INDIVIDUAL SECURITIES INTO THIRD-PARTY SOFTWARE TO TRIGGER THE DELIVERY OF A PROSPECTUS WHEN A CUSTOMER PURCHASED THE SECURITY. THE FIRM RELIED ON A SINGLE EMPLOYEE TO MANUALLY ASSIGN THE TRAILER CODES TO ETFS AND ETNS ON A SECURITY-BY-SECURITY BASIS, AND HAD NO SUPERVISORY SYSTEMS OR CONTROLS IN PLACE TO MONITOR OR SUPERVISE THE EMPLOYEE'S PERFORMANCE OF THESE DUTIES. AS A RESULT, THE FIRM DID NOT DETECT THAT THE EMPLOYEE HAD INADVERTENTLY CAUSED THE SYSTEM TO OVERWRITE THE TRAILER CODES THAT TRIGGERED PROSPECTUS DELIVERY AND FAILED TO IDENTIFY NEW ETFS AND ETNS REQUIRING A TRAILER CODE. EVEN AFTER DISCOVERING THE EXTENT OF THE CODING ERRORS, THE FIRM'S EFFORTS TO ADDRESS THE ISSUES WERE NOT EFFECTIVE. THE FIRM'S SUPERVISORY SYSTEM RELATED TO PROSPECTUS DELIVERY FOR www.finra.org/brokercheck MUTUAL FUNDS ALSO WAS NOT REASONABLY DESIGNED. THE FIRM User Guidance MERGED WITH AN AFFILIATE, AND BEGAN USING A NEW AUTOMATED VENDOR SYSTEM TO IDENTIFY MUTUAL FUND PURCHASES REQUIRING PROSPECTUS DELIVERY. THE VENDOR SYSTEM DID NOT CORRECTLY DESIGNATE FOR PROSPECTUS DELIVERY CERTAIN CUSTOMER MUTUAL FUND ORDERS PLACED THROUGH THE FIRM'S MANAGED ACCOUNTS PLATFORM. THE FIRM'S SUPERVISORY SYSTEM INCLUDED A WRITTEN PROCEDURE OBLIGATING IT TO DESIGNATE AN EMPLOYEE TO CONDUCT PERIODIC SUPERVISORY REVIEWS TO DETERMINE WHETHER PRODUCTS WERE PROPERLY CODED FOR PROSPECTUS DELIVERY. HOWEVER, WITH RESPECT TO MUTUAL FUNDS, THE FIRM FAILED TO ASSIGN THESE SUPERVISORY DUTIES, THEREBY FAILING TO ENFORCE THIS PROCEDURE, AND THUS THESE DUTIES WERE NOT PERFORMED FOR MORE THAN EIGHT YEARS. AS A RESULT, THE ABSENCE OF APPROPRIATE CODING FOR AT LEAST HUNDREDS OF THOUSANDS OF MUTUAL FUND PURCHASES WAS NOT DISCOVERED UNTIL FINRA'S INVESTIGATION IN THIS MATTER. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN OR ENFORCE SUPERVISORY CONTROLS TO TEST AND VERIFY THAT IT WAS DELIVERING ETF, ETN AND MUTUAL FUND PROSPECTUSES WHERE REQUIRED. THE ABSENCE OF ANY TESTING BY THE FIRM IN THIS AREA WAS PARTICULARLY PROBLEMATIC GIVEN THE ITS PRIOR DISCIPLINARY HISTORY, THE FACT THAT IT ADDED A NEW VENDOR SYSTEM FOR MUTUAL FUND PROSPECTUS DELIVERY, AND ITS RELIANCE ON ONE INDIVIDUAL TO MANUALLY CODE ETFS AND ETNS WITH NO SUPERVISORY OVERSIGHT. THESE FAILURES PREVENTED THE FIRM FROM DETECTING THE SIGNIFICANT ETF, ETN, AND MUTUAL FUND PROSPECTUS DELIVERY FAILURES AND RELATED SUPERVISORY DEFICIENCIES. THE FIRM ALSO FAILED TO TEST THE SYSTEM MODIFICATIONS AND SURVEILLANCE PROCEDURES PUT IN PLACE TO ADDRESS THE ETF AND ETN CODING ERRORS THAT WERE PREVIOUSLY DISCOVERED. THIS LACK OF POST-IMPLEMENTATION TESTING PREVENTED THE FIRM FROM IDENTIFYING THE FAILURES THAT CAUSED THESE NEW PROCESSES NOT TO BE IMPLEMENTED PROPERLY. THE FINDINGS ALSO INCLUDED THAT DUE TO THE FIRM'S FAILURE TO HAVE REASONABLE SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, THE FIRM FAILED TO DELIVER PROSPECTUSES WHERE REQUIRED FOR ETF, ETN, AND MUTUAL FUND PURCHASES. Initiated By: FINRA Date Initiated: 10/17/2019 Docket/Case Number: 2015046652401

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 78 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/17/2019 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 $2,900,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $2,900,000 AND REQUIRED TO PROVIDE A WRITTEN CERTIFICATION THAT IT HAS ESTABLISHED AND IMPLEMENTED A SUPERVISORY SYSTEM AND WRITTEN PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULES AND THE FEDERAL SECURITIES LAWS APPLICABLE TO PROSPECTUS DELIVERY. FINES PAID IN FULL ON OCTOBER 28, 2019. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WITH FINRA THAT FOUND THAT FROM MARCH 2008 TO JUNE 2016, THE FIRM FAILED TO DELIVER PROSPECTUSES TO CUSTOMERS IN CONNECTION WITH APPROXIMATELY 165,000 ETF AND ETN PURCHASES AND AT LEAST HUNDREDS OF THOUSANDS OF MUTUAL FUND PURCHASES. THE AWC ALSO FOUND THAT THE FIRM FAILED TO DESIGN, IMPLEMENT, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM, CONTROLS AND PROCEDURES TO COMPLY WITH THE PROSPECTUS DELIVERY RULES FOR ETFS, ETNS AND MUTUAL FUNDS. RBC FAILED TO HAVE IN PLACE A SYSTEM TO SUPERVISE ITS MANUAL CODING OF SOFTWARE TO TRIGGER THE DELIVERY OF AN ETF OR ETN PROSPECTUS. ALTHOUGH THE FIRM INSTITUTED A SURVEILLANCE PROCEDURE TO IDENTIFY PROSPECTUS DELIVERY CODING ISSUES AFTER DISCOVERING CERTAIN CODING ERRORS, RBC FAILED TO PROPERLY IMPLEMENT THAT PROCESS. WITH RESPECT TO MUTUAL FUNDS, RBC RELIED UPON THIRD-PARTY SOFTWARE TO AUTOMATICALLY CODE MUTUAL FUND PURCHASES FOR ©2021 FINRA. All rights reserved. Report aboutPROSPECTUS RBC CAPITAL DELIVERY. MARKETS, LLC DUE TO A DESIGN FLAW, THE SOFTWARE DID 79 NOT CODE CERTAIN MUTUAL FUND PURCHASES FOR PROSPECTUS DELIVERY AS REQUIRED. RBC'S SUPERVISORY SYSTEM INCLUDED A WRITTEN PROCEDURE TO DESIGNATE AN EMPLOYEE TO CONDUCT PERIODIC SUPERVISORY REVIEWS TO DETERMINE WHETHER MUTUAL FUNDS WERE PROPERLY CODED FOR PROSPECTUS DELIVERY. THE FIRM DID NOT ASSIGN THESE SUPERVISORY DUTIES. THEREFORE, THESE DUTIES WERE NOT PERFORMED DURING THE RELEVANT PERIOD. AS A RESULT, ISSUES WITH THE CODING WAS NOT DISCOVERED UNTIL FINRA'S INVESTIGATION IN THIS MATTER. RBC FAILED TO PERFORM AN AUDIT, REVIEW OR OTHER TESTING TO VERIFY THAT IT WAS DELIVERING PROSPECTUSES. THE FIRM ALSO DID NOT TEST THE SYSTEM MODIFICATIONS AND SURVEILLANCE PROCEDURES PUT IN PLACE TO ADDRESS THE ETF AND ETN CODING ERRORS IT HAD PREVIOUSLY DISCOVERED. IN DETERMINING THE APPROPRIATE SANCTION IN THIS MATTER, FINRA TOOK INTO ACCOUNT (I) THE FIRM'S PRIOR DISCIPLINARY HISTORY; (II) THE MORE THAN EIGHT YEARS OVER WHICH THE VIOLATIONS OCCURRED; (III) THE EXTENT OF THE SUPERVISORY DEFICIENCIES; (IV) THE LACK OF SUPERVISORY CONTROLS AND TESTING; (V) THAT THE FIRM VOLUNTARILY UNDERTOOK A COMPREHENSIVE REVIEW OF ITS ETF AND ETN PROSPECTUS DELIVERY PROCESSES UPON DISCOVERY OF THE ISSUES AND DISCLOSED ITS FINDINGS FROM THAT EXERCISE TO FINRA; (VI) THE FIRM'S EXTENSIVE TESTING OF ITS NON-ETF/ETN PROSPECTUS DELIVERY PROCESSES TO ASSIST FINRA IN UNDERSTANDING THE SCOPE OF THE ISSUE; AND (VII) CERTAIN FIRM CORRECTIVE ACTIONS CITED IN THE SETTLEMENT. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WITH FINRA THAT FOUND THAT FROM MARCH 2008 TO JUNE 2016, THE FIRM FAILED TO DELIVER PROSPECTUSES TO CUSTOMERS IN CONNECTION WITH APPROXIMATELY 165,000 ETF AND ETN PURCHASES AND AT LEAST HUNDREDS OF THOUSANDS OF MUTUAL FUND PURCHASES. THE AWC ALSO FOUND THAT THE FIRM FAILED TO DESIGN, IMPLEMENT, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM, CONTROLS AND PROCEDURES TO COMPLY WITH THE PROSPECTUS DELIVERY RULES FOR ETFS, ETNS AND MUTUAL FUNDS. RBC FAILED TO HAVE IN PLACE A SYSTEM TO SUPERVISE ITS MANUAL CODING OF SOFTWARE TO TRIGGER THE DELIVERY OF AN ETF OR ETN PROSPECTUS. ALTHOUGH THE FIRM INSTITUTED A SURVEILLANCE PROCEDURE TO IDENTIFY PROSPECTUS DELIVERY CODING ISSUES www.finra.org/brokercheck AFTER DISCOVERING CERTAIN CODING ERRORS, RBC FAILED TO User Guidance PROPERLY IMPLEMENT THAT PROCESS. WITH RESPECT TO MUTUAL FUNDS, RBC RELIED UPON THIRD-PARTY SOFTWARE TO AUTOMATICALLY CODE MUTUAL FUND PURCHASES FOR PROSPECTUS DELIVERY. DUE TO A DESIGN FLAW, THE SOFTWARE DID NOT CODE CERTAIN MUTUAL FUND PURCHASES FOR PROSPECTUS DELIVERY AS REQUIRED. RBC'S SUPERVISORY SYSTEM INCLUDED A WRITTEN PROCEDURE TO DESIGNATE AN EMPLOYEE TO CONDUCT PERIODIC SUPERVISORY REVIEWS TO DETERMINE WHETHER MUTUAL FUNDS WERE PROPERLY CODED FOR PROSPECTUS DELIVERY. THE FIRM DID NOT ASSIGN THESE SUPERVISORY DUTIES. THEREFORE, THESE DUTIES WERE NOT PERFORMED DURING THE RELEVANT PERIOD. AS A RESULT, ISSUES WITH THE CODING WAS NOT DISCOVERED UNTIL FINRA'S INVESTIGATION IN THIS MATTER. RBC FAILED TO PERFORM AN AUDIT, REVIEW OR OTHER TESTING TO VERIFY THAT IT WAS DELIVERING PROSPECTUSES. THE FIRM ALSO DID NOT TEST THE SYSTEM MODIFICATIONS AND SURVEILLANCE PROCEDURES PUT IN PLACE TO ADDRESS THE ETF AND ETN CODING ERRORS IT HAD PREVIOUSLY DISCOVERED. IN DETERMINING THE APPROPRIATE SANCTION IN THIS MATTER, FINRA TOOK INTO ACCOUNT (I) THE FIRM'S PRIOR DISCIPLINARY HISTORY; (II) THE MORE THAN EIGHT YEARS OVER WHICH THE VIOLATIONS OCCURRED; (III) THE EXTENT OF THE SUPERVISORY DEFICIENCIES; (IV) THE LACK OF SUPERVISORY CONTROLS AND TESTING; (V) THAT THE FIRM VOLUNTARILY UNDERTOOK A COMPREHENSIVE REVIEW OF ITS ETF AND ETN PROSPECTUS DELIVERY PROCESSES UPON DISCOVERY OF THE ISSUES AND DISCLOSED ITS FINDINGS FROM THAT EXERCISE TO FINRA; (VI) THE FIRM'S EXTENSIVE TESTING OF ITS NON-ETF/ETN PROSPECTUS DELIVERY PROCESSES TO ASSIST FINRA IN UNDERSTANDING THE SCOPE OF THE ISSUE; AND (VII) CERTAIN FIRM CORRECTIVE ACTIONS CITED IN THE SETTLEMENT. Initiated By: FINRA Date Initiated: 10/17/2019 Docket/Case Number: 2015046652401

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/17/2019 Sanctions Ordered: Censure Monetary/Fine $2,900,000.00 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 80 www.finra.org/brokercheck User Guidance

Censure Monetary/Fine $2,900,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED, FINED $2.9 MILLION AND AGREED TO AN UNDERTAKING TO CERTIFY THAT IT HAS ESTABLISHED AND IMPLEMENTED A SUPERVISORY SYSTEM AND WRITTEN PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULES AND THE FEDERAL SECURITIES LAWS APPLICABLE TO PROSPECTUS DELIVERY. i Disclosure 22 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC (I) FAILED TO RECORD ACCURATE ORDER RECEIPT TIMES FOR TEN OF THE TWENTY SAMPLED MANUAL CUSTOMER OPTION ORDERS REVIEWED THAT WERE ROUTED TO AND EXECUTED ON CBOE; (II) FAILED TO RECORD ACCURATE ORDER TRANSMISSION TIMES FOR EIGHT OF THE TWENTY SAMPLED MANUAL CUSTOMER OPTIONS ORDERS REVIEWED THAT WERE ROUTED TO AND EXECUTED ON CBOE; (III) FAILED TO RECORD AN ACCURATE ORDER RECEIPT TIME FOR ONE OF TWENTY-ONE SAMPLED MANUAL CUSTOMER OPTION ORDERS THAT WERE ROUTED TO AND EXECUTED (OR PARTIALLY EXECUTED) ON CBOE; AND (IV) FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF CBOE RULE 15.1; AND SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER, IN CONNECTION WITH THE CONDUCT DESCRIBED. VIOLATION OF EXCHANGE RULES 4.2, 4.24 AND 15.1; SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED AND RULE 17A-3, THEREUNDER. SANCTION: A CENSURE AND A MONETARY FINE OF $27,000. Initiated By: CBOE EXCHANGE, INC. Date Initiated: 10/16/2019 Docket/Case Number: USE-1710 / STAR NO. 20160487713

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: 10/18/2019 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 $27,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $27,000 i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM (I) FAILED TO RECORD ACCURATE ORDER RECEIPT TIMES FOR TEN OF THE TWENTY SAMPLED MANUAL CUSTOMER OPTION ORDERS REVIEWED THAT WERE ROUTED TO AND EXECUTED ON CBOE; (II) FAILED TO RECORD ACCURATE ORDER TRANSMISSION TIMES FOR EIGHT OF THE TWENTY SAMPLED MANUAL CUSTOMER OPTIONS ORDERS REVIEWED THAT WERE ROUTED TO AND EXECUTED ON CBOE; (III) FAILED TO RECORD AN ACCURATE ORDER RECEIPT TIME FOR ONE OF TWENTY-ONE SAMPLED MANUAL CUSTOMER OPTION ORDERS THAT WERE ROUTED TO AND EXECUTED (OR PARTIALLY EXECUTED) ON CBOE; AND (IV) FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF CBOE RULE 15.1; AND SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER, IN CONNECTION WITH THE CONDUCT DESCRIBED. VIOLATION OF EXCHANGE RULES 4.2, 4.24 AND 15.1; SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED AND RULE 17A-3, THEREUNDER. SANCTION: A CENSURE AND A MONETARY FINE OF $27,000. Initiated By: CBOE EXCHANGE, INC. Date Initiated: 10/18/2019 Docket/Case Number: USE-1710 / STAR NO. 20160487713

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: 10/18/2019 Sanctions Ordered: Censure Monetary/Fine $27,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $27,000 i Disclosure 23 of 336 Reporting Source: Regulator Current Status: Final Allegations: CFTC ADMIN RELEASE CFTC DOCKET NO. 19-47 / SEPTEMBER 30, 2019: THE COMMODITY FUTURES TRADING COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE INSTITUTED AGAINST RBC CAPITAL MARKETS, LLC ("RBCCM" OR "RESPONDENT"). ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT DURING THE RELEVANT PERIOD, RBCCM, A REGISTERED FUTURES COMMISSION MERCHANT ("FCM"), FAILED TO SUPERVISE ITS FCM ACTIVITIES IN VIOLATION OF CFTC REGULATION. RBCCM'S SUPERVISION FAILURES RESULTED IN HUNDREDS OF TRADES THAT VIOLATED THE ACT AND REGULATIONS, IN ADDITION TO OTHER VIOLATIONS. BETWEEN DECEMBER 2011 AND OCTOBER 2015, RBCCM ENGAGED IN AT LEAST 385 NONCOMPETITIVE, FICTITIOUS, WASH SALE TRANSACTIONS KNOWN AS EXCHANGE FOR PHYSICAL ("EFP") TRANSACTIONS ("WASH EFPS"), IN VIOLATION OF THE CFTC'S ACT AND REGULATIONS. NOTABLY, 217 OF THOSE WASH EFPS OCCURRED AFTER ENTRY OF A CONSENT ORDER IN DECEMBER 2014, WHICH RESOLVED A CFTC ENFORCEMENT ACTION AGAINST RBCCM' S PARENT, THE ROYAL BANK OF CANADA ("RBC"), FOR WASH AND FICTITIOUS TRANSACTIONS ("CONSENT ORDER"). IN ADDITION, RBCCM'S SUPERVISION FAILURES RESULTED IN ADDITIONAL VIOLATIONS, INCLUDING: (1) FAILURES TO PREPARE, PRESENT, AND TIMELY FILE QUARTERLY RISK EXPOSURE REPORTS ("RER") AS REQUIRED ON FIVE OCCASIONS BETWEEN OCTOBER 2014 AND DECEMBER 2016; (2) FAILURE TO DISCLOSE RBCCM'S ©2021 FINRA. All rights reserved. Report aboutVIOLATIONS RBC CAPITAL AS MARKETS, MATERIAL LLC ISSUES OF NON-COMPLIANCE, AND MISSTATING 83 THE STATUS AND EFFECTIVENESS OF RBCCM'S RISK MANAGEMENT PROGRAM ("RMP") IN ITS CHIEF COMPLIANCE OFFICER ("CCO") REPORTS AS REQUIRED; AND (3) FAILING TO MAINTAIN AND TIMELY PRODUCE REQUIRED RECORDS. BASED ON THE FOREGOING, THE COMMISSION FINDS THAT RBCCM VIOLATED SECTIONS 4C(A) AND 4G OF THE ACT, 7 U.S.C. 6C(A), 6G (2012), AND REGULATIONS 1.11(E), 1.31, 1.35, 1.38, 3.3(E), AND 166.3, 17 C.F.R. 1.11(E), 1.31, 1.35, 1.38, 3.3(E), 166.3 (2018). CFTC ADMIN RELEASE CFTC DOCKET NO. 19-47 / SEPTEMBER 30, 2019: THE COMMODITY FUTURES TRADING COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE INSTITUTED AGAINST RBC CAPITAL MARKETS, LLC ("RBCCM" OR "RESPONDENT"). ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT DURING THE RELEVANT PERIOD, RBCCM, A REGISTERED FUTURES COMMISSION MERCHANT ("FCM"), FAILED TO SUPERVISE ITS FCM ACTIVITIES IN VIOLATION OF CFTC REGULATION. RBCCM'S SUPERVISION FAILURES RESULTED IN HUNDREDS OF TRADES THAT VIOLATED THE ACT AND REGULATIONS, IN ADDITION TO OTHER VIOLATIONS. BETWEEN DECEMBER 2011 AND OCTOBER 2015, RBCCM ENGAGED IN AT LEAST 385 NONCOMPETITIVE, FICTITIOUS, WASH SALE TRANSACTIONS KNOWN AS EXCHANGE FOR PHYSICAL ("EFP") TRANSACTIONS ("WASH EFPS"), IN VIOLATION OF THE CFTC'S ACT AND REGULATIONS. NOTABLY, 217 OF THOSE WASH EFPS OCCURRED AFTER ENTRY OF A CONSENT ORDER IN DECEMBER 2014, WHICH RESOLVED A CFTC ENFORCEMENT ACTION AGAINST RBCCM' S PARENT, THE ROYAL BANK OF CANADA ("RBC"), FOR WASH AND FICTITIOUS TRANSACTIONS ("CONSENT ORDER"). IN ADDITION, RBCCM'S SUPERVISION FAILURES www.finra.org/brokercheck RESULTED IN ADDITIONAL VIOLATIONS, INCLUDING: (1) FAILURES TO User Guidance PREPARE, PRESENT, AND TIMELY FILE QUARTERLY RISK EXPOSURE REPORTS ("RER") AS REQUIRED ON FIVE OCCASIONS BETWEEN OCTOBER 2014 AND DECEMBER 2016; (2) FAILURE TO DISCLOSE RBCCM'S VIOLATIONS AS MATERIAL ISSUES OF NON-COMPLIANCE, AND MISSTATING THE STATUS AND EFFECTIVENESS OF RBCCM'S RISK MANAGEMENT PROGRAM ("RMP") IN ITS CHIEF COMPLIANCE OFFICER ("CCO") REPORTS AS REQUIRED; AND (3) FAILING TO MAINTAIN AND TIMELY PRODUCE REQUIRED RECORDS. BASED ON THE FOREGOING, THE COMMISSION FINDS THAT RBCCM VIOLATED SECTIONS 4C(A) AND 4G OF THE ACT, 7 U.S.C. 6C(A), 6G (2012), AND REGULATIONS 1.11(E), 1.31, 1.35, 1.38, 3.3(E), AND 166.3, 17 C.F.R. 1.11(E), 1.31, 1.35, 1.38, 3.3(E), 166.3 (2018). Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 09/30/2019 Docket/Case Number: 19-47

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

Resolution: Order Resolution Date: 09/30/2019 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 $5,000,000.00 Cease and Desist/Injunction Other Sanctions Ordered: CONDITIONS AND UNDERTAKINGS Sanction Details: RESPONDENT SHALL CEASE AND DESIST FROM VIOLATING SECTIONS 4C(A) AND 4G OF THE ACT, 7 U.S.C. 6C(A), 6G (2012), AND REGULATIONS 1.11(E), 1.31, 1.35, 1.38, 3.3(E), AND 166.3, 17 C.F.R. 1.11(E), 1.31, 1.35, 1.38, 3.3(E), 166.3 (2018). RESPONDENT SHALL PAY A CIVIL MONETARY PENALTY FOR $5,000,000. RBCCM AND ITS SUCCESSORS AND ASSIGNS SHALL COMPLY WITH THE CONDITIONS AND UNDERTAKINGS SET FORTH IN ITS OFFER. Regulator Statement RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE OFFER) WHICH UPON CONSIDERATION, THE COMMISSION HAS DETERMINED TO ACCEPT THE OFFER. ©2021 FINRA. All rights reserved. Report aboutACCORDINGLY, RBC CAPITAL MARKETS, IT IS ORDERED LLC THAT RESPONDENT SHALL CEASE AND 84 DESIST FROM VIOLATING SECTIONS 4C(A) AND 4G OF THE ACT, 7 U.S.C. 6C(A), 6G (2012), AND REGULATIONS 1.11(E), 1.31, 1.35, 1.38, 3.3(E), AND 166.3, 17 C.F.R. 1.11(E), 1.31, 1.35, 1.38, 3.3(E), 166.3 (2018). RESPONDENT SHALL PAY A CIVIL MONETARY PENALTY FOR $5,000,000. RBCCM AND ITS SUCCESSORS AND ASSIGNS SHALL COMPLY WITH THE CONDITIONS AND UNDERTAKINGS SET FORTH IN ITS OFFER. www.finra.org/brokercheck User Guidance RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE OFFER) WHICH UPON CONSIDERATION, THE COMMISSION HAS DETERMINED TO ACCEPT THE OFFER. ACCORDINGLY, IT IS ORDERED THAT RESPONDENT SHALL CEASE AND DESIST FROM VIOLATING SECTIONS 4C(A) AND 4G OF THE ACT, 7 U.S.C. 6C(A), 6G (2012), AND REGULATIONS 1.11(E), 1.31, 1.35, 1.38, 3.3(E), AND 166.3, 17 C.F.R. 1.11(E), 1.31, 1.35, 1.38, 3.3(E), 166.3 (2018). RESPONDENT SHALL PAY A CIVIL MONETARY PENALTY FOR $5,000,000. RBCCM AND ITS SUCCESSORS AND ASSIGNS SHALL COMPLY WITH THE CONDITIONS AND UNDERTAKINGS SET FORTH IN ITS OFFER. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT THE FIRM ENGAGED IN AT LEAST 385 NON- COMPETITIVE, FICTITIOUS WASH EXCHANGE-FOR-PHYSICAL TRANSACTIONS. IT IS FURTHER ALLEGED THAT THE FIRM FAILED TO MEET SUPERVISORY OBLIGATIONS, RESULTING IN ADDITIONAL VIOLATIONS INCLUDE FAILURES TO PREPARE AND TIMELY FILE QUARTERLY RISK EXPOSURE REPORTS, FAILURES TO DISCLOSE MATERIAL NON-COMPLIANCE ISSUES, AND FAILURES TO MAINTAIN AND TIMELY PRODUCE REQUIRED RECORDS. Initiated By: COMMODITY FUTURES TRADING COMMISSION Date Initiated: 09/30/2019 Docket/Case Number: 19-47

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

Resolution: Order Resolution Date: 09/30/2019 Sanctions Ordered: Monetary/Fine $5,000,000.00 Cease and Desist/Injunction Other Sanctions Ordered: FOR A PERIOD OF THREE YEARS, THE FIRM SHALL COOPERATE WITH THE COMMISSION IN ANY INVESTIGATION, CIVIL LITIGATION OR ADMINISTRATIVE MATTER RELATING TO THIS ORDER. Sanction Details: THE FIRM WAS CENSURED AND FINED $5,000,000.00

i Disclosure 24 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC (I) SUBMITTED ORDERS WITH THE INCORRECT ORIGIN CODE OF "C" (INSTEAD OF "F") TO THE CLEARING CORPORATION, RESULTING IN THE EXECUTION OF APPROXIMATELY 6,501 CONTRACTS ON C2 WITH AN INCORRECT ORIGIN CODE; (II) BY SUBMITTING ORDERS WITH INCORRECT ORDER ORIGIN CODES RESULTING IN THE EXECUTION OF APPROXIMATELY 6,501 CONTRACTS ON C2 WITH AN INCORRECT ORIGIN CODE, FAILED TO MAKE AND MAINTAIN ACCURATE BOOKS AND RECORDS; (III) FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES RELATED TO ORIGIN CODE MARKING AND EXECUTION, IN THAT RBC FAILED TO DETECT THE ABOVE CONDUCT, NOTWITHSTANDING THE SUPERVISORY REPORTS AND PROCESSES THAT THE FIRM HAD ESTABLISHED; (IV) FAILED TO SUPERVISE ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH C2 RULES 4.2, 4.22, 6.38 AND 15.1; AND SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER, AS SUCH RULES RELATE TO ORIGIN CODE MARKING AND EXECUTION. VIOLATION OF EXCHANGE RULES 4.2, 4.22, 4.24, 6.38 AND 15.1; SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED AND RULE 17A-3 THEREUNDER. SANCTION: A CENSURE AND A MONETARY FINE OF $5,984. Initiated By: CBOE C2 EXCHANGE, INC. Date Initiated: 08/22/2019 Docket/Case Number: USRI-7935 / STAR NO. 20160509336

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: 08/28/2019 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about RBC CAPITAL MARKETS, LLC 86 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 $5,984.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE OF $5,984 i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MAKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITON TO THE FOREGOING, FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. Initiated By: CBOE C2 EXCHANGE, INC. Date Initiated: 08/22/2019 Docket/Case Number: USRI-7935 / STAR NO. 20160509336

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: 08/28/2019 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine RBC CAPITAL $5,984.00 MARKETS, LLC 87 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $5,984.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE OF $5,984 i Disclosure 25 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. EACH INSTANCE IN WHICH THE FIRM EXECUTED AN ORDER WITH AN INCORRECT ORIGIN CODE POTENTIALLY HAD ADVERSE CONSEQUENCES, SUCH AS INADVERTENTLY IMPACTING THE PRIORITY OF ORDER EXECUTION, CREATING INACCURATE RECORDS OF PURCHASES AND SALES, CREATING AN INACCURATE AUDIT TRAIL, REPORTING TRADES TO THE OPTIONS CLEARING CORPORATION (OCC) WITH INACCURATE TRADE DETAILS, AND IMPEDING THE EXCHANGE'S ABILITY TO SURVEIL FOR AND DETECT POTENTIAL VIOLATIONS OF ITS RULES AND FEDERAL SECURITIES LAWS.

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/02/2019 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 $6,721.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $6,721 IS PAYABLE TO THE EXCHANGE. THE REMAINING BALANCE IS TO BE PAID TO OTHER SELF-REGULATORY ORGANIZATIONS IN RELATED SETTLEMENT AGREEMENTS BETWEEN THE FIRM AND THESE SELF- REGULATORY ORGANIZATIONS. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MAKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITON TO THE FOREGOING, FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. Initiated By: NASDAQ ISE, LLC Date Initiated: 10/02/2019 Docket/Case Number: 2016050933604 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 89 www.finra.org/brokercheck User Guidance

Docket/Case Number: 2016050933604

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/02/2019 Sanctions Ordered: Censure Monetary/Fine $6,721.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $6,721 IS PAYABLE TO THE EXCHANGE. THE REMAINING BALANCE IS TO BE PAID TO OTHER SELF-REGULATORY ORGANIZATIONS IN RELATED SETTLEMENT AGREEMENTS BETWEEN THE FIRM AND THESE SELF- REGULATORY ORGANIZATIONS. i Disclosure 26 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC (I) SUBMITTED ORDERS WITH THE INCORRECT ORIGIN CODE OF "C" (INSTEAD OF "F") TO THE CLEARING CORPORATION, RESULTING IN THE EXECUTION OF APPROXIMATELY 39,756 CONTRACTS ON CBOE WITH AN INCORRECT ORIGIN CODE; (II) BY SUBMITTING ORDERS WITH INCORRECT ORDER ORIGIN CODES RESULTING IN THE EXECUTION OF APPROXIMATELY 39,756 CONTRACTS ON CBOE WITH AN INCORRECT ORIGIN CODE, FAILED TO MAKE AND MAINTAIN ACCURATE BOOKS AND RECORDS; (III) FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES RELATED TO ORIGIN CODE MARKING AND EXECUTION, IN THAT RBC FAILED TO DETECT THE CONDUCT DESCRIBED ABOVE IN A TIMELY MANNER, NOTWITHSTANDING THE SUPERVISORY REPORTS AND PROCESSES THAT THE FIRM HAD ESTABLISHED. IN ADDITION, RBC FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES, IN THAT RBC FAILED CONDUCT ITS MONTHLY SUPERVISORY REVIEWS IN A TIMELY MANNER IN ELEVEN OUT OF TWELVE MONTHS IN 2018; AND (IV) FAILED TO SUPERVISE ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH CBOE RULES 4.2, ©2021 FINRA. All rights reserved. Report about4.22, RBC 6.51 CAPITAL AND 15.1; MARKETS, AND LLC SECTION 17(A) OF THE EXCHANGE ACT AND RULE 90 17A-3 THEREUNDER, IN CONJUNCTION WITH THE CONDUCT DESCRIBED ABOVE. VIOLATION OF EXCHANGE RULES 4.2, 4.22, 4.24, 6.51 AND 15.1; SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED AND RULE 17A-3 THEREUNDER. SANCTION: A CENSURE AND A MONETARY FINE OF $36,592. RBC CAPITAL MARKETS, LLC (I) SUBMITTED ORDERS WITH THE INCORRECT ORIGIN CODE OF "C" (INSTEAD OF "F") TO THE CLEARING CORPORATION, RESULTING IN THE EXECUTION OF APPROXIMATELY 39,756 CONTRACTS ON CBOE WITH AN INCORRECT ORIGIN CODE; (II) BY SUBMITTING ORDERS WITH INCORRECT ORDER ORIGIN CODES RESULTING IN THE EXECUTION OF APPROXIMATELY 39,756 CONTRACTS ON CBOE WITH AN INCORRECT ORIGIN CODE, FAILED TO MAKE AND MAINTAIN ACCURATE BOOKS AND RECORDS; (III) FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES RELATED TO ORIGIN CODE MARKING AND EXECUTION, IN THAT RBC FAILED TO DETECT THE CONDUCT DESCRIBED ABOVE IN A TIMELY MANNER, NOTWITHSTANDING THE SUPERVISORY REPORTS AND PROCESSES THAT THE FIRM HAD ESTABLISHED. IN ADDITION, RBC FAILED TO ENFORCE ITS WRITTEN www.finra.org/brokercheck SUPERVISORY PROCEDURES, IN THAT RBC FAILED CONDUCT ITS User Guidance MONTHLY SUPERVISORY REVIEWS IN A TIMELY MANNER IN ELEVEN OUT OF TWELVE MONTHS IN 2018; AND (IV) FAILED TO SUPERVISE ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH CBOE RULES 4.2, 4.22, 6.51 AND 15.1; AND SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER, IN CONJUNCTION WITH THE CONDUCT DESCRIBED ABOVE. VIOLATION OF EXCHANGE RULES 4.2, 4.22, 4.24, 6.51 AND 15.1; SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED AND RULE 17A-3 THEREUNDER. SANCTION: A CENSURE AND A MONETARY FINE OF $36,592. Initiated By: CBOE EXCHANGE, INC. Date Initiated: 08/22/2019 Docket/Case Number: USRI-7935 / STAR NO. 20160509336

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: 08/28/2019 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 $36,592.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE OF $36,592 i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MAKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. THE FINDINGS STATED THAT ©2021 FINRA. All rights reserved. Report aboutTHE RBC FIRM CAPITAL IGNORED MARKETS, RED LLC FLAGS AND FAILED TO REMEDY THE PATTERN OF 91 ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITON TO THE FOREGOING, FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MAKETS, www.finra.org/brokercheck LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE User Guidance ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITON TO THE FOREGOING, FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. Initiated By: CBOE EXCHANGE, INC. Date Initiated: 08/22/2019 Docket/Case Number: USRI-7935 / STAR NO. 20160509336

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: 08/28/2019 Sanctions Ordered: Censure Monetary/Fine $36,592.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A MONETARY FINE OF $36,592 i Disclosure 27 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. EACH INSTANCE IN WHICH THE FIRM EXECUTED AN ORDER WITH AN INCORRECT ORIGIN CODE POTENTIALLY HAD ADVERSE CONSEQUENCES, SUCH AS INADVERTENTLY IMPACTING THE PRIORITY OF ORDER EXECUTION, CREATING INACCURATE RECORDS OF PURCHASES AND SALES, CREATING AN INACCURATE AUDIT TRAIL, REPORTING TRADES TO THE OPTIONS CLEARING CORPORATION (OCC) WITH INACCURATE TRADE DETAILS, AND IMPEDING THE EXCHANGE'S ABILITY TO SURVEIL FOR AND DETECT ©2021 FINRA. All rights reserved. Report aboutPOTENTIAL RBC CAPITAL VIOLATIONS MARKETS, LLC OF ITS RULES AND FEDERAL SECURITIES LAWS. 92

THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITION TO THE FOREGOING, RBC'S WRITTEN SUPERVISORY PROCEDURES PROVIDED FOR A MONTHLY REVIEW OF A SAMPLE OF ORDERS TO VERIFY THAT ACCURATE ORIGIN CODES WERE PLACED ON ORDERS. FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. THE FIRM CONDUCTED THESE REVIEWS FROM FIVE TO FIFTY-THREE DAYS AFTER THE DUE DATE FOR THE REVIEWS. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. TO REMEDY THIS ISSUE, RBC MOVED RESPONSIBILITY FOR ITS ORIGIN CODE REVIEWS FROM SURVEILLANCE ANALYSTS TO THE FIRM'S REGULATORY SUPERVISORY GROUP WHERE REVIEWS WOULD BE CONDUCTED, BY PEOPLE WITH SUPERVISORY RESPONSIBILITY. WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. EACH INSTANCE IN WHICH THE FIRM EXECUTED AN ORDER WITH AN INCORRECT ORIGIN CODE POTENTIALLY HAD ADVERSE CONSEQUENCES, SUCH AS INADVERTENTLY www.finra.org/brokercheck IMPACTING THE PRIORITY OF ORDER EXECUTION, CREATING User Guidance INACCURATE RECORDS OF PURCHASES AND SALES, CREATING AN INACCURATE AUDIT TRAIL, REPORTING TRADES TO THE OPTIONS CLEARING CORPORATION (OCC) WITH INACCURATE TRADE DETAILS, AND IMPEDING THE EXCHANGE'S ABILITY TO SURVEIL FOR AND DETECT POTENTIAL VIOLATIONS OF ITS RULES AND FEDERAL SECURITIES LAWS.

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

Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $7,138 IS PAYABLE TO THE EXCHANGE. THE REMAINING BALANCE IS TO BE PAID TO OTHER SELF-REGULATORY ORGANIZATIONS IN RELATED SETTLEMENT AGREEMENTS BETWEEN THE FIRM AND THESE SELF- REGULATORY ORGANIZATIONS. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MAKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITON TO THE FOREGOING, FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. Initiated By: NASDAQ PHLX LLC Date Initiated: 10/02/2019 Docket/Case Number: 2016050933606

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/02/2019 Sanctions Ordered: Censure Monetary/Fine $7,138.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $7,138 IS PAYABLE TO THE EXCHANGE. THE REMAINING BALANCE IS TO BE PAID TO OTHER SELF-REGULATORY ORGANIZATIONS IN RELATED SETTLEMENT AGREEMENTS BETWEEN THE FIRM AND THESE SELF- REGULATORY ORGANIZATIONS. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 94 www.finra.org/brokercheck THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH User Guidance $7,138 IS PAYABLE TO THE EXCHANGE. THE REMAINING BALANCE IS TO BE PAID TO OTHER SELF-REGULATORY ORGANIZATIONS IN RELATED SETTLEMENT AGREEMENTS BETWEEN THE FIRM AND THESE SELF- REGULATORY ORGANIZATIONS. i Disclosure 28 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. EACH INSTANCE IN WHICH THE FIRM EXECUTED AN ORDER WITH AN INCORRECT ORIGIN CODE POTENTIALLY HAD ADVERSE CONSEQUENCES, SUCH AS INADVERTENTLY IMPACTING THE PRIORITY OF ORDER EXECUTION, CREATING INACCURATE RECORDS OF PURCHASES AND SALES, CREATING AN INACCURATE AUDIT TRAIL, REPORTING TRADES TO THE OPTIONS CLEARING CORPORATION (OCC) WITH INACCURATE TRADE DETAILS, AND IMPEDING THE EXCHANGE'S ABILITY TO SURVEIL FOR AND DETECT POTENTIAL VIOLATIONS OF ITS RULES AND FEDERAL SECURITIES LAWS.

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Other Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 95 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/02/2019 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 $5,687.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $5,687 IS PAYABLE TO THE EXCHANGE. THE REMAINING BALANCE IS TO BE PAID TO OTHER SELF-REGULATORY ORGANIZATIONS IN RELATED SETTLEMENT AGREEMENTS BETWEEN THE FIRM AND THESE SELF- REGULATORY ORGANIZATIONS. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MAKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITON TO THE FOREGOING, FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. Initiated By: NASDAQ STOCK MARKET -THE NASDAQ OPTIONS MARKET Date Initiated: 10/02/2019 Docket/Case Number: 2016050933605

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: 10/02/2019 Sanctions Ordered: Censure Monetary/Fine $5,687.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $5,687 IS PAYABLE TO THE EXCHANGE. THE REMAINING BALANCE IS TO BE PAID TO OTHER SELF-REGULATORY ORGANIZATIONS IN RELATED SETTLEMENT AGREEMENTS BETWEEN THE FIRM AND THESE SELF- REGULATORY ORGANIZATIONS. i Disclosure 29 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. EACH INSTANCE IN WHICH THE FIRM EXECUTED AN ORDER WITH AN INCORRECT ORIGIN CODE POTENTIALLY HAD ADVERSE CONSEQUENCES, SUCH AS INADVERTENTLY IMPACTING THE PRIORITY OF ORDER EXECUTION. AS WELL AS, ADVERSE CONSEQUENCES, SUCH AS CREATING INACCURATE RECORDS OF PURCHASES AND SALES, CREATING AN INACCURATE AUDIT TRAIL, REPORTING TRADES TO THE OPTIONS CLEARING CORPORATION (OCC) WITH INACCURATE TRADE DETAILS, AND IMPEDING THE EXCHANGE'S ABILITY TO SURVEIL FOR AND DETECT POTENTIAL VIOLATIONS OF ITS RULES AND FEDERAL SECURITIES LAWS.

THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITION TO THE FOREGOING, RBC'S WRITTEN SUPERVISORY PROCEDURES PROVIDED FOR A MONTHLY REVIEW OF A SAMPLE OF ORDERS TO VERIFY THAT ACCURATE ORIGIN CODES WERE PLACED ON ORDERS. FOR THE CALENDAR YEAR 2018, RBC ©2021 FINRA. All rights reserved. Report aboutCONDUCTED RBC CAPITAL ELEVEN MARKETS, OF LLC TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. 97 THE FIRM CONDUCTED THESE REVIEWS FROM FIVE TO 53 DAYS AFTER THE DUE DATE FOR THE REVIEWS. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. TO REMEDY THIS ISSUE, RBC MOVED RESPONSIBILITY FOR ITS ORIGIN CODE REVIEWS TO ANOTHER GROUP RESPONSIBLE FOR CONDUCTING REVIEWS. WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. EACH INSTANCE IN WHICH THE FIRM EXECUTED AN ORDER WITH AN INCORRECT ORIGIN CODE POTENTIALLY HAD ADVERSE CONSEQUENCES, SUCH AS INADVERTENTLY IMPACTING THE PRIORITY OF ORDER EXECUTION. AS WELL AS, ADVERSE CONSEQUENCES, SUCH AS CREATING INACCURATE RECORDS OF PURCHASES AND SALES, CREATING AN INACCURATE AUDIT TRAIL, REPORTING TRADES TO THE OPTIONS CLEARING CORPORATION (OCC) WITH INACCURATE TRADE DETAILS, AND IMPEDING THE EXCHANGE'S ABILITY TO SURVEIL FOR AND DETECT POTENTIAL VIOLATIONS OF ITS RULES AND FEDERAL SECURITIES LAWS.

THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED www.finra.org/brokercheck TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH User Guidance INCORRECT ORIGIN CODES. IN ADDITION TO THE FOREGOING, RBC'S WRITTEN SUPERVISORY PROCEDURES PROVIDED FOR A MONTHLY REVIEW OF A SAMPLE OF ORDERS TO VERIFY THAT ACCURATE ORIGIN CODES WERE PLACED ON ORDERS. FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. THE FIRM CONDUCTED THESE REVIEWS FROM FIVE TO 53 DAYS AFTER THE DUE DATE FOR THE REVIEWS. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. TO REMEDY THIS ISSUE, RBC MOVED RESPONSIBILITY FOR ITS ORIGIN CODE REVIEWS TO ANOTHER GROUP RESPONSIBLE FOR CONDUCTING REVIEWS. Initiated By: NYSE AMERICAN LLC Date Initiated: 09/30/2019 Docket/Case Number: 2016050933607

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/30/2019 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 $4,098.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $4,098 IS PAYABLE TO THE EXCHANGE. THE REMAINING BALANCE IS TO BE PAID TO OTHER SELF-REGULATORY ORGANIZATIONS IN RELATED SETTLEMENT AGREEMENTS BETWEEN THE FIRM AND THESE SELF- REGULATORY ORGANIZATIONS. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MAKETS, ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 98 LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITON TO THE FOREGOING, FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. www.finra.org/brokercheck User Guidance

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MAKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITON TO THE FOREGOING, FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. Initiated By: NYSE AMERICAN LLC Date Initiated: 09/30/2019 Docket/Case Number: 2016050933607

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/30/2019 Sanctions Ordered: Censure Monetary/Fine $4,098.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $4,098 IS PAYABLE TO THE EXCHANGE. THE REMAINING BALANCE IS TO BE PAID TO OTHER SELF-REGULATORY ORGANIZATIONS IN RELATED SETTLEMENT AGREEMENTS BETWEEN THE FIRM AND THESE SELF- REGULATORY ORGANIZATIONS. i Disclosure 30 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS ©2021 FINRA. All rights reserved. Report aboutWITH RBC INCORRECT CAPITAL MARKETS, ORIGIN LLC CODES, INDICATING THAT THE ORDERS WERE 99 FOR CUSTOMERS INSTEAD OF THE FIRM. EACH INSTANCE IN WHICH THE FIRM EXECUTED AN ORDER WITH AN INCORRECT ORIGIN CODE POTENTIALLY HAD ADVERSE CONSEQUENCES, SUCH AS CREATING INACCURATE RECORDS OF PURCHASES AND SALES, CREATING AN INACCURATE AUDIT TRAIL, REPORTING TRADES TO THE OPTIONS CLEARING CORPORATION (OCC) WITH INACCURATE TRADE DETAILS, AND IMPEDING THE EXCHANGE'S ABILITY TO SURVEIL FOR AND DETECT POTENTIAL VIOLATIONS OF ITS RULES AND FEDERAL SECURITIES LAWS.

WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. EACH INSTANCE IN WHICH THE FIRM EXECUTED AN ORDER WITH AN INCORRECT ORIGIN CODE POTENTIALLY HAD ADVERSE CONSEQUENCES, SUCH AS CREATING INACCURATE RECORDS OF PURCHASES AND SALES, CREATING AN INACCURATE AUDIT TRAIL, REPORTING TRADES TO THE OPTIONS CLEARING CORPORATION (OCC) WITH INACCURATE TRADE DETAILS, AND IMPEDING THE EXCHANGE'S ABILITY TO SURVEIL FOR AND DETECT POTENTIAL VIOLATIONS OF ITS RULES AND FEDERAL SECURITIES LAWS.

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/30/2019 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or ©2021deceptive FINRA. conduct? All rights reserved. Report about RBC CAPITAL MARKETS, LLC 100 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 $5,509.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $5,509 IS PAYABLE TO THE EXCHANGE. THE REMAINING BALANCE IS TO BE PAID TO OTHER SELF-REGULATORY ORGANIZATIONS IN RELATED SETTLEMENT AGREEMENTS BETWEEN THE FIRM AND THESE SELF- REGULATORY ORGANIZATIONS. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MAKETS, LLC ("RBC" OR THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM ENTERED 670 PRINCIPAL ORDERS WITH INCORRECT ORIGIN CODES, INDICATING THAT THE ORDERS WERE FOR CUSTOMERS INSTEAD OF THE FIRM. THE FINDINGS STATED THAT THE FIRM IGNORED RED FLAGS AND FAILED TO REMEDY THE PATTERN OF ENTERING AND EXECUTING ORDERS WITH INCORRECT ORIGIN CODES. IN ADDITON TO THE FOREGOING, FOR THE CALENDAR YEAR 2018, RBC CONDUCTED ELEVEN OF TWELVE MONTHLY ORIGIN CODE REVIEWS LATE. RBC FAILED TO ENFORCE ITS PROCEDURES REQUIRING TIMELY ORIGIN CODE REVIEWS. Initiated By: NYSE ARCA, INC. Date Initiated: 09/30/2019 Docket/Case Number: 2016050933608

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/30/2019 Sanctions Ordered: Censure Monetary/Fine $5,509.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $100,000, OF WHICH $5,509 IS PAYABLE TO THE EXCHANGE. THE REMAINING BALANCE IS TO BE PAID TO OTHER SELF-REGULATORY ORGANIZATIONS IN RELATED SETTLEMENT AGREEMENTS BETWEEN THE FIRM AND THESE SELF- REGULATORY ORGANIZATIONS. i Disclosure 31 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC (THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30). THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. Initiated By: CBOE EDGA EXCHANGE, INC. Date Initiated: 04/08/2019 Docket/Case Number: 2017055792103

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

Resolution Date: 05/07/2019 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 $3,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $30,000 TO BE PAID JOINTLY, OF WHICH $3,000 WAS ALLOCATED TO THE EXCHANGE. THE FIRM WAS ALSO REQUIRED TO REVISE ITS SUPERVISORY PROCEDURES TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING INTERMARKET SWEEP ORDERS (ISOS) THAT COMPLIED WITH THE SEC'S REGULATION NMS.

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/07/2019 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED A TOTAL OF $30,000 TO BE PAID JOINTLY, OF WHICH $3,000 WAS ALLOCATED TO THE EXCHANGE. THE FIRM WAS ALSO REQUIRED TO REVISE ITS SUPERVISORY PROCEDURES TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING INTERMARKET SWEEP ORDERS (ISOS) THAT COMPLIED WITH THE SEC'S REGULATION NMS. THIS MATTER WILL BECOME FINAL MAY 7, 2019. i Disclosure 32 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC (THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30). THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. Initiated By: CBOE BZX EXCHANGE, INC. Date Initiated: 04/08/2019 Docket/Case Number: 2017055792102

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/07/2019 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 $15,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $30,000 TO BE PAID JOINTLY, OF WHICH $15,000 WAS ALLOCATED TO THE EXCHANGE. THE FIRM WAS ALSO REQUIRED TO REVISE ITS SUPERVISORY PROCEDURES TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING INTERMARKET SWEEP ORDERS (ISOS) THAT COMPLIED WITH THE SEC'S REGULATION NMS.

THIS MATTER BECAME FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THIS DECISION. THEREFORE, THIS MATTER BECAME FINAL MAY 7, 2019. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30) LEADING TO CONDUCT IN VIOLATION OF RULE 611(C). THE FINDINGS STATE THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND ©2021 FINRA. All rights reserved. Report aboutREGULATIONS, RBC CAPITAL MARKETS, AND THE LLC RULES OF THE EXCHANGE, CONCERNING ISOS 105 THAT COMPLIED WITH THE SEC'S REGULATION NMS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE www.finra.org/brokercheck DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE User Guidance 600(B)(30) LEADING TO CONDUCT IN VIOLATION OF RULE 611(C). THE FINDINGS STATE THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. Initiated By: CBOE BZX EXCHANGE, INC Date Initiated: 04/08/2019 Docket/Case Number: 2017055792102

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/07/2019 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED A TOTAL OF $30,000 TO BE PAID JOINTLY, OF WHICH $15,000 WAS ALLOCATED TO THE EXCHANGE. THE FIRM WAS ALSO REQUIRED TO REVISE ITS SUPERVISORY PROCEDURES TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING INTERMARKET SWEEP ORDERS (ISOS) THAT COMPLIED WITH THE SEC'S REGULATION NMS. THIS MATTER WILL BECOME FINAL MAY 7, 2019. i Disclosure 33 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC (THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30). THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO ©2021 FINRA. All rights reserved. Report aboutTHE RBC APPLICABLE CAPITAL MARKETS, SECURITIES LLC LAWS AND REGULATIONS, AND THE RULES 106 OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS, LLC (THE "FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO www.finra.org/brokercheck ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) User Guidance IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30). THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. Initiated By: CBOE EDGX EXCHANGE, INC. Date Initiated: 04/08/2019 Docket/Case Number: 2017055792101

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/07/2019 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 $12,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED AND FINED A TOTAL OF $30,000 TO BE PAID JOINTLY, OF WHICH $12,000 WAS ALLOCATED TO THE EXCHANGE. THE FIRM WAS ALSO REQUIRED TO REVISE ITS SUPERVISORY PROCEDURES TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING INTERMARKET SWEEP ORDERS (ISOS) THAT COMPLIED WITH THE SEC'S REGULATION NMS.

THIS MATTER BECAME FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THIS DECISION. THEREFORE, THIS MATTER BECAME FINAL MAY 7, 2019. i Reporting Source: Firm

Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30) LEADING TO CONDUCT IN VIOLATION OF RULE 611(C). THE FINDINGS STATE THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. Initiated By: CBOE EDGX EXCHANGE, INC. Date Initiated: 04/08/2019 Docket/Case Number: 2017055792101

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/07/2019 Sanctions Ordered: Censure Monetary/Fine $12,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED A TOTAL OF $30,000 TO BE PAID JOINTLY, OF WHICH $12,000 WAS ALLOCATED TO THE EXCHANGE. THE FIRM WAS ALSO REQUIRED TO REVISE ITS SUPERVISORY PROCEDURES TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING INTERMARKET SWEEP ORDERS (ISOS) THAT COMPLIED WITH THE SEC'S REGULATION NMS. THIS MATTER WILL BECOME FINAL MAY 7, 2019. i Disclosure 34 of 336

Reporting Source: Regulator Current Status: Final Allegations: IA RELEASE 40-5198, MARCH 11, 2019: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST RBC CAPITAL MARKETS, LLC ("RESPONDENT"). ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THE RESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE FEES IT RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENT RECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 03/11/2019 Docket/Case Number: 3-19101

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

Resolution: Order Resolution Date: 03/11/2019 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 RBC CAPITAL MARKETS, LLC 109 www.finra.org/brokercheck User Guidance

RESPONDENT SELF-REPORTED TO THE COMMISSION THE VIOLATIONS DISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE ("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENT'S OFFER ARE BASED ON THE INFORMATION SELF-REPORTED BY RESPONDENT. i Reporting Source: Firm Current Status: Final Allegations: THE SEC ALLEGED THAT RBCCM, DURING THE PERIOD JANUARY 1, 2014 THROUGH MARCH 27, 2017, FAILED TO MAKE ADEQUATE DISCLOSURES, IN ITS FORM ADV OR OTHERWISE, REGARDING ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES, AND THE 12B-1 FEES IT RECEIVED, IN CONNECTION WITH ADVISORY ACCOUNT TRANSACTIONS. SPECIFICALLY, AT TIMES DURING THE RELEVANT PERIOD, RBCCM PURCHASED, RECOMMENDED OR HELD IN ADVISORY ACCOUNTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES IN THE SAME FUND. THE SEC ALLEGED THAT RBCCM FAILED TO ADEQUATELY DISCLOSE THE RECEIPT OF THE 12B-1 FEES AND THE CONFLICT CREATED THEREBY, THEREBY ALLEGEDLY WILLFULLY VIOLATING SECTIONS 206(2) AND 207 OF THE INVESTMENT ADVISERS ACT. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 110 THE SEC ALLEGED THAT RBCCM, DURING THE PERIOD JANUARY 1, 2014 THROUGH MARCH 27, 2017, FAILED TO MAKE ADEQUATE DISCLOSURES, IN ITS FORM ADV OR OTHERWISE, REGARDING ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES, AND THE 12B-1 FEES IT RECEIVED, IN CONNECTION WITH ADVISORY ACCOUNT TRANSACTIONS. SPECIFICALLY, AT TIMES DURING THE RELEVANT PERIOD, RBCCM PURCHASED, RECOMMENDED OR HELD IN ADVISORY ACCOUNTS MUTUAL FUND SHARE www.finra.org/brokercheck CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE User Guidance CLASSES IN THE SAME FUND. THE SEC ALLEGED THAT RBCCM FAILED TO ADEQUATELY DISCLOSE THE RECEIPT OF THE 12B-1 FEES AND THE CONFLICT CREATED THEREBY, THEREBY ALLEGEDLY WILLFULLY VIOLATING SECTIONS 206(2) AND 207 OF THE INVESTMENT ADVISERS ACT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 03/11/2019 Docket/Case Number: 3-19101

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

Resolution: Order Resolution Date: 03/11/2019 Sanctions Ordered: Censure Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKINGS AND PREJUDGMENT INTEREST Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS THE FIRM SHALL CEASE FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $10,494,813.38 AND PREJUDGMENT INTEREST OF $1,220,581.34, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. Firm Statement THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER. RESPONDENT SELF-REPORTED TO THE COMMISSION THE VIOLATIONS DISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE ("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENT'S OFFER ARE BASED ON THE INFORMATION SELF-REPORTED BY RESPONDENT. i Disclosure 35 of 336 Reporting Source: Regulator

Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IMPLEMENT AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS AND REGULATIONS, INCLUDING SEC AND FINRA RULES, REGARDING THE CLOSE-OUT OF FAIL-TO-DELIVER POSITIONS. THE FINDINGS STATED THAT THE FIRM MISAPPLIED THE SEC'S REGULATORY GUIDANCE REGARDING THE MULTI-DAY APPROACH TO CALCULATING CREDIT TOWARD A CLOSE-OUT OBLIGATION WHEN ALLOCATING AND SUBSEQUENTLY TRACKING FAILS ON BEHALF OF ITS AFFILIATED CORRESPONDENT BROKER-DEALER FIRM. THIS RESULTED IN FAILS EXTENDING BEYOND THE TIME FRAME REQUIRED FOR BONA FIDE MARKET MAKING ACTIVITY. THE FINDINGS ALSO STATED THAT THE FIRM HAD A FAIL-TO-DELIVER POSITION AT A REGISTERED CLEARING AGENCY IN AN EQUITY SECURITY THAT WAS ATTRIBUTABLE TO MARKET MAKING ACTIVITIES, AND DID NOT CLOSE OUT THE FAIL-TO-DELIVER POSITIONS BY PURCHASING OR BORROWING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME PRESCRIBED BY SEC RULE 204(A)(3). THE FINDINGS ALSO INCLUDED THAT THE FIRM HAD A FAIL-TO-DELIVER POSITION AT A REGISTERED CLEARING AGENCY IN AN EQUITY SECURITY AND DID NOT CLOSE OUT THE FAIL-TO-DELIVER POSITIONS BY PURCHASING OR BORROWING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME PRESCRIBED BY SEC RULE 204(A). Initiated By: FINRA Date Initiated: 11/08/2018 Docket/Case Number: 2013039211801

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: 11/08/2018 Does the order constitute a No final order based on violations of any laws or regulations that prohibit ©2021fraudulent, FINRA. Allmanipulative, rights reserved. or Report about RBC CAPITAL MARKETS, LLC 112 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 $215,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $215,000. FINES PAID IN FULL ON NOVEMBER 28, 2018. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DURING THE PERIOD OF JANUARY 1, 2014 THROUGH APRIL 5, 2016, THE FIRM'S SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO ACCOUNT FOR THE MULTI-DAY APPROACH, WHICH IS UTILIZED TO CALCULATE CREDIT TOWARD THE FIRM'S CLOSE-OUT AND DELIVERY OBLIGATIONS. THE FIRM'S DEFICIENT SUPERVISORY SYSTEM ALLOWED NUMEROUS VIOLATIONS OF RULE 204 OF REGULATION SHO TO GO UNDETECTED.

THE FINDINGS ALSO PROVIDED THAT THE FIRM FAILED TO CLOSE OUT THE FAIL-TO-DELIVER POSITIONS IN ACCORDANCE WITH RULE 204 OF REGULATION SHO DURING THE PERIODS OF JUNE 1, 2013 THROUGH SEPTEMBER 30, 2013, OCTOBER 1, 2014 THROUGH DECEMBER 31, 2014, AND JANUARY 1, 2016 THROUGH JUNE 2, 2016.

THIRD, THE FINDINGS PROVIDED THAT THE FIRM HAD A FAIL-TO-DELIVER POSITION AT A REGISTERED CLEARING AGENCY IN AN EQUITY SECURITY AND DID NOT CLOSE OUT THE FAIL-TO-DELIVER POSITIONS BY PURCHASING OR BORROWING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME PRESCRIBED BY RULE 204(A) OF REGULATION SHO, AND FINRA RULE 2010.

THE DEPARTMENT OF ENFORCEMENT FOUND THAT THE FIRM VIOLATED NASD RULE 3010 (FOR CONDUCT PRIOR TO DECEMBER 1, 2014) AND FINRA RULE 3110 (FOR CONDUCT ON OR AFTER DECEMBER 1, 2014), RULE 204(A) OF REGULATION SHO OF THE EXCHANGE ACT, AND FINRA RULE 2010. Initiated By: FINRA ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 113 www.finra.org/brokercheck User Guidance

Initiated By: FINRA Date Initiated: 11/08/2018 Docket/Case Number: 2013039211801

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/08/2018 Sanctions Ordered: Censure Monetary/Fine $215,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDING, THE FIRM CONSENTED TO THE DESCRIBED SANCATIONS AND TO THE ENTRY OR FINDINGS; THEREFORE THE FIRM WAS CENSURED AND FINED $215,000. i Disclosure 36 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC: (I) ON TWO SETTLEMENT DATES, ENTERED SELL-SIDE STRATEGY ORDERS PRIOR TO THE 8:15 A.M. CUT-OFF TIME FOR PARTICIPATION IN THE SOQ AND SUBSEQUENTLY CHANGED ITS STRATEGY ORDERS THROUGH ITS SUBMISSION OF BUY-SIDE ORDERS AFTER THE 8:15 A.M. CUT-OFF TIME; (II) FAILED TO ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY PROCEDURES TO ASSURE COMPLIANCE WITH EXCHANGE RULE 6.2B; AND (III) FAILED TO SUPERVISE ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH EXCHANGE RULE 6.2B. VIOLATIONS OF EXCHANGE RULES 4.2 AND 6.2B. Initiated By: CBOE EXCHANGE, INC. Date Initiated: 06/21/2018 Docket/Case Number: 18-0012/ 20160498080

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: 08/30/2018 Sanctions Ordered: Censure Monetary/Fine $75,000.00 Other Sanctions Ordered: Sanction Details: A $75,000 FINE AND A CENSURE. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT ON TWO SETTLEMENT DATES THE FIRM ENTERED SELL-SIDE ORDERS PRIOR TO THE CUT-OFF TIME FOR PARTICIPATION IN THE SPECIAL OPENING QUOTATION AND SUBSEQUENTLY CHANGED ITS ORDERS THROUGH SUBMISSION OF BUY-SIDE ORDERS AFTER THE CUT- OFF TIME WHICH IS VIOLATION OF CBOE RULE 6.2B. IT WAS FURTHER ALLEGED THAT THE FIRM VIOLATED CBOE RULE 4.2 FOR FAILING TO SUPERVISE ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH EXCHANGE RULE 6.2B FOR FAILING TO ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY PROCEDURES FOR COMPLIANCE WITH EXCHANGE RULE 6.2B. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED Date Initiated: 06/21/2018 Docket/Case Number: 18-0012/20160498080

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: 08/30/2018 Sanctions Ordered: Censure Monetary/Fine $75,000.00 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 WAS FINED $75,000.00. i Disclosure 37 of 336 Reporting Source: Firm Current Status: Final Allegations: THE CLEARING HOUSE RISK COMMITTEE OF THE CHICAGO MERCHANTILE EXCHANGE ALLEGED THAT THE FIRM VIOLATED CME RULE 971.A.1. Initiated By: CHICAGO MERCANTILE EXCHANGE Date Initiated: 06/29/2018 Docket/Case Number: 18-CH-1804

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: Settled Resolution Date: 06/29/2018 Sanctions Ordered: 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 IT IS FINED $50,000. i Disclosure 38 of 336 Reporting Source: Firm

Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, IT WAS ALLEGED THAT THE FIRM VIOLATED CFE RULES 401A, 412B(A) AND 609. ON NUMEROUS DATES FROM MAY 2016 THROUGH MAY 2017, DUE TO A THIRD PARTY SERVICE PROVIDER PROGRAMMING ERROR AND A FAILURE TO FOLLOW ITS OWN WRITTEN PROCEDURES, THE FIRM REPORTED INACCURATE OPEN INTEREST IN VARIOUS VX WEEKLY CONTRACTS, RESULTING IN OVERSTATEMENTS OF OVERALL EXCHANGE OPEN INTEREST. IN ADDITION, ON NUMEROUS DATES BETWEEN DECEMBER 2016 AND AUGUST 2017, DUE TO A THIRD PARTY SERVICE PROVIDER INPUTTING INCORRECT REPORTABLE LEVELS AND A FAILURE TO FOLLOW ITS OWN WRITTEN PROCEDURES, THE FIRM FAILED TO REPORT LARGE TRADER POSITIONS IN VARIOUS VX WEEKLY CONTRACTS. Initiated By: CBOE FUTURES EXCHANGE, LLC Date Initiated: 06/13/2018 Docket/Case Number: 18-0002

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: 06/13/2018 Sanctions Ordered: 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 IT IS FINED $50,000.00. i Disclosure 39 of 336 Reporting Source: Regulator Current Status: Final Allegations: THE FIRM VIOLATED SECURITIES EXCHANGE ACT OF 1934 RULE 15C3- 5(C)(1)(II) (MARKET ACCESS RULE) BY FAILING TO ESTABLISH, DOCUMENT, AND MAINTAIN RISK MANAGEMENT CONTROLS AND SUPERVISORY ©2021 FINRA. All rights reserved. Report aboutPROCEDURES RBC CAPITAL THATMARKETS, WERE LLC REASONABLY DESIGNED TO PREVENT THE 117 ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME; AND NYSE ARCA EQUITIES RULES 6.18(B) AND (C), BY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY SYSTEMS AND WRITTEN PROCEDURES THAT WERE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH RULE 15C3-5. www.finra.org/brokercheck User Guidance

THE FIRM VIOLATED SECURITIES EXCHANGE ACT OF 1934 RULE 15C3- 5(C)(1)(II) (MARKET ACCESS RULE) BY FAILING TO ESTABLISH, DOCUMENT, AND MAINTAIN RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES THAT WERE REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME; AND NYSE ARCA EQUITIES RULES 6.18(B) AND (C), BY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY SYSTEMS AND WRITTEN PROCEDURES THAT WERE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH RULE 15C3-5. Initiated By: NYSE ARCA, INC. Date Initiated: 05/25/2018 Docket/Case Number: 2016-10-00034

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

Resolution: Decision & Order of Offer of Settlement Resolution Date: 05/25/2018 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 $25,000.00 Other Sanctions Ordered: UNDERTAKING: ADDRESS ANY REMAINING MARKET ACCESS RULE DEFICIENCIES DESCRIBED IN THIS DECISION TO ENSURE THAT THE FIRM HAS IMPLEMENTED CONTROLS AND PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES AND REGULATIONS CITED HEREIN PERTAINING TO MARKET ACCESS REQUIREMENTS. Sanction Details: THE FIRM AND NYSE ARCA, INC. ENTERED INTO AN OFFER OF SETTLEMENT AND CONSENT FOR THE SOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING, WITHOUT ADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS REFERRED TO IN THE OFFER OF SETTLEMENT. THE ©2021 FINRA. All rights reserved. Report aboutHEARING RBC CAPITAL OFFICER MARKETS, ACCEPTS LLC THE OFFER OF SETTLEMENT AND CONSENT 118 AND ISSUES THIS DECISION IN ACCORDANCE WITH NYSE ARCA RULES. THE FIRM WAS CENSURED, FINED $25,000, AND SHALL UNDERTAKE TO ADDRESS ANY REMAINING MARKET ACCESS RULE DEFICIENCIES DESCRIBED IN THIS DECISION TO ENSURE THAT IT HAS IMPLEMENTED CONTROLS AND PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES AND REGULATIONS CITED HEREIN PERTAINING TO MARKET ACCESS REQUIREMENTS. www.finra.org/brokercheck THE FIRM AND NYSE ARCA, INC. ENTERED INTO AN OFFER OF User Guidance SETTLEMENT AND CONSENT FOR THE SOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING, WITHOUT ADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS REFERRED TO IN THE OFFER OF SETTLEMENT. THE HEARING OFFICER ACCEPTS THE OFFER OF SETTLEMENT AND CONSENT AND ISSUES THIS DECISION IN ACCORDANCE WITH NYSE ARCA RULES. THE FIRM WAS CENSURED, FINED $25,000, AND SHALL UNDERTAKE TO ADDRESS ANY REMAINING MARKET ACCESS RULE DEFICIENCIES DESCRIBED IN THIS DECISION TO ENSURE THAT IT HAS IMPLEMENTED CONTROLS AND PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES AND REGULATIONS CITED HEREIN PERTAINING TO MARKET ACCESS REQUIREMENTS. Regulator Statement IN DETERMINING TO RESOLVE THIS MATTER ON THE BASIS SET FORTH HEREIN, ENFORCEMENT TOOK INTO CONSIDERATION THAT RBC CAPITAL COOPERATED IN NYSE REGULATION'S INVESTIGATION AND MODIFIED CONTROLS RELATING TO THE ENTRY OF ERRONEOUS ORDERS, INCLUDING PRE-MARKET ORDERS, AND MODIFIED ITS PROCESS FOR HANDLING THE SUBMISSION OF REQUESTS FOR REVIEW PURSUANT TO NYSE ARCA RULE 7.10-E DURING PRE-MARKET HOURS. THE FIRM HAS UNDERTAKEN TO ADDRESS ANY REMAINING DEFICIENCIES. i Reporting Source: Firm Current Status: Final Allegations: THE FIRM VIOLATED SECURITIES EXCHANGE ACT OF 1934 RULE 15C3- 5(C)(1)(II) (MARKET ACCESS RULE) BY FAILING TO ESTABLISH, DOCUMENT, AND MAINTAIN RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES THAT WERE REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME; AND NYSE ARCA EQUITIES RULES 6.18(B) AND (C), BY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY SYSTEMS AND WRITTEN PROCEDURES THAT WERE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH RULE 15C3-5. Initiated By: NYSE ARCA, INC. Date Initiated: 05/25/2018 Docket/Case Number: 2016-10-00034

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 CENSURE AND UNDERTAKING ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 119 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief CENSURE AND UNDERTAKING Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 05/25/2018 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Other Sanctions Ordered: UNDERTAKING: ADDRESS ANY REMAINING MARKET ACCESS RULE DEFICIENCIES DESCRIBED IN THIS DECISION TO ENSURE THAT THE FIRM HAS IMPLEMENTED CONTROLS AND PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES AND REGULATIONS CITED HEREIN PERTAINING TO MARKET ACCESS REQUIREMENTS. Sanction Details: THE FIRM AND NYSE ARCA, INC. ENTERED INTO AN OFFER OF SETTLEMENT AND CONSENT FOR THE SOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING, WITHOUT ADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS REFERRED TO IN THE OFFER OF SETTLEMENT. THE HEARING OFFICER ACCEPTS THE OFFER OF SETTLEMENT AND CONSENT AND ISSUES THIS DECISION IN ACCORDANCE WITH NYSE ARCA RULES. THE FIRM WAS CENSURED, FINED $25,000, AND SHALL UNDERTAKE TO ADDRESS ANY REMAINING MARKET ACCESS RULE DEFICIENCIES DESCRIBED IN THIS DECISION TO ENSURE THAT IT HAS IMPLEMENTED CONTROLS AND PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES AND REGULATIONS CITED HEREIN PERTAINING TO MARKET ACCESS REQUIREMENTS. Firm Statement IN DETERMINING TO RESOLVE THIS MATTER ON THE BASIS SET FORTH HEREIN, ENFORCEMENT TOOK INTO CONSIDERATION THAT THE FIRM COOPERATED IN NYSE REGULATION'S INVESTIGATION AND MODIFIED CONTROLS RELATING TO THE ENTRY OF ERRONEOUS ORDERS, INCLUDING PRE-MARKET ORDERS, AND MODIFIED ITS PROCESS FOR HANDLING THE SUBMISSION OF REQUESTS FOR REVIEW PURSUANT TO NYSE ARCA RULE 7.10-E DURING PRE-MARKET HOURS. THE FIRM HAS UNDERTAKEN TO ADDRESS ANY REMAINING DEFICIENCIES. i Disclosure 40 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DID NOT FOLLOW UP ON POSITION LIMIT OVERAGES AND FAILED TO PROMPTLY ©2021 FINRA. All rights reserved. Report aboutTAKE RBC THE CAPITAL ACTION MARKETS, NECESSARY LLC TO BRING A POSITION INTO COMPLIANCE. 120 THE FINDINGS STATED THAT A CORRESPONDENT FIRM, A CLIENT OF THE FIRM, EFFECTED OPENING TRANSACTIONS FOR THE ACCOUNT OF ITS CUSTOMER THAT EXCEEDED THE APPLICABLE POSITION LIMIT ON THE BULLISH SIDE OF THE MARKET IN A SECURITY, WHICH WAS 50,000 CONTRACTS, BY 5,676 CONTRACTS. THE NEXT DAY, THE CORRESPONDENT FIRM EXECUTED AN ADDITIONAL 500 CONTRACTS IN THE SECURITY FOR THE SAME CUSTOMER WHILE THE CUSTOMER'S POSITION IN THE SECURITY HAD ALREADY EXCEEDED THE POSITION LIMIT ON THE PREVIOUS TRADING DAY, WHICH FURTHER CAUSED THE APPLICABLE POSITION LIMIT TO BE EXCEEDED BY A TOTAL OF 6,176 CONTRACTS. THE FINDINGS ALSO STATED THAT THE FIRM MAINTAINED AND CLEARED THE OPTIONS POSITIONS IN THE SECURITY FOR THE CORRESPONDENT FIRM. DURING A BI-MONTHLY SURVEILLANCE REVIEW OF OPTIONS POSITIONS THAT THE FIRM CONDUCTED, IT IDENTIFIED THE POSITIONS IN THE SECURITY. HOWEVER, THE FIRM MISTOOK THE 5,000,000 SHARES POSITION LIMIT, WHICH IT HAD OBTAINED FROM THE WEBSITE OF THE OPTIONS CLEARING CORPORATION, AS CONTRACTS. THE 5,000,000 SHARES POSITION LIMIT IS EQUIVALENT TO THE 50,000 CONTRACTS POSITION LIMIT SINCE THE SHARES DELIVERABLE OF AN OPTIONS CONTRACT IS 100 SHARES. AS SUCH, THE FIRM CONSIDERED THE SUBJECT OPTIONS POSITION TO BE WITHIN THE POSITION LIMIT. AS A RESULT, THE FIRM DID NOT FOLLOW UP ON THESE POSITION LIMIT OVERAGES AND FAILED TO PROMPTLY TAKE THE ACTION NECESSARY TO BRING THE POSITION INTO COMPLIANCE. FURTHER, THE CORRESPONDENT FIRM ALSO FAILED TO BRING ITS CUSTOMER'S POSITION IN THE SECURITY INTO COMPLIANCE WITH THE APPLICABLE POSITION LIMIT. THE POSITION LIMIT IN A SECURITY WAS EXCEEDED FOR A TOTAL 16 CONSECUTIVE TRADING DAYS, WHICH RANGED FROM APPROXIMATELY 11 PERCENT TO 12 PERCENT OVER THE APPLICABLE LIMIT FOR THE SECURITY. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE NASDAQ OPTIONS MARKET LLC (NOM), CONCERNING POSITION LIMITS. SPECIFICALLY, THE FIRM ONLY CONDUCTED A BI-MONTHLY SURVEILLANCE REVIEW OF OPTIONS POSITIONS TO DETERMINE COMPLIANCE WITH POSITION LIMITS, AND IT FAILED TO DETECT THE POSITION LIMIT OVERAGES IN THE SECURITY WHEN THEY WERE REVIEWED. www.finra.org/brokercheck User Guidance

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DID NOT FOLLOW UP ON POSITION LIMIT OVERAGES AND FAILED TO PROMPTLY TAKE THE ACTION NECESSARY TO BRING A POSITION INTO COMPLIANCE. THE FINDINGS STATED THAT A CORRESPONDENT FIRM, A CLIENT OF THE FIRM, EFFECTED OPENING TRANSACTIONS FOR THE ACCOUNT OF ITS CUSTOMER THAT EXCEEDED THE APPLICABLE POSITION LIMIT ON THE BULLISH SIDE OF THE MARKET IN A SECURITY, WHICH WAS 50,000 CONTRACTS, BY 5,676 CONTRACTS. THE NEXT DAY, THE CORRESPONDENT FIRM EXECUTED AN ADDITIONAL 500 CONTRACTS IN THE SECURITY FOR THE SAME CUSTOMER WHILE THE CUSTOMER'S POSITION IN THE SECURITY HAD ALREADY EXCEEDED THE POSITION LIMIT ON THE PREVIOUS TRADING DAY, WHICH FURTHER CAUSED THE APPLICABLE POSITION LIMIT TO BE EXCEEDED BY A TOTAL OF 6,176 CONTRACTS. THE FINDINGS ALSO STATED THAT THE FIRM MAINTAINED AND CLEARED THE OPTIONS POSITIONS IN THE SECURITY FOR THE CORRESPONDENT FIRM. DURING A BI-MONTHLY SURVEILLANCE REVIEW OF OPTIONS POSITIONS THAT THE FIRM CONDUCTED, IT IDENTIFIED THE POSITIONS IN THE SECURITY. HOWEVER, THE FIRM MISTOOK THE 5,000,000 SHARES POSITION LIMIT, WHICH IT HAD OBTAINED FROM THE WEBSITE OF THE OPTIONS CLEARING CORPORATION, AS CONTRACTS. THE 5,000,000 SHARES POSITION LIMIT IS EQUIVALENT TO THE 50,000 CONTRACTS POSITION LIMIT SINCE THE SHARES DELIVERABLE OF AN OPTIONS CONTRACT IS 100 SHARES. AS SUCH, THE FIRM CONSIDERED THE SUBJECT OPTIONS POSITION TO BE WITHIN THE POSITION LIMIT. AS A RESULT, THE FIRM DID NOT FOLLOW UP ON THESE POSITION LIMIT OVERAGES AND FAILED TO PROMPTLY TAKE THE ACTION NECESSARY TO BRING THE POSITION INTO COMPLIANCE. FURTHER, THE CORRESPONDENT FIRM ALSO FAILED TO BRING ITS CUSTOMER'S POSITION IN THE SECURITY INTO COMPLIANCE WITH THE APPLICABLE POSITION LIMIT. THE POSITION LIMIT IN A SECURITY WAS EXCEEDED FOR A TOTAL 16 CONSECUTIVE TRADING DAYS, WHICH RANGED FROM APPROXIMATELY 11 PERCENT TO 12 PERCENT OVER THE APPLICABLE LIMIT FOR THE SECURITY. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE NASDAQ OPTIONS MARKET LLC (NOM), CONCERNING POSITION LIMITS. SPECIFICALLY, THE FIRM ONLY CONDUCTED A BI-MONTHLY SURVEILLANCE REVIEW OF OPTIONS POSITIONS TO DETERMINE COMPLIANCE WITH POSITION LIMITS, AND IT FAILED TO DETECT THE POSITION LIMIT OVERAGES IN THE SECURITY WHEN THEY WERE REVIEWED. Initiated By: NASDAQ STOCK MARKET Date Initiated: 05/09/2018 Docket/Case Number: 2016049343501

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/09/2018 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 $13,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $13,500. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DID NOT FOLLOW UP ON POSITION LIMIT OVERAGES AND FAILED TO PROMPTLY TAKE THE ACTION NECESSARY TO BRING A POSITION INTO COMPLIANCE. THE FINDINGS STATED THAT A CORRESPONDENT FIRM, A CLIENT OF THE FIRM, EFFECTED OPENING TRANSACTIONS FOR THE ACCOUNT OF ITS CUSTOMER THAT EXCEEDED THE APPLICABLE POSITION LIMIT ON THE BULLISH SIDE OF THE MARKET IN A SECURITY, WHICH WAS 50,000 CONTRACTS, BY 5,676 CONTRACTS. THE NEXT DAY, THE CORRESPONDENT FIRM EXECUTED AN ADDITIONAL 500 CONTRACTS IN THE SECURITY FOR THE SAME CUSTOMER WHILE THE CUSTOMER'S POSITION IN THE SECURITY HAD ALREADY EXCEEDED THE POSITION LIMIT ON THE PREVIOUS TRADING DAY, WHICH FURTHER CAUSED THE APPLICABLE POSITION LIMIT TO BE EXCEEDED BY A TOTAL OF 6,176 CONTRACTS. THE FINDINGS ALSO STATED THAT THE FIRM MAINTAINED AND CLEARED THE OPTIONS POSITIONS IN THE SECURITY FOR THE CORRESPONDENT FIRM. DURING A BI-MONTHLY SURVEILLANCE REVIEW OF OPTIONS POSITIONS THAT THE FIRM CONDUCTED, IT IDENTIFIED THE ©2021 FINRA. All rights reserved. Report aboutPOSITIONS RBC CAPITAL IN THE MARKETS, SECURITY. LLC HOWEVER, THE FIRM MISTOOK THE 122 5,000,000 SHARES POSITION LIMIT, WHICH IT HAD OBTAINED FROM THE WEBSITE OF THE OPTIONS CLEARING CORPORATION, AS CONTRACTS. THE 5,000,000 SHARES POSITION LIMIT IS EQUIVALENT TO THE 50,000 CONTRACTS POSITION LIMIT SINCE THE SHARES DELIVERABLE OF AN OPTIONS CONTRACT IS 100 SHARES. AS SUCH, THE FIRM CONSIDERED THE SUBJECT OPTIONS POSITION TO BE WITHIN THE POSITION LIMIT. AS A RESULT, THE FIRM DID NOT FOLLOW UP ON THESE POSITION LIMIT OVERAGES AND FAILED TO PROMPTLY TAKE THE ACTION NECESSARY TO BRING THE POSITION INTO COMPLIANCE. FURTHER, THE CORRESPONDENT FIRM ALSO FAILED TO BRING ITS CUSTOMER'S POSITION IN THE SECURITY INTO COMPLIANCE WITH THE APPLICABLE POSITION LIMIT. THE POSITION LIMIT IN A SECURITY WAS EXCEEDED FOR A TOTAL 16 CONSECUTIVE TRADING DAYS, WHICH RANGED FROM APPROXIMATELY 11 PERCENT TO 12 PERCENT OVER THE APPLICABLE LIMIT FOR THE SECURITY. ON MARCH 18, 2016, A POSITION LIMIT INCREASE WAS PUBLISHED BY THE OPTIONS CLEARING CORPORATION THAT INCREASED THE LIMIT FROM 50,000 CONTRACTS TO 75,000 CONTRACTS, WHICH BROUGHT THE CUSTOMER'S POSITIONS IN COMPLIANCE. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE NASDAQ OPTIONS MARKET LLC (NOM), CONCERNING POSITION LIMITS. SPECIFICALLY, THE FIRM ONLY CONDUCTED A BI- MONTHLY SURVEILLANCE REVIEW OF OPTIONS POSITIONS TO DETERMINE COMPLIANCE WITH POSITION LIMITS, AND IT FAILED TO DETECT THE POSITION LIMIT OVERAGES IN THE SECURITY WHEN THEY WERE REVIEWED. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DID NOT FOLLOW UP ON POSITION LIMIT OVERAGES AND FAILED TO PROMPTLY TAKE THE ACTION NECESSARY TO BRING A POSITION INTO COMPLIANCE. THE FINDINGS STATED THAT A CORRESPONDENT FIRM, A CLIENT OF THE FIRM, EFFECTED OPENING TRANSACTIONS FOR THE ACCOUNT OF ITS CUSTOMER THAT EXCEEDED THE APPLICABLE POSITION LIMIT ON THE BULLISH SIDE OF THE MARKET IN A SECURITY, WHICH WAS 50,000 CONTRACTS, BY 5,676 CONTRACTS. THE NEXT DAY, THE CORRESPONDENT FIRM EXECUTED AN ADDITIONAL 500 CONTRACTS IN THE SECURITY FOR THE SAME CUSTOMER WHILE THE CUSTOMER'S POSITION IN THE SECURITY HAD ALREADY EXCEEDED THE POSITION LIMIT ON THE PREVIOUS TRADING DAY, WHICH FURTHER CAUSED THE www.finra.org/brokercheck APPLICABLE POSITION LIMIT TO BE EXCEEDED BY A TOTAL OF 6,176 User Guidance CONTRACTS. THE FINDINGS ALSO STATED THAT THE FIRM MAINTAINED AND CLEARED THE OPTIONS POSITIONS IN THE SECURITY FOR THE CORRESPONDENT FIRM. DURING A BI-MONTHLY SURVEILLANCE REVIEW OF OPTIONS POSITIONS THAT THE FIRM CONDUCTED, IT IDENTIFIED THE POSITIONS IN THE SECURITY. HOWEVER, THE FIRM MISTOOK THE 5,000,000 SHARES POSITION LIMIT, WHICH IT HAD OBTAINED FROM THE WEBSITE OF THE OPTIONS CLEARING CORPORATION, AS CONTRACTS. THE 5,000,000 SHARES POSITION LIMIT IS EQUIVALENT TO THE 50,000 CONTRACTS POSITION LIMIT SINCE THE SHARES DELIVERABLE OF AN OPTIONS CONTRACT IS 100 SHARES. AS SUCH, THE FIRM CONSIDERED THE SUBJECT OPTIONS POSITION TO BE WITHIN THE POSITION LIMIT. AS A RESULT, THE FIRM DID NOT FOLLOW UP ON THESE POSITION LIMIT OVERAGES AND FAILED TO PROMPTLY TAKE THE ACTION NECESSARY TO BRING THE POSITION INTO COMPLIANCE. FURTHER, THE CORRESPONDENT FIRM ALSO FAILED TO BRING ITS CUSTOMER'S POSITION IN THE SECURITY INTO COMPLIANCE WITH THE APPLICABLE POSITION LIMIT. THE POSITION LIMIT IN A SECURITY WAS EXCEEDED FOR A TOTAL 16 CONSECUTIVE TRADING DAYS, WHICH RANGED FROM APPROXIMATELY 11 PERCENT TO 12 PERCENT OVER THE APPLICABLE LIMIT FOR THE SECURITY. ON MARCH 18, 2016, A POSITION LIMIT INCREASE WAS PUBLISHED BY THE OPTIONS CLEARING CORPORATION THAT INCREASED THE LIMIT FROM 50,000 CONTRACTS TO 75,000 CONTRACTS, WHICH BROUGHT THE CUSTOMER'S POSITIONS IN COMPLIANCE. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE NASDAQ OPTIONS MARKET LLC (NOM), CONCERNING POSITION LIMITS. SPECIFICALLY, THE FIRM ONLY CONDUCTED A BI- MONTHLY SURVEILLANCE REVIEW OF OPTIONS POSITIONS TO DETERMINE COMPLIANCE WITH POSITION LIMITS, AND IT FAILED TO DETECT THE POSITION LIMIT OVERAGES IN THE SECURITY WHEN THEY WERE REVIEWED. Initiated By: NASDAQ STOCK MARKET Date Initiated: 05/09/2018 Docket/Case Number: 2016049343501

Principal Product Type: Options 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: 05/09/2018

Sanctions Ordered: Censure Monetary/Fine $13,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $13,500. Firm Statement ON MAY 2, 2016, THE FIRM MODIFIED ITS SUPERVISORY SYSTEMS AND PROCEDURES TO PROVIDE FOR A DAILY REVIEW OF OPTIONS POSITIONS TO DETERMINE COMPLIANCE WITH POSITION LIMITS FOR SECURITIES IN RBC WEALTH MANAGEMENT, A DIVISION OF THE FIRM. i Disclosure 41 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT INAPPROPRIATELY USED OPTIONS CLEARING CORPORATION (OCC) ADJUSTMENTS TO CREATE A POSITION WITHOUT TRADING ON AN EXCHANGE AND SUBSEQUENTLY INAPPROPRIATELY USED OCC ADJUSTMENTS TO CLOSE OUT A POSITION WITHOUT TRADING ON AN EXCHANGE. THE FINDINGS STATED THAT FURTHER, IT WAS DETERMINED THAT THE FIRM THROUGH 273 INTERNAL ENTRIES TRIGGERED OCC ADJUSTMENTS IN A TOTAL OF 107 SYMBOLS FOR A TOTAL OF 203,478 CONTRACTS, WHICH CREATED LONG AND SHORT POSITIONS AT THE OCC WITHOUT TRADING ON AN EXCHANGE, AND RESULTED IN INFLATED OPEN INTEREST. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO FOLLOW ITS WRITTEN SUPERVISORY PROCEDURES RELATED TO THE PROPER USE OF OCC ADJUSTMENTS. THE FIRM FURTHER FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND BOX RULES, CONCERNING OCC ADJUSTMENTS, AS THE FIRM DID NOT HAVE ANY PROCEDURES IN PLACE TO VERIFY THAT OCC ADJUSTMENTS WERE NOT ASSOCIATED WITH INTERNAL ENTRIES. Initiated By: BOX OPTIONS EXCHANGE LLC Date Initiated: 04/13/2018 Docket/Case Number: 2014043230901

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 124 www.finra.org/brokercheck User Guidance

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

Resolution: Consent Resolution Date: 04/13/2018 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 $150,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $150,000. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT INAPPROPRIATELY USED OPTIONS CLEARING CORPORATION (OCC) ADJUSTMENTS TO CREATE A POSITION WITHOUT TRADING ON AN EXCHANGE AND SUBSEQUENTLY INAPPROPRIATELY USED OCC ADJUSTMENTS TO CLOSE OUT A POSITION WITHOUT TRADING ON AN EXCHANGE. THE FINDINGS STATED THAT FURTHER, IT WAS DETERMINED THAT THE FIRM THROUGH 273 INTERNAL ENTRIES TRIGGERED OCC ADJUSTMENTS IN A TOTAL OF 107 SYMBOLS FOR A TOTAL OF 203,478 CONTRACTS, WHICH CREATED LONG AND SHORT POSITIONS AT THE OCC WITHOUT TRADING ON AN EXCHANGE, AND RESULTED IN INFLATED OPEN INTEREST. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO FOLLOW ITS WRITTEN SUPERVISORY PROCEDURES RELATED TO THE PROPER USE OF OCC ADJUSTMENTS. THE FIRM FURTHER FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND BOX RULES, CONCERNING OCC ADJUSTMENTS, AS THE FIRM DID NOT HAVE ANY PROCEDURES IN PLACE TO VERIFY THAT OCC ADJUSTMENTS WERE NOT ASSOCIATED WITH INTERNAL ENTRIES.

Initiated By: BOX OPTIONS EXCHANGE LLC Date Initiated: 04/13/2018 Docket/Case Number: 2014043230901

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

Resolution: Consent Resolution Date: 04/13/2018 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $150,000. i Disclosure 42 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC TENDERED 32,567 SHARES FOR THE PARTIAL TENDER OFFER IN BAX IN EXCESS OF ITS NET LONG POSITION. IN ADDITION, RBC FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES, DESIGNED TO PREVENT AND DETECT VIOLATIONS OF EXCHANGE ACT RULE 14E-4 RELATING TO PARTIAL SHORT TENDER ACTIVITY. (VIOLATION OF CBOE RULE 4.2 AND 4.24) Initiated By: CBOE EXCHANGE, INC. Date Initiated: 11/07/2017 Docket/Case Number: 17-0052/ 20160501553

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 126 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 12/29/2017 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Disgorgement/Restitution Other Sanctions Ordered: A $20,000 FINE, A CENSURE AND DISGORGEMENT IN THE AMOUNT OF $6,865.12. Sanction Details: A $20,000 FINE, A CENSURE AND DISGORGEMENT IN THE AMOUNT OF $6,865.12. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO ENFORCE WRITTEN SUPERVISORY PROCEDURES, DESIGNED TO PREVENT AND DETECT VIOLATIONS OF EXCHANGE ACT RULE 14E-4 RELATING TO ITS TENDER OF 32,567 SHARES INTO THE BAXTER INTERNATIONAL ("BAX") PARTIAL TENDER OFFER ON MAY 18, 2016 IN EXCESS OF ITS NET LONG POSITION. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED Date Initiated: 11/07/2017 Docket/Case Number: 11-0052/20160501553

Resolution: Stipulation and Consent Resolution Date: 12/29/2017 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Disgorgement/Restitution ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 127 www.finra.org/brokercheck User Guidance

Censure Monetary/Fine $20,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE FIRM CONSENTED TO A $20,000 FINE, A CENSURE AND DISGORGEMENT IN THE AMOUNT OF $6,865.12. PAYMENT WAS MADE ON JANUARY 5, 2018. Firm Statement A SUMMARY OF THIS ACTION IS SET FORTH IN THE LETTER OF CONSENT, WHICH IS PUBLICLY AVAILABLE VIA THE CBOE. i Disclosure 43 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS.

THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: BATS BYX EXCHANGE, INC. Date Initiated: 09/20/2017 Docket/Case Number: 2014041635008

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

Resolution Date: 10/18/2017 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 $10,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO BYX.

PURSUANT TO BYX RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC BECAME FINAL OCTOBER 18, 2017. Regulator Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: BATS BYX EXCHANGE, INC. Date Initiated: 09/20/2017 Docket/Case Number: 2014041635008

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

THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: BATS BZX EXCHANGE, INC. Date Initiated: 09/20/2017 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 130 www.finra.org/brokercheck User Guidance

Date Initiated: 09/20/2017 Docket/Case Number: 2014041635007

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

PURSUANT TO BZX RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC BECAME FINAL OCTOBER 18, 2017. Regulator Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE ©2021 FINRA. All rights reserved. Report aboutSECURITIES RBC CAPITAL LAWS MARKETS, AND LLCREGULATIONS, AND THE RULES OF THE 131 EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF www.finra.org/brokercheck THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE User Guidance DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: BATS BZX EXCHANGE, INC. Date Initiated: 09/20/2017 Docket/Case Number: 2014041635007

Principal Product Type: Other Other Product Type(s): UNSPECIFIED SECURITIES 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: 10/18/2017 Sanctions Ordered: Censure Monetary/Fine $10,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO BZX. PURSUANT TO BZX RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC BECAME FINAL OCTOBER 18, 2017. Firm Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Disclosure 45 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE ©2021 FINRA. All rights reserved. Report aboutLICENSING RBC CAPITAL STATUS MARKETS, OF SUCHLLC EMPLOYEES. 132 IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR www.finra.org/brokercheck TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO User Guidance WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF NORTH CAROLINA Date Initiated: 08/28/2017 Docket/Case Number: 13 SEC 088

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 08/28/2017 Sanctions Ordered: Monetary/Fine $77,145.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN, POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM THE JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF 78A-39(AL)(2(A)AND 78A-36(B)OF THE NORTH CAROLINA GENERAL STATUTES. Firm Statement AS PART OF A MULTISTATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH THE APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 46 of 336 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 133 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: THE FIRM ENTERED INTO AN OFFER OF SETTLEMENT AND CONSENT FOR THE SOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING, WITHOUT ADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS REFERRED TO IN THE OFFER OF SETTLEMENT. THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: NYSE ARCA, INC. Date Initiated: 09/19/2017 Docket/Case Number: 2014041635001

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

Resolution: Decision & Order of Offer of Settlement Resolution Date: 09/19/2017 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 $10,500.00 Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO NYSE ARCA. Regulator Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Reporting Source: Firm Current Status: Final Allegations: THE FIRM ENTERED INTO AN OFFER OF SETTLEMENT AND CONSENT FOR THE SOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING, WITHOUT ADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS REFERRED TO IN THE OFFER OF SETTLEMENT. THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: NYSE ARCA, INC. Date Initiated: 09/19/2017 Docket/Case Number: 2014041635001

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

Resolution: Decision & Order of Offer of Settlement Resolution Date: 09/19/2017 Sanctions Ordered: Censure Monetary/Fine $10,500.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 135 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO NYSE ARCA. Firm Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Disclosure 47 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS.

THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: NASDAQ BX, INC. Date Initiated: 09/20/2017 Docket/Case Number: 2014041635004

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/20/2017 Does the order constitute a No final order based on ©2021violations FINRA. of All any rights laws reserved. or Report about RBC CAPITAL MARKETS, LLC 136 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 $10,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO NASDAQ BX. Regulator Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: NASDAQ BX, INC. Date Initiated: 09/20/2017 Docket/Case Number: 2014041635004

Principal Product Type: Other Other Product Type(s): UNSPECIFIED SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 137 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/20/2017 Sanctions Ordered: Censure Monetary/Fine $10,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO NASDAQ BX. Firm Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Disclosure 48 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT ON THE REVIEW DATE, THE FIRM FAILED TO TAKE REASONABLE STEPS TO AVOID DISPLAYING, AND ENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED OR CROSSED A PROTECTED QUOTATION, WITHOUT SIMULTANEOUSLY ROUTING AN ISO TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF ANY PROTECTED QUOTATION THAT WAS A LOCKING QUOTATION OR CROSSING QUOTATION. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. THE FIRM'S REGULATION NMS COMPLIANCE ISO EXCEPTION REPORTS, WHICH WERE REVIEWED BY FIRM PERSONNEL, DID NOT IDENTIFY THAT THE FIRM HAD LOCKED OR CROSSED A PROTECTED QUOTATION ON THE REVIEW DATE. Initiated By: BATS EDGX EXCHANGE, INC. Date Initiated: 09/20/2017 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 138 www.finra.org/brokercheck User Guidance

Date Initiated: 09/20/2017 Docket/Case Number: 2014041635006

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

PURSUANT TO EDGX RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC BECAME FINAL OCTOBER 18, 2017. Regulator Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT ON THE REVIEW DATE, ©2021 FINRA. All rights reserved. Report aboutTHE RBC FIRM CAPITAL FAILED MARKETS, TO TAKE LLC REASONABLE STEPS TO AVOID DISPLAYING, 139 AND ENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED OR CROSSED A PROTECTED QUOTATION, WITHOUT SIMULTANEOUSLY ROUTING AN ISO TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF ANY PROTECTED QUOTATION THAT WAS A LOCKING QUOTATION OR CROSSING QUOTATION. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. THE FIRM'S REGULATION NMS COMPLIANCE ISO EXCEPTION REPORTS, WHICH WERE REVIEWED BY FIRM PERSONNEL, DID NOT IDENTIFY THAT THE FIRM HAD LOCKED OR CROSSED A PROTECTED QUOTATION ON THE REVIEW DATE. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED www.finra.org/brokercheck TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM User Guidance FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT ON THE REVIEW DATE, THE FIRM FAILED TO TAKE REASONABLE STEPS TO AVOID DISPLAYING, AND ENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING, QUOTATIONS THAT LOCKED OR CROSSED A PROTECTED QUOTATION, WITHOUT SIMULTANEOUSLY ROUTING AN ISO TO EXECUTE AGAINST THE FULL DISPLAYED SIZE OF ANY PROTECTED QUOTATION THAT WAS A LOCKING QUOTATION OR CROSSING QUOTATION. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. THE FIRM'S REGULATION NMS COMPLIANCE ISO EXCEPTION REPORTS, WHICH WERE REVIEWED BY FIRM PERSONNEL, DID NOT IDENTIFY THAT THE FIRM HAD LOCKED OR CROSSED A PROTECTED QUOTATION ON THE REVIEW DATE. Initiated By: BATS EDGX EXCHANGE, INC. Date Initiated: 09/20/2017 Docket/Case Number: 2014041635006

Principal Product Type: Other Other Product Type(s): UNSPECIFIED SECURITIES 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: 10/18/2017 Sanctions Ordered: Censure Monetary/Fine $21,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO EDGX. THE FIRM WAS ALSO FINED $10,500 FOR THE FINDINGS IN THE REVIEW OF ACTION NUMBER 20160512855. THUS, THE FIRM WAS FINED A TOTAL FINE OF 21,000. PURSUANT TO EDGX RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC BECAME FINAL OCTOBER 18, 2017. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 140 THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO EDGX. THE FIRM WAS ALSO FINED $10,500 www.finra.org/brokercheck FOR THE FINDINGS IN THE REVIEW OF ACTION NUMBER 20160512855. User Guidance THUS, THE FIRM WAS FINED A TOTAL FINE OF 21,000. PURSUANT TO EDGX RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC BECAME FINAL OCTOBER 18, 2017. Firm Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Disclosure 49 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS.

THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 08/24/2017 Docket/Case Number: 2014041635002

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/18/2017 Does the order constitute a No final order based on violations of any laws or regulations that prohibit ©2021fraudulent, FINRA. Allmanipulative, rights reserved. or Report about RBC CAPITAL MARKETS, LLC 141 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 $10,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO NYSE. Regulator Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 08/24/2017 Docket/Case Number: 2014041635002

Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/18/2017 Sanctions Ordered: Censure Monetary/Fine $10,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO NYSE. Firm Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Disclosure 50 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS.

THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: NASDAQ STOCK MARKET Date Initiated: 09/20/2017 Docket/Case Number: 2014041635003

Principal Product Type: Other Other Product Type(s): UNSPECIFIED SECURITIES Principal Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 143 www.finra.org/brokercheck User Guidance

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/20/2017 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 $10,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO NASDAQ. Regulator Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: NASDAQ STOCK MARKET Date Initiated: 09/20/2017 Docket/Case Number: 2014041635003 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 144 www.finra.org/brokercheck User Guidance

Docket/Case Number: 2014041635003

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

THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: BATS EDGA EXCHANGE, INC. Date Initiated: 09/20/2017 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 145 www.finra.org/brokercheck User Guidance

Date Initiated: 09/20/2017 Docket/Case Number: 2014041635005

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/18/2017 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 $10,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO EDGA. PURSUANT TO EDGA RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC BECAME FINAL OCTOBER 18, 2017. Regulator Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE ©2021 FINRA. All rights reserved. Report aboutEXCHANGE, RBC CAPITAL CONCERNING MARKETS, LLC ISOS THAT COMPLIED WITH THE SEC'S 146 REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT CERTAIN OF THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE www.finra.org/brokercheck DEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OF User Guidance REGULATION NMS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE EXCHANGE, CONCERNING ISOS THAT COMPLIED WITH THE SEC'S REGULATION NMS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES THAT WOULD ENABLE IT IN CERTAIN INSTANCES TO PROMPTLY IDENTIFY ISSUES WITH THE FIRM'S ACCESS TO TIMELY AND ACCURATE MARKET DATA. Initiated By: BATS EDGA EXCHANGE, INC. Date Initiated: 09/20/2017 Docket/Case Number: 2014041635005

Principal Product Type: Other Other Product Type(s): UNSPECIFIED SECURITIES 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: 10/18/2017 Sanctions Ordered: Censure Monetary/Fine $10,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, THE TOTAL AMOUNT OF $84,000, OF WHICH $10,500 IS PAYABLE TO EDGA. PURSUANT TO EDGA RULE 8.8, THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC BECAME FINAL OCTOBER 18, 2017. Firm Statement ACTION NUMBER 20140416350 INCLUDES 20150441761 AND 20160512855 i Disclosure 52 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ON ONE TRADE, IT HAD MODIFIED AN EXPIRING EXERCISE DECLARATION (EED) SUBMISSION AFTER THE 5:30 P.M. (ET) CUT-OFF TIME, WITHOUT AN ALLOWABLE EXCEPTION AND BASED ON AFTER-HOURS TRADING INFORMATION, IN VIOLATION OF BOX RULE 9000, AND ALSO HAD RELATED ©2021 FINRA. All rights reserved. Report aboutSUPERVISORY RBC CAPITAL MARKETS,DEFICIENCIES. LLC 147

THE FINDINGS STATED THAT THIS CUT-OFF TIME WAS ESTABLISHED TO PREVENT OPTION HOLDERS FROM WAITING FOR MATERIAL INFORMATION TO DETERMINE IF THE UNDERLYING PRICE WILL VARY SUBSTANTIALLY FROM THE CLOSING PRICE ON EXPIRATION, UNFAIRLY DISADVANTAGING THE SHORT OPTION HOLDERS.

THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ENSURE THAT ANY EXERCISE INSTRUCTIONS SUBMITTED AFTER THE APPLICABLE CUT-OFF TIME ARE THE RESULT OF A GOOD FAITH ERROR OR OTHER APPLICABLE EXCEPTION, AND ARE NOT BASED ON MATERIAL INFORMATION, INCLUDING AFTER-HOURS TRADING ACTIVITY, RELEASED AFTER THE CUT- OFF TIME. AS A RESULT, A FIRM TRADER SUBMITTED THIS PARTICULAR MODIFIED EED TO THE FIRM'S OPERATIONS DEPARTMENT BASED ON AFTER-HOURS TRADING AFTER THE 5:30 P.M. CUT-OFF TIME, AND THE OPERATIONS STAFF SUBMITTED THE MODIFIED EED TO THE FIRM'S CLEARING FIRM WITHOUT COMPLETELY UNDERSTANDING THE RULES GOVERNING EED SUBMISSIONS. IN ADDITION, THE FIRM FAILED TO HAVE ADEQUATE SUPERVISORY POLICIES AND SYSTEMS, INCLUDING WRITTEN SUPERVISORY PROCEDURES ("WSPS"), REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH BOX RULES RELATING TO THE OBLIGATIONS OF A BOX PARTICIPANT WHEN EXERCISING OPTIONS CONTRACTS. SPECIFICALLY, THE FIRM'S WSPS LACKED REFERENCES TO THE IDENTITY OF THE INDIVIDUAL RESPONSIBLE FOR SUPERVISION; THE SUPERVISORY STEPS AND REVIEWS TO BE TAKEN BY THE DESIGNATED SUPERVISOR; THE FREQUENCY OF SUCH REVIEWS; AND HOW SUCH REVIEWS SHOULD BE DOCUMENTED. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ON ONE www.finra.org/brokercheck TRADE, IT HAD MODIFIED AN EXPIRING EXERCISE DECLARATION (EED) User Guidance SUBMISSION AFTER THE 5:30 P.M. (ET) CUT-OFF TIME, WITHOUT AN ALLOWABLE EXCEPTION AND BASED ON AFTER-HOURS TRADING INFORMATION, IN VIOLATION OF BOX RULE 9000, AND ALSO HAD RELATED SUPERVISORY DEFICIENCIES.

THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ENSURE THAT ANY EXERCISE INSTRUCTIONS SUBMITTED AFTER THE APPLICABLE CUT-OFF TIME ARE THE RESULT OF A GOOD FAITH ERROR OR OTHER APPLICABLE EXCEPTION, AND ARE NOT BASED ON MATERIAL INFORMATION, INCLUDING AFTER-HOURS TRADING ACTIVITY, RELEASED AFTER THE CUT- OFF TIME. AS A RESULT, A FIRM TRADER SUBMITTED THIS PARTICULAR MODIFIED EED TO THE FIRM'S OPERATIONS DEPARTMENT BASED ON AFTER-HOURS TRADING AFTER THE 5:30 P.M. CUT-OFF TIME, AND THE OPERATIONS STAFF SUBMITTED THE MODIFIED EED TO THE FIRM'S CLEARING FIRM WITHOUT COMPLETELY UNDERSTANDING THE RULES GOVERNING EED SUBMISSIONS. IN ADDITION, THE FIRM FAILED TO HAVE ADEQUATE SUPERVISORY POLICIES AND SYSTEMS, INCLUDING WRITTEN SUPERVISORY PROCEDURES ("WSPS"), REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH BOX RULES RELATING TO THE OBLIGATIONS OF A BOX PARTICIPANT WHEN EXERCISING OPTIONS CONTRACTS. SPECIFICALLY, THE FIRM'S WSPS LACKED REFERENCES TO THE IDENTITY OF THE INDIVIDUAL RESPONSIBLE FOR SUPERVISION; THE SUPERVISORY STEPS AND REVIEWS TO BE TAKEN BY THE DESIGNATED SUPERVISOR; THE FREQUENCY OF SUCH REVIEWS; AND HOW SUCH REVIEWS SHOULD BE DOCUMENTED. Initiated By: BOX OPTIONS EXCHANGE LLC Date Initiated: 09/13/2017 Docket/Case Number: 2015046552701

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/13/2017 Does the order constitute a No ©2021final orderFINRA. basedAll rights on reserved. Report about RBC CAPITAL MARKETS, LLC 148 violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/13/2017 Sanctions Ordered: Censure Monetary/Fine $45,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED, FINED $45,000, AND ORDERED TO PAY $4,000 IN DISGORGEMENT. i Disclosure 53 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTS IN WHICH THE SPECIAL HANDLING CODE FIELD WAS NOT POPULATED TO INDICATE WHETHER THE ORDERS WERE "HELD" OR "NOT HELD." THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF FINRA, CONCERNING TRANSMITTING ACCURATE INFORMATION TO OATS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES (WSPS) PROVIDING FOR A REVIEW OF THE FIRM'S OATS REPORTS THAT WAS REPRESENTATIVE OF THE TYPES OF BUSINESS IN ©2021 FINRA. All rights reserved. Report aboutWHICH RBC THECAPITAL FIRM MARKETS, ENGAGED LLC TO ENSURE ITS SUBMISSIONS WERE 150 ACCURATE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES THAT IT WAS REQUIRED TO REPORT. IN THESE INSTANCES, THE FIRM REPORTED BLOCK TRANSACTIONS THAT WERE TO BE ALLOCATED TO SEPARATE MANAGED ACCOUNTS AS A SINGLE BLOCK INSTEAD OF REPORTING THE ALLOCATIONS AS INDIVIDUAL TRANSACTIONS, AS REQUIRED. THE FINDINGS ALSO INCLUDED THAT THE FIRM EFFECTED CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNT LOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE, WHICH WERE NOT SUBJECT TO AN EXCEPTION UNDER THE APPLICABLE MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB) RULE. FINRA FOUND THAT THE FIRM ALSO FAILED TO DISCLOSE ALL MATERIAL FACTS CONCERNING MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TO THE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITS CUSTOMER THAT THE MUNICIPAL SECURITIES TRANSACTION WAS IN AN AMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE. IN NOTICE 2002-05, THE MSRB STATED THAT A DEALER SHOULD CONSIDER A TRANSACTION BELOW AN ISSUE'S MINIMUM DENOMINATION TO BE A MATERIAL FACT THAT GENERALLY REQUIRES DISCLOSURE TO THE CUSTOMER. FINRA ALSO FOUND THAT THE FIRM FAILED TO REPORT INFORMATION REGARDING 18,634 PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS). FOR APPROXIMATELY 1,500 OF THESE INSTANCES, THE FIRM REPORTED BLOCK TRANSACTIONS THAT WERE TO BE ALLOCATED TO SEPARATE MANAGED ACCOUNTS AS A SINGLE BLOCK INSTEAD OF REPORTING THE ALLOCATIONS AS INDIVIDUAL TRANSACTIONS, AS REQUIRED. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTS IN WHICH THE SPECIAL HANDLING CODE FIELD WAS NOT POPULATED TO INDICATE WHETHER THE ORDERS WERE "HELD" OR "NOT HELD." THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND www.finra.org/brokercheck REGULATIONS, AND THE RULES OF FINRA, CONCERNING TRANSMITTING User Guidance ACCURATE INFORMATION TO OATS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES (WSPS) PROVIDING FOR A REVIEW OF THE FIRM'S OATS REPORTS THAT WAS REPRESENTATIVE OF THE TYPES OF BUSINESS IN WHICH THE FIRM ENGAGED TO ENSURE ITS SUBMISSIONS WERE ACCURATE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES THAT IT WAS REQUIRED TO REPORT. IN THESE INSTANCES, THE FIRM REPORTED BLOCK TRANSACTIONS THAT WERE TO BE ALLOCATED TO SEPARATE MANAGED ACCOUNTS AS A SINGLE BLOCK INSTEAD OF REPORTING THE ALLOCATIONS AS INDIVIDUAL TRANSACTIONS, AS REQUIRED. THE FINDINGS ALSO INCLUDED THAT THE FIRM EFFECTED CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNT LOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE, WHICH WERE NOT SUBJECT TO AN EXCEPTION UNDER THE APPLICABLE MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB) RULE. FINRA FOUND THAT THE FIRM ALSO FAILED TO DISCLOSE ALL MATERIAL FACTS CONCERNING MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TO THE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITS CUSTOMER THAT THE MUNICIPAL SECURITIES TRANSACTION WAS IN AN AMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE. IN NOTICE 2002-05, THE MSRB STATED THAT A DEALER SHOULD CONSIDER A TRANSACTION BELOW AN ISSUE'S MINIMUM DENOMINATION TO BE A MATERIAL FACT THAT GENERALLY REQUIRES DISCLOSURE TO THE CUSTOMER. FINRA ALSO FOUND THAT THE FIRM FAILED TO REPORT INFORMATION REGARDING 18,634 PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS). FOR APPROXIMATELY 1,500 OF THESE INSTANCES, THE FIRM REPORTED BLOCK TRANSACTIONS THAT WERE TO BE ALLOCATED TO SEPARATE MANAGED ACCOUNTS AS A SINGLE BLOCK INSTEAD OF REPORTING THE ALLOCATIONS AS INDIVIDUAL TRANSACTIONS, AS REQUIRED. Initiated By: FINRA Date Initiated: 05/03/2017 Docket/Case Number: 2015046469501

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

Resolution Date: 05/03/2017 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 $225,000.00 Other Sanctions Ordered: UNDERTAKING; AND OFFER OF RESCISSION TO AFFECTED CUSTOMERS Sanction Details: THE FIRM WAS CENSURED, FINED $225,000, REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO PROVIDING FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF FINRA, CONCERNING TRANSMITTING ACCURATE INFORMATION TO OATS, AND REQUIRED TO OFFER RESCISSION TO THE CUSTOMERS WHO EXECUTED THE TRANSACTIONS AT EITHER THE ORIGINAL PURCHASE PRICE OR THE CURRENT FAIR MARKET VALUE, WHICHEVER IS HIGHER, BESIDES THE OFFER OF RESCISSION SHALL REMAIN OPEN WITH THE AFFECTED CUSTOMER FOR A PERIOD OF 60 DAYS. FINES PAID IN FULL ON 5/24/17. Regulator Statement FINRA CASE NUMBER 20150464695 INCLUDES CASE NUMBERS 20150465800, 20160492672, 20160494357, AND 20160502372- i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT THE FIRM TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTS IN WHICH THE SPECIAL HANDLING CODE FIELD WAS NOT POPULATED TO INDICATE WHETHER THE ORDERS WERE "HELD" OR "NOT HELD." THE FINDINGS ALLEGED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF FINRA, CONCERNING TRANSMITTING ACCURATE INFORMATION TO OATS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES (WSPS) PROVIDING FOR A REVIEW OF THE FIRM'S OATS REPORTS THAT WAS REPRESENTATIVE OF THE TYPES OF BUSINESS IN WHICH THE FIRM ENGAGED TO ENSURE ITS SUBMISSIONS WERE ACCURATE. THE FINDINGS ALSO ALLEGED THAT THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE ELIGIBLE CORPORATE DEBT ©2021 FINRA. All rights reserved. Report aboutSECURITIES RBC CAPITAL THAT MARKETS, IT WAS LLC REQUIRED TO REPORT. IN THESE INSTANCES, 152 THE FIRM REPORTED BLOCK TRANSACTIONS THAT WERE TO BE ALLOCATED TO SEPARATE MANAGED ACCOUNTS AS A SINGLE BLOCK INSTEAD OF REPORTING THE ALLOCATIONS AS INDIVIDUAL TRANSACTIONS, AS REQUIRED. THE FINDINGS ALSO ALLEGED THAT THE FIRM EFFECTED CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNT LOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE, WHICH WERE NOT SUBJECT TO AN EXCEPTION UNDER THE APPLICABLE MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB) RULE. FINRA ALLEGED THAT THE FIRM ALSO FAILED TO DISCLOSE ALL MATERIAL FACTS CONCERNING MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TO THE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITS CUSTOMER THAT THE MUNICIPAL SECURITIES TRANSACTION WAS IN AN AMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE. FINRA ALSO ALLEGED THAT THE FIRM FAILED TO REPORT INFORMATION REGARDING 18,634 PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REALTIME TRANSACTION REPORTING SYSTEM (RTRS). FOR APPROXIMATELY 1,500 OF THESE INSTANCES, THE FIRM REPORTED BLOCK TRANSACTIONS THAT WERE TO BE ALLOCATED TO SEPARATE MANAGED ACCOUNTS AS A SINGLE BLOCK INSTEAD OF REPORTING THE ALLOCATIONS AS INDIVIDUAL TRANSACTIONS, AS REQUIRED. IT IS ALLEGED THAT THE FIRM TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTS IN WHICH THE SPECIAL HANDLING CODE FIELD WAS NOT POPULATED TO INDICATE WHETHER THE ORDERS WERE "HELD" OR "NOT HELD." THE FINDINGS ALLEGED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF FINRA, CONCERNING TRANSMITTING ACCURATE INFORMATION TO OATS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES (WSPS) PROVIDING FOR A REVIEW www.finra.org/brokercheck OF THE FIRM'S OATS REPORTS THAT WAS REPRESENTATIVE OF THE User Guidance TYPES OF BUSINESS IN WHICH THE FIRM ENGAGED TO ENSURE ITS SUBMISSIONS WERE ACCURATE. THE FINDINGS ALSO ALLEGED THAT THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE ELIGIBLE CORPORATE DEBT SECURITIES THAT IT WAS REQUIRED TO REPORT. IN THESE INSTANCES, THE FIRM REPORTED BLOCK TRANSACTIONS THAT WERE TO BE ALLOCATED TO SEPARATE MANAGED ACCOUNTS AS A SINGLE BLOCK INSTEAD OF REPORTING THE ALLOCATIONS AS INDIVIDUAL TRANSACTIONS, AS REQUIRED. THE FINDINGS ALSO ALLEGED THAT THE FIRM EFFECTED CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNT LOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE, WHICH WERE NOT SUBJECT TO AN EXCEPTION UNDER THE APPLICABLE MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB) RULE. FINRA ALLEGED THAT THE FIRM ALSO FAILED TO DISCLOSE ALL MATERIAL FACTS CONCERNING MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TO THE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITS CUSTOMER THAT THE MUNICIPAL SECURITIES TRANSACTION WAS IN AN AMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE. FINRA ALSO ALLEGED THAT THE FIRM FAILED TO REPORT INFORMATION REGARDING 18,634 PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REALTIME TRANSACTION REPORTING SYSTEM (RTRS). FOR APPROXIMATELY 1,500 OF THESE INSTANCES, THE FIRM REPORTED BLOCK TRANSACTIONS THAT WERE TO BE ALLOCATED TO SEPARATE MANAGED ACCOUNTS AS A SINGLE BLOCK INSTEAD OF REPORTING THE ALLOCATIONS AS INDIVIDUAL TRANSACTIONS, AS REQUIRED. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 05/03/2017 Docket/Case Number: 20150464695-01

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/03/2017 Sanctions Ordered: Censure Monetary/Fine $225,000.00 Other Sanctions Ordered: UNDERTAKING AND OFFER OF RESCISSION Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED $225,000.00 ($125,000 FOR THE OATS REPORTING ©2021 FINRA. All rights reserved. Report aboutVIOLATIONS RBC CAPITAL OF MARKETS, NASD RULE LLC 6955(A) AND FINRA RULE 7450(A), $25,000 FOR 153 SUPERVISION VIOLATIONS OF NASD RULE 3010, FINRA RULE 3110, NASD RULE 2110 AND FINRA RULE 2010; $25,000 FOR TRACE REPORTING VIOLATIONS OF FINRA RULE 6730(B); $22,500 FOR THE MUNICIPAL SECURITIES MINIMUM DENOMINATION VIOLATIONS OF MSRB RULE G- 15(F); $7,500 FOR THE MUNICIPAL SECURITIES DISCLOSURE VIOLATIONS OF MSRB RULE G-17 AND MSRB RULE G-47; AND $20,000 FOR THE MUNICIPAL SECURITIES TRADE REPORTING VIOLATIONS OF MSRB RULE G-14). THE FIRM WILL UNDERTAKE TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO PROVIDING FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE OATS REPORTING VIOLATIONS AS DESCRIBED IN THE AWC, AND OFFER RESCISSION TO THE CUSTOMERS WHO EXECUTED THE TRANSACTIONS LISTED ON EXHIBIT A OF THE AWC AT EITHER THE ORIGINAL PURCHASE PRICE OR THE CURRENT FAIR MARKET VALUE, WHICHEVER IS HIGHER; ADDITIONALLY THE OFFER OF RESCISSION SHALL REMAIN OPEN WITH THE AFFECTED CUSTOMER FOR A PERIOD OF 60 DAYS. www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED $225,000.00 ($125,000 FOR THE OATS REPORTING VIOLATIONS OF NASD RULE 6955(A) AND FINRA RULE 7450(A), $25,000 FOR SUPERVISION VIOLATIONS OF NASD RULE 3010, FINRA RULE 3110, NASD RULE 2110 AND FINRA RULE 2010; $25,000 FOR TRACE REPORTING VIOLATIONS OF FINRA RULE 6730(B); $22,500 FOR THE MUNICIPAL SECURITIES MINIMUM DENOMINATION VIOLATIONS OF MSRB RULE G- 15(F); $7,500 FOR THE MUNICIPAL SECURITIES DISCLOSURE VIOLATIONS OF MSRB RULE G-17 AND MSRB RULE G-47; AND $20,000 FOR THE MUNICIPAL SECURITIES TRADE REPORTING VIOLATIONS OF MSRB RULE G-14). THE FIRM WILL UNDERTAKE TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO PROVIDING FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE OATS REPORTING VIOLATIONS AS DESCRIBED IN THE AWC, AND OFFER RESCISSION TO THE CUSTOMERS WHO EXECUTED THE TRANSACTIONS LISTED ON EXHIBIT A OF THE AWC AT EITHER THE ORIGINAL PURCHASE PRICE OR THE CURRENT FAIR MARKET VALUE, WHICHEVER IS HIGHER; ADDITIONALLY THE OFFER OF RESCISSION SHALL REMAIN OPEN WITH THE AFFECTED CUSTOMER FOR A PERIOD OF 60 DAYS. Firm Statement FINRA CASE NUMBER 20150464695 INCLUDES CASE NUMBERS 20150465800, 20160492672, 20160494357, AND 2016052372 i Disclosure 54 of 336 Reporting Source: Regulator Current Status: Final Allegations: FAILURE TO ESTABLISH AN ADEQUATE SUPERVISORY SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS; FAILURE TO ENFORCE ESTABLISHED WRITTEN PROCEDURES; ALLOWING THE ACCEPTANCE OF ORDERS IN TENNESSEE THROUGH CA(S) [AGENTS] WHO WERE NOT PROPERLY REGISTERED; Initiated By: TENNESSEE SECURITIES DIVISION Date Initiated: 01/17/2014 Docket/Case Number: 13-003 URL for Regulatory Action: HTTP://TN. GOV/ASSETS/ENTITIES/COMMERCE/ATTACHMENTS/RBCCONSENTORDER0 11714.PDF Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 154 www.finra.org/brokercheck User Guidance

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

Resolution: Order Resolution Date: 01/17/2014 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 $40,570.17 Other Sanctions Ordered: Sanction Details: MONETARY FINE i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: COMMISSIONER OF COMMERCE AND INSURANCE FOR THE STATE OF TENNESSEE Date Initiated: 01/17/2014 Docket/Case Number: 13-003

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 01/17/2014 Sanctions Ordered: Monetary/Fine $40,570.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 48-1-112(A)(2)(J) AND SECTION 48-1-109(B) OF THE TENNESSEE CODE ANNOTATED. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE SATTE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 55 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, ALONG WITH ANOTHER FIRM, FAILED TO MAINTAIN APPROXIMATELY 172 MILLION ELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON- REWRITABLE FORMAT, KNOWN AS WORM ("WRITE ONCE, READ MANY") FORMAT. THE FINDINGS STATED THAT WORM FORMAT IS INTENDED TO PREVENT THE ALTERATION OR DESTRUCTION OF BROKER-DEALER RECORDS STORED ELECTRONICALLY. THE FINDINGS ALSO STATED THAT THE FIRM DID NOT HAVE AN AUDIT SYSTEM FOR THOSE RECORDS THEY FAILED TO MAINTAIN IN WORM FORMAT. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO OBTAIN AN ATTESTATION FROM THEIR THIRD- PARTY VENDOR THAT THEY WILL SUPPLY ELECTRONICALLY STORED RECORDS TO REGULATORY AUTHORITIES IN THE EVENT THE FIRM IS ©2021 FINRA. All rights reserved. Report aboutUNABLE RBC CAPITAL TO PROVIDE MARKETS, THE LLC ELECTRONICALLY STORED RECORDS. FINRA 156 FOUND THAT THE FIRM FAILED TO ENFORCE WSPS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE WORM REQUIREMENT. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, ALONG WITH ANOTHER FIRM, FAILED TO MAINTAIN APPROXIMATELY 172 MILLION ELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON- REWRITABLE FORMAT, KNOWN AS WORM ("WRITE ONCE, READ MANY") FORMAT. THE FINDINGS STATED THAT WORM FORMAT IS INTENDED TO PREVENT THE ALTERATION OR DESTRUCTION OF BROKER-DEALER RECORDS STORED ELECTRONICALLY. THE FINDINGS ALSO STATED THAT www.finra.org/brokercheck THE FIRM DID NOT HAVE AN AUDIT SYSTEM FOR THOSE RECORDS THEY User Guidance FAILED TO MAINTAIN IN WORM FORMAT. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO OBTAIN AN ATTESTATION FROM THEIR THIRD- PARTY VENDOR THAT THEY WILL SUPPLY ELECTRONICALLY STORED RECORDS TO REGULATORY AUTHORITIES IN THE EVENT THE FIRM IS UNABLE TO PROVIDE THE ELECTRONICALLY STORED RECORDS. FINRA FOUND THAT THE FIRM FAILED TO ENFORCE WSPS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE WORM REQUIREMENT. Initiated By: FINRA Date Initiated: 12/21/2016 Docket/Case Number: 2016049821601

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/21/2016 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 $3,500,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $3,500,000, JOINTLY AND SEVERALLY, AND IS REQUIRED TO REVIEW ITS POLICIES AND PROCEDURES RELATED TO THE ADEQUACY OF ITS RELEVANT POLICIES AND PROCEDURES (WRITTEN OR OTHERWISE), INCLUDING A DESCRIPTION OF THE REMEDIAL MEASURES LEADING TO FULL COMPLIANCE, RELATING TO THE CONDUCT ADDRESSED IN THE AWC. FINES PAID IN FULL ON 12/27/16. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT RBC CAPITAL MARKETS, LLC AND RBC CAPITAL MARKETS ARBITRAGE, S.A. (BOTH NOTED TOGETHER AS "RBC" HEREAFTER) FAILED TO RETAIN ELECTRONIC RECORDS IN WORM ("WRITE ONCE, READ MANY") FORMAT. RBC IS ALSO ALLEGED TO HAVE FAILED TO ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 157 IMPLEMENT AN AUDIT SYSTEM REGARDING THE INPUTTING OF RECORDS IN ELECTRONIC STORAGE MEDIA. RBC IS ALLEGED TO HAVE FAILED TO OBTAIN AN ATTESTATION FROM THEIR THIRD PARTY VENDOR. RBC'S SUPERVISORY SYSTEM WAS ALLEGEDLY NOT REASONABLY DESIGNED TO ENFORCE SPECIFIC PROCEDURES CONCERNING STORAGE OF ELECTRONIC BROKER-DEALER RECORDS IN WORM FORMAT. www.finra.org/brokercheck User Guidance IT IS ALLEGED THAT RBC CAPITAL MARKETS, LLC AND RBC CAPITAL MARKETS ARBITRAGE, S.A. (BOTH NOTED TOGETHER AS "RBC" HEREAFTER) FAILED TO RETAIN ELECTRONIC RECORDS IN WORM ("WRITE ONCE, READ MANY") FORMAT. RBC IS ALSO ALLEGED TO HAVE FAILED TO IMPLEMENT AN AUDIT SYSTEM REGARDING THE INPUTTING OF RECORDS IN ELECTRONIC STORAGE MEDIA. RBC IS ALLEGED TO HAVE FAILED TO OBTAIN AN ATTESTATION FROM THEIR THIRD PARTY VENDOR. RBC'S SUPERVISORY SYSTEM WAS ALLEGEDLY NOT REASONABLY DESIGNED TO ENFORCE SPECIFIC PROCEDURES CONCERNING STORAGE OF ELECTRONIC BROKER-DEALER RECORDS IN WORM FORMAT. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 12/21/2016 Docket/Case Number: 2016049821601

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 AND UNDERTAKING Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/21/2016 Sanctions Ordered: Censure Monetary/Fine $3,500,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRMS CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE THE FIRMS ARE CENSURED AND FINED $3,500,000.00, TO BE PAID JOINTLY AND SEVERALLY, AND UNDERTAKE TO REVIEW RELEVANT POLICIES AND PROCEDURES. i Disclosure 56 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT OVERSTATED ITS ADVERTISED TRADE VOLUME DUE TO A COMPUTER CODING ERROR THAT CAUSED THE FIRM'S SYSTEMS TO INCORPORATE TRADE VOLUME FROM ITS ELECTRONIC TRADING DESK NOT ONLY ON T+3, BUT ALSO ERRONEOUSLY ON AT LEAST T+4 AND T+5, RESULTING IN MULTIPLE ADVERTISEMENTS OF THE SAME VOLUME. THE FINDINGS ©2021 FINRA. All rights reserved. Report aboutSTATED RBC CAPITAL THAT AS MARKETS, A RESULT, LLC THE FIRM'S TRADE VOLUME ADVERTISED 158 THROUGH PRIVATE SERVICE PROVIDERS WAS OVERSTATED IN AT LEAST 350,000 INSTANCES ACROSS MORE THAN 6,000 SECURITIES, TOTALING AT LEAST 20 BILLION SHARES. A COMPUTER CODING ERROR CAUSED ADVERTISED TRADE VOLUME FROM THE FIRM'S ELECTRONIC TRADING DESK TO BE REPORTED WITH THE WRONG EXECUTION DATE. IN PARTICULAR, TRADE VOLUME FROM THAT DESK, WHICH WAS SUBMITTED ON T+3, WAS INACCURATELY PUBLISHED BY A PRIVATE SERVICE PROVIDER AS IF IT WAS EXECUTED ON THE SUBMISSION DATE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND NASD AND FINRA RULES, CONCERNING ADVERTISED TRADE VOLUME AND ITS SUPERVISORY SYSTEM DID NOT INCLUDE SUFFICIENT WRITTEN SUPERVISORY PROCEDURES. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT www.finra.org/brokercheck OVERSTATED ITS ADVERTISED TRADE VOLUME DUE TO A COMPUTER User Guidance CODING ERROR THAT CAUSED THE FIRM'S SYSTEMS TO INCORPORATE TRADE VOLUME FROM ITS ELECTRONIC TRADING DESK NOT ONLY ON T+3, BUT ALSO ERRONEOUSLY ON AT LEAST T+4 AND T+5, RESULTING IN MULTIPLE ADVERTISEMENTS OF THE SAME VOLUME. THE FINDINGS STATED THAT AS A RESULT, THE FIRM'S TRADE VOLUME ADVERTISED THROUGH PRIVATE SERVICE PROVIDERS WAS OVERSTATED IN AT LEAST 350,000 INSTANCES ACROSS MORE THAN 6,000 SECURITIES, TOTALING AT LEAST 20 BILLION SHARES. A COMPUTER CODING ERROR CAUSED ADVERTISED TRADE VOLUME FROM THE FIRM'S ELECTRONIC TRADING DESK TO BE REPORTED WITH THE WRONG EXECUTION DATE. IN PARTICULAR, TRADE VOLUME FROM THAT DESK, WHICH WAS SUBMITTED ON T+3, WAS INACCURATELY PUBLISHED BY A PRIVATE SERVICE PROVIDER AS IF IT WAS EXECUTED ON THE SUBMISSION DATE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND NASD AND FINRA RULES, CONCERNING ADVERTISED TRADE VOLUME AND ITS SUPERVISORY SYSTEM DID NOT INCLUDE SUFFICIENT WRITTEN SUPERVISORY PROCEDURES. Initiated By: FINRA Date Initiated: 11/03/2016 Docket/Case Number: 2014041377101

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: 11/03/2016 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 $975,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $975,000. FINES PAID IN FULL ON 12/8/16. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 159 www.finra.org/brokercheck User Guidance

Sanction Details: THE FIRM WAS CENSURED AND FINED $975,000. FINES PAID IN FULL ON 12/8/16. Regulator Statement IN RESOLVING THIS MATTER IN THE MANNER SET FORTH HEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION, FINRA CONSIDERED THE FIRM'S COOPERATION, INCLUDING THAT THE FIRM SELF-REPORTED ITS ADVERTISING VIOLATIONS AND THE IMMEDIATE REMEDIAL STEPS UNDERTAKEN BY THE FIRM TO CORRECT THE IDENTIFIED DEFICIENCIES UPON THEIR DISCOVERY. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT DURING THE PERIODS OF APRIL 2011 THROUGH APRIL 2014 AND NOVEMBER 2002 THROUGH DECEMBER 29, 2014, THE FIRM EXPERIENCED SYSTEMS ISSUES DURING THE REVIEW PERIODS THAT RESULTED IN VIOLATION OF NASD RULES 2110 (FOR CONDUCT PRIOR TO DECEMBER 15, 2008), 3010 (FOR CONDUCT PRIOR TO DECEMBER 1, 2014), AND 3310 (FOR CONDUCT PRIOR TO FEBRUARY 15, 2010), AND FINRA RULES 2010 (FOR CONDUCT ON AND AFTER DECEMBER 15, 2008), 3110 (FOR CONDUCT ON AND AFTER DECEMBER 1, 2014), AND 5210 (FOR CONDUCT ON AND AFTER FEBRUARY 15, 2010). THE FIRM IS ALLEGED TO HAVE OVERSTATED ITS ADVERTISED TRADE VOLUME DUE TO A COMPUTER CODING ERROR. DUE TO A SEPARATE COMPUTER CODING ERROR, IT IS ALLEGED THAT THE ADVERTISED TRADE VOLUME FROM THE FIRM'S ELECTRONIC TRADING DESK WAS REPORTED WITH THE WRONG EXECUTION DATE. ADDITIONALLY, THE FIRM IS ALLEGED TO HAVE FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND NASD AND FINRA RULES, CONCERNING ADVERTISED TRADE VOLUME. THE FIRM'S SUPERVISORY SYSTEM ALLEGEDLY DID NOT INCLUDE SUFFICIENT WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR: (1) THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; (2) A STATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THE IDENTIFIED PERSON(S); (3) A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 10/18/2016 Docket/Case Number: 20140413771-01

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/18/2016 Sanctions Ordered: Censure Monetary/Fine $975,000.00 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 $975,000.00 ($650,000 FOR VIOLATIONS OF NASD RULES 2110 AND 3310, AND FINRA RULES 2010 AND 5210; AND $325,000 FOR VIOLATIONS OF NASD RULES 2110 AND 3010, AND FINRA RULES 2010 AND 3110. i Disclosure 57 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO TRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS). THE FINDINGS STATED THAT THESE ROES WERE LIMITED TO TRANSACTIONS WITH A SINGLE COUNTERPARTY THAT OCCURRED OUTSIDE OF THE FIRM'S USUAL ORDER MANAGEMENT SYSTEM (OMS). THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION CONCERNING TRANSMITTING ORDERS THAT TOOK PLACE OUTSIDE OF THE FIRM'S OMSS TO OATS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; A STATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THE IDENTIFIED PERSON(S); A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 161 WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO TRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS). THE FINDINGS STATED THAT THESE ROES WERE LIMITED TO TRANSACTIONS WITH A SINGLE COUNTERPARTY THAT OCCURRED OUTSIDE OF THE FIRM'S USUAL ORDER MANAGEMENT SYSTEM (OMS). THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION CONCERNING TRANSMITTING ORDERS THAT TOOK PLACE OUTSIDE OF THE FIRM'S OMSS TO OATS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; A STATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THE www.finra.org/brokercheck IDENTIFIED PERSON(S); A STATEMENT AS TO HOW OFTEN SUCH User Guidance PERSON(S) SHOULD TAKE SUCH STEP(S); AND A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED. Initiated By: FINRA Date Initiated: 10/19/2016 Docket/Case Number: 2015044230501

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/19/2016 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 $22,500.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $22,500, AND UNDERTAKES TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES. FINES PAID IN FULL ON NOVEMBER 14, 2016. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT THE FIRM FAILED TO TRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS). IT IS ALSO ALLEGED THAT THE FIRMS SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY CALCULATED TO COMPLY WITH APPLICABLE RULES REGARDING TRANSMITTING ORDERS THAT TOOK PLACE OUTSIDE OF THE FIRM'S OMSS TO OATS. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; A STATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THE IDENTIFIED PERSON(S); A STATEMENT AS TO HOW OFTEN SUCH ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 162 PERSON(S) SHOULD TAKE SUCH STEP(S); AND A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED. IT IS ALLEGED THAT THE FIRM FAILED TO TRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS). IT IS ALSO ALLEGED THAT THE FIRMS SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY CALCULATED TO COMPLY WITH APPLICABLE RULES REGARDING TRANSMITTING ORDERS THAT TOOK PLACE OUTSIDE OF THE FIRM'S OMSS TO OATS. SPECIFICALLY, THE FIRM'S SUPERVISORY www.finra.org/brokercheck SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES User Guidance PROVIDING FOR THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; A STATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THE IDENTIFIED PERSON(S); A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 10/19/2016 Docket/Case Number: 20150442305-01

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/19/2016 Sanctions Ordered: Censure Monetary/Fine $22,500.00 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 AND FINED $22,500 AND UNDERTAKES TO REVIEW ITS WRITTEN SUPERVISORY PROCEDURES. i Disclosure 58 of 336 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASE 34-78735, AUGUST 31, 2016: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE THAT CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AGAINST RBC CAPITAL MARKETS, LLC ("RBC" OR "RESPONDENT"). RBC CAUSED RURAL/METRO CORPORATION'S VIOLATIONS OF THE PROXY STATEMENT PROVISIONS OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH THE SALE OF RURAL/METRO CORPORATION ("RURAL") IN 2011 TO A PRIVATE EQUITY FIRM. RBC, WHICH SERVED AS RURAL'S LEAD FINANCIAL ADVISER FOR THE SALE, RENDERED A FAIRNESS ©2021 FINRA. All rights reserved. Report aboutOPINION RBC CAPITAL TO RURAL'S MARKETS, BOARD LLC OF DIRECTORS THAT CONTAINED 163 MATERIALLY FALSE AND MISLEADING INFORMATION CONCERNING RBC'S VALUATION ANALYSIS. RBC CAUSED THAT INFORMATION TO BE INCLUDED IN THE PROXY STATEMENT THAT RURAL FILED TO SOLICIT SHAREHOLDER APPROVAL FOR THE SALE. AS A RESULT, RBC CAUSED RURAL TO VIOLATE SECTION 14(A) OF THE EXCHANGE ACT AND RULE 14A-9 THEREUNDER, WHICH PROHIBITS SOLICITATION BY MEANS OF A PROXY STATEMENT THAT CONTAINS ANY MATERIALLY FALSE OR MISLEADING STATEMENT. SEC ADMIN RELEASE 34-78735, AUGUST 31, 2016: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE THAT CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AGAINST RBC CAPITAL MARKETS, LLC ("RBC" OR "RESPONDENT"). www.finra.org/brokercheck RBC CAUSED RURAL/METRO CORPORATION'S VIOLATIONS OF THE PROXY User Guidance STATEMENT PROVISIONS OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH THE SALE OF RURAL/METRO CORPORATION ("RURAL") IN 2011 TO A PRIVATE EQUITY FIRM. RBC, WHICH SERVED AS RURAL'S LEAD FINANCIAL ADVISER FOR THE SALE, RENDERED A FAIRNESS OPINION TO RURAL'S BOARD OF DIRECTORS THAT CONTAINED MATERIALLY FALSE AND MISLEADING INFORMATION CONCERNING RBC'S VALUATION ANALYSIS. RBC CAUSED THAT INFORMATION TO BE INCLUDED IN THE PROXY STATEMENT THAT RURAL FILED TO SOLICIT SHAREHOLDER APPROVAL FOR THE SALE. AS A RESULT, RBC CAUSED RURAL TO VIOLATE SECTION 14(A) OF THE EXCHANGE ACT AND RULE 14A-9 THEREUNDER, WHICH PROHIBITS SOLICITATION BY MEANS OF A PROXY STATEMENT THAT CONTAINS ANY MATERIALLY FALSE OR MISLEADING STATEMENT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 08/31/2016 Docket/Case Number: 3-17520

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

Resolution: Order Resolution Date: 08/31/2016 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 $2,000,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: PREJUDGMENT INTEREST ON DISGORGEMENT Sanction Details: RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IT IS ORDERED THAT PURSUANT TO SECTION 21C OF THE EXCHANGE ACT, RESPONDENT RBC CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 14(A) OF THE EXCHANGE ACT AND RULE 14A-9 THEREUNDER. RBC SHALL, WITHIN 14 DAYS OF THE ENTRY OF THIS ORDER, PAY DISGORGEMENT OF $500,000 AND PREJUDGMENT INTEREST OF $77,759, PLUS A CIVIL MONEY PENALTY IN THE AMOUNT OF $2,000,000, FOR A ©2021 FINRA. All rights reserved. Report aboutTOTAL RBC PAYMENT CAPITAL MARKETS, OF $2,577,759, LLC TO THE SECURITIES AND EXCHANGE 164 COMMISSION. RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IT IS ORDERED THAT PURSUANT TO SECTION 21C OF THE EXCHANGE ACT, RESPONDENT RBC CEASE AND DESIST FROM COMMITTING OR CAUSING www.finra.org/brokercheck ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 14(A) OF THE User Guidance EXCHANGE ACT AND RULE 14A-9 THEREUNDER. RBC SHALL, WITHIN 14 DAYS OF THE ENTRY OF THIS ORDER, PAY DISGORGEMENT OF $500,000 AND PREJUDGMENT INTEREST OF $77,759, PLUS A CIVIL MONEY PENALTY IN THE AMOUNT OF $2,000,000, FOR A TOTAL PAYMENT OF $2,577,759, TO THE SECURITIES AND EXCHANGE COMMISSION. i Reporting Source: Firm Current Status: Final Allegations: SEC ADMIN RELEASE 3478735, AUGUST 31, 2016: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE THAT CEASE AND DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AGAINST RBC CAPITAL MARKETS, LLC ("RBC" OR "RESPONDENT"). IT IS ALLEGED THAT RBC CAUSED RURAL/METRO CORPORATION'S VIOLATIONS OF THE PROXY STATEMENT PROVISIONS OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH THE SALE OF RURAL/METRO CORPORATION ("RURAL") IN 2011 TO A PRIVATE EQUITY FIRM. RBC, WHICH SERVED AS RURAL'S LEAD FINANCIAL ADVISER FOR THE SALE, ALLEGEDLY RENDERED A FAIRNESS OPINION TO RURAL'S BOARD OF DIRECTORS THAT CONTAINED MATERIALLY FALSE AND MISLEADING INFORMATION CONCERNING RBC'S VALUATION ANALYSIS. RBC ALLEGEDLY CAUSED THAT INFORMATION TO BE INCLUDED IN THE PROXY STATEMENT THAT RURAL FILED TO SOLICIT VS HAREHOLDER APPROVAL FOR THE SALE. AS A RESULT, RBC ALLEGEDLY CAUSED RURAL TO VIOLATE SECTION 14(A) OF THE EXCHANGE ACT AND RULE 14A9 THEREUNDER, WHICH PROHIBITS SOLICITATION BY MEANS OF A PROXY STATEMENT THAT CONTAINS ANY MATERIALLY FALSE OR MISLEADING STATEMENT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 08/31/2016 Docket/Case Number: 317520

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

Resolution Date: 08/31/2016 Sanctions Ordered: Monetary/Fine $2,000,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: PREJUDGMENT INTEREST ON DISGORGEMENT Sanction Details: RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IT IS ORDERED THAT PURSUANT TO SECTION 21C OF THE EXCHANGE ACT, RESPONDENT RBC CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 14(A) OF THE EXCHANGE ACT AND RULE 14A9 THEREUNDER. RBC SHALL, WITHIN 14 DAYS OF THE ENTRY OF THIS ORDER, PAY DISGORGEMENT OF $500,000 AND PREJUDGMENT INTEREST OF $77,759, PLUS A CIVIL MONEY PENALTY IN THE AMOUNT OF $2,000,000, FOR A TOTAL PAYMENT OF $2,577,759, TO THE SECURITIES AND EXCHANGE COMMISSION. i Disclosure 59 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF LOUISIANA Date Initiated: 07/22/2016 Docket/Case Number: OFI2016004

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 07/22/2016

Sanctions Ordered: Monetary/Fine $41,040.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN, POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM THE JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF TITLE 10, PART XIII, CHAPTER 19, SECTION 1901(A) OF THE LOUISIANA ADMINISTRATIVE CODE. Firm Statement AS PART OF A MULTISTATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH THE APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 60 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT ON JANUARY 13, 2014, RBC CAPITAL MARKETS, LLC ("RBCCM") EXECUTED A BLOCK TRADE IN THE MARCH 2014 5YEAR NOTE CONTRACT THAT WAS NOT REPORTED TO THE EXCHANGE WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION, AND THAT RBCCM REPORTED AN INACCURATE TIME OF EXECUTION OF THE BLOCK TRADE. ADDITIONALLY, IT IS ALLEGED THE RBCCM AGREED TO SELL TO THE CUSTOMER AT ONE PRICE, BUT REPORTED THAT THE BLOCK TRADE WAS EXECUTED AT A DIFFERENT PRICE TO THE EXCHANGE. THIS CONDUCT ALLEGEDLY VIOLATED CBOT RULE 526.F. Initiated By: CHICAGO BAORD OF TRADE Date Initiated: 07/29/2016 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 167 www.finra.org/brokercheck User Guidance

Date Initiated: 07/29/2016 Docket/Case Number: CBOT 149940BC

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

Resolution: Settled Resolution Date: 07/29/2016 Sanctions Ordered: Monetary/Fine $30,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO PAY A FINE OF $30,000.00. i Disclosure 61 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CONDITIONED SETTLEMENT IN A FINRA DISPUTE RESOLUTION ARBITRATION BY INCLUDING A PROVISION IN THE SETTLEMENT AGREEMENT THAT THE FIRM'S FORMER CUSTOMERS AGREE NOT TO OBJECT TO, OR OPPOSE ANY EFFORTS TO SEEK, EXPUNGEMENT OF ALL REFERENCE TO THE ARBITRATION OR CUSTOMER DISPUTE INFORMATION FROM THE CRD SYSTEM. THE FINDINGS STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH FINRA RULE 2081 BY FAILING TO HAVE AN ADEQUATE SYSTEM TO ADDRESS AND TAKE SUFFICIENT STEPS TO ACHIEVE COMPLIANCE WITH THE PROHIBITION IN THE RULE ON CONDITIONING OR SEEKING TO CONDITION SETTLEMENT OF A DISPUTE WITH A CUSTOMER ON THE CUSTOMER'S AGREEMENT TO CONSENT TO, OR NOT TO OPPOSE, EXPUNGEMENT; FAILING TO ENACT ANY PROCEDURES TO ENSURE AND DOCUMENT THAT THE REQUIREMENTS OF FINRA RULE 2081 WERE COMMUNICATED TO RELEVANT STAFF; AND FAILING TO DESIGNATE A SUPERVISOR RESPONSIBLE FOR ENFORCING THE FIRM'S PROCEDURES REGARDING FINRA RULE 2081 AND FOR ESTABLISHING, MAINTAINING OR ©2021 FINRA. All rights reserved. Report aboutTESTING RBC CAPITAL A REASONABLE MARKETS, LLC SUPERVISORY SYSTEM FOR COMPLIANCE WITH 168 FINRA RULE 2081. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 2081, IN WHICH ITS PROCEDURES MERELY RESTATED THE TEXT OF FINRA RULE 2081 AND CERTAIN EXPLANATORY INFORMATION FROM REGULATORY NOTICE 14-31, BUT DID NOT INCLUDE ANY OF THE REQUIRED ELEMENTS FOUND IN WSPS, SUCH AS A DESIGNATED SUPERVISOR RESPONSIBLE FOR CONDUCTING SUPERVISION REGARDING COMPLIANCE WITH RULE 2081; A DESCRIPTION OF THE REVIEW PROCESS THAT SUCH A SUPERVISOR WOULD TAKE TO REVIEW FOR COMPLIANCE; THE FREQUENCY OF SUCH REVIEWS; HOW SUCH REVIEWS WILL BE DOCUMENTED; OR WHAT THE FIRM WILL DO WHEN IT IDENTIFIES DEFICIENCIES IN COMPLIANCE. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CONDITIONED SETTLEMENT IN A FINRA DISPUTE RESOLUTION ARBITRATION BY INCLUDING A PROVISION IN THE SETTLEMENT AGREEMENT THAT THE FIRM'S FORMER CUSTOMERS AGREE NOT TO OBJECT TO, OR OPPOSE ANY EFFORTS TO SEEK, EXPUNGEMENT OF ALL REFERENCE TO THE ARBITRATION OR CUSTOMER DISPUTE INFORMATION FROM THE CRD SYSTEM. THE FINDINGS STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH FINRA RULE 2081 BY FAILING TO HAVE AN ADEQUATE SYSTEM TO ADDRESS AND TAKE SUFFICIENT STEPS TO ACHIEVE COMPLIANCE WITH THE PROHIBITION IN THE RULE ON CONDITIONING OR SEEKING TO CONDITION SETTLEMENT OF A DISPUTE WITH A CUSTOMER ON THE CUSTOMER'S AGREEMENT TO CONSENT TO, OR NOT TO OPPOSE, www.finra.org/brokercheck EXPUNGEMENT; FAILING TO ENACT ANY PROCEDURES TO ENSURE AND User Guidance DOCUMENT THAT THE REQUIREMENTS OF FINRA RULE 2081 WERE COMMUNICATED TO RELEVANT STAFF; AND FAILING TO DESIGNATE A SUPERVISOR RESPONSIBLE FOR ENFORCING THE FIRM'S PROCEDURES REGARDING FINRA RULE 2081 AND FOR ESTABLISHING, MAINTAINING OR TESTING A REASONABLE SUPERVISORY SYSTEM FOR COMPLIANCE WITH FINRA RULE 2081. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 2081, IN WHICH ITS PROCEDURES MERELY RESTATED THE TEXT OF FINRA RULE 2081 AND CERTAIN EXPLANATORY INFORMATION FROM REGULATORY NOTICE 14-31, BUT DID NOT INCLUDE ANY OF THE REQUIRED ELEMENTS FOUND IN WSPS, SUCH AS A DESIGNATED SUPERVISOR RESPONSIBLE FOR CONDUCTING SUPERVISION REGARDING COMPLIANCE WITH RULE 2081; A DESCRIPTION OF THE REVIEW PROCESS THAT SUCH A SUPERVISOR WOULD TAKE TO REVIEW FOR COMPLIANCE; THE FREQUENCY OF SUCH REVIEWS; HOW SUCH REVIEWS WILL BE DOCUMENTED; OR WHAT THE FIRM WILL DO WHEN IT IDENTIFIES DEFICIENCIES IN COMPLIANCE. Initiated By: FINRA Date Initiated: 06/10/2016 Docket/Case Number: 2014043628201

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: 06/10/2016 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: UNDERTAKING: Sanction Details: THE FIRM WAS CENSURED, FINED $125,000, AND UNDERTAKES TO ADOPT AND IMPLEMENT SUPERVISORY SYSTEMS AND WRITTEN PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE REQUIREMENTS OF FINRA RULE 2081. FINE PAID IN FULL ON JULY 1, 2016. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 169 www.finra.org/brokercheck User Guidance THE FIRM WAS CENSURED, FINED $125,000, AND UNDERTAKES TO ADOPT AND IMPLEMENT SUPERVISORY SYSTEMS AND WRITTEN PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE REQUIREMENTS OF FINRA RULE 2081. FINE PAID IN FULL ON JULY 1, 2016. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT RBC CAPITAL MARKETS, LLC VIOLATED FINRA RULE 2010 AND 2081 WHEN MEDIATING A DISPUTE WITH A CLAIMANT ON OCTOBER, 2014 BY INCLUDING A "A TERM OR CONDITION" THAT "CLAIMANTS WILL NOT OPPOSE EXPUNGEMENT" ON A SETTLEMENT AGREEMENT. ADDITIONALLY, IT IS ALLEGED THAT THE FIRM VIOLATED NASD RULE 3010(A) AND FINRA RULES 3110(A) AND 2010 BY FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH FINRA RULE 2081. THE FIRM IS ALSO ALLEGED TO HAVE FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) WHICH SHOULD HAVE INCLUDED A DESIGNATED SUPERVISOR RESPONSIBLE FOR CONDUCTING SUPERVISION REGARDING COMPLIANCE WITH RULE 2081, A DESCRIPTION OF THE REVIEW PROCESS THAT SUCH SUPERVISOR WOULD TAKE TO REVIEW FOR COMPLIANCE, THE FREQUENCY OF SUCH REVIEW, HOW SUCH REVIEWS SHOULD BE DOCUMENTED, AS WELL AS WHAT THE FIRM SHOULD DO WHEN DEFICIENCIES IN COMPLIANCE ARE IDENTIFIED, LEADING TO A VIOLATION OF FINRA RULES 3110(B) AND 2010. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 06/10/2016 Docket/Case Number: 2014043628201

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/10/2016 Sanctions Ordered: Censure Monetary/Fine $125,000.00 Other Sanctions Ordered: THE FIRM WAS CENSURED AND FINED $125,000.00 AND UNDERTAKES TO ADOPT AND IMPLEMENT SUPERVISORY SYSTEMS AND WRITTEN ©2021 FINRA. All rights reserved. Report aboutPROCEDURES RBC CAPITAL REASONABLYMARKETS, LLC DESIGNED TO ACHIEVE COMPLIANCE WITH 170 THE REQUIREMENTS OF FINRA RULE 2081. www.finra.org/brokercheck User Guidance

THE FIRM WAS CENSURED AND FINED $125,000.00 AND UNDERTAKES TO ADOPT AND IMPLEMENT SUPERVISORY SYSTEMS AND WRITTEN PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE REQUIREMENTS OF FINRA RULE 2081. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CONDITIONED SETTLEMENT IN A FINRA DISPUTE RESOLUTION ARBITRATION BY INCLUDING A PROVISION IN THE SETTLEMENT AGREEMENT THAT THE FIRM'S FORMER CUSTOMERS AGREE NOT TO OBJECT TO, OR OPPOSE ANY EFFORTS TO SEEK, EXPUNGEMENT OF ALL REFERENCE TO THE ARBITRATION OR CUSTOMER DISPUTE INFORMATION FROM THE CRD SYSTEM. THE FINDINGS STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH FINRA RULE 2081 BY FAILING TO HAVE AN ADEQUATE SYSTEM TO ADDRESS AND TAKE SUFFICIENT STEPS TO ACHIEVE COMPLIANCE WITH THE PROHIBITION IN THE RULE ON CONDITIONING OR SEEKING TO CONDITION SETTLEMENT OF A DISPUTE WITH A CUSTOMER ON THE CUSTOMER'S AGREEMENT TO CONSENT TO, OR NOT TO OPPOSE, EXPUNGEMENT; FAILING TO ENACT PROCEDURES TO ENSURE AND DOCUMENT THAT THE REQUIREMENTS OF FINRA RULE 2081 WERE COMMUNICATED TO RELEVANT STAFF; AND FAILING TO DESIGNATE A SUPERVISOR RESPONSIBLE FOR ENFORCING THE FIRM'S PROCEDURES REGARDING FINRA RULE 2081 AND FOR ESTABLISHING, MAINTAINING OR TESTING A REASONABLE SUPERVISORY SYSTEM FOR COMPLIANCE WITH FINRA RULE 2081. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 2081, SUCH AS A DESIGNATED SUPERVISOR RESPONSIBLE FOR CONDUCTING SUPERVISION REGARDING COMPLIANCE WITH RULE 2081; A DESCRIPTION OF THE REVIEW PROCESS THAT SUCH A SUPERVISOR WOULD TAKE TO REVIEW FOR COMPLIANCE; THE FREQUENCY OF SUCH REVIEWS; HOW SUCH REVIEWS WILL BE DOCUMENTED; OR WHAT THE FIRM WILL DO WHEN IT IDENTIFIES DEFICIENCIES IN COMPLIANCE. i Disclosure 62 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM TRANSMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. THE FINDINGS STATED THAT THE INACCURATE, INCOMPLETE, OR IMPROPERLY ©2021 FINRA. All rights reserved. Report aboutFORMATTED RBC CAPITAL DATA MARKETS, PREVENTED LLC THE OATS SYSTEM FROM MATCHING THE 171 REPORTS TO THE RELATED TRADE REPORT IN A FINRA TRADE REPORTING FACILITY (TRF). THE FINDINGS ALSO STATED THAT THE FIRM TRANSMITTED TO OATS EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT IT WAS NOT REQUIRED TO REPORT. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED www.finra.org/brokercheck TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM User Guidance TRANSMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. THE FINDINGS STATED THAT THE INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA PREVENTED THE OATS SYSTEM FROM MATCHING THE REPORTS TO THE RELATED TRADE REPORT IN A FINRA TRADE REPORTING FACILITY (TRF). THE FINDINGS ALSO STATED THAT THE FIRM TRANSMITTED TO OATS EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT IT WAS NOT REQUIRED TO REPORT. Initiated By: FINRA Date Initiated: 05/04/2016 Docket/Case Number: 2014043005601

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/04/2016 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 $15,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $15,000.

FINE PAID IN FULL ON JUNE 20, 2016. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT RBC CAPITAL MARKEST, LLC TRANSMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA WHICH PREVENTED THE OATS SYSTEM FROM MATCHING THE REPORTS TO THE RELATED ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 172 TRADE REPORT IN A FINRA TRADE REPORTING FACILITY (TRF). THE FINDINGS ALSO ALLEGED THAT THE FIRM TRANSMITTED TO OATS EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT IT WAS NOT REQUIRED TO REPORT. www.finra.org/brokercheck IT IS ALLEGED THAT RBC CAPITAL MARKEST, LLC TRANSMITTED User Guidance EXECUTION OR COMBINED ORDER/EXECUTION REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA WHICH PREVENTED THE OATS SYSTEM FROM MATCHING THE REPORTS TO THE RELATED TRADE REPORT IN A FINRA TRADE REPORTING FACILITY (TRF). THE FINDINGS ALSO ALLEGED THAT THE FIRM TRANSMITTED TO OATS EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT IT WAS NOT REQUIRED TO REPORT. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 05/04/2016 Docket/Case Number: 2014043005601

Principal Product Type: Other Other Product Type(s): UNSPECIFIED SECURITIES 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: 05/04/2016 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $15,000. Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA WHICH PREVENTED THE OATS SYSTEM FROM MATCHING THE REPORTS TO THE RELATED TRADE REPORT IN A FINRA TRADE REPORTING FACILITY (TRF). THE FIRM ALSO CONSENTED TO THE ENTRY OF FINDINGS THAT THE FIRM TRANSMITTED TO OATS EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT IT WAS NOT REQUIRED TO REPORT. i Disclosure 63 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ©2021 FINRA. All rights reserved. Report aboutIDENTIFY RBC CAPITAL AND APPLYMARKETS, SALES LLC CHARGE DISCOUNTS TO CERTAIN 173 CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS). THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM FAILED TO APPLY SALES CHARGE DISCOUNTS TO 4,399 ELIGIBLE UIT PURCHASES RESULTING IN CUSTOMERS PAYING EXCESSIVE SALES CHARGES OF APPROXIMATELY $502,088.88. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WSPS REASONABLY DESIGNED TO ENSURE CUSTOMERS RECEIVED SALES CHARGE DISCOUNTS ON ALL ELIGIBLE UIT PURCHASES. ALTHOUGH THE FIRM HAD WSPS RELATED TO UIT SALES CHARGE DISCOUNTS, THE FIRM FAILED TO EFFECTIVELY INFORM AND TRAIN REGISTERED REPRESENTATIVES AND SUPERVISORS TO ENSURE THAT REPRESENTATIVES FOLLOWED THESE PROCEDURES AND IDENTIFIED AND APPLIED ALL APPLICABLE DISCOUNTS. www.finra.org/brokercheck User Guidance

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS). THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM FAILED TO APPLY SALES CHARGE DISCOUNTS TO 4,399 ELIGIBLE UIT PURCHASES RESULTING IN CUSTOMERS PAYING EXCESSIVE SALES CHARGES OF APPROXIMATELY $502,088.88. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WSPS REASONABLY DESIGNED TO ENSURE CUSTOMERS RECEIVED SALES CHARGE DISCOUNTS ON ALL ELIGIBLE UIT PURCHASES. ALTHOUGH THE FIRM HAD WSPS RELATED TO UIT SALES CHARGE DISCOUNTS, THE FIRM FAILED TO EFFECTIVELY INFORM AND TRAIN REGISTERED REPRESENTATIVES AND SUPERVISORS TO ENSURE THAT REPRESENTATIVES FOLLOWED THESE PROCEDURES AND IDENTIFIED AND APPLIED ALL APPLICABLE DISCOUNTS. Initiated By: FINRA Date Initiated: 04/04/2016 Docket/Case Number: 2014042542901

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/04/2016 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 $225,000.00 Disgorgement/Restitution Other Sanctions Ordered: PLUS INTEREST ON THE RESTITUTION Sanction Details: THE FIRM WAS CENSURED, FINED $225,000, AND ORDERED TO PAY $502,088.88, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.

FINE PAID IN FULL ON APRIL 11, 2016. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 174 www.finra.org/brokercheck User Guidance THE FIRM WAS CENSURED, FINED $225,000, AND ORDERED TO PAY $502,088.88, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.

FINE PAID IN FULL ON APRIL 11, 2016. i Reporting Source: Firm Current Status: Final Allegations: THE FIRM IS ALLEGED TO HAVE FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS). THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM FAILED TO APPLY SALES CHARGE DISCOUNTS TO 4,399 ELIGIBLE UIT PURCHASES RESULTING IN CUSTOMERS PAYING EXCESSIVE SALES CHARGES OF APPROXIMATELY $502,088.88. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WSPS REASONABLY DESIGNED TO ENSURE CUSTOMERS RECEIVED SALES CHARGE DISCOUNTS ON ALL ELIGIBLE UIT PURCHASES. ALTHOUGH THE FIRM HAD WSPS RELATED TO UIT SALES CHARGE DISCOUNTS, THE FIRM FAILED TO EFFECTIVELY INFORM AND TRAIN REGISTERED REPRESENTATIVES AND SUPERVISORS TO ENSURE THAT REPRESENTATIVES FOLLOWED THESE PROCEDURES AND IDENTIFIED AND APPLIED ALL APPLICABLE DISCOUNTS. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 04/04/2016 Docket/Case Number: 2014042542901

Principal Product Type: Unit Investment Trust(s) 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: 04/04/2016 Sanctions Ordered: Censure Monetary/Fine $225,000.00 Other Sanctions Ordered: RESTITUTION TO AFFECTED CUSTOMERS IN THE TOTAL AMOUNT OF $502,088.88, PLUS INTEREST. Sanction Details: THE FIRM WAS CENSURED, FINED $225,000.00, AND ORDERED TO PAY $502,088.88, PLUS INTEREST IN RESTITUTION TO CUSTOMERS.

©2021Firm StatementFINRA. All rights reserved. Report aboutWITHOUT RBC CAPITAL ADMITTING MARKETS, OR LLC DENYING THE FINDINGS, THE FIRM CONSENTED 175 TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS). www.finra.org/brokercheck User Guidance

Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS). i Disclosure 64 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) S1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES WITHIN THE TIME REQUIRED BY FINRA RULE 6730 AND FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS AND TRACE-ELIGIBLE AGENCY DEBT SECURITIES WITHIN THE TIME REQUIRED BY FINRA RULE 6730. Initiated By: FINRA Date Initiated: 03/31/2016 Docket/Case Number: 2014041197401

Principal Product Type: Debt - Corporate Other Product Type(s): AGENCY DEBT SECURITIES; SECURITIZED PRODUCTS Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/31/2016 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 $40,000.00 Other Sanctions Ordered:

©2021Sanction FINRA. Details: All rights reserved. Report aboutTHE RBC FIRM CAPITAL WAS MARKETS,CENSURED LLC AND FINED $40,000. FINE PAID IN FULL ON MAY 176 3, 2016. www.finra.org/brokercheck User Guidance

Sanction Details: THE FIRM WAS CENSURED AND FINED $40,000. FINE PAID IN FULL ON MAY 3, 2016. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) S1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES WITHIN THE TIME REQUIRED BY FINRA RULE 6730 AND FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS AND TRACE- ELIGIBLE AGENCY DEBT SECURITIES WITHIN THE TIME REQUIRED BY FINRA RULE 6730. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 03/31/2016 Docket/Case Number: 2014041197401

Principal Product Type: Debt - Corporate Other Product Type(s): AGENCY DEBT SECURITIES; SECURITIZED PRODUCTS 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: 03/31/2016 Sanctions Ordered: Censure Monetary/Fine $40,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $40,000.00. Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) S1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES WITHIN THE TIME REQUIRED BY FINRA RULE 6730 AND FAILED TO REPORT TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS AND TRACE-ELIGIBLE AGENCY DEBT SECURITIES WITHIN THE TIME REQUIRED BY FINRA RULE 6730.

i Disclosure 65 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASAA COORDINATED INVESTIGATION DETERMINED THAT CLIENT ASSOCIATES WERE NOT PROPERLY REGISTERED TO SELL SECURITIES. Initiated By: OKLAHOMA DEPARTMENT OF SECURITIES Date Initiated: 03/17/2016 Docket/Case Number: 14-078 URL for Regulatory Action: 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: 03/17/2016 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 $41,520.17 Other Sanctions Ordered: UNDERTAKINGS TO COMPLY WITH REGISTRATION PROVISIONS Sanction Details: FINE PAID IN FULL i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ©2021 FINRA. All rights reserved. Report aboutESTABLISH RBC CAPITAL AND MARKETS, ENFORCE LLC AN ADEQUATE SYSTEM TO MONITOR THE 178 LICENSING STATUS OF SUCH EMPLOYEES. www.finra.org/brokercheck User Guidance IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF OKLAHOMA DEPARTMENT OF SECURITIES Date Initiated: 03/17/2016 Docket/Case Number: 14-078

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 03/17/2016 Sanctions Ordered: Monetary/Fine $41,520.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 1-402(A) OF THE OKLAHOMA UNIFORM SECURITIES ACT OF 2004. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 66 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 179 www.finra.org/brokercheck User Guidance

Disclosure 66 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO AMEND, OR TIMELY AMEND, THE FORMS U4 FOR REGISTERED REPRESENTATIVES TO REPORT UNSATISFIED TAX LIENS AND CIVIL JUDGMENTS. THE FINDINGS STATED THAT THE FIRM RECEIVED WAGE GARNISHMENT ORDERS FROM COURTS AND TAX AUTHORITIES (INCLUDING THE IRS) RESULTING FROM TAX LEVIES, CIVIL JUDGMENTS, AND SIMILAR ACTIONS, FOR REGISTERED REPRESENTATIVES. THE FIRM, HOWEVER, FAILED TO CONSISTENTLY CONDUCT A SUFFICIENT INQUIRY TO DETERMINE IF THE UNDERLYING EVENT TRIGGERING EACH GARNISHMENT ORDER INVOLVED AN EVENT THAT SHOULD HAVE BEEN REPORTED ON THE AFFECTED INDIVIDUAL'S FORM U4. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WSPS REASONABLY DESIGNED TO ENSURE THAT IT DISCLOSED REPORTABLE UNSATISFIED LIENS AND JUDGMENTS OF REGISTERED REPRESENTATIVES ON FORMS U4, IN INSTANCES IN WHICH A GARNISHMENT NOTICE WAS SENT TO THE FIRM. Initiated By: FINRA Date Initiated: 03/01/2016 Docket/Case Number: 2013039474902

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/01/2016 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 ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine RBC CAPITAL $300,000.00 MARKETS, LLC 180 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $300,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $300,000, AND REQUIRED TO PROVIDE TO FINRA A WRITTEN CERTIFICATION THAT THE FIRM'S SYSTEMS, POLICIES AND PROCEDURES REGARDING THE REVIEW AND DISCLOSURE OF REPORTABLE UNSATISFIED LIENS AND JUDGMENTS OF REGISTERED REPRESENTATIVES ON FORMS U4, IN INSTANCES WHERE A GARNISHMENT NOTICE IS RECEIVED BY THE FIRM, ARE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH ARTICLE V, SECTION 2(C) OF FINRA'S BY-LAWS. FINE PAID IN FULL ON JULY 12, 2016. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT RBC CAPITAL MARKETS, LLC ("THE FIRM") FAILED TO AMEND, OR TIMELY AMEND, THE FORMS U4 FOR REGISTERED REPRESENTATIVES TO REPORT UNSATISFIED TAX LIENS AND CIVIL JUDGMENTS. THE FINDINGS STATE THAT THE FIRM RECEIVED WAGE GARNISHMENT ORDERS FROM COURTS AND TAX AUTHORITIES (INCLUDING THE IRS) RESULTING FROM TAX LEVIES, CIVIL JUDGMENTS, AND SIMILAR ACTIONS, FOR REGISTERED REPRESENTATIVES. THE FIRM HOWEVER IS ALLEGED TO HAVE FAILED TO CONSISTENTLY CONDUCT A SUFFICIENT INQUIRY TO DETERMINE IF THE UNDERLYING EVENT TRIGGERING EACH GARNISHMENT ORDER INVOLVED AN EVENT THAT SHOULD HAVE BEEN REPORTED ON THE AFFECTED INDIVIDUAL'S FORM U4. THE FINDINGS ALSO ALLEGED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WSPS REASONABLY DESIGNED TO ENSURE THAT IT DISCLOSED REPORTABLE UNSATISFIED LIENS AND JUDGMENTS OF REGISTERED REPRESENTATIVES ON FORMS U4, IN INSTANCES IN WHICH A GARNISHMENT NOTICE WAS SENT TO THE FIRM. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 03/01/2016 Docket/Case Number: 2013039474902

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: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 181 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/01/2016 Sanctions Ordered: Censure Monetary/Fine $300,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $300,000, AND REQUIRED TO PROVIDE TO FINRA A WRITTEN CERTIFICATION THAT THE FIRM'S SYSTEMS, POLICIES AND PROCEDURES REGARDING THE REVIEW AND DISCLOSURE OF REPORTABLE UNSATISFIED AND JUDGMENTS OF REGISTERED REPRESENTATIVES ON FORMS U4, IN INSTANCES WHERE A GARNISHMENT NOTICE IS RECEIVED BY THE FIRM, ARE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH ARTICLE V, SECTION 2(C) OF FINRA'S BY-LAWS. Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO AMEND, OR TIMELY AMEND, THE FORMS U4 FOR REGISTERED REPRESENTATIVES TO REPORT UNSATISFIED TAX LIENS AND CIVIL JUDGMENTS BETWEEN JANUART 1, 2013 THROUGH JUNE 30, 2015. i Disclosure 67 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC ("RBC"), AN EXCHANGE TPH ORGANIZATION, WAS CENSURED AND FINED $75,000 FOR: (I) FAILING TO PROPERLY CLOSE OUT A FAIL-TO-DELIVER POSITION IN SEVEN SAMPLED SECURITIES, INCLUDING SANOMEDICS INTERNATIONAL HOLDINGS INC. ("SIMH"), APPLIED DNA SCIENCES INC. ("APDN"), GREAT ATLANTIC AND PACIFIC TEA CO. INC. ("GAPTQ"), QUAMTEL INC. ("QUMI"), TITAN IRON ORE CORP. ("TFER"), JINKOSOLAR HOLDING CO., LTD. ("JKS"), AND ITT EDUCATIONAL SERVICES, INC. ("ESI"); (II) INCREASING ITS SHORT POSITION WHEN A FAIL- TO-DELIVER POSITION HAD NOT BEEN PROPERLY CLOSED OUT WITHOUT DEMONSTRATING THAT IT MADE ARRANGEMENTS FOR PRE-BORROWING IN THE FOLLOWING EQUITY SECURITIES: APDN, QUMI, TFER, GAPTQ, AND JKS; AND (III) FAILING TO SUPERVISE ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH REGULATION SHO RULE 204 AS: (1) RBC FAILED TO ASSURE THAT NUMEROUS FAIL-TO-DELIVER POSITIONS WERE CLOSED OUT ON A TIMELY BASIS; AND (2) RBC IMPROPERLY ASSERTED RELIANCE ON CERTAIN EXEMPTIONS UNDER REG. SHO RULE 204 ©2021 FINRA. All rights reserved. Report aboutWITHOUT RBC CAPITAL UNDERTAKING MARKETS, LLC SUFFICIENT DUE DILIGENCE TO ASCERTAIN AND 182 DOCUMENT THAT SPECIFIC REQUIREMENTS THEREUNDER WERE MET. (EXCHANGE RULE 4.2 - ADHERENCE TO LAW; AND REGULATION SHO RULE 204 - CLOSE-OUT REQUIREMENT, PROMULGATED UNDER THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED) RBC CAPITAL MARKETS, LLC ("RBC"), AN EXCHANGE TPH ORGANIZATION, WAS CENSURED AND FINED $75,000 FOR: (I) FAILING TO PROPERLY CLOSE OUT A FAIL-TO-DELIVER POSITION IN SEVEN SAMPLED SECURITIES, INCLUDING SANOMEDICS INTERNATIONAL HOLDINGS INC. ("SIMH"), APPLIED DNA SCIENCES INC. ("APDN"), GREAT ATLANTIC AND PACIFIC TEA CO. INC. ("GAPTQ"), QUAMTEL INC. ("QUMI"), TITAN IRON ORE CORP. ("TFER"), JINKOSOLAR HOLDING CO., LTD. ("JKS"), AND ITT EDUCATIONAL SERVICES, INC. ("ESI"); (II) INCREASING ITS SHORT POSITION WHEN A FAIL- TO-DELIVER POSITION HAD NOT BEEN PROPERLY CLOSED OUT WITHOUT DEMONSTRATING THAT IT MADE ARRANGEMENTS FOR PRE-BORROWING IN THE FOLLOWING EQUITY SECURITIES: APDN, QUMI, TFER, GAPTQ, AND www.finra.org/brokercheck JKS; AND (III) FAILING TO SUPERVISE ITS ASSOCIATED PERSONS TO User Guidance ASSURE COMPLIANCE WITH REGULATION SHO RULE 204 AS: (1) RBC FAILED TO ASSURE THAT NUMEROUS FAIL-TO-DELIVER POSITIONS WERE CLOSED OUT ON A TIMELY BASIS; AND (2) RBC IMPROPERLY ASSERTED RELIANCE ON CERTAIN EXEMPTIONS UNDER REG. SHO RULE 204 WITHOUT UNDERTAKING SUFFICIENT DUE DILIGENCE TO ASCERTAIN AND DOCUMENT THAT SPECIFIC REQUIREMENTS THEREUNDER WERE MET. (EXCHANGE RULE 4.2 - ADHERENCE TO LAW; AND REGULATION SHO RULE 204 - CLOSE-OUT REQUIREMENT, PROMULGATED UNDER THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED) Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 11/11/2015 Docket/Case Number: 15-0093/ 20150459684

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: 04/11/2016 Sanctions Ordered: Censure Monetary/Fine $75,000.00 Other Sanctions Ordered: Sanction Details: A $75,000 FINE AND A CENSURE. i Reporting Source: Firm Current Status: Final Allegations: FROM IN OR ABOUT DECEMBER 2011 THROUGH IN OR ABOUT MARCH 2012, RBC CAPITAL MARKETS, LLC ("RBCCM") IS ALLEGED TO HAVE FAILED TO PROPERLY CLOSE OUT A FAIL-TO-DELIVER POSITION IN SEVEN SAMPLED EQUITY SECURITIES. FROM IN OR ABOUT DECEMBER 2011 THROUGH IN OR ABOUT MARCH 2012, RBCCM IS ALLEGED TO HAVE INCREASED ITS SHORT POSITION WHEN A FAIL-TO- DELIVER POSITION HAD NOT BEEN PROPERLY CLOSED OUT WITHOUT DEMONSTRATING THAT IT MADE ARRANGEMENTS FOR PRE-BORROWING IN SPECIFIC EQUITY SECURITIES. FROM IN OR ABOUT DECEMBER 2011 THROUGH IN OR ABOUT MARCH 2012, RBCCM IS ALLEGED TO HAVE FAILED TO SUPERVISE ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH REGULATION SHO RULE 204 IN THAT IT: (1) FAILED TO ASSURE THAT NUMEROUS FAIL-TO-DELIVER POSITIONS WERE CLOSED ©2021 FINRA. All rights reserved. Report aboutOUT RBC ON CAPITAL A TIMELY MARKETS, BASIS; LLC AND (2) IMPROPERLY ASSERTED RELIANCE ON 183 CERTAIN EXEMPTIONS UNDER REG. SHO RULE 204 WITHOUT UNDERTAKING SUFFICIENT DUE DILIGENCE TO ASCERTAIN AND DOCUMENT THAT SPECIFIC REQUIREMENTS THEREUNDER WERE MET. FROM IN OR ABOUT DECEMBER 2011 THROUGH IN OR ABOUT MARCH 2012, RBC CAPITAL MARKETS, LLC ("RBCCM") IS ALLEGED TO HAVE FAILED TO PROPERLY CLOSE OUT A FAIL-TO-DELIVER POSITION IN SEVEN SAMPLED EQUITY SECURITIES. FROM IN OR ABOUT DECEMBER 2011 THROUGH IN OR ABOUT MARCH 2012, RBCCM IS ALLEGED TO HAVE INCREASED ITS SHORT POSITION WHEN A FAIL-TO- DELIVER POSITION HAD NOT BEEN PROPERLY CLOSED OUT WITHOUT DEMONSTRATING THAT IT MADE ARRANGEMENTS FOR PRE-BORROWING www.finra.org/brokercheck IN SPECIFIC EQUITY SECURITIES. FROM IN OR ABOUT DECEMBER 2011 User Guidance THROUGH IN OR ABOUT MARCH 2012, RBCCM IS ALLEGED TO HAVE FAILED TO SUPERVISE ITS ASSOCIATED PERSONS TO ASSURE COMPLIANCE WITH REGULATION SHO RULE 204 IN THAT IT: (1) FAILED TO ASSURE THAT NUMEROUS FAIL-TO-DELIVER POSITIONS WERE CLOSED OUT ON A TIMELY BASIS; AND (2) IMPROPERLY ASSERTED RELIANCE ON CERTAIN EXEMPTIONS UNDER REG. SHO RULE 204 WITHOUT UNDERTAKING SUFFICIENT DUE DILIGENCE TO ASCERTAIN AND DOCUMENT THAT SPECIFIC REQUIREMENTS THEREUNDER WERE MET. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED ("CBOE") Date Initiated: 11/11/2015 Docket/Case Number: 15-0093/20150459684

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: 04/11/2016 Sanctions Ordered: Censure Monetary/Fine $75,000.00 Other Sanctions Ordered: Sanction Details: A $75,000 FINE AND A CENSURE Firm Statement WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND AGREED TO PAY A FINE OF $75,000. i Disclosure 68 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ON 13 OCCASIONS, THE FIRM VIOLATED NYSE RULE 92(A) BY ENTERING A PROPRIETARY ORDER TO BUY OR SELL AN NYSE-LISTED SECURITY WHILE KNOWINGLY IN POSSESSION OF A CUSTOMER ORDER TO BUY OR SELL SUCH SECURITY THAT COULD BE EXECUTED AT THE SAME PRICE, AND WHICH PROPRIETARY ORDER THEN TRADED ALONG WITH, OR AHEAD OF, ©2021 FINRA. All rights reserved. Report aboutTHE RBC CUSTOMER CAPITAL MARKETS, ORDER, LLC OR TRADED OUTSIDE OF THE CUSTOMER'S 184 CONSENT PARAMETERS. THE FINDINGS STATED THAT ON TWO OCCASIONS, THE FIRM VIOLATED NYSE RULE 2010 BY FAILING TO DOCUMENT CUSTOMER CONSENT TO THE ALLOCATION SPLIT AS REQUIRED BY NYSE RULE 92(B). THE FINDINGS ALSO STATED THAT THE FIRM VIOLATED NYSE RULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE AND IMPLEMENT ADEQUATE CONTROLS, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN NYSE RULES AND POLICIES, INCLUDING WITH RESPECT TO TRANSMITTING AND EXECUTING PROPRIETARY AND AGENCY TRADES ON THE NYSE. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ON 13 OCCASIONS, THE FIRM VIOLATED NYSE RULE 92(A) BY ENTERING A www.finra.org/brokercheck PROPRIETARY ORDER TO BUY OR SELL AN NYSE-LISTED SECURITY WHILE User Guidance KNOWINGLY IN POSSESSION OF A CUSTOMER ORDER TO BUY OR SELL SUCH SECURITY THAT COULD BE EXECUTED AT THE SAME PRICE, AND WHICH PROPRIETARY ORDER THEN TRADED ALONG WITH, OR AHEAD OF, THE CUSTOMER ORDER, OR TRADED OUTSIDE OF THE CUSTOMER'S CONSENT PARAMETERS. THE FINDINGS STATED THAT ON TWO OCCASIONS, THE FIRM VIOLATED NYSE RULE 2010 BY FAILING TO DOCUMENT CUSTOMER CONSENT TO THE ALLOCATION SPLIT AS REQUIRED BY NYSE RULE 92(B). THE FINDINGS ALSO STATED THAT THE FIRM VIOLATED NYSE RULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE AND IMPLEMENT ADEQUATE CONTROLS, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN NYSE RULES AND POLICIES, INCLUDING WITH RESPECT TO TRANSMITTING AND EXECUTING PROPRIETARY AND AGENCY TRADES ON THE NYSE. Initiated By: NYSE MKT LLC Date Initiated: 08/28/2015 Docket/Case Number: 2013039452701

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: 08/28/2015 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 $80,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $80,000. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED ©2021 FINRA. All rights reserved. Report aboutTO THE RBC CAPITALSANCTIONS MARKETS, AND LLC TO THE ENTRY OF FINDINGS THAT ON 13 185 OCCASIONS, THE FIRM VIOLATED NYSE RULE 92(A) BY ENTERING A PROPRIETARY ORDER TO BUY OR SELL AN NYSE-LISTED SECURITY WHILE KNOWINGLY IN POSSESSION OF A CUSTOMER ORDER TO BUY OR SELL SUCH SECURITY THAT COULD BE EXECUTED AT THE SAME PRICE, AND WHICH PROPRIETARY ORDER THEN TRADED ALONG WITH, OR AHEAD OF, THE CUSTOMER ORDER, OR TRADED OUTSIDE OF THE CUSTOMER'S CONSENT PARAMETERS. THE FINDINGS STATED THAT ON TWO OCCASIONS, THE FIRM VIOLATED NYSE RULE 2010 BY FAILING TO DOCUMENT CUSTOMER CONSENT TO THE ALLOCATION SPLIT AS REQUIRED BY NYSE RULE 92(B). THE FINDINGS ALSO STATED THAT THE FIRM VIOLATED NYSE RULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE AND IMPLEMENT ADEQUATE CONTROLS, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN NYSE RULES AND POLICIES, INCLUDING WITH RESPECT TO TRANSMITTING AND EXECUTING PROPRIETARY AND AGENCY TRADES ON THE NYSE. www.finra.org/brokercheck User Guidance

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ON 13 OCCASIONS, THE FIRM VIOLATED NYSE RULE 92(A) BY ENTERING A PROPRIETARY ORDER TO BUY OR SELL AN NYSE-LISTED SECURITY WHILE KNOWINGLY IN POSSESSION OF A CUSTOMER ORDER TO BUY OR SELL SUCH SECURITY THAT COULD BE EXECUTED AT THE SAME PRICE, AND WHICH PROPRIETARY ORDER THEN TRADED ALONG WITH, OR AHEAD OF, THE CUSTOMER ORDER, OR TRADED OUTSIDE OF THE CUSTOMER'S CONSENT PARAMETERS. THE FINDINGS STATED THAT ON TWO OCCASIONS, THE FIRM VIOLATED NYSE RULE 2010 BY FAILING TO DOCUMENT CUSTOMER CONSENT TO THE ALLOCATION SPLIT AS REQUIRED BY NYSE RULE 92(B). THE FINDINGS ALSO STATED THAT THE FIRM VIOLATED NYSE RULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE AND IMPLEMENT ADEQUATE CONTROLS, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN NYSE RULES AND POLICIES, INCLUDING WITH RESPECT TO TRANSMITTING AND EXECUTING PROPRIETARY AND AGENCY TRADES ON THE NYSE. Initiated By: NYSE MKT LLC Date Initiated: 08/28/2015 Docket/Case Number: 2013039452701

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/28/2015 Sanctions Ordered: Censure Monetary/Fine $80,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $80,000.00 i Disclosure 69 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED ©2021 FINRA. All rights reserved. Report aboutTO THE RBC CAPITALSANCTIONS MARKETS, AND LLC TO THE ENTRY OF FINDINGS THAT IT FAILED TO 186 TRANSMIT 1,183,844,292 REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) ON 589 BUSINESS DAYS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS AND FINRA RULES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE WSPS REGARDING OATS REPORTING. www.finra.org/brokercheck User Guidance

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO TRANSMIT 1,183,844,292 REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) ON 589 BUSINESS DAYS. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS AND FINRA RULES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE WSPS REGARDING OATS REPORTING. Initiated By: FINRA Date Initiated: 07/27/2015 Docket/Case Number: 2013037784601

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/27/2015 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 $450,000.00 Other Sanctions Ordered: UNDERTAKINGS: REQUIRED TO REVISE ITS WSPS Sanction Details: THE FIRM WAS CENSURED, FINED $450,000 AND UNDERTAKES TO REVISE ITS WSPS.

FINE PAID IN FULL ON AUGUST 18, 2015. Regulator Statement THE FIRM SELF-REPORTED TO FINRA IN JULY 2013 THAT IT HAD FAILED TO SUBMIT A PORTION OF ITS OATS-REPORTABLE ACTIVITY, AS WELL AS OATS-REPORTABLE ACTIVITY OF AN AFFILIATED BROKER-DEALER. THE FIRM FURTHER UNDERTOOK STEPS TO REMEDIATE THE ISSUE, ©2021 FINRA. All rights reserved. Report aboutINCLUDING RBC CAPITAL THE MARKETS, ENGAGEMENT LLC OF AN EXTERNAL CONSULTING FIRM, TO 187 ASSESS AND EVALUATE THE CORRECTIVE ACTIONS TAKEN FOR THE ISSUE THAT LED TO THE JULY 2013 SELF-REPORT AND, IN THE COURSE OF THAT ENGAGEMENT, IDENTIFIED AND REPORTED TO THE STAFF ADDITIONAL OATS REPORTING ISSUES AFFECTING BOTH THE FIRM'S REPORTING TO OATS AND THE REPORTING FOR ITS AFFILIATE. THE SANCTIONS TAKE INTO CONSIDERATION THE FIRM'S INITIAL AND SUBSEQUENT SELF-REPORTING TO THE STAFF AND THE REMEDIAL MEASURES TAKEN BY THE FIRM TO ADDRESS THE OATS REPORTING ISSUES. www.finra.org/brokercheck THE FIRM SELF-REPORTED TO FINRA IN JULY 2013 THAT IT HAD FAILED TO User Guidance SUBMIT A PORTION OF ITS OATS-REPORTABLE ACTIVITY, AS WELL AS OATS-REPORTABLE ACTIVITY OF AN AFFILIATED BROKER-DEALER. THE FIRM FURTHER UNDERTOOK STEPS TO REMEDIATE THE ISSUE, INCLUDING THE ENGAGEMENT OF AN EXTERNAL CONSULTING FIRM, TO ASSESS AND EVALUATE THE CORRECTIVE ACTIONS TAKEN FOR THE ISSUE THAT LED TO THE JULY 2013 SELF-REPORT AND, IN THE COURSE OF THAT ENGAGEMENT, IDENTIFIED AND REPORTED TO THE STAFF ADDITIONAL OATS REPORTING ISSUES AFFECTING BOTH THE FIRM'S REPORTING TO OATS AND THE REPORTING FOR ITS AFFILIATE. THE SANCTIONS TAKE INTO CONSIDERATION THE FIRM'S INITIAL AND SUBSEQUENT SELF-REPORTING TO THE STAFF AND THE REMEDIAL MEASURES TAKEN BY THE FIRM TO ADDRESS THE OATS REPORTING ISSUES. i Reporting Source: Firm Current Status: Final Allegations: THE FIRM SELF-REPORTED AN ORDER AUDIT TRAIL SYSTEM ("OATS") REPORTING SYSTEM LOGIC CHANGE IMPLEMENTED IN JANUARY 2012 MAY HAVE CAUSED THE FIRM'S SYSTEM TO CEASE REPORTING REPORTABLE ORDER EVENTS ("ROES"), WHICH AFFECTED APPROXIMATELY 500 MILLION ROES, THEREFORE POTENTIALLY VIOLATING NASD RULE 3010, FINRA RULE 2010, AND FINRA RULE 7450. AFTER IMPLEMENTING A SYSTEM FIX, THE FIRM ENGAGED AN EXTERNAL CONSULTING FIRM TO ASSESS AND EVALUATE THE EFFICACY OF ITS CORRECTIVE ACTIONS. ADDITIONAL OATS REPORTING ISSUES WERE IDENTIFIED AND SUBMITTED VIA SELF-REPORT IN MARCH 2014. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 07/27/2015 Docket/Case Number: 20130377846-01

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/27/2015 Sanctions Ordered: Censure Monetary/Fine $450,000.00 Other Sanctions Ordered: THE FIRM UNDERTAKES TO REVISE THE FIRM'S WRITTEN SUPERVISORY ©2021 FINRA. All rights reserved. Report aboutPROCEDURES RBC CAPITAL WITHMARKETS, RESPECT LLC TO OATS REPORTING [CATEGORIES (B),(C), 188 AND (D)] www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: THE FIRM UNDERTAKES TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO OATS REPORTING [CATEGORIES (B),(C), AND (D)] Sanction Details: $325,000.00 FOR THE RULE 7450 VIOLATIONS AND $125,000.00 FOR THE SUPERVISION VIOLATIONS Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM FAILED TO TRANSMIT TO OATS 1,183,844,292 ROES OVER A PERIOD CONSTITUTING APPROXIMATELY 28 MONTHS, THEREFORE VIOLATING FINRA RULE 7450, FINRA RULE 2010, AND NASD RULE 3010. i Disclosure 70 of 336 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASES 33-9839; 34-75233, JUNE 18, 2015: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST RBC CAPITAL MARKERS, LLC ("RESPONDENT"). RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAIN MUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF- REPORTED BY RESPONDENT TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 06/18/2015 Docket/Case Number: 3-16632

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 189 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 06/18/2015 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 $500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKINGS Sanction Details: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 AND COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. Regulator Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT RESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OF THE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THE SECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 190 IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT RESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OF THE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THIS www.finra.org/brokercheck ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THE User Guidance SECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE. i Reporting Source: Firm Current Status: Final Allegations: SEC ADMIN RELEASES 339839;3475233,JUNE 18, 2015: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST RBC CAPITAL MARKERS, LLC ("THE FIRM"). THE FIRM WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH THE FIRM'S UNDERWRITING OF CERTAIN MUNICIPAL SECURITIES OFFERINGS. THE FIRM, A REGISTERED BROKER DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN THE FIRM OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY THE FIRM TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 06/18/2015 Docket/Case Number: 3-16632

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief MONETARY PENALTY Sought:

Resolution: Order Resolution Date: 06/18/2015 Sanctions Ordered: Monetary/Fine $500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKINGS ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 191 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: UNDERTAKINGS Sanction Details: RBC CAPITAL MARKETS, LLC SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 AND COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. Firm Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RBC CAPITAL MARKETS, LLC ("THE FIRM") HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER THE FIRM AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTSTO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE- AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE FIRM'S OFFER. THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OF THE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THE SECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE. i Disclosure 71 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF MARYLAND SECURITIES DIVISION

Date Initiated: 03/18/2015 Docket/Case Number: 2014-0094

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 03/18/2015 Sanctions Ordered: Monetary/Fine $48,580.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN, POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM THE JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 11-402(A)(1) AND SECTION 11-412(A)(10) OF THE MARYLAND SECURITIES ACT, CORPORATIONS AND ASSOCIATIONS ARTICLE, TITLE 11, ANNOTATED CODE OF MARYLAND (2014 REPL. VOL.). Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH THE APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 72 of 336 Reporting Source: Regulator

Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO HAVE IN PLACE SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND ITS INTERNAL GUIDELINES CONCERNING THE SUITABILITY OF REVERSE CONVERTIBLES. REVERSE CONVERTIBLES, A COMPLEX STRUCTURED PRODUCT, ARE INTEREST-BEARING NOTES IN WHICH PRINCIPAL REPAYMENT IS LINKED TO THE PERFORMANCE OF A REFERENCE ASSET, OFTEN A STOCK, A BASKET OF STOCKS OR AN INDEX. THE REFERENCE ASSET IS GENERALLY UNRELATED TO THE ISSUER OF THE NOTE. REVERSE CONVERTIBLES ARE NOT SUITABLE FOR EVERY CUSTOMER. IN FEBRUARY 2010, FINRA ISSUED NTM 10-09 THAT IS SPECIFIC TO REVERSE CONVERTIBLES AND REITERATES THE NEED FOR FIRMS TO PERFORM REASONABLE BASIS SUITABILITY AS WELL AS CUSTOMER SPECIFIC SUITABILITY ANALYSES IN CONNECTION WITH THE SALES OF REVERSE CONVERTIBLES. SPECIFICALLY AS TO THE FIRM, IT OFFERED AT LEAST 3,000 DIFFERENT REVERSE CONVERTIBLE PRODUCTS TO ITS CUSTOMERS. THE FIRM EFFECTED THROUGH APPROXIMATELY 360 OF ITS REGISTERED REPRESENTATIVES IN EXCESS OF 100,000 TRANSACTIONS WITH REVERSE CONVERTIBLE IN AT LEAST 5,000 CUSTOMER ACCOUNTS. HOWEVER, THE FIRM DID NOT HAVE IN PLACE SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS, NASD/FINRA RULES AND ITS OWN WRITTEN SUPERVISORY PROCEDURES ("WSPS") IN CONNECTION WITH ITS SALE OF REVERSE CONVERTIBLES. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM AND PROCEDURES DID NOT ADEQUATELY IDENTIFY TRANSACTIONS FOR RESPONSIBLE SUPERVISORY PERSONNEL WHEN REVERSE CONVERTIBLES WERE SOLD TO CUSTOMERS IN VIOLATION OF THE FIRM'S SUITABILITY GUIDELINES, INCLUDING THOSE RELATED TO CUSTOMER INVESTMENT OBJECTIVES, ANNUAL INCOME, NET WORTH AND LIQUID NET WORTH. FOR A PERIOD OF AT LEAST FIVE YEARS THE FIRM'S ELECTRONIC SURVEILLANCE SYSTEMS DID NOT REVIEW TRANSACTIONS FOR COMPLIANCE WITH THE REQUIREMENTS AND GUIDELINES OF ITS WSPS APPLICABLE TO REVERSE CONVERTIBLES. THE FIRM BEGAN ISSUING TO THE FIRM'S COMPLEX DIRECTORS A QUARTERLY EXCEPTION REPORT FOR REVERSE CONVERTIBLE TRANSACTIONS. HOWEVER, THE QUARTERLY REPORT WAS ALSO AN INEFFECTIVE SUPERVISORY TOOL GIVEN THAT IT WAS CREATED AND REVIEWED ONLY AFTER THE TRANSACTIONS HAD BEEN EFFECTED. IN ADDITION, THIS REPORT WAS ISSUED ONLY ON A QUARTERLY BASIS, THEREBY ALLOWING POTENTIALLY NON-COMPLIANT TRANSACTIONS TO REMAIN IN EFFECT WITHOUT REVIEW FOR UP TO THREE MONTHS AFTER THEY WERE EFFECTED. ADDITIONALLY, THE FIRM LACKED ANY WRITTEN ESCALATION ©2021 FINRA. All rights reserved. Report aboutPROCEDURES RBC CAPITAL REQUIRINGMARKETS, LLC NOTIFICATION AND/OR CONSULTATION WITH 194 THE FIRM'S COMPLIANCE DEPARTMENT WHEN POTENTIALLY VIOLATIVE TRANSACTIONS WERE IDENTIFIED. THE FIRM FAILED TO ENSURE THAT IT IMPLEMENTED REASONABLY DESIGNED SYSTEMS AND PROCEDURES TO FLAG FOR ITS SUPERVISORY PERSONNEL POTENTIALLY UNSUITABLE TRANSACTIONS IN REVERSE CONVERTIBLES AND ENSURE THAT ITS REGISTERED PERSONS WERE ADEQUATELY TRAINED REGARDING THE RISKS ASSOCIATED WITH REVERSE CONVERTIBLES AND THE CUSTOMERS FOR WHOM SUCH INVESTMENTS WERE SUITABLE. THE FINDINGS ALSO STATED THAT GIVEN THE NATURE OF THE REVERSE CONVERTIBLE PRODUCT, THESE TRANSACTIONS EXPOSED CUSTOMERS TO A RISK OF LOSS THAT WAS INCONSISTENT WITH THEIR RISK TOLERANCE, INVESTMENT OBJECTIVES AND FINANCIAL STATUS AND THE FIRM DID NOT HAVE REASONABLE GROUNDS TO BELIEVE THAT THE RECOMMENDATION AND SALE OF REVERSE CONVERTIBLES WERE SUITABLE FOR THESE CUSTOMERS. MOREOVER, THE GUIDELINES ARTICULATED IN THE FIRM'S OWN WSPS ESTABLISH THAT REVERSE CONVERTIBLES SHOULD NOT HAVE BEEN SOLD TO THESE CUSTOMERS. CONSEQUENTLY, THE FIRM'S SUPERVISORS FAILED TO DETECT THE SALE BY ITS REGISTERED REPRESENTATIVES OF REVERSE CONVERTIBLE TRANSACTIONS IN SEVERAL CUSTOMERS' ACCOUNTS THAT WERE UNSUITABLE FOR THOSE CUSTOMERS. THESE CUSTOMERS INCURRED LOSSES TOTALING AT LEAST $1.1 MILLION. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO HAVE IN PLACE SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND ITS INTERNAL GUIDELINES CONCERNING THE SUITABILITY OF REVERSE CONVERTIBLES. REVERSE CONVERTIBLES, A COMPLEX STRUCTURED PRODUCT, ARE INTEREST-BEARING NOTES IN WHICH PRINCIPAL REPAYMENT IS LINKED TO THE PERFORMANCE OF A REFERENCE ASSET, OFTEN A STOCK, A BASKET OF STOCKS OR AN INDEX. THE REFERENCE ASSET IS GENERALLY UNRELATED TO THE ISSUER OF THE NOTE. REVERSE CONVERTIBLES ARE NOT SUITABLE FOR EVERY CUSTOMER. IN FEBRUARY 2010, FINRA ISSUED NTM 10-09 THAT IS SPECIFIC TO REVERSE CONVERTIBLES AND REITERATES THE NEED FOR FIRMS TO PERFORM REASONABLE BASIS SUITABILITY AS WELL AS CUSTOMER SPECIFIC SUITABILITY ANALYSES IN CONNECTION WITH THE SALES OF REVERSE CONVERTIBLES. SPECIFICALLY AS TO THE FIRM, IT OFFERED AT LEAST 3,000 DIFFERENT REVERSE CONVERTIBLE PRODUCTS TO ITS CUSTOMERS. THE FIRM EFFECTED THROUGH APPROXIMATELY 360 OF ITS REGISTERED REPRESENTATIVES IN EXCESS OF 100,000 TRANSACTIONS WITH REVERSE CONVERTIBLE IN AT LEAST 5,000 CUSTOMER ACCOUNTS. HOWEVER, THE FIRM DID NOT HAVE IN PLACE SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS, NASD/FINRA RULES AND ITS OWN WRITTEN SUPERVISORY PROCEDURES ("WSPS") IN CONNECTION WITH ITS SALE OF REVERSE CONVERTIBLES. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM AND PROCEDURES DID NOT ADEQUATELY IDENTIFY TRANSACTIONS FOR RESPONSIBLE SUPERVISORY PERSONNEL WHEN REVERSE CONVERTIBLES WERE SOLD TO CUSTOMERS IN VIOLATION OF THE FIRM'S SUITABILITY GUIDELINES, INCLUDING THOSE RELATED TO CUSTOMER INVESTMENT OBJECTIVES, ANNUAL INCOME, NET WORTH AND LIQUID NET WORTH. FOR A PERIOD OF AT LEAST FIVE YEARS THE FIRM'S ELECTRONIC SURVEILLANCE SYSTEMS DID NOT REVIEW TRANSACTIONS FOR COMPLIANCE WITH THE REQUIREMENTS AND GUIDELINES OF ITS WSPS APPLICABLE TO REVERSE CONVERTIBLES. THE FIRM BEGAN ISSUING TO THE FIRM'S COMPLEX DIRECTORS A QUARTERLY EXCEPTION REPORT FOR REVERSE CONVERTIBLE TRANSACTIONS. HOWEVER, THE QUARTERLY REPORT WAS ALSO AN INEFFECTIVE SUPERVISORY TOOL GIVEN THAT IT WAS CREATED AND REVIEWED ONLY AFTER THE www.finra.org/brokercheck TRANSACTIONS HAD BEEN EFFECTED. IN ADDITION, THIS REPORT WAS User Guidance ISSUED ONLY ON A QUARTERLY BASIS, THEREBY ALLOWING POTENTIALLY NON-COMPLIANT TRANSACTIONS TO REMAIN IN EFFECT WITHOUT REVIEW FOR UP TO THREE MONTHS AFTER THEY WERE EFFECTED. ADDITIONALLY, THE FIRM LACKED ANY WRITTEN ESCALATION PROCEDURES REQUIRING NOTIFICATION AND/OR CONSULTATION WITH THE FIRM'S COMPLIANCE DEPARTMENT WHEN POTENTIALLY VIOLATIVE TRANSACTIONS WERE IDENTIFIED. THE FIRM FAILED TO ENSURE THAT IT IMPLEMENTED REASONABLY DESIGNED SYSTEMS AND PROCEDURES TO FLAG FOR ITS SUPERVISORY PERSONNEL POTENTIALLY UNSUITABLE TRANSACTIONS IN REVERSE CONVERTIBLES AND ENSURE THAT ITS REGISTERED PERSONS WERE ADEQUATELY TRAINED REGARDING THE RISKS ASSOCIATED WITH REVERSE CONVERTIBLES AND THE CUSTOMERS FOR WHOM SUCH INVESTMENTS WERE SUITABLE. THE FINDINGS ALSO STATED THAT GIVEN THE NATURE OF THE REVERSE CONVERTIBLE PRODUCT, THESE TRANSACTIONS EXPOSED CUSTOMERS TO A RISK OF LOSS THAT WAS INCONSISTENT WITH THEIR RISK TOLERANCE, INVESTMENT OBJECTIVES AND FINANCIAL STATUS AND THE FIRM DID NOT HAVE REASONABLE GROUNDS TO BELIEVE THAT THE RECOMMENDATION AND SALE OF REVERSE CONVERTIBLES WERE SUITABLE FOR THESE CUSTOMERS. MOREOVER, THE GUIDELINES ARTICULATED IN THE FIRM'S OWN WSPS ESTABLISH THAT REVERSE CONVERTIBLES SHOULD NOT HAVE BEEN SOLD TO THESE CUSTOMERS. CONSEQUENTLY, THE FIRM'S SUPERVISORS FAILED TO DETECT THE SALE BY ITS REGISTERED REPRESENTATIVES OF REVERSE CONVERTIBLE TRANSACTIONS IN SEVERAL CUSTOMERS' ACCOUNTS THAT WERE UNSUITABLE FOR THOSE CUSTOMERS. THESE CUSTOMERS INCURRED LOSSES TOTALING AT LEAST $1.1 MILLION. Initiated By: FINRA Date Initiated: 04/23/2015 Docket/Case Number: 2010022918701

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/23/2015 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or ©2021deceptive FINRA. conduct? All rights reserved. Report about RBC CAPITAL MARKETS, LLC 195 www.finra.org/brokercheck User Guidance

Principal Product Type: Other Other Product Type(s): REVERSE CONVERTIBLE NOTES Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE AND RESTITUTION Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/23/2015 Sanctions Ordered: Censure Monetary/Fine $1,000,000.00 Disgorgement/Restitution Other Sanctions Ordered: PLUS INTEREST ON THE RESTITUION Sanction Details: THE FIRM WAS CENSURED, FINED $1,000,000 AND ORDERED TO PAY $433,898.10, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND THE TO THE ENTRY OF FINDINGS THAT BETWEEN 2008 AND 2012, THE FIRM FAILED TO HAVE IN PLACE SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND ITS INTERNAL GUIDELINES CONCERNING THE SUITABILITY OF REVERSE CONVERTIBLES THEREFORE VIOLATING NASD RULES 3010(A), 2310, 2110, AND FINRA RULE 2010. i Disclosure 73 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC IS ALLEGED TO HAVE VIOLATED SECTION 11- 402 OF THE MARYLAND SECURITIES ACT BY FAILING TO REGISTER AN INDIVIDUAL APPROPRIATELY AS AN INVESTMENT ADVISER REPRESENTATIVE BETWEEN AUGUST 3, 2011 AND JUNE 2, 2014. Initiated By: STATE OF MARYLAND SECURITIES DIVISION Date Initiated: 01/23/2015 Docket/Case Number: 2014-0458

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: 01/23/2015

Sanctions Ordered: Monetary/Fine $15,000.00 Other Sanctions Ordered: THE FIRM UNDERTAKES TO MAINTAIN POLICIES AND PROCEDURES THAT ARE DESIGNED TO PREVENT ANY FUTURE UNREGISTERED INVESTMENT ADVISER REPRESENTATIVE ACTIVITIES. Sanction Details: THE FIRM CONSENTED TO THE PAYMENT OF A $15,000 FINE FOR VIOLATION OF SECTION 11-402 OF THE MARYLAND SECURITIES ACT. i Disclosure 74 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC ("RBC"), AN EXCHANGE TPH ORGANIZATION, WAS CENSURED AND FINED $40,000 FOR THE FOLLOWING CONDUCT. RBC (I) FAILED TO REGISTER SEVENTEEN (17) ASSOCIATED PERSONS AS A PROPRIETARY TRADER (PT) WITH THE EXCHANGE IN WEBCRD, (II) FAILED TO REGISTER TWO (2) ASSOCIATED PERSONS AS A PROPRIETARY TRADER PRINCIPAL (TP) WITH THE EXCHANGE IN WEBCRD, AND (III) FAILED TO REGISTER ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER (CT) WITH THE EXCHANGE IN WEBCRD. (EXCHANGE RULE 3.6A - QUALIFICATION AND REGISTRATION OF TRADING PERMIT HOLDERS AND ASSOCIATED PERSONS) Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 10/02/2014 Docket/Case Number: 14-0143

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: 12/01/2014 Sanctions Ordered: Censure Monetary/Fine $40,000.00 Other Sanctions Ordered: Sanction Details: A $40,000 FINE AND A CENSURE. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 198 www.finra.org/brokercheck User Guidance

i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT RBC CAPITAL MARKETS, LLC (RBCCM) FAILED TO REGISTER SEVENTEEN ASSOCIATED PERSONS AS PROPRIETARY TRADERS WITH THE CHICAGO BOARD OPTIONS EXCHANGE (CBOE) ON VARIOUS DATES BETWEEN ON OR ABOUT NOVEMBER 5, 2011 THROUGH ON OR ABOUT APRIL 29, 2013. IT IS ALSO ALLEGED THAT RBCCM FAILED TO REGISTER ONE ASSOCIATED PERSON WITH CBOE FROM ON OR ABOUT DECEMBER 18, 2012 THROUGH ON OR ABOUT MAY 13, 2013 AS A PROPRIETARY TRADING PRINCIPAL. IN ADDITION, FROM ON OR ABOUT APRIL 1, 2012 THROUGH ON OR ABOUT APRIL 19, 2013, IT IS ALLEGED THAT RBCCM FAILED TO REGISTER ONE ASSOCIATED PERSON WITH CBOE AS A PROPRIETARY TRADER PRINCIPAL. IT IS ALSO ALLEGED THAT RBCCM FAILED TO REGISTER ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER WITH CBOE BY NOVEMBER 5, 2011 PURSUANT TO EXCHANGE RULE 3.6A. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 10/02/2014 Docket/Case Number: 14-0143

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: Settled Resolution Date: 12/01/2014 Sanctions Ordered: Censure Monetary/Fine $40,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND THE ENTRY OF FINDINGS THAT IT FAILED TO REGISTER: SEVENTEEN ASSOCIATED PERSONS AS PROPRIETARY TRADERS WITH THE CHICAGO BOARD OPTIONS EXCHANGE (CBOE) ON VARIOUS DATES BETWEEN ON OR ABOUT NOVEMBER 5, 2011 THROUGH ON OR ABOUT APRIL 29, 2013, ONE ASSOCIATED PERSON WITH CBOE ©2021 FINRA. All rights reserved. Report aboutFROM RBC ON CAPITAL OR ABOUT MARKETS, DECEMBER LLC 18, 2012 THROUGH ON OR ABOUT MAY 199 13, 2013 AS A PROPRIETARY TRADING PRINCIPAL, ONE ASSOCIATED PERSON WITH CBOE AS A PROPRIETARY TRADER PRINCIPAL FROM ON OR ABOUT APRIL 1, 2012 THROUGH ON OR ABOUT APRIL 19, 2013, AND ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER WITH CBOE BY NOVEMBER 5, 2011 PURSUANT TO EXCHANGE RULE 3.6A; THEREFORE THE FIRM IS FINED $40,000.00 AND CENSURED. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED www.finra.org/brokercheck TO THE SANCTIONS AND THE ENTRY OF FINDINGS THAT IT FAILED TO User Guidance REGISTER: SEVENTEEN ASSOCIATED PERSONS AS PROPRIETARY TRADERS WITH THE CHICAGO BOARD OPTIONS EXCHANGE (CBOE) ON VARIOUS DATES BETWEEN ON OR ABOUT NOVEMBER 5, 2011 THROUGH ON OR ABOUT APRIL 29, 2013, ONE ASSOCIATED PERSON WITH CBOE FROM ON OR ABOUT DECEMBER 18, 2012 THROUGH ON OR ABOUT MAY 13, 2013 AS A PROPRIETARY TRADING PRINCIPAL, ONE ASSOCIATED PERSON WITH CBOE AS A PROPRIETARY TRADER PRINCIPAL FROM ON OR ABOUT APRIL 1, 2012 THROUGH ON OR ABOUT APRIL 19, 2013, AND ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER WITH CBOE BY NOVEMBER 5, 2011 PURSUANT TO EXCHANGE RULE 3.6A; THEREFORE THE FIRM IS FINED $40,000.00 AND CENSURED. i Disclosure 75 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT DURING THE APPROXIMATE PERIOD FROM IN OR ABOUT MAY 2012 THROUGH IN OR ABOUT APRIL 2013, ON NUMEROUS DATES, RBC CAPITAL MARKETS, LLC FAILED TO SUBMIT ORDER ENTRY OPERATOR IDS PURSUANT TO CFE RULE 303A WITH NUMEROUS ORDERS SENT TO CFE. Initiated By: CBOE FUTURES EXCHANGE, LLC Date Initiated: 10/01/2014 Docket/Case Number: CFE-14-0003

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 CENSURE Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 11/05/2014 Sanctions Ordered: Censure Monetary/Fine $25,000.00 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 $25,000.00. i Disclosure 76 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 200 www.finra.org/brokercheck User Guidance

Disclosure 76 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO CONTEMPORANEOUSLY OR PARTIALLY EXECUTE 27 CUSTOMER LIMIT ORDERS IN 15 OVER-THE-COUNTER (OTC) 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. Initiated By: FINRA Date Initiated: 09/16/2014 Docket/Case Number: 2012031757601

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: 09/16/2014 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 $5,000.00 Disgorgement/Restitution Other Sanctions Ordered: RESTITUTION IN THE AMOUNT OF $1,605.95, PLUS INTEREST Sanction Details: SEE ABOVE- FINE PAID IN FULL ON OCTOBER 14, 2014. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED ©2021 FINRA. All rights reserved. Report aboutTO THE RBC CAPITALSANCTIONS MARKETS, AND LLC TO THE ENTRY OF FINDINGS THAT IT FAILED TO 201 CONTEMPORANEOUSLY OR PARTIALLY EXECUTE 27 CUSTOMER LIMIT ORDERS IN 15 OVER-THE-COUNTER (OTC) 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. www.finra.org/brokercheck User Guidance

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO CONTEMPORANEOUSLY OR PARTIALLY EXECUTE 27 CUSTOMER LIMIT ORDERS IN 15 OVER-THE-COUNTER (OTC) 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. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 09/16/2014 Docket/Case Number: 20120317576-01

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 RESTITUTION Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/16/2014 Sanctions Ordered: Monetary/Fine $5,000.00 Disgorgement/Restitution Other Sanctions Ordered: RESTITUTION IN THE AMOUNT OF $1,605.95, PLUS INTEREST Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO CONTEMPORANEOUSLY OR PARTIALLY EXECUTE 27 CUSTOMER LIMIT ORDERS IN 15 OVER-THE-COUNTER (OTC) 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; THEREFORE, THE FIRM IS FINED $5,000.00 AND MUST PAY RESTITUTION IN THE AMOUNT OF $1,605.95, PLUS INTEREST TO THE CUSTOMER(S). i Disclosure 77 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE ©2021 FINRA. All rights reserved. Report aboutLICENSING RBC CAPITAL STATUS MARKETS, OF SUCHLLC EMPLOYEES. 202 www.finra.org/brokercheck IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR User Guidance TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: NEBRASKA DEPARTMENT OF BANKING & FINANCE Date Initiated: 06/16/2014 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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 06/16/2014 Sanctions Ordered: Monetary/Fine $35,240.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 8-1103(1)(REISSUE 2012) OF THE NEBRASKA REVISED STATUTES. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $.28 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 78 of 336

Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: NEW YORK OFFICE OF THE ATTORNEY GENERAL Date Initiated: 06/20/2014 Docket/Case Number: AOD NO. 14-126

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 06/20/2014 Sanctions Ordered: Monetary/Fine $65,370.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF ARTICLE 23-A, SECTION 359-E(3) OF THE GENERAL BUSINESS LAW COMMONLY KNOWN AS THE MARTIN ACT. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $.28 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND ©2021 FINRA. All rights reserved. Report aboutSYSTEMS RBC CAPITAL THAT MARKETS, REASONABLY LLC SUPERVISE THE TRADE PROCESS SO THAT 204 THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $.28 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR www.finra.org/brokercheck TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND User Guidance ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 79 of 336 Reporting Source: Regulator Current Status: Final Allegations: MULTI-STATE INVESTIGATION DETERMINED THAT IT WAS HIGHLY LIKELY THAT CERTAIN RBC SALES ASSISTANTS ACCEPTED ORDERS IN MISSOURI AT TIMES WHEN THE SALES ASSISTANTS WERE NOT APPROPRIATELY REGISTERED, IN VIOLATION OF 409.4-402(D), RSMO. (CUM. SUPP. 2012). IN ADDITION, RBC'S FAILURE TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS CONSTITUTES A FAILURE TO REASONABLY SUPERVISE UNDER 409.4-412(D)(9), RSMO. (CUM. SUPP. 2012). Initiated By: MISSOURI Date Initiated: 07/02/2014 Docket/Case Number: AP-14-11 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief PAYMENT TO MISSOURI SECRETARY OF STATE INVESTOR EDUCATION AND Sought: PROTECTION FUND; UNDERTAKINGS

Resolution: Consent Resolution Date: 07/02/2014 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 $50,220.17 Other Sanctions Ordered: RBC IS ORDERED TO COMPLY WITH THE UNDERTAKINGS CONTAINED IN THE CONSENT. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 205 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: RBC IS ORDERED TO COMPLY WITH THE UNDERTAKINGS CONTAINED IN THE CONSENT. Sanction Details: RBC IS ORDERED TO COMPLY WITH THE UNDERTAKINGS CONTAINED IN THE CONSENT. IN ADDITION, RBC IS ORDERED TO PAY THE SUM OF $50,220.17 TO THE MO INVESTOR EDUCATION AND PROTECTION FUND. Regulator Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION WHICH RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED PER STATE LAWS ACCEPTED ORDERS FOR SECURITIES TRANSACTIONS AND THAT THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE THAT ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: MISSOURI OFFICE OF SECRETARY OF STATE Date Initiated: 07/02/2014 Docket/Case Number: AP-14-11

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 UNDERTAKING Sought:

Sanctions Ordered: Monetary/Fine $50,220.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 409.4-402(D) RSMO (CUM. SUPP. 2012) AND 409.4-412(D)(9) RSMO (CUM. SUPP. 2012)OF THE MISSOURI REVISED STATUTES Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $.28 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 80 of 336 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) FOR WHICH IT DID NOT HAVE AN OATS REPORTING RESPONSIBILITY. Initiated By: FINRA Date Initiated: 06/30/2014 Docket/Case Number: 2013035826001

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 207 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/30/2014 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 $12,500.00 Other Sanctions Ordered: Sanction Details: SEE ABOVE Regulator Statement FINE PAID IN FULL ON JULY 16, 2014. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT THE FIRM TRANSMITTED TO ORDER AUDIT TRAIL SYSTEM ("OATS") 174 REPORTS FOR WHICH IT DID NOT HAVE AN OATS REPORTING RESPONSIBILITY. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 06/27/2014 Docket/Case Number: 20130358260-01

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: 06/27/2014 Sanctions Ordered: Censure Monetary/Fine $12,500.00 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 208 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $12,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED REPORTS TO THE ORDER AUDIT TRAIL SYSTEM ("OATS") FOR WHICH IT DID NOT HAVE AN OATS REPORTING RESPONSIBILITY; THEREFORE, THE FIRM IS CENSURED AND FINED $12,500.00. i Disclosure 81 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: COMMONWEALTH OF KENTUCKY DEPARTMENT OF FINANCIAL INSTITUTIONS Date Initiated: 04/21/2014 Docket/Case Number: 2014-AH-0021

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 04/21/2014 Sanctions Ordered: Monetary/Fine $38,020.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES ©2021 FINRA. All rights reserved. Report aboutAND RBC PENALTIES CAPITAL MARKETS, FOR VIOLATIONS LLC OF 808 KAR 10:030, SECTION 4(1)(A)1 OF 209 THE KENTUCKY ADMINISTRATIVE REGULATIONS AND SECTION KRS 292.337(K) OF THE KENTUCKY REVISED STATUTES. www.finra.org/brokercheck User Guidance

Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF 808 KAR 10:030, SECTION 4(1)(A)1 OF THE KENTUCKY ADMINISTRATIVE REGULATIONS AND SECTION KRS 292.337(K) OF THE KENTUCKY REVISED STATUTES. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 82 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF SOUTH DAKOTA DIVISION OF SECURITIES Date Initiated: 03/21/2014 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 UNDERTAKING Sought:

Resolution Date: 03/21/2014 Sanctions Ordered: Monetary/Fine $46,470.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 20:08:03:08 OF THE SOUTH DAKOTA ADMINISTRATIVE RULE AS WELL AS SECTION 47-31B-402(D) OF THE SOUTH DAKOTA CODIFIED LAW. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 83 of 336 Reporting Source: Regulator Current Status: Final Allegations: N/A Initiated By: FLORIDA OF FINANCIAL REGULATION Date Initiated: 03/26/2014 Docket/Case Number: 0273-SR-07/13 URL for Regulatory Action: 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: Order Resolution Date: 03/26/2014 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 $71,380.00 Cease and Desist/Injunction Other Sanctions Ordered: N/A Sanction Details: 3/26/2014 - $71,380 ADMINISTRATIVE FINE PAID IN FULL. Regulator Statement ON MARCH 26, 2014, THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF RBC CAPITAL MARKETS, LLC. RBC CAPITAL MARKETS, LLC NEITHER ADMITS OR DENIES THE FINDINGS BY THE OFFICE. THE OFFICE FOUND THAT RBC CAPITAL MARKETS, LLC FAILED TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR THE REGISTRATION STATUS OF CLIENT SERVICES ASSOCIATES AND TO ENFORCE ESTABLISHED WRITTEN PROCEDURES. THE FINAL ORDER FOLLOWS AN INVESTIGATION INTO THE REGISTRATION OF RBC'S CLIENT SERVICE ASSOCIATES AND SUPERVISORY SYSTEM BY THE NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION (NASAA) MULTI-STATE WORKING GROUP. RBC CAPITAL MARKETS, LLC AGREED TO PAY A $71,380 ADMINISTRATIVE FINE. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION Date Initiated: 03/26/2014

Docket/Case Number: 0273-SR-07/13

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 03/26/2014 Sanctions Ordered: Monetary/Fine $71,380.17 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. THE FIRM SHALL CEASE AND DESIST FROM VIOLATING THE FLORIDA SECURITIES AND INVESTOR PROTECTION ACT. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 517.12(1) OF THE FLORIDA STATUTES Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 84 of 336 Reporting Source: Regulator Current Status: Final ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 213 www.finra.org/brokercheck User Guidance

Allegations: UNLICENSED ACTIVITY AND FAILURE TO SUPERVISE Initiated By: MAINE OFFICE OF SECURITIES Date Initiated: 07/12/2013 Docket/Case Number: 13-9686 URL for Regulatory Action: 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: Order Resolution Date: 02/19/2014 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 $35,390.17 Other Sanctions Ordered: Sanction Details: RBC HAS AGREED TO PAY $2.8 MILLION DOLLARS TO BE DISTRIBUTED AMONG THE 50 STATES, THE DISTRICT OF COLUMBIA, PUERTO RICO, AND THE U.S. VIRGIN ISLANDS.THE SETTLEMENT AMOUNT FOR MAINE IS $35,390.17. THIS AMOUNT INCLUDES A $27,720.17 BASE FOR EACH JURISDICTION PLUS AN ADDITIONAL SUM REPRESENTING AN ASSESSMENT OF REGISTRATION FEES RBC MAY HAVE AVOIDED PAYING YOUR SPECIFIC JURISDICTION DURING THE PERIOD 2005 THROUGH 2009. Regulator Statement AS PART OF A MULTISTATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION WHICH RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED ACCEPTED ORDERS FOR SECURITIES TRANSACTIONS AND THAT THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ©2021 FINRA. All rights reserved. Report aboutORIGINATE RBC CAPITAL FROM MARKETS, JURISDICTIONS LLC WHERE THE EMPLOYEE THAT ACCEPTS 214 THE ORDER IS APPROPRIATELY LICENSED. AS PART OF A MULTISTATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION WHICH RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED ACCEPTED ORDERS FOR SECURITIES TRANSACTIONS AND THAT THE FIRM FAILED TO ESTABLISH www.finra.org/brokercheck AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING User Guidance STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE THAT ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF MAINE OFFICE OF SECURITIES Date Initiated: 02/19/2014 Docket/Case Number: 13-9686

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 02/19/2014 Sanctions Ordered: Monetary/Fine $35,390.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF TITLE 32 M.R.S. SECTION 16412(4)(I) AND TITLE 32 M.R.S. SECTION 16402(4) OF THE MAINE UNIFORM SECURITIES ACT. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT ©2021 FINRA. All rights reserved. Report aboutCLIENT RBC ASSOCIATESCAPITAL MARKETS, WHO LLC WERE NOT APPROPRIATELY LICENSED IN 215 ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. www.finra.org/brokercheck User Guidance AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 85 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC EMPLOYEES ACCEPTED ORDERS FOR SECURITIES TRANSACTIONS IN IDAHO WITHOUT BEING PROPERLY REGISTERED; THE FIRM FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES RELATING TO REGISTRATION OF CLIENT ASSOCIATES AND FAILED TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS Initiated By: IDAHO Date Initiated: 07/22/2013 Docket/Case Number: 2013-7-10 URL for Regulatory Action: 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: 01/17/2014 Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 216 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 $45,770.17 Other Sanctions Ordered: THE FIRM UNDERTAKES AND AGREES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT A PERSON CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE PERSON ACCEPTING THE ORDER IS APPROPRIATELY REGISTERED Sanction Details: THE CIVIL MONETARY PENALTY OF $44,770.17 IS TO BE PAID WITHIN TEN DAYS OF THE ORDER. Regulator Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION WHICH RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED PER STATE LAWS ACCEPTED ORDERS FOR SECURITIES TRANSACTIONS AND THAT THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE THAT ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: IDAHO DEPARTMENT OF FINANCE Date Initiated: 01/17/2014 Docket/Case Number: 2013-7-10

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 01/17/2014 Sanctions Ordered: Monetary/Fine $45,770.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 12.01.08.105.01 AND SECTION 12.01.08.105.03 OF THE IDAHO ADMINISTRATIVE PROCEDURES ACT. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE SATTE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 86 of 336 Reporting Source: Regulator Current Status: Final Allegations: ALLEGED VIOLATION OF § 31-5602.07(12),§ 31-5602.01(A) AND §31-5606. 02(B)4 FOR FAILURE TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR THE REGISTRATION STATUS OF ITS PERSON ACCEPTING CLIENT ORDERS; AND FAILURE TO ENFORCE ITS ESTABLISHED WRITTEN PROCEDURES ©2021 FINRA. All rights reserved. Report aboutAND RBC FOR CAPITAL ACCEPTING MARKETS, ORDERS LLC IN THE DISTRICT THROUGH RBC'S CLIENT 218 ASSOCIATES WHO WERE NOT PROPERLY LICENSE. www.finra.org/brokercheck User Guidance ALLEGED VIOLATION OF § 31-5602.07(12),§ 31-5602.01(A) AND §31-5606. 02(B)4 FOR FAILURE TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR THE REGISTRATION STATUS OF ITS PERSON ACCEPTING CLIENT ORDERS; AND FAILURE TO ENFORCE ITS ESTABLISHED WRITTEN PROCEDURES AND FOR ACCEPTING ORDERS IN THE DISTRICT THROUGH RBC'S CLIENT ASSOCIATES WHO WERE NOT PROPERLY LICENSE. Initiated By: DISTRICT OF COLUMBIA Date Initiated: 01/10/2014 Docket/Case Number: SB-CO-12-13 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CONSENT ORDER Sought:

Resolution: Consent Resolution Date: 01/10/2014 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 $38,925.17 Other Sanctions Ordered: RBC AGREES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT A PERSON CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE PERSON ACCEPTING THE ORDER IS APPROPRIATELY REGISTERED. Sanction Details: THE MONETARY PENALTY OF $38925.17 WAS PAID PURSUANT TO THIS ORDER. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ©2021 FINRA. All rights reserved. Report aboutESTABLISH RBC CAPITAL AND MARKETS, ENFORCE LLC AN ADEQUATE SYSTEM TO MONITOR THE 219 LICENSING STATUS OF SUCH EMPLOYEES. www.finra.org/brokercheck IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR User Guidance TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: DISTRICT OF COLUMBIA DEPARTMENT OF INSURANCE, SECURITIES AND BANKING Date Initiated: 01/10/2014 Docket/Case Number: SB-CO-12-13

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

Resolution: Order Resolution Date: 01/10/2014 Sanctions Ordered: Monetary/Fine $38,925.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 31-5602.01(A) AND SECTION 31-5602.07(12) OF THE D.C. OFFICIAL CODE. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE SATTE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 87 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 220 www.finra.org/brokercheck User Guidance

Disclosure 87 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS, LLC FAILED TO REASONABLY SUPERVISE ITS AGENTS IN VIOLATION OF THE PA SECURITIES ACT OF 1972. Initiated By: PENNSYLVANIA CONTACT: COUNSEL CAROLYN MENDELSON (412)-565- 5083 Date Initiated: 01/02/2014 Docket/Case Number: 2013-10-15 (#140001) URL for Regulatory Action: 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: 01/02/2014 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 $95,646.17 Other Sanctions Ordered: Sanction Details: RBC CAPITAL MARKETS, LLC IS ORDERED TO PAY THE SUM OF $95,646.17 TO THE DEPARTMENT OF BANKING AND SECURITIES WITHIN 10 DAYS OF THE DATE OF THIS ORDER. Regulator Statement CONSENT AGREEMENT AND ORDER ISSUED TO RBC CAPITAL MARKETS, LLC. i Reporting Source: Firm Current Status: Final

©2021Allegations: FINRA. All rights reserved. Report aboutIT IS RBC HIGHLY CAPITAL LIKELY MARKETS, THAT LLC THE FIRM ACCEPTED ORDERS FOR 221 TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. www.finra.org/brokercheck User Guidance

Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: PENNSYLVANIA DEPARTMENT OF BANKING Date Initiated: 12/31/2013 Docket/Case Number: 140001

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 12/31/2013 Sanctions Ordered: Monetary/Fine $95,646.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 305(A)(VII) OF THE 1972 ACT, 70 P.S., SECTION 1-305(A)(VII) AND REGULATION SECTION 305.011(A), 10 PA. CODE SECTION 1-305.011(A) OF THE PENNSYLVANIA CODE. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE SATTE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 222 APPROPRIATELY LICENSED. AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE SATTE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS www.finra.org/brokercheck OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM User Guidance UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 88 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC EMPLOYEES ACCEPTED ORDERS FOR SECURITIES TRANSACTIONS IN KANSAS WITHOUT BEING PROPERLY REGISTERED; THE FIRM FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES RELATING TO REGISTRATION OF CLIENT ASSOCIATES AND FAILED TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS Initiated By: KANSAS Date Initiated: 12/12/2013 Docket/Case Number: 14E04/2014-6130 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Undertaking Sought: Other Sanction(s)/Relief CIVIL MONETARY PENALTY Sought:

Resolution: Order Resolution Date: 12/30/2013 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 $44,275.17 Other Sanctions Ordered: THE FIRM UNDERTAKES AND AGREES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT A PERSON CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE PERSON ACCEPTING THE ORDER IS APPROPRIATELY REGISTERED

©2021Sanction FINRA. Details: All rights reserved. Report aboutTHE RBC CIVIL CAPITAL MONETARY MARKETS, PENALTY LLC OF $44,275.17 IS TO BE PAID WITHIN TEN 223 DAYS OF THE ORDER TO THE INVESTOR EDUCATION FUND PER K.S.A. 17- 12A601(D) www.finra.org/brokercheck User Guidance

Sanction Details: THE CIVIL MONETARY PENALTY OF $44,275.17 IS TO BE PAID WITHIN TEN DAYS OF THE ORDER TO THE INVESTOR EDUCATION FUND PER K.S.A. 17- 12A601(D) Regulator Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION WHICH RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED PER STATE LAWS ACCEPTED ORDERS FOR SECURITIES TRANSACTIONS AND THAT THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE THAT ACCEPTS THE ORDER IS APPROPRIATELY LICENSED i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: SECURITIES COMMISSIONER OF THE STATE OF KANSAS Date Initiated: 12/30/2013 Docket/Case Number: 14E04/2014-6130

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 12/30/2013 Sanctions Ordered: Monetary/Fine $44,275.17 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 224 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $44,275.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 81-3-7 OF THE KANSAS ADMINISTRATIVE REGULATION AND SECTION 17-12A-402(A) OF THE KANSAS UNIFORM SECURITIES ACT. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE SATTE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 89 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF NEW JERSEY BUREAU OF SECURITIES Date Initiated: 12/30/2013 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: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 225 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: Order Resolution Date: 12/30/2013 Sanctions Ordered: Monetary/Fine $48,690.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 49:3-58(A)(2)(XI) AND SECTION 49:3-56(H) OF THE NEW JERSEY STATUTES ANNOTATED. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 90 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF OHIO DIVISION OF SECURITIES ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 226 www.finra.org/brokercheck User Guidance

Initiated By: STATE OF OHIO DIVISION OF SECURITIES Date Initiated: 12/31/2013 Docket/Case Number: 13-040

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 12/31/2013 Sanctions Ordered: Monetary/Fine $57,270.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF CHAPTER 1707.44(A)(1) OF THE REVISED CODE AND CHAPTER 1301:6-3-19(B)(9) OF THE OHIO ADMINISTRATIVE CODE Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 91 of 336 Reporting Source: Firm

Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF WISCONSIN DEPARTMENT OF FINANCIAL INSTITUTIONS Date Initiated: 12/06/2013 Docket/Case Number: S-228969(LX)

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 12/06/2013 Sanctions Ordered: Monetary/Fine $41,220.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 551.412(4)(I) OF THE WISCONSIN UNIFORM SECURITIES LAW AND DFI SECTION 4.05(2) Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM ©2021 FINRA. All rights reserved. Report aboutJURISDICTIONS RBC CAPITAL MARKETS, WHERE LLCTHE EMPLOYEE WHO ACCEPTS THE ORDER IS 228 APPROPRIATELY LICENSED. AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND www.finra.org/brokercheck ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS User Guidance OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 92 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF INDIANA SECURITIES DIVISION Date Initiated: 12/02/2013 Docket/Case Number: 13-0249 CO

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 12/02/2013 Sanctions Ordered: Monetary/Fine $36,870.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 23-19-4-2(D)SECTION 23-19- 4-12(D)(9) OF THE INDIANA UNIFORM SECURITIES ACT AND SECTION 4-7- 6(D)1) OF THE 710 INDIANA ADMINISTRATION CODE. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE ©2021 FINRA. All rights reserved. Report aboutAMOUNT RBC CAPITAL OF $2.8 MARKETS, MILLION. LLC THIS RESULTED FROM ALLEGATIONS THAT 229 CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. www.finra.org/brokercheck User Guidance

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 12/05/2013 Sanctions Ordered: Monetary/Fine $38,930.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS ©2021 FINRA. All rights reserved. Report aboutTHE RBC ORDER CAPITAL IS APPROPRIATELYMARKETS, LLC LICENSED. 230 www.finra.org/brokercheck THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, User Guidance PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF 9 V.S.A. SECTION 5402(A), SECTION 5412(D)(9) AND SECTION 5402(D) OF THE VERMONT UNIFORM SECURITIES ACT. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 94 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: IOWA INSURANCE DIVISION Date Initiated: 12/05/2013 Docket/Case Number: 80979

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 12/05/2013 Sanctions Ordered: Monetary/Fine $37,290.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 502.402(1)(2013), SECTION 502.412(4)(I)(2013) AND SECTION 502.412(3)(2013) OF THE IOWA UNIFORM SECURITIES ACT, IOWA CODE. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 95 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: SECURITIES COMMISSIONER OF SOUTH CAROLINA Date Initiated: 12/03/2013 Docket/Case Number: 13063

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 12/03/2013 Sanctions Ordered: Monetary/Fine $70,950.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTION 35-1-402(D)(SUPP. 2012) AND SECTION 35-1-412(D)(9) (SUPP.2012) OF THE SOUTH CAROLINA CODE OF LAWS. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 96 of 336 Reporting Source: Regulator Current Status: Final Allegations: THE DIVISION ALLEGED RBC EMPLOYEES ACCEPTED ORDERS FOR SECURITY TRANSACTIONS WITHOUT BEING PROPERLY REGISTERED IN VIRGINIA, AND FAILED TO ENFORCE ITS WRITTEN PROCEDURES IN THIS MATTER. RBC FAILED TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR ©2021 FINRA. All rights reserved. Report aboutTHE RBC LICENSE CAPITAL STATUS MARKETS, OF LLC PERSONS ACCEPTING ORDERS. 233 www.finra.org/brokercheck User Guidance THE DIVISION ALLEGED RBC EMPLOYEES ACCEPTED ORDERS FOR SECURITY TRANSACTIONS WITHOUT BEING PROPERLY REGISTERED IN VIRGINIA, AND FAILED TO ENFORCE ITS WRITTEN PROCEDURES IN THIS MATTER. RBC FAILED TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR THE LICENSE STATUS OF PERSONS ACCEPTING ORDERS. Initiated By: VIRGINIA - STATE CORPORATION COMMISSION DIVISION OF SECURITIES & RETAIL FRANCHISING Date Initiated: 11/12/2013 Docket/Case Number: SEC-2013-00026 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Undertaking Sought: Other Sanction(s)/Relief COST OF INVESTIGATION Sought:

Resolution: Order Resolution Date: 11/12/2013 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 $27,720.17 Other Sanctions Ordered: COST OF INVESTIGATION $23,220.00. RBC UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT A PERSON CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE PERSON ACCEPTING ORDERS IS PROPERLY REGISTERED. Sanction Details: PENALTIES AND COST OF INVESTIGATION WERE PAID ON OR ABOUT 10/25/2013. Regulator Statement THE MATTER AROSE FROM A MULTI-STATE INVESTIGATION COORDINATED BY NASAA. RBC FAILED TO EXERCISE DILIGENT SUPERVISION OVER ALL OF IT'S AGENTS PURSUANT TO COMMISSION RULE 21 VAC 5-20-260B BY FAILING TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS. RBC FAILED TO ESTABLISH WRITTEN PROCEDURES PURSUANT TO COMMISSION RULE 21 VAC 520-260D FOR FAILING TO ENSURE CLIENT ASSOCIATES WERE REGISTERED IN APPROPRIATE JURISDICTIONS. RBC'S ACCEPTANCE OF ORDERS IN VIRGINIA THROUGH CLIENT ASSOCIATES ©2021 FINRA. All rights reserved. Report aboutNOT RBC PROPERLY CAPITAL MARKETS, REGISTERED LLC VIOLATES SECTION 13.1-504 OF THE ACT. 234 CONTACT GLORIA PULKOWSKI AT 804-371-9566 FOR FURTHER INFORMATION. THE MATTER AROSE FROM A MULTI-STATE INVESTIGATION COORDINATED BY NASAA. RBC FAILED TO EXERCISE DILIGENT SUPERVISION OVER ALL OF IT'S AGENTS PURSUANT TO COMMISSION RULE 21 VAC 5-20-260B BY FAILING TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS. RBC www.finra.org/brokercheck FAILED TO ESTABLISH WRITTEN PROCEDURES PURSUANT TO User Guidance COMMISSION RULE 21 VAC 520-260D FOR FAILING TO ENSURE CLIENT ASSOCIATES WERE REGISTERED IN APPROPRIATE JURISDICTIONS. RBC'S ACCEPTANCE OF ORDERS IN VIRGINIA THROUGH CLIENT ASSOCIATES NOT PROPERLY REGISTERED VIOLATES SECTION 13.1-504 OF THE ACT. CONTACT GLORIA PULKOWSKI AT 804-371-9566 FOR FURTHER INFORMATION. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION Date Initiated: 11/12/2013 Docket/Case Number: SEC-2013-00026

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 11/12/2013 Sanctions Ordered: Monetary/Fine $27,720.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. ADDITIONALLY, RBC PAID THE COST OF THE INVESTIGATION $23,220.00. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF SECTION 13.1-504A OF THE VIRGINIA SECURITIES ACT AND COMMISSION RULE 21 VAC 5-20-260 B. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT ©2021 FINRA. All rights reserved. Report aboutCLIENT RBC ASSOCIATESCAPITAL MARKETS, WHO LLC WERE NOT APPROPRIATELY LICENSED IN 235 ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. www.finra.org/brokercheck User Guidance AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 97 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: MONTANA STATE AUDITOR & COMMISIONNER OF SECURITIES AND INSURANCE Date Initiated: 10/31/2013 Docket/Case Number: SEC-2013-144

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 10/31/2013 Sanctions Ordered: Monetary/Fine $42,520.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS ©2021 FINRA. All rights reserved. Report aboutTHE RBC ORDER CAPITAL IS APPROPRIATELYMARKETS, LLC LICENSED. 236 www.finra.org/brokercheck THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, User Guidance PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF SECTION 30-10-201(13)(K) AND 30-10- 201(L) OF THE SECURITIES ACT OF MONTANA. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 98 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: SECURITIES COMMISSIONER FOR THE STATE OF DELAWARE Date Initiated: 10/31/2013 Docket/Case Number: 13-4-1

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 UNDERTAKING Sought:

Resolution: Order

Resolution Date: 10/31/2013 Sanctions Ordered: Monetary/Fine $33,520.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF SECTION 73-304(A)(10) AND 73-301(A) OF THE DELAWARE SECURITIES ACT Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 99 of 336 Reporting Source: Regulator Current Status: Final Allegations: FROM 2005 TO 2009, RESPONDENT'S SALES ASSISTANCE ENGAGED IN UNLICESNED ACTIVITY IN NH. Initiated By: NEW HAMPSHIRE BUREAU OF SECURITIES REGULATION Date Initiated: 07/12/2013 Docket/Case Number: I-2013-00026 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 238 www.finra.org/brokercheck User Guidance

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

Resolution: Consent Resolution Date: 11/14/2013 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 $53,630.17 Other Sanctions Ordered: NA Sanction Details: SAME AS ABOVE. Regulator Statement SAME AS ABOVE. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: THE STATE OF NEW HAMPSHIRE BUREAU OF SECURITIES REGULATION Date Initiated: 11/14/2013 Docket/Case Number: INV-2013-0026

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 11/14/2013 Sanctions Ordered: Monetary/Fine $53,630.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF RSA 421-B:10(A) AND (B)(10) OF THE NEW HAMPSHIRE SECURITIES ACT. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 100 of 336 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULES 2010, 6730(B), 6730(C)(6), NASD INTERPRETATIVE MATERIAL 2110-2, MSRB RULES G-17, G-30(A) - RBC CAPITAL MARKETS, LLC FAILED TO EXECUTE CUSTOMER LIMIT ORDERS AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT A PRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER. THE FIRM FAILED TO CONTEMPORANEOUSLY EXECUTE CUSTOMER LIMIT ORDERS AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWN MARKET- MAKING ACCOUNT, AND FAILED TO EXECUTE SUCH ORDERS AT A PRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER. THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING ©2021 FINRA. All rights reserved. Report aboutINTO RBC CONSIDERATION CAPITAL MARKETS, ALL LLC RELEVANT FACTS, INCLUDING THE BEST 240 JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS FOR A PARTICULAR MARKET PARTICIPANT IDENTIFIER (MPID) IN TRACE-ELIGIBLE SECURITIZED PRODUCTS. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS. THE FIRM REPORTED INTER-DEALER TRANSACTIONS FOR ITS MPID AS CUSTOMER TRADES. FINRA RULES 2010, 6730(B), 6730(C)(6), NASD INTERPRETATIVE MATERIAL 2110-2, MSRB RULES G-17, G-30(A) - RBC CAPITAL MARKETS, LLC FAILED TO EXECUTE CUSTOMER LIMIT ORDERS AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT A PRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER. THE FIRM FAILED TO CONTEMPORANEOUSLY EXECUTE CUSTOMER LIMIT ORDERS AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWN MARKET- MAKING ACCOUNT, AND FAILED TO EXECUTE SUCH ORDERS AT A PRICE www.finra.org/brokercheck THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER. THE FIRM User Guidance PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS FOR A PARTICULAR MARKET PARTICIPANT IDENTIFIER (MPID) IN TRACE-ELIGIBLE SECURITIZED PRODUCTS. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS. THE FIRM REPORTED INTER-DEALER TRANSACTIONS FOR ITS MPID AS CUSTOMER TRADES. Initiated By: FINRA Date Initiated: 11/13/2013 Docket/Case Number: 2011028031401

Principal Product Type: Debt - Municipal Other Product Type(s): TRACE-ELIGIBLE SECURITIZED PRODUCTS Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/13/2013 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, $15,000 OF ©2021 FINRA. All rights reserved. Report aboutWHICH RBC WASCAPITAL FOR MARKETS, MSRB LLCRULE VIOLATIONS. FINE PAID IN FULL ON JANUARY 241 3, 2014. www.finra.org/brokercheck User Guidance

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, $15,000 OF WHICH WAS FOR MSRB RULE VIOLATIONS. FINE PAID IN FULL ON JANUARY 3, 2014. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULES 2010, 6730(B), 6730(C)(6), NASD INTERPRETATIVE MATERIAL 2110-2, MSRB RULES G-17, G-30(A) - IT IS ALLEGED THAT RBC CAPITAL MARKETS, LLC FAILED TO EXECUTE CUSTOMER LIMIT ORDERS AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT A PRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER. IT IS ALLEGED THAT THE FIRM FAILED TO CONTEMPORANEOUSLY EXECUTE CUSTOMER LIMIT ORDERS AFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT, AND FAILED TO EXECUTE SUCH ORDERS AT A PRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER. IT IS ALLEGED THAT THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. IT IS ALLEGED THAT THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS FOR A PARTICULAR MARKET PARTICIPANT IDENTIFIER (MPID) IN TRACE-ELIGIBLE SECURITIZED PRODUCTS. IT IS ALLEGED THAT THE FIRM FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS. THE FIRM REPORTED INTER-DEALER TRANSACTIONS FOR ITS MPID AS CUSTOMER TRADES. Initiated By: FINRA Date Initiated: 11/13/2013 Docket/Case Number: 2011028031401

Principal Product Type: Debt - Municipal Other Product Type(s): TRACE-ELIGIBLE SECURITIZED PRODUCTS ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 242 www.finra.org/brokercheck User Guidance

Other Product Type(s): TRACE-ELIGIBLE SECURITIZED PRODUCTS Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/13/2013 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 $50,000.00, COMPRISED OF $10,000 FOR THE LIMIT ORDER PROTECTION VIOLATIONS, $15,000 FOR THE FAIR PRICING VIOLATIONS OF MSRB RULES; AND $25,000 FOR THE TRACE REPORTING VIOLATIONS. i Disclosure 101 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: GOVERNMENT OF THE U.S. VIRGIN ISLANDS Date Initiated: 11/07/2013 Docket/Case Number: 10-2013

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 11/07/2013 Sanctions Ordered: Monetary/Fine $28,070.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF CHAPTER 23, 9VIC, SECTION 632(D) AND 642(D)(9) OF THE VIRGIN ISLANDS UNIFORM SECURITIES ACT Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 102 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF RHODE ISLAND Date Initiated: 11/05/2013 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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 11/05/2013 Sanctions Ordered: Monetary/Fine $37,870.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF SECTION 7-11-212(B)(11) AS WELL AS SECTION 7-11-201(A) AND (B) OF THE RHODE ISLAND UNIFORM SECURITIES ACT. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 103 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ©2021 FINRA. All rights reserved. Report aboutESTABLISH RBC CAPITAL AND MARKETS, ENFORCE LLC AN ADEQUATE SYSTEM TO MONITOR THE 245 LICENSING STATUS OF SUCH EMPLOYEES. www.finra.org/brokercheck User Guidance IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: OFFICE OF THE MISSISSIPPI SECRETARY OF STATE SECURITIES DIVISION Date Initiated: 10/31/2013 Docket/Case Number: LS-13-0732

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 10/31/2013 Sanctions Ordered: Monetary/Fine $34,070.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF RULE 521 OF THE PREDECESSOR ACT OF THE MISSISSIPPI CODE. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 104 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 246 www.finra.org/brokercheck User Guidance

Disclosure 104 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF MINNESOTA DEPARTMENT OF COMMERCE Date Initiated: 11/01/2013 Docket/Case Number: 28523

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 10/31/2013 Sanctions Ordered: Monetary/Fine $50,720.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF SECTION 80A.57(A) AND SECTION 80A.67(D)(9)OF THE MINNESOTA STATUES. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM ©2021 FINRA. All rights reserved. Report aboutUNDERTAKES RBC CAPITAL TO MARKETS, ESTABLISH LLC AND MAINTAIN POLICIES, PROCEDURES AND 247 SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT www.finra.org/brokercheck CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN User Guidance ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 105 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: COMMONWEATH OF MASSACHUSETTS SECURITIES DIVISION Date Initiated: 10/22/2013 Docket/Case Number: E-2013-0078

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 10/31/2013 Sanctions Ordered: Monetary/Fine $68,670.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF CHAPTER 110A, SECTION204(A)(2)(J) AND SECTION 201(B) OF THE MASSACHUSETTS GENERAL LAWS.

©2021Firm StatementFINRA. All rights reserved. Report aboutAS PART RBC CAPITAL OF A MULTI-STATE MARKETS, LLC SETTLEMENT, THE FIRM ENTERED INTO AN 248 AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. www.finra.org/brokercheck User Guidance

Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 106 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF GEORGIA COMMISSIONER OF SECURITIES Date Initiated: 10/31/2013 Docket/Case Number: ENSC-140336

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 10/31/2013 Sanctions Ordered: Monetary/Fine $54,180.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE ©2021 FINRA. All rights reserved. Report aboutPROCESS RBC CAPITAL SO THAT MARKETS, THE LLC FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT 249 ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF SECTION 10-5-4(A)(11) AND SECTION 10-5-3(A) OF THE 1973 GEORGIA UNIFORM SECURITIES ACT AND RULE 590- 4-2-.07 OF THE 1973 RULES, AS WELL AS SECTION 10-5-41(D)(9)AND SECTION 10.5.31(D)OF THE 2008 GEORGIA UNIFORM SECURITIES ACT AND RULE 590-4-5.12 OF THE 2008 RULES. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 107 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF CALIFORNIA COMMISSIONER OF BUSINESS OVERSIGHT Date Initiated: 10/31/2013 Docket/Case Number: 12366

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 250 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: Order Resolution Date: 10/31/2013 Sanctions Ordered: Monetary/Fine $33,520.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF CALIFORNIA CORPORATIONS CODE SECTION 25217(A) AND 25210(B), AS WELL AS CALIFORNIA CODE OF REGULATIONS, TITLE 10, SECTIONS 260.218.4 AND 260.218.4(C). Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 108 of 336 Reporting Source: Regulator Current Status: Final Allegations: THE ARKANSAS SECURITIES COMMISSIONER ENTERED INTO A CONSENT ORDER (ORDER NO. S-13-0113-13-OR01) WITH RBC CAPITAL MARKETS, LLC, ON OCTOBER 31, 2013. THE CONSENT ORDER WAS BASED ON A GLOBAL SETTLEMENT BETWEEN RBC AND A NUMBER OF STATES, LED BY A MEMBER TASK FORCE OF THE NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION ("NASAA"), REGARDING RBC'S FAILURE TO ESTABLISH AN ADEQUATE SUPERVISORY SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS, ©2021 FINRA. All rights reserved. Report aboutFAILURE RBC CAPITAL TO ENSURE MARKETS, ITS LLC CLIENT ASSOCIATES WERE REGISTERED IN THE 251 APPROPRIATE JURISDICTIONS CONSTITUTING A FAILURE TO ENFORCE ITS ESTABLISHED WRITTEN SUPERVISORY PROCEDURES, AND ACCEPTANCE OF ORDERS IN ARKANSAS THROUGH CLIENT ASSOCIATES WHO WERE NOT PROPERLY REGISTERED. AS A RESULT, RBC ENGAGED IN CONDUCT GIVING RISE TO LIABILITY UNDER ARK. CODE ANN. § 23-42-308 OF THE ARKANSAS SECURITIES ACT. RBC AGREED TO PAY $2.8 MILLION DOLLARS TO BE DISTRIBUTED AMONG THE 50 STATES, THE DISTRICT OF COLUMBIA, PUERTO RICO, AND THE U.S. VIRGIN ISLANDS. THE CONSENT ORDER IMPOSED A FINE OF $44,745.17 AS ARKANSAS'S PORTION OF THE TOTAL AMOUNT. THE ARKANSAS SECURITIES COMMISSIONER ENTERED INTO A CONSENT ORDER (ORDER NO. S-13-0113-13-OR01) WITH RBC CAPITAL MARKETS, LLC, ON OCTOBER 31, 2013. THE CONSENT ORDER WAS BASED ON A www.finra.org/brokercheck GLOBAL SETTLEMENT BETWEEN RBC AND A NUMBER OF STATES, LED BY User Guidance A MEMBER TASK FORCE OF THE NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION ("NASAA"), REGARDING RBC'S FAILURE TO ESTABLISH AN ADEQUATE SUPERVISORY SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS, FAILURE TO ENSURE ITS CLIENT ASSOCIATES WERE REGISTERED IN THE APPROPRIATE JURISDICTIONS CONSTITUTING A FAILURE TO ENFORCE ITS ESTABLISHED WRITTEN SUPERVISORY PROCEDURES, AND ACCEPTANCE OF ORDERS IN ARKANSAS THROUGH CLIENT ASSOCIATES WHO WERE NOT PROPERLY REGISTERED. AS A RESULT, RBC ENGAGED IN CONDUCT GIVING RISE TO LIABILITY UNDER ARK. CODE ANN. § 23-42-308 OF THE ARKANSAS SECURITIES ACT. RBC AGREED TO PAY $2.8 MILLION DOLLARS TO BE DISTRIBUTED AMONG THE 50 STATES, THE DISTRICT OF COLUMBIA, PUERTO RICO, AND THE U.S. VIRGIN ISLANDS. THE CONSENT ORDER IMPOSED A FINE OF $44,745.17 AS ARKANSAS'S PORTION OF THE TOTAL AMOUNT. Initiated By: ARKANSAS SECURITIES DEPARTMENT Date Initiated: 10/31/2013 Docket/Case Number: S-13-0113 URL for Regulatory Action: 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: 10/31/2013 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 $44,745.17 Other Sanctions Ordered: Sanction Details: RBC CAPITAL MARKETS, LLC, PAID A FINE OF $44,745.17 TO THE ARKANSAS SECURITIES DEPARTMENT WITHIN TEN DAYS OF THE ENTRY OF THE CONSENT ORDER. Regulator Statement THE CONSENT ORDER WAS BASED ON A GLOBAL SETTLEMENT BETWEEN RBC CAPITAL MARKETS, LLC, AND A NUMBER OF STATES, WHICH RESULTED FROM AN INVESTIGATION AND SETTLEMENT NEGOTIATION LED ©2021 FINRA. All rights reserved. Report aboutBY A RBC MEMBER CAPITAL TASKMARKETS, FORCE LLC OF NASAA. 252 www.finra.org/brokercheck User Guidance THE CONSENT ORDER WAS BASED ON A GLOBAL SETTLEMENT BETWEEN RBC CAPITAL MARKETS, LLC, AND A NUMBER OF STATES, WHICH RESULTED FROM AN INVESTIGATION AND SETTLEMENT NEGOTIATION LED BY A MEMBER TASK FORCE OF NASAA. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: ARKANSAS SECURITIES COMMISSIONER Date Initiated: 10/31/2013 Docket/Case Number: S-13-0113

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 10/31/2013 Sanctions Ordered: Monetary/Fine $44,745.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTIONS 23-42-301(B)(1) AND SECTION 23-42-308(A)(2)(J) OF THE ARKANSAS CODE. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ©2021 FINRA. All rights reserved. Report aboutENFORCE RBC CAPITAL AN ADEQUATE MARKETS, LLC SYSTEM TO MONITOR THE LICENSING STATUS 253 OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE www.finra.org/brokercheck AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT User Guidance CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 109 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: ALASKA DIVISION OF BANKING & SECURITIES Date Initiated: 10/31/2013 Docket/Case Number: 13-1399-S

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 10/31/2013 Sanctions Ordered: Monetary/Fine $44,370.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF AS 45.55.030(A) AND AS 45.55060 OF THE ALASKA SECURITIES ACT. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 254 www.finra.org/brokercheck User Guidance

THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF AS 45.55.030(A) AND AS 45.55060 OF THE ALASKA SECURITIES ACT. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 110 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF NEVADA SECURITIES DIVISION Date Initiated: 09/26/2013 Docket/Case Number: I13-161-DJF

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 09/26/2013 Sanctions Ordered: Monetary/Fine $90,200.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, ©2021 FINRA. All rights reserved. Report aboutPROCEDURES RBC CAPITAL ANDMARKETS, SYSTEMS LLC THAT REASONABLY SUPERVISE THE TRADE 255 PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF SECTION NRS 90.310(2) AND CONDUCT RULE 3010 OF THE NEVADA UNIFORM SECURITIES ACT. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 111 of 336 Reporting Source: Regulator Current Status: Final Allegations: ON NOVEMBER 1, 2013, THE SECURITIES DIVISION ENTERED INTO A CONSENT ORDER WITH RBC CAPITAL MARKETS, LLC (RBC) TO SETTLE ALLEGATIONS RELATED TO RBC SALESPERSONS ACCEPTING ORDERS FROM CLIENTS IN WASHINGTON STATE WHEN THE SALESPERSONS WERE NOT REGISTERED IN THE STATE. THE DIVISION ALLEGED THAT RBC FAILED TO REASONABLY SUPERVISE ITS SALESPERSONS IN VIOLATION OF RCW 21.20.110(1)(J), AND THAT RBC EMPLOYED UNREGISTERED SALESPERSONS IN VIOLATION OF RCW 21.20.110(1)(B). RBC NEITHER ADMITTED NOR DENIED THE DIVISION'S ALLEGATIONS. RBC UNDERTOOK AND AGREED TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES, AND SYSTEMS THAT WOULD ENSURE RBC SALESPERSONS WOULD ONLY ACCEPT CLIENT ORDERS FROM STATES IN WHICH THEY WERE REGISTERED. FURTHER, RBC AGREED TO PAY A FINE OF $45,140.17 AND WAIVED ITS RIGHT TO A HEARING AND JUDICIAL REVIEW OF THE MATTER. Initiated By: WASHINGTON Date Initiated: 11/01/2013

Docket/Case Number: S-13-1276-13-CO01 URL for Regulatory Action: 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:

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

Resolution: Order Resolution Date: 11/01/2013 Sanctions Ordered: Monetary/Fine $45,140.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF RCW 21.20.040(2) AND RCW 21.20. 110(1)(J) OF THE SECURITIES ACT OF WASHINGTON. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 112 of 336 Reporting Source: Regulator Current Status: Final Allegations: EMPLOYING UNLICESED SALESPERSONS TO ACT IN OREGON; FAILURE TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR THE LICENSE STATUS OF PERSONS ACCEPTING CLIENT ORDERS Initiated By: OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, DIVISION OF FINANCE AND CORPORATE SECURITIES

Date Initiated: 11/01/2013 Docket/Case Number: S-13-0146 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Undertaking Sought: Other Sanction(s)/Relief CIVIL PENALTY AND PAYMENT FOR DCBS CONSUMER FINANCIAL Sought: EDUCATION ACCOUNT

Resolution: Consent Resolution Date: 11/01/2013 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 $57,370.17 Other Sanctions Ordered: N/A Sanction Details: PAYMENT OF $57,370.17 INCLUDING CIVIL PENALTY OF $54,501.66 AND $2,868.51 FOR DCBS CONCUMER FINANCIAL EDUCATION ACCOUNT Regulator Statement THIS MATTER AROSE FROM A MULTI-STATE INVESTIGATION COORDINATED BY NASAA REGARDING LICENSING OF CLIENT ASSOCIATES AT RBC CAPITAL MARKETS, LLC AND RBC'S SUPERVISION SYSTEM WITH RESPECT TO THE LICENSE OF CLIENT ASSOCIATES. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WHERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: STATE OF OREGON DIVISION OF FINANCE AND CORPORATE SECURITIES Date Initiated: 11/01/2013 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 259 www.finra.org/brokercheck User Guidance

Date Initiated: 11/01/2013 Docket/Case Number: S-13-0146

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 11/01/2013 Sanctions Ordered: Monetary/Fine $57,370.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF OREGON ADMINISTRATIVE RULE 441- 205-0210(3) AS WELL AS OREGON REVISED STATUE 59.165(3). Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 113 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASDAQ RULE 4611(A)(6): THE FIRM FAILED TO POPULATE 194,219 ©2021 FINRA. All rights reserved. Report aboutORDERS RBC CAPITAL IT ROUTED MARKETS, TO LLCNASDAQ WITH THE CORRECT CAPACITY CODE. 260 www.finra.org/brokercheck User Guidance

Allegations: NASDAQ RULE 4611(A)(6): THE FIRM FAILED TO POPULATE 194,219 ORDERS IT ROUTED TO NASDAQ WITH THE CORRECT CAPACITY CODE. Initiated By: NASDAQ STOCK MARKET Date Initiated: 10/15/2013 Docket/Case Number: 2012034738501

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/15/2013 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 $12,500.00 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 $12,500. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT THE FIRM VIOLATED NASDAQ RULE 4611(A)(6): THE FIRM FAILED TO POPULATE 194,219 ORDERS IT ROUTED TO NASDAQ WITH THE CORRECT CAPACITY CODE. Initiated By: NASDAQ STOCK MARKET Date Initiated: 10/15/2013 Docket/Case Number: 2012034738501

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/15/2013 Sanctions Ordered: Censure Monetary/Fine $12,500.00 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 $12,500.00. i Disclosure 114 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: ILLINOIS SECURITIES DEPARTMENT Date Initiated: 09/11/2013 Docket/Case Number: 1300159

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 UNDERTAKING Sought:

Resolution: Order

Resolution Date: 09/11/2013 Sanctions Ordered: Monetary/Fine $137,970.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF SECTION 12 OF THE ILLINOIS SECURITIES LAW OF 1953. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 115 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: NORTH DAKOTA SECURITIES DEPARTMENT Date Initiated: 09/27/2013 Docket/Case Number: N/A

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

Resolution: Order Resolution Date: 09/27/2013 Sanctions Ordered: Monetary/Fine $33,540.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF SECTION 10-04-10(2) AND DISCIPLINE UNDER SECTION 10-04-11(1)(M) OF THE NORTH DAKOTA CENTURY CODE. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 116 of 336 Reporting Source: Regulator Current Status: Final Allegations: THE DIVISION ALLEGED RESPONDENT FAILED TO REASONABLY SUPERVISE AGENTS UNDER SECTION 61-1-6(2)(A)(II)(J) OF THE UTAH UNIFORM SECURITIES ACT ("ACT")AND EMPLOYED UNLICENSED AGENTS UNDER SECTION 61-1-3 OF THE ACT. Initiated By: UTAH Date Initiated: 09/26/2013 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 264 www.finra.org/brokercheck User Guidance

Date Initiated: 09/26/2013 Docket/Case Number: SD-13-0043 URL for Regulatory Action: 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: Stipulation and Consent Resolution Date: 09/26/2013 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 $45,270.17 Other Sanctions Ordered: Sanction Details: THE FINE WAS PAID IN FULL ON OR ABOUT 10/1/2013. Regulator Statement A PDF OF THE CONSENT ORDER CAN BE VIEWED ON THE DIVISION'S WEB SITE. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WEERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: UTAH DIVISION OF SECURITIES Date Initiated: 09/26/2013 Docket/Case Number: SD-13-0043

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 09/26/2013 Sanctions Ordered: Monetary/Fine $45,270.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDITIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF SECTION 61-1-6(2)(A)(II)(J) AND 61-1- 3(2)(A) OF THE UTAH UNIFORM SECURITIES ACT. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 117 of 336 Reporting Source: Regulator Current Status: Final Allegations: ON SEPTEMBER 27, 2013, THE ALABAMA SECURITIES COMMISSION AND RBC CAPITAL MARKETS LLC ENTERED INTO A CONSENT ORDER TO RESOLVE THE OUTSTANDING ISSUES SURROUNDING THE FIRM'S FAILURE TO SUPERVISE CERTAIN CLIENT ASSOCIATES AND SENIOR CLIENT ASSOCIATES. THE FIRM AGREED TO PAY $37,770.17 IN INVESTIGATIVE COSTS TO THE ALABAMA SECURITIES COMMISSION. THE FIRM FURTHER ©2021 FINRA. All rights reserved. Report aboutAGREED RBC CAPITAL TO MAKE MARKETS, CERTAIN LLC CHANGES TO THEIR SUPERVISORY SYSTEM 266 IN RESPECT TO THE CLIENT ASSOCIATES. THEY FURTHERMORE AGREED TO WAIVE THEIR RIGHT TO A HEARING ON THIS MATTER. ON SEPTEMBER 27, 2013, THE ALABAMA SECURITIES COMMISSION AND www.finra.org/brokercheck RBC CAPITAL MARKETS LLC ENTERED INTO A CONSENT ORDER TO User Guidance RESOLVE THE OUTSTANDING ISSUES SURROUNDING THE FIRM'S FAILURE TO SUPERVISE CERTAIN CLIENT ASSOCIATES AND SENIOR CLIENT ASSOCIATES. THE FIRM AGREED TO PAY $37,770.17 IN INVESTIGATIVE COSTS TO THE ALABAMA SECURITIES COMMISSION. THE FIRM FURTHER AGREED TO MAKE CERTAIN CHANGES TO THEIR SUPERVISORY SYSTEM IN RESPECT TO THE CLIENT ASSOCIATES. THEY FURTHERMORE AGREED TO WAIVE THEIR RIGHT TO A HEARING ON THIS MATTER. Initiated By: ALABAMA SECURITIES COMMISSION Date Initiated: 09/27/2013 Docket/Case Number: CO-2013-0016 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): CONSENT ORDER Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/27/2013 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 $37,770.17 Other Sanctions Ordered: Sanction Details: ON SEPTEMBER 27, 2013, THE ALABAMA SECURITIES COMMISSION AND RBC CAPITAL MARKETS LLC ENTERED INTO A CONSENT ORDER TO RESOLVE THE OUTSTANDING ISSUES SURROUNDING THE FIRM'S FAILURE TO SUPERVISE CERTAIN CLIENT ASSOCIATES AND SENIOR CLIENT ASSOCIATES. THE FIRM AGREED TO PAY $37,770.17 IN INVESTIGATIVE COSTS TO THE ALABAMA SECURITIES COMMISSION. THE FIRM FURTHER AGREED TO MAKE CERTAIN CHANGES TO THEIR SUPERVISORY SYSTEM IN RESPECT TO THE CLIENT ASSOCIATES. THEY FURTHERMORE AGREED TO WAIVE THEIR RIGHT TO A HEARING ON THIS MATTER. Regulator Statement ON SEPTEMBER 27, 2013, THE ALABAMA SECURITIES COMMISSION AND RBC CAPITAL MARKETS LLC ENTERED INTO A CONSENT ORDER TO RESOLVE THE OUTSTANDING ISSUES SURROUNDING THE FIRM'S FAILURE TO SUPERVISE CERTAIN CLIENT ASSOCIATES AND SENIOR CLIENT ASSOCIATES. THE FIRM AGREED TO PAY $37,770.17 IN INVESTIGATIVE ©2021 FINRA. All rights reserved. Report aboutCOSTS RBC TOCAPITAL THE MARKETS,ALABAMA LLC SECURITIES COMMISSION. THE FIRM FURTHER 267 AGREED TO MAKE CERTAIN CHANGES TO THEIR SUPERVISORY SYSTEM IN RESPECT TO THE CLIENT ASSOCIATES. THEY FURTHERMORE AGREED TO WAIVE THEIR RIGHT TO A HEARING ON THIS MATTER. ON SEPTEMBER 27, 2013, THE ALABAMA SECURITIES COMMISSION AND www.finra.org/brokercheck RBC CAPITAL MARKETS LLC ENTERED INTO A CONSENT ORDER TO User Guidance RESOLVE THE OUTSTANDING ISSUES SURROUNDING THE FIRM'S FAILURE TO SUPERVISE CERTAIN CLIENT ASSOCIATES AND SENIOR CLIENT ASSOCIATES. THE FIRM AGREED TO PAY $37,770.17 IN INVESTIGATIVE COSTS TO THE ALABAMA SECURITIES COMMISSION. THE FIRM FURTHER AGREED TO MAKE CERTAIN CHANGES TO THEIR SUPERVISORY SYSTEM IN RESPECT TO THE CLIENT ASSOCIATES. THEY FURTHERMORE AGREED TO WAIVE THEIR RIGHT TO A HEARING ON THIS MATTER. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: ALABAMA SECURITIES COMMISSION Date Initiated: 09/27/2013 Docket/Case Number: CO-2013-0016

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 09/27/2013 Sanctions Ordered: Monetary/Fine $37,770.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF RULE 830-X-3-13(3) OF THE RULES OF THE ALABAMA SECURITIES COMMISSION AS WELL AS SECTION 8-6-3(A) OF THE CODE OF ALABAMA. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE ©2021 FINRA. All rights reserved. Report aboutAMOUNT RBC CAPITAL OF $2.8 MARKETS, MILLION. LLC THIS RESULTED FROM ALLEGATIONS THAT 268 CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. www.finra.org/brokercheck User Guidance

AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 118 of 336 Reporting Source: Regulator Current Status: Final Allegations: 1.RBC ADMITS THE JURISDICTION OF THE TEXAS STATE SECURITIES BOARD IN THIS MATTER. BACKGROUND ON CLIENT ASSOCIATES 2.THE CAS FUNCTION AS SALES ASSISTANTS AND TYPICALLY PROVIDE ADMINISTRATIVE AND SALES SUPPORT TO ONE OR MORE OF RBC'S REGISTERED REPRESENTATIVES ("RRS"). THERE ARE DIFFERENT CA POSITIONS, INCLUDING REGISTERED CLIENT ASSOCIATE AND REGISTERED SENIOR CLIENT ASSOCIATE. 3.THE PRIMARY JOB DUTIES VARY DEPENDING ON THE SPECIFIC CA POSITION. IN VARYING DEGREES, THE "MAJOR JOB ACCOUNTABILITIES" OF A CA INCLUDE: A.HANDLING CLIENT REQUESTS; B.RESOLVING CLIENT INQUIRIES; C.DETERMINING IF CLIENT ISSUES REQUIRE ESCALATION TO THE RR OR THE BRANCH MANAGEMENT TEAM; AND D.PROCESSING OF OPERATIONAL DOCUMENTS SUCH AS LETTERS OF AUTHORIZATION AND CLIENT CHECK REQUESTS. 4.IN ADDITION TO THE RESPONSIBILITIES DESCRIBED ABOVE, AND OF PARTICULAR SIGNIFICANCE TO THIS ORDER, SOME CAS ARE PERMITTED TO ACCEPT UNSOLICITED ORDERS FROM CLIENTS; OTHERS ARE PERMITTED, WITH THE ASSISTANCE OF A RR, TO PROSPECT FOR NEW CLIENTS, OPEN NEW ACCOUNTS, GATHER ASSETS AND SELECT INVESTMENTS TO RECOMMEND TO CLIENTS. AS DISCUSSED BELOW, RBC'S WRITTEN POLICIES AND PROCEDURES REQUIRE THAT ANY CAS ACCEPTING CLIENT ORDERS FIRST OBTAIN THE NECESSARY LICENSES AND REGISTRATIONS. 5.NOTABLY, RRS MIGHT HAVE A "PRIMARY CA" AND A "SECONDARY CA", OR A "PRIMARY CA TEAM" AND A "SECONDARY CA TEAM". AS SUGGESTED BY THE DESIGNATION, THE CUSTOMARY PRACTICE IS THAT THE PRIMARY CA ©2021 FINRA. All rights reserved. Report aboutOR TEAMRBC CAPITAL WOULD MARKETS, HANDLE LLC THE RR'S ADMINISTRATIVE MATTERS AND 269 CLIENT ORDERS. HOWEVER, IF THE PRIMARY CA OR TEAM WAS UNAVAILABLE, THE SECONDARY CA OR TEAM WOULD STEP IN TO HANDLE THE RR'S ADMINISTRATIVE MATTERS AND CLIENT ORDERS. 6.DURING THE PERIOD FROM 2005 TO 2009, RBC EMPLOYED AN AVERAGE OF APPROXIMATELY 672 CAS PER YEAR. REGISTRATION REQUIRED 7.SECTION 12.A OF THE TEXAS SECURITIES ACT SPECIFIES THAT AN AGENT CANNOT SELL, OFFER FOR SALE, OR MAKE SALE OF ANY SECURITIES ON BEHALF OF A DEALER WITHIN TEXAS UNLESS HE OR SHE IS REGISTERED AS AN AGENT FOR THAT PARTICULAR DEALER. 8.PURSUANT TO THE GENERAL PROHIBITION UNDER SECTION 12.A OF THE TEXAS SECURITIES ACT, A PERSON CANNOT ACCEPT UNSOLICITED ORDERS IN TEXAS WITHOUT BEING REGISTERED AS AN AGENT OF THE RELEVANT DEALER. 9.PURSUANT TO SECTION 14.A.5(A) OF THE TEXAS SECURITIES ACT, A DEALER MAY BE REPRIMANDED FOR SELLING SECURITIES IN TEXAS THROUGH AN AGENT OTHER THAN A REGISTERED AGENT. RBC REQUIRES REGISTRATION OF CLIENT ASSOCIATES 10.IN ORDER FOR A CA TO ACCEPT CLIENT ORDERS, RBC GENERALLY REQUIRED EACH CA TO PASS THE SERIES 7 AND 63 QUALIFICATION EXAMS AND TO REGISTER IN THE APPROPRIATE JURISDICTIONS. 11.AT ALL TIMES RELEVANT TO THIS ORDER, RBC'S POLICIES AND PROCEDURES SPECIFIED THAT EACH CA MAINTAIN REGISTRATIONS IN THE SAME JURISDICTIONS AS HIS OR HER FA, OR BROADLY REQUIRED THAT EACH CA MAINTAIN REGISTRATIONS IN ALL NECESSARY JURISDICTIONS. REGULATORY INVESTIGATIONS AND FINDINGS 12.DURING LATE 2009, RBC RECEIVED REGULATORY INQUIRIES REGARDING CA REGISTRATIONS. 13.THE MULTI-STATE INVESTIGATION FOCUSED ON SYSTEMIC ISSUES WITH RBC CA REGISTRATIONS AND RELATED SUPERVISORY STRUCTURE. SPECIFICALLY: A.AFTER ACCEPTING AN ORDER FROM A CLIENT, CAS ACCESSED THE ELECTRONIC ORDER ENTRY SYSTEM TO PLACE THE ORDER; B.THE ORDER ENTRY SYSTEM AUTOMATICALLY RECORDED THE IDENTITY OF THE PERSON ENTERING THE ORDER USING THE USER'S LOGIN INFORMATION. IF THE ORDER WAS RECEIVED FROM THE CLIENT BY SOMEONE OTHER THAN THE PERSON ENTERING THE ORDER, THE PERSON ENTERING THE ORDER WAS REQUIRED TO IDENTIFY THE PERSON WHO ACCEPTED THE ORDER FROM THE CLIENT BY TYPING THE NAME OR INITIALS IN A TEXT BOX; C.RBC'S TRADING SYSTEM CHECKED THE REGISTRATION OF THE RR ASSIGNED TO THE ACCOUNT, BUT DID NOT CHECK THE REGISTRATION STATUS OF THE PERSON ACCEPTING THE ORDER, IF DIFFERENT FROM THE RR, (THE "WHO ACCEPTED FIELD") TO ENSURE THAT THE PERSON WAS REGISTERED IN THE APPROPRIATE JURISDICTION. 1.RBC ADMITS THE JURISDICTION OF THE TEXAS STATE SECURITIES BOARD IN THIS MATTER. BACKGROUND ON CLIENT ASSOCIATES 2.THE CAS FUNCTION AS SALES ASSISTANTS AND TYPICALLY PROVIDE ADMINISTRATIVE AND SALES SUPPORT TO ONE OR MORE OF RBC'S REGISTERED REPRESENTATIVES ("RRS"). THERE ARE DIFFERENT CA POSITIONS, INCLUDING REGISTERED CLIENT ASSOCIATE AND REGISTERED SENIOR CLIENT ASSOCIATE. 3.THE PRIMARY JOB DUTIES VARY DEPENDING ON THE SPECIFIC CA POSITION. IN VARYING DEGREES, THE "MAJOR JOB ACCOUNTABILITIES" OF A CA INCLUDE: A.HANDLING CLIENT REQUESTS; B.RESOLVING CLIENT INQUIRIES; C.DETERMINING IF CLIENT ISSUES REQUIRE ESCALATION TO THE RR OR THE BRANCH MANAGEMENT TEAM; AND D.PROCESSING OF OPERATIONAL DOCUMENTS SUCH AS LETTERS OF AUTHORIZATION AND CLIENT CHECK REQUESTS. 4.IN ADDITION TO THE RESPONSIBILITIES DESCRIBED ABOVE, AND OF PARTICULAR SIGNIFICANCE TO THIS ORDER, SOME CAS ARE PERMITTED TO ACCEPT UNSOLICITED ORDERS FROM CLIENTS; OTHERS ARE PERMITTED, WITH THE ASSISTANCE OF A RR, TO PROSPECT FOR NEW CLIENTS, OPEN NEW ACCOUNTS, GATHER ASSETS AND SELECT INVESTMENTS TO RECOMMEND TO CLIENTS. AS DISCUSSED BELOW, RBC'S WRITTEN POLICIES AND PROCEDURES REQUIRE THAT ANY CAS www.finra.org/brokercheck ACCEPTING CLIENT ORDERS FIRST OBTAIN THE NECESSARY LICENSES User Guidance AND REGISTRATIONS. 5.NOTABLY, RRS MIGHT HAVE A "PRIMARY CA" AND A "SECONDARY CA", OR A "PRIMARY CA TEAM" AND A "SECONDARY CA TEAM". AS SUGGESTED BY THE DESIGNATION, THE CUSTOMARY PRACTICE IS THAT THE PRIMARY CA OR TEAM WOULD HANDLE THE RR'S ADMINISTRATIVE MATTERS AND CLIENT ORDERS. HOWEVER, IF THE PRIMARY CA OR TEAM WAS UNAVAILABLE, THE SECONDARY CA OR TEAM WOULD STEP IN TO HANDLE THE RR'S ADMINISTRATIVE MATTERS AND CLIENT ORDERS. 6.DURING THE PERIOD FROM 2005 TO 2009, RBC EMPLOYED AN AVERAGE OF APPROXIMATELY 672 CAS PER YEAR. REGISTRATION REQUIRED 7.SECTION 12.A OF THE TEXAS SECURITIES ACT SPECIFIES THAT AN AGENT CANNOT SELL, OFFER FOR SALE, OR MAKE SALE OF ANY SECURITIES ON BEHALF OF A DEALER WITHIN TEXAS UNLESS HE OR SHE IS REGISTERED AS AN AGENT FOR THAT PARTICULAR DEALER. 8.PURSUANT TO THE GENERAL PROHIBITION UNDER SECTION 12.A OF THE TEXAS SECURITIES ACT, A PERSON CANNOT ACCEPT UNSOLICITED ORDERS IN TEXAS WITHOUT BEING REGISTERED AS AN AGENT OF THE RELEVANT DEALER. 9.PURSUANT TO SECTION 14.A.5(A) OF THE TEXAS SECURITIES ACT, A DEALER MAY BE REPRIMANDED FOR SELLING SECURITIES IN TEXAS THROUGH AN AGENT OTHER THAN A REGISTERED AGENT. RBC REQUIRES REGISTRATION OF CLIENT ASSOCIATES 10.IN ORDER FOR A CA TO ACCEPT CLIENT ORDERS, RBC GENERALLY REQUIRED EACH CA TO PASS THE SERIES 7 AND 63 QUALIFICATION EXAMS AND TO REGISTER IN THE APPROPRIATE JURISDICTIONS. 11.AT ALL TIMES RELEVANT TO THIS ORDER, RBC'S POLICIES AND PROCEDURES SPECIFIED THAT EACH CA MAINTAIN REGISTRATIONS IN THE SAME JURISDICTIONS AS HIS OR HER FA, OR BROADLY REQUIRED THAT EACH CA MAINTAIN REGISTRATIONS IN ALL NECESSARY JURISDICTIONS. REGULATORY INVESTIGATIONS AND FINDINGS 12.DURING LATE 2009, RBC RECEIVED REGULATORY INQUIRIES REGARDING CA REGISTRATIONS. 13.THE MULTI-STATE INVESTIGATION FOCUSED ON SYSTEMIC ISSUES WITH RBC CA REGISTRATIONS AND RELATED SUPERVISORY STRUCTURE. SPECIFICALLY: A.AFTER ACCEPTING AN ORDER FROM A CLIENT, CAS ACCESSED THE ELECTRONIC ORDER ENTRY SYSTEM TO PLACE THE ORDER; B.THE ORDER ENTRY SYSTEM AUTOMATICALLY RECORDED THE IDENTITY OF THE PERSON ENTERING THE ORDER USING THE USER'S LOGIN INFORMATION. IF THE ORDER WAS RECEIVED FROM THE CLIENT BY SOMEONE OTHER THAN THE PERSON ENTERING THE ORDER, THE PERSON ENTERING THE ORDER WAS REQUIRED TO IDENTIFY THE PERSON WHO ACCEPTED THE ORDER FROM THE CLIENT BY TYPING THE NAME OR INITIALS IN A TEXT BOX; C.RBC'S TRADING SYSTEM CHECKED THE REGISTRATION OF THE RR ASSIGNED TO THE ACCOUNT, BUT DID NOT CHECK THE REGISTRATION STATUS OF THE PERSON ACCEPTING THE ORDER, IF DIFFERENT FROM ©2021 FINRA. All rights reserved. Report aboutTHE RBC RR, CAPITAL (THE "WHO MARKETS, ACCEPTED LLC FIELD") TO ENSURE THAT THE PERSON 270 WAS REGISTERED IN THE APPROPRIATE JURISDICTION. 1.RBC ADMITS THE JURISDICTION OF THE TEXAS STATE SECURITIES BOARD IN THIS MATTER. BACKGROUND ON CLIENT ASSOCIATES 2.THE CAS FUNCTION AS SALES ASSISTANTS AND TYPICALLY PROVIDE ADMINISTRATIVE AND SALES SUPPORT TO ONE OR MORE OF RBC'S REGISTERED REPRESENTATIVES ("RRS"). THERE ARE DIFFERENT CA POSITIONS, INCLUDING REGISTERED CLIENT ASSOCIATE AND REGISTERED SENIOR CLIENT ASSOCIATE. 3.THE PRIMARY JOB DUTIES VARY DEPENDING ON THE SPECIFIC CA POSITION. IN VARYING DEGREES, THE "MAJOR JOB ACCOUNTABILITIES" OF A CA INCLUDE: A.HANDLING CLIENT REQUESTS; B.RESOLVING CLIENT INQUIRIES; C.DETERMINING IF CLIENT ISSUES REQUIRE ESCALATION TO THE RR OR THE BRANCH MANAGEMENT TEAM; AND D.PROCESSING OF OPERATIONAL DOCUMENTS SUCH AS LETTERS OF AUTHORIZATION AND CLIENT CHECK REQUESTS. 4.IN ADDITION TO THE RESPONSIBILITIES DESCRIBED ABOVE, AND OF PARTICULAR SIGNIFICANCE TO THIS ORDER, SOME CAS ARE PERMITTED TO ACCEPT UNSOLICITED ORDERS FROM CLIENTS; OTHERS ARE PERMITTED, WITH THE ASSISTANCE OF A RR, TO PROSPECT FOR NEW CLIENTS, OPEN NEW ACCOUNTS, GATHER ASSETS AND SELECT INVESTMENTS TO RECOMMEND TO CLIENTS. AS DISCUSSED BELOW, RBC'S WRITTEN POLICIES AND PROCEDURES REQUIRE THAT ANY CAS ACCEPTING CLIENT ORDERS FIRST OBTAIN THE NECESSARY LICENSES AND REGISTRATIONS. 5.NOTABLY, RRS MIGHT HAVE A "PRIMARY CA" AND A "SECONDARY CA", OR A "PRIMARY CA TEAM" AND A "SECONDARY CA TEAM". AS SUGGESTED BY THE DESIGNATION, THE CUSTOMARY PRACTICE IS THAT THE PRIMARY CA OR TEAM WOULD HANDLE THE RR'S ADMINISTRATIVE MATTERS AND CLIENT ORDERS. HOWEVER, IF THE PRIMARY CA OR TEAM WAS UNAVAILABLE, THE SECONDARY CA OR TEAM WOULD STEP IN TO HANDLE THE RR'S ADMINISTRATIVE MATTERS AND CLIENT ORDERS. 6.DURING THE PERIOD FROM 2005 TO 2009, RBC EMPLOYED AN AVERAGE OF APPROXIMATELY 672 CAS PER YEAR. REGISTRATION REQUIRED 7.SECTION 12.A OF THE TEXAS SECURITIES ACT SPECIFIES THAT AN AGENT CANNOT SELL, OFFER FOR SALE, OR MAKE SALE OF ANY SECURITIES ON BEHALF OF A DEALER WITHIN TEXAS UNLESS HE OR SHE IS REGISTERED AS AN AGENT FOR THAT PARTICULAR DEALER. 8.PURSUANT TO THE GENERAL PROHIBITION UNDER SECTION 12.A OF THE TEXAS SECURITIES ACT, A PERSON CANNOT ACCEPT UNSOLICITED ORDERS IN TEXAS WITHOUT BEING REGISTERED AS AN AGENT OF THE RELEVANT DEALER. 9.PURSUANT TO SECTION 14.A.5(A) OF THE TEXAS SECURITIES ACT, A DEALER MAY BE REPRIMANDED FOR SELLING SECURITIES IN TEXAS THROUGH AN AGENT OTHER THAN A REGISTERED AGENT. RBC REQUIRES REGISTRATION OF CLIENT ASSOCIATES 10.IN ORDER FOR A CA TO ACCEPT CLIENT ORDERS, RBC GENERALLY REQUIRED EACH CA TO PASS THE SERIES 7 AND 63 QUALIFICATION EXAMS AND TO REGISTER IN THE APPROPRIATE JURISDICTIONS. 11.AT ALL TIMES RELEVANT TO THIS ORDER, RBC'S POLICIES AND PROCEDURES SPECIFIED THAT EACH CA MAINTAIN REGISTRATIONS IN THE SAME JURISDICTIONS AS HIS OR HER FA, OR BROADLY REQUIRED THAT EACH CA MAINTAIN REGISTRATIONS IN ALL NECESSARY JURISDICTIONS. REGULATORY INVESTIGATIONS AND FINDINGS 12.DURING LATE 2009, RBC RECEIVED REGULATORY INQUIRIES REGARDING CA REGISTRATIONS. 13.THE MULTI-STATE INVESTIGATION FOCUSED ON SYSTEMIC ISSUES WITH RBC CA REGISTRATIONS AND RELATED SUPERVISORY STRUCTURE. SPECIFICALLY: A.AFTER ACCEPTING AN ORDER FROM A CLIENT, CAS ACCESSED THE ELECTRONIC ORDER ENTRY SYSTEM TO PLACE THE ORDER; B.THE ORDER ENTRY SYSTEM AUTOMATICALLY RECORDED THE IDENTITY OF THE PERSON ENTERING THE ORDER USING THE USER'S LOGIN INFORMATION. IF THE ORDER WAS RECEIVED FROM THE CLIENT BY SOMEONE OTHER THAN THE PERSON ENTERING THE ORDER, THE PERSON ENTERING THE ORDER WAS REQUIRED TO IDENTIFY THE www.finra.org/brokercheck PERSON WHO ACCEPTED THE ORDER FROM THE CLIENT BY TYPING THE User Guidance NAME OR INITIALS IN A TEXT BOX; C.RBC'S TRADING SYSTEM CHECKED THE REGISTRATION OF THE RR ASSIGNED TO THE ACCOUNT, BUT DID NOT CHECK THE REGISTRATION STATUS OF THE PERSON ACCEPTING THE ORDER, IF DIFFERENT FROM THE RR, (THE "WHO ACCEPTED FIELD") TO ENSURE THAT THE PERSON WAS REGISTERED IN THE APPROPRIATE JURISDICTION. Initiated By: TEXAS Date Initiated: 09/10/2013 Docket/Case Number: IC13-CAF-09 URL for Regulatory Action: Principal Product Type: Other 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: 09/16/2013 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 $236,035.17 Other Sanctions Ordered: REPRIMAND AND FINE. Sanction Details: REPRIMAND AND FINE. Regulator Statement 14.THE MULTI-STATE INVESTIGATION IDENTIFIED INSTANCES IN WHICH CAS SUPPORTED RRS REGISTERED IN TEXAS WHEN THE CAS WERE NOT REGISTERED IN TEXAS AS AGENTS OF RBC. THIS DIFFERENCE IN REGISTRATION STATUS INCREASED THE POSSIBILITY THAT CAS WOULD ACCEPT ORDERS WHICH THEY DID NOT SOLICIT FROM CUSTOMERS WITHOUT PROPER REGISTRATION. 15.THE MULTI-STATE INVESTIGATION DETERMINED THAT IT WAS HIGHLY LIKELY THAT CERTAIN RBC CAS ACCEPTED ORDERS, WHICH THEY DID NOT SOLICIT, IN TEXAS AT TIMES WHEN THE CAS WERE NOT APPROPRIATELY REGISTERED IN TEXAS. 16.AS A RESULT OF THE INQUIRIES BY STATE REGULATORS, RBC CONDUCTED A REVIEW OF ITS CA REGISTRATION PRACTICES. 17.RBC'S REVIEW FOUND THAT AS OF NOVEMBER 2008, THE FIRM HAD 692 REGISTERED CAS. WHILE CAS WERE REGISTERED IN APPROXIMATELY 7 ©2021 FINRA. All rights reserved. Report aboutSTATES, RBC CAPITAL AT THAT MARKETS, TIME RRSLLC WERE REGISTERED, ON AVERAGE, IN 17 271 STATES. APPROXIMATELY 454, ALMOST 66%, OF THOSE REGISTERED CAS WERE ONLY REGISTERED IN THEIR HOME STATE OR THEIR HOME STATE AND ONE ADDITIONAL STATE. 18.MANY RBC CAS WERE NOT REGISTERED IN THE SAME JURISDICTIONS AS THEIR RESPECTIVE RRS. RBC'S REVIEW IDENTIFIED INCIDENCES WHERE CAS WHO WERE NOT PROPERLY STATE REGISTERED ACCEPTED ORDERS THEY HAD NOT SOLICITED. 19.BEGINNING IN 2010, RBC TOOK STEPS TO ENHANCE ITS POLICIES AND PROCEDURES REGARDING CAS' STATE REGISTRATIONS, AND ADDED A SUBSTANTIAL NUMBER OF CA STATE REGISTRATIONS. A.IN JANUARY 2010, RBC AMENDED ITS REGISTRATION POLICY TO REQUIRE THAT EACH CA REGISTER IN THE SAME STATES AS THE RRS WHOM THEY SUPPORT. RBC ALERTED THE FIELD TO THIS POLICY. B.IN NOVEMBER 2010, SUPERVISORS IN RBC'S BRANCHES AND COMPLEXES REVIEWED THE CURRENT CA REGISTRATIONS TO ENSURE THE CAS WERE PROPERLY REGISTERED PRIOR TO THE ANNUAL RENEWALS. C.RBC UPDATED ITS TRAINING TO INCLUDE ADDITIONAL INFORMATION ON REGISTRATION REQUIREMENTS AND ON THE FIRM'S POLICIES ON CA REGISTRATION. RBC ALSO, AS PART OF THE ANNUAL REGISTRATION RENEWAL PROCESS, ADDED TO THE ANNUAL RENEWAL NOTICE INFORMATION REGARDING THE CA REGISTRATION POLICY. D.RBC MODIFIED ITS PROCEDURES REGARDING THE MANNER IN WHICH IT GRANTS ELECTRONIC ORDER ENTRY ACCESS TO CLIENT ACCOUNTS. THE REQUIRED FORMS WERE REVISED TO IDENTIFY SUPPORTING CAS AND THE FORMS ARE PROVIDED TO THE LICENSING AND REGISTRATION DEPARTMENT TO VERIFY THAT PROPER REGISTRATIONS ARE IN PLACE FOR RRS AND CAS WHEN ACCESS IS GRANTED. E.RBC CONDUCTED COMPLIANCE TRAINING SESSIONS FOR CAS COVERING INFORMATION ON ORDER ENTRY PROCEDURES AND REGISTRATION REQUIREMENTS. F.RBC REVISED ITS REGISTRATION FORMS TO IDENTIFY ASSIGNED CAS ON RRS' REGISTRATION FORMS AND ASSIGNED RRS ON CAS' REGISTRATION FORMS. THIS ALLOWS THE REGISTRATION AND LICENSING GROUP TO SUBMIT REGISTRATIONS FOR THE CAS THAT MIRROR THOSE HELD BY THE RRS WHOM THEY SUPPORT. 20.RBC HAS ALSO UNDERTAKEN TO IMPLEMENT ENHANCEMENTS TO ITS ORDER ENTRY SYSTEMS AND TO ITS SUPERVISION OF THE ORDER ENTRY PROCEDURES. THE ORDER ENTRY SYSTEMS WILL REQUIRE THE INDIVIDUAL ENTERING AN ORDER EITHER TO ATTEST THAT HE OR SHE ALSO ACCEPTED THE ORDER OR TO IDENTIFY THE PERSON WHO ACCEPTED THE ORDER BY ENTERING THAT PERSON'S SYSTEM ID. RBC POLICIES AND PROCEDURES PROHIBIT RBC PERSONNEL FROM USING ANY CREDENTIALS BUT THEIR OWN TO LOG ON TO THE ORDER ENTRY SYSTEMS. RBC IS DEVELOPING AN EXCEPTION REPORT TO IDENTIFY ANY TRADES ENTERED IN AN ACCOUNT FOR WHICH THE PERSON WHO ACCEPTED THE ORDER DID NOT HOLD THE NECESSARY STATE REGISTRATION. 21.RBC PROVIDED TIMELY RESPONSES AND SUBSTANTIAL COOPERATION IN CONNECTION WITH THE REGULATORY INVESTIGATIONS INTO THIS ISSUE. 14.THE MULTI-STATE INVESTIGATION IDENTIFIED INSTANCES IN WHICH CAS SUPPORTED RRS REGISTERED IN TEXAS WHEN THE CAS WERE NOT REGISTERED IN TEXAS AS AGENTS OF RBC. THIS DIFFERENCE IN REGISTRATION STATUS INCREASED THE POSSIBILITY THAT CAS WOULD ACCEPT ORDERS WHICH THEY DID NOT SOLICIT FROM CUSTOMERS WITHOUT PROPER REGISTRATION. 15.THE MULTI-STATE INVESTIGATION DETERMINED THAT IT WAS HIGHLY LIKELY THAT CERTAIN RBC CAS ACCEPTED ORDERS, WHICH THEY DID NOT SOLICIT, IN TEXAS AT TIMES WHEN THE CAS WERE NOT www.finra.org/brokercheck APPROPRIATELY REGISTERED IN TEXAS. User Guidance 16.AS A RESULT OF THE INQUIRIES BY STATE REGULATORS, RBC CONDUCTED A REVIEW OF ITS CA REGISTRATION PRACTICES. 17.RBC'S REVIEW FOUND THAT AS OF NOVEMBER 2008, THE FIRM HAD 692 REGISTERED CAS. WHILE CAS WERE REGISTERED IN APPROXIMATELY 7 STATES, AT THAT TIME RRS WERE REGISTERED, ON AVERAGE, IN 17 STATES. APPROXIMATELY 454, ALMOST 66%, OF THOSE REGISTERED CAS WERE ONLY REGISTERED IN THEIR HOME STATE OR THEIR HOME STATE AND ONE ADDITIONAL STATE. 18.MANY RBC CAS WERE NOT REGISTERED IN THE SAME JURISDICTIONS AS THEIR RESPECTIVE RRS. RBC'S REVIEW IDENTIFIED INCIDENCES WHERE CAS WHO WERE NOT PROPERLY STATE REGISTERED ACCEPTED ORDERS THEY HAD NOT SOLICITED. 19.BEGINNING IN 2010, RBC TOOK STEPS TO ENHANCE ITS POLICIES AND PROCEDURES REGARDING CAS' STATE REGISTRATIONS, AND ADDED A SUBSTANTIAL NUMBER OF CA STATE REGISTRATIONS. A.IN JANUARY 2010, RBC AMENDED ITS REGISTRATION POLICY TO REQUIRE THAT EACH CA REGISTER IN THE SAME STATES AS THE RRS WHOM THEY SUPPORT. RBC ALERTED THE FIELD TO THIS POLICY. B.IN NOVEMBER 2010, SUPERVISORS IN RBC'S BRANCHES AND COMPLEXES REVIEWED THE CURRENT CA REGISTRATIONS TO ENSURE THE CAS WERE PROPERLY REGISTERED PRIOR TO THE ANNUAL RENEWALS. C.RBC UPDATED ITS TRAINING TO INCLUDE ADDITIONAL INFORMATION ON REGISTRATION REQUIREMENTS AND ON THE FIRM'S POLICIES ON CA REGISTRATION. RBC ALSO, AS PART OF THE ANNUAL REGISTRATION RENEWAL PROCESS, ADDED TO THE ANNUAL RENEWAL NOTICE INFORMATION REGARDING THE CA REGISTRATION POLICY. D.RBC MODIFIED ITS PROCEDURES REGARDING THE MANNER IN WHICH IT GRANTS ELECTRONIC ORDER ENTRY ACCESS TO CLIENT ACCOUNTS. THE REQUIRED FORMS WERE REVISED TO IDENTIFY SUPPORTING CAS AND THE FORMS ARE PROVIDED TO THE LICENSING AND REGISTRATION DEPARTMENT TO VERIFY THAT PROPER REGISTRATIONS ARE IN PLACE FOR RRS AND CAS WHEN ACCESS IS GRANTED. E.RBC CONDUCTED COMPLIANCE TRAINING SESSIONS FOR CAS COVERING INFORMATION ON ORDER ENTRY PROCEDURES AND REGISTRATION REQUIREMENTS. F.RBC REVISED ITS REGISTRATION FORMS TO IDENTIFY ASSIGNED CAS ON RRS' REGISTRATION FORMS AND ASSIGNED RRS ON CAS' REGISTRATION FORMS. THIS ALLOWS THE REGISTRATION AND LICENSING GROUP TO SUBMIT REGISTRATIONS FOR THE CAS THAT MIRROR THOSE HELD BY THE RRS WHOM THEY SUPPORT. 20.RBC HAS ALSO UNDERTAKEN TO IMPLEMENT ENHANCEMENTS TO ITS ORDER ENTRY SYSTEMS AND TO ITS SUPERVISION OF THE ORDER ENTRY PROCEDURES. THE ORDER ENTRY SYSTEMS WILL REQUIRE THE INDIVIDUAL ENTERING AN ORDER EITHER TO ATTEST THAT HE OR SHE ALSO ACCEPTED THE ORDER OR TO IDENTIFY THE PERSON WHO ACCEPTED THE ORDER BY ENTERING THAT PERSON'S SYSTEM ID. RBC POLICIES AND PROCEDURES PROHIBIT RBC PERSONNEL FROM USING ANY CREDENTIALS BUT THEIR OWN TO LOG ON TO THE ORDER ENTRY ©2021 FINRA. All rights reserved. Report aboutSYSTEMS. RBC CAPITAL RBC MARKETS, IS DEVELOPING LLC AN EXCEPTION REPORT TO IDENTIFY ANY 272 TRADES ENTERED IN AN ACCOUNT FOR WHICH THE PERSON WHO ACCEPTED THE ORDER DID NOT HOLD THE NECESSARY STATE REGISTRATION. 21.RBC PROVIDED TIMELY RESPONSES AND SUBSTANTIAL COOPERATION IN CONNECTION WITH THE REGULATORY INVESTIGATIONS INTO THIS ISSUE. 14.THE MULTI-STATE INVESTIGATION IDENTIFIED INSTANCES IN WHICH CAS SUPPORTED RRS REGISTERED IN TEXAS WHEN THE CAS WERE NOT REGISTERED IN TEXAS AS AGENTS OF RBC. THIS DIFFERENCE IN REGISTRATION STATUS INCREASED THE POSSIBILITY THAT CAS WOULD ACCEPT ORDERS WHICH THEY DID NOT SOLICIT FROM CUSTOMERS WITHOUT PROPER REGISTRATION. 15.THE MULTI-STATE INVESTIGATION DETERMINED THAT IT WAS HIGHLY LIKELY THAT CERTAIN RBC CAS ACCEPTED ORDERS, WHICH THEY DID NOT SOLICIT, IN TEXAS AT TIMES WHEN THE CAS WERE NOT APPROPRIATELY REGISTERED IN TEXAS. 16.AS A RESULT OF THE INQUIRIES BY STATE REGULATORS, RBC CONDUCTED A REVIEW OF ITS CA REGISTRATION PRACTICES. 17.RBC'S REVIEW FOUND THAT AS OF NOVEMBER 2008, THE FIRM HAD 692 REGISTERED CAS. WHILE CAS WERE REGISTERED IN APPROXIMATELY 7 STATES, AT THAT TIME RRS WERE REGISTERED, ON AVERAGE, IN 17 STATES. APPROXIMATELY 454, ALMOST 66%, OF THOSE REGISTERED CAS WERE ONLY REGISTERED IN THEIR HOME STATE OR THEIR HOME STATE AND ONE ADDITIONAL STATE. 18.MANY RBC CAS WERE NOT REGISTERED IN THE SAME JURISDICTIONS AS THEIR RESPECTIVE RRS. RBC'S REVIEW IDENTIFIED INCIDENCES WHERE CAS WHO WERE NOT PROPERLY STATE REGISTERED ACCEPTED ORDERS THEY HAD NOT SOLICITED. 19.BEGINNING IN 2010, RBC TOOK STEPS TO ENHANCE ITS POLICIES AND PROCEDURES REGARDING CAS' STATE REGISTRATIONS, AND ADDED A SUBSTANTIAL NUMBER OF CA STATE REGISTRATIONS. A.IN JANUARY 2010, RBC AMENDED ITS REGISTRATION POLICY TO REQUIRE THAT EACH CA REGISTER IN THE SAME STATES AS THE RRS WHOM THEY SUPPORT. RBC ALERTED THE FIELD TO THIS POLICY. B.IN NOVEMBER 2010, SUPERVISORS IN RBC'S BRANCHES AND COMPLEXES REVIEWED THE CURRENT CA REGISTRATIONS TO ENSURE THE CAS WERE PROPERLY REGISTERED PRIOR TO THE ANNUAL RENEWALS. C.RBC UPDATED ITS TRAINING TO INCLUDE ADDITIONAL INFORMATION ON REGISTRATION REQUIREMENTS AND ON THE FIRM'S POLICIES ON CA REGISTRATION. RBC ALSO, AS PART OF THE ANNUAL REGISTRATION RENEWAL PROCESS, ADDED TO THE ANNUAL RENEWAL NOTICE INFORMATION REGARDING THE CA REGISTRATION POLICY. D.RBC MODIFIED ITS PROCEDURES REGARDING THE MANNER IN WHICH IT GRANTS ELECTRONIC ORDER ENTRY ACCESS TO CLIENT ACCOUNTS. THE REQUIRED FORMS WERE REVISED TO IDENTIFY SUPPORTING CAS AND THE FORMS ARE PROVIDED TO THE LICENSING AND REGISTRATION DEPARTMENT TO VERIFY THAT PROPER REGISTRATIONS ARE IN PLACE FOR RRS AND CAS WHEN ACCESS IS GRANTED. E.RBC CONDUCTED COMPLIANCE TRAINING SESSIONS FOR CAS COVERING INFORMATION ON ORDER ENTRY PROCEDURES AND REGISTRATION REQUIREMENTS. F.RBC REVISED ITS REGISTRATION FORMS TO IDENTIFY ASSIGNED CAS ON RRS' REGISTRATION FORMS AND ASSIGNED RRS ON CAS' REGISTRATION FORMS. THIS ALLOWS THE REGISTRATION AND LICENSING GROUP TO SUBMIT REGISTRATIONS FOR THE CAS THAT MIRROR THOSE HELD BY THE RRS WHOM THEY SUPPORT. 20.RBC HAS ALSO UNDERTAKEN TO IMPLEMENT ENHANCEMENTS TO ITS ORDER ENTRY SYSTEMS AND TO ITS SUPERVISION OF THE ORDER ENTRY PROCEDURES. THE ORDER ENTRY SYSTEMS WILL REQUIRE THE www.finra.org/brokercheck INDIVIDUAL ENTERING AN ORDER EITHER TO ATTEST THAT HE OR SHE User Guidance ALSO ACCEPTED THE ORDER OR TO IDENTIFY THE PERSON WHO ACCEPTED THE ORDER BY ENTERING THAT PERSON'S SYSTEM ID. RBC POLICIES AND PROCEDURES PROHIBIT RBC PERSONNEL FROM USING ANY CREDENTIALS BUT THEIR OWN TO LOG ON TO THE ORDER ENTRY SYSTEMS. RBC IS DEVELOPING AN EXCEPTION REPORT TO IDENTIFY ANY TRADES ENTERED IN AN ACCOUNT FOR WHICH THE PERSON WHO ACCEPTED THE ORDER DID NOT HOLD THE NECESSARY STATE REGISTRATION. 21.RBC PROVIDED TIMELY RESPONSES AND SUBSTANTIAL COOPERATION IN CONNECTION WITH THE REGULATORY INVESTIGATIONS INTO THIS ISSUE. i Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: TEXAS STATE SECURITIES BOARD Date Initiated: 09/10/2013 Docket/Case Number: IC13-CAF-09

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 09/16/2013 Sanctions Ordered: Monetary/Fine $236,035.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE PERSON ACCEPTING THE ORDER IS APPROPRIATELY REGISTERED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTIONS 115.10(A) AND 115.10(B)(1) AND REPRIMAND UNDER SECTION 14.A(5) OF THE RULES AND ©2021 FINRA. All rights reserved. Report aboutREGULATIONS RBC CAPITAL MARKETS,OF THE TEXAS LLC STATE SECURITIES BOARD. 273 www.finra.org/brokercheck User Guidance

THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATIONS OF SECTIONS 115.10(A) AND 115.10(B)(1) AND REPRIMAND UNDER SECTION 14.A(5) OF THE RULES AND REGULATIONS OF THE TEXAS STATE SECURITIES BOARD. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 119 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS HIGHLY LIKELY THAT THE FIRM ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES THROUGH CERTAIN EMPLOYEES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS, CONSTITUTING FAILURE BY THE FIRM TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. Initiated By: COLORADO DIVISION OF SECURITIES Date Initiated: 07/08/2013 Docket/Case Number: 14-L-01

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 UNDERTAKING Sought:

Resolution: Order Resolution Date: 07/08/2013 Sanctions Ordered: Monetary/Fine $37,380.17 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 274 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $37,380.17 Other Sanctions Ordered: THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM THE JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. Sanction Details: THE FIRM CONSENTED TO THE REPAYMENT OF BACK LICENSING FEES AND PENALTIES FOR VIOLATION OF SECTIONS 11-51-410(1)(I) AND 11-51- 410(2) OF THE COLORADO REVISED STATUTES. IN ADDITION TO THE FINE, THE FIRM PAID THE STATE OF COLORADO $100,000.00 AND THE NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION $10,000.00 AS REIMBURSEMENT OF THEIR COSTS ASSOCIATED WITH THIS MATTER. Firm Statement AS PART OF A MULTI-STATE SETTLEMENT, THE FIRM ENTERED INTO AN AGREEMENT INDIVIDUALLY WITH EACH STATE IN THE AGGREGATE AMOUNT OF $2.8 MILLION. THIS RESULTED FROM ALLEGATIONS THAT CLIENT ASSOCIATES WHO WERE NOT APPROPRIATELY LICENSED IN ACCORDANCE WITH APPLICABLE STATE LAWS ACCEPTED ORDERS FOR TRANSACTIONS IN SECURITIES; AND THE FIRM FAILED TO ESTABLISH AND ENFORCE AN ADEQUATE SYSTEM TO MONITOR THE LICENSING STATUS OF SUCH EMPLOYEES. IN ADDITION TO THE AGGREGATE FINE, THE FIRM UNDERTAKES TO ESTABLISH AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE TRADE PROCESS SO THAT THE FIRM CAN ONLY ACCEPT CLIENT ORDERS THAT ORIGINATE FROM JURISDICTIONS WHERE THE EMPLOYEE WHO ACCEPTS THE ORDER IS APPROPRIATELY LICENSED. i Disclosure 120 of 336 Reporting Source: Firm Current Status: Final Allegations: THE CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE (PANEL) ALLEGES THAT ON NOVEMBER 4, 2010, THE FIRM EXECUTED AN INTER-COMMODITY SPREAD BLOCK TRADE IN THE CBOT U.S. TREASURY NOTE FUTURES CONTRACTS, AND DID NOT REPORT THE TRADE TO THE EXCHANGE WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION. DURING THE SAME TIME FRAME, THE FIRM MISREPORTED TO THE EXCHANGE THE ACCURATE TIME OF EXECUTION OF THE BLOCK TRADE. THE PANEL ALLEGES THAT AS A RESULT, THE FIRM VIOLATED CBOT LEGACY RULE 526.F AND RULE 432.1. Initiated By: CHICAGO MERCANTILE EXCHANGE INC. Date Initiated: 06/24/2013

Docket/Case Number: CBOT 11-8064-BC

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: 06/26/2013 Sanctions Ordered: Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ANY RULE VIOLATIONS, THE FIRM CONSENTED TO PAYING A FINE OF $15,000.00. THE FIRM SENT PAYMENT TO THE CHICAGO MERCANTILE EXCHANGE ON JULY 5, 2013. i Disclosure 121 of 336 Reporting Source: Regulator Current Status: Final Allegations: SEC RULE 10B-10, SEC RULE 203(B)(1) OF REGULATION SHO, FINRA RULES 2010, 6730(B)(1), 6730(C)(5), 6730(C)(6), 6730(D)(4)(D), 6760(C), 7450, NASD RULE 2320, MSRB RULES G-17, G-30(A), G-34 - RBC CAPITAL MARKETS, LLC IN TRANSACTIONS IN CORPORATE BONDS FOR OR WITH CUSTOMERS, 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 WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTIONS AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTIONS, THE FACT THAT THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM FAILED TO ©2021 FINRA. All rights reserved. Report aboutTRANSMIT RBC CAPITAL REPORTABLE MARKETS, LLC ORDER EVENTS (ROES) TO THE ORDER AUDIT 276 TRAIL SYSTEM (OATS) AND TRANSMITTED TO OATS EXECUTION REPORTS THAT FAILED TO REFLECT PARTIAL EXECUTIONS OF AN ORDER. THE FIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY IN TRANSACTIONS; FAILED TO DISCLOSE "DETAILS AVAILABLE UPON REQUEST" FOR THE COMPENSATION, WHICH IS STATED IN A SINGLE AMOUNT ON CUSTOMER CONFIRMATIONS; AND DISCLOSED THAT A "COMMISSION" WAS CHARGED FOR AN ORDER FILLED IN A PRINCIPAL CAPACITY ON THE CUSTOMER CONFIRMATION. THE FIRM ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITY FROM ANOTHER PERSON, OR EFFECTED A SHORT SALE IN AN EQUITY SECURITY FOR ITS OWN ACCOUNT, WITHOUT BORROWING THE SECURITY OR ENTERED INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY; OR HAVING REASONABLE GROUNDS TO BELIEVE THAT THE SECURITY COULD BE BORROWED SO THAT IT COULD BE DELIVERED ON THE DATE DELIVERY IS DUE; AND DOCUMENTING COMPLIANCE WITH SEC RULE 203(B)(1) OF REGULATION SHO. THE FIRM FAILED TO SUBMIT INFORMATION REGARDING THE RESULT OF AN AUCTION RATE SECURITY (ARS) AND INTEREST RATE RESET (VARIABLE RATE DEMAND OBLIGATION, OR VRDO) TO THE MSRB'S SHORT-TERM OBLIGATORY RATE TRANSPARENCY (SHORT) SYSTEM WITHIN THE TIME REQUIREMENTS PRESCRIBED BY MSRB RULE G-34. THE FIRM FAILED TO SUBMIT ACCURATE INFORMATION REGARDING THE RESULT OF AN INTEREST RATE (VRDO) RESET IN NUMEROUS INSTANCES TO THE MSRB'S SHORT SYSTEM; THE FIRM FAILED TO SUBMIT AN ACCURATE RATE RESET DATE TO THE SHORT SYSTEM. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES IT WAS REQUIRED TO REPORT; FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES; FAILED TO ACCURATELY REPORT TO TRACE THE MARKET IDENTIFIER FOR P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES; AND FAILED TO SUBMIT A REPORT TO TRACE IDENTIFYING THE CORRECT EXECUTION DATE FOR SOME P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES. THE FIRM, AS MANAGING UNDERWRITER/SECURITIZER, FAILED TO REPORT NEW ISSUE OFFERINGS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS TO FINRA IN ACCORDANCE WITH THE REQUIREMENTS OF FINRA RULE 6760(C). SEC RULE 10B-10, SEC RULE 203(B)(1) OF REGULATION SHO, FINRA RULES 2010, 6730(B)(1), 6730(C)(5), 6730(C)(6), 6730(D)(4)(D), 6760(C), 7450, NASD RULE 2320, MSRB RULES G-17, G-30(A), G-34 - RBC CAPITAL MARKETS, LLC IN TRANSACTIONS IN CORPORATE BONDS FOR OR WITH CUSTOMERS, 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 WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTIONS AND OF ANY SECURITIES EXCHANGED OR TRADED IN www.finra.org/brokercheck CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN User Guidance EFFECTING THE TRANSACTIONS, THE FACT THAT THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM FAILED TO TRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) AND TRANSMITTED TO OATS EXECUTION REPORTS THAT FAILED TO REFLECT PARTIAL EXECUTIONS OF AN ORDER. THE FIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY IN TRANSACTIONS; FAILED TO DISCLOSE "DETAILS AVAILABLE UPON REQUEST" FOR THE COMPENSATION, WHICH IS STATED IN A SINGLE AMOUNT ON CUSTOMER CONFIRMATIONS; AND DISCLOSED THAT A "COMMISSION" WAS CHARGED FOR AN ORDER FILLED IN A PRINCIPAL CAPACITY ON THE CUSTOMER CONFIRMATION. THE FIRM ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITY FROM ANOTHER PERSON, OR EFFECTED A SHORT SALE IN AN EQUITY SECURITY FOR ITS OWN ACCOUNT, WITHOUT BORROWING THE SECURITY OR ENTERED INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY; OR HAVING REASONABLE GROUNDS TO BELIEVE THAT THE SECURITY COULD BE BORROWED SO THAT IT COULD BE DELIVERED ON THE DATE DELIVERY IS DUE; AND DOCUMENTING COMPLIANCE WITH SEC RULE 203(B)(1) OF REGULATION SHO. THE FIRM FAILED TO SUBMIT INFORMATION REGARDING THE RESULT OF AN AUCTION RATE SECURITY (ARS) AND INTEREST RATE RESET (VARIABLE RATE DEMAND OBLIGATION, OR VRDO) TO THE MSRB'S SHORT-TERM OBLIGATORY RATE TRANSPARENCY (SHORT) SYSTEM WITHIN THE TIME REQUIREMENTS PRESCRIBED BY MSRB RULE G-34. THE FIRM FAILED TO SUBMIT ACCURATE INFORMATION REGARDING THE RESULT OF AN INTEREST RATE (VRDO) RESET IN NUMEROUS INSTANCES TO THE MSRB'S SHORT SYSTEM; THE FIRM FAILED TO SUBMIT AN ACCURATE RATE RESET DATE TO THE SHORT SYSTEM. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES IT WAS REQUIRED TO REPORT; FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES; FAILED TO ACCURATELY REPORT TO TRACE THE MARKET IDENTIFIER FOR P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES; AND FAILED TO SUBMIT A REPORT TO TRACE IDENTIFYING THE CORRECT EXECUTION DATE FOR SOME P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES. THE FIRM, AS MANAGING UNDERWRITER/SECURITIZER, FAILED TO REPORT NEW ISSUE OFFERINGS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS TO FINRA IN ACCORDANCE WITH THE REQUIREMENTS OF FINRA RULE 6760(C). Initiated By: FINRA Date Initiated: 04/24/2013 Docket/Case Number: 2010022619301

Other Product Type(s): CORPORATE BONDS, EQUITY SECURITIES, AUCTION RATE SECURITIES, TRACE-ELIGIBLE CORPORATE DEBT AND SECURITIZED PRODUCTS Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/24/2013 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 $97,500.00 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 $97,500, OF WHICH $42,500 IS FOR MSRB RULE VIOLATIONS. FINE PAID ON JUNE 3, 2013. i Reporting Source: Firm Current Status: Final Allegations: SEC RULE 10B-10, SEC RULE 203(B)(1) OF REGULATION SHO, FINRA RULES 2010, 6730(B)(1), 6730(C)(5), 6730(C)(6), 6730(D)(4)(D), 6760(C), 7450, NASD RULE 2320, MSRB RULES G-17, G-30(A), G-34 - RBC CAPITAL MARKETS, LLC IN TRANSACTIONS IN CORPORATE BONDS FOR OR WITH CUSTOMERS, 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 WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE ©2021 FINRA. All rights reserved. Report aboutTRANSACTIONS RBC CAPITAL MARKETS, AND OF LLC ANY SECURITIES EXCHANGED OR TRADED IN 278 CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTIONS, THE FACT THAT THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM FAILED TO TRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) AND TRANSMITTED TO OATS EXECUTION REPORTS THAT FAILED TO REFLECT PARTIAL EXECUTIONS OF AN ORDER. THE FIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY IN TRANSACTIONS; FAILED TO DISCLOSE "DETAILS AVAILABLE UPON REQUEST" FOR THE COMPENSATION, WHICH IS STATED IN A SINGLE AMOUNT ON CUSTOMER CONFIRMATIONS; AND DISCLOSED THAT A "COMMISSION" WAS CHARGED FOR AN ORDER FILLED IN A PRINCIPAL CAPACITY ON THE CUSTOMER CONFIRMATION. THE FIRM ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITY FROM ANOTHER PERSON, OR EFFECTED A SHORT SALE IN AN EQUITY SECURITY FOR ITS OWN ACCOUNT, WITHOUT BORROWING THE SECURITY OR ENTERED INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY; OR HAVING REASONABLE GROUNDS TO BELIEVE THAT THE SECURITY COULD BE BORROWED SO THAT IT COULD BE DELIVERED ON THE DATE DELIVERY IS DUE; AND DOCUMENTING COMPLIANCE WITH SEC RULE 203(B)(1) OF REGULATION SHO. THE FIRM FAILED TO SUBMIT INFORMATION REGARDING THE RESULT OF AN AUCTION RATE SECURITY (ARS) AND INTEREST RATE RESET (VARIABLE RATE DEMAND OBLIGATION, OR VRDO) TO THE MSRB'S SHORT-TERM OBLIGATORY RATE TRANSPARENCY (SHORT) SYSTEM WITHIN THE TIME REQUIREMENTS PRESCRIBED BY MSRB RULE G-34. THE FIRM FAILED TO SUBMIT ACCURATE INFORMATION REGARDING THE RESULT OF AN INTEREST RATE (VRDO) RESET IN NUMEROUS INSTANCES TO THE MSRB'S SHORT SYSTEM; THE FIRM FAILED TO SUBMIT AN ACCURATE RATE RESET DATE TO THE SHORT SYSTEM. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES IT WAS REQUIRED TO REPORT; FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES; FAILED TO ACCURATELY REPORT TO TRACE THE MARKET IDENTIFIER FOR P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES; AND FAILED TO SUBMIT A REPORT TO TRACE IDENTIFYING THE CORRECT EXECUTION DATE FOR SOME P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES. THE FIRM, AS MANAGING UNDERWRITER/SECURITIZER, FAILED TO REPORT NEW ISSUE OFFERINGS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS TO FINRA IN ACCORDANCE WITH THE REQUIREMENTS OF FINRA RULE 6760(C). SEC RULE 10B-10, SEC RULE 203(B)(1) OF REGULATION SHO, FINRA RULES 2010, 6730(B)(1), 6730(C)(5), 6730(C)(6), 6730(D)(4)(D), 6760(C), 7450, NASD RULE 2320, MSRB RULES G-17, G-30(A), G-34 - RBC CAPITAL MARKETS, LLC IN TRANSACTIONS IN CORPORATE BONDS FOR OR WITH CUSTOMERS, 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 WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY www.finra.org/brokercheck MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING User Guidance INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTIONS AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTIONS, THE FACT THAT THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM FAILED TO TRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) AND TRANSMITTED TO OATS EXECUTION REPORTS THAT FAILED TO REFLECT PARTIAL EXECUTIONS OF AN ORDER. THE FIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY IN TRANSACTIONS; FAILED TO DISCLOSE "DETAILS AVAILABLE UPON REQUEST" FOR THE COMPENSATION, WHICH IS STATED IN A SINGLE AMOUNT ON CUSTOMER CONFIRMATIONS; AND DISCLOSED THAT A "COMMISSION" WAS CHARGED FOR AN ORDER FILLED IN A PRINCIPAL CAPACITY ON THE CUSTOMER CONFIRMATION. THE FIRM ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITY FROM ANOTHER PERSON, OR EFFECTED A SHORT SALE IN AN EQUITY SECURITY FOR ITS OWN ACCOUNT, WITHOUT BORROWING THE SECURITY OR ENTERED INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY; OR HAVING REASONABLE GROUNDS TO BELIEVE THAT THE SECURITY COULD BE BORROWED SO THAT IT COULD BE DELIVERED ON THE DATE DELIVERY IS DUE; AND DOCUMENTING COMPLIANCE WITH SEC RULE 203(B)(1) OF REGULATION SHO. THE FIRM FAILED TO SUBMIT INFORMATION REGARDING THE RESULT OF AN AUCTION RATE SECURITY (ARS) AND INTEREST RATE RESET (VARIABLE RATE DEMAND OBLIGATION, OR VRDO) TO THE MSRB'S SHORT-TERM OBLIGATORY RATE TRANSPARENCY (SHORT) SYSTEM WITHIN THE TIME REQUIREMENTS PRESCRIBED BY MSRB RULE G-34. THE FIRM FAILED TO SUBMIT ACCURATE INFORMATION REGARDING THE RESULT OF AN INTEREST RATE (VRDO) RESET IN NUMEROUS INSTANCES TO THE MSRB'S SHORT SYSTEM; THE FIRM FAILED TO SUBMIT AN ACCURATE RATE RESET DATE TO THE SHORT SYSTEM. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES IT WAS REQUIRED TO REPORT; FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES; FAILED TO ACCURATELY REPORT TO TRACE THE MARKET IDENTIFIER FOR P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES; AND FAILED TO SUBMIT A REPORT TO TRACE IDENTIFYING THE CORRECT EXECUTION DATE FOR SOME P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES. THE FIRM, AS MANAGING UNDERWRITER/SECURITIZER, FAILED TO REPORT NEW ISSUE OFFERINGS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS TO FINRA IN ACCORDANCE WITH THE REQUIREMENTS OF FINRA RULE 6760(C). Initiated By: FINRA

Date Initiated: 04/24/2013 Docket/Case Number: 2010022619301

Principal Product Type: Debt - Municipal Other Product Type(s): CORPORATE BONDS, EQUITY SECURITIES, AUCTION RATE SECURITIES, TRACE-ELIGIBLE CORPORATE DEBT AND SECURITIZED PRODUCTS Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/24/2013 Sanctions Ordered: Censure Monetary/Fine $97,500.00 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 $97,500, OF WHICH $42,500 IS FOR MSRB RULE VIOLATIONS. i Disclosure 122 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASDAQ OMX BX RULE 4755 - RBC CAPITAL MARKETS, LLC ENTERED ORDERS INTO THE NASDAQ OMX BX MARKET CENTER THAT FAILED TO CORRECTLY INDICATE WHETHER THE ORDERS WERE A BUY, SHORT SALE OR LONG SALE. Initiated By: NASDAQ OMX BX, INC. Date Initiated: 04/25/2013 Docket/Case Number: 2011026152001

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 280 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/25/2013 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 FINDINGS, THE FIRM 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: NASDAQ OMX BX RULE 4755 - RBC CAPITAL MARKETS, LLC ENTERED ORDERS INTO THE NASDAQ OMX BX MARKET CENTER THAT FAILED TO CORRECTLY INDICATE WHETHER THE ORDERS WERE A BUY, SHORT SALE OR LONG SALE. Initiated By: NASDAQ OMX BX, INC. Date Initiated: 04/25/2013 Docket/Case Number: 2011026152001

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: 04/25/2013

Sanctions Ordered: Censure Monetary/Fine $7,500.00 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 $7,500. i Disclosure 123 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NEW JERSEY BUREAU OF SECURITIES ALLEGES THAT RBC CAPITAL MARKETS, LLC FAILED TO FOLLOW ITS OWN PROCEDURES WITH RESPECT TO MONTHLY ACCOUNT REVIEWS ("MARS"), FAILED TO REASONABLY SUPERVISE ITS AGENTS AND IS SUBJECT TO SANCTIONS UNDER N.J.S.A 49.3-58(A)(2)(XI), AND ALSO FAILED TO MAINTAIN COPIES OF THE MARS, RBC CAPITAL MARKETS, LLC FAILED TO KEEP ACCURATE BOOKS AND RECORDS, IN VIOLATION OF N.J.S.A. 49:3-59(B). Initiated By: STATE OF NEW JERSEY BUREAU OF SECURITIES Date Initiated: 03/11/2013 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 DISGORGEMENT Sought:

Resolution: Consent Resolution Date: 03/11/2013 Sanctions Ordered: Monetary/Fine $450,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT AND CONCLUSIONS OF LAW, AND SOLELY FOR THE PURPOSE OF THIS PROCEEDING, THE FIRM CONSENTS TO THE BUREAU CHIEF MAKING THE FOLLOWING CONCLUSIONS OF LAW: BY FAILING TO FOLLOW ITS OWN PROCEDURES WITH RESPECT TO MARS, THE FIRM FAILED TO ©2021 FINRA. All rights reserved. Report aboutREASONABLY RBC CAPITAL SUPERVISE MARKETS, LLC ITS AGENTS AND IS SUBJECT TO SANCTIONS 282 UNDER N.J.S.A 49:3-58(A)(2)(XI). BY FAILING TO MAINTAIN COPIES OF THE MARS, RBC CAPITAL MARKETS, LLC FAILED TO KEEP ACCURATE BOOKS AND RECORDS, IN VIOLATION OF N.J.S.A. 49:3-59(B). PURSUANT TO N.J.S.A. 49:3-70.1, RBC IS ASSESSED A CIVIL MONETARY PENALTY IN THE AMOUNT OF $150,000.00, OF WHICH $100,000.00 IS SUSPENDED DUE TO RBC'S EXTENSIVE COOPERATION WITH THE BUREAU DURING ITS INVESTIGATION. RBC SHALL PAY $300,000 IN DISGORGEMENT TO THE BUREAU. www.finra.org/brokercheck WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT AND User Guidance CONCLUSIONS OF LAW, AND SOLELY FOR THE PURPOSE OF THIS PROCEEDING, THE FIRM CONSENTS TO THE BUREAU CHIEF MAKING THE FOLLOWING CONCLUSIONS OF LAW: BY FAILING TO FOLLOW ITS OWN PROCEDURES WITH RESPECT TO MARS, THE FIRM FAILED TO REASONABLY SUPERVISE ITS AGENTS AND IS SUBJECT TO SANCTIONS UNDER N.J.S.A 49:3-58(A)(2)(XI). BY FAILING TO MAINTAIN COPIES OF THE MARS, RBC CAPITAL MARKETS, LLC FAILED TO KEEP ACCURATE BOOKS AND RECORDS, IN VIOLATION OF N.J.S.A. 49:3-59(B). PURSUANT TO N.J.S.A. 49:3-70.1, RBC IS ASSESSED A CIVIL MONETARY PENALTY IN THE AMOUNT OF $150,000.00, OF WHICH $100,000.00 IS SUSPENDED DUE TO RBC'S EXTENSIVE COOPERATION WITH THE BUREAU DURING ITS INVESTIGATION. RBC SHALL PAY $300,000 IN DISGORGEMENT TO THE BUREAU. i Disclosure 124 of 336 Reporting Source: Regulator Current Status: Final Allegations: DURING THE FIRST QUARTER OF 2010, THE FIRM SUBMITTED 108 ENTRIES TO THE LARGE OPTIONS POSTION REPORT("LOPR") WITH A SOCIAL SECURITY NUMBER WHICH HAD NOT BEEN ASSIGNED AN IN-CONCERT NUMBER AND IN-CONCERT FIRM ID.

DURING THE THIRD QUARTER OF 2010, THE FIRM SUBMITTED 148 ENTRIES TO THE LARGE OPTIONS POSTION REPORT("LOPR") WITH A SOCIAL SECURITY NUMBER WHICH HAD NOT BEEN ASSIGNED AN IN- CONCERT NUMBER AND IN-CONCERT FIRM ID.

THESE CONSITIUTE DISTINCT VIOLATIONS OF ISE RULE 415(A) Initiated By: INTERNATIONAL SECURITIES EXCHANGE Date Initiated: 10/03/2012 Docket/Case Number: 2010-086 & 2010-140

Principal Product Type: Options 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: 12/21/2012 Does the order constitute a No final order based on ©2021violations FINRA. of All any rights laws reserved. or Report about RBC CAPITAL MARKETS, LLC 283 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 $40,000.00 Other Sanctions Ordered: Sanction Details: FIRM FINED $40000 i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF ISE RULE 415(A): IT WAS ALLEGED THAT INNACURATE ENTRIES WERE SUBMITTED INTO THE FIRM'S LARGE OPTIONS POSITION REPORT DURING THE FIRST AND THIRD QUARTERS OF 2010. Initiated By: INTERNATIONAL SECURITIES EXCHANGE, LLC Date Initiated: 12/21/2012 Docket/Case Number: 2010-086 AND 2010-140

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/21/2012 Sanctions Ordered: Censure Monetary/Fine $40,000.00 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 $40,000.

i Disclosure 125 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASDAQ RULES 4611, 4755: IN NUMEROUS INSTANCES DURING A 2010 EXAMINATION BY THE TRADING AND MARKET-MAKING SURVEILLANCE (TMMS) GROUP OF FINRA'S DEPARTMENT OF MARKET REGULATION, THE FIRM ENTERED AN ORDER INTO NASDAQ WITH AN INCORRECT CAPACITY. IN SOME INSTANCES DURING THE 2010 TMMS EXAM REVIEW PERIOD, THE FIRM INCORRECTLY ENTERED A SHORT SALE ORDER INTO NASDAQ AS A LONG SALE ORDER. Initiated By: NASDAQ STOCK MARKET Date Initiated: 12/14/2012 Docket/Case Number: 2010021597801

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/14/2012 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 $16,500.00 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 $16,500 (COMPRISED OF $6,500 FOR VIOLATIONS OF NASDAQ RULE 4611 AND $10,000 FOR VIOLATIONS OF NASDAQ RULE 4755).

i Reporting Source: Firm Current Status: Final Allegations: NASDAQ RULES 4611, 4755: IN NUMEROUS INSTANCES DURING A 2010 EXAMINATION BY THE TRADING AND MARKET-MAKING SURVEILLANCE (TMMS) GROUP OF FINRA'S DEPARTMENT OF MARKET REGULATION, THE FIRM ENTERED AN ORDER INTO NASDAQ WITH AN INCORRECT CAPACITY. IN SOME INSTANCES DURING THE 2010 TMMS EXAM REVIEW PERIOD, THE FIRM INCORRECTLY ENTERED A SHORT SALE ORDER INTO NASDAQ AS A LONG SALE ORDER. Initiated By: NASDAQ STOCK MARKET Date Initiated: 12/14/2012 Docket/Case Number: 2010021597801

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/14/2012 Sanctions Ordered: Censure Monetary/Fine $16,500.00 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 $16,500 (COMPRISED OF $6,500 FOR VIOLATIONS OF NASDAQ RULE 4611 AND $10,000 FOR VIOLATIONS OF NASDAQ RULE 4755). i Disclosure 126 of 336 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULES 2010, 6760(B), 7230A, 7450, NASD RULES 2110, 3010, 6730(A), MSRB RULES G-17, G-30(A) - RBC CAPITAL MARKETS, LLC TRANSMITTED ©2021 FINRA. All rights reserved. Report aboutREPORTABLE RBC CAPITAL ORDER MARKETS, EVENTS LLC (ROES) TO THE ORDER AUDIT TRAIL 286 SYSTEM (OATS) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE SO THAT BECAUSE OF THE FIRM'S FAILURE TO REPAIR THE ROES, THE FIRM FAILED TO TRANSMIT THEM TO OATS DURING THE REVIEW PERIOD. THE FIRM REPORTED AN ERRONEOUS ROUTING DESTINATION CODE; REPORTED AN INCORRECT ROUTING FIRM MARKET PARTICIPANT IDENTIFIER (MPID); SUBMITTED INACCURATE INFORMATION TO OATS FOR AN ORDER, FAILED TO REPORT BOTH CANCEL-REPLACE AND CANCEL EVENTS FOR THE SAME ORDER; REPORTED AN INCORRECT CAPACITY TO OATS; SUBMITTED INACCURATE INFORMATION TO OATS FOR AN ORDER; REPORTED A PRINCIPAL CAPACITY TO OATS WHEN THE ORDER WAS FILLED IN A RISKLESS PRINCIPAL CAPACITY AND FAILED TO REPORT A NEXT DAY SETTLEMENT SPECIAL HANDLING CODE TO OATS. THE FIRM MATCHED TRADE REPORTS TO THE FINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) WITH AN INACCURATE CAPACITY AND REPORTED NON-MEDIA REPORTED TRADES WITH AN INACCURATE RELATED MARKET CENTER CODE. THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTIONS, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM, AS MANAGING UNDERWRITER, FAILED TO TIMELY REPORT NEW ISSUES IN TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLE SECURITIES TO FINRA ACCORDING TO THE TIME FRAMES SET FORTH IN FINRA RULE 6760. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND/OR NASD RULES ADDRESSING MINIMUM REQUIREMENTS FOR REGISTRATION OF TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TO TRACE S1 BLOCK SIZE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE EXECUTION TIME. www.finra.org/brokercheck User Guidance

Allegations: FINRA RULES 2010, 6760(B), 7230A, 7450, NASD RULES 2110, 3010, 6730(A), MSRB RULES G-17, G-30(A) - RBC CAPITAL MARKETS, LLC TRANSMITTED REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE SO THAT BECAUSE OF THE FIRM'S FAILURE TO REPAIR THE ROES, THE FIRM FAILED TO TRANSMIT THEM TO OATS DURING THE REVIEW PERIOD. THE FIRM REPORTED AN ERRONEOUS ROUTING DESTINATION CODE; REPORTED AN INCORRECT ROUTING FIRM MARKET PARTICIPANT IDENTIFIER (MPID); SUBMITTED INACCURATE INFORMATION TO OATS FOR AN ORDER, FAILED TO REPORT BOTH CANCEL-REPLACE AND CANCEL EVENTS FOR THE SAME ORDER; REPORTED AN INCORRECT CAPACITY TO OATS; SUBMITTED INACCURATE INFORMATION TO OATS FOR AN ORDER; REPORTED A PRINCIPAL CAPACITY TO OATS WHEN THE ORDER WAS FILLED IN A RISKLESS PRINCIPAL CAPACITY AND FAILED TO REPORT A NEXT DAY SETTLEMENT SPECIAL HANDLING CODE TO OATS. THE FIRM MATCHED TRADE REPORTS TO THE FINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) WITH AN INACCURATE CAPACITY AND REPORTED NON-MEDIA REPORTED TRADES WITH AN INACCURATE RELATED MARKET CENTER CODE. THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTIONS, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM, AS MANAGING UNDERWRITER, FAILED TO TIMELY REPORT NEW ISSUES IN TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLE SECURITIES TO FINRA ACCORDING TO THE TIME FRAMES SET FORTH IN FINRA RULE 6760. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND/OR NASD RULES ADDRESSING MINIMUM REQUIREMENTS FOR REGISTRATION OF TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TO TRACE S1 BLOCK SIZE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE EXECUTION TIME. Initiated By: FINRA Date Initiated: 12/12/2012 Docket/Case Number: 2010021496301

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/12/2012 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 $62,500.00 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 $62,500, $20,000 OF WHICH IS FOR MSRB RULE VIOLATIONS, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING MINIMUM REQUIREMENTS FOR REGISTRATION OF TRACE-ELIGIBLE SECURITIES WITHIN 90 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. FINE PAID IN FULL ON 1/9/2013. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULES 2010, 6760(B), 7230A, 7450, NASD RULES 2110, 3010, 6730(A), MSRB RULES G-17, G-30(A) - RBC CAPITAL MARKETS, LLC TRANSMITTED REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE SO THAT BECAUSE OF THE FIRM'S FAILURE TO REPAIR THE ROES, THE FIRM FAILED TO TRANSMIT THEM TO OATS DURING THE REVIEW PERIOD. THE FIRM REPORTED AN ERRONEOUS ROUTING DESTINATION CODE; REPORTED AN INCORRECT ROUTING FIRM MARKET PARTICIPANT IDENTIFIER (MPID); SUBMITTED INACCURATE INFORMATION TO OATS FOR AN ORDER, FAILED TO REPORT BOTH CANCEL-REPLACE AND CANCEL EVENTS FOR THE SAME ORDER; ©2021 FINRA. All rights reserved. Report aboutREPORTED RBC CAPITAL AN MARKETS,INCORRECT LLC CAPACITY TO OATS; SUBMITTED INACCURATE 288 INFORMATION TO OATS FOR AN ORDER; REPORTED A PRINCIPAL CAPACITY TO OATS WHEN THE ORDER WAS FILLED IN A RISKLESS PRINCIPAL CAPACITY AND FAILED TO REPORT A NEXT DAY SETTLEMENT SPECIAL HANDLING CODE TO OATS. THE FIRM MATCHED TRADE REPORTS TO THE FINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) WITH AN INACCURATE CAPACITY AND REPORTED NON-MEDIA REPORTED TRADES WITH AN INACCURATE RELATED MARKET CENTER CODE. THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTIONS, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM, AS MANAGING UNDERWRITER, FAILED TO TIMELY REPORT NEW ISSUES IN TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLE SECURITIES TO FINRA ACCORDING TO THE TIME FRAMES SET FORTH IN FINRA RULE 6760. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND/OR NASD RULES ADDRESSING MINIMUM REQUIREMENTS FOR REGISTRATION OF TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TO TRACE S1 BLOCK SIZE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE EXECUTION TIME. FINRA RULES 2010, 6760(B), 7230A, 7450, NASD RULES 2110, 3010, 6730(A), MSRB RULES G-17, G-30(A) - RBC CAPITAL MARKETS, LLC TRANSMITTED REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE SO THAT BECAUSE OF THE FIRM'S FAILURE TO REPAIR THE ROES, THE FIRM FAILED TO TRANSMIT www.finra.org/brokercheck THEM TO OATS DURING THE REVIEW PERIOD. THE FIRM REPORTED AN User Guidance ERRONEOUS ROUTING DESTINATION CODE; REPORTED AN INCORRECT ROUTING FIRM MARKET PARTICIPANT IDENTIFIER (MPID); SUBMITTED INACCURATE INFORMATION TO OATS FOR AN ORDER, FAILED TO REPORT BOTH CANCEL-REPLACE AND CANCEL EVENTS FOR THE SAME ORDER; REPORTED AN INCORRECT CAPACITY TO OATS; SUBMITTED INACCURATE INFORMATION TO OATS FOR AN ORDER; REPORTED A PRINCIPAL CAPACITY TO OATS WHEN THE ORDER WAS FILLED IN A RISKLESS PRINCIPAL CAPACITY AND FAILED TO REPORT A NEXT DAY SETTLEMENT SPECIAL HANDLING CODE TO OATS. THE FIRM MATCHED TRADE REPORTS TO THE FINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) WITH AN INACCURATE CAPACITY AND REPORTED NON-MEDIA REPORTED TRADES WITH AN INACCURATE RELATED MARKET CENTER CODE. THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTIONS, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM, AS MANAGING UNDERWRITER, FAILED TO TIMELY REPORT NEW ISSUES IN TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLE SECURITIES TO FINRA ACCORDING TO THE TIME FRAMES SET FORTH IN FINRA RULE 6760. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND/OR NASD RULES ADDRESSING MINIMUM REQUIREMENTS FOR REGISTRATION OF TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TO TRACE S1 BLOCK SIZE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE EXECUTION TIME. Initiated By: FINRA Date Initiated: 12/12/2012 Docket/Case Number: 2010021496301

Principal Product Type: Debt - Municipal Other Product Type(s): UNSPECIFIED SECURITIES 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: 12/12/2012 Sanctions Ordered: Censure Monetary/Fine $62,500.00 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 $62,500, $20,000 OF WHICH IS FOR MSRB RULE VIOLATIONS, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING MINIMUM REQUIREMENTS FOR REGISTRATION OF TRACE-ELIGIBLE SECURITIES WITHIN 90 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. i Disclosure 127 of 336 Reporting Source: Regulator Current Status: Final Allegations: EXCHANGE ACT RULES 15C3-1, 15C3-3, 17A-3, 17A-5, FINRA RULE 2010, NASD RULES 2110, 3010(A) AND (B), NYSE RULES 416(A), 440.20: THE FIRM UNDERWENT A MERGER COMBINING THE INSTITUTIONAL FIRM WITH ITS AFFILIATED RETAIL FIRM, AND FOLLOWING THE MERGER AND CONVERSION, IT EXPERIENCED DIFFICULTIES IN RECONCILING ITS ACCOUNTS, WHICH RESULTED IN CUSTOMER RESERVE, NET CAPITAL, RECORDKEEPING, AND SUPERVISORY VIOLATIONS. WITH RESPECT TO CUSTOMER RESERVE, THE FIRM FAILED TO PREPARE AN ACCURATE CUSTOMER RESERVE FORMULA, WHICH RESULTED IN AN APPARENT HINDSIGHT DEFICIENCY OF APPROXIMATELY $51 MILLION. THE FIRM FAILED TO INCLUDE APPROXIMATELY $453 MILLION OF AGED CREDIT BALANCES FROM SUSPENSE, CLEARANCE, AND WASH ACCOUNTS IN ITS CUSTOMER RESERVE FORMULA. WITH RESPECT TO BALANCES IN OTHER ACCOUNTS, THE FIRM FAILED TO MOVE APPROXIMATELY $127 MILLION OF ITEMS, SEVEN DAYS OR OLDER, FROM A BANK'S CLEARANCE ACCOUNTS TO SUSPENSE ACCOUNTS, AND FAILED TO INCLUDE THE BALANCE IN ITS CUSTOMER RESERVE FORMULA; FAILED TO TAKE A CUSTOMER RESERVE FORMULA CREDIT FOR SEVEN AGED, SHORT POSITIONS OF FOREIGN SHARES HELD IN THE BANK'S DEPOSITORY ACCOUNT OF APPROXIMATELY $37 MILLION, WHICH HAD BEEN IN THE ACCOUNT FOR PERIODS RANGING FROM 16 TO 23 BUSINESS DAYS; FAILED TO INCLUDE, AGED, CREDIT BALANCES IN A MONEY DIFFERENCE ACCOUNT OF APPROXIMATELY $20 MILLION AND $9.7 MILLION, WHICH WERE RESOLVED AFTER 49 AND 63 BUSINESS DAYS; FAILED TO INCLUDE AN AGED BALANCE OF APPROXIMATELY $18 MILLION IN A TREASURY SUSPENSE ACCOUNT, WHICH REMAINED UNRESOLVED FOR 43 BUSINESS DAYS; FAILED TO MOVE SOME, AGED CASH BREAKS OF APPROXIMATELY $3.6 MILLION ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 290 FROM A CUSTOMER'S RECONCILIATION ACCOUNT TO A SUSPENSE ACCOUNT OR INCLUDE THEM IN THE CUSTOMER RESERVE FORMULA, SOME OF WHICH REMAINED UNRESOLVED AS OF THE PERIOD, AND SOME OF WHICH REMAINED OPEN FOR. PERIODS RANGING FROM 19 TO 47 BUSINESS DAYS; FAILED TO INCLUDE AN AGED ITEM IN ITS SECURITIES CLEARING SUSPENSE ACCOUNT IN THE AMOUNT OF APPROXIMATELY $2.2 MILLION IN ITS CUSTOMER RESERVE FORMULA, WHICH WAS RESOLVED AFTER 69 BUSINESS DAYS. THE FIRM OVERSTATED FAILS TO RECEIVE AND AGED DIVIDENDS OF APPROXIMATELY $228 MILLION IN ITS CUSTOMER RESERVE FORMULA. THE FIRM FAILED TO PAIR OFF APPROXIMATELY $192 MILLION OF FAILS TO RECEIVE AGAINST SUSPENSE LONGS, AND ERRONEOUSLY INCLUDED THIS AMOUNT IN THE CUSTOMER RESERVE FORMULA. IN ADDITION, THE FIRM FAILED TO NET AGED STOCK DIVIDENDS IN THE AMOUNT OF APPROXIMATELY $35 MILLION WITH RELATED ITEMS AND ERRONEOUSLY INCLUDED THAT AMOUNT IN THE CUSTOMER RESERVE FORMULA. THE FIRM MADE A LATE DEPOSIT TO ITS CUSTOMER RESERVE ACCOUNT RESULTING IN AN EIGHT-MINUTE HINDSIGHT DEFICIENCY OF APPROXIMATELY $317 MILLION, AND IT MADE SOME LATE WITHDRAWALS FROM CUSTOMER RESERVE AND PROPRIETARY ACCOUNTS OF INTRODUCING BROKERS. THE FIRM FAILED TO TAKE NET CAPITAL CHARGES OF APPROXIMATELY $366 MILLION FOR AGED DEBITS IN SOME ACCOUNTS. THIS AMOUNT REDUCED THE FIRM'S EXCESS NET CAPITAL FROM APPROXIMATELY $627 MILLION TO $260 MILLION, BUT DID NOT RESULT IN A DEFICIENCY. THE FIRM FAILED TO INCLUDE AN ACCOUNT THAT CONTAINED UNRESOLVED DEBIT ITEMS OF APPROXIMATELY $191 MILLION, IN THE SUSPENSE RANGE OF ACCOUNTS AND FAILED TO TAKE A NET CAPITAL CHARGE ON THE BALANCE. THE FIRM FAILED TO MOVE AGED EXCEPTIONS TO A BANK'S SUSPENSE ACCOUNTS AND FAILED TO TAKE A NET CAPITAL CHARGE OF APPROXIMATELY $91 MILLION. THE FIRM FAILED TO ACCOUNT FOR AGED DEBIT BALANCES IN A MONEY DIFFERENCE ACCOUNT IN THE AMOUNTS OF APPROXIMATELY $1.2 MILLION AND $1 MILLION. THESE BALANCES WERE RESOLVED AFTER 60 BUSINESS DAYS AND 37 BUSINESS DAYS, RESPECTIVELY. THE FIRM FAILED TO MOVE THESE BALANCES TO A SUSPENSE ACCOUNT OR INCLUDE THE APPROXIMATELY $2 MILLION DEBIT IN ITS NET CAPITAL CALCULATION FOR THE PERIOD. THE FIRM FAILED TO INCLUDE AN ACCOUNT THAT HAD A BALANCE OF APPROXIMATELY $2.1 MILLION IN THE SUSPENSE RANGE OF ACCOUNTS, AND FAILED TO TAKE A NET CAPITAL CHARGE ON THE BALANCE. (CONT. IN COMMENT) EXCHANGE ACT RULES 15C3-1, 15C3-3, 17A-3, 17A-5, FINRA RULE 2010, NASD RULES 2110, 3010(A) AND (B), NYSE RULES 416(A), 440.20: THE FIRM UNDERWENT A MERGER COMBINING THE INSTITUTIONAL FIRM WITH ITS AFFILIATED RETAIL FIRM, AND FOLLOWING THE MERGER AND CONVERSION, IT EXPERIENCED DIFFICULTIES IN RECONCILING ITS ACCOUNTS, WHICH RESULTED IN CUSTOMER RESERVE, NET CAPITAL, RECORDKEEPING, AND SUPERVISORY VIOLATIONS. WITH RESPECT TO CUSTOMER RESERVE, THE FIRM FAILED TO PREPARE AN ACCURATE CUSTOMER RESERVE FORMULA, WHICH RESULTED IN AN APPARENT HINDSIGHT DEFICIENCY OF APPROXIMATELY $51 MILLION. THE FIRM FAILED TO INCLUDE APPROXIMATELY $453 MILLION OF AGED CREDIT BALANCES FROM SUSPENSE, CLEARANCE, AND WASH ACCOUNTS IN ITS CUSTOMER RESERVE FORMULA. WITH RESPECT TO BALANCES IN OTHER ACCOUNTS, THE FIRM FAILED TO MOVE APPROXIMATELY $127 MILLION OF ITEMS, SEVEN DAYS OR OLDER, FROM A BANK'S CLEARANCE ACCOUNTS TO SUSPENSE ACCOUNTS, AND FAILED TO INCLUDE THE BALANCE IN ITS CUSTOMER RESERVE FORMULA; FAILED TO TAKE A CUSTOMER RESERVE FORMULA CREDIT FOR SEVEN AGED, SHORT POSITIONS OF FOREIGN SHARES HELD IN THE BANK'S DEPOSITORY ACCOUNT OF APPROXIMATELY $37 MILLION, WHICH HAD BEEN IN THE ACCOUNT FOR PERIODS RANGING FROM 16 TO 23 BUSINESS DAYS; FAILED TO INCLUDE, AGED, CREDIT BALANCES IN A MONEY DIFFERENCE ACCOUNT OF APPROXIMATELY $20 www.finra.org/brokercheck MILLION AND $9.7 MILLION, WHICH WERE RESOLVED AFTER 49 AND 63 User Guidance BUSINESS DAYS; FAILED TO INCLUDE AN AGED BALANCE OF APPROXIMATELY $18 MILLION IN A TREASURY SUSPENSE ACCOUNT, WHICH REMAINED UNRESOLVED FOR 43 BUSINESS DAYS; FAILED TO MOVE SOME, AGED CASH BREAKS OF APPROXIMATELY $3.6 MILLION FROM A CUSTOMER'S RECONCILIATION ACCOUNT TO A SUSPENSE ACCOUNT OR INCLUDE THEM IN THE CUSTOMER RESERVE FORMULA, SOME OF WHICH REMAINED UNRESOLVED AS OF THE PERIOD, AND SOME OF WHICH REMAINED OPEN FOR. PERIODS RANGING FROM 19 TO 47 BUSINESS DAYS; FAILED TO INCLUDE AN AGED ITEM IN ITS SECURITIES CLEARING SUSPENSE ACCOUNT IN THE AMOUNT OF APPROXIMATELY $2.2 MILLION IN ITS CUSTOMER RESERVE FORMULA, WHICH WAS RESOLVED AFTER 69 BUSINESS DAYS. THE FIRM OVERSTATED FAILS TO RECEIVE AND AGED DIVIDENDS OF APPROXIMATELY $228 MILLION IN ITS CUSTOMER RESERVE FORMULA. THE FIRM FAILED TO PAIR OFF APPROXIMATELY $192 MILLION OF FAILS TO RECEIVE AGAINST SUSPENSE LONGS, AND ERRONEOUSLY INCLUDED THIS AMOUNT IN THE CUSTOMER RESERVE FORMULA. IN ADDITION, THE FIRM FAILED TO NET AGED STOCK DIVIDENDS IN THE AMOUNT OF APPROXIMATELY $35 MILLION WITH RELATED ITEMS AND ERRONEOUSLY INCLUDED THAT AMOUNT IN THE CUSTOMER RESERVE FORMULA. THE FIRM MADE A LATE DEPOSIT TO ITS CUSTOMER RESERVE ACCOUNT RESULTING IN AN EIGHT-MINUTE HINDSIGHT DEFICIENCY OF APPROXIMATELY $317 MILLION, AND IT MADE SOME LATE WITHDRAWALS FROM CUSTOMER RESERVE AND PROPRIETARY ACCOUNTS OF INTRODUCING BROKERS. THE FIRM FAILED TO TAKE NET CAPITAL CHARGES OF APPROXIMATELY $366 MILLION FOR AGED DEBITS IN SOME ACCOUNTS. THIS AMOUNT REDUCED THE FIRM'S EXCESS NET CAPITAL FROM APPROXIMATELY $627 MILLION TO $260 MILLION, BUT DID NOT RESULT IN A DEFICIENCY. THE FIRM FAILED TO INCLUDE AN ACCOUNT THAT CONTAINED UNRESOLVED DEBIT ITEMS OF APPROXIMATELY $191 MILLION, IN THE SUSPENSE RANGE OF ACCOUNTS AND FAILED TO TAKE A NET CAPITAL CHARGE ON THE BALANCE. THE FIRM FAILED TO MOVE AGED EXCEPTIONS TO A BANK'S SUSPENSE ACCOUNTS AND FAILED TO TAKE A NET CAPITAL CHARGE OF APPROXIMATELY $91 MILLION. THE FIRM FAILED TO ACCOUNT FOR AGED DEBIT BALANCES IN A MONEY DIFFERENCE ACCOUNT IN THE AMOUNTS OF APPROXIMATELY $1.2 MILLION AND $1 MILLION. THESE BALANCES WERE RESOLVED AFTER 60 BUSINESS DAYS AND 37 BUSINESS DAYS, RESPECTIVELY. THE FIRM FAILED TO MOVE THESE BALANCES TO A SUSPENSE ACCOUNT OR INCLUDE THE APPROXIMATELY $2 MILLION DEBIT IN ITS NET CAPITAL CALCULATION FOR THE PERIOD. THE FIRM FAILED TO INCLUDE AN ACCOUNT THAT HAD A BALANCE OF APPROXIMATELY $2.1 MILLION IN THE SUSPENSE RANGE OF ACCOUNTS, AND FAILED TO TAKE A NET CAPITAL CHARGE ON THE BALANCE. (CONT. IN COMMENT) Initiated By: FINRA Date Initiated: 07/16/2012 Docket/Case Number: 2009019725701

Principal Product Type: Other Other Product Type(s): UNSPECIFIED SECURITIES AND FOREIGN SHARES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/16/2012 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: 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 $250,000. FINE PAID IN FULL JULY 30, 2012. Regulator Statement (CONT. FROM ALLEGATIONS) A RECONCILIATION ACCOUNT INCLUDED AN AGED CASH BREAK OF APPROXIMATELY $630,000 AND THE FIRM FAILED TO MOVE THIS ITEM TO A SUSPENSE ACCOUNT OR INCLUDE IT II ITS NET CAPITAL COMPUTATION FOR THE PERIOD. IN CONNECTION WITH THE CUSTOMER RESERVE AND NET CAPITAL VIOLATIONS, THE FIRM'S BOOKS AND RECORDS WERE INACCURATE IN THAT IT: FAILED TO INCLUDE NUMEROUS SUSPENSE BALANCES IN THE CUSTOMER RESERVE FORMULA; FAILED TO PROVIDE EVIDENCE THAT NETTED BALANCES IN SUSPENSE ACCOUNTS WERE RELATED; FAILED TO TIMELY MOVE AGED BALANCES FROM VARIOUS ACCOUNTS TO SUSPENSE ACCOUNTS, WHERE THEY WOULD HAVE INCREASED ITS RESERVE REQUIREMENT; AND FAILED TO TAKE NET CAPITAL CHARGES FOR AGED DEBITS IN FIVE ACCOUNTS. IN ADDITION, THE FIRM WAS UNABLE TO PROVIDE DOCUMENTATION REGARDING CERTAIN OF ITS CUSTOMER RESERVE CALCULATIONS. THE FIRM HAD NUMEROUS ACCOUNTS THAT HELD OPEN AGED ITEMS, UNTIL THE FIRM RESEARCHED AND RESOLVED THE ITEMS AND MADE THE APPROPRIATE CORRECTING ENTRIES. THESE ACCOUNTS WERE FUNCTIONING AS SUSPENSE ACCOUNTS, BUT WERE ERRONEOUSLY MAINTAINED OUTSIDE THE SUSPENSE ACCOUNT RANGE. NUMEROUS TRANSACTIONS POSTED TO THESE ACCOUNTS WERE NOT RESOLVED ©2021 FINRA. All rights reserved. Report aboutWITHIN RBC SEVENCAPITAL MARKETS,BUSINESS LLC DAYS. AS A RESULT, THESE ACCOUNTS 292 CONTAINED UNRESOLVED DIFFERENCES THAT WERE NOT RECOGNIZED AND CLASSIFIED ON THE FIRM'S BOOKS AND RECORDS AS SUSPENSE BALANCES, AND THE UNRESOLVED BALANCES WERE NOT MOVED TO SUSPENSE ACCOUNTS AFTER SEVEN BUSINESS DAYS. THEREFORE, THE FIRM MAINTAINED SUSPENSE ACCOUNTS OUTSIDE THE SUSPENSE ACCOUNT RANGE AND FAILED TO MOVE AGED ITEMS TO SUSPENSE ACCOUNTS. IN CONNECTION WITH THE ADJUSTMENTS REQUIRED TO THE FIRM'S CUSTOMER RESERVE FORMULA COMPUTATIONS AND NET CAPITAL CALCULATIONS, THE FIRM'S FOCUS REPORT WAS INACCURATE. IN ADDITION, THE FIRM FAILED TO COMPLETE THE FINANCIAL AND OPERATIONAL DATA (POTENTIAL OPERATIONAL DEDUCTIONS FROM CAPITAL) SECTION. BECAUSE OF THE AGED SUSPENSE AND BALANCING DIFFERENCES, THE FIRM FILED INACCURATE KEY OPERATIONAL INDICATOR REPORTS WITH FINRA. WHEN THE FIRM ESTABLISHED NEW PROCEDURES, THE FIRM FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SYSTEM TO SUPERVISE, AND WRITTEN PROCEDURES RELATED TO, THE COMPUTATION OF ITS CUSTOMER RESERVE AND NET CAPITAL FORMULAS. THE FIRM'S SYSTEM OF SUPERVISION AND WRITTEN PROCEDURES WAS INADEQUATE, HOWEVER, IN THAT IT FAILED TO ADDRESS SYSTEM AND OPERATIONAL CHANGES THAT OCCURRED AT THE TIME OF THE CONVERSION, FAILED TO ASSIGN RESPONSIBILITY FOR VARIOUS CUSTOMER RESERVE AND NET CAPITAL COMPUTATION FUNCTIONS, AND FAILED TO PROVIDE FOR AN ADEQUATE SYSTEM OF REVIEW. FIRM EMPLOYEES WERE NOT ADEQUATELY TRAINED ON HOW THE NEW SYSTEMS WORKED TO BE ABLE TO FORESEE AND PROPERLY ADDRESS THE BACK-OFFICE POSTING PROBLEMS CAUSED BY THE CONVERSION. AT THE TIME OF THE CONVERSION, THERE WERE INCONSISTENCIES AND MISCOMMUNICATIONS BETWEEN DEPARTMENTS DUE TO THE LACK OF ADEQUATE TRAINING AND INSUFFICIENT WRITTEN PROCEDURES. AS A RESULT, THE FIRM EXPERIENCED A LARGE VOLUME OF STOCK RECORD BREAKS AND MONEY AND SECURITY DIFFERENCES THAT IT WAS UNABLE TO RESOLVE, WHICH RESULTED IN THE CAPITAL RESERVE, NET CAPITAL, AND RECORDKEEPING VIOLATIONS. (CONT. FROM ALLEGATIONS) A RECONCILIATION ACCOUNT INCLUDED AN AGED CASH BREAK OF APPROXIMATELY $630,000 AND THE FIRM FAILED TO MOVE THIS ITEM TO A SUSPENSE ACCOUNT OR INCLUDE IT II ITS NET CAPITAL COMPUTATION FOR THE PERIOD. IN CONNECTION WITH THE CUSTOMER RESERVE AND NET CAPITAL VIOLATIONS, THE FIRM'S BOOKS AND RECORDS WERE INACCURATE IN THAT IT: FAILED TO INCLUDE NUMEROUS SUSPENSE BALANCES IN THE CUSTOMER RESERVE FORMULA; FAILED TO PROVIDE EVIDENCE THAT NETTED BALANCES IN SUSPENSE ACCOUNTS WERE RELATED; FAILED TO TIMELY MOVE AGED BALANCES FROM VARIOUS ACCOUNTS TO SUSPENSE ACCOUNTS, WHERE THEY WOULD HAVE INCREASED ITS RESERVE REQUIREMENT; AND FAILED TO TAKE NET CAPITAL CHARGES FOR AGED DEBITS IN FIVE ACCOUNTS. IN ADDITION, THE FIRM WAS UNABLE TO PROVIDE DOCUMENTATION REGARDING CERTAIN OF ITS CUSTOMER RESERVE CALCULATIONS. THE FIRM HAD NUMEROUS ACCOUNTS THAT HELD OPEN AGED ITEMS, UNTIL www.finra.org/brokercheck THE FIRM RESEARCHED AND RESOLVED THE ITEMS AND MADE THE User Guidance APPROPRIATE CORRECTING ENTRIES. THESE ACCOUNTS WERE FUNCTIONING AS SUSPENSE ACCOUNTS, BUT WERE ERRONEOUSLY MAINTAINED OUTSIDE THE SUSPENSE ACCOUNT RANGE. NUMEROUS TRANSACTIONS POSTED TO THESE ACCOUNTS WERE NOT RESOLVED WITHIN SEVEN BUSINESS DAYS. AS A RESULT, THESE ACCOUNTS CONTAINED UNRESOLVED DIFFERENCES THAT WERE NOT RECOGNIZED AND CLASSIFIED ON THE FIRM'S BOOKS AND RECORDS AS SUSPENSE BALANCES, AND THE UNRESOLVED BALANCES WERE NOT MOVED TO SUSPENSE ACCOUNTS AFTER SEVEN BUSINESS DAYS. THEREFORE, THE FIRM MAINTAINED SUSPENSE ACCOUNTS OUTSIDE THE SUSPENSE ACCOUNT RANGE AND FAILED TO MOVE AGED ITEMS TO SUSPENSE ACCOUNTS. IN CONNECTION WITH THE ADJUSTMENTS REQUIRED TO THE FIRM'S CUSTOMER RESERVE FORMULA COMPUTATIONS AND NET CAPITAL CALCULATIONS, THE FIRM'S FOCUS REPORT WAS INACCURATE. IN ADDITION, THE FIRM FAILED TO COMPLETE THE FINANCIAL AND OPERATIONAL DATA (POTENTIAL OPERATIONAL DEDUCTIONS FROM CAPITAL) SECTION. BECAUSE OF THE AGED SUSPENSE AND BALANCING DIFFERENCES, THE FIRM FILED INACCURATE KEY OPERATIONAL INDICATOR REPORTS WITH FINRA. WHEN THE FIRM ESTABLISHED NEW PROCEDURES, THE FIRM FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SYSTEM TO SUPERVISE, AND WRITTEN PROCEDURES RELATED TO, THE COMPUTATION OF ITS CUSTOMER RESERVE AND NET CAPITAL FORMULAS. THE FIRM'S SYSTEM OF SUPERVISION AND WRITTEN PROCEDURES WAS INADEQUATE, HOWEVER, IN THAT IT FAILED TO ADDRESS SYSTEM AND OPERATIONAL CHANGES THAT OCCURRED AT THE TIME OF THE CONVERSION, FAILED TO ASSIGN RESPONSIBILITY FOR VARIOUS CUSTOMER RESERVE AND NET CAPITAL COMPUTATION FUNCTIONS, AND FAILED TO PROVIDE FOR AN ADEQUATE SYSTEM OF REVIEW. FIRM EMPLOYEES WERE NOT ADEQUATELY TRAINED ON HOW THE NEW SYSTEMS WORKED TO BE ABLE TO FORESEE AND PROPERLY ADDRESS THE BACK-OFFICE POSTING PROBLEMS CAUSED BY THE CONVERSION. AT THE TIME OF THE CONVERSION, THERE WERE INCONSISTENCIES AND MISCOMMUNICATIONS BETWEEN DEPARTMENTS DUE TO THE LACK OF ADEQUATE TRAINING AND INSUFFICIENT WRITTEN PROCEDURES. AS A RESULT, THE FIRM EXPERIENCED A LARGE VOLUME OF STOCK RECORD BREAKS AND MONEY AND SECURITY DIFFERENCES THAT IT WAS UNABLE TO RESOLVE, WHICH RESULTED IN THE CAPITAL RESERVE, NET CAPITAL, AND RECORDKEEPING VIOLATIONS. i Reporting Source: Firm Current Status: Final Allegations: EXCHANGE ACT RULES 15C3-1, 15C3-3, 17A-3, 17A-5, FINRA RULE 2010, NASD RULES 2110, 3010(A) AND (B), NYSE RULES 416(A), 440.20: THE FIRM UNDERWENT A MERGER COMBINING THE INSTITUTIONAL FIRM WITH ITS AFFILIATED RETAIL FIRM, AND FOLLOWING THE MERGER AND CONVERSION, IT EXPERIENCED DIFFICULTIES IN RECONCILING ITS ACCOUNTS, WHICH RESULTED IN CUSTOMER RESERVE, NET CAPITAL, ©2021 FINRA. All rights reserved. Report aboutRECORDKEEPING, RBC CAPITAL MARKETS, AND LLCSUPERVISORY VIOLATIONS. WITH RESPECT TO 293 CUSTOMER RESERVE, THE FIRM FAILED TO PREPARE AN ACCURATE CUSTOMER RESERVE FORMULA, WHICH RESULTED IN AN APPARENT HINDSIGHT DEFICIENCY OF APPROXIMATELY $51 MILLION. THE FIRM FAILED TO INCLUDE APPROXIMATELY $453 MILLION OF AGED CREDIT BALANCES FROM SUSPENSE, CLEARANCE, AND WASH ACCOUNTS IN ITS CUSTOMER RESERVE FORMULA. WITH RESPECT TO BALANCES IN OTHER ACCOUNTS, THE FIRM FAILED TO MOVE APPROXIMATELY $127 MILLION OF ITEMS, SEVEN DAYS OR OLDER, FROM A BANK'S CLEARANCE ACCOUNTS TO SUSPENSE ACCOUNTS, AND FAILED TO INCLUDE THE BALANCE IN ITS CUSTOMER RESERVE FORMULA; FAILED TO TAKE A CUSTOMER RESERVE FORMULA CREDIT FOR SEVEN AGED, SHORT POSITIONS OF FOREIGN SHARES HELD IN THE BANK'S DEPOSITORY ACCOUNT OF APPROXIMATELY $37 MILLION, WHICH HAD BEEN IN THE ACCOUNT FOR PERIODS RANGING FROM 16 TO 23 BUSINESS DAYS; FAILED TO INCLUDE, AGED, CREDIT BALANCES IN A MONEY DIFFERENCE ACCOUNT OF APPROXIMATELY $20 MILLION AND $9.7 MILLION, WHICH WERE RESOLVED AFTER 49 AND 63 BUSINESS DAYS; FAILED TO INCLUDE AN AGED BALANCE OF APPROXIMATELY $18 MILLION IN A TREASURY SUSPENSE ACCOUNT, WHICH REMAINED UNRESOLVED FOR 43 BUSINESS DAYS; FAILED TO MOVE SOME, AGED CASH BREAKS OF APPROXIMATELY $3.6 MILLION FROM A CUSTOMER'S RECONCILIATION ACCOUNT TO A SUSPENSE ACCOUNT OR INCLUDE THEM IN THE CUSTOMER RESERVE FORMULA, SOME OF WHICH REMAINED UNRESOLVED AS OF THE PERIOD, AND SOME OF WHICH REMAINED OPEN FOR. PERIODS RANGING FROM 19 TO 47 BUSINESS DAYS; FAILED TO INCLUDE AN AGED ITEM IN ITS SECURITIES CLEARING SUSPENSE ACCOUNT IN THE AMOUNT OF APPROXIMATELY $2.2 MILLION IN ITS CUSTOMER RESERVE FORMULA, WHICH WAS RESOLVED AFTER 69 BUSINESS DAYS. THE FIRM OVERSTATED FAILS TO RECEIVE AND AGED DIVIDENDS OF APPROXIMATELY $228 MILLION IN ITS CUSTOMER RESERVE FORMULA. THE FIRM FAILED TO PAIR OFF APPROXIMATELY $192 MILLION OF FAILS TO RECEIVE AGAINST SUSPENSE LONGS, AND ERRONEOUSLY INCLUDED THIS AMOUNT IN THE CUSTOMER RESERVE FORMULA. IN ADDITION, THE FIRM FAILED TO NET AGED STOCK DIVIDENDS IN THE AMOUNT OF APPROXIMATELY $35 MILLION WITH RELATED ITEMS AND ERRONEOUSLY INCLUDED THAT AMOUNT IN THE CUSTOMER RESERVE FORMULA. THE FIRM MADE A LATE DEPOSIT TO ITS CUSTOMER RESERVE ACCOUNT RESULTING IN AN EIGHT-MINUTE HINDSIGHT DEFICIENCY OF APPROXIMATELY $317 MILLION, AND IT MADE SOME LATE WITHDRAWALS FROM CUSTOMER RESERVE AND PROPRIETARY ACCOUNTS OF INTRODUCING BROKERS. THE FIRM FAILED TO TAKE NET CAPITAL CHARGES OF APPROXIMATELY $366 MILLION FOR AGED DEBITS IN SOME ACCOUNTS. THIS AMOUNT REDUCED THE FIRM'S EXCESS NET CAPITAL FROM APPROXIMATELY $627 MILLION TO $260 MILLION, BUT DID NOT RESULT IN A DEFICIENCY. THE FIRM FAILED TO INCLUDE AN ACCOUNT THAT CONTAINED UNRESOLVED DEBIT ITEMS OF APPROXIMATELY $191 MILLION, IN THE SUSPENSE RANGE OF ACCOUNTS AND FAILED TO TAKE A NET CAPITAL CHARGE ON THE BALANCE. THE FIRM FAILED TO MOVE AGED EXCEPTIONS TO A BANK'S SUSPENSE ACCOUNTS AND FAILED TO TAKE A NET CAPITAL CHARGE OF APPROXIMATELY $91 MILLION. THE FIRM FAILED TO ACCOUNT FOR AGED DEBIT BALANCES IN A MONEY DIFFERENCE ACCOUNT IN THE AMOUNTS OF APPROXIMATELY $1.2 MILLION AND $1 MILLION. THESE BALANCES WERE RESOLVED AFTER 60 BUSINESS DAYS AND 37 BUSINESS DAYS, RESPECTIVELY. THE FIRM FAILED TO MOVE THESE BALANCES TO A SUSPENSE ACCOUNT OR INCLUDE THE APPROXIMATELY $2 MILLION DEBIT IN ITS NET CAPITAL CALCULATION FOR THE PERIOD. THE FIRM FAILED TO INCLUDE AN ACCOUNT THAT HAD A BALANCE OF APPROXIMATELY $2.1 MILLION IN THE SUSPENSE RANGE OF ACCOUNTS, AND FAILED TO TAKE A NET CAPITAL CHARGE ON THE BALANCE. (CONT. IN COMMENT) EXCHANGE ACT RULES 15C3-1, 15C3-3, 17A-3, 17A-5, FINRA RULE 2010, www.finra.org/brokercheck NASD RULES 2110, 3010(A) AND (B), NYSE RULES 416(A), 440.20: THE FIRM User Guidance UNDERWENT A MERGER COMBINING THE INSTITUTIONAL FIRM WITH ITS AFFILIATED RETAIL FIRM, AND FOLLOWING THE MERGER AND CONVERSION, IT EXPERIENCED DIFFICULTIES IN RECONCILING ITS ACCOUNTS, WHICH RESULTED IN CUSTOMER RESERVE, NET CAPITAL, RECORDKEEPING, AND SUPERVISORY VIOLATIONS. WITH RESPECT TO CUSTOMER RESERVE, THE FIRM FAILED TO PREPARE AN ACCURATE CUSTOMER RESERVE FORMULA, WHICH RESULTED IN AN APPARENT HINDSIGHT DEFICIENCY OF APPROXIMATELY $51 MILLION. THE FIRM FAILED TO INCLUDE APPROXIMATELY $453 MILLION OF AGED CREDIT BALANCES FROM SUSPENSE, CLEARANCE, AND WASH ACCOUNTS IN ITS CUSTOMER RESERVE FORMULA. WITH RESPECT TO BALANCES IN OTHER ACCOUNTS, THE FIRM FAILED TO MOVE APPROXIMATELY $127 MILLION OF ITEMS, SEVEN DAYS OR OLDER, FROM A BANK'S CLEARANCE ACCOUNTS TO SUSPENSE ACCOUNTS, AND FAILED TO INCLUDE THE BALANCE IN ITS CUSTOMER RESERVE FORMULA; FAILED TO TAKE A CUSTOMER RESERVE FORMULA CREDIT FOR SEVEN AGED, SHORT POSITIONS OF FOREIGN SHARES HELD IN THE BANK'S DEPOSITORY ACCOUNT OF APPROXIMATELY $37 MILLION, WHICH HAD BEEN IN THE ACCOUNT FOR PERIODS RANGING FROM 16 TO 23 BUSINESS DAYS; FAILED TO INCLUDE, AGED, CREDIT BALANCES IN A MONEY DIFFERENCE ACCOUNT OF APPROXIMATELY $20 MILLION AND $9.7 MILLION, WHICH WERE RESOLVED AFTER 49 AND 63 BUSINESS DAYS; FAILED TO INCLUDE AN AGED BALANCE OF APPROXIMATELY $18 MILLION IN A TREASURY SUSPENSE ACCOUNT, WHICH REMAINED UNRESOLVED FOR 43 BUSINESS DAYS; FAILED TO MOVE SOME, AGED CASH BREAKS OF APPROXIMATELY $3.6 MILLION FROM A CUSTOMER'S RECONCILIATION ACCOUNT TO A SUSPENSE ACCOUNT OR INCLUDE THEM IN THE CUSTOMER RESERVE FORMULA, SOME OF WHICH REMAINED UNRESOLVED AS OF THE PERIOD, AND SOME OF WHICH REMAINED OPEN FOR. PERIODS RANGING FROM 19 TO 47 BUSINESS DAYS; FAILED TO INCLUDE AN AGED ITEM IN ITS SECURITIES CLEARING SUSPENSE ACCOUNT IN THE AMOUNT OF APPROXIMATELY $2.2 MILLION IN ITS CUSTOMER RESERVE FORMULA, WHICH WAS RESOLVED AFTER 69 BUSINESS DAYS. THE FIRM OVERSTATED FAILS TO RECEIVE AND AGED DIVIDENDS OF APPROXIMATELY $228 MILLION IN ITS CUSTOMER RESERVE FORMULA. THE FIRM FAILED TO PAIR OFF APPROXIMATELY $192 MILLION OF FAILS TO RECEIVE AGAINST SUSPENSE LONGS, AND ERRONEOUSLY INCLUDED THIS AMOUNT IN THE CUSTOMER RESERVE FORMULA. IN ADDITION, THE FIRM FAILED TO NET AGED STOCK DIVIDENDS IN THE AMOUNT OF APPROXIMATELY $35 MILLION WITH RELATED ITEMS AND ERRONEOUSLY INCLUDED THAT AMOUNT IN THE CUSTOMER RESERVE FORMULA. THE FIRM MADE A LATE DEPOSIT TO ITS CUSTOMER RESERVE ACCOUNT RESULTING IN AN EIGHT-MINUTE HINDSIGHT DEFICIENCY OF APPROXIMATELY $317 MILLION, AND IT MADE SOME LATE WITHDRAWALS FROM CUSTOMER RESERVE AND PROPRIETARY ACCOUNTS OF INTRODUCING BROKERS. THE FIRM FAILED TO TAKE NET CAPITAL CHARGES OF APPROXIMATELY $366 MILLION FOR AGED DEBITS IN SOME ACCOUNTS. THIS AMOUNT REDUCED THE FIRM'S EXCESS NET CAPITAL FROM APPROXIMATELY $627 MILLION TO $260 MILLION, BUT DID NOT RESULT IN A DEFICIENCY. THE FIRM FAILED TO ©2021 FINRA. All rights reserved. Report aboutINCLUDE RBC CAPITAL AN ACCOUNT MARKETS, THATLLC CONTAINED UNRESOLVED DEBIT ITEMS OF 294 APPROXIMATELY $191 MILLION, IN THE SUSPENSE RANGE OF ACCOUNTS AND FAILED TO TAKE A NET CAPITAL CHARGE ON THE BALANCE. THE FIRM FAILED TO MOVE AGED EXCEPTIONS TO A BANK'S SUSPENSE ACCOUNTS AND FAILED TO TAKE A NET CAPITAL CHARGE OF APPROXIMATELY $91 MILLION. THE FIRM FAILED TO ACCOUNT FOR AGED DEBIT BALANCES IN A MONEY DIFFERENCE ACCOUNT IN THE AMOUNTS OF APPROXIMATELY $1.2 MILLION AND $1 MILLION. THESE BALANCES WERE RESOLVED AFTER 60 BUSINESS DAYS AND 37 BUSINESS DAYS, RESPECTIVELY. THE FIRM FAILED TO MOVE THESE BALANCES TO A SUSPENSE ACCOUNT OR INCLUDE THE APPROXIMATELY $2 MILLION DEBIT IN ITS NET CAPITAL CALCULATION FOR THE PERIOD. THE FIRM FAILED TO INCLUDE AN ACCOUNT THAT HAD A BALANCE OF APPROXIMATELY $2.1 MILLION IN THE SUSPENSE RANGE OF ACCOUNTS, AND FAILED TO TAKE A NET CAPITAL CHARGE ON THE BALANCE. (CONT. IN COMMENT) EXCHANGE ACT RULES 15C3-1, 15C3-3, 17A-3, 17A-5, FINRA RULE 2010, NASD RULES 2110, 3010(A) AND (B), NYSE RULES 416(A), 440.20: THE FIRM UNDERWENT A MERGER COMBINING THE INSTITUTIONAL FIRM WITH ITS AFFILIATED RETAIL FIRM, AND FOLLOWING THE MERGER AND CONVERSION, IT EXPERIENCED DIFFICULTIES IN RECONCILING ITS ACCOUNTS, WHICH RESULTED IN CUSTOMER RESERVE, NET CAPITAL, RECORDKEEPING, AND SUPERVISORY VIOLATIONS. WITH RESPECT TO CUSTOMER RESERVE, THE FIRM FAILED TO PREPARE AN ACCURATE CUSTOMER RESERVE FORMULA, WHICH RESULTED IN AN APPARENT HINDSIGHT DEFICIENCY OF APPROXIMATELY $51 MILLION. THE FIRM FAILED TO INCLUDE APPROXIMATELY $453 MILLION OF AGED CREDIT BALANCES FROM SUSPENSE, CLEARANCE, AND WASH ACCOUNTS IN ITS CUSTOMER RESERVE FORMULA. WITH RESPECT TO BALANCES IN OTHER ACCOUNTS, THE FIRM FAILED TO MOVE APPROXIMATELY $127 MILLION OF ITEMS, SEVEN DAYS OR OLDER, FROM A BANK'S CLEARANCE ACCOUNTS TO SUSPENSE ACCOUNTS, AND FAILED TO INCLUDE THE BALANCE IN ITS CUSTOMER RESERVE FORMULA; FAILED TO TAKE A CUSTOMER RESERVE FORMULA CREDIT FOR SEVEN AGED, SHORT POSITIONS OF FOREIGN SHARES HELD IN THE BANK'S DEPOSITORY ACCOUNT OF APPROXIMATELY $37 MILLION, WHICH HAD BEEN IN THE ACCOUNT FOR PERIODS RANGING FROM 16 TO 23 BUSINESS DAYS; FAILED TO INCLUDE, AGED, CREDIT BALANCES IN A MONEY DIFFERENCE ACCOUNT OF APPROXIMATELY $20 MILLION AND $9.7 MILLION, WHICH WERE RESOLVED AFTER 49 AND 63 BUSINESS DAYS; FAILED TO INCLUDE AN AGED BALANCE OF APPROXIMATELY $18 MILLION IN A TREASURY SUSPENSE ACCOUNT, WHICH REMAINED UNRESOLVED FOR 43 BUSINESS DAYS; FAILED TO MOVE SOME, AGED CASH BREAKS OF APPROXIMATELY $3.6 MILLION FROM A CUSTOMER'S RECONCILIATION ACCOUNT TO A SUSPENSE ACCOUNT OR INCLUDE THEM IN THE CUSTOMER RESERVE FORMULA, SOME OF WHICH REMAINED UNRESOLVED AS OF THE PERIOD, AND SOME OF WHICH REMAINED OPEN FOR. PERIODS RANGING FROM 19 TO 47 BUSINESS DAYS; FAILED TO INCLUDE AN AGED ITEM IN ITS SECURITIES CLEARING SUSPENSE ACCOUNT IN THE AMOUNT OF APPROXIMATELY $2.2 MILLION IN ITS CUSTOMER RESERVE FORMULA, WHICH WAS RESOLVED AFTER 69 BUSINESS DAYS. THE FIRM OVERSTATED FAILS TO RECEIVE AND AGED DIVIDENDS OF APPROXIMATELY $228 MILLION IN ITS CUSTOMER RESERVE FORMULA. THE FIRM FAILED TO PAIR OFF APPROXIMATELY $192 MILLION OF FAILS TO RECEIVE AGAINST SUSPENSE LONGS, AND ERRONEOUSLY INCLUDED THIS AMOUNT IN THE CUSTOMER RESERVE FORMULA. IN ADDITION, THE FIRM FAILED TO NET AGED STOCK DIVIDENDS IN THE AMOUNT OF APPROXIMATELY $35 MILLION WITH RELATED ITEMS AND ERRONEOUSLY INCLUDED THAT AMOUNT IN THE CUSTOMER RESERVE FORMULA. THE FIRM MADE A LATE DEPOSIT TO ITS CUSTOMER RESERVE ACCOUNT RESULTING IN AN EIGHT-MINUTE HINDSIGHT DEFICIENCY OF APPROXIMATELY $317 MILLION, AND IT MADE SOME LATE WITHDRAWALS FROM CUSTOMER RESERVE AND www.finra.org/brokercheck PROPRIETARY ACCOUNTS OF INTRODUCING BROKERS. THE FIRM FAILED User Guidance TO TAKE NET CAPITAL CHARGES OF APPROXIMATELY $366 MILLION FOR AGED DEBITS IN SOME ACCOUNTS. THIS AMOUNT REDUCED THE FIRM'S EXCESS NET CAPITAL FROM APPROXIMATELY $627 MILLION TO $260 MILLION, BUT DID NOT RESULT IN A DEFICIENCY. THE FIRM FAILED TO INCLUDE AN ACCOUNT THAT CONTAINED UNRESOLVED DEBIT ITEMS OF APPROXIMATELY $191 MILLION, IN THE SUSPENSE RANGE OF ACCOUNTS AND FAILED TO TAKE A NET CAPITAL CHARGE ON THE BALANCE. THE FIRM FAILED TO MOVE AGED EXCEPTIONS TO A BANK'S SUSPENSE ACCOUNTS AND FAILED TO TAKE A NET CAPITAL CHARGE OF APPROXIMATELY $91 MILLION. THE FIRM FAILED TO ACCOUNT FOR AGED DEBIT BALANCES IN A MONEY DIFFERENCE ACCOUNT IN THE AMOUNTS OF APPROXIMATELY $1.2 MILLION AND $1 MILLION. THESE BALANCES WERE RESOLVED AFTER 60 BUSINESS DAYS AND 37 BUSINESS DAYS, RESPECTIVELY. THE FIRM FAILED TO MOVE THESE BALANCES TO A SUSPENSE ACCOUNT OR INCLUDE THE APPROXIMATELY $2 MILLION DEBIT IN ITS NET CAPITAL CALCULATION FOR THE PERIOD. THE FIRM FAILED TO INCLUDE AN ACCOUNT THAT HAD A BALANCE OF APPROXIMATELY $2.1 MILLION IN THE SUSPENSE RANGE OF ACCOUNTS, AND FAILED TO TAKE A NET CAPITAL CHARGE ON THE BALANCE. (CONT. IN COMMENT) Initiated By: FINRA Date Initiated: 07/16/2012 Docket/Case Number: 2009019725701

Principal Product Type: Other Other Product Type(s): UNSPECIFIED SECURITIES AND FOREIGN SHARES 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: 07/16/2012 Sanctions Ordered: Censure Monetary/Fine $250,000.00 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 $250,000. Firm Statement (CONT. FROM ALLEGATIONS) A RECONCILIATION ACCOUNT INCLUDED AN AGED CASH BREAK OF APPROXIMATELY $630,000 AND THE FIRM FAILED TO MOVE THIS ITEM TO A SUSPENSE ACCOUNT OR INCLUDE IT II ITS NET CAPITAL COMPUTATION FOR THE PERIOD. IN CONNECTION WITH THE CUSTOMER RESERVE AND NET CAPITAL VIOLATIONS, THE FIRM'S BOOKS AND RECORDS WERE INACCURATE IN THAT IT: FAILED TO INCLUDE ©2021 FINRA. All rights reserved. Report aboutNUMEROUS RBC CAPITAL SUSPENSE MARKETS, LLCBALANCES IN THE CUSTOMER RESERVE 295 FORMULA; FAILED TO PROVIDE EVIDENCE THAT NETTED BALANCES IN SUSPENSE ACCOUNTS WERE RELATED; FAILED TO TIMELY MOVE AGED BALANCES FROM VARIOUS ACCOUNTS TO SUSPENSE ACCOUNTS, WHERE THEY WOULD HAVE INCREASED ITS RESERVE REQUIREMENT; AND FAILED TO TAKE NET CAPITAL CHARGES FOR AGED DEBITS IN FIVE ACCOUNTS. IN ADDITION, THE FIRM WAS UNABLE TO PROVIDE DOCUMENTATION REGARDING CERTAIN OF ITS CUSTOMER RESERVE CALCULATIONS. THE FIRM HAD NUMEROUS ACCOUNTS THAT HELD OPEN AGED ITEMS, UNTIL THE FIRM RESEARCHED AND RESOLVED THE ITEMS AND MADE THE APPROPRIATE CORRECTING ENTRIES. THESE ACCOUNTS WERE FUNCTIONING AS SUSPENSE ACCOUNTS, BUT WERE ERRONEOUSLY MAINTAINED OUTSIDE THE SUSPENSE ACCOUNT RANGE. NUMEROUS TRANSACTIONS POSTED TO THESE ACCOUNTS WERE NOT RESOLVED WITHIN SEVEN BUSINESS DAYS. AS A RESULT, THESE ACCOUNTS CONTAINED UNRESOLVED DIFFERENCES THAT WERE NOT RECOGNIZED AND CLASSIFIED ON THE FIRM'S BOOKS AND RECORDS AS SUSPENSE BALANCES, AND THE UNRESOLVED BALANCES WERE NOT MOVED TO SUSPENSE ACCOUNTS AFTER SEVEN BUSINESS DAYS. THEREFORE, THE FIRM MAINTAINED SUSPENSE ACCOUNTS OUTSIDE THE SUSPENSE ACCOUNT RANGE AND FAILED TO MOVE AGED ITEMS TO SUSPENSE ACCOUNTS. IN CONNECTION WITH THE ADJUSTMENTS REQUIRED TO THE FIRM'S CUSTOMER RESERVE FORMULA COMPUTATIONS AND NET CAPITAL CALCULATIONS, THE FIRM'S FOCUS REPORT WAS INACCURATE. IN ADDITION, THE FIRM FAILED TO COMPLETE THE FINANCIAL AND OPERATIONAL DATA (POTENTIAL OPERATIONAL DEDUCTIONS FROM CAPITAL) SECTION. BECAUSE OF THE AGED SUSPENSE AND BALANCING DIFFERENCES, THE FIRM FILED INACCURATE KEY OPERATIONAL INDICATOR REPORTS WITH FINRA. WHEN THE FIRM ESTABLISHED NEW PROCEDURES, THE FIRM FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SYSTEM TO SUPERVISE, AND WRITTEN PROCEDURES RELATED TO, THE COMPUTATION OF ITS CUSTOMER RESERVE AND NET CAPITAL FORMULAS. THE FIRM'S SYSTEM OF SUPERVISION AND WRITTEN PROCEDURES WAS INADEQUATE, HOWEVER, IN THAT IT FAILED TO ADDRESS SYSTEM AND OPERATIONAL CHANGES THAT OCCURRED AT THE TIME OF THE CONVERSION, FAILED TO ASSIGN RESPONSIBILITY FOR VARIOUS CUSTOMER RESERVE AND NET CAPITAL COMPUTATION FUNCTIONS, AND FAILED TO PROVIDE FOR AN ADEQUATE SYSTEM OF REVIEW. FIRM EMPLOYEES WERE NOT ADEQUATELY TRAINED ON HOW THE NEW SYSTEMS WORKED TO BE ABLE TO FORESEE AND PROPERLY ADDRESS THE BACK-OFFICE POSTING PROBLEMS CAUSED BY THE CONVERSION. AT THE TIME OF THE CONVERSION, THERE WERE INCONSISTENCIES AND MISCOMMUNICATIONS BETWEEN DEPARTMENTS DUE TO THE LACK OF ADEQUATE TRAINING AND INSUFFICIENT WRITTEN PROCEDURES. AS A RESULT, THE FIRM EXPERIENCED A LARGE VOLUME OF STOCK RECORD BREAKS AND MONEY AND SECURITY DIFFERENCES THAT IT WAS UNABLE TO RESOLVE, WHICH RESULTED IN THE CAPITAL RESERVE, NET CAPITAL, AND RECORDKEEPING VIOLATIONS. (CONT. FROM ALLEGATIONS) A RECONCILIATION ACCOUNT INCLUDED AN www.finra.org/brokercheck AGED CASH BREAK OF APPROXIMATELY $630,000 AND THE FIRM FAILED User Guidance TO MOVE THIS ITEM TO A SUSPENSE ACCOUNT OR INCLUDE IT II ITS NET CAPITAL COMPUTATION FOR THE PERIOD. IN CONNECTION WITH THE CUSTOMER RESERVE AND NET CAPITAL VIOLATIONS, THE FIRM'S BOOKS AND RECORDS WERE INACCURATE IN THAT IT: FAILED TO INCLUDE NUMEROUS SUSPENSE BALANCES IN THE CUSTOMER RESERVE FORMULA; FAILED TO PROVIDE EVIDENCE THAT NETTED BALANCES IN SUSPENSE ACCOUNTS WERE RELATED; FAILED TO TIMELY MOVE AGED BALANCES FROM VARIOUS ACCOUNTS TO SUSPENSE ACCOUNTS, WHERE THEY WOULD HAVE INCREASED ITS RESERVE REQUIREMENT; AND FAILED TO TAKE NET CAPITAL CHARGES FOR AGED DEBITS IN FIVE ACCOUNTS. IN ADDITION, THE FIRM WAS UNABLE TO PROVIDE DOCUMENTATION REGARDING CERTAIN OF ITS CUSTOMER RESERVE CALCULATIONS. THE FIRM HAD NUMEROUS ACCOUNTS THAT HELD OPEN AGED ITEMS, UNTIL THE FIRM RESEARCHED AND RESOLVED THE ITEMS AND MADE THE APPROPRIATE CORRECTING ENTRIES. THESE ACCOUNTS WERE FUNCTIONING AS SUSPENSE ACCOUNTS, BUT WERE ERRONEOUSLY MAINTAINED OUTSIDE THE SUSPENSE ACCOUNT RANGE. NUMEROUS TRANSACTIONS POSTED TO THESE ACCOUNTS WERE NOT RESOLVED WITHIN SEVEN BUSINESS DAYS. AS A RESULT, THESE ACCOUNTS CONTAINED UNRESOLVED DIFFERENCES THAT WERE NOT RECOGNIZED AND CLASSIFIED ON THE FIRM'S BOOKS AND RECORDS AS SUSPENSE BALANCES, AND THE UNRESOLVED BALANCES WERE NOT MOVED TO SUSPENSE ACCOUNTS AFTER SEVEN BUSINESS DAYS. THEREFORE, THE FIRM MAINTAINED SUSPENSE ACCOUNTS OUTSIDE THE SUSPENSE ACCOUNT RANGE AND FAILED TO MOVE AGED ITEMS TO SUSPENSE ACCOUNTS. IN CONNECTION WITH THE ADJUSTMENTS REQUIRED TO THE FIRM'S CUSTOMER RESERVE FORMULA COMPUTATIONS AND NET CAPITAL CALCULATIONS, THE FIRM'S FOCUS REPORT WAS INACCURATE. IN ADDITION, THE FIRM FAILED TO COMPLETE THE FINANCIAL AND OPERATIONAL DATA (POTENTIAL OPERATIONAL DEDUCTIONS FROM CAPITAL) SECTION. BECAUSE OF THE AGED SUSPENSE AND BALANCING DIFFERENCES, THE FIRM FILED INACCURATE KEY OPERATIONAL INDICATOR REPORTS WITH FINRA. WHEN THE FIRM ESTABLISHED NEW PROCEDURES, THE FIRM FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SYSTEM TO SUPERVISE, AND WRITTEN PROCEDURES RELATED TO, THE COMPUTATION OF ITS CUSTOMER RESERVE AND NET CAPITAL FORMULAS. THE FIRM'S SYSTEM OF SUPERVISION AND WRITTEN PROCEDURES WAS INADEQUATE, HOWEVER, IN THAT IT FAILED TO ADDRESS SYSTEM AND OPERATIONAL CHANGES THAT OCCURRED AT THE TIME OF THE CONVERSION, FAILED TO ASSIGN RESPONSIBILITY FOR VARIOUS CUSTOMER RESERVE AND NET CAPITAL COMPUTATION FUNCTIONS, AND FAILED TO PROVIDE FOR AN ADEQUATE SYSTEM OF REVIEW. FIRM EMPLOYEES WERE NOT ADEQUATELY TRAINED ON HOW THE NEW SYSTEMS WORKED TO BE ABLE TO FORESEE AND PROPERLY ADDRESS THE BACK-OFFICE POSTING PROBLEMS CAUSED BY THE CONVERSION. AT THE TIME OF THE CONVERSION, THERE WERE INCONSISTENCIES AND MISCOMMUNICATIONS BETWEEN DEPARTMENTS DUE TO THE LACK OF ADEQUATE TRAINING AND INSUFFICIENT WRITTEN PROCEDURES. AS A RESULT, THE FIRM EXPERIENCED A LARGE VOLUME ©2021 FINRA. All rights reserved. Report aboutOF STOCK RBC CAPITAL RECORD MARKETS, BREAKS LLC AND MONEY AND SECURITY DIFFERENCES 296 THAT IT WAS UNABLE TO RESOLVE, WHICH RESULTED IN THE CAPITAL RESERVE, NET CAPITAL, AND RECORDKEEPING VIOLATIONS. (CONT. FROM ALLEGATIONS) A RECONCILIATION ACCOUNT INCLUDED AN AGED CASH BREAK OF APPROXIMATELY $630,000 AND THE FIRM FAILED TO MOVE THIS ITEM TO A SUSPENSE ACCOUNT OR INCLUDE IT II ITS NET CAPITAL COMPUTATION FOR THE PERIOD. IN CONNECTION WITH THE CUSTOMER RESERVE AND NET CAPITAL VIOLATIONS, THE FIRM'S BOOKS AND RECORDS WERE INACCURATE IN THAT IT: FAILED TO INCLUDE NUMEROUS SUSPENSE BALANCES IN THE CUSTOMER RESERVE FORMULA; FAILED TO PROVIDE EVIDENCE THAT NETTED BALANCES IN SUSPENSE ACCOUNTS WERE RELATED; FAILED TO TIMELY MOVE AGED BALANCES FROM VARIOUS ACCOUNTS TO SUSPENSE ACCOUNTS, WHERE THEY WOULD HAVE INCREASED ITS RESERVE REQUIREMENT; AND FAILED TO TAKE NET CAPITAL CHARGES FOR AGED DEBITS IN FIVE ACCOUNTS. IN ADDITION, THE FIRM WAS UNABLE TO PROVIDE DOCUMENTATION REGARDING CERTAIN OF ITS CUSTOMER RESERVE CALCULATIONS. THE FIRM HAD NUMEROUS ACCOUNTS THAT HELD OPEN AGED ITEMS, UNTIL THE FIRM RESEARCHED AND RESOLVED THE ITEMS AND MADE THE APPROPRIATE CORRECTING ENTRIES. THESE ACCOUNTS WERE FUNCTIONING AS SUSPENSE ACCOUNTS, BUT WERE ERRONEOUSLY MAINTAINED OUTSIDE THE SUSPENSE ACCOUNT RANGE. NUMEROUS TRANSACTIONS POSTED TO THESE ACCOUNTS WERE NOT RESOLVED WITHIN SEVEN BUSINESS DAYS. AS A RESULT, THESE ACCOUNTS CONTAINED UNRESOLVED DIFFERENCES THAT WERE NOT RECOGNIZED AND CLASSIFIED ON THE FIRM'S BOOKS AND RECORDS AS SUSPENSE BALANCES, AND THE UNRESOLVED BALANCES WERE NOT MOVED TO SUSPENSE ACCOUNTS AFTER SEVEN BUSINESS DAYS. THEREFORE, THE FIRM MAINTAINED SUSPENSE ACCOUNTS OUTSIDE THE SUSPENSE ACCOUNT RANGE AND FAILED TO MOVE AGED ITEMS TO SUSPENSE ACCOUNTS. IN CONNECTION WITH THE ADJUSTMENTS REQUIRED TO THE FIRM'S CUSTOMER RESERVE FORMULA COMPUTATIONS AND NET CAPITAL CALCULATIONS, THE FIRM'S FOCUS REPORT WAS INACCURATE. IN ADDITION, THE FIRM FAILED TO COMPLETE THE FINANCIAL AND OPERATIONAL DATA (POTENTIAL OPERATIONAL DEDUCTIONS FROM CAPITAL) SECTION. BECAUSE OF THE AGED SUSPENSE AND BALANCING DIFFERENCES, THE FIRM FILED INACCURATE KEY OPERATIONAL INDICATOR REPORTS WITH FINRA. WHEN THE FIRM ESTABLISHED NEW PROCEDURES, THE FIRM FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SYSTEM TO SUPERVISE, AND WRITTEN PROCEDURES RELATED TO, THE COMPUTATION OF ITS CUSTOMER RESERVE AND NET CAPITAL FORMULAS. THE FIRM'S SYSTEM OF SUPERVISION AND WRITTEN PROCEDURES WAS INADEQUATE, HOWEVER, IN THAT IT FAILED TO ADDRESS SYSTEM AND OPERATIONAL CHANGES THAT OCCURRED AT THE TIME OF THE CONVERSION, FAILED TO ASSIGN RESPONSIBILITY FOR VARIOUS CUSTOMER RESERVE AND NET CAPITAL COMPUTATION FUNCTIONS, AND FAILED TO PROVIDE FOR AN ADEQUATE SYSTEM OF REVIEW. FIRM EMPLOYEES WERE NOT ADEQUATELY TRAINED ON HOW THE NEW SYSTEMS WORKED TO BE ABLE TO FORESEE AND PROPERLY www.finra.org/brokercheck ADDRESS THE BACK-OFFICE POSTING PROBLEMS CAUSED BY THE User Guidance CONVERSION. AT THE TIME OF THE CONVERSION, THERE WERE INCONSISTENCIES AND MISCOMMUNICATIONS BETWEEN DEPARTMENTS DUE TO THE LACK OF ADEQUATE TRAINING AND INSUFFICIENT WRITTEN PROCEDURES. AS A RESULT, THE FIRM EXPERIENCED A LARGE VOLUME OF STOCK RECORD BREAKS AND MONEY AND SECURITY DIFFERENCES THAT IT WAS UNABLE TO RESOLVE, WHICH RESULTED IN THE CAPITAL RESERVE, NET CAPITAL, AND RECORDKEEPING VIOLATIONS. i Disclosure 128 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF ILLINOIS SECRETARY OF STATE SECURITIES DEPARTMENT Date Initiated: 06/12/2012 Docket/Case Number: 08-00614

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

Resolution: Consent Resolution Date: 06/12/2012 Sanctions Ordered: Monetary/Fine $1,400,139.82 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF THE ILLINOIS SECURITIES LAW OF 1953. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, ©2021 FINRA. All rights reserved. Report about2009, RBC LIQUIDITY CAPITAL MARKETS, OPPORTUNITIES LLC FOR CUSTOMERS INELIGIBLE FOR THE 297 BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. www.finra.org/brokercheck User Guidance THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 129 of 336 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULES 1122, 2010, NASD RULES 2110, 3010: THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE RULES AND REGULATIONS CONCERNING SHORT-TERM TRANSACTIONS IN CLOSED END FUNDS (CEFS). THE FIRM UNDERWROTE IPOS INVOLVING CEFS. NEVERTHELESS, THE FIRM DID NOT HAVE A SYSTEM AND WRITTEN PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT PATTERNS OF UNSUITABLE SHORT-TERM TRADING OF CEFS, INCLUDING THOSE PURCHASED AT THE INITIAL PUBLIC OFFERING. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES FAILED TO ADDRESS THE SUITABILITY OF RECOMMENDATIONS INVOLVING CEFS. FURTHERMORE, THE FIRM'S PROCEDURES DID NOT PROVIDE ANY GUIDANCE TO SUPERVISORS ABOUT POTENTIAL ABUSES RELATING TO SHORT-TERM TRADING SALES OF CEFS PURCHASED AT THE INITIAL PUBLIC OFFERING. AS A RESULT, THE FIRM'S SUPERVISORS LACKED ADEQUATE GUIDANCE CONCERNING POTENTIAL PROBLEMS INVOLVING CEF TRANSACTIONS. IN ADDITION, THE FIRM DID NOT UTILIZE ANY EXCEPTION REPORTS OR OTHER PROCESSES TO DETECT SHORT-TERM TRADING OF CEFS. RATHER, THE SOLE MEANS AVAILABLE TO FIRM SUPERVISORS TO IDENTIFY SUCH TRADING WAS THROUGH THE DAILY REVIEW OF TRADE BLOTTERS. GIVEN THE HUNDREDS OF POTENTIAL TRANSACTIONS SUPERVISORS WERE REQUIRED TO REVIEW DAILY, THIS WAS AN INEFFECTIVE SYSTEM. MOREOVER, THE TRADE BLOTTERS DID NOT IDENTIFY WHEN THE CEFS HAD BEEN PURCHASED OR IF THEY HAD BEEN ACQUIRED AT THE INITIAL PUBLIC OFFERING. ACCORDINGLY, FIRM SUPERVISORS HAD NO EFFECTIVE WAY TO DETERMINE HOW LONG A CEF HAD BEEN HELD BY A CUSTOMER BEFORE THE SALE. AS A RESULT OF THE FIRM'S SUPERVISORY DEFICIENCIES, THE FIRM FAILED TO TIMELY DETECT AND PREVENT A REGISTERED REPRESENTATIVE'S UNSUITABLE SHORT- TERM TRADING OF CEFS PURCHASED AT THE INITIAL PUBLIC OFFERING. THE FIRM ALSO FILED AN INACCURATE FORM U5 FOR THE REGISTERED REPRESENTATIVE. SPECIFICALLY, IN RESPONSE TO A DISCLOSURE QUESTION, THE FIRM REPORTED THAT THE REGISTERED REPRESENTATIVE WAS NOT UNDER INTERNAL REVIEW AT THE TIME OF HIS TERMINATION WHEN, IN FACT, HE HAD BEEN UNDER SUCH REVIEW.

Initiated By: FINRA Date Initiated: 05/10/2012 Docket/Case Number: 2010022094901

Principal Product Type: Other Other Product Type(s): CLOSED END FUNDS Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/10/2012 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 Disgorgement/Restitution 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, FINED $200,000 AND ORDERED TO PAY PARTIAL RESTITUTION TO A CUSTOMER IN THE TOTAL AMOUNT OF $70,000. A REGISTERED PRINCIPAL ON BEHALF OF THE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION. THIS PROOF SHALL BE PROVIDED TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE THE CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN 120 DAYS FROM THE DATE THE AWC IS ACCEPTED, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA IN WRITING, THE FIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS LAST KNOWN TO HAVE RESIDED. THE FIRM SHALL PROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE ©2021 FINRA. All rights reserved. Report aboutSTATE RBC AUTHORITY. CAPITAL MARKETS, FINE LLC PAID IN FULL ON MAY 22, 2012. 299 WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED, FINED $200,000 AND ORDERED TO PAY PARTIAL RESTITUTION TO A CUSTOMER IN THE TOTAL AMOUNT OF $70,000. A REGISTERED PRINCIPAL ON BEHALF OF THE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION. THIS PROOF SHALL BE PROVIDED TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE THE CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN 120 DAYS FROM THE DATE THE AWC IS ACCEPTED, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA IN WRITING, THE FIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONED www.finra.org/brokercheck PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS LAST User Guidance KNOWN TO HAVE RESIDED. THE FIRM SHALL PROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE STATE AUTHORITY. FINE PAID IN FULL ON MAY 22, 2012. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULES 1122, 2010, NASD RULES 2110, 3010: THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE RULES AND REGULATIONS CONCERNING SHORT-TERM TRANSACTIONS IN CLOSED END FUNDS (CEFS). THE FIRM UNDERWROTE IPOS INVOLVING CEFS. NEVERTHELESS, THE FIRM DID NOT HAVE A SYSTEM AND WRITTEN PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT PATTERNS OF UNSUITABLE SHORT-TERM TRADING OF CEFS, INCLUDING THOSE PURCHASED AT THE INITIAL PUBLIC OFFERING. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES FAILED TO ADDRESS THE SUITABILITY OF RECOMMENDATIONS INVOLVING CEFS. FURTHERMORE, THE FIRM'S PROCEDURES DID NOT PROVIDE ANY GUIDANCE TO SUPERVISORS ABOUT POTENTIAL ABUSES RELATING TO SHORT-TERM TRADING SALES OF CEFS PURCHASED AT THE INITIAL PUBLIC OFFERING. AS A RESULT, THE FIRM'S SUPERVISORS LACKED ADEQUATE GUIDANCE CONCERNING POTENTIAL PROBLEMS INVOLVING CEF TRANSACTIONS. IN ADDITION, THE FIRM DID NOT UTILIZE ANY EXCEPTION REPORTS OR OTHER PROCESSES TO DETECT SHORT-TERM TRADING OF CEFS. RATHER, THE SOLE MEANS AVAILABLE TO FIRM SUPERVISORS TO IDENTIFY SUCH TRADING WAS THROUGH THE DAILY REVIEW OF TRADE BLOTTERS. GIVEN THE HUNDREDS OF POTENTIAL TRANSACTIONS SUPERVISORS WERE REQUIRED TO REVIEW DAILY, THIS WAS AN INEFFECTIVE SYSTEM. MOREOVER, THE TRADE BLOTTERS DID NOT IDENTIFY WHEN THE CEFS HAD BEEN PURCHASED OR IF THEY HAD BEEN ACQUIRED AT THE INITIAL PUBLIC OFFERING. ACCORDINGLY, FIRM SUPERVISORS HAD NO EFFECTIVE WAY TO DETERMINE HOW LONG A CEF HAD BEEN HELD BY A CUSTOMER BEFORE THE SALE. AS A RESULT OF THE FIRM'S SUPERVISORY DEFICIENCIES, THE FIRM FAILED TO TIMELY DETECT AND PREVENT A REGISTERED REPRESENTATIVE'S UNSUITABLE SHORT- TERM TRADING OF CEFS PURCHASED AT THE INITIAL PUBLIC OFFERING. THE FIRM ALSO FILED AN INACCURATE FORM U5 FOR THE REGISTERED REPRESENTATIVE. SPECIFICALLY, IN RESPONSE TO A DISCLOSURE QUESTION, THE FIRM REPORTED THAT THE REGISTERED REPRESENTATIVE WAS NOT UNDER INTERNAL REVIEW AT THE TIME OF HIS TERMINATION WHEN, IN FACT, HE HAD BEEN UNDER SUCH REVIEW. Initiated By: FINRA Date Initiated: 05/10/2012

Docket/Case Number: 2010022094901

Principal Product Type: Other Other Product Type(s): CLOSED END FUNDS Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE AND RESTITUTION Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/10/2012 Sanctions Ordered: Censure Monetary/Fine $200,000.00 Disgorgement/Restitution 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, FINED $200,000 AND ORDERED TO PAY PARTIAL RESTITUTION TO A CUSTOMER IN THE TOTAL AMOUNT OF $70,000. A REGISTERED PRINCIPAL ON BEHALF OF THE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION. THIS PROOF SHALL BE PROVIDED TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE THE CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN 120 DAYS FROM THE DATE THE AWC IS ACCEPTED, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA IN WRITING, THE FIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS LAST KNOWN TO HAVE RESIDED. THE FIRM SHALL PROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE STATE AUTHORITY. i Disclosure 130 of 336 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULE 2010, NASD RULES 2110, 3010: DURING JUNE 4, 2008 THROUGH JUNE 26, 2009, IN 234 TRANSACTIONS IN COLLATERALIZED ©2021 FINRA. All rights reserved. Report aboutMORTGAGE RBC CAPITAL OBLIGATIONS MARKETS, LLC (CMOS) WITH MOSTLY RETAIL, NON- 301 INSTITUTIONAL CUSTOMERS, THE FIRM CHARGED MARKUPS AND MARKDOWNS THAT WERE AS HIGH AS 16.9%. THESE CHARGES EXCEEDED THE FIRM'S OWN INTERNAL GUIDELINES BASED ON THE TYPE AND MATURITY OF EACH SECURITY. THE FIRM'S INTERNAL GUIDELINES WERE INTENDED TO ENSURE THAT CHARGES WERE FAIR, REASONABLE AND COMPLIANT WITH NASD RULE 2440. ACCORDING TO THE FIRM'S PROCEDURES, CHARGES EXCEEDING THE FIRM'S GUIDELINES HAD TO BE ADJUSTED IF NOT OTHERWISE JUSTIFIED IN WRITING ON THE FIRM'S ORDER RECORDS. THE FIRM'S NEXT DAY SURVEILLANCE REPORTS FLAGGED EACH OF THE 234 TRANSACTIONS AS OUTSIDE OF THE FIRM'S MARKUP/MARKDOWN POLICY THRESHOLDS. THE CHARGES WERE NOT JUSTIFIED ON THE FIRM'S ORDER RECORDS, AND ACCORDINGLY, EACH TRANSACTION WAS IDENTIFIED FOR PRICE ADJUSTMENT. HOWEVER, DUE TO MISCOMMUNICATIONS BETWEEN THE FIRM'S FIXED INCOME TRADING DESK AND TRADE SUPPORT PERSONNEL RESPONSIBLE FOR MAKING THE PRICE ADJUSTMENTS, FIRM PERSONNEL ASSUMED THAT THE MARKUPS AND MARKDOWNS ON THE TRANSACTIONS WERE ADJUSTED TO COMPLY WITH THE FIRM'S GUIDELINES. THE FIRM FAILED TO VERIFY THAT THE TRADE CORRECTIONS HAD ACTUALLY BEEN EFFECTED. ACCORDINGLY, THE FIRM DID NOT ADJUST ANY OF THE CHARGES IMPOSED ON THE FIRM'S CUSTOMERS THAT WERE FLAGGED AS EXCEEDING THE FIRM'S GUIDELINES, WHICH TOTALED $30,000, UNTIL AFTER FINRA STAFF BROUGHT THE MATTER TO THE FIRM'S ATTENTION IN OR AROUND JULY 2010. THE FIRM ALSO FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ENSURE THAT THE FIRM ONLY CHARGED CUSTOMERS MARKUPS AND MARKDOWNS ON CMO TRANSACTIONS THAT WERE FAIR, REASONABLE AND COMPLIANT WITH NASD RULE 2440. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR (1) IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR ENSURING THAT MARKUPS AND MARKDOWNS ON FIXED INCOME TRANSACTIONS THAT WERE FLAGGED AS EXCEEDING THE FIRM'S INTERNAL GUIDELINES AND DESIGNATED FOR CORRECTION WERE ACTUALLY ADJUSTED CONSISTENT WITH NASD RULE 2440; (2) A STATEMENT AS TO THE SUPERVISORY STEPS TO BE TAKEN BY THE IDENTIFIED PERSON(S) TO ENSURE THE ADJUSTMENTS WERE MADE; (3) A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED. www.finra.org/brokercheck User Guidance

Allegations: FINRA RULE 2010, NASD RULES 2110, 3010: DURING JUNE 4, 2008 THROUGH JUNE 26, 2009, IN 234 TRANSACTIONS IN COLLATERALIZED MORTGAGE OBLIGATIONS (CMOS) WITH MOSTLY RETAIL, NON- INSTITUTIONAL CUSTOMERS, THE FIRM CHARGED MARKUPS AND MARKDOWNS THAT WERE AS HIGH AS 16.9%. THESE CHARGES EXCEEDED THE FIRM'S OWN INTERNAL GUIDELINES BASED ON THE TYPE AND MATURITY OF EACH SECURITY. THE FIRM'S INTERNAL GUIDELINES WERE INTENDED TO ENSURE THAT CHARGES WERE FAIR, REASONABLE AND COMPLIANT WITH NASD RULE 2440. ACCORDING TO THE FIRM'S PROCEDURES, CHARGES EXCEEDING THE FIRM'S GUIDELINES HAD TO BE ADJUSTED IF NOT OTHERWISE JUSTIFIED IN WRITING ON THE FIRM'S ORDER RECORDS. THE FIRM'S NEXT DAY SURVEILLANCE REPORTS FLAGGED EACH OF THE 234 TRANSACTIONS AS OUTSIDE OF THE FIRM'S MARKUP/MARKDOWN POLICY THRESHOLDS. THE CHARGES WERE NOT JUSTIFIED ON THE FIRM'S ORDER RECORDS, AND ACCORDINGLY, EACH TRANSACTION WAS IDENTIFIED FOR PRICE ADJUSTMENT. HOWEVER, DUE TO MISCOMMUNICATIONS BETWEEN THE FIRM'S FIXED INCOME TRADING DESK AND TRADE SUPPORT PERSONNEL RESPONSIBLE FOR MAKING THE PRICE ADJUSTMENTS, FIRM PERSONNEL ASSUMED THAT THE MARKUPS AND MARKDOWNS ON THE TRANSACTIONS WERE ADJUSTED TO COMPLY WITH THE FIRM'S GUIDELINES. THE FIRM FAILED TO VERIFY THAT THE TRADE CORRECTIONS HAD ACTUALLY BEEN EFFECTED. ACCORDINGLY, THE FIRM DID NOT ADJUST ANY OF THE CHARGES IMPOSED ON THE FIRM'S CUSTOMERS THAT WERE FLAGGED AS EXCEEDING THE FIRM'S GUIDELINES, WHICH TOTALED $30,000, UNTIL AFTER FINRA STAFF BROUGHT THE MATTER TO THE FIRM'S ATTENTION IN OR AROUND JULY 2010. THE FIRM ALSO FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ENSURE THAT THE FIRM ONLY CHARGED CUSTOMERS MARKUPS AND MARKDOWNS ON CMO TRANSACTIONS THAT WERE FAIR, REASONABLE AND COMPLIANT WITH NASD RULE 2440. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR (1) IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR ENSURING THAT MARKUPS AND MARKDOWNS ON FIXED INCOME TRANSACTIONS THAT WERE FLAGGED AS EXCEEDING THE FIRM'S INTERNAL GUIDELINES AND DESIGNATED FOR CORRECTION WERE ACTUALLY ADJUSTED CONSISTENT WITH NASD RULE 2440; (2) A STATEMENT AS TO THE SUPERVISORY STEPS TO BE TAKEN BY THE IDENTIFIED PERSON(S) TO ENSURE THE ADJUSTMENTS WERE MADE; (3) A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED. Initiated By: FINRA Date Initiated: 01/03/2012

Docket/Case Number: 2009020904501

Principal Product Type: Other Other Product Type(s): COLLATERALIZED MORTGAGE OBLIGATIONS Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/03/2012 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 $25,000.00 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 $25,000. FINE PAID IN FULL JANUARY 17, 2012. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULE 2010, NASD RULES 2110, 3010: DURING JUNE 4, 2008 THROUGH JUNE 26, 2009, IN 234 TRANSACTIONS IN COLLATERALIZED MORTGAGE OBLIGATIONS (CMOS) WITH MOSTLY RETAIL, NON- INSTITUTIONAL CUSTOMERS, THE FIRM CHARGED MARKUPS AND MARKDOWNS THAT WERE AS HIGH AS 16.9%. THESE CHARGES EXCEEDED THE FIRM'S OWN INTERNAL GUIDELINES BASED ON THE TYPE AND MATURITY OF EACH SECURITY. THE FIRM'S INTERNAL GUIDELINES WERE INTENDED TO ENSURE THAT CHARGES WERE FAIR, REASONABLE AND COMPLIANT WITH NASD RULE 2440. ACCORDING TO THE FIRM'S PROCEDURES, CHARGES EXCEEDING THE FIRM'S GUIDELINES HAD TO BE ADJUSTED IF NOT OTHERWISE JUSTIFIED IN WRITING ON THE FIRM'S ORDER RECORDS. THE FIRM'S NEXT DAY SURVEILLANCE REPORTS FLAGGED EACH OF THE 234 TRANSACTIONS AS OUTSIDE OF THE FIRM'S ©2021 FINRA. All rights reserved. Report aboutMARKUP/MARKDOWN RBC CAPITAL MARKETS, POLICY LLC THRESHOLDS. THE CHARGES WERE NOT 303 JUSTIFIED ON THE FIRM'S ORDER RECORDS, AND ACCORDINGLY, EACH TRANSACTION WAS IDENTIFIED FOR PRICE ADJUSTMENT. HOWEVER, DUE TO MISCOMMUNICATIONS BETWEEN THE FIRM'S FIXED INCOME TRADING DESK AND TRADE SUPPORT PERSONNEL RESPONSIBLE FOR MAKING THE PRICE ADJUSTMENTS, FIRM PERSONNEL ASSUMED THAT THE MARKUPS AND MARKDOWNS ON THE TRANSACTIONS WERE ADJUSTED TO COMPLY WITH THE FIRM'S GUIDELINES. THE FIRM FAILED TO VERIFY THAT THE TRADE CORRECTIONS HAD ACTUALLY BEEN EFFECTED. ACCORDINGLY, THE FIRM DID NOT ADJUST ANY OF THE CHARGES IMPOSED ON THE FIRM'S CUSTOMERS THAT WERE FLAGGED AS EXCEEDING THE FIRM'S GUIDELINES, WHICH TOTALED $30,000, UNTIL AFTER FINRA STAFF BROUGHT THE MATTER TO THE FIRM'S ATTENTION IN OR AROUND JULY 2010. THE FIRM ALSO FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ENSURE THAT THE FIRM ONLY CHARGED CUSTOMERS MARKUPS AND MARKDOWNS ON CMO TRANSACTIONS THAT WERE FAIR, REASONABLE AND COMPLIANT WITH NASD RULE 2440. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR (1) IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR ENSURING THAT MARKUPS AND MARKDOWNS ON FIXED INCOME TRANSACTIONS THAT WERE FLAGGED AS EXCEEDING THE FIRM'S INTERNAL GUIDELINES AND DESIGNATED FOR CORRECTION WERE ACTUALLY ADJUSTED CONSISTENT WITH NASD RULE 2440; (2) A STATEMENT AS TO THE SUPERVISORY STEPS TO BE TAKEN BY THE IDENTIFIED PERSON(S) TO ENSURE THE ADJUSTMENTS WERE MADE; (3) A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED. FINRA RULE 2010, NASD RULES 2110, 3010: DURING JUNE 4, 2008 THROUGH JUNE 26, 2009, IN 234 TRANSACTIONS IN COLLATERALIZED MORTGAGE OBLIGATIONS (CMOS) WITH MOSTLY RETAIL, NON- INSTITUTIONAL CUSTOMERS, THE FIRM CHARGED MARKUPS AND MARKDOWNS THAT WERE AS HIGH AS 16.9%. THESE CHARGES EXCEEDED THE FIRM'S OWN INTERNAL GUIDELINES BASED ON THE TYPE AND MATURITY OF EACH SECURITY. THE FIRM'S INTERNAL GUIDELINES WERE INTENDED TO ENSURE THAT CHARGES WERE FAIR, REASONABLE AND www.finra.org/brokercheck COMPLIANT WITH NASD RULE 2440. ACCORDING TO THE FIRM'S User Guidance PROCEDURES, CHARGES EXCEEDING THE FIRM'S GUIDELINES HAD TO BE ADJUSTED IF NOT OTHERWISE JUSTIFIED IN WRITING ON THE FIRM'S ORDER RECORDS. THE FIRM'S NEXT DAY SURVEILLANCE REPORTS FLAGGED EACH OF THE 234 TRANSACTIONS AS OUTSIDE OF THE FIRM'S MARKUP/MARKDOWN POLICY THRESHOLDS. THE CHARGES WERE NOT JUSTIFIED ON THE FIRM'S ORDER RECORDS, AND ACCORDINGLY, EACH TRANSACTION WAS IDENTIFIED FOR PRICE ADJUSTMENT. HOWEVER, DUE TO MISCOMMUNICATIONS BETWEEN THE FIRM'S FIXED INCOME TRADING DESK AND TRADE SUPPORT PERSONNEL RESPONSIBLE FOR MAKING THE PRICE ADJUSTMENTS, FIRM PERSONNEL ASSUMED THAT THE MARKUPS AND MARKDOWNS ON THE TRANSACTIONS WERE ADJUSTED TO COMPLY WITH THE FIRM'S GUIDELINES. THE FIRM FAILED TO VERIFY THAT THE TRADE CORRECTIONS HAD ACTUALLY BEEN EFFECTED. ACCORDINGLY, THE FIRM DID NOT ADJUST ANY OF THE CHARGES IMPOSED ON THE FIRM'S CUSTOMERS THAT WERE FLAGGED AS EXCEEDING THE FIRM'S GUIDELINES, WHICH TOTALED $30,000, UNTIL AFTER FINRA STAFF BROUGHT THE MATTER TO THE FIRM'S ATTENTION IN OR AROUND JULY 2010. THE FIRM ALSO FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ENSURE THAT THE FIRM ONLY CHARGED CUSTOMERS MARKUPS AND MARKDOWNS ON CMO TRANSACTIONS THAT WERE FAIR, REASONABLE AND COMPLIANT WITH NASD RULE 2440. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR (1) IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR ENSURING THAT MARKUPS AND MARKDOWNS ON FIXED INCOME TRANSACTIONS THAT WERE FLAGGED AS EXCEEDING THE FIRM'S INTERNAL GUIDELINES AND DESIGNATED FOR CORRECTION WERE ACTUALLY ADJUSTED CONSISTENT WITH NASD RULE 2440; (2) A STATEMENT AS TO THE SUPERVISORY STEPS TO BE TAKEN BY THE IDENTIFIED PERSON(S) TO ENSURE THE ADJUSTMENTS WERE MADE; (3) A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED. Initiated By: FINRA Date Initiated: 01/03/2012 Docket/Case Number: 2009020904501

Principal Product Type: Other Other Product Type(s): COLLATERALIZED MORTGAGE OBLIGATIONS 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: 01/03/2012 Sanctions Ordered: Censure Monetary/Fine $25,000.00 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 $25,000. i Disclosure 131 of 336 Reporting Source: Regulator Current Status: Final Allegations: SEC RULE 17A-3, FINRA RULES 2010, 6622(A), 6730, 6730(A), 6730(B), 6730(C)(8), 7230A(D)(4), NASD RULES 2110, 2111(A), 2320, 3110, 6230(A), 6230(B), 6230(C), 6230(C)(6), 6230(C)(8),6230(E), MSRB RULES G-14, G- 14(B)(II), G-15(A)(I) - RBC CAPITAL MARKETS LLC FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)BLOCK TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF EXECUTION TIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6730(A) OR NASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010 OR NASD RULE 2110. THE FIRM FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE- ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO TRACE THE TIME OF TRADE EXECUTION IN THE CORRECT FORMAT FOR ONE TRANSACTION IN A TRACE-ELIGIBLE SECURITY. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT PRICE AND SYMBOL INDICATING WHETHER THE TRADE WAS A BUY OR SELL FOR ONE TRANSACTION IN A TRACE-ELIGIBLE SECURITY. THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS AND BLOCK PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL. THE FIRM IMPROPERLY REPORTED INFORMATION AND A TRANSACTION TO THE RTRS THAT IT SHOULD NOT HAVE; THE FIRM IMPROPERLY REPORTED MUNICIPAL SECURITIES TRANSACTIONS TO THE RTRS WHEN THE INTER-DEALER ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 305 DELIVERIES WERE "STEP OUTS" AND THUS, WERE NOT INTER-DEALER TRANSACTIONS REPORTABLE TO THE RTRS AND THE FIRM IMPROPERLY REPORTED CUSTOMER TRANSACTIONS TO THE RTRS IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTC REPORTING FACILITY (OTCRF)LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6622(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTCRF LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE TO THE OTCRF SUCH LAST SALE REPORTS AS LATE. THE FIRM FAILED TO REPORT TO THE OTCRF THE CORRECT EXECUTION TIME FOR TRANSACTIONS IN REPORTABLE SECURITIES. THE FIRM DOUBLE REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT TRADE EXECUTION TIME FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES TO TRACE IT WAS REQUIRED TO REPORT. THE FIRM FAILED TO SHOW THE CORRECT EXECUTION TIME ON BROKERAGE ORDER MEMORANDA. THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. IN 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 PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TO REPORT THE CORRECT YIELD TO THE RTRS IN REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM PROVIDED WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS AN INCORRECT YIELD IN MUNICIPAL SECURITIES TRANSACTIONS. THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE RTRS. SEC RULE 17A-3, FINRA RULES 2010, 6622(A), 6730, 6730(A), 6730(B), 6730(C)(8), 7230A(D)(4), NASD RULES 2110, 2111(A), 2320, 3110, 6230(A), 6230(B), 6230(C), 6230(C)(6), 6230(C)(8),6230(E), MSRB RULES G-14, G- 14(B)(II), G-15(A)(I) - RBC CAPITAL MARKETS LLC FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)BLOCK TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF EXECUTION TIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6730(A) OR NASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010 OR NASD RULE 2110. THE FIRM FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE- ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO TRACE THE TIME OF TRADE EXECUTION IN THE CORRECT FORMAT FOR ONE TRANSACTION IN A TRACE-ELIGIBLE SECURITY. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT PRICE AND SYMBOL INDICATING WHETHER THE TRADE WAS A BUY OR SELL FOR ONE TRANSACTION IN A TRACE-ELIGIBLE SECURITY. THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS AND BLOCK PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL; THE FIRM FAILED TO www.finra.org/brokercheck REPORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES User Guidance OF TIME OF TRADE TO AN RTRS PORTAL. THE FIRM IMPROPERLY REPORTED INFORMATION AND A TRANSACTION TO THE RTRS THAT IT SHOULD NOT HAVE; THE FIRM IMPROPERLY REPORTED MUNICIPAL SECURITIES TRANSACTIONS TO THE RTRS WHEN THE INTER-DEALER DELIVERIES WERE "STEP OUTS" AND THUS, WERE NOT INTER-DEALER TRANSACTIONS REPORTABLE TO THE RTRS AND THE FIRM IMPROPERLY REPORTED CUSTOMER TRANSACTIONS TO THE RTRS IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTC REPORTING FACILITY (OTCRF)LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6622(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTCRF LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE TO THE OTCRF SUCH LAST SALE REPORTS AS LATE. THE FIRM FAILED TO REPORT TO THE OTCRF THE CORRECT EXECUTION TIME FOR TRANSACTIONS IN REPORTABLE SECURITIES. THE FIRM DOUBLE REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT TRADE EXECUTION TIME FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES TO TRACE IT WAS REQUIRED TO REPORT. THE FIRM FAILED TO SHOW THE CORRECT EXECUTION TIME ON BROKERAGE ORDER MEMORANDA. THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. IN 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 PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TO REPORT THE CORRECT YIELD TO THE RTRS IN REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM PROVIDED WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS AN INCORRECT YIELD IN MUNICIPAL SECURITIES TRANSACTIONS. THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE RTRS. Initiated By: FINRA Date Initiated: 11/08/2011 Docket/Case Number: 2008015368701

Principal Product Type: Debt - Municipal Other Product Type(s): TRACE-ELIGIBLE SECURITIES, OTC EQUITY TRANSACTIONS, REPORTABLE SECURITIES Principal Sanction(s)/Relief Sought:

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/08/2011 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 Disgorgement/Restitution 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, FINED $125,000, OF WHICH $70,000 PERTAINS TO MSRB RULE VIOLATIONS, AND ORDERED TO PAY $241.26, PLUS INTEREST, IN RESTITUTION TO INVESTORS. 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 FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. 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. FINE PAID IN FULL DECEMBER 14, 2011. i Reporting Source: Firm Current Status: Final Allegations: SEC RULE 17A-3, FINRA RULES 2010, 6622(A), 6730, 6730(A), 6730(B), 6730(C)(8), 7230A(D)(4), NASD RULES 2110, 2111(A), 2320, 3110, 6230(A), 6230(B), 6230(C), 6230(C)(6), 6230(C)(8),6230(E), MSRB RULES G-14, G- 14(B)(II), G-15(A)(I) - RBC CAPITAL MARKETS LLC FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)BLOCK TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF EXECUTION TIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6730(A) OR NASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010 OR NASD RULE 2110. ©2021 FINRA. All rights reserved. Report aboutTHE RBC FIRM CAPITAL FAILED MARKETS, TO REPORT LLC TO TRACE TRANSACTIONS IN TRACE- 307 ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO TRACE THE TIME OF TRADE EXECUTION IN THE CORRECT FORMAT FOR ONE TRANSACTION IN A TRACE-ELIGIBLE SECURITY. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT PRICE AND SYMBOL INDICATING WHETHER THE TRADE WAS A BUY OR SELL FOR ONE TRANSACTION IN A TRACE-ELIGIBLE SECURITY. THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS AND BLOCK PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL. THE FIRM IMPROPERLY REPORTED INFORMATION AND A TRANSACTION TO THE RTRS THAT IT SHOULD NOT HAVE; THE FIRM IMPROPERLY REPORTED MUNICIPAL SECURITIES TRANSACTIONS TO THE RTRS WHEN THE INTER-DEALER DELIVERIES WERE "STEP OUTS" AND THUS, WERE NOT INTER-DEALER TRANSACTIONS REPORTABLE TO THE RTRS AND THE FIRM IMPROPERLY REPORTED CUSTOMER TRANSACTIONS TO THE RTRS IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTC REPORTING FACILITY (OTCRF)LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6622(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTCRF LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE TO THE OTCRF SUCH LAST SALE REPORTS AS LATE. THE FIRM FAILED TO REPORT TO THE OTCRF THE CORRECT EXECUTION TIME FOR TRANSACTIONS IN REPORTABLE SECURITIES. THE FIRM DOUBLE REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT TRADE EXECUTION TIME FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES TO TRACE IT WAS REQUIRED TO REPORT. THE FIRM FAILED TO SHOW THE CORRECT EXECUTION TIME ON BROKERAGE ORDER MEMORANDA. THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. IN 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 PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TO REPORT THE CORRECT YIELD TO THE RTRS IN REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM PROVIDED WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS AN INCORRECT YIELD IN MUNICIPAL SECURITIES TRANSACTIONS. THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE RTRS. SEC RULE 17A-3, FINRA RULES 2010, 6622(A), 6730, 6730(A), 6730(B), 6730(C)(8), 7230A(D)(4), NASD RULES 2110, 2111(A), 2320, 3110, 6230(A), 6230(B), 6230(C), 6230(C)(6), 6230(C)(8),6230(E), MSRB RULES G-14, G- 14(B)(II), G-15(A)(I) - RBC CAPITAL MARKETS LLC FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)BLOCK TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF www.finra.org/brokercheck EXECUTION TIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT User Guidance VIOLATIONS OF FINRA RULE 6730(A) OR NASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010 OR NASD RULE 2110. THE FIRM FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE- ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO TRACE THE TIME OF TRADE EXECUTION IN THE CORRECT FORMAT FOR ONE TRANSACTION IN A TRACE-ELIGIBLE SECURITY. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT PRICE AND SYMBOL INDICATING WHETHER THE TRADE WAS A BUY OR SELL FOR ONE TRANSACTION IN A TRACE-ELIGIBLE SECURITY. THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS AND BLOCK PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL. THE FIRM IMPROPERLY REPORTED INFORMATION AND A TRANSACTION TO THE RTRS THAT IT SHOULD NOT HAVE; THE FIRM IMPROPERLY REPORTED MUNICIPAL SECURITIES TRANSACTIONS TO THE RTRS WHEN THE INTER-DEALER DELIVERIES WERE "STEP OUTS" AND THUS, WERE NOT INTER-DEALER TRANSACTIONS REPORTABLE TO THE RTRS AND THE FIRM IMPROPERLY REPORTED CUSTOMER TRANSACTIONS TO THE RTRS IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTC REPORTING FACILITY (OTCRF)LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6622(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTCRF LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE TO THE OTCRF SUCH LAST SALE REPORTS AS LATE. THE FIRM FAILED TO REPORT TO THE OTCRF THE CORRECT EXECUTION TIME FOR TRANSACTIONS IN REPORTABLE SECURITIES. THE FIRM DOUBLE REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT TRADE EXECUTION TIME FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES TO TRACE IT WAS REQUIRED TO REPORT. THE FIRM FAILED TO SHOW THE CORRECT EXECUTION TIME ON BROKERAGE ORDER MEMORANDA. THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. IN 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 ©2021 FINRA. All rights reserved. Report aboutTHE RBC RESULTANT CAPITAL MARKETS, PRICE LLCTO ITS CUSTOMER WAS AS FAVORABLE AS 308 POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TO REPORT THE CORRECT YIELD TO THE RTRS IN REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM PROVIDED WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS AN INCORRECT YIELD IN MUNICIPAL SECURITIES TRANSACTIONS. THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE RTRS. SEC RULE 17A-3, FINRA RULES 2010, 6622(A), 6730, 6730(A), 6730(B), 6730(C)(8), 7230A(D)(4), NASD RULES 2110, 2111(A), 2320, 3110, 6230(A), 6230(B), 6230(C), 6230(C)(6), 6230(C)(8),6230(E), MSRB RULES G-14, G- 14(B)(II), G-15(A)(I) - RBC CAPITAL MARKETS LLC FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)BLOCK TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF EXECUTION TIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6730(A) OR NASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010 OR NASD RULE 2110. THE FIRM FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE- ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO TRACE THE TIME OF TRADE EXECUTION IN THE CORRECT FORMAT FOR ONE TRANSACTION IN A TRACE-ELIGIBLE SECURITY. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT PRICE AND SYMBOL INDICATING WHETHER THE TRADE WAS A BUY OR SELL FOR ONE TRANSACTION IN A TRACE-ELIGIBLE SECURITY. THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS AND BLOCK PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL. THE FIRM IMPROPERLY REPORTED INFORMATION AND A TRANSACTION TO THE RTRS THAT IT SHOULD NOT HAVE; THE FIRM IMPROPERLY REPORTED MUNICIPAL SECURITIES TRANSACTIONS TO THE RTRS WHEN THE INTER-DEALER DELIVERIES WERE "STEP OUTS" AND THUS, WERE NOT INTER-DEALER TRANSACTIONS REPORTABLE TO THE RTRS AND THE FIRM IMPROPERLY REPORTED CUSTOMER TRANSACTIONS TO THE RTRS IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTC REPORTING FACILITY (OTCRF)LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6622(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTCRF LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE TO THE OTCRF SUCH LAST SALE REPORTS AS LATE. THE FIRM FAILED TO REPORT TO THE OTCRF THE CORRECT EXECUTION TIME FOR TRANSACTIONS IN REPORTABLE SECURITIES. THE FIRM DOUBLE REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT TRADE EXECUTION TIME FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO REPORT TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES TO TRACE IT WAS REQUIRED TO REPORT. THE FIRM FAILED www.finra.org/brokercheck TO SHOW THE CORRECT EXECUTION TIME ON BROKERAGE ORDER User Guidance MEMORANDA. THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. IN 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 PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TO REPORT THE CORRECT YIELD TO THE RTRS IN REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM PROVIDED WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS AN INCORRECT YIELD IN MUNICIPAL SECURITIES TRANSACTIONS. THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE RTRS. Initiated By: FINRA Date Initiated: 11/08/2011 Docket/Case Number: 2008015368701

Principal Product Type: Debt - Municipal Other Product Type(s): TRACE-ELIGIBLE SECURITIES, OTC EQUITY TRANSACTIONS, REPORTABLE SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE AND RESTITUTION Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/08/2011 Sanctions Ordered: Censure Monetary/Fine $125,000.00 Disgorgement/Restitution 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, FINED $125,000, OF WHICH $70,000 PERTAINS TO MSRB RULE VIOLATIONS, AND ORDERED TO PAY $241.26, PLUS INTEREST, IN RESTITUTION TO INVESTORS. 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 FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. 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 Disclosure 132 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT THE FIRM MAY HAVE VIOLATED EXCHANGE RULE 27.09(A) BY FAILING TO ASSIGN UNIQUE LOGIN IDS TO THREE EMPLOYEES OF A CORPORATE AFFILIATE WHO ACCESSED THE EXCHANGE'S ELECTONIC TRADING PLATFORM THROUGH THE FIRM. Initiated By: ICE FUTURES U.S., INC. Date Initiated: 09/28/2011 Docket/Case Number: 2010-018

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 CEASE AND DESIST Sought:

Resolution: Settled Resolution Date: 09/28/2011 Sanctions Ordered: Monetary/Fine $15,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE VIOLATION OF ANY EXCHANGE RULES, THE FIRM AGREED TO PAY A FINE OF $15,000. THE FIRM ADDITIONALLY AGREED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF EXCHANGE RULE 27.09(A). i Disclosure 133 of 336 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASE 33-9262, 34-65404, IA RELEASE 3289, SEPTEMBER 27, 2011: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 310 ("SECURITIES ACT"), SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST RBC CAPITAL MARKETS, LLC ("RESPONDENT" OR "RBCCM").

THE PROCEEDINGS AROSE OUT OF THE SALE OF $200 MILLION OF CREDIT-LINKED NOTES THAT WERE TIED TO THE PERFORMANCE OF SYNTHETIC COLLATERALIZED DEBT OBLIGATIONS HOLDING A PORTFOLIO OF 100+ CREDIT DEFAULT SWAPS REFERENCING CORPORATE BOND OBLIGATIONS (THE "CDO INVESTMENTS"). RESPONDENT RBCCM, A U.S. BROKER-DEALER AFFILIATED WITH THE CDO INVESTMENT ARRANGER, A UK BANK, MARKETED AND SOLD THE CDO INVESTMENTS TO FIVE SCHOOL DISTRICTS IN WISCONSIN (THE "SCHOOL DISTRICTS") IN THREE SEPARATE TRANSACTIONS BETWEEN JUNE AND DECEMBER 2006.

THE COMMISSION FOUND THAT RBCCM VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT BY NEGLIGENTLY SELLING THE CDO INVESTMENTS TO THE SCHOOL DISTRICTS, DESPITE SIGNIFICANT CONCERNS WITHIN RBCCM ABOUT THE SUITABILITY OF THE PRODUCT FOR MUNICIPALITIES LIKE THE SCHOOL DISTRICTS. THESE CDO INVESTMENTS WERE UNSUITABLE FOR THE SCHOOL DISTRICTS. RBCCM'S MARKETING MATERIALS ALSO FAILED TO EXPLAIN ADEQUATELY THE RISKS ASSOCIATED WITH THE CDO INVESTMENTS. THE SCHOOL DISTRICTS LACKED SUFFICIENT KNOWLEDGE AND SOPHISTICATION TO APPRECIATE THE NATURE OF SUCH INVESTMENTS. www.finra.org/brokercheck SEC ADMIN RELEASE 33-9262, 34-65404, IA RELEASE 3289, SEPTEMBER 27, User Guidance 2011: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST RBC CAPITAL MARKETS, LLC ("RESPONDENT" OR "RBCCM").

Principal Product Type: Other Other Product Type(s): SYNTHETIC COLLATERALIZED DEBIT OBLIGATIONS Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 09/27/2011 Does the order constitute a Yes final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about RBC CAPITAL MARKETS, LLC 311 fraudulent, manipulative, or deceptive conduct? 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: Censure Monetary/Fine $22,000,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: PREJUDGMENT INTEREST Sanction Details: IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, RBCCM SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED, RBCCM CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING ADMINISTRATIVE AND CEASE- AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933, SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER (THE "ORDER"). THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT RBCCM'S OFFER. ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIES ACT, SECTION 15(B) OF THE EXCHANGE ACT, AND SECTION 203(E) OF THE ADVISERS ACT, IT IS HEREBY ORDERED THAT: A. RESPONDENT RBCCM CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. B. RESPONDENT RBCCM IS CENSURED. C. RESPONDENT RBCCM SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY DISGORGEMENT OF $6,600,000, PREJUDGMENT INTEREST OF $1,800,000, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $22,000,000. (CONTINUED IN #14) Regulator Statement (CONTINUED FROM #13C.) RBCCM SHALL SATISFY THIS OBLIGATION BY DISBURSING THE FOREGOING DISGORGEMENT AND CIVIL PENALTY PURSUANT TO THE FAIR FUND PROVISIONS OF SECTION 308(A) OF THE SARBANES-OXLEY ACT OF 2002 AS FOLLOWS: RBCCM SHALL MAKE A $12,560,898 PAYMENT TO AND FOR THE BENEFIT OF THE SCHOOL DISTRICT OF WEST ALLIS-WEST MILWAUKEE; RBCCM SHALL MAKE A $6,331,061 PAYMENT TO AND FOR THE BENEFIT OF KENOSHA SCHOOL DISTRICT NO. 1; RBCCM SHALL MAKE A $10,417,322 PAYMENT TO AND FOR ©2021 FINRA. All rights reserved. Report aboutTHE RBC BENEFIT CAPITAL OF MARKETS, THE SCHOOL LLC DISTRICT OF WAUKESHA; RESPONDENT 312 SHALL MAKE A $458,030 PAYMENT TO AND FOR THE BENEFIT OF THE KIMBERLY AREA SCHOOL DISTRICT; AND RBCCM SHALL MAKE A $632,689 PAYMENT TO AND FOR THE BENEFIT OF THE SCHOOL DISTRICT OF WHITEFISH BAY. IF TIMELY PAYMENT IS NOT MADE, ADDITIONAL INTEREST SHALL ACCRUE PURSUANT TO SEC RULE OF PRACTICE 600 OR 31 U.S.C. § 3717. PAYMENTS SHALL BE ACCOMPANIED WITH A NOTIFICATION THAT IDENTIFIES RBCCM AS THE RESPONDENT IN THESE PROCEEDINGS. RBCCM SHALL SIMULTANEOUSLY TRANSMIT A COPY OF SUCH PAYMENT AND NOTIFICATION TO ANNE MCKINLEY, ASSISTANT REGIONAL DIRECTOR, CHICAGO REGIONAL OFFICE, 175 W. JACKSON BLVD., SUITE 900, CHICAGO, IL 60604. RBCCM WILL COOPERATE WITH THE STAFF OF THE COMMISSION TO OBTAIN EVIDENCE OF RECEIPT OF THE PAYMENTS SET FORTH HEREIN. IN THE EVENT THAT RBCCM FAILS TO COMPLETE THE DISTRIBUTION UNDER THE TERMS SET FORTH IN THIS ORDER, PAYMENT OF THE FULL DISTRIBUTION AMOUNT (OR THE BALANCE THEREOF) SHALL BE DUE AND PAYABLE IMMEDIATELY TO THE COMMISSION, WITHOUT FURTHER APPLICATION. (CONTINUED FROM #13C.) RBCCM SHALL SATISFY THIS OBLIGATION BY DISBURSING THE FOREGOING DISGORGEMENT AND CIVIL PENALTY PURSUANT TO THE FAIR FUND PROVISIONS OF SECTION 308(A) OF THE www.finra.org/brokercheck SARBANES-OXLEY ACT OF 2002 AS FOLLOWS: RBCCM SHALL MAKE A User Guidance $12,560,898 PAYMENT TO AND FOR THE BENEFIT OF THE SCHOOL DISTRICT OF WEST ALLIS-WEST MILWAUKEE; RBCCM SHALL MAKE A $6,331,061 PAYMENT TO AND FOR THE BENEFIT OF KENOSHA SCHOOL DISTRICT NO. 1; RBCCM SHALL MAKE A $10,417,322 PAYMENT TO AND FOR THE BENEFIT OF THE SCHOOL DISTRICT OF WAUKESHA; RESPONDENT SHALL MAKE A $458,030 PAYMENT TO AND FOR THE BENEFIT OF THE KIMBERLY AREA SCHOOL DISTRICT; AND RBCCM SHALL MAKE A $632,689 PAYMENT TO AND FOR THE BENEFIT OF THE SCHOOL DISTRICT OF WHITEFISH BAY. IF TIMELY PAYMENT IS NOT MADE, ADDITIONAL INTEREST SHALL ACCRUE PURSUANT TO SEC RULE OF PRACTICE 600 OR 31 U.S.C. § 3717. PAYMENTS SHALL BE ACCOMPANIED WITH A NOTIFICATION THAT IDENTIFIES RBCCM AS THE RESPONDENT IN THESE PROCEEDINGS. RBCCM SHALL SIMULTANEOUSLY TRANSMIT A COPY OF SUCH PAYMENT AND NOTIFICATION TO ANNE MCKINLEY, ASSISTANT REGIONAL DIRECTOR, CHICAGO REGIONAL OFFICE, 175 W. JACKSON BLVD., SUITE 900, CHICAGO, IL 60604. RBCCM WILL COOPERATE WITH THE STAFF OF THE COMMISSION TO OBTAIN EVIDENCE OF RECEIPT OF THE PAYMENTS SET FORTH HEREIN. IN THE EVENT THAT RBCCM FAILS TO COMPLETE THE DISTRIBUTION UNDER THE TERMS SET FORTH IN THIS ORDER, PAYMENT OF THE FULL DISTRIBUTION AMOUNT (OR THE BALANCE THEREOF) SHALL BE DUE AND PAYABLE IMMEDIATELY TO THE COMMISSION, WITHOUT FURTHER APPLICATION. i Reporting Source: Firm Current Status: Final Allegations: SEC ADMIN RELEASE 33-9262, 34-65404, IA RELEASE 3289, SEPTEMBER 27, 2011: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST RBC CAPITAL MARKETS, LLC ("RESPONDENT" OR "RBCCM"). THE PROCEEDINGS AROSE OUT OF THE SALE OF $200 MILLION OF CREDIT-LINKED NOTES THAT WERE TIED TO THE PERFORMANCE OF SYNTHETIC COLLATERALIZED DEBT OBLIGATIONS HOLDING A PORTFOLIO OF 100+ CREDIT DEFAULT SWAPS REFERENCING CORPORATE BOND OBLIGATIONS (THE "CDO INVESTMENTS"). RESPONDENT RBCCM, A U.S. BROKER-DEALER AFFILIATED WITH THE CDO INVESTMENT ARRANGER, A UK BANK, MARKETED AND SOLD THE CDO INVESTMENTS TO FIVE SCHOOL DISTRICTS IN WISCONSIN (THE "SCHOOL DISTRICTS") IN THREE SEPARATE TRANSACTIONS BETWEEN JUNE AND DECEMBER 2006. THE COMMISSION FOUND THAT RBCCM VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT BY NEGLIGENTLY SELLING THE CDO INVESTMENTS TO THE SCHOOL DISTRICTS, DESPITE SIGNIFICANT CONCERNS WITHIN RBCCM ABOUT THE SUITABILITY OF THE PRODUCT FOR MUNICIPALITIES ©2021 FINRA. All rights reserved. Report aboutLIKE RBC THE CAPITAL SCHOOL MARKETS, DISTRICTS. LLC THESE CDO INVESTMENTS WERE 313 UNSUITABLE FOR THE SCHOOL DISTRICTS. RBCCM'S MARKETING MATERIALS ALSO FAILED TO EXPLAIN ADEQUATELY THE RISKS ASSOCIATED WITH THE CDO INVESTMENTS. THE SCHOOL DISTRICTS LACKED SUFFICIENT KNOWLEDGE AND SOPHISTICATION TO APPRECIATE THE NATURE OF SUCH INVESTMENTS. SEC ADMIN RELEASE 33-9262, 34-65404, IA RELEASE 3289, SEPTEMBER 27, 2011: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST RBC CAPITAL MARKETS, LLC ("RESPONDENT" OR "RBCCM"). THE PROCEEDINGS AROSE OUT OF THE SALE OF $200 MILLION OF CREDIT-LINKED NOTES THAT WERE TIED TO THE PERFORMANCE OF SYNTHETIC COLLATERALIZED DEBT OBLIGATIONS HOLDING A PORTFOLIO OF 100+ CREDIT DEFAULT SWAPS REFERENCING CORPORATE BOND OBLIGATIONS (THE "CDO INVESTMENTS"). RESPONDENT RBCCM, A U.S. BROKER-DEALER AFFILIATED WITH THE CDO INVESTMENT ARRANGER, A UK BANK, MARKETED AND SOLD THE CDO INVESTMENTS TO FIVE SCHOOL DISTRICTS IN WISCONSIN (THE "SCHOOL DISTRICTS") IN THREE SEPARATE www.finra.org/brokercheck TRANSACTIONS BETWEEN JUNE AND DECEMBER 2006. THE COMMISSION User Guidance FOUND THAT RBCCM VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT BY NEGLIGENTLY SELLING THE CDO INVESTMENTS TO THE SCHOOL DISTRICTS, DESPITE SIGNIFICANT CONCERNS WITHIN RBCCM ABOUT THE SUITABILITY OF THE PRODUCT FOR MUNICIPALITIES LIKE THE SCHOOL DISTRICTS. THESE CDO INVESTMENTS WERE UNSUITABLE FOR THE SCHOOL DISTRICTS. RBCCM'S MARKETING MATERIALS ALSO FAILED TO EXPLAIN ADEQUATELY THE RISKS ASSOCIATED WITH THE CDO INVESTMENTS. THE SCHOOL DISTRICTS LACKED SUFFICIENT KNOWLEDGE AND SOPHISTICATION TO APPRECIATE THE NATURE OF SUCH INVESTMENTS. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/27/2011 Docket/Case Number: 3-14564

Principal Product Type: Other Other Product Type(s): SYNTHETIC COLLATERALIZED DEBIT OBLIGATIONS Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CENSURE, DISGORGEMENT AND CIVIL FINE Sought:

Resolution: Order Resolution Date: 09/27/2011 Sanctions Ordered: Censure Monetary/Fine $22,000,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: PREJUDGMENT INTEREST Sanction Details: IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, RBCCM SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED, RBCCM CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING ADMINISTRATIVE AND CEASE- AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933, SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER (THE "ORDER"). THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT RBCCM'S OFFER. ACCORDINGLY, PURSUANT ©2021 FINRA. All rights reserved. Report aboutTO SECTION RBC CAPITAL 8A MARKETS, OF THE LLCSECURITIES ACT, SECTION 15(B) OF THE 314 EXCHANGE ACT, AND SECTION 203(E) OF THE ADVISERS ACT, IT IS HEREBY ORDERED THAT: A. RESPONDENT RBCCM CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. B. RESPONDENT RBCCM IS CENSURED. C. RESPONDENT RBCCM SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY DISGORGEMENT OF $6,600,000, PREJUDGMENT INTEREST OF $1,800,000, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $22,000,000. (CONTINUED IN #13) IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, RBCCM SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED, RBCCM CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING ADMINISTRATIVE AND CEASE- AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933, SECTION 15(B) OF THE SECURITIES EXCHANGE www.finra.org/brokercheck ACT OF 1934, AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF User Guidance 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER (THE "ORDER"). THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT RBCCM'S OFFER. ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIES ACT, SECTION 15(B) OF THE EXCHANGE ACT, AND SECTION 203(E) OF THE ADVISERS ACT, IT IS HEREBY ORDERED THAT: A. RESPONDENT RBCCM CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. B. RESPONDENT RBCCM IS CENSURED. C. RESPONDENT RBCCM SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY DISGORGEMENT OF $6,600,000, PREJUDGMENT INTEREST OF $1,800,000, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $22,000,000. (CONTINUED IN #13) Firm Statement (CONTINUED FROM #12C.) RBCCM SHALL SATISFY THIS OBLIGATION BY DISBURSING THE FOREGOING DISGORGEMENT AND CIVIL PENALTY PURSUANT TO THE FAIR FUND PROVISIONS OF SECTION 308(A) OF THE SARBANES-OXLEY ACT OF 2002 AS FOLLOWS: RBCCM SHALL MAKE A $12,560,898 PAYMENT TO AND FOR THE BENEFIT OF THE SCHOOL DISTRICT OF WEST ALLIS-WEST MILWAUKEE; RBCCM SHALL MAKE A $6,331,061 PAYMENT TO AND FOR THE BENEFIT OF KENOSHA SCHOOL DISTRICT NO. 1; RBCCM SHALL MAKE A $10,417,322 PAYMENT TO AND FOR THE BENEFIT OF THE SCHOOL DISTRICT OF WAUKESHA; RESPONDENT SHALL MAKE A $458,030 PAYMENT TO AND FOR THE BENEFIT OF THE KIMBERLY AREA SCHOOL DISTRICT; AND RBCCM SHALL MAKE A $632,689 PAYMENT TO AND FOR THE BENEFIT OF THE SCHOOL DISTRICT OF WHITEFISH BAY. IF TIMELY PAYMENT IS NOT MADE, ADDITIONAL INTEREST SHALL ACCRUE PURSUANT TO SEC RULE OF PRACTICE 600 OR 31 U.S.C. § 3717. PAYMENTS SHALL BE ACCOMPANIED WITH A NOTIFICATION THAT IDENTIFIES RBCCM AS THE RESPONDENT IN THESE PROCEEDINGS. RBCCM SHALL SIMULTANEOUSLY TRANSMIT A COPY OF SUCH PAYMENT AND NOTIFICATION TO ANNE MCKINLEY, ASSISTANT REGIONAL DIRECTOR, CHICAGO REGIONAL OFFICE, 175 W. JACKSON BLVD., SUITE 900, CHICAGO, IL 60604. RBCCM WILL COOPERATE WITH THE STAFF OF THE COMMISSION TO OBTAIN EVIDENCE OF RECEIPT OF THE PAYMENTS SET FORTH HEREIN. IN THE EVENT THAT RBCCM FAILS TO COMPLETE THE DISTRIBUTION UNDER THE TERMS SET FORTH IN THIS ORDER, PAYMENT OF THE FULL DISTRIBUTION AMOUNT (OR THE BALANCE THEREOF) SHALL BE DUE AND PAYABLE IMMEDIATELY TO THE COMMISSION, WITHOUT FURTHER APPLICATION. i Disclosure 134 of 336 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULES G-17 AND G-30(A): IN SEVERAL TRANSACTIONS, THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ©2021 FINRA. All rights reserved. Report aboutACCOUNT RBC CAPITAL TO A MARKETS, CUSTOMER LLC AT AN AGGREGATE PRICE (INCLUDING ANY 315 MARK-DOWN OR MARK-UP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. www.finra.org/brokercheck User Guidance

MSRB RULES G-17 AND G-30(A): IN SEVERAL TRANSACTIONS, THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARK-DOWN OR MARK-UP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. Initiated By: FINRA Date Initiated: 08/25/2011 Docket/Case Number: 2008013634901

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/25/2011 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 FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED $95,000 (COMPOSING OF A $30,000 FINE FOR THE FAIR PRICE VIOLATION IN 20080136349; AND A $65,000 FINE FOR THE MUNICIPAL FAIR PRICING VIOLATIONS IN 20090181039); AND RESTITUTION OWED TO INVESTORS IN THE AMOUNT OF $32,913.50, PLUS INTEREST AT A RATE SET FORTH IN SECTION 6621(A) ©2021 FINRA. All rights reserved. Report aboutOF THE RBC CAPITALINTERNAL MARKETS, REVENUE LLC CODE, 26 U.S.C. 6621(A)(2), FROM THE DATE 316 OF THE VIOLATIVE CONDUCT UNTIL THE DATE THE AWC IS ACCEPTED BY THE NAC. THE OVERALL AMOUNT OF RESTITUTION WAS $43,157, OF WHICH THE FIRM ALREADY PAID $10,243.50. 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 FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. IF FOR ANY REASON, RESPONDENT CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, OR SUCH ADDITIONAL PERIOD AS AGREED BY FINRA, 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 IS KNOWN TO HAVE LAST RESIDED. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, www.finra.org/brokercheck THEREFORE THE FIRM IS CENSURED AND FINED $95,000 (COMPOSING OF User Guidance A $30,000 FINE FOR THE FAIR PRICE VIOLATION IN 20080136349; AND A $65,000 FINE FOR THE MUNICIPAL FAIR PRICING VIOLATIONS IN 20090181039); AND RESTITUTION OWED TO INVESTORS IN THE AMOUNT OF $32,913.50, PLUS INTEREST AT A RATE SET FORTH IN SECTION 6621(A) OF THE INTERNAL REVENUE CODE, 26 U.S.C. 6621(A)(2), FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THE DATE THE AWC IS ACCEPTED BY THE NAC. THE OVERALL AMOUNT OF RESTITUTION WAS $43,157, OF WHICH THE FIRM ALREADY PAID $10,243.50. 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 FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. IF FOR ANY REASON, RESPONDENT CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, OR SUCH ADDITIONAL PERIOD AS AGREED BY FINRA, 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 IS KNOWN TO HAVE LAST RESIDED. i Reporting Source: Firm Current Status: Final Allegations: MSRB RULES G-17 AND G-30(A): IN SEVERAL TRANSACTIONS, THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARK-DOWN OR MARK-UP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. Initiated By: FINRA Date Initiated: 08/25/2011 Docket/Case Number: 20080136349-01

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 & RESTITUTION ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 317 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief CENSURE & RESTITUTION Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/25/2011 Sanctions Ordered: Censure Monetary/Fine $95,000.00 Disgorgement/Restitution 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 $95,000 (COMPOSING OF A $30,000 FINE FOR THE FAIR PRICE VIOLATION IN 20080136349; AND A $65,000 FINE FOR THE MUNICIPAL FAIR PRICING VIOLATIONS IN 20090181039); AND RESTITUTION OWED TO INVESTORS IN THE AMOUNT OF $32,913.50, PLUS INTEREST AT A RATE SET FORTH IN SECTION 6621(A) OF THE INTERNAL REVENUE CODE, 26 U.S.C. 6621(A)(2), FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THE DATE THE AWC IS ACCEPTED BY THE NAC. THE OVERALL AMOUNT OF RESTITUTION WAS $43,157, OF WHICH THE FIRM ALREADY PAID $10,243.50. 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 FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. IF FOR ANY REASON, RESPONDENT CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, OR SUCH ADDITIONAL PERIOD AS AGREED BY FINRA, 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 IS KNOWN TO HAVE LAST RESIDED. i Disclosure 135 of 336 Reporting Source: Regulator Current Status: Final Allegations: THE MASSACHUSETTS SECURITIES DIVISION ALLEGED THAT RBC CAPITAL MARKETS, LLC MADE UNSUITABLE RECOMMENDATIONS TO BROKERAGE AND ADVISORY CLIENTS REGARDING THE PURCHASE AND SALE OF LEVERAGED, INVERSE AND INVERSE-LEVERAGED EXCHANGE TRADED FUNDS AND THAT RBC CAPITAL MARKETS, LLC FAILED TO SUPERVISE THE SALE OF THESE PRODUCTS. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 318 www.finra.org/brokercheck User Guidance

Initiated By: MASSACHUSETTS SECURITIES DIVISION Date Initiated: 07/20/2011 Docket/Case Number: E-2009-0059, E-2011-0001&E-2011-0037 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): LEVERAGED, INVERSE, AND INVERSE-LEVERAGED EXCHANGE TRADED FUNDS Principal Sanction(s)/Relief Restitution Sought: Other Sanction(s)/Relief PERMANENTLY CEASE AND DESIST, ADMINISTRATIVE FINE AND ANY Sought: OTHER ACTION THAT A HEARING OFFICER MAY DEEM APPROPRIATE.

Resolution: Consent Resolution Date: 05/02/2012 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 $3,150,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: RBC IS TO PAY A FINE OF $250,000.00 USD AND TO OFFER RESTITUTION OF APPROXIAMATELY $2,900,000.00 TO CERTAIN CLIENTS i Reporting Source: Firm Current Status: Final Allegations: THE MASSACHUSETTS SECURITIES DIVISION ALLEGED THAT RBC CAPITAL MARKETS, LLC MADE UNSUITABLE RECOMMENDATIONS TO BROKERAGE AND ADVISORY CLIENTS REGARDING THE PURCHASE AND SALE OF LEVERAGED, INVERSE AND INVERSE-LEVERAGED EXCHANGE TRADED FUNDS AND THAT RBC CAPITAL MARKETS, LLC FAILED TO SUPERVISE THE SALE OF THESE PRODUCTS. Initiated By: MASSACHUSETTS SECURITIES DIVISION Date Initiated: 07/20/2011

Docket/Case Number: E-2009-0059 , E-2011-0001 & E-2011-0037

Principal Product Type: Other Other Product Type(s): LEVERAGED, INVERSE, AND INVERSE-LEVERAGED EXCHANGE TRADED FUNDS Principal Sanction(s)/Relief Restitution Sought: Other Sanction(s)/Relief PERMANENTLY CEASE AND DESIST, ADMINISTRATIVE FINE AND ANY Sought: OTHER ACTION THAT A HEARING OFFICER MAY DEEM APPROPRIATE.

Resolution: Consent Resolution Date: 05/02/2012 Sanctions Ordered: Monetary/Fine $250,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: RBC IS TO PAY A FINE OF $250,000.00 USD AND TO OFFER RESTITUTION OF APPROXIMATELY $2,900,000.00 TO CERTAIN CLIENTS. i Disclosure 136 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF GEORGIA COMMISSIONER OF SECURITIES Date Initiated: 07/07/2011 Docket/Case Number: ENSC-110031

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

Resolution: Consent

Resolution Date: 07/07/2011 Sanctions Ordered: Monetary/Fine $623,323.34 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF SECTIONS 10-5-12(A)(1), 10-5-12(A)(2)(B), 10-5-12(H)(2) AND 10-5-4(A)(11) OF THE GEORGIA SECURITIES ACT OF 1973 AND RULES 590-4-2-.07 AND 590-4-2-.14(1) OF THE COMMISSIONER'S RULES. THE FIRM ALSO REIMBURSED THE COMMISSIONER FOR ITS INVESTIGATIVE COSTS IN THE AMOUNT OF $10,000.00. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 137 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF MARYLAND SECURITIES DIVISION Date Initiated: 03/31/2011 Docket/Case Number: 2009-0262

Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Undertaking Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 321 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/31/2011 Sanctions Ordered: Monetary/Fine $47,920.68 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATING THE MARYLAND SECURITIES ACT. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 138 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: DISTRICT OF COLUMBIA DEPARTMENT OF INSURANCE, SECURITIES & BANKING Date Initiated: 02/23/2011 Docket/Case Number: SB-CO-03-11

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

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 02/23/2011 Sanctions Ordered: Monetary/Fine $38,232.02 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF D.C. OFFICIAL CODE 31-5602.07(A)(9) AND 31-5602. 07(A)(12). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 139 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: ALASKA DIVISION OF BANKING AND SECURITIES Date Initiated: 11/23/2010 Docket/Case Number: 10-16-S

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

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 11/23/2010 Sanctions Ordered: Monetary/Fine $19,646.58 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF ALASKA STATUTES 45.55.060(A)(7) AND 45.55. 060(B)(1). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 140 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 2310, 3010(A), 3010(B): FERRIS, BAKER WATTS, INC.'S (FBW) (N/K/A RBC CAPITAL MARKETS CORPORATION) FAILED TO HAVE ADEQUATE WRITTEN SUPERVISORY PROCEDURES GOVERNING THE SALES OF REVERSE CONVERTIBLE NOTES ("REVERSE CONVERTIBLES" OR "RCNS") AND TO REASONABLY SUPERVISE CERTAIN ACCOUNTS THAT PURCHASED RCNS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE IN THAT THEY DID NOT SET FORTH STANDARDS DESIGNED TO ENSURE THAT REVERSE CONVERTIBLE WERE ONLY SOLD TO CUSTOMERS FOR WHOM THE RISKS OF LOSING PRINCIPAL AND ILLIQUIDITY DURING THE TERM OF THE REVERSE CONVERTIBLE WERE APPROPRIATE. DURING THE PERIOD JANUARY 2006 TO JULY 2008, FBW DID NOT CONDUCT REVIEWS OF ACCOUNTS THAT HELD REVERSE CONVERTIBLES AT EITHER THE BRANCH OFFICE MANAGER LEVEL OR COMPLIANCE OFFICE LEVEL FOR OVERCONCENTRATION IN REVERSE CONVERTIBLES OR CONDUCT REASONABLE REVIEWS FOR SUITABILITY ©2021 FINRA. All rights reserved. Report aboutCOMPATIBILITY RBC CAPITAL MARKETS, WITH CERTAIN LLC CUSTOMER PROFILES, SUCH AS AGE AND 324 NET WORTH. FBW ALSO DID NOT HAVE REASONABLE GROUNDS TO BELIEVE THAT THE RECOMMENDED SALES OF REVERSE CONVERTIBLES WERE SUITABLE FOR 57 ACCOUNTS HELD BY CUSTOMERS 85 YEARS OLD AND OLDER OR CUSTOMERS WHO HAD A STATED NET WORTH OF UNDER $50,000 (AMONG APPROXIMATELY 2,000 FBW ACCOUNTS IN WHICH REVERSE CONVERTIBLES WERE PURCHASED DURING THE RELEVANT PERIOD). SALES OF REVERSE CONVERTIBLES EXPOSED THESE 57 ACCOUNTS TO RISK OF LOSS THAT WAS INCONSISTENT WITH THEIR INVESTMENT OBJECTIVES, RISK TOLERANCE, AGE, NET WORTH, OR INVESTMENT EXPERIENCE. SOME OF THE ACCOUNTS WERE ALSO OVER- CONCENTRATED IN REVERSE CONVERTIBLES RELATIVE TO THE PERCENTAGE OF ASSETS IN THE ACCOUNTS. THESE CUSTOMERS SUFFERED NET LOSSES AS A RESULT OF INVESTING IN REVERSE CONVERTIBLES.THE FIRM'S WRITTEN SUPERVISORY PROCEDURES RELATING TO STRUCTURED PRODUCTS, INCLUDING REVERSE CONVERTIBLES, SPECIFICALLY STATED THAT "THE FIRM HAS DETERMINED THAT RECOMMENDATIONS AND/OR PURCHASES OF THE PRODUCT WILL NOT BE LIMITED TO ONLY PERSONS WHO HAVE APPROVED OPTIONS ACCOUNTS." THE FIRM'S WRITTEN PROCEDURES FURTHER STATED THAT "FBW WILL PREPARE A DOCUMENT THAT OUTLINES WHAT STANDARDS OF CUSTOMER-SPECIFIC SUITABILITY MUST BE USED IN RECOMMENDING SUCH PRODUCTS. THE FIRM NEVER PROMULGATED SUCH PROCEDURES. FURTHERMORE, REVIEW OF ACCOUNTS THAT PURCHASED REVERSE CONVERTIBLES WAS THE RESPONSIBILITY OF BRANCH OFFICE MANAGERS WITHOUT THE AID OF COMPLIANCE REPORTS SUCH AS ADEQUATE OVERCONCENTRATION REPORTS OR REPORTS THAT HIGHLIGHTED PURCHASES BY SENIORS OR CUSTOMERS WITH MODEST NET WORTH. SPECIFICALLY, BRANCH MANAGERS CONDUCTED A SPOT CHECK OF DAILY BLOTTERS, BUT THE FIRM DID NOT GIVE BRANCH MANAGERS ANY GUIDANCE OR TOOLS TO DETERMINE SUITABILITY AND WHETHER A CUSTOMER WAS OVER-CONCENTRATED IN THIS PARTICULAR PRODUCT. FOR THIS REASON, THE FIRM'S PROCEDURES WERE INADEQUATE. NASD RULES 2110, 2310, 3010(A), 3010(B): FERRIS, BAKER WATTS, INC.'S (FBW) (N/K/A RBC CAPITAL MARKETS CORPORATION) FAILED TO HAVE ADEQUATE WRITTEN SUPERVISORY PROCEDURES GOVERNING THE SALES OF REVERSE CONVERTIBLE NOTES ("REVERSE CONVERTIBLES" OR "RCNS") AND TO REASONABLY SUPERVISE CERTAIN ACCOUNTS THAT PURCHASED RCNS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE IN THAT THEY DID NOT SET FORTH STANDARDS DESIGNED TO ENSURE THAT REVERSE CONVERTIBLE WERE ONLY SOLD TO CUSTOMERS FOR WHOM THE RISKS OF LOSING PRINCIPAL AND ILLIQUIDITY DURING THE TERM OF THE REVERSE CONVERTIBLE WERE www.finra.org/brokercheck APPROPRIATE. DURING THE PERIOD JANUARY 2006 TO JULY 2008, FBW User Guidance DID NOT CONDUCT REVIEWS OF ACCOUNTS THAT HELD REVERSE CONVERTIBLES AT EITHER THE BRANCH OFFICE MANAGER LEVEL OR COMPLIANCE OFFICE LEVEL FOR OVERCONCENTRATION IN REVERSE CONVERTIBLES OR CONDUCT REASONABLE REVIEWS FOR SUITABILITY COMPATIBILITY WITH CERTAIN CUSTOMER PROFILES, SUCH AS AGE AND NET WORTH. FBW ALSO DID NOT HAVE REASONABLE GROUNDS TO BELIEVE THAT THE RECOMMENDED SALES OF REVERSE CONVERTIBLES WERE SUITABLE FOR 57 ACCOUNTS HELD BY CUSTOMERS 85 YEARS OLD AND OLDER OR CUSTOMERS WHO HAD A STATED NET WORTH OF UNDER $50,000 (AMONG APPROXIMATELY 2,000 FBW ACCOUNTS IN WHICH REVERSE CONVERTIBLES WERE PURCHASED DURING THE RELEVANT PERIOD). SALES OF REVERSE CONVERTIBLES EXPOSED THESE 57 ACCOUNTS TO RISK OF LOSS THAT WAS INCONSISTENT WITH THEIR INVESTMENT OBJECTIVES, RISK TOLERANCE, AGE, NET WORTH, OR INVESTMENT EXPERIENCE. SOME OF THE ACCOUNTS WERE ALSO OVER- CONCENTRATED IN REVERSE CONVERTIBLES RELATIVE TO THE PERCENTAGE OF ASSETS IN THE ACCOUNTS. THESE CUSTOMERS SUFFERED NET LOSSES AS A RESULT OF INVESTING IN REVERSE CONVERTIBLES.THE FIRM'S WRITTEN SUPERVISORY PROCEDURES RELATING TO STRUCTURED PRODUCTS, INCLUDING REVERSE CONVERTIBLES, SPECIFICALLY STATED THAT "THE FIRM HAS DETERMINED THAT RECOMMENDATIONS AND/OR PURCHASES OF THE PRODUCT WILL NOT BE LIMITED TO ONLY PERSONS WHO HAVE APPROVED OPTIONS ACCOUNTS." THE FIRM'S WRITTEN PROCEDURES FURTHER STATED THAT "FBW WILL PREPARE A DOCUMENT THAT OUTLINES WHAT STANDARDS OF CUSTOMER-SPECIFIC SUITABILITY MUST BE USED IN RECOMMENDING SUCH PRODUCTS. THE FIRM NEVER PROMULGATED SUCH PROCEDURES. FURTHERMORE, REVIEW OF ACCOUNTS THAT PURCHASED REVERSE CONVERTIBLES WAS THE RESPONSIBILITY OF BRANCH OFFICE MANAGERS WITHOUT THE AID OF COMPLIANCE REPORTS SUCH AS ADEQUATE OVERCONCENTRATION REPORTS OR REPORTS THAT HIGHLIGHTED PURCHASES BY SENIORS OR CUSTOMERS WITH MODEST NET WORTH. SPECIFICALLY, BRANCH MANAGERS CONDUCTED A SPOT CHECK OF DAILY BLOTTERS, BUT THE FIRM DID NOT GIVE BRANCH MANAGERS ANY GUIDANCE OR TOOLS TO DETERMINE SUITABILITY AND WHETHER A CUSTOMER WAS OVER-CONCENTRATED IN THIS PARTICULAR PRODUCT. FOR THIS REASON, THE FIRM'S PROCEDURES WERE INADEQUATE. Initiated By: FINRA Date Initiated: 10/20/2010 Docket/Case Number: 2007009180301

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

Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/20/2010 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 $500,000.00 Disgorgement/Restitution 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, FINED $500,000 AND ORDERED TO PAY $189,723.22 IN RESTITUTION TO CUSTOMERS. A REGISTERED PRINCIPAL ON BEHALF OF THE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATER THAN 120 DAYS FROM ACCEPTANCE OF THE AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY CUSTOMER TO WHOM RESTITUTION IS TO BE PAID AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN 120 DAYS FROM THE DATE THE AWC IS ACCEPTED, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA STAFF IN WRITING, THE FIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS LAST KNOWN TO HAVE RESIDED. THE FIRM SHALL PROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA STAFF WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE STATE AUTHORITY. i Reporting Source: Firm Current Status: Final Allegations: NASD RULES 2110, 2310, 3010(A), 3010(B): FERRIS, BAKER WATTS, INC.'S (FBW) (N/K/A RBC CAPITAL MARKETS CORPORATION) FAILED TO HAVE ADEQUATE WRITTEN SUPERVISORY PROCEDURES GOVERNING THE SALES OF REVERSE CONVERTIBLE NOTES ("REVERSE CONVERTIBLES" ©2021 FINRA. All rights reserved. Report aboutOR "RCNS")RBC CAPITAL AND MARKETS, TO REASONABLY LLC SUPERVISE CERTAIN ACCOUNTS THAT 326 PURCHASED RCNS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE IN THAT THEY DID NOT SET FORTH STANDARDS DESIGNED TO ENSURE THAT REVERSE CONVERTIBLE WERE ONLY SOLD TO CUSTOMERS FOR WHOM THE RISKS OF LOSING PRINCIPAL AND ILLIQUIDITY DURING THE TERM OF THE REVERSE CONVERTIBLE WERE APPROPRIATE. DURING THE PERIOD JANUARY 2006 TO JULY 2008, FBW DID NOT CONDUCT REVIEWS OF ACCOUNTS THAT HELD REVERSE CONVERTIBLES AT EITHER THE BRANCH OFFICE MANAGER LEVEL OR COMPLIANCE OFFICE LEVEL FOR OVERCONCENTRATION IN REVERSE CONVERTIBLES OR CONDUCT REASONABLE REVIEWS FOR SUITABILITY COMPATIBILITY WITH CERTAIN CUSTOMER PROFILES, SUCH AS AGE AND NET WORTH. FBW ALSO DID NOT HAVE REASONABLE GROUNDS TO BELIEVE THAT THE RECOMMENDED SALES OF REVERSE CONVERTIBLES WERE SUITABLE FOR 57 ACCOUNTS HELD BY CUSTOMERS 85 YEARS OLD AND OLDER AND CUSTOMERS WHO HAD A STATED NET WORTH OF UNDER $50,000 (AMONG APPROXIMATELY 2,000 FBW ACCOUNTS IN WHICH REVERSE CONVERTIBLES WERE PURCHASED DURING THE RELEVANT PERIOD). SALES OF REVERSE CONVERTIBLES EXPOSED THESE 57 ACCOUNTS TO RISK OF LOSS THAT WAS INCONSISTENT WITH THEIR INVESTMENT OBJECTIVES, RISK TOLERANCE, AGE, NET WORTH, AND INVESTMENT EXPERIENCE. SOME OF THE ACCOUNTS WERE ALSO OVER- CONCENTRATED IN REVERSE CONVERTIBLES RELATIVE TO THE PERCENTAGE OF ASSETS IN THE ACCOUNTS. THESE CUSTOMERS SUFFERED NET LOSSES AS A RESULT OF INVESTING IN REVERSE CONVERTIBLES.THE FIRM'S WRITTEN SUPERVISORY PROCEDURES RELATING TO STRUCTURED PRODUCTS, INCLUDING REVERSE CONVERTIBLES, SPECIFICALLY STATED THAT "THE FIRM HAS DETERMINED THAT RECOMMENDATIONS AND/OR PURCHASES OF THE PRODUCT WILL NOT BE LIMITED TO ONLY PERSONS WHO HAVE APPROVED OPTIONS ACCOUNTS." THE FIRM'S WRITTEN PROCEDURES FURTHER STATED THAT "FBW WILL PREPARE A DOCUMENT THAT OUTLINES WHAT STANDARDS OF CUSTOMER-SPECIFIC SUITABILITY MUST BE USED IN RECOMMENDING SUCH PRODUCTS. THE FIRM NEVER PROMULGATED SUCH PROCEDURES. FURTHERMORE, REVIEW OF ACCOUNTS THAT PURCHASED REVERSE CONVERTIBLES WAS THE RESPONSIBILITY OF BRANCH OFFICE MANAGERS WITHOUT THE AID OF COMPLIANCE REPORTS SUCH AS ADEQUATE OVERCONCENTRATION REPORTS OR REPORTS THAT HIGHLIGHTED PURCHASES BY SENIOR OR CUSTOMERS WITH MODEST NET WORTH. SPECIFICALLY, BRANCH MANAGERS CONDUCTED A SPOT CHECK OF DAILY BLOTTERS, BUT THE FIRM DID NOT GIVE BRANCH MANAGERS ANY GUIDANCE OR TOOLS TO DETERMINE SUITABILITY AND WHETHER A CUSTOMER WAS OVER-CONCENTRATED IN THIS PARTICULAR PRODUCT. FOR THIS REASON, THE FIRM'S PROCEDURES WERE INADEQUATE. www.finra.org/brokercheck NASD RULES 2110, 2310, 3010(A), 3010(B): FERRIS, BAKER WATTS, INC.'S User Guidance (FBW) (N/K/A RBC CAPITAL MARKETS CORPORATION) FAILED TO HAVE ADEQUATE WRITTEN SUPERVISORY PROCEDURES GOVERNING THE SALES OF REVERSE CONVERTIBLE NOTES ("REVERSE CONVERTIBLES" OR "RCNS") AND TO REASONABLY SUPERVISE CERTAIN ACCOUNTS THAT PURCHASED RCNS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE IN THAT THEY DID NOT SET FORTH STANDARDS DESIGNED TO ENSURE THAT REVERSE CONVERTIBLE WERE ONLY SOLD TO CUSTOMERS FOR WHOM THE RISKS OF LOSING PRINCIPAL AND ILLIQUIDITY DURING THE TERM OF THE REVERSE CONVERTIBLE WERE APPROPRIATE. DURING THE PERIOD JANUARY 2006 TO JULY 2008, FBW DID NOT CONDUCT REVIEWS OF ACCOUNTS THAT HELD REVERSE CONVERTIBLES AT EITHER THE BRANCH OFFICE MANAGER LEVEL OR COMPLIANCE OFFICE LEVEL FOR OVERCONCENTRATION IN REVERSE CONVERTIBLES OR CONDUCT REASONABLE REVIEWS FOR SUITABILITY COMPATIBILITY WITH CERTAIN CUSTOMER PROFILES, SUCH AS AGE AND NET WORTH. FBW ALSO DID NOT HAVE REASONABLE GROUNDS TO BELIEVE THAT THE RECOMMENDED SALES OF REVERSE CONVERTIBLES WERE SUITABLE FOR 57 ACCOUNTS HELD BY CUSTOMERS 85 YEARS OLD AND OLDER AND CUSTOMERS WHO HAD A STATED NET WORTH OF UNDER $50,000 (AMONG APPROXIMATELY 2,000 FBW ACCOUNTS IN WHICH REVERSE CONVERTIBLES WERE PURCHASED DURING THE RELEVANT PERIOD). SALES OF REVERSE CONVERTIBLES EXPOSED THESE 57 ACCOUNTS TO RISK OF LOSS THAT WAS INCONSISTENT WITH THEIR INVESTMENT OBJECTIVES, RISK TOLERANCE, AGE, NET WORTH, AND INVESTMENT EXPERIENCE. SOME OF THE ACCOUNTS WERE ALSO OVER- CONCENTRATED IN REVERSE CONVERTIBLES RELATIVE TO THE PERCENTAGE OF ASSETS IN THE ACCOUNTS. THESE CUSTOMERS SUFFERED NET LOSSES AS A RESULT OF INVESTING IN REVERSE CONVERTIBLES.THE FIRM'S WRITTEN SUPERVISORY PROCEDURES RELATING TO STRUCTURED PRODUCTS, INCLUDING REVERSE CONVERTIBLES, SPECIFICALLY STATED THAT "THE FIRM HAS DETERMINED THAT RECOMMENDATIONS AND/OR PURCHASES OF THE PRODUCT WILL NOT BE LIMITED TO ONLY PERSONS WHO HAVE APPROVED OPTIONS ACCOUNTS." THE FIRM'S WRITTEN PROCEDURES FURTHER STATED THAT "FBW WILL PREPARE A DOCUMENT THAT OUTLINES WHAT STANDARDS OF CUSTOMER-SPECIFIC SUITABILITY MUST BE USED IN RECOMMENDING SUCH PRODUCTS. THE FIRM NEVER PROMULGATED SUCH PROCEDURES. FURTHERMORE, REVIEW OF ACCOUNTS THAT PURCHASED REVERSE CONVERTIBLES WAS THE RESPONSIBILITY OF BRANCH OFFICE MANAGERS WITHOUT THE AID OF COMPLIANCE REPORTS SUCH AS ADEQUATE OVERCONCENTRATION REPORTS OR REPORTS THAT HIGHLIGHTED PURCHASES BY SENIOR OR CUSTOMERS WITH MODEST NET WORTH. SPECIFICALLY, BRANCH MANAGERS CONDUCTED A SPOT CHECK OF DAILY BLOTTERS, BUT THE FIRM DID NOT GIVE BRANCH MANAGERS ANY GUIDANCE OR TOOLS TO DETERMINE SUITABILITY AND WHETHER A CUSTOMER WAS OVER-CONCENTRATED IN THIS PARTICULAR PRODUCT. FOR THIS REASON, THE FIRM'S PROCEDURES WERE INADEQUATE. Initiated By: FINRA ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 327 www.finra.org/brokercheck User Guidance

Initiated By: FINRA Date Initiated: 10/20/2010 Docket/Case Number: 2007009180301

Principal Product Type: Other Other Product Type(s): REVERSE CONVERTIBLE NOTES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE AND RESTITUTION Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/20/2010 Sanctions Ordered: Censure Monetary/Fine $500,000.00 Disgorgement/Restitution 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, FINED $500,000 AND ORDERED TO PAY $189,723.22 IN RESTITUTION TO CUSTOMERS. A REGISTERED PRINCIPAL ON BEHALF OF THE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATER THAN 120 DAYS FROM ACCEPTANCE OF THE AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY CUSTOMER TO WHOM RESTITUTION IS TO BE PAID AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN 120 DAYS FROM THE DATE THE AWC IS ACCEPTED, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA STAFF IN WRITING, THE FIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS LAST KNOWN TO HAVE RESIDED. THE FIRM SHALL PROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA STAFF WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE STATE AUTHORITY. i Disclosure 141 of 336 Reporting Source: Firm

Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: OHIO DIVISION OF SECURITIES Date Initiated: 08/25/2010 Docket/Case Number: 10-071

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

Resolution: Consent Resolution Date: 08/25/2010 Sanctions Ordered: Monetary/Fine $141,981.34 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF ORC 1707.19(A)(4),(8) AND (9) AND OHIO ADMINISTRATIVE CODE., RULE 1301:6-3-19(A)(5) AND (B)(9). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 142 of 336 Reporting Source: Regulator

Current Status: Final Allegations: **08/09/2010**OFFER OF SETTLEMENT AND CONSENT FILED BY FINRA'S MARKET REGULATION DEPARTMENT - LEGAL SECTION, ON BEHALF OF NYSE REGULATION INC. AND PENDING. CONSENTED TO FINDINGS:FOR THE SOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING, WITHOUT ADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, RBC CAPITAL MARKETS CORPORATION STIPULATED THAT IT VIOLATED NYSE ARCA EQUITIES RULE 6.18(A) AND (C) BY FAILING TO REASONABLY SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS IN THAT THE FIRM FAILED TO IMPLEMENT ADEQUATE CONTROLS, INCLUDING A REASONABLE SYSTEM OF FOLLOW-UP AND REVIEW, DESIGNED TO DETECT AND PREVENT POTENTIALLY VIOLATIVE WASH TRADING ACTIVITY ON THE NYSE ARCA MARKETPLACE. STIPULATED SANCTION:CENSURE AND FINE IN THE AMOUNT OF $95,000. Initiated By: NYSE ARCA, INC. Date Initiated: 08/09/2010 Docket/Case Number: HBD#: 10-ARCA-02

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

Resolution: Decision Resolution Date: 09/15/2010 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 Other Sanctions Ordered: Sanction Details: **09/15/2010**HEARING BOARD DECISION 10-ARCA-02. DURING THE PERIOD OF 2007 THROUGH APRIL 30, 2008, RBC CAPITAL MARKETS ©2021 FINRA. All rights reserved. Report aboutCORPORATION RBC CAPITAL MARKETS, VIOLATED LLC NYSE ARCA EQUITIES RULES 6.18(A) AND (C) BY 330 FAILING TO REASONABLY SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS IN THAT IT FAILED TO IMPLEMENT ADEQUATE CONTROLS, INCLUDING A REASONABLE SYSTEM OF FOLLOW-UP AND REVIEW, DESIGNED TO DETECT AND PREVENT POTENTIALLY VIOLATIVE WASH TRADING ACTIVITY ON THE NYSE ARCA MARKETPLACE. CONSENTED TO A CENSURE AND $95,000.00 FINE. www.finra.org/brokercheck User Guidance

Sanction Details: **09/15/2010**HEARING BOARD DECISION 10-ARCA-02. DURING THE PERIOD OF 2007 THROUGH APRIL 30, 2008, RBC CAPITAL MARKETS CORPORATION VIOLATED NYSE ARCA EQUITIES RULES 6.18(A) AND (C) BY FAILING TO REASONABLY SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS IN THAT IT FAILED TO IMPLEMENT ADEQUATE CONTROLS, INCLUDING A REASONABLE SYSTEM OF FOLLOW-UP AND REVIEW, DESIGNED TO DETECT AND PREVENT POTENTIALLY VIOLATIVE WASH TRADING ACTIVITY ON THE NYSE ARCA MARKETPLACE. CONSENTED TO A CENSURE AND $95,000.00 FINE. Regulator Statement **09/15/2010**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY. i Reporting Source: Firm Current Status: Final Allegations: **08/09/2010**OFFER OF SETTLEMENT AND CONSENT FILED BY FINRA'S MARKET REGULATION DEPARTMENT - LEGAL SECTION, ON BEHALF OF NYSE REGULATION INC. AND PENDING. CONSENTED TO FINDINGS:FOR THE SOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING, WITHOUT ADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS, RBC CAPITAL MARKETS CORPORATION STIPULATED THAT IT VIOLATED NYSE ARCA EQUITIES RULE 6.18(A) AND (C) BY FAILING TO REASONABLY SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS IN THAT THE FIRM FAILED TO IMPLEMENT ADEQUATE CONTROLS, INCLUDING A REASONABLE SYSTEM OF FOLLOW-UP AND REVIEW, DESIGNED TO DETECT AND PREVENT POTENTIALLY VIOLATIVE WASH TRADING ACTIVITY ON THE NYSE ARCA MARKETPLACE. STIPULATED SANCTION:CENSURE AND FINE IN THE AMOUNT OF $95,000. Initiated By: NYSE ARCA, INC. Date Initiated: 08/09/2010 Docket/Case Number: HBD#: 10-ARCA-02

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: Decision Resolution Date: 09/15/2010

Sanctions Ordered: Censure Monetary/Fine $95,000.00 Other Sanctions Ordered: Sanction Details: **09/15/2010**HEARING BOARD DECISION 10-ARCA-02. DURING THE PERIOD OF 2007 THROUGH APRIL 30, 2008, RBC CAPITAL MARKETS CORPORATION VIOLATED NYSE ARCA EQUITIES RULES 6.18(A) AND (C) BY FAILING TO REASONABLY SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS IN THAT IT FAILED TO IMPLEMENT ADEQUATE CONTROLS, INCLUDING A REASONABLE SYSTEM OF FOLLOW-UP AND REVIEW, DESIGNED TO DETECT AND PREVENT POTENTIALLY VIOLATIVE WASH TRADING ACTIVITY ON THE NYSE ARCA MARKETPLACE. CONSENTED TO A CENSURE AND $95,000.00 FINE. Firm Statement **09/15/2010**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY. i Disclosure 143 of 336 Reporting Source: Regulator Current Status: Final Allegations: ON JULY 19, 2010, THE CONNECTICUT BANKING COMMISSIONER ENTERED A CONSENT ORDER WITH RESPECT TO RBC CAPITAL MARKETS CORPORATION. THE CONSENT ORDER FOLLOWED AN INVESTIGATION BY A MULTISTATE TASK FORCE INTO THE MARKETING AND SALE OF AUCTION RATE SECURITIES (ARS) BY THE FIRM. THE CONSENT ORDER ALLEGED THAT, IN CONJUNCTION WITH THE MARKETING OF ARS, THE FIRM FAILED TO REASONABLY SUPERVISE ITS AGENTS AND ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS BY REPRESENTING TO CERTAIN CUSTOMERS THAT ARS WERE HIGHLY LIQUID, SAFE, CASH ALTERNATIVE INVESTMENTS. Initiated By: CONNECTICUT Date Initiated: 07/19/2010 Docket/Case Number: CO-10-7808-S URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 07/19/2010 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 $33,403.22 Cease and Desist/Injunction Other Sanctions Ordered: THE CONSENT ORDER FINED THE FIRM $33,403.22, AND DIRECTED IT TO CEASE AND DESIST FROM REGULATORY VIOLATIONS. Sanction Details: SEE RESPONSE TO ITEM 13.B. i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: CONNECTICUT DEPARTMENT OF BANKING, SECURITIES AND BUSINESS INVESTMENTS DIVISION Date Initiated: 07/19/2010 Docket/Case Number: CO-10-7808-S

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

Resolution: Consent Resolution Date: 07/19/2010 Sanctions Ordered: Monetary/Fine $33,403.22 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES ©2021 FINRA. All rights reserved. Report aboutFROM RBC CERTAIN CAPITAL MARKETS, CUSTOMERS LLC BEFORE JUNE 30, 2009. THE FIRM ALSO 333 UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. www.finra.org/brokercheck User Guidance

Resolution Date: 06/24/2010 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 $709,699.11 Cease and Desist/Injunction Other Sanctions Ordered: VARIOUS REQUIREMENTS PERTAINING TO THE SALE OF AUCTION RATE SECURITIES ("ARS"). Sanction Details: TOTAL FINE OF $709,699.11 PAID IN FULL AS OF 07/22/2010. Regulator Statement A PDF VERSION OF THE STIPULATION AND CONSENT ORDER CAN BE VIEWED ONLINE AT: HTTP://WWW.SECURITIES.UTAH.GOV/DOCKETS/10004701.PDF (NOTE: THE ADDRESS MUST BE TYPED IN LOWER CASE LETTERS). i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: UTAH DIVISION OF SECURITIES Date Initiated: 06/24/2010 Docket/Case Number: SD-10-0047

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

Resolution: Consent Resolution Date: 06/24/2010 Sanctions Ordered: Monetary/Fine $709,699.11 Cease and Desist/Injunction ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 335 www.finra.org/brokercheck User Guidance

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

Resolution: Consent Resolution Date: 06/09/2010 Sanctions Ordered: Monetary/Fine $19,600.00 Cease and Desist/Injunction

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

Resolution: Consent Resolution Date: 05/13/2010 Sanctions Ordered: Monetary/Fine $19,615.53 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES ©2021 FINRA. All rights reserved. Report aboutFROM RBC CERTAIN CAPITAL MARKETS, CUSTOMERS LLC BEFORE JUNE 30, 2009. THE FIRM ALSO 337 UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF THE LOUISIANA SECURITIES ACT LSA-R.S. 51:712 A. (2). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 147 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC WEALTH MANAGEMENT ("RBC") IS A DIVISION OF RBC CAPITAL MARKETS, A CORPORATION ORGANIZED UNDER THE LAWS OF THE STATE OF MINNESOTA, AND REGISTERED AS A FOREIGN CORPORATION IN THE STATE OF NEBRASKA, WITH ITS PRINCIPAL PLACE OF BUSINESS AT ONE LIBERTY PLAZA, 165 BROADWAY, NEW YORK, NEW YORK. RBC WAS REGISTERED AS A BROKER-DEALER APPROVED TO TRANSACT A GENERAL SECURITIES BUSINESS IN NEBRASKA. RANDY RANKIN ("RANKIN") HAS BEEN AN AGENT OF RBC, REGISTERED TO TRANSACT A GENERAL SECURITIES BUSINESS IN NEBRASKA. RANKIN MAINTAINED AN OFFICE IN NEBRASKA. GARY HOEBELHEINRICH("HOEBELHEINRICH") WAS THE BRANCH MANAGER OF THE RBC WEALTH MANAGEMENT OFFICE. ON OR ABOUT NOVEMBER 12, 1999, JW, A RESIDENT OF THE STATE OF NEBRASKA, OPENED AN ACCOUNT FOR FINANCIAL AND INVESTMENT SERVICES WITH RBC, WITH RANKIN AS HER AGENT ON THAT ACCOUNT. RBC IS AWARE OF THE IDENTITY OF JW, WHICH IS BEING KEPT CONFIDENTIAL FOR PRIVACY REASONS. ON OR ABOUT FEBRUARY 12,2001, HOEBELHEINRICH AND RANKIN REVIEWED THE ACCOUNT OF JW AT RBC FOR THE CALENDAR YEAR 2000. THE REVIEW DISCLOSED THAT: A. THE "ANNUALIZED COMMISSION ON ASSETS (EQUITY)" FOR THE ACCOUNT AS A PERCENTAGE WAS NINE POINT EIGHT (9.8%); B. THE AVERAGE ACCOUNT VALUE FOR THE YEAR HAD BEEN FOUR HUNDRED FIFTY-NINE THOUSAND SIX HUNDRED EIGHT DOLLARS AND ELEVEN CENTS ($459,608.1 1); C. THE TOTAL COMMISSIONS PAID WERE FORTY- ©2021 FINRA. All rights reserved. Report aboutFIVE RBC THOUSAND CAPITAL MARKETS, TWO HUNDRED LLC FIFTY-THREE DOLLARS AND SEVEN 338 CENTS ($45,253.07); AND D. A TOTAL OF ONE HUNDRED AND THIRTY-ONE (13 1) TRADES WERE MADE IN THE ACCOUNT FOR THE CALENDAR YEAR 2000. RANKIN STATED THAT THE CLIENT RELIED ON HIS RECOMMENDATIONS ONE-HUNDRED PERCENT (100%) OF THE TIME. ON OR ABOUT APRIL 25,2002, HOEBELHEINRICH AND RANKIN CONDUCTED A REVIEW OF THE ACCOUNT OF JW AT RBC FOR THE CALENDAR YEAR 2001. THE REVIEW DISCLOSED THAT: A. THE "ANNUALIZED COMMISSION ON ASSETS (EQUITY)" FOR THE ACCOUNT AS A PERCENTAGE WAS THIRTEEN POINT ZERO (1 3 .O%); B. THE AVERAGE ACCOUNT VALUE FOR THE YEAR HAD BEEN ONE HUNDRED FIFTY THOUSAND EIGHT HUNDRED TWENTY-EIGHT DOLLARS AND FIVE CENTS ($150,828.05); C. THE TOTAL COMMISSIONS PAID WERE NINETEEN THOUSAND SIX HUNDRED SIXTEEN DOLLARS AND SEVENTY- THREE CENTS ($19,616.73); AND D. A TOTAL OF ONE HUNDRED AND TWENTY-TWO (122) WERE TRADES MADE IN THE ACCOUNT FOR THE CALENDAR YEAR 2001. RANKIN STATED THAT THE CLIENT RELIED ON HIS RECOMMENDATIONS ONE-HUNDRED PERCENT (100%) OF THE TIME. ON OR ABOUT FEBRUARY 17,2003, HOEBELHEINRICH AND RANKIN CONDUCTED A REVIEW OF THE ACCOUNT OF JW AT RBC FOR THE CALENDAR YEAR 2002. THE REVIEW DISCLOSED THAT: A. THE "COMMISSION AS A % OF AVERAGE BALANCE" FOR THE ACCOUNT AS A PERCENTAGE WAS TWELVE POINT ZERO SIX (12.06%); B. THE AVERAGE ACCOUNT VALUE FOR THE YEAR HAD BEEN ONE HUNDRED AND TEN THOUSAND FOUR HUNDRED SIXTY-SEVEN DOLLARS AND ZERO CENTS ($1 10,467.00); C. THE TOTAL COMMISSIONS PAID WERE THIRTEEN THOUSAND FOUR HUNDRED THIRTY-EIGHT DOLLARS AND ZERO CENTS ($13,438.00); AND D. THE TOTAL OF SEVENTY-THREE (73) TRADES WERE MADE IN THE ACCOUNT FOR THE CALENDAR YEAR 2002. RANKIN STATED THAT ONE-HUNDRED PERCENT (100%) OF THE TIME SOLICITATION OF THE TRADES CAME FROM RANKIN. RBC WEALTH MANAGEMENT ("RBC") IS A DIVISION OF RBC CAPITAL MARKETS, A CORPORATION ORGANIZED UNDER THE LAWS OF THE STATE OF MINNESOTA, AND REGISTERED AS A FOREIGN CORPORATION IN THE STATE OF NEBRASKA, WITH ITS PRINCIPAL PLACE OF BUSINESS AT ONE LIBERTY PLAZA, 165 BROADWAY, NEW YORK, NEW YORK. RBC WAS REGISTERED AS A BROKER-DEALER APPROVED TO TRANSACT A GENERAL SECURITIES BUSINESS IN NEBRASKA. RANDY RANKIN ("RANKIN") HAS BEEN AN AGENT OF RBC, REGISTERED TO TRANSACT A GENERAL SECURITIES BUSINESS IN NEBRASKA. RANKIN MAINTAINED AN OFFICE IN NEBRASKA. GARY HOEBELHEINRICH("HOEBELHEINRICH") WAS THE BRANCH MANAGER OF THE RBC WEALTH MANAGEMENT OFFICE. ON OR ABOUT NOVEMBER 12, 1999, JW, A RESIDENT OF THE STATE OF NEBRASKA, OPENED AN ACCOUNT FOR FINANCIAL AND INVESTMENT SERVICES WITH RBC, WITH RANKIN AS HER AGENT ON THAT ACCOUNT. RBC IS AWARE OF THE IDENTITY OF JW, WHICH IS BEING KEPT CONFIDENTIAL FOR PRIVACY REASONS. ON OR ABOUT FEBRUARY 12,2001, HOEBELHEINRICH AND RANKIN REVIEWED THE ACCOUNT OF JW AT RBC FOR THE CALENDAR YEAR 2000. THE REVIEW DISCLOSED THAT: www.finra.org/brokercheck A. THE "ANNUALIZED COMMISSION ON ASSETS (EQUITY)" FOR THE User Guidance ACCOUNT AS A PERCENTAGE WAS NINE POINT EIGHT (9.8%); B. THE AVERAGE ACCOUNT VALUE FOR THE YEAR HAD BEEN FOUR HUNDRED FIFTY-NINE THOUSAND SIX HUNDRED EIGHT DOLLARS AND ELEVEN CENTS ($459,608.1 1); C. THE TOTAL COMMISSIONS PAID WERE FORTY- FIVE THOUSAND TWO HUNDRED FIFTY-THREE DOLLARS AND SEVEN CENTS ($45,253.07); AND D. A TOTAL OF ONE HUNDRED AND THIRTY-ONE (13 1) TRADES WERE MADE IN THE ACCOUNT FOR THE CALENDAR YEAR 2000. RANKIN STATED THAT THE CLIENT RELIED ON HIS RECOMMENDATIONS ONE-HUNDRED PERCENT (100%) OF THE TIME. ON OR ABOUT APRIL 25,2002, HOEBELHEINRICH AND RANKIN CONDUCTED A REVIEW OF THE ACCOUNT OF JW AT RBC FOR THE CALENDAR YEAR 2001. THE REVIEW DISCLOSED THAT: A. THE "ANNUALIZED COMMISSION ON ASSETS (EQUITY)" FOR THE ACCOUNT AS A PERCENTAGE WAS THIRTEEN POINT ZERO (1 3 .O%); B. THE AVERAGE ACCOUNT VALUE FOR THE YEAR HAD BEEN ONE HUNDRED FIFTY THOUSAND EIGHT HUNDRED TWENTY-EIGHT DOLLARS AND FIVE CENTS ($150,828.05); C. THE TOTAL COMMISSIONS PAID WERE NINETEEN THOUSAND SIX HUNDRED SIXTEEN DOLLARS AND SEVENTY- THREE CENTS ($19,616.73); AND D. A TOTAL OF ONE HUNDRED AND TWENTY-TWO (122) WERE TRADES MADE IN THE ACCOUNT FOR THE CALENDAR YEAR 2001. RANKIN STATED THAT THE CLIENT RELIED ON HIS RECOMMENDATIONS ONE-HUNDRED PERCENT (100%) OF THE TIME. ON OR ABOUT FEBRUARY 17,2003, HOEBELHEINRICH AND RANKIN CONDUCTED A REVIEW OF THE ACCOUNT OF JW AT RBC FOR THE CALENDAR YEAR 2002. THE REVIEW DISCLOSED THAT: A. THE "COMMISSION AS A % OF AVERAGE BALANCE" FOR THE ACCOUNT AS A PERCENTAGE WAS TWELVE POINT ZERO SIX (12.06%); B. THE AVERAGE ACCOUNT VALUE FOR THE YEAR HAD BEEN ONE HUNDRED AND TEN THOUSAND FOUR HUNDRED SIXTY-SEVEN DOLLARS AND ZERO CENTS ($1 10,467.00); C. THE TOTAL COMMISSIONS PAID WERE THIRTEEN THOUSAND FOUR HUNDRED THIRTY-EIGHT DOLLARS AND ZERO CENTS ($13,438.00); AND D. THE TOTAL OF SEVENTY-THREE (73) TRADES WERE MADE IN THE ACCOUNT FOR THE CALENDAR YEAR 2002. RANKIN STATED THAT ONE-HUNDRED PERCENT (100%) OF THE TIME SOLICITATION OF THE TRADES CAME FROM RANKIN. Initiated By: NEBRASKA Date Initiated: 04/01/2010 Docket/Case Number: URL for Regulatory Action: 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 FINE - $15000.00 ©2021Sought: FINRA. All rights reserved. Report aboutDISGORGEMENT RBC CAPITAL MARKETS, - $40000.00 LLC 339 COSTS OF INVESTIGATION - $5000.00 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief FINE - $15000.00 Sought: DISGORGEMENT - $40000.00 COSTS OF INVESTIGATION - $5000.00

Resolution: Consent Resolution Date: 05/01/2010 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 $60,000.00 Disgorgement/Restitution Other Sanctions Ordered: FINE - $15000.00 DISGORGEMENT - $40000.00 COSTS OF INVESTIGATION - $5000.00

TOTAL SANCTION AMOUNT - $60,000.00 Sanction Details: RBC WEALTH MANAGEMENT, F/KJA RBC DAIN RAUSCHER, SHALL DISGORGE COMMISSIONS PAID BY JW IN 2000, 2001 AND 2002 IN THE AMOUNT OF FORTY THOUSAND DOLLARS ($40,000.00) WITHIN THIRTY (30) DAYS OF THE EFFECTIVE DATE OF THIS ORDER. RBC SHALL PROVIDE THE DEPARTMENT WITH PROOF OF THE PAYMENT OF THE DISGORGEMENT WITHIN FIFTEEN (1 5 ) DAYS OF THE PAYMENT. RBC WEALTH MANAGEMENT, F/K/A RBC DAIN RAUSCHER, SHALL PAY A FINE IN THE AMOUNT OF FIFTEEN THOUSAND DOLLARS ($15,000.00). RBC WEALTH MANAGEMENT SHALL REIMBURSE THE DEPARTMENT FOR A PORTION OF THE COSTS OF THE INVESTIGATION IN THE AMOUNT OF FIVE THOUSAND DOLLARS ($5,000.00). RBC WEALTH MANAGEMENT SHALL PAY THE TOTAL AMOUNT OF THE FINE AND COSTS ASSESSED AGAINST RBC WEALTH MANAGEMENT PURSUANT TO THIS ORDER IN THE AMOUNT OF TWENTY THOUSAND DOLLARS ($20,000.00), BY CHECK OR MONEY ORDER PAYABLE TO THE NEBRASKA DEPARTMENT OF BANKING AND FINANCE, WITHIN THIRTY (30) DAYS OF THE EFFECTIVE DATE OF THIS ORDER. Regulator Statement RBC NEITHER ADMITS NOR DENIES THE FINDINGS OF FACT AND CONCLUSIONS OF LAW CONTAINED IN THIS ORDER AND CONSENTS TO ENTRY OF THIS ORDER BY THE DEPARTMENT AS SETTLEMENT OF THE ISSUES CONTAINED IN THIS ORDER. i Reporting Source: Firm

Current Status: Final Allegations: THE DEPARTMENT ALLEGED THAT RBC DID NOT ENFORCE POLICIES AND PROCEDURES DESIGNED TO PREVENT AN RBC BROKER FROM ENGAGING IN TRADING IN A CUSTOMER'S ACCOUNT THAT APPEARED TO BE EXCESSIVE IN SIZE OR FREQUENCY IN VIEW OF THE CUSTOMER'S FINANCIAL RESOURCES AND THE CHARACTER OF THE ACCOUNT. Initiated By: NEBRASKA DEPARTMENT OF BANKING AND FINANCE Date Initiated: 04/01/2010 Docket/Case Number: N/A

Resolution: Consent Resolution Date: 05/01/2010 Sanctions Ordered: Monetary/Fine $60,000.00 Disgorgement/Restitution Other Sanctions Ordered: FINE - $15,000, DISGORGEMENT - $40,000, COST OF INVESTIGATION - $5,000 TOTAL SANCTION AMOUNT - $60,000 Sanction Details: WITHOUT ADMITTING ANY WRONGDOING, THE FIRM AGREED TO RETURN $40,000 IN COMMISSIONS, PAID A $15,000 FINE TO THE DEPARTMENT, AND PAID $5,000 IN COSTS. Firm Statement RBC MADE THE PAYMENTS SPECIFIED IN THE CONSENT ORDER ON APRIL 28, 2010. MATTER CLOSED. i Disclosure 148 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: TENNESSEE SECURITIES DIVISION ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 341 www.finra.org/brokercheck User Guidance

Initiated By: TENNESSEE SECURITIES DIVISION Date Initiated: 04/12/2010 Docket/Case Number: 10-002

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

Resolution: Consent Resolution Date: 04/12/2010 Sanctions Ordered: Monetary/Fine $224,428.05 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF TENN. CODE ANN. 48-2-112(A)(2)(G) AND 48-2- 112(A)(2)(J). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 149 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD.

Initiated By: SECURITIES COMMISSIONER OF SOUTH CAROLINA Date Initiated: 02/05/2010 Docket/Case Number: 10005

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

Resolution: Consent Resolution Date: 02/05/2010 Sanctions Ordered: Monetary/Fine $51,786.82 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF 23 S.C. CODE REG. 13-501(A)(SUPP. 2009) Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 150 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF MINNESOTA COMMISSIONER OF COMMERCE ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 343 www.finra.org/brokercheck User Guidance

Initiated By: STATE OF MINNESOTA COMMISSIONER OF COMMERCE Date Initiated: 01/14/2010 Docket/Case Number: 12746

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

Resolution: Consent Resolution Date: 01/14/2010 Sanctions Ordered: Monetary/Fine $563,251.41 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF MINN. STAT. 80A.07, SUBD. 1(7), (10) AND MINN. STAT. 80A.67(D)(9), (13). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 151 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: WISCONSIN DEPARTMENT OF FINANCIAL INSTITUTIONS DIVISION OF ©2021 FINRA. All rights reserved. Report aboutSECURITIES RBC CAPITAL MARKETS, LLC 344 www.finra.org/brokercheck User Guidance

Initiated By: WISCONSIN DEPARTMENT OF FINANCIAL INSTITUTIONS DIVISION OF SECURITIES Date Initiated: 01/14/2010 Docket/Case Number: S-09149(EX)

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

Resolution: Consent Resolution Date: 01/14/2010 Sanctions Ordered: Monetary/Fine $324,978.87 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF SEC. 551.34(1)(G) AND SEC. 551.34(1)(J) OF THE WIS. STATS. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 152 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC MADE MISREPRESENTATIONS TO CERTAIN INVESTORS IN CONNECTION WITH THE SALE OF AUCTION RATE SECURITIES. RBC ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. RBC FAILED TO RESONABLY SUPERVISE AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH ©2021 FINRA. All rights reserved. Report aboutCONDUCT. RBC CAPITAL MARKETS, LLC 345 www.finra.org/brokercheck RBC MADE MISREPRESENTATIONS TO CERTAIN INVESTORS IN User Guidance CONNECTION WITH THE SALE OF AUCTION RATE SECURITIES. RBC ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. RBC FAILED TO RESONABLY SUPERVISE AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. Initiated By: NEW JERSEY BUREAU OF SECURITIES Date Initiated: 05/22/2009 Docket/Case Number: 2010-004 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST FROM VIOLATING THE SECURITIES LAW, RBC SHALL Sought: TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CUSTOMERS THAT PURCHASED "ELIGIBLE ARS" FROM RBC, INCLUDING BUT NOT LIMITED TO, OFFERING TO BUY BACK ARS UNDER SPECIFIED TERMS.

Resolution: Consent Resolution Date: 01/28/2010 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 $51,724.71 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: RBC SHALL TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CUSTOMERS THAT PURCHASED ELIGIBLE ARS FROM RBC INCLUDING BUT NOT LIMITED TO OFFERING TO BUY BACK FROM ELIGIBLE INVESTORS AT PAR PLUS ACCRUED INTEREST AND DIVIDENDS, IF ANY, ELIGIBLE ARS THAT HAVE FAILED AT AUCTION AT LEAST ONCE BETWEEN 10/3/08 AND 6/30/09. i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN ©2021 FINRA. All rights reserved. Report aboutCOMMUNICATIONS RBC CAPITAL MARKETS, WITH LLC CUSTOMERS THE INCREASING RISKS 346 ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. THE STATE OF NEW JERSEY ADDITIONALLY ALLEGES THAT THE FIRM: (1) MADE MISREPRESENTATIONS TO CERTAIN INVESTORS IN CONNECTION WITH THE SALE OF AUCTION RATE SECURITIES; (2) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS; (3) FAILED TO RESONABLY SUPERVISE AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. www.finra.org/brokercheck User Guidance

Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. THE STATE OF NEW JERSEY ADDITIONALLY ALLEGES THAT THE FIRM: (1) MADE MISREPRESENTATIONS TO CERTAIN INVESTORS IN CONNECTION WITH THE SALE OF AUCTION RATE SECURITIES; (2) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS; (3) FAILED TO RESONABLY SUPERVISE AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. Initiated By: NEW JERSEY BUREAU OF SECURITIES Date Initiated: 05/22/2009 Docket/Case Number: 2010-004

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

Resolution: Consent Resolution Date: 01/28/2010 Sanctions Ordered: Monetary/Fine $51,724.71 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF N.J.S.A. 49:3-58(A)(2)(VII) AND N.J.S.A. 49:3-58(A)(2)(XI). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 153 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 347 www.finra.org/brokercheck User Guidance

Disclosure 153 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: ARKANSAS SECURITIES COMMISSIONER Date Initiated: 12/21/2009 Docket/Case Number: S-09-024-09-CO05

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

Resolution: Consent Resolution Date: 12/21/2009 Sanctions Ordered: Monetary/Fine $19,693.16 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF SECTION ARK. CODE ANN. 23-42-308(A)(2)(G) AND 23- 42-308(A)(2)(J). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i

Disclosure 154 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: NEW MEXICO SECURITIES DIVISION Date Initiated: 01/04/2010 Docket/Case Number: 09-09-999-064

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

Resolution: Consent Resolution Date: 01/04/2010 Sanctions Ordered: Monetary/Fine $21,432.15 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF SECTION 58-13B-16.A(2)(H) AND (K) OF THE NEW MEXICO SECURITIES ACT. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i

Disclosure 155 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF KANSAS SECURITIES COMMISSIONER Date Initiated: 09/04/2009 Docket/Case Number: 09 E 019

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

Resolution: Consent Resolution Date: 09/04/2009 Sanctions Ordered: Monetary/Fine $22,534.54 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF K.S.A. 17-12A412 (D)(13) AND K.S.A. 17-12A412(D)(9). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 156 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 350 www.finra.org/brokercheck User Guidance

Disclosure 156 of 336 Reporting Source: Regulator Current Status: Final Allegations: RESPONDENT OFFERED ARS SALES IN PA, WHICH WOULD CONSTITUTE DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND WOULD CONSTITUTE FAILURE TO SUPERVISE ITS AGENTS IN VIOLATION OF THE PA SECURITIES ACT OF 1972. Initiated By: PENNSYLVANIA CONTACT: COUNSEL CAROLYN MENDELSON (412)-565- 5083 Date Initiated: 01/05/2010 Docket/Case Number: 2008-08-16 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief WITHIN TEN DAYS AFTER ENTRY OF THIS ORDER, RBC CAPITAL MARKETS Sought: CORPORATION (RESPONDENT) SHALL PAY THE SUM OF $74,809.79 TO THE COMMONWEALTH OF PA, WHICH AMOUNT REPRESENTS AN ADMINISTRATIVE ASSESSMENT.

Resolution: Settled Resolution Date: 01/05/2010 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 $74,809.79 Other Sanctions Ordered: RESPONDENT HAS OFFERED A BUYBACK OF AUCTION RATE SECURITIES TO ELIGIBLE PA RESIDENTS. IN ADDITION, RESPONDENT WILL PAY FOR PA RESIDENTS TO SUE IN SPECIAL EXPEDITED ARBITRATION FOR CONSEQUENTIAL DAMAGES THAT PA RESIDENTS MAY HAVE INCURRED DUE TO ARS ILLIQUIDITY. Sanction Details: WITHIN TEN DAYS AFTER ENTRY OF THIS ORDER, RBC CAPITAL MARKETS CORPORATION (RESPONDENT) SHALL PAY THE SUM OF $74,809.79 TO THE COMMONWEALTH OF PA, WHICH AMOUNT REPRESENTS AN ADMINISTRATIVE ASSESSMENT.

Regulator Statement FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER ISSUED TO RESPONDENT. i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: PENNSYLVANIA SECURITIES COMMISSION Date Initiated: 01/05/2010 Docket/Case Number: 2008-08-16

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

Resolution: Consent Resolution Date: 01/05/2010 Sanctions Ordered: Monetary/Fine $74,809.79 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF SECTIONS 305(A)(IX) AND 305(A)(VII)OF THE 1972 PENNSYLVANIA SECURITIES ACT. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO ©2021 FINRA. All rights reserved. Report aboutTHE RBC REGULATOR. CAPITAL MARKETS, LLC 352 www.finra.org/brokercheck THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES User Guidance FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 157 of 336 Reporting Source: Regulator Current Status: Final Allegations: SEC RULES 10B-10, 203(B)(3), 605 AND 606 OF REGULATION NMS, NASD RULES 2110, 2111(A), 2320, 3010, 6130(B), 6230(A), 6955(A), MSRB RULES G- 14, G-14(B)(II), G-17, G-30(A) - RBC CAPITAL MARKETS CORPORATION HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN THRESHOLD SECURITIES FOR 13 CONSECUTIVE SETTLEMENT DAYS AND FAILED TO IMMEDIATELY THEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY OR WITHOUT CLOSING OUT THE FAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY, IT FAILED TO BORROW THE SECURITY OR ENTER INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY BEFORE EXECUTING PROPRIETARY SHORT SALES IN THE SECURITY. THE FIRM TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS (ROES)THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE; THE FIRM FAILED TO REPAIR MANY OF THEM AND THEREFORE, FAILED TO TRANSMIT THE ROES TO OATS. THE FIRM ALSO FAILED TO POPULATE THE REJECTED ROE RESUBMIT FLAG WITH A "Y" FOR SOME REJECTION SUBMISSIONS. THE FIRM TRANSMITTED REPORTS TO OATS RELATING TO ORDERS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. THE FIRM MADE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON THAT INCLUDED INCORRECT INFORMATION. THE FIRM, WHEN IT ACTED AS PRINCIPAL FOR ITS OWN ACCOUNT, FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THAT IT WAS A MARKET MAKER IN EACH SUCH SECURITY. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING THE USE OF MULTIPLE MARKET PARTICIPANT IDENTIFIERS (MPIDS). THE FIRM FAILED TO TIMELY MAKE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON OR FROM ANY PERSON VIA HYPERLINK. THE FIRM FAILED TO TIMELY MAKE PUBLICLY AVAILABLE REPORTS ON THE ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITIES. THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. IN TRANSACTIONS FOR OR WITH CUSTOMERS, 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 ©2021 FINRA. All rights reserved. Report aboutTHE RBC RESULTANT CAPITAL MARKETS, PRICE LLCTO ITS CUSTOMERS WAS AS FAVORABLE AS 353 POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TO ACCEPT OR DECLINE IN THE NASD/NASDAQ TRADE REPORTING FACILITY AND THE OTC REPORTING FACILITY TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION THAT IT HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE ORDER ENTRY IDENTIFIER (OEID). THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE 2110. [CONTINUED IN COMMENTS] SEC RULES 10B-10, 203(B)(3), 605 AND 606 OF REGULATION NMS, NASD RULES 2110, 2111(A), 2320, 3010, 6130(B), 6230(A), 6955(A), MSRB RULES G- 14, G-14(B)(II), G-17, G-30(A) - RBC CAPITAL MARKETS CORPORATION HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN THRESHOLD SECURITIES FOR 13 CONSECUTIVE SETTLEMENT DAYS AND FAILED TO IMMEDIATELY THEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY OR WITHOUT CLOSING OUT THE FAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY, IT FAILED TO BORROW THE SECURITY OR ENTER INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY BEFORE EXECUTING PROPRIETARY SHORT SALES IN THE SECURITY. THE FIRM TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS (ROES)THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE; THE FIRM FAILED TO REPAIR MANY OF THEM AND THEREFORE, FAILED TO TRANSMIT THE ROES TO OATS. THE FIRM ALSO FAILED TO POPULATE THE REJECTED ROE RESUBMIT FLAG WITH A "Y" FOR SOME REJECTION SUBMISSIONS. THE FIRM TRANSMITTED REPORTS TO OATS RELATING TO ORDERS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. THE FIRM MADE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON THAT INCLUDED INCORRECT INFORMATION. THE FIRM, WHEN IT ACTED AS PRINCIPAL FOR ITS OWN ACCOUNT, FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THAT IT WAS A MARKET MAKER IN EACH SUCH SECURITY. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING THE USE OF MULTIPLE MARKET PARTICIPANT IDENTIFIERS (MPIDS). THE FIRM FAILED TO TIMELY MAKE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON OR FROM ANY PERSON VIA HYPERLINK. THE FIRM FAILED TO TIMELY MAKE PUBLICLY AVAILABLE www.finra.org/brokercheck REPORTS ON THE ROUTING OF NON-DIRECTED ORDERS IN COVERED User Guidance SECURITIES. THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. IN TRANSACTIONS FOR OR WITH CUSTOMERS, 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 PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TO ACCEPT OR DECLINE IN THE NASD/NASDAQ TRADE REPORTING FACILITY AND THE OTC REPORTING FACILITY TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION THAT IT HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE ORDER ENTRY IDENTIFIER (OEID). THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE 2110. [CONTINUED IN COMMENTS] Initiated By: FINRA Date Initiated: 01/06/2010 Docket/Case Number: 2006006102602

Principal Product Type: Debt - Municipal Other Product Type(s): THRESHOLD SECURITIES, NATIONAL MARKET SYSTEM SECURITIES, REPORTABLE SECURITIES, TRACE-ELIGIBLE SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/06/2010 Does the order constitute a No final order based on ©2021violations FINRA. of All any rights laws reserved. or Report about RBC CAPITAL MARKETS, LLC 354 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 $150,000.00 Disgorgement/Restitution 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 $150,000, ORDERED TO PAY $7,254.18, PLUS INTEREST, IN RESTITUTION TO INVESTORS AND ORDERED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING THE USE OF MULTIPLE MPIDS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. A REGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. 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. Regulator Statement ALLEGAGTIONS CONTINUED: THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS AND BLOCK PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL. THE FIRM FAILED TO REPORT THE CORRECT SPECIAL CONDITION INDICATOR CODE TO THE RTRS IN MUNICIPAL SECURITIES TRANSACTION REPORTS. THE FIRM OVER- REPORTED TRANSACTIONS IN MUNICIPAL SECURITIES TO THE RTRS. i Reporting Source: Firm Current Status: Final Allegations: SEC RULES 10B-10, 203(B)(3), 605 AND 606 OF REGULATION NMS, NASD RULES 2110, 2111(A), 2320, 3010, 6130(B), 6230(A), 6955(A), MSRB RULES G- 14, G-14(B)(II), G-17, G-30(A) - RBC CAPITAL MARKETS CORPORATION HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN ©2021 FINRA. All rights reserved. Report aboutTHRESHOLD RBC CAPITAL SECURITIES MARKETS, LLC FOR 13 CONSECUTIVE SETTLEMENT DAYS AND 355 FAILED TO IMMEDIATELY THEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY OR WITHOUT CLOSING OUT THE FAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY, IT FAILED TO BORROW THE SECURITY OR ENTER INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY BEFORE EXECUTING PROPRIETARY SHORT SALES IN THE SECURITY. THE FIRM TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS (ROES)THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE; THE FIRM FAILED TO REPAIR MANY OF THEM AND THEREFORE, FAILED TO TRANSMIT THE ROES TO OATS. THE FIRM ALSO FAILED TO POPULATE THE REJECTED ROE RESUBMIT FLAG WITH A "Y" FOR SOME REJECTION SUBMISSIONS. THE FIRM TRANSMITTED REPORTS TO OATS RELATING TO ORDERS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. THE FIRM MADE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON THAT INCLUDED INCORRECT INFORMATION. THE FIRM, WHEN IT ACTED AS PRINCIPAL FOR ITS OWN ACCOUNT, FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THAT IT WAS A MARKET MAKER IN EACH SUCH SECURITY. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING THE USE OF MULTIPLE MARKET PARTICIPANT IDENTIFIERS (MPIDS). THE FIRM FAILED TO TIMELY MAKE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON OR FROM ANY PERSON VIA HYPERLINK. THE FIRM FAILED TO TIMELY MAKE PUBLICLY AVAILABLE REPORTS ON THE ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITIES. THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. IN TRANSACTIONS FOR OR WITH CUSTOMERS, 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 PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TO ACCEPT OR DECLINE IN THE NASD/NASDAQ TRADE REPORTING FACILITY AND THE OTC REPORTING FACILITY TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION THAT IT HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE ORDER ENTRY IDENTIFIER (OEID). THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE 2110. [CONTINUED IN COMMENTS] www.finra.org/brokercheck User Guidance SEC RULES 10B-10, 203(B)(3), 605 AND 606 OF REGULATION NMS, NASD RULES 2110, 2111(A), 2320, 3010, 6130(B), 6230(A), 6955(A), MSRB RULES G- 14, G-14(B)(II), G-17, G-30(A) - RBC CAPITAL MARKETS CORPORATION HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN THRESHOLD SECURITIES FOR 13 CONSECUTIVE SETTLEMENT DAYS AND FAILED TO IMMEDIATELY THEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY OR WITHOUT CLOSING OUT THE FAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY, IT FAILED TO BORROW THE SECURITY OR ENTER INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY BEFORE EXECUTING PROPRIETARY SHORT SALES IN THE SECURITY. THE FIRM TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS (ROES)THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE; THE FIRM FAILED TO REPAIR MANY OF THEM AND THEREFORE, FAILED TO TRANSMIT THE ROES TO OATS. THE FIRM ALSO FAILED TO POPULATE THE REJECTED ROE RESUBMIT FLAG WITH A "Y" FOR SOME REJECTION SUBMISSIONS. THE FIRM TRANSMITTED REPORTS TO OATS RELATING TO ORDERS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. THE FIRM MADE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON THAT INCLUDED INCORRECT INFORMATION. THE FIRM, WHEN IT ACTED AS PRINCIPAL FOR ITS OWN ACCOUNT, FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THAT IT WAS A MARKET MAKER IN EACH SUCH SECURITY. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING THE USE OF MULTIPLE MARKET PARTICIPANT IDENTIFIERS (MPIDS). THE FIRM FAILED TO TIMELY MAKE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON OR FROM ANY PERSON VIA HYPERLINK. THE FIRM FAILED TO TIMELY MAKE PUBLICLY AVAILABLE REPORTS ON THE ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITIES. THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. IN TRANSACTIONS FOR OR WITH CUSTOMERS, 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 PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TO ACCEPT OR DECLINE IN THE NASD/NASDAQ TRADE REPORTING FACILITY AND THE OTC REPORTING FACILITY TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION THAT IT HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE ORDER ENTRY IDENTIFIER (OEID). THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE ©2021 FINRA. All rights reserved. Report aboutBEST RBC JUDGMENT CAPITAL MARKETS, OF THE LLC BROKER, DEALER OR MUNICIPAL SECURITIES 356 DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE 2110. [CONTINUED IN COMMENTS] SEC RULES 10B-10, 203(B)(3), 605 AND 606 OF REGULATION NMS, NASD RULES 2110, 2111(A), 2320, 3010, 6130(B), 6230(A), 6955(A), MSRB RULES G- 14, G-14(B)(II), G-17, G-30(A) - RBC CAPITAL MARKETS CORPORATION HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN THRESHOLD SECURITIES FOR 13 CONSECUTIVE SETTLEMENT DAYS AND FAILED TO IMMEDIATELY THEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY OR WITHOUT CLOSING OUT THE FAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY, IT FAILED TO BORROW THE SECURITY OR ENTER INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY BEFORE EXECUTING PROPRIETARY SHORT SALES IN THE SECURITY. THE FIRM TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS (ROES)THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE; THE FIRM FAILED TO REPAIR MANY OF THEM AND THEREFORE, FAILED TO TRANSMIT THE ROES TO OATS. THE FIRM ALSO FAILED TO POPULATE THE REJECTED ROE RESUBMIT FLAG WITH A "Y" FOR SOME REJECTION SUBMISSIONS. THE FIRM TRANSMITTED REPORTS TO OATS RELATING TO ORDERS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. THE FIRM MADE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON THAT INCLUDED INCORRECT INFORMATION. THE FIRM, WHEN IT ACTED AS PRINCIPAL FOR ITS OWN ACCOUNT, FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THAT IT WAS A MARKET MAKER IN EACH SUCH SECURITY. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING THE USE OF MULTIPLE MARKET PARTICIPANT IDENTIFIERS (MPIDS). THE FIRM FAILED TO TIMELY MAKE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON OR FROM ANY PERSON VIA HYPERLINK. THE FIRM FAILED TO TIMELY MAKE PUBLICLY AVAILABLE REPORTS ON THE ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITIES. THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. IN TRANSACTIONS FOR OR WITH CUSTOMERS, 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 PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TO ACCEPT OR DECLINE IN THE NASD/NASDAQ TRADE REPORTING FACILITY AND THE OTC REPORTING FACILITY TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION THAT IT HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE ORDER ENTRY IDENTIFIER www.finra.org/brokercheck (OEID). THE FIRM PURCHASED MUNICIPAL SECURITIES FOR ITS OWN User Guidance ACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE 2110. [CONTINUED IN COMMENTS] Initiated By: FINRA Date Initiated: 01/06/2010 Docket/Case Number: 2006006102602

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/06/2010 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Disgorgement/Restitution 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 $150,000, ORDERED TO PAY $7,254.18, PLUS INTEREST, IN RESTITUTION TO INVESTORS AND ORDERED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING THE USE OF MULTIPLE MPIDS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. A REGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OF ©2021 FINRA. All rights reserved. Report aboutREASONABLE RBC CAPITAL AND MARKETS, DOCUMENTED LLC EFFORTS UNDERTAKEN TO EFFECT 357 RESTITUTION NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. 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. 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 $150,000, ORDERED TO PAY $7,254.18, PLUS INTEREST, IN RESTITUTION TO INVESTORS AND ORDERED www.finra.org/brokercheck TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING THE User Guidance USE OF MULTIPLE MPIDS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. A REGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. 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. Firm Statement ALLEGATIONS CONTINUED: THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS AND BLOCK PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL. THE FIRM FAILED TO REPORT THE CORRECT SPECIAL CONDITION INDICATOR CODE TO THE RTRS IN MUNICIPAL SECURITIES TRANSACTION REPORTS. THE FIRM OVER- REPORTED TRANSACTIONS IN MUNICIPAL SECURITIES TO THE RTRS. i Disclosure 158 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASDAQ RULE 4755 - RBC CAPITAL MARKETS CORPORATION ENTERED ORDERS INTO THE NASDAQ MARKET CENTER THAT FAILED TO CORRECTLY INDICATE WHETHER THE ORDERS WERE A BUY, SHORT SALE OR LONG SALE. Initiated By: NASDAQ STOCK MARKET Date Initiated: 01/06/2010 Docket/Case Number: 2006006102601

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/06/2010 Does the order constitute a No ©2021final orderFINRA. basedAll rights on reserved. Report about RBC CAPITAL MARKETS, LLC 358 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: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS FINED $5,000. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATION OF NASDAQ RULE 4755 - RBC CAPITAL MARKETS CORPORATION ENTERED ORDERS INTO THE NASDAQ MARKET CENTER THAT FAILED TO CORRECTLY INDICATE WHETHER THE ORDERS WERE A BUY, SHORT SALE OR LONG SALE. Initiated By: NASDAQ STOCK MARKETS LLC Date Initiated: 01/06/2010 Docket/Case Number: 2006006102601

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/06/2010 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS FINED $5,000.

i Disclosure 159 of 336 Reporting Source: Regulator Current Status: Final Allegations: SECTION 5 OF THE SECURITIES ACT OF 1933 AND NASD RULES 2110 AND 3010: RESPONDENT RBC CAPITAL MARKETS CORPORATION PARTICIPATED IN THE DISTRIBUTION OF UNREGISTERED SHARES BY OFFERING AND SELLING THROUGH THE MEANS OF INTERSTATE COMMERCE OVER 2 BILLION UNREGISTERED SHARES WITHOUT AN EXEMPTION. THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SYSTEM TO SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS THAT WERE REASONABLY DESIGNED TO DETECT AND PREVENT THE SALE OF UNREGISTERED SECURITIES. Initiated By: FINRA Date Initiated: 01/04/2010 Docket/Case Number: 2009020545701

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

i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGED THE FIRM VIOLATED (1) NASD RULE 2110 FOR SELLING UNREGISTERED SECURITIES IN VIOLATION OF SECTION 5 OF THE 1933 ACT AND (2) NASD RULE 3010 FOR FAILING TO ESTABLISH MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO DETECT AND PREVENT THE SALE OF UNREGISTERED SECURITIES. Initiated By: FINRA Date Initiated: 10/22/2009 Docket/Case Number: 20090205457

Principal Product Type: Penny Stock(s) 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: 01/04/2010 Sanctions Ordered: Censure Monetary/Fine $135,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS CORPORATION CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $135,000. i Disclosure 160 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010(B): THE FIRM FAILED TO MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES RELATING TO NON-CASH COMPENSATION THAT WAS RELEVANT FOR ITS NON-CASH COMPENSATION MONITORING COMPLIANCE AND FINRA'S NON-CASH COMPENSATION RULES. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 361 www.finra.org/brokercheck NASD RULES 2110, 3010(B): THE FIRM FAILED TO MAINTAIN ADEQUATE User Guidance WRITTEN SUPERVISORY PROCEDURES RELATING TO NON-CASH COMPENSATION THAT WAS RELEVANT FOR ITS NON-CASH COMPENSATION MONITORING COMPLIANCE AND FINRA'S NON-CASH COMPENSATION RULES. Initiated By: FINRA Date Initiated: 01/04/2010 Docket/Case Number: 2007007126202

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/04/2010 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 $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE THE FIRM IS FINED $5,000. i Reporting Source: Firm Current Status: Final Allegations: NASD RULES 2110, 3010(B): THE FIRM FAILED TO MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES RELATING TO NON-CASH COMPENSATION THAT WAS RELEVANT FOR ITS NON-CASH COMPENSATION MONITORING COMPLIANCE AND FINRA'S NON-CASH COMPENSATION RULES. Initiated By: FINRA Date Initiated: 01/04/2010 Docket/Case Number: 2007007126202

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/04/2010 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE THE FIRM IS FINED $5,000. i Disclosure 161 of 336 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULE G-36: THE FIRM ACTING AS AN UNDERWRITER IN PRIMARY OFFERINGS AND ADVANCES REFUNDING OF MUNICIPAL SECURITIES FAILED TO SUBMIT FORMS G-36(OS) AND RELATED OFFICIAL STATEMENTS WITH THE MSRB IN A TIMELY MANNER, AS WELL AS, FAILED TO SUBMIT FORMS G-36(ARD) AND RELATED ADVANCE REFUNDING DOCUMENTS TO THE MSRB IN A TIMELY MANNER. THE FIRM ALSO SUBMITTED A FORM G- 36(OS) WITH INACCURATE INFORMATION. Initiated By: FINRA Date Initiated: 01/04/2010 Docket/Case Number: 2007007126201

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

WITHIN 30 DAYS AFTER THE AWC IS ACCEPTED BY FINRA, THE FIRM PRINCIPAL SHALL CERTIFY THAT THE FIRM IS CURRENTLY FULLY IN COMPLIANCE WITH MSRB RULE G-36 (OR ANY SUCCESSOR RULE). THEREAFTER, THE FIRM, THROUGH A PRINCIPAL, SHALL CERTIFY, ON A QUARTERLY BASIS FOR A PERIOD OF ONE YEAR THAT IT IS FULLY IN COMPLIANCE WITH MSRB RULE G-36 (OR ANY SUCCESSOR RULE). i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGED THE FIRM VIOLATED MSRB RULE G-36 BY ACTING AS AN UNDERWRITER IN PRIMARY OFFERINGS AND ADVANCES REFUNDING OF MUNICIPAL SECURITIES FAILED TO SUBMIT FORMS G-36 (OS) AND RELATED OFFICIAL STATEMENTS WITH THE MSRB IN A TIMELY MANNER, AS WELL AS, FAILED TO SUBMIT FORMS G-36(ARD) AND RELATED ADVANCE REFUNDING DOCUMENTS TO THE MSRB IN A TIMELY MANNER. IT IS ALSO ALLEGED THE FIRM SUBMITTED A FORM G-36(OS) WITH INACCURATE INFORMATION. Initiated By: FINRA Date Initiated: 01/04/2010 Docket/Case Number: 2007007126201

Principal Product Type: Other Other Product Type(s): MUNICIPAL SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 364 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: 01/04/2010 Sanctions Ordered: Censure Monetary/Fine $7,500.00 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 AND FINED $7,500. WITHIN 30 DAYS AFTER THE AWC IS ACCEPTED BY FINRA, THE FIRM PRINCIPAL SHALL CERTIFY THAT THE FIRM IS CURRENTLY FULLY IN COMPLIANCE WITH MSRB RULE G-36 (OR ANY SUCCESSOR RULE). THEREAFTER, THE FIRM, THROUGH A PRINCIPAL, SHALL CERTIFY, ON A QUARTERLY BASIS FOR A PERIOD OF ONE YEAR THAT IT IS FULLY IN COMPLIANCE WITH MSRB RULE G-36 (OR ANY SUCCESSOR RULE). i Disclosure 162 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF MICHIGAN OFFICE OF FINANCIAL AND INSURANCE REGULATION Date Initiated: 11/19/2009 Docket/Case Number: N/A

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

Resolution: Consent Resolution Date: 11/19/2009 Sanctions Ordered: Monetary/Fine $59,829.65 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF SECTION 204(A)(1)(G) OF THE UNIFORM SECURITIES ACT, MCL 451.604(A)(1)(G)AND SECTION 204(A)(2) OF THE UNIFORM SECURITIES ACT, MCL 451.604(A)(2). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 163 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION Date Initiated: 10/26/2009 Docket/Case Number: SEC-2009-00053

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 10/26/2009 Sanctions Ordered: Monetary/Fine $272,001.82 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF 13.1-506 7 OF THE ACT AND COMMISSION RULES 21 VAC 5-20-260 A AND B AND 21 VAC 5-20-280 A 3 AND E 12. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 164 of 336 Reporting Source: Regulator Current Status: Final Allegations: THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0031, CITED THE FIRM WITH ENGAGING IN UNETHICAL AND DISHONEST PRACTICES AND FAILURE TO PROPERLY SUPERVISE ITS AGENTS. THIS ACTION STEMMED FROM THE FIRMS INAPPROPRIATE MARKETING OF AUCTION RATE SECURITIES (ARS) TO CUSTOMERS WITHOUT ADEQUATELY DISCLOSING RISKS OF ILLIQUIDITY Initiated By: ALABAMA SECURITIES COMMISSION Date Initiated: 10/20/2009 Docket/Case Number: CO-2009-0031 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 367 www.finra.org/brokercheck User Guidance

Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CONSENT ORDER Sought:

Resolution: Consent Resolution Date: 10/21/2009 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 $25,251.71 Other Sanctions Ordered: Sanction Details: $25,251.71 TO ALABAMA SECURITIES COMMISSION Regulator Statement THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0031, CITED THE FIRM WITH ENGAGING IN UNETHICAL AND DISHONEST PRACTICES AND FAILURE TO PROPERLY SUPERVISE ITS AGENTS. THIS ACTION STEMMED FROM THE FIRMS INAPPROPRIATE MARKETING OF AUCTION RATE SECURITIES (ARS) TO CUSTOMERS WITHOUT ADEQUATELY DISCLOSING RISKS OF ILLIQUIDITY i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF ALABAMA SECURITIES COMMISSION Date Initiated: 10/20/2009 Docket/Case Number: CO-2009-0031

Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Undertaking ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 368 www.finra.org/brokercheck User Guidance

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

Resolution: Consent Resolution Date: 10/20/2009 Sanctions Ordered: Monetary/Fine $25,251.71 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF SECTION 8-6-17(B)(4) AND SECTION 8-6-3 (J)(10), CODE OF ALABAMA 1975, THE ALABAMA SECURITIES ACT. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 165 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION MARKETED AND SOLD AUCTION RATE SECURITIES AS MONEY-MARKET ALTERNATIVES, CASH EQUIVALENTS AND/OR LIQUID INVESTMENTS; DID NOT PROVIDE THE FINANCIAL ADVISERS WITH ADEQUATE TRAINING AND INFORMATION NECESSARY TO EXPLAIN AUCTION RATE SECURITIES OR THE MECHANICS OF THE AUCTION PROCESS; CONTINUED SELLING AUCTION RATE SECURITIES WHILE IT CONTEMPLATED TO NO LONGER SUPPORT THE AUCTIONS. INCREASED COMMISSIONS TO ITS FINANCIAL ADVISERS TO BOOST SALES OF AUCTION RATE SECURITIES JUST MONTHS BEFORE THE MARKET SEIZED UP. Initiated By: TEXAS Date Initiated: 10/16/2009 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 369 www.finra.org/brokercheck User Guidance

Date Initiated: 10/16/2009 Docket/Case Number: IC09-CDO-25 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 10/16/2009 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 $163,144.22 Cease and Desist/Injunction Other Sanctions Ordered: RBC SHALL CEASE AND DESIST FROM VIOLATING THE TEXAS SECURITIES ACT AND WILL COMPLY WITH THE TEXAS SECURITIES ACT. Sanction Details: NO OTHER SANCTIONS FOLLOW. i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: TEXAS STATE SECURITIES BOARD Date Initiated: 10/16/2009 Docket/Case Number: IC09-CDO-25

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

Resolution: Consent Resolution Date: 10/16/2009 Sanctions Ordered: Monetary/Fine $163,144.22 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF 115.10(B)(1) OF THE BOARD RULES. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 166 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF COLORADO SECURITIES COMMISSIONER Date Initiated: 09/03/2009 Docket/Case Number: 10-6-0G

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

Resolution: Consent Resolution Date: 09/03/2009 Sanctions Ordered: Monetary/Fine $184,012.08 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF 11-51-410(1)(G) AND (I), C.R.S. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 167 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF CALIFORNIA COMMISSIONER OF CORPORATIONS Date Initiated: 09/30/2009 Docket/Case Number: N/A

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

Resolution: Consent Resolution Date: 09/30/2009 Sanctions Ordered: Monetary/Fine $692,790.55 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF TITLE 10, CH. 3, SECTIONS 260.218 AND 260.218.4(A) OF THE CALIFORNIA CODE OF REGULATIONS. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 168 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF NEVADA SECURITIES DIVISION Date Initiated: 09/28/2009 Docket/Case Number: I09-152

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

Resolution: Consent Resolution Date: 09/28/2009 Sanctions Ordered: Monetary/Fine $83,476.79 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF NRS 90.420(1), SUBSECTIONS (H) AND (L). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 169 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF NEBRASKA DEPARTMENT OF BANKING & FINANCE Date Initiated: 08/21/2009 Docket/Case Number: N/A

Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Undertaking Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 374 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 08/21/2009 Sanctions Ordered: Monetary/Fine $25,158.55 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF NEB. REV. STAT. 8-1103(9)(A)(VII) AND (XI)(REISSUE 2007). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 170 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: COMMONWEALTH OF KENTUCKY DEPARTMENT OF FINANCIAL INSTITUTIONS Date Initiated: 10/08/2009 Docket/Case Number: 2009-AH-67

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

Resolution: Consent Resolution Date: 10/08/2009 Sanctions Ordered: Monetary/Fine $52,516.58 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF KRS 292.330(13)(A)7 AND KRS 292.330(13)(A)9A. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 171 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: IOWA INSURANCE DIVISION Date Initiated: 08/31/2009 Docket/Case Number: 65430

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

Resolution: Consent Resolution Date: 08/31/2009 Sanctions Ordered: Monetary/Fine $117,573.39 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF IOWA CODE SECTION 502.412(4)(M)(2009) AND IOWA CODE SECTION 502.412(4)(I)(2009). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 172 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: SECURITIES COMMISSIONER FOR THE STATE OF DELAWARE Date Initiated: 09/01/2009 Docket/Case Number: 09-7-5

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

Resolution: Consent Resolution Date: 09/01/2009 Sanctions Ordered: Monetary/Fine $22,115.32 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF 6 DEL. C. SECS. 7316(A)(7) AND (10). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 173 of 336 Reporting Source: Regulator Current Status: Final Allegations: ON AUGUST 31, 2009, THE SECURITIES DIVISION ENTERED INTO A CONSENT ORDER WITH RBC CAPITAL MARKETS CORPORATION ("RESPONDENT"), IN ORDER TO SETTLE THE ALLEGATIONS THAT RESPONDENT ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OF AUCTION RATE SECURITIES ("ARS"), AND FAILED TO SUPERVISE REASONABLY ITS SALESPERSONS AND EMPLOYEES IN THE MARKETING AND SALE OF ARS. RESPONDENT NEITHER ADMITTED NOR DENIED THE ALLEGATIONS. RESPONDENT AGREED TO BUY BACK AT PAR ARS THAT FAILED AT AUCTION AT LEAST ONCE BETWEEN OCTOBER 3, 2008 AND JUNE 30, 2009 FROM INVESTORS WHO PURCHASED THE ARS FROM OR THROUGH RESPONDENT PRIOR TO FEBRUARY 11, 2008 INTO AN ACCOUNT MAINTAINED IN THE CUSTODY OF RESPONDENT. RESPONDENT AGREED TO CEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OF WASHINGTON AND PAY A CIVIL PENALTY OF $41,042.35. RESPONDENT WAIVED ITS RIGHT TO A HEARING AND TO JUDICIAL REVIEW OF THIS ©2021 FINRA. All rights reserved. Report aboutMATTER. RBC CAPITAL MARKETS, LLC 378 ON AUGUST 31, 2009, THE SECURITIES DIVISION ENTERED INTO A CONSENT ORDER WITH RBC CAPITAL MARKETS CORPORATION ("RESPONDENT"), IN ORDER TO SETTLE THE ALLEGATIONS THAT RESPONDENT ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OF AUCTION RATE SECURITIES ("ARS"), AND FAILED TO SUPERVISE REASONABLY ITS SALESPERSONS AND EMPLOYEES IN THE MARKETING AND SALE OF ARS. RESPONDENT NEITHER ADMITTED NOR DENIED THE ALLEGATIONS. RESPONDENT AGREED TO BUY BACK AT PAR ARS THAT FAILED AT AUCTION AT LEAST ONCE BETWEEN OCTOBER 3, 2008 AND JUNE 30, 2009 FROM INVESTORS WHO PURCHASED THE ARS www.finra.org/brokercheck FROM OR THROUGH RESPONDENT PRIOR TO FEBRUARY 11, 2008 INTO AN User Guidance ACCOUNT MAINTAINED IN THE CUSTODY OF RESPONDENT. RESPONDENT AGREED TO CEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OF WASHINGTON AND PAY A CIVIL PENALTY OF $41,042.35. RESPONDENT WAIVED ITS RIGHT TO A HEARING AND TO JUDICIAL REVIEW OF THIS MATTER. Initiated By: WASHINGTON Date Initiated: 08/31/2009 Docket/Case Number: S-09-167-09-CO01 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 08/31/2009 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 $41,042.35 Cease and Desist/Injunction Other Sanctions Ordered: RBC SHALL PAY A TOTAL CIVIL PENALTY OF NINE MILLION EIGHT HUNDRED THOUSAND DOLLARS ($9,800,000) TO THE STATE OF WASHINGTON AND TO THOSE STATES AND TERRITORIES THAT ENTER ADMINISTRATIVE OR CIVIL CONSENT ORDERS APPROVING THE TERMS OF THE NASAA SETTLEMENT, OF WHICH $41,042.35 SHALL BE PAID TO THE STATE OF WASHINGTON. Sanction Details: RBC SHALL CEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OF WASHINGTON AND WILL COMPLY WITH THE SECURITIES ACT OF WASHINGTON. Regulator Statement CONTACT JACK MCCLELLAN 360-902-8732 i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ©2021 FINRA. All rights reserved. Report aboutASSOCIATED RBC CAPITAL WITH MARKETS, AUCTION LLC RATE SECURITIES THAT RBC UNDERWROTE, 379 MARKETED AND SOLD. www.finra.org/brokercheck User Guidance

Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS SECURITIES DIVISION Date Initiated: 08/31/2009 Docket/Case Number: S-09-167-09-CO01

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

Resolution: Consent Resolution Date: 08/31/2009 Sanctions Ordered: Monetary/Fine $41,042.35 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF RCW 21.20.110(1)(G) AND RCW 21.20.110(1)(J). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 174 of 336 Reporting Source: Regulator Current Status: Final Allegations: CONDUCT RESULTING IN THE VIOLATION OF 485-15(7) DISHONEST OR ©2021 FINRA. All rights reserved. Report aboutUNETHICAL RBC CAPITAL PRACTICS MARKETS, AND LLC 485-15(10) FAILURE TO SUPERVISE. 380 www.finra.org/brokercheck User Guidance

Allegations: CONDUCT RESULTING IN THE VIOLATION OF 485-15(7) DISHONEST OR UNETHICAL PRACTICS AND 485-15(10) FAILURE TO SUPERVISE. Initiated By: HAWAII Date Initiated: 05/26/2009 Docket/Case Number: SEU-2009-26 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST FROM VIOLATING SECTIONS 485-15(7) AND 485-15(10), Sought: HAWAII REVISED STATUTES.

Resolution: Consent Resolution Date: 09/02/2009 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 $19,600.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: RBC PAID AN ADMINISTRATIVE PENALTY OF $19,600.00 TO THE STATE OF HAWAII. i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF HAWAII Date Initiated: 05/26/2009 Docket/Case Number: SEU-2009-26

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

Resolution: Consent Resolution Date: 09/02/2009 Sanctions Ordered: Monetary/Fine $19,600.00 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF SECTIONS 485-15(7) AND 485-15(10), HAWAII REVISED STATUTES. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 175 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, DIVISION OF FINANCE AND CORPORATE SECURITIES, ENFORCEMENT SECTION Date Initiated: 08/07/2009

Docket/Case Number: S-09-0035

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

Resolution: Consent Resolution Date: 08/07/2009 Sanctions Ordered: Monetary/Fine $24,149.32 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF ORS 59.205(2) AND ORS 59.205(13). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 176 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: OFFICE OF THE MISSISSIPPI SECRETARY OF STATE SECURITIES AND CHARITIES DIVISION Date Initiated: 07/07/2009

Docket/Case Number: S-09-0189

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

Resolution: Consent Resolution Date: 07/07/2009 Sanctions Ordered: Monetary/Fine $107,946.85 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF MISS. CODE ANN. SECTIONS 75-71-321(A)(F) AND 75- 71-321(B)(A). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 177 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: DEPARTMENT OF FINANCE OF THE STATE OF IDAHO Date Initiated: 07/14/2009

Docket/Case Number: 2009-7-15

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

Resolution: Consent Resolution Date: 07/14/2009 Sanctions Ordered: Monetary/Fine $21,432.15 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF IDAHO CODE 30-14-412(D)(13) AND 30-14-412(D)(9). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 178 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION Date Initiated: 08/04/2009 Docket/Case Number: 09-196 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 385 www.finra.org/brokercheck User Guidance

Docket/Case Number: 09-196

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

Resolution: Consent Resolution Date: 08/04/2009 Sanctions Ordered: Monetary/Fine $21,913.48 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF 7-11-212(8) AND 7-11-212(11). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 179 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF MAINE OFFICE OF SECURITIES Date Initiated: 08/06/2009 Docket/Case Number: 09-073

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

Resolution: Consent Resolution Date: 08/06/2009 Sanctions Ordered: Monetary/Fine $20,997.40 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF 32 M.R.S.A. 16412(4)M, AND 32 M.R.S.A. 16412(4)I. Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 180 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: ARIZONA CORPORATION COMMISSION Date Initiated: 06/02/2009 Docket/Case Number: S-20684A-09-0281

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

Resolution: Consent Resolution Date: 06/02/2009 Sanctions Ordered: Monetary/Fine $37,067.52 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF A.R.S. 44-1961(A)(12) AND (13). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 181 of 336 Reporting Source: Regulator Current Status: Final Allegations: RBC AND ITS SUBSIDIARIES AND AFFILIATES INCLUDING FERRIS, BAKER WATTS, LLC AND J.B. HANAUER & CO. HAVE ENGAGED IN THE SALE OF ARS IN THE STATE OF MISSOURI IN VIOLATION OF SECTION 409.4- 412(D)(13), RSMO. (CUM. SUPP. 2008) AND SECTION 409.4-412(D)(9), RSMO. (CUM. SUPP. 2008). Initiated By: MISSOURI Date Initiated: 07/30/2009 Docket/Case Number: AP-09-32 URL for Regulatory Action:

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

Resolution: Consent Resolution Date: 07/30/2009 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 $9,800,000.00 Cease and Desist/Injunction Other Sanctions Ordered: RBC SHALL CEASE AND DESIST FROM VIOLATING THE MISSOURI SECURITIES ACT OF 2003 AND WILL COMPLY WITH THE MISSOURI SECURITIES ACT OF 2003. NO LATER THAN 10 BUSINESS DAYS AFTER SIGNING THIS ORDER, RBC SHALL PAY A TOTAL CIVIL PENALTY OF $9,800,000 TO THE STATE OF MISSOURI AND TO THOSE STATES AND TERRITORIES THAT ENTER ADMINISTRATIVE OR CIVIL CONSENT ORDERS APPROVING THE TERMS OF THE NASAA SETTLEMENT, OF WHICH $22,534.54 SHALL BE PAID TO THE STATE OF MISSOURI. Sanction Details: SEE ABOVE i Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: OFFICE OF THE MISSOURI SECRETARY OF STATE Date Initiated: 07/30/2009 Docket/Case Number: AP-09-32

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

Resolution: Consent Resolution Date: 07/30/2009 Sanctions Ordered: Monetary/Fine $22,534.54 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF SECTION 409.4-412(D)(13), RSMO. (CUM. SUPP. 2008) AND SECTION 409.4-412(D)(9), RSMO. (CUM. SUPP. 2008). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 182 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF INDIANA OFFICE OF THE SECRETARY OF STATE SECURITIES DIVISION Date Initiated: 06/02/2009 Docket/Case Number: 09-0117 CO

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

Resolution: Consent Resolution Date: 06/02/2009 Sanctions Ordered: Monetary/Fine $38,666.77 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF IND. CODE 23-19-4-12(D)(13) AND IND. CODE 23-19-4- 12(D)(9). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 183 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: MONTANA STATE AUDITOR AND COMMISSIONER OF SECURITIES Date Initiated: 06/02/2009 Docket/Case Number: SEC-2009-34

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

Resolution: Consent Resolution Date: 06/02/2009 Sanctions Ordered: Monetary/Fine $20,733.04 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF MONT. CODE ANN 30-10-201(13)(G) AND 30-10- 201(13)(K). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 184 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF NORTH DAKOTA SECURITIES DEPARTMENT Date Initiated: 06/02/2009 Docket/Case Number: NONE

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

Resolution: Consent Resolution Date: 06/02/2009 Sanctions Ordered: Monetary/Fine $19,600.00 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF N.D.C.C. 10-04-11(1)(C) AND N.D.C.C. 10-04-11(1)(M). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 185 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION Date Initiated: 06/02/2009 Docket/Case Number: 09-067-S

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

Resolution: Consent Resolution Date: 06/02/2009 Sanctions Ordered: Monetary/Fine $19,600.00 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF 9 V.S.A. 5412(D)(13) AND 9 V.S.A. 5412(D)(9). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 186 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE SECURITIES DIVISION Date Initiated: 06/02/2009 Docket/Case Number: 09SEC056

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

Resolution: Consent Resolution Date: 06/02/2009 Sanctions Ordered: Monetary/Fine $143,068.21 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF N.C.G.S. 78A-39(A)(2)(G) AND 78A-39(A1)(2)(A). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 187 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE AND REGULATION DIVISION OF SECURITIES Date Initiated: 06/02/2009 Docket/Case Number: NONE

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

Resolution: Consent Resolution Date: 06/02/2009 Sanctions Ordered: Monetary/Fine $26,323.06 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATION OF SDCL 47-31B-412(D)(13) AND SDCL 47-31B-412(D)(9). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 188 of 336 Reporting Source: Firm Current Status: Final Allegations: RBC CAPITAL MARKETS CORPORATION FAILED TO DISCLOSE IN COMMUNICATIONS WITH CUSTOMERS THE INCREASING RISKS ASSOCIATED WITH AUCTION RATE SECURITIES THAT RBC UNDERWROTE, MARKETED AND SOLD. Initiated By: OFFICE OF THE ATTORNEY GENERAL OF THE STATE OF NEW YORK Date Initiated: 06/02/2009 Docket/Case Number:

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

Resolution: Consent Resolution Date: 06/02/2009 Sanctions Ordered: Monetary/Fine $2,378,386.29 Cease and Desist/Injunction Other Sanctions Ordered: THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. Sanction Details: THE FIRM CONSENTED TO ENTRY OF A JUDGMENT ENJOINING THE FIRM FROM VIOLATING THE MARTIN ACT, GENERAL BUSINESS LAW SECTION 349 AND/OR EXECUTIVE LAW SECTION 63(12). Firm Statement THE FIRM UNDERTOOK TO REPURCHASE AUCTION RATE SECURITIES FROM CERTAIN CUSTOMERS BEFORE JUNE 30, 2009. THE FIRM ALSO UNDERTOOK TO USE BEST EFFORTS TO PROVIDE, BY DECEMBER 31, 2009, LIQUIDITY OPPORTUNITIES FOR CUSTOMERS INELIGIBLE FOR THE BUYBACK. THE FIRM UNDERTOOK TO PROVIDE PERIODIC REPORTS TO THE REGULATOR. i Disclosure 189 of 336 Reporting Source: Regulator Current Status: Final Allegations: SECTIONS 15(A)(1) AND 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES 17A-3 AND 17A-4 THEREUNDER; NASD RULES 2110, 2420, 3010 AND 3110, NYSE RULE 345(A): RESPONDENT RBC CAPITAL MARKETS CORP. PERMITTED A NON-REGISTERED FINDER TO ACT IN THE CAPACITY OF A REGISTERED BROKER-DEALER IN THE CONDUCT OF CERTAIN STOCK LOAN TRANSACTIONS AND MADE OR CAUSED PROFIT-BASED PAYMENTS TO BE MADE TO THE NON-REGISTERED FINDER. RBC ALLOWED THE NON- REGISTERED FINDER TO NEGOTIATE THE TERMS OF THE STOCK LOAN TRANSACTIONS, SELECT THE COUNTERPARTIES TO THOSE TRANSACTIONS, AND WAS AWARE OF AND ARRANGED WITH THE NON- REGISTERED FINDER FOR ANOTHER BROKER-DEALER TO MAKE PAYMENT ©2021 FINRA. All rights reserved. Report aboutTO THE RBC CAPITALNON-REGISTERED MARKETS, LLC FINDER BASED ON THE PROFITS OF RELATED 397 ARBITRAGE TRANSACTIONS. RBC ALSO FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF ITS STOCK LOAN DEPARTMENT IN THAT IT DID NOT HAVE ADEQUATE SUPERVISORY PROCEDURES IN PLACE TO DETECT AND DETER THESE TYPES OF TRANSACTIONS AND PAYMENTS. IN ADDITION, RBC FAILED TO MAKE AND KEEP ACCURATE RECORDS REFLECTING ITS STOCK LOAN ACTIVITIES. SECTIONS 15(A)(1) AND 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES 17A-3 AND 17A-4 THEREUNDER; NASD RULES 2110, 2420, 3010 AND 3110, NYSE RULE 345(A): RESPONDENT RBC CAPITAL MARKETS CORP. PERMITTED A NON-REGISTERED FINDER TO ACT IN THE CAPACITY OF A REGISTERED BROKER-DEALER IN THE CONDUCT OF CERTAIN STOCK LOAN TRANSACTIONS AND MADE OR CAUSED PROFIT-BASED PAYMENTS www.finra.org/brokercheck TO BE MADE TO THE NON-REGISTERED FINDER. RBC ALLOWED THE NON- User Guidance REGISTERED FINDER TO NEGOTIATE THE TERMS OF THE STOCK LOAN TRANSACTIONS, SELECT THE COUNTERPARTIES TO THOSE TRANSACTIONS, AND WAS AWARE OF AND ARRANGED WITH THE NON- REGISTERED FINDER FOR ANOTHER BROKER-DEALER TO MAKE PAYMENT TO THE NON-REGISTERED FINDER BASED ON THE PROFITS OF RELATED ARBITRAGE TRANSACTIONS. RBC ALSO FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF ITS STOCK LOAN DEPARTMENT IN THAT IT DID NOT HAVE ADEQUATE SUPERVISORY PROCEDURES IN PLACE TO DETECT AND DETER THESE TYPES OF TRANSACTIONS AND PAYMENTS. IN ADDITION, RBC FAILED TO MAKE AND KEEP ACCURATE RECORDS REFLECTING ITS STOCK LOAN ACTIVITIES. Initiated By: FINRA Date Initiated: 03/16/2009 Docket/Case Number: 2007011878501

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/16/2009 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 $400,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS CORP. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $400,000. i Reporting Source: Firm Current Status: Final Allegations: SECTIONS 15(A)(1) AND 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES 17A-3 AND 17A-4 THEREUNDER; NASD RULES 2110, 2420, 3010 AND 3110, NYSE RULE 345(A): RESPONDENT RBC CAPITAL MARKETS ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 398 CORPORATION PERMITTED A NON-REGISTERED FINDER TO ACT IN THE CAPACITY OF A REGISTERED BROKER-DEALER IN THE CONDUCT OF CERTAIN STOCK LOAN TRANSACTIONS AND MADE OR CAUSED PROFIT- BASED PAYMENTS TO BE MADE TO THE NON-REGISTERED FINDER. RBC ALLOWED THE NON-REGISTERED FINDER TO NEGOTIATE THE TERMS OF THE STOCK LOAN TRANSACTIONS, SELECT THE COUNTERPARTIES TO THOSE TRANSACTIONS, AND WAS AWARE OF AND ARRANGED WITH THE NON-REGISTERED FINDER FOR ANOTHER BROKER-DEALER TO MAKE PAYMENT TO THE NON-REGISTERED FINDER BASED ON THE PROFITS OF RELATED ARBITRAGE TRANSACTIONS. RBC ALSO FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF ITS STOCK LOAN DEPARTMENT IN THAT IT DID NOT HAVE ADEQUATE SUPERVISORY PROCEDURES IN PLACE TO DETECT AND DETER THESE TYPES OF TRANSACTIONS AND PAYMENTS. www.finra.org/brokercheck User Guidance

SECTIONS 15(A)(1) AND 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES 17A-3 AND 17A-4 THEREUNDER; NASD RULES 2110, 2420, 3010 AND 3110, NYSE RULE 345(A): RESPONDENT RBC CAPITAL MARKETS CORPORATION PERMITTED A NON-REGISTERED FINDER TO ACT IN THE CAPACITY OF A REGISTERED BROKER-DEALER IN THE CONDUCT OF CERTAIN STOCK LOAN TRANSACTIONS AND MADE OR CAUSED PROFIT- BASED PAYMENTS TO BE MADE TO THE NON-REGISTERED FINDER. RBC ALLOWED THE NON-REGISTERED FINDER TO NEGOTIATE THE TERMS OF THE STOCK LOAN TRANSACTIONS, SELECT THE COUNTERPARTIES TO THOSE TRANSACTIONS, AND WAS AWARE OF AND ARRANGED WITH THE NON-REGISTERED FINDER FOR ANOTHER BROKER-DEALER TO MAKE PAYMENT TO THE NON-REGISTERED FINDER BASED ON THE PROFITS OF RELATED ARBITRAGE TRANSACTIONS. RBC ALSO FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF ITS STOCK LOAN DEPARTMENT IN THAT IT DID NOT HAVE ADEQUATE SUPERVISORY PROCEDURES IN PLACE TO DETECT AND DETER THESE TYPES OF TRANSACTIONS AND PAYMENTS. Initiated By: FINRA Date Initiated: 03/16/2009 Docket/Case Number: 2007011878501

Principal Product Type: Other Other Product Type(s): STOCK LOANS 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: 03/16/2009 Sanctions Ordered: Censure Monetary/Fine $400,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RBC CAPITAL MARKETS CORPORATION CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $400,000. i Disclosure 190 of 336 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMINISTRATIVE RELEASE 34-59439, FEBRUARY 24, 2009: THE ©2021 FINRA. All rights reserved. Report aboutSECURITIES RBC CAPITAL AND MARKETS, EXCHANGE LLC COMMISSION ("COMMISSION") DEEMS IT 399 APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B)(4), 15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AGAINST RBC CAPITAL MARKETS CORPORATION ("RBC") BASED ON RBC'S VIOLATIONS OF THE FAIR DEALING, GIFTS AND GRATUITIES, AND SUPERVISORY RULES OF THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") FOR ADVANCES MADE ON BEHALF OF AND EXPENSES REIMBURSED TO ONE OF ITS MUNICIPAL CLIENTS DURING THE CLIENT'S MUNICIPAL BOND ISSUANCE PROCESS. THE COMMISSION ALLEGES THAT OFFICIALS OF RBC'S CLIENT TRAVELED TO NEW YORK CITY ON A NEARLY ANNUAL BASIS TO MEET WITH ANALYSTS FROM CREDIT RATING AGENCIES, AND DURING THESE TRIPS BROUGHT FAMILY MEMBERS, DINED AT UPSCALE RESTAURANTS, ATTENDED BROADWAY SHOWS AND SPORTING EVENTS, AND HAD ACCESS TO A PRIVATE CAR SERVICE. THE COMMISSION ALLEGES THAT RBC, UPON INSTRUCTIONS FROM A REPRESENTATIVE OF THEIR CLIENT, ORGANIZED THE ACTIVITIES FOR THE TRIPS, AND THEN ADVANCED THE PAYMENT FOR NEARLY ALL OF THE EXPENSES INCURRED BY THE CLIENT'S OFFICIALS AND THEIR FAMILY MEMBERS. RBC THEN OBTAINED, WITH THE KNOWLEDGE AND APPROVAL OF CERTAIN OFFICIALS OF THE CLIENT, REIMBURSEMENT FOR ALL EXPENSES INCURRED ON THE TRIPS AS A COST OF ISSUANCE, DIRECTLY FROM BOND PROCEEDS AT CLOSING. AS A RESULT OF THESE ACTIVITIES, RBC VIOLATED MSRB RULES G-17, G-20 AND G-27, AND WILLFULLY VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT. www.finra.org/brokercheck User Guidance

Allegations: SEC ADMINISTRATIVE RELEASE 34-59439, FEBRUARY 24, 2009: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B)(4), 15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AGAINST RBC CAPITAL MARKETS CORPORATION ("RBC") BASED ON RBC'S VIOLATIONS OF THE FAIR DEALING, GIFTS AND GRATUITIES, AND SUPERVISORY RULES OF THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") FOR ADVANCES MADE ON BEHALF OF AND EXPENSES REIMBURSED TO ONE OF ITS MUNICIPAL CLIENTS DURING THE CLIENT'S MUNICIPAL BOND ISSUANCE PROCESS. THE COMMISSION ALLEGES THAT OFFICIALS OF RBC'S CLIENT TRAVELED TO NEW YORK CITY ON A NEARLY ANNUAL BASIS TO MEET WITH ANALYSTS FROM CREDIT RATING AGENCIES, AND DURING THESE TRIPS BROUGHT FAMILY MEMBERS, DINED AT UPSCALE RESTAURANTS, ATTENDED BROADWAY SHOWS AND SPORTING EVENTS, AND HAD ACCESS TO A PRIVATE CAR SERVICE. THE COMMISSION ALLEGES THAT RBC, UPON INSTRUCTIONS FROM A REPRESENTATIVE OF THEIR CLIENT, ORGANIZED THE ACTIVITIES FOR THE TRIPS, AND THEN ADVANCED THE PAYMENT FOR NEARLY ALL OF THE EXPENSES INCURRED BY THE CLIENT'S OFFICIALS AND THEIR FAMILY MEMBERS. RBC THEN OBTAINED, WITH THE KNOWLEDGE AND APPROVAL OF CERTAIN OFFICIALS OF THE CLIENT, REIMBURSEMENT FOR ALL EXPENSES INCURRED ON THE TRIPS AS A COST OF ISSUANCE, DIRECTLY FROM BOND PROCEEDS AT CLOSING. AS A RESULT OF THESE ACTIVITIES, RBC VIOLATED MSRB RULES G-17, G-20 AND G-27, AND WILLFULLY VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 02/24/2009 Docket/Case Number: 3-13379

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

Resolution: Order Resolution Date: 02/24/2009 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about RBC CAPITAL MARKETS, LLC 400 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 $125,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: RESPONDENT RBC HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER RBC AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RBC CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS PURSUANT TO SECTIONS 15(B)(4), 15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("ORDER"). ACCORDINGLY, PURSUANT TO SECTIONS 15(B)(4), 15B(C)(2) AND 21C OF THE EXCHANGE ACT, RBC IS CENSURED, FINED $125,000, AND SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15B(C)(1) OF THE EXCHANGE ACT, AND MSRB RULES G-17, G- 20 AND G-27. THE FINE IS DUE WITHIN 30 DAYS OF THE ENTRY OF THIS ORDER. i Reporting Source: Firm Current Status: Final Allegations: SEC ADMINISTRATIVE RELEASE 34-59439, FEBRUARY 24, 2009: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B)(4), 15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AGAINST RBC CAPITAL MARKETS CORPORATION ("RBC") BASED ON RBC'S VIOLATIONS OF THE FAIR DEALING, GIFTS AND GRATUITIES, AND SUPERVISORY RULES OF THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") FOR ADVANCES MADE ON BEHALF OF AND EXPENSES REIMBURSED TO ONE OF ITS MUNICIPAL CLIENTS DURING THE CLIENT'S MUNICIPAL BOND ISSUANCE PROCESS. THE COMMISSION ©2021 FINRA. All rights reserved. Report aboutALLEGES RBC CAPITAL THAT MARKETS, OFFICIALS LLC OF RBC'S CLIENT TRAVELED TO NEW YORK 401 CITY ON A NEARLY ANNUAL BASIS TO MEET WITH ANALYSTS FROM CREDIT RATING AGENCIES, AND DURING THESE TRIPS BROUGHT FAMILY MEMBERS, DINED AT UPSCALE RESTAURANTS, ATTENDED BROADWAY SHOWS AND SPORTING EVENTS, AND HAD ACCESS TO A PRIVATE CAR SERVICE. THE COMMISSION ALLEGES THAT RBC, UPON INSTRUCTIONS FROM A REPRESENTATIVE OF THEIR CLIENT, ORGANIZED THE ACTIVITIES FOR THE TRIPS, AND THEN ADVANCED THE PAYMENT FOR NEARLY ALL OF THE EXPENSES INCURRED BY THE CLIENT'S OFFICIALS AND THEIR FAMILY MEMBERS. RBC THEN OBTAINED, WITH THE KNOWLEDGE AND APPROVAL OF CERTAIN OFFICIALS OF THE CLIENT, REIMBURSEMENT FOR ALL EXPENSES INCURRED ON THE TRIPS AS A COST OF ISSUANCE, DIRECTLY FROM BOND PROCEEDS AT CLOSING. AS A RESULT OF THESE ACTIVITIES, RBC VIOLATED MSRB RULES G-17, G-20 AND G-27, AND WILLFULLY VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT. SEC ADMINISTRATIVE RELEASE 34-59439, FEBRUARY 24, 2009: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B)(4), 15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AGAINST RBC CAPITAL MARKETS CORPORATION ("RBC") BASED ON RBC'S VIOLATIONS OF THE FAIR DEALING, GIFTS AND www.finra.org/brokercheck GRATUITIES, AND SUPERVISORY RULES OF THE MUNICIPAL SECURITIES User Guidance RULEMAKING BOARD ("MSRB") FOR ADVANCES MADE ON BEHALF OF AND EXPENSES REIMBURSED TO ONE OF ITS MUNICIPAL CLIENTS DURING THE CLIENT'S MUNICIPAL BOND ISSUANCE PROCESS. THE COMMISSION ALLEGES THAT OFFICIALS OF RBC'S CLIENT TRAVELED TO NEW YORK CITY ON A NEARLY ANNUAL BASIS TO MEET WITH ANALYSTS FROM CREDIT RATING AGENCIES, AND DURING THESE TRIPS BROUGHT FAMILY MEMBERS, DINED AT UPSCALE RESTAURANTS, ATTENDED BROADWAY SHOWS AND SPORTING EVENTS, AND HAD ACCESS TO A PRIVATE CAR SERVICE. THE COMMISSION ALLEGES THAT RBC, UPON INSTRUCTIONS FROM A REPRESENTATIVE OF THEIR CLIENT, ORGANIZED THE ACTIVITIES FOR THE TRIPS, AND THEN ADVANCED THE PAYMENT FOR NEARLY ALL OF THE EXPENSES INCURRED BY THE CLIENT'S OFFICIALS AND THEIR FAMILY MEMBERS. RBC THEN OBTAINED, WITH THE KNOWLEDGE AND APPROVAL OF CERTAIN OFFICIALS OF THE CLIENT, REIMBURSEMENT FOR ALL EXPENSES INCURRED ON THE TRIPS AS A COST OF ISSUANCE, DIRECTLY FROM BOND PROCEEDS AT CLOSING. AS A RESULT OF THESE ACTIVITIES, RBC VIOLATED MSRB RULES G-17, G-20 AND G-27, AND WILLFULLY VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 02/24/2009 Docket/Case Number: 3-13379

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief CIVIL & ADMINISTRATIVE PENALITIES/FINES AND CEASE & DESIST Sought:

Resolution: Order Resolution Date: 02/24/2009 Sanctions Ordered: Censure Monetary/Fine $125,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: RESPONDENT RBC HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER RBC AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RBC CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST ©2021 FINRA. All rights reserved. Report aboutPROCEEDINGS, RBC CAPITAL MARKETS, MAKING LLC FINDINGS, AND IMPOSING REMEDIAL SANCTIONS 402 PURSUANT TO SECTIONS 15(B)(4), 15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("ORDER"). ACCORDINGLY, PURSUANT TO SECTIONS 15(B)(4), 15B(C)(2) AND 21C OF THE EXCHANGE ACT, RBC IS CENSURED, FINED $125,000, AND SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15B(C)(1) OF THE EXCHANGE ACT, AND MSRB RULES G-17, G- 20 AND G-27. THE FINE IS DUE WITHIN 30 DAYS OF THE ENTRY OF THIS ORDER. RESPONDENT RBC HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO www.finra.org/brokercheck WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR User Guidance DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER RBC AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RBC CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS PURSUANT TO SECTIONS 15(B)(4), 15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("ORDER"). ACCORDINGLY, PURSUANT TO SECTIONS 15(B)(4), 15B(C)(2) AND 21C OF THE EXCHANGE ACT, RBC IS CENSURED, FINED $125,000, AND SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15B(C)(1) OF THE EXCHANGE ACT, AND MSRB RULES G-17, G- 20 AND G-27. THE FINE IS DUE WITHIN 30 DAYS OF THE ENTRY OF THIS ORDER. i Disclosure 191 of 336 Reporting Source: Regulator Current Status: Final Allegations: **9/11/08** STIPULATION OF FACTS AND CONSENT TO PENALTY FILED BY FINRA ENFORCEMENT ON BEHALF OF NYSE REGULATION'S DIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT, RBC CAPITAL MARKETS CORP. CONSENTS TO FINDINGS THAT IT VIOLATED: 1. NYSE RULE 411(B)(1) BY ENTERING FOR EXECUTION ON THE NYSE PROPRIETARY ODD-LOT ORDERS THAT AGGREGATE 100 SHARES OR MORE WITHOUT HAVING THOSE ORDERS CONSOLIDATED INTO ROUND LOTS AS FAR AS POSSIBLE; 2. NYSE RULE 476(A)(10) BY FILING WITH THE NYSE INACCURATE DAILY PROGRAM TRADE REPORTS; 3. NYSE RULE 476(A)(11) BY FAILING TO FILE CERTAIN DAILY PROGRAM TRADE INFORMATION WITH THE NYSE WITHIN THE REQUIRED TIME FRAMES; AND 4. NYSE RULE 342 (A) AND (B) BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULES AND POLICIES PERTAINING TO:(I) ODD-LOT ORDERS; AND (II) THE SUBMISSION OF DAILY PROGRAM TRADE REPORTS. STIPULATED SANCTION: THE IMPOSITION BY THE NYSE OF A PENALTY CONSISTING OF: A. A CENSURE; AND B. A $125,000 FINE. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 09/11/2008 Docket/Case Number: HBD# 08-43

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

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

Resolution: Decision Resolution Date: 10/08/2008 Sanctions Ordered: Censure Monetary/Fine $125,000.00 Other Sanctions Ordered: Sanction Details: **9/12/08** DECISION NO. 08-43 ISSUED BY NYSE HEARING BOARD DECISION: RESPONDENT FIRM RBC CAPITAL MARKETS CORP. VIOLATED (1) NYSE RULE 411(B)(1) BY ENTERING FOR EXECUTION ON THE NYSE PROPRIETARY ODD-LOT ORDERS THAT AGGREGATE 100 SHARES OR MORE WITHOUT HAVING THOSE ORDERS CONSOLIDATED INTO ROUND LOTS AS FAR AS POSSIBLE; (2) NYSE RULE 476(A)(10) BY FILING WITH THE NYSE INACCURATE DAILY PROGRAM TRADE REPORTS; (3) NYSE RULE 476(A)(11) BY FAILING TO FILE CERTAIN DAILY PROGRAM TRADE INFORMATION WITH THE NYSE WITHIN THE REQUIRED TIME FRAMES; AND NYSE RULE 342 (A) AND (B) BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULES AND POLICIES PERTAINING TO: (I) ODD-LOT ORDERS; AND (II) THE SUBMISSION OF DAILY PROGRAM TRADE REPORTS. SANCTION: CENSURE AND A $125,000 FINE. Regulator Statement **9/12/08** UNLESS A REVIEW HAS BEEN REQUESTED BY ANY PERSON OR BODY AUTHORIZED BY NYSE RULE 476(G), THIS DECISION WILL BECOME FINAL 25 CALENDAR DAYS AFTER NOTICE OF THE HEARING BOARD'S DETERMINATION HAS BEEN SERVED UPON THE RESPONDENT. **10/8/08** THE DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESS ON OCTOBER 7, 2008. THE FINE BECAME PAYABLE ON THAT SAME DATE. i Reporting Source: Firm Current Status: Final Allegations: **9/11/08** STIPULATION OF FACTS AND CONSENT TO PENALTY FILED BY FINRA ENFORCEMENT ON BEHALF OF NYSE REGULATION'S DIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT, RBC CAPITAL MARKETS CORP. CONSENTS TO FINDINGS THAT IT VIOLATED: 1. NYSE RULE 411(B)(1) BY ENTERING FOR EXECUTION ON THE NYSE PROPRIETARY ODD-LOT ORDERS THAT AGGREGATE 100 SHARES OR MORE WITHOUT HAVING THOSE ORDERS ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 404 CONSOLIDATED INTO ROUND LOTS AS FAR AS POSSIBLE; 2. NYSE RULE 476(A)(10) BY FILING WITH THE NYSE INACCURATE DAILY PROGRAM TRADE REPORTS; 3. NYSE RULE 476(A)(11) BY FAILING TO FILE CERTAIN DAILY PROGRAM TRADE INFORMATION WITH THE NYSE WITHIN THE REQUIRED TIME FRAMES; AND 4. NYSE RULE 342 (A) AND (B) BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULES AND POLICIES PERTAINING TO:(I) ODD-LOT ORDERS; AND (II) THE SUBMISSION OF DAILY PROGRAM TRADE REPORTS. STIPULATED SANCTION: THE IMPOSITION BY THE NYSE OF A PENALTY CONSISTING OF: A. A CENSURE; AND B. A $125,000 FINE. **9/11/08** STIPULATION OF FACTS AND CONSENT TO PENALTY FILED BY FINRA ENFORCEMENT ON BEHALF OF NYSE REGULATION'S DIVISION OF www.finra.org/brokercheck ENFORCEMENT AND PENDING CONSENTED TO FINDINGS: WITHOUT User Guidance ADMITTING OR DENYING GUILT, RBC CAPITAL MARKETS CORP. CONSENTS TO FINDINGS THAT IT VIOLATED: 1. NYSE RULE 411(B)(1) BY ENTERING FOR EXECUTION ON THE NYSE PROPRIETARY ODD-LOT ORDERS THAT AGGREGATE 100 SHARES OR MORE WITHOUT HAVING THOSE ORDERS CONSOLIDATED INTO ROUND LOTS AS FAR AS POSSIBLE; 2. NYSE RULE 476(A)(10) BY FILING WITH THE NYSE INACCURATE DAILY PROGRAM TRADE REPORTS; 3. NYSE RULE 476(A)(11) BY FAILING TO FILE CERTAIN DAILY PROGRAM TRADE INFORMATION WITH THE NYSE WITHIN THE REQUIRED TIME FRAMES; AND 4. NYSE RULE 342 (A) AND (B) BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULES AND POLICIES PERTAINING TO:(I) ODD-LOT ORDERS; AND (II) THE SUBMISSION OF DAILY PROGRAM TRADE REPORTS. STIPULATED SANCTION: THE IMPOSITION BY THE NYSE OF A PENALTY CONSISTING OF: A. A CENSURE; AND B. A $125,000 FINE. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 09/11/2008 Docket/Case Number: HBD# 08-43

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

Resolution: Stipulation and Consent Resolution Date: 10/08/2008 Sanctions Ordered: Censure Monetary/Fine $125,000.00 Other Sanctions Ordered: Sanction Details: **9/12/08** DECISION NO. 08-43 ISSUED BY NYSE HEARING BOARD DECISION: RESPONDENT FIRM RBC CAPITAL MARKETS CORP. VIOLATED (1) NYSE RULE 411(B)(1) BY ENTERING FOR EXECUTION ON THE NYSE PROPRIETARY ODD-LOT ORDERS THAT AGGREGATE 100 SHARES OR MORE WITHOUT HAVING THOSE ORDERS CONSOLIDATED INTO ROUND LOTS AS FAR AS POSSIBLE; (2) NYSE RULE 476(A)(10) BY FILING WITH THE NYSE INACCURATE DAILY PROGRAM TRADE REPORTS; (3) NYSE RULE 476(A)(11) BY FAILING TO FILE CERTAIN DAILY PROGRAM TRADE INFORMATION WITH THE NYSE WITHIN THE REQUIRED TIME FRAMES; AND NYSE RULE 342 (A) AND (B) BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW REASONABLY ©2021 FINRA. All rights reserved. Report aboutDESIGNED RBC CAPITAL TO ACHIEVE MARKETS, LLCCOMPLIANCE WITH NYSE RULES AND POLICIES 405 PERTAINING TO: (I) ODD-LOT ORDERS; AND (II) THE SUBMISSION OF DAILY PROGRAM TRADE REPORTS. SANCTION: CENSURE AND A $125,000 FINE. **9/12/08** DECISION NO. 08-43 ISSUED BY NYSE HEARING BOARD DECISION: RESPONDENT FIRM RBC CAPITAL MARKETS CORP. VIOLATED (1) NYSE RULE 411(B)(1) BY ENTERING FOR EXECUTION ON THE NYSE PROPRIETARY ODD-LOT ORDERS THAT AGGREGATE 100 SHARES OR MORE WITHOUT HAVING THOSE ORDERS CONSOLIDATED INTO ROUND LOTS AS FAR AS POSSIBLE; (2) NYSE RULE 476(A)(10) BY FILING WITH THE NYSE INACCURATE DAILY PROGRAM TRADE REPORTS; (3) NYSE RULE www.finra.org/brokercheck 476(A)(11) BY FAILING TO FILE CERTAIN DAILY PROGRAM TRADE User Guidance INFORMATION WITH THE NYSE WITHIN THE REQUIRED TIME FRAMES; AND NYSE RULE 342 (A) AND (B) BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULES AND POLICIES PERTAINING TO: (I) ODD-LOT ORDERS; AND (II) THE SUBMISSION OF DAILY PROGRAM TRADE REPORTS. SANCTION: CENSURE AND A $125,000 FINE. i Disclosure 192 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 1050 AND 2110: PERSONS ASSOCIATED WITH RESPONDENT RBC CAPITAL MARKETS CORPORATION FUNCTIONED AS RESEARCH ANALYSTS WITHOUT HAVING SERIES 86 OR 87 RESEARCH ANALYST REGISTRATIONS BY HAVING THEIR NAMES APPEAR ON RESEARCH REPORTS. THE UNREGISTERED ANALYSTS PUBLISHED MORE THAN 3,500 RESEARCH REPORTS, AND PUBLISHED MORE THAN 400 RESEARCH REPORTS AFTER RBC CAPITAL WAS INFORMED BY FINRA STAFF THAT IT HAD MADE A PRELIMINARY DETERMINATION (THE "WELLS NOTICE") TO RECOMMEND DISCIPLINARY ACTION BE INITIATED AGAINST THE FIRM FOR ITS FAILURE TO APPROPRIATELY REGISTER ITS RESEARCH ANALYSTS. THE LAST OF THOSE REPORTS CAME SEVEN MONTHS AFTER THE WELLS NOTICE. Initiated By: FINRA Date Initiated: 07/07/2008 Docket/Case Number: 2005002206701

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

Resolution: Decision & Order of Offer of Settlement Resolution Date: 07/08/2009 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 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 406 Monetary/Fine $150,000.00 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $150,000.00 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 $150,000. i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGES THAT THE FIRM VIOLATED THE PREDECESSOR VERSION OF NASD RULE 1050 BY ALLOWING RESEARCH ANALYSTS EMPLOYED BY THE FIRM'S CANADIAN AFFILIATE BROKER-DEALER TO ISSUE RESEARCH INTO THE UNITED STATES WITHOUT HAVING SERIES 86/87 REGISTRATIONS. Initiated By: FINRA Date Initiated: 07/07/2008 Docket/Case Number: 2005002206701

Principal Product Type: Options Other Product Type(s): RESEARCH Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief COMPLAINT REQUESTS THAT "ONE OR MORE OF THE SANCTIONS Sought: PROVIDED UNDER THE NASD RULE 8310(A) BE IMPOSED

Resolution: Decision & Order of Offer of Settlement Resolution Date: 07/08/2009 Sanctions Ordered: Censure Monetary/Fine $150,000.00 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 $150,000. Firm Statement 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 $150,000.

i Disclosure 193 of 336 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULE G-14 - RBC DAIN RAUSCHER INC. FAILED TO REPORT INFORMATION ABOUT TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS)IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL - THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES OF THE TIME OF TRADE TO AN RTRS PORTAL. Initiated By: FINRA Date Initiated: 01/10/2008 Docket/Case Number: 20060040596-01

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: 01/10/2008 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 $7,500.00 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 $7,500. i

Reporting Source: Firm Current Status: Final Allegations: SEASONGOOD & MAYER, LLC, A BROKER-DEALER ACQUIRED BY RBC DAIN RAUSCHER INC., ALLEGEDLY VIOLATED MSRB RULE G-14 BY FAILING TO REPORT INFORMATION ABOUT TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL - THE FIRM FAILED TO REPORT INFORMATIN ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES OF THE TIME OF TRADE TO AN RTRS PORTAL. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) Date Initiated: 01/10/2008 Docket/Case Number: 20060040596-01

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: 01/10/2008 Sanctions Ordered: Censure Monetary/Fine $7,500.00 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 $7,500. PAYMENT OF THE FINE IS IN PROCESS. Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $7,500. PAYMENT OF THE FINE IS IN PROCESS. i Disclosure 194 of 336 Reporting Source: Regulator

Current Status: Final Allegations: NASD RULE 3370 - RBC DAIN RAUSCHER ACCEPTED CUSTOMER SHORT SALES 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. Initiated By: FINRA Date Initiated: 01/03/2008 Docket/Case Number: 20041000189-01

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: 01/03/2008 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: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS FINED $5,000. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF NASD RULE 3370 - RBC DAIN RAUSCHER ACCEPTED CUSTOMER SHORT SALES IN CERTAIN SECURITIES AND, FOR EACH ORDER, FAILED TO MAKE/ANNOTATE AN AFFIRMATIVE DETERMINATION THAT THE FIRM WOULD RECEIVE DELIVERY OF THE ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 410 SECURITY ON BEHALF OF THE CUSTOMER OR THAT THE FIRM COULD BORROW THE SECURITY ON BEHALF OF THE CUSTOMER FOR DELIVERY BY SETTLEMENT DATE. www.finra.org/brokercheck User Guidance ALLEGED VIOLATIONS OF NASD RULE 3370 - RBC DAIN RAUSCHER ACCEPTED CUSTOMER SHORT SALES 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. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) Date Initiated: 01/03/2008 Docket/Case Number: 20041000189-01

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: 01/03/2008 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS FINED $5,000. THE FINE IS IN THE PROCESS OF PAYMENT AND WILL BE REMITTED BY NO LATER THAN JANUARY 30, 2008. Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS FINED $5,000. THE FINE IS IN THE PROCESS OF PAYMENT AND WILL BE REMITTED BY NO LATER THAN JANUARY 30, 2008. i Disclosure 195 of 336 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, RBC DAIN RAUSCHER, INC. CONSENTS TO FINDINGS THAT IT VIOLATED: 1. NYSE RULE 401(A) BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM FAILED TO ENSURE THE DELIVERY OF PROSPECTUSES IN CONNECTION WITH CERTAIN SALES OF ©2021 FINRA. All rights reserved. Report aboutREGISTERED RBC CAPITAL SECURITIES MARKETS, LLC IN VIOLATION OF SECTION 5(B)(2) OF THE 411 SECURITIES ACT OF 1933; 2. NYSE RULE 1100(B) BY FAILING TO DELIVER PRODUCT DESCRIPTIONS TO CUSTOMERS THAT PURCHASED EXCHANGE TRADED FUNDS; AND 3. NYSE RULE 342 BY FAILING 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. STIPULATED SANCTION: THE IMPOSITION BY THE NYSE OF: 1. CENSURE; 2. A FINE IN THE AMOUNT OF $500,000; AND 3. AN UNDERTAKING TO PROVIDE ENFORCEMENT WITH A WRITTEN CERTIFICATION THAT ITS 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. THE FIRM WILL PROVIDE ENFORCEMENT WITH THIS WRITTEN CERTIFICATION WITHIN 90 DAYS FROM THE DATE THAT A HEARING PANEL DECISION IN THIS MATTER BECOMES FINAL. **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, RBC DAIN www.finra.org/brokercheck RAUSCHER, INC. CONSENTS TO FINDINGS THAT IT VIOLATED: 1. NYSE User Guidance RULE 401(A) BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM 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; 2. NYSE RULE 1100(B) BY FAILING TO DELIVER PRODUCT DESCRIPTIONS TO CUSTOMERS THAT PURCHASED EXCHANGE TRADED FUNDS; AND 3. NYSE RULE 342 BY FAILING 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. STIPULATED SANCTION: THE IMPOSITION BY THE NYSE OF: 1. CENSURE; 2. A FINE IN THE AMOUNT OF $500,000; AND 3. AN UNDERTAKING TO PROVIDE ENFORCEMENT WITH A WRITTEN CERTIFICATION THAT ITS 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. THE FIRM WILL PROVIDE ENFORCEMENT WITH THIS WRITTEN CERTIFICATION WITHIN 90 DAYS FROM THE DATE THAT A HEARING PANEL DECISION IN THIS MATTER BECOMES FINAL. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 06/29/2007 Docket/Case Number: HBD# 07-127

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 $500,000.00 Other Sanctions Ordered: Sanction Details: **9/7/07** DECISION 07-127 ISSUED BY NYSE HEARING BOARD DECISION: RBC DAIN RAUSCHER, INC. CONSENTED TO FINDINGS THAT IT VIOLATED: 1. NYSE RULE 401(A) BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM FAILED TO ENSURE THE DELIVERY OF PROSPECTUSES IN CONNECTION WITH ©2021 FINRA. All rights reserved. Report aboutCERTAIN RBC CAPITAL SALES MARKETS, OF REGISTERED LLC SECURITIES IN VIOLATION OF SECTION 412 5(B)(2) OF THE SECURITIES ACT OF 1933; 2. NYSE RULE 1100(B) BY FAILING TO DELIVER PRODUCT DESCRIPTIONS TO CUSTOMERS THAT PURCHASED EXCHANGE TRADED FUNDS; AND 3. NYSE RULE 342 BY FAILING 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. SANCTION: CENSURE, A $500,000 FINE AND AN UNDERTAKING. www.finra.org/brokercheck **9/7/07** DECISION 07-127 ISSUED BY NYSE HEARING BOARD User Guidance DECISION: RBC DAIN RAUSCHER, INC. CONSENTED TO FINDINGS THAT IT VIOLATED: 1. NYSE RULE 401(A) BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM 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; 2. NYSE RULE 1100(B) BY FAILING TO DELIVER PRODUCT DESCRIPTIONS TO CUSTOMERS THAT PURCHASED EXCHANGE TRADED FUNDS; AND 3. NYSE RULE 342 BY FAILING 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. SANCTION: CENSURE, A $500,000 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 DATE. CONTACT: PEGGY GERMINO 212-656-8450. i Reporting Source: Firm Current Status: Final Allegations: NYSE ALLEGES RULE VIOLATIONS IN CONNECTION WITH THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS FOR SALES OF REGISTERED SECURITIES AND EXCHANGE TRADED FUNDS, AND PROVIDING FOR, ESTABLISHING, AND MAINTAINING APPROPRIATE SUPERVISION AND CONTROL PROCEDURES RELATING TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 06/29/2007 Docket/Case Number: HBD# 07-127

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

Resolution: Decision Resolution Date: 10/02/2007 Sanctions Ordered: Censure Monetary/Fine $500,000.00 Other Sanctions Ordered: UNDERTAKING ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 413 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM ACCEPTED THE STIPULATION OF FACTS AND CONSENT TO PENALTY ALONG WITH A CENSURE, $500,000 FINE, AND UNDERTAKING TO PROVIDE WRITTEN CERTIFICATION THAT THE FIRM'S CURRENT POLICIES AND PROCEDURES ARE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH FEDERAL SECURITIES LAWS AND NYSE RULES APPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS. THE FINE WAS SENT TO THE NYSE ON OCTOBER 10, 2007. i Disclosure 196 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT THE FIRM VIOLATED SOUTH DAKOTA STATUTE SDCL- 47-31B-404(A), WHEREIN ONE INVESTMENT ADVISOR REPRESENTATIVE OF THE FIRM CONDUCTED INVESTMENT ADVISORY BUSINESS IN THE STATE WITHOUT BEING LICENSED OR EXEMPT FROM LICENSING. Initiated By: SOUTH DAKOTA DEPARTMENT OF REVENUE & REGULATION, DIVISION OF SECURITIES Date Initiated: 04/02/2007 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: Other Resolution Date: 04/02/2007 Sanctions Ordered: Monetary/Fine $750.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM SUBMITTED PAYMENT FOR THE $750 FINE AND $250 IN BACK REGISTRATION FEES TO THE STATE. FULL PAYMENT OF THESE AMOUNTS WERE SENT TO THE STATE ON 4/18/07. Firm Statement DUE TO AN ADMINISTRATIVE ERROR, AN INVESTMENT ADVISOR ©2021 FINRA. All rights reserved. Report aboutREPRESENTATIVE RBC CAPITAL MARKETS, REGISTRATION LLC REQUEST FOR SOUTH DAKOTA WAS 414 NOT SUBMITTED FOR ONE EMPLOYEE AT THE TIME OF THEIR TRANSFER TO THE FIRM. TO RESOLVE THIS MATTER, THE STATE REQUESTED THE FIRM TO PAY A $750 FINE AND $250 IN BACK REGISTRATION FEES. UPON RECEIPT OF THE ABOVE PAYMENTS, THE STATE APPROVED THE EMPLOYEE'S INVESTMENT ADVISOR REPRESENTATIVE REGISTRATION REQUEST. www.finra.org/brokercheck User Guidance

Firm Statement DUE TO AN ADMINISTRATIVE ERROR, AN INVESTMENT ADVISOR REPRESENTATIVE REGISTRATION REQUEST FOR SOUTH DAKOTA WAS NOT SUBMITTED FOR ONE EMPLOYEE AT THE TIME OF THEIR TRANSFER TO THE FIRM. TO RESOLVE THIS MATTER, THE STATE REQUESTED THE FIRM TO PAY A $750 FINE AND $250 IN BACK REGISTRATION FEES. UPON RECEIPT OF THE ABOVE PAYMENTS, THE STATE APPROVED THE EMPLOYEE'S INVESTMENT ADVISOR REPRESENTATIVE REGISTRATION REQUEST. i Disclosure 197 of 336 Reporting Source: Regulator Current Status: Final Allegations: **3/19/07** EVENT: EXECUTED STIPULATION OF FACTS AND CONSENT TO PENALTY FILED BY THE DIVISION OF ENFORCEMENT OF NYSE REGULATION, INC. AND PENDING.CHARGES: RBC DAIN RAUSCHER: VIOLATED NYSE RULE 445 REQUIRING MEMBER ORGANIZATIONS TO ESTABLISH AN ADEQUATE ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM BY FAILING TO: (A) ESTABLISH WRITTEN PROCEDURES REGARDING THE FILING OF SUSPICIOUS ACTIVITY REPORTS; (B)CONDUCT AN ADEQUATE REVIEW FOR STRUCTURING; AND (C)HAVE AN ADEQUATE MONITORING SYSTEM TO REVIEW AND DOCUMENT FOLLOW-UP ON EXCEPTIONS FOUND BY THE FIRM'S ANTI-MONEY LAUNDERING DEPARTMENT.VIOLATED NYSE RULE 351(A)(8) IN THAT THE FIRM FAILED IN CERTAIN INSTANCES TO PROMPTLY REPORT TO THE EXCHANGE THE SETTLEMENT OF CUSTOMER COMPLAINTS.STIPULATED SANCTION: CENSURE AND $90,000 FINE. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 03/19/2007 Docket/Case Number: HBD# 07-44

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

Resolution: Decision Resolution Date: 04/18/2007 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine RBC CAPITAL $90,000.00 MARKETS, LLC 415 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $90,000.00 Other Sanctions Ordered: Sanction Details: **3/23/07** HEARING BOARD DECISION 07-44 ISSUED. CHARGES: RBC DAIN RAUSCHER: VIOLATED NYSE RULE 445 REQUIRING MEMBER ORGANIZATIONS TO ESTABLISH AN ADEQUATE ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM BY FAILING TO: (A) ESTABLISH WRITTEN PROCEDURES REGARDING THE FILING OF SUSPICIOUS ACTIVITY REPORTS; (B)CONDUCT AN ADEQUATE REVIEW FOR STRUCTURING; AND (C)HAVE AN ADEQUATE MONITORING SYSTEM TO REVIEW AND DOCUMENT FOLLOW-UP ON EXCEPTIONS FOUND BY THE FIRM'S ANTI-MONEY LAUNDERING DEPARTMENT.VIOLATED NYSE RULE 351(A)(8) IN THAT THE FIRM FAILED IN CERTAIN INSTANCES TO PROMPTLY REPORT TO THE EXCHANGE THE SETTLEMENT OF CUSTOMER COMPLAINTS.STIPULATED SANCTION: CENSURE AND $90,000 FINE. Regulator Statement **4/18/07** THE DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESS ON APRIL 17, 2007. CONTACT: PEGGY GERMINO 212-656-8450. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT THE FIRM VIOLATED NYSE RULE 445 REQUIRING MEMBER ORGANIZATIONS TO ESTABLISH AN ADEQUATE ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM BY FAILING TO: (A) ESTABLISH WRITTEN PROCEDURES REGARDING THE FILING OF SUSPICIOUS ACTIVITY REPORTS; (B)CONDUCT AN ADEQUATE REVIEW FOR STRUCTURING; AND (C)HAVE AN ADEQUATE MONITORING SYSTEM TO REVIEW AND DOCUMENT FOLLOW-UP ON EXCEPTIONS FOUND BY THE FIRM'S ANTI-MONEY LAUNDERING DEPARTMENT. IT IS ALSO ALLEGED THAT THE FIRM VIOLATED NYSE RULE 351(A)(8) IN THAT THE FIRM FAILED IN CERTAIN INSTANCES TO PROMPTLY REPORT TO THE EXCHANGE THE SETTLEMENT OF CUSTOMER COMPLAINTS. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 03/19/2007 Docket/Case Number: HBD# 07-44

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

Other Sanction(s)/Relief CENSURE Sought:

Resolution: Decision Resolution Date: 04/18/2007 Sanctions Ordered: Censure Monetary/Fine $90,000.00 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 $90,000. PAYMENT OF THE FINE WAS SENT TO THE NYSE ON 5/1/2007. Firm Statement 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 $90,000. PAYMENT OF THE FINE WAS SENT TO THE NYSE ON 5/1/2007. i Disclosure 198 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110 AND 3010 - FROM JANUARY 2002 THROUGH JULY 31, 2004, THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE SYSTEMS AND PROCEDURES DESIGNED TO ENSURE THAT ALL ELIGIBLE INVESTORS RECEIVED THE OPPORTUNITY TO PURCHASE CLASS A SHARES OF CERTAIN MUTUAL FUNDS AT NET ASSET VALUE (NAV). IN PARTICULAR, CERTAIN MUTUAL FUNDS OFFERED "NAV TRANSFER PROGRAMS" THAT ALLOWED INVESTORS TO PURCHASE CLASS A SHARES AT NAV AND NOT PAY ANY SALES CHARGES, IF THE CUSTOMER INVESTED PROCEEDS FROM THE REDEMPTION OF SHARES OF ANOTHER MUTUAL FUND WITHIN SPECIFIED TIME FRAMES AND PREVIOUSLY HAD PAID EITHER A FRONT- END OR BACK-END SALES CHARGE. THE FIRM FAILED TO EXERCISE REASONABLE DUE DILIGENCE TO IDENTIFY THE ESSENTIAL TERMS AND CONDITIONS OF THE NAV TRANSFER PROGRAMS OF CERTAIN MUTUAL FUNDS. THE FIRM FAILED TO ENSURE, AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SYSTEM AND PROCEDURES TO ENSURE, THAT ITS CUSTOMERS RECEIVED NAV PRICING WHEN APPROPRIATE. AS A RESULT, INVESTORS WHO WERE ELIGIBLE TO PURCHASE CLASS A SHARES UNDER NAV TRANSFER PROGRAMS (1) PURCHASED CLASS A SHARES AND INCURRED FRONT-END SALES CHARGES THAT THEY SHOULD NOT HAVE PAID, AND/OR (2) PURCHASED OTHER SHARE CLASSES OF THESE MUTUAL FUNDS AND THEREBY BECAME SUBJECT TO ©2021 FINRA. All rights reserved. Report aboutBACK-END RBC CAPITAL SALES MARKETS, CHARGES, LLC ALSO KNOWN AS CONTINGENT DEFERRED 417 SALES CHARGES AS WELL AS HIGHER ONGOING DISTRIBUTION AND SERVICE FEES, TYPICALLY ASSOCIATED WITH SHARE CLASSES OTHER THAN CLASS A. NASD RULES 2110 AND 3010 - FROM JANUARY 2002 THROUGH JULY 31, 2004, THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE SYSTEMS AND PROCEDURES DESIGNED TO ENSURE THAT ALL ELIGIBLE INVESTORS RECEIVED THE OPPORTUNITY TO PURCHASE CLASS A SHARES OF CERTAIN MUTUAL FUNDS AT NET ASSET VALUE (NAV). IN PARTICULAR, CERTAIN MUTUAL FUNDS OFFERED "NAV TRANSFER PROGRAMS" THAT ALLOWED INVESTORS TO PURCHASE CLASS A SHARES AT NAV AND NOT PAY ANY SALES CHARGES, IF THE CUSTOMER INVESTED PROCEEDS FROM THE REDEMPTION OF SHARES OF ANOTHER MUTUAL FUND WITHIN SPECIFIED TIME FRAMES AND PREVIOUSLY HAD PAID EITHER A FRONT- END OR BACK-END SALES CHARGE. THE FIRM FAILED TO EXERCISE REASONABLE DUE DILIGENCE TO IDENTIFY THE ESSENTIAL TERMS AND CONDITIONS OF THE NAV TRANSFER PROGRAMS OF CERTAIN MUTUAL FUNDS. THE FIRM FAILED TO ENSURE, AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SYSTEM AND PROCEDURES TO ENSURE, THAT ITS CUSTOMERS RECEIVED NAV PRICING WHEN APPROPRIATE. AS A www.finra.org/brokercheck RESULT, INVESTORS WHO WERE ELIGIBLE TO PURCHASE CLASS A User Guidance SHARES UNDER NAV TRANSFER PROGRAMS (1) PURCHASED CLASS A SHARES AND INCURRED FRONT-END SALES CHARGES THAT THEY SHOULD NOT HAVE PAID, AND/OR (2) PURCHASED OTHER SHARE CLASSES OF THESE MUTUAL FUNDS AND THEREBY BECAME SUBJECT TO BACK-END SALES CHARGES, ALSO KNOWN AS CONTINGENT DEFERRED SALES CHARGES AS WELL AS HIGHER ONGOING DISTRIBUTION AND SERVICE FEES, TYPICALLY ASSOCIATED WITH SHARE CLASSES OTHER THAN CLASS A. Initiated By: NASD Date Initiated: 12/11/2006 Docket/Case Number: EAF0401190003

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: 12/11/2006 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 $250,000.00 Other Sanctions Ordered: UNDERTAKINGS 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 COMPLY WITH THE FOLLOWING UNDERTAKINGS: THE FIRM WILL PROVIDE REMEDIATION TO CLIENTS WHO PURCHASED SHARES OF MUTUAL FUNDS, AND QUALIFIED FOR, BUT DID NOT RECEIVE, THE BENEFIT OF NAV TRANSFER PROGRAMS. THE FIRM WILL PROVIDE REMEDIATION IN ACCORDANCE WITH A METHODOLOGY NOT UNACCEPTABLE TO NASD. WITHIN 60 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL RETAIN A THIRD PARTY EXAMINER, NOT UNACCEPTABLE TO NASD, TO ASSESS THE FIRM'S REMEDIATION AND PROVIDE A REPORT TO NASD. WITHIN 60 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL SUBMIT TO NASD FOR REVIEW A SAMPLE LETTER NOTIFYING CLIENTS OF REMEDIATION PAYMENTS. WITHIN 90 DAYS FROM ©2021 FINRA. All rights reserved. Report aboutTHE RBC NOTICE CAPITAL OF MARKETS, ACCEPTANCE LLC OF THIS AWC, THE FIRM WILL DESIGNATE 418 AND TRAIN STAFF TO FIELD AND RESPOND TO CLIENT INQUIRIES IN CONNECTION WITH THIS REMEDIATION PROCESS; WITHIN 120 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL COMPLETE THE REMEDIATION PROCESS; WITHIN 150 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL FILE A REPORT WITH NASD, AND SIMULTANEOUSLY PROVIDE A COPY TO THE THIRD PARTY EXAMINER, CERTIFIED TO, AND SIGNED BY, AN OFFICER OF THE FIRM WHO IS REGISTERED WITH NASD AT THE TIME OF CERTIFICATION. THE THIRD PARTY EXAMINER WILL UTILIZE HE REMEDIATION METHODOLOGY TO ASSESS THE FIRM'S REMEDIATION PROCESS. NOT LATER THAN 210 DAYS AFTER THE DATE OF NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL REQUIRE THE THIRD PARTY EXAMINER TO SUBMIT A FINAL REPORT TO THE FIRM AND TO NASD. 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 COMPLY WITH THE FOLLOWING UNDERTAKINGS: THE FIRM WILL PROVIDE REMEDIATION TO CLIENTS WHO PURCHASED SHARES OF MUTUAL FUNDS, AND QUALIFIED FOR, BUT DID NOT RECEIVE, THE BENEFIT OF NAV TRANSFER PROGRAMS. THE FIRM WILL PROVIDE REMEDIATION IN ACCORDANCE WITH A METHODOLOGY NOT UNACCEPTABLE TO NASD. WITHIN 60 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE www.finra.org/brokercheck FIRM SHALL RETAIN A THIRD PARTY EXAMINER, NOT UNACCEPTABLE TO User Guidance NASD, TO ASSESS THE FIRM'S REMEDIATION AND PROVIDE A REPORT TO NASD. WITHIN 60 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL SUBMIT TO NASD FOR REVIEW A SAMPLE LETTER NOTIFYING CLIENTS OF REMEDIATION PAYMENTS. WITHIN 90 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM WILL DESIGNATE AND TRAIN STAFF TO FIELD AND RESPOND TO CLIENT INQUIRIES IN CONNECTION WITH THIS REMEDIATION PROCESS; WITHIN 120 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL COMPLETE THE REMEDIATION PROCESS; WITHIN 150 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL FILE A REPORT WITH NASD, AND SIMULTANEOUSLY PROVIDE A COPY TO THE THIRD PARTY EXAMINER, CERTIFIED TO, AND SIGNED BY, AN OFFICER OF THE FIRM WHO IS REGISTERED WITH NASD AT THE TIME OF CERTIFICATION. THE THIRD PARTY EXAMINER WILL UTILIZE HE REMEDIATION METHODOLOGY TO ASSESS THE FIRM'S REMEDIATION PROCESS. NOT LATER THAN 210 DAYS AFTER THE DATE OF NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL REQUIRE THE THIRD PARTY EXAMINER TO SUBMIT A FINAL REPORT TO THE FIRM AND TO NASD. i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGES THAT FROM JANUARY 2002 THROUGH JULY 2004 THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE SYSTEMS AND PROCEDURES DESIGNED TO ENSURE THAT ALL ELIGIBLE INVESTORS RECEIVED THE BENEFIT OF NET ASSET VALUE TRANSFER PROGRAMS OFFERED BY VARIOUS MUTUAL FUND COMPANIES. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 12/11/2006 Docket/Case Number: EAF0401190003

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Restitution Sought: Other Sanction(s)/Relief CIVIL AND ADMINISTRATIVE PENALTY/FINE, CENSURE AND UNDERTAKING Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/11/2006 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Disgorgement/Restitution

Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM ACCEPTED THE AWC ALONG WITH THE CENSURE AND FINE. THE FINE WAS PAID ON DECEMBER 21, 2006. IN ADDITION, THE FIRM SHALL COMPLY WITH THE FOLLOWING UNDERTAKINGS: (1) COMPILATION AND SUBMISSION OF A REPORT BY AN OFFICER OF THE FIRM AS TO THE FIRM'S REMEDIATION EFFORTS, DUE BY MAY 10, 2007; AND (2) ENGAGEMENT OF A THIRD PARTY EXAMINER TO VALIDATE THE PERFORMANCE OF THE FIRM AS PERTAINS TO THE FIRM'S REMEDIATION EFFORTS AND REPORT ON SUCH. THE THIRD PARTY EXAMINER'S REPORT IS DUE BY JULY 9, 2007. RESTITUTION TO CLIENTS IS DUE BY APRIL 10, 2007. Firm Statement FIRM IS IN THE PROCESS OF ENGAGING THE THIRD PARTY EXAMINER TO VALIDATE THE FIRM'S COMPUTATION OF REMEDIATION AMOUNTS. UPON SUCH VALIDATION, REMEDIATION WILL BE MADE AND THE REQUIRED REPORTS BY AN OFFICER OF THE FIRM AND BY THE THIRD PARTY EXAMINER WILL BE COMPILED AND SUBMITTED. i Disclosure 199 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD RULE 6955(A) - RBC DAIN RAUSCHER, INC, FAILED TO SUBMIT TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REQUIRED INFORMATION FOR REPORTING MEMBERS. Initiated By: NASD Date Initiated: 07/11/2006 Docket/Case Number: 2005000442701

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/11/2006 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about RBC CAPITAL MARKETS, LLC 420 fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

Principal Product Type: Other Other Product Type(s): UNKNOWN SECURITIES 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: 07/11/2006 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. PAYMENT OF ©2021 FINRA. All rights reserved. Report aboutTHE RBC FINE CAPITAL WAS SENTMARKETS, TO LLC THE NASD ON 8/1/2006. 421 www.finra.org/brokercheck User Guidance 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. PAYMENT OF THE FINE WAS SENT TO THE NASD ON 8/1/2006. Firm Statement 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. PAYMENT OF THE FINE WAS SENT TO THE NASD ON 8/1/2006. i Disclosure 200 of 336 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 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 MUNICIPAL BONDS, CORPORATE BONDS Sought:

Resolution: Order Resolution Date: 05/31/2006 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about RBC CAPITAL MARKETS, LLC 422 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 $1,500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: 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 THIS ORDER Regulator Statement 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: 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 UNDERWRITES, AND MANAGES 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 PROVIDING CERTAIN CUSTOMERS WITH INFORMATION THAT GAVE THEM AN ADVANTAGE OVER OTHER CUSTOMERS. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 05/31/2006 Docket/Case Number: 3-12310

Principal Product Type: Debt - Municipal Other Product Type(s): DEBT - CORPORATE AND EQUITY LISTED (COMMON & PREFERRED STOCK) Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST Sought:

Resolution: Order Resolution Date: 05/31/2006 Sanctions Ordered: Monetary/Fine $1,500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKINGS Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT, TO BE CENSURED, TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT ©2021 FINRA. All rights reserved. Report aboutOF $1,500,000 RBC CAPITAL AND MARKETS, TO COMPLY LLC WITH CERTAIN UNDERTAKINGS AS 424 FOLLOWS: 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 THIS ORDER. PAYMENT FOR THE FINE WAS SENT TO THE SEC ON JUNE 8, 2006. www.finra.org/brokercheck WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED User Guidance TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT, TO BE CENSURED, TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $1,500,000 AND TO COMPLY WITH CERTAIN UNDERTAKINGS AS FOLLOWS: 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 THIS ORDER. PAYMENT FOR THE FINE WAS SENT TO THE SEC ON JUNE 8, 2006. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT, TO BE CENSURED, TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $1,500,000 AND TO COMPLY WITH CERTAIN UNDERTAKINGS. i Disclosure 201 of 336 Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT THE FIRM VIOLATED SECTION 7-11-203 OF THE RHODE ISLAND UNIFORM SECURITIES ACT OF 1990, WHEREIN FIVE INVESTMENT ADVISER REPRESENTATIVES OF THE FIRM CONDUCTED INVESTMENT ADVISORY BUSINESS IN THE STATE WITHOUT BEING LICENSED OR EXEMPT FROM LICENSING. Initiated By: STATE OF RHODE ISLAND Date Initiated: 05/02/2006 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 425 www.finra.org/brokercheck User Guidance

Date Initiated: 05/02/2006 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: 05/02/2006 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM CONSENTED TO THE AGREEMENT INCLUDING THE FINE OF $10,000 AND PAYMENT OF $750 IN BACK FEES TO THE STATE. FULL PAYMENT OF THESE AMOUNTS WERE SENT TO THE STATE ON 4/28/06. Firm Statement THE FIRM CONSENTED TO THE AGREEMENT INCLUDING THE FINE OF $10,000 AND PAYMENT OF $750 IN BACK FEES TO THE STATE. FULL PAYMENT OF THESE AMOUNTS WERE SENT TO THE STATE ON 4/28/06. i Disclosure 202 of 336 Reporting Source: Regulator Current Status: Final Allegations: SEC RULES 17A-3, 17A-4, NASD CONDUCT RULES 2110, 2440, 3010 AND 3110 AND IM-2440 - RBC DAIN RAUSCHER, INC. BOUGHT A SECURITY FOR ITS OWN ACCOUNT FROM A CUSTOMER OR SOLD A SECURITY FOR ITS OWN ACCOUNT TO A CUSTOMER, AND FAILED TO BUY OR SELL SUCH SECURITY AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO SUCH SECURITY AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED, AND THE FIRM WAS ENTITLED TO A PROFIT. THE FIRM'S SUPERVISORY SYSTEM FOR ITS HIGH-YIELD BOND DESK DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS AND THE RULES OF NASD CONCERNING FAIR PRICING AND NASD'S MARK-UP POLICY. ALTHOUGH THE FIRM'S SUPERVISORY SYSTEM INCLUDED WRITTEN SUPERVISORY PROCEDURES IDENTIFYING INDIVIDUALS RESPONSIBLE FOR MONITORING FOR EXCESSIVE MARK- ©2021 FINRA. All rights reserved. Report aboutUPS/MARK-DOWNS RBC CAPITAL MARKETS, AS WELL LLC AS DOCUMENTS TO BE REVIEWED DAILY, 426 SUCH REVIEWS WERE INCONSISTENT AND THE SYSTEM AND PROCEDURES DESCRIBED IN THE WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE. FURTHERMORE, SUPERVISORY REVIEWS CONDUCTED OF MARK-UPS AND MARK-DOWNS WERE INADEQUATE AND OVERLY RELIED ON TRADERS' SUBJECTIVE ASSESSMENTS OF FAIR PRICING. ALTHOUGH THE FIRM GENERATED EXCEPTION REPORTS THAT IDENTIFIED TRANSACTIONS THAT HAD MARK-UPS/MARK-DOWNS THAT EXCEEDED THE FIRM'S GUIDELINES, SUPERVISORS RESPONSIBLE FOR REVIEWING THE REPORTS FAILED TO MAINTAIN ADEQUATE DOCUMENTATION OF THEIR SUPERVISORY REVIEWS AND THESE EXCEPTION REPORTS GENERATED INADEQUATE ADDITIONAL REVIEW, DISCUSSION, AND CORRECTIVE ACTION BY THE FIRM. FINALLY, FOR THOSE TRANSACTIONS WITH MARK-UPS THAT EXCEEDED NASD'S MARK- UP POLICY, THE FIRM WAS UNABLE TO PROVIDE CONTEMPORANEOUS DOCUMENTATION EVIDENCING SPECIFIC FACTORS THAT MAY HAVE JUSTIFIED A MARK-UP IN EXCESS OF NASD'S MARK-UP POLICY. SEC RULES 17A-3, 17A-4, NASD CONDUCT RULES 2110, 2440, 3010 AND 3110 AND IM-2440 - RBC DAIN RAUSCHER, INC. BOUGHT A SECURITY FOR ITS OWN ACCOUNT FROM A CUSTOMER OR SOLD A SECURITY FOR ITS OWN ACCOUNT TO A CUSTOMER, AND FAILED TO BUY OR SELL SUCH SECURITY AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO SUCH SECURITY AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED, AND THE FIRM WAS ENTITLED TO A PROFIT. THE FIRM'S SUPERVISORY SYSTEM FOR ITS HIGH-YIELD BOND DESK DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE www.finra.org/brokercheck COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND User Guidance REGULATIONS AND THE RULES OF NASD CONCERNING FAIR PRICING AND NASD'S MARK-UP POLICY. ALTHOUGH THE FIRM'S SUPERVISORY SYSTEM INCLUDED WRITTEN SUPERVISORY PROCEDURES IDENTIFYING INDIVIDUALS RESPONSIBLE FOR MONITORING FOR EXCESSIVE MARK- UPS/MARK-DOWNS AS WELL AS DOCUMENTS TO BE REVIEWED DAILY, SUCH REVIEWS WERE INCONSISTENT AND THE SYSTEM AND PROCEDURES DESCRIBED IN THE WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE. FURTHERMORE, SUPERVISORY REVIEWS CONDUCTED OF MARK-UPS AND MARK-DOWNS WERE INADEQUATE AND OVERLY RELIED ON TRADERS' SUBJECTIVE ASSESSMENTS OF FAIR PRICING. ALTHOUGH THE FIRM GENERATED EXCEPTION REPORTS THAT IDENTIFIED TRANSACTIONS THAT HAD MARK-UPS/MARK-DOWNS THAT EXCEEDED THE FIRM'S GUIDELINES, SUPERVISORS RESPONSIBLE FOR REVIEWING THE REPORTS FAILED TO MAINTAIN ADEQUATE DOCUMENTATION OF THEIR SUPERVISORY REVIEWS AND THESE EXCEPTION REPORTS GENERATED INADEQUATE ADDITIONAL REVIEW, DISCUSSION, AND CORRECTIVE ACTION BY THE FIRM. FINALLY, FOR THOSE TRANSACTIONS WITH MARK-UPS THAT EXCEEDED NASD'S MARK- UP POLICY, THE FIRM WAS UNABLE TO PROVIDE CONTEMPORANEOUS DOCUMENTATION EVIDENCING SPECIFIC FACTORS THAT MAY HAVE JUSTIFIED A MARK-UP IN EXCESS OF NASD'S MARK-UP POLICY. Initiated By: NASD Date Initiated: 10/28/2005 Docket/Case Number: 2005000162002

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/28/2005 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: Censure Monetary/Fine $1,000,000.00 Disgorgement/Restitution Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 427 www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RBC DAIN RAUSCHER, INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE THE FIRM IS CENSURED, FINED $1,000,000, MUST PAY $158,467, PLUS INTEREST, IN RESTITUTION AND REQUIRED TO REVISE THE FIRM'S SUPERVISORY PROCEDURES WITH RESPECT TO THE RULES OF NASD CONCERNING FAIR PRICING AND NASD'S MARK-UP POLICY. Regulator Statement MOREOVER, THE FIRM FAILED TO SHOW THE TIMES OF RECEIPT ON MEMORANDA OF BROKERAGE ORDERS FOR FIXED INCOME TRANSACTIONS; FAILED TO PRESERVE MEMORANDA OF BROKERAGE ORDERS FOR FIXED INCOME TRANSACTIONS FULLY COMPLYING WITH SEC RULE 17A-3 FOR A PERIOD OF NOT LESS THAN THREE YEARS, THE FIRST TWO IN AN ACCESSIBLE PLACE. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF SEC RULES 17A-3, 17A-4, NASD CONDUCT RULES 2110, 2440, 3010 AND 3110 AND IM-2440. IT IS ALLEGED THAT THE FIRM BOUGHT A SECURITY FOR ITS OWN ACCOUNT FROM A CUSTOMER OR SOLD A SECURITY FOR ITS OWN ACCOUNT TO A CUSTOMER, AND FAILED TO BUY OR SELL SUCH SECURITY AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO SUCH SECURITY AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED, AND THE FIRM WAS ENTITLED TO A PROFIT. THE FIRM'S SUPERVISORY SYSTEM FOR ITS HIGH-YIELD BOND DESK DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS AND THE RULES OF NASD CONCERNING FAIR PRICING AND NASD'S MARK-UP POLICY. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 10/28/2005 Docket/Case Number: 20050001620-02

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/28/2005 Sanctions Ordered: Censure Monetary/Fine $1,000,000.00 Disgorgement/Restitution Other Sanctions Ordered: 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 $1,000,000, MUST PAY $158,467, PLUS INTEREST, IN RESTITUTION AND REQUIRED TO REVISE THE FIRM'S SUPERVISORY PROCEDURES WITH RESPECT TO THE RULES OF NASD CONCERNING FAIR PRICING AND NASD'S MARK-UP POLICY. THE FINE WAS PAID ON NOVEMBER 3, 2005. PAYMENT OF THE RESITUTION IS PENDING. Firm Statement 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 $1,000,000, MUST PAY $158,467, PLUS INTEREST, IN RESTITUTION AND REQUIRED TO REVISE THE FIRM'S SUPERVISORY PROCEDURES WITH RESPECT TO THE RULES OF NASD CONCERNING FAIR PRICING AND NASD'S MARK-UP POLICY. THE FINE WAS PAID ON NOVEMBER 3, 2005. PAYMENT OF THE RESITUTION IS PENDING. i Disclosure 203 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULES 2110 AND 3010, AND NASD MARKETPLACE RULE 6130(B); RESPONDENT MEMBER FAILED TO ACCEPT OR DECLINE IN ACT TRANSACTIONS IN ELIGIBLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION; FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES WHICH SPECIFIED THAT IT WAS TO CONDUCT A WEEKLY REVEIW OF TRADE REPORTS FOR COMPLIANCE WITH NASD MARKETPLACE RULE 6130(B). Initiated By: NASD Date Initiated: 06/03/2005 Docket/Case Number: CLG050071

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/03/2005 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: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $15,000. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT RBC DAIN RAUSCHER INC. VIOLATED NASD CONDUCT RULES 2110 AND 3010, AND NASD MARKETPLACE RULE 6130(B) RELATING TO VIOLATIONS OF ACT REPORTING AND FIRM PROCEDURE TO REVIEW TRADE REPORTS FOR COMPLIANCE WITH RULE 6130(B). Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 06/03/2005 Docket/Case Number: CLG050071

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/03/2005 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE CENSURE AND FINE OF $15,000. THE FINE WAS PAID ON JUNE 22, 2005. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE CENSURE AND FINE OF $15,000. THE FINE WAS PAID ON JUNE 22, 2005. i Disclosure 204 of 336 Reporting Source: Regulator Current Status: Final Allegations: SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934, RULE 17A-4 THEREUNDER; NASD CONDUCT RULES 2830(K), 2110, 3110 AND 3010; RBC DAIN RAUSCHER INC., MAINTAINED SHELF SPACE (OR REVENUE SHARING) PROGRAMS IN WHICH PARTICIPATING MUTUAL FUND COMPLEXES PAID A FEE IN RETURN FOR PREFERENTIAL TREATMENT, WHICH INCLUDED ENHANCED ACCESS TO THE FIRM'S SALES FORCES AND HYPERLINKS TO THOSE FUNDS' WEB SITES ON THE FIRM'S INTERNAL WEB SITE. PARTICIPATING FUND COMPLEXES PAID ALL OR SOME OF THEIR FEES FOR PARTICIPATING IN THE PROGRAMS BY DIRECTING MUTUAL FUND PORTFOLIO BROKERAGE COMMISSIONS TO THE FIRM. IN ADDITION, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SYSTEM AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE FOREGOING ELECTRONIC MAIL RETENTION VIOLATIONS. Initiated By: NASD Date Initiated: 06/08/2005 Docket/Case Number: CE1050003

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/08/2005 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: Censure Monetary/Fine $1,700,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS RBC DAIN RAUSCHER INC., CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS THEREFORE, THE FIRM IS CENSURED AND FINED $1,700,000.00. i Reporting Source: Firm Current Status: Final Allegations: SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934, RULE 17A-4 THEREUNDER; NASD CONDUCT RULES 2830(K), 2110, 3110, AND 3010; RBC DAIN RAUSCHER INC., MAINTAINED SHELF SPACE (OR REVENUE SHARING) PROGRAMS IN WHICH PARTICIPATING MUTUAL FUND COMPLEXES PAID A FEE IN RETURN FOR PREFERENTIAL TREATMENT, WHICH INCLUDED ENHANCED ACCESS TO THE FIRM'S SALES FORCES AND HYPERLINKS TO THOSE FUNDS' WEB SITES ON THE FIRM'S INTERNAL WEB SITE. PARTICIPATING FUND COMPLEXES PAID ALL OR SOME OF THEIR FEES FOR PARTICIPATING IN THE PROGRAMS BY DIRECTING MUTUAL FUND PORTFOLIO BROKERAGE COMMISSIONS TO THE FIRM. IN ADDITION, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SYSTEM AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE ELECTRONIC MAIL RETENTION VIOLATIONS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 06/08/2005 Docket/Case Number: CE1050003

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 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/08/2005 Sanctions Ordered: Censure Monetary/Fine $1,700,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE CENSURE AND FINE OF $1,700,000 PAID ON JUNE 10, 2005. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE CENSURE AND FINE OF $1,700,000 PAID ON JUNE 10, 2005. i Disclosure 205 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD RULE 6130 - RESPONDENT MEMBER EXECUTED SHORT SALE TRANSACTIONS AND FAILED TO REPORT OR CAUSE TO BE REPORTED THESE TRANSACTIONS TO ACT WITH A SHORT SALE MODIFIER. Initiated By: NASD Date Initiated: 02/08/2005 Docket/Case Number: CLG050015

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: 02/08/2005 Does the order constitute a No ©2021final orderFINRA. basedAll rights on reserved. Report about RBC CAPITAL MARKETS, LLC 433 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 $8,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DAIN CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED $8,000. i Reporting Source: Firm Current Status: Final Allegations: NASD ENTERED FINDINGS THAT DURING THE PERIOD DECEMBER 23, 2002 TO JANUARY 21, 2003 THE FIRM FAILED TO REPORT FIFTEEN SHORT SALE TRANSACTIONS WITH THE APPROPRIATE SHORT SALE MODIFIER. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/08/2005 Docket/Case Number: CLG050015

Principal Product Type: Other Other Product Type(s): EQUITY 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: 02/08/2005 Sanctions Ordered: Censure Monetary/Fine $8,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF 8,000 LEVIED SOLELY AGAINST THE FIRM. Firm Statement NASD PROPOSED RESOLUTION OF THE MATTER VIA EXECUTION OF THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT. THE FIRM EXECUTED ©2021 FINRA. All rights reserved. Report aboutSUCH RBC LETTER CAPITAL ONMARKETS, DECEMBER LLC 20, 2004. THE NASD ACCEPTED THE LETTER 434 ON FEBRUARY 7, 2005 AND ISSUED NOTIFICATION OF THIS ACCEPTANCE ON FEBRUARY 8, 2005. www.finra.org/brokercheck User Guidance

Firm Statement NASD PROPOSED RESOLUTION OF THE MATTER VIA EXECUTION OF THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT. THE FIRM EXECUTED SUCH LETTER ON DECEMBER 20, 2004. THE NASD ACCEPTED THE LETTER ON FEBRUARY 7, 2005 AND ISSUED NOTIFICATION OF THIS ACCEPTANCE ON FEBRUARY 8, 2005. i Disclosure 206 of 336 Reporting Source: Regulator Current Status: Final Allegations: ARTICLE V, SECTIONS 2(C) AND 3(B) OF NASD'S BY-LAWS, AND NASD RULES 2110 AND 3010 - RBC DAIN RAUSCHER INC. ("RESPONDENT FIRM") FILED AT LEAST 140 LATE AMENDMENTS TO FORMS U4 AND U5, WHICH REPRESENTED APPROXIMATELY 35% OF THE REQUIRED AMENDMENTS RELATING TO REPORTABLE CUSTOMER COMPLAINTS, TERMINATIONS, REGULATORY ACTIONS, AND CRIMINAL DISCLOSURES. DURING THE RELEVANT PERIOD, THE RESPONDENT FIRM'S SUPERVISORY SYSTEM AND PROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS ARTICLE V REPORTING OBLIGATIONS. Initiated By: NASD Date Initiated: 11/30/2004 Docket/Case Number: CAF040105

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: 11/30/2004 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 $150,000.00 Other Sanctions Ordered: UNDERTAKINGS ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 435 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: UNDERTAKINGS Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, IT IS CENSURED AND FINED $150,000, WHICH SHALL BE PAID WITHIN 10 DAYS OF NOTICE OF ACCEPTANCE OF THIS AWC. IN ADDITION RESPONDENT FIRM SHALL COMPLY WITH THE FOLLOWING UNDERTAKINGS: (1) PROMPTLY FOLLOWING NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM'S INTERNAL AUDIT DEPARTMENT OR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE V REPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALL CONDUCT AN AUDIT TO ASSESS THE EFFECTIVENESS OF ITS SYSTEM AND PROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5 AMENDMENTS SUMMARIZING FINDINGS AND RECOMMENDATIONS AND SHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTH QUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILAR WRITTEN AUDIT REPORT. (2) NO LATER THAN 90 DAYS AFTER NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY IN WRITING TO NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICER HAS REVIEWED THE CURRENT AUDIT REPORT. (3) NO LATER THAN 60 DAYS AFTER THE DATE OF THE CURRENT AUDIT REPORT, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS IMPLEMENTED, OR HAS BEGUN TO IMPLEMENT, ANY RECOMMENDATIONS WITHIN A SPECIFIED TIME PERIOD. (4) NO LATER THAN 60 DAYS AFTER THE LAST DAY OF THE NEXT FOUR QUARTERS, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT AN AUDIT WAS CONDUCTED, THE CURRENT AUDIT REPORT WAS REVIEWED, AND RECOMMENDATIONS IMPLEMENTED, OR BEGUN TO BE IMPLEMENTED. (5) NO LATER THAN SIX MONTHS AFTER NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS REVIEWED ITS SYSTEM AND PROCEDURES FOR COMPLYING WITH ITS ARTICLE V REPORTING OBLIGATIONS AND HAS ESTABLISHED A SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REPORTING REQUIREMENTS SET FORTH THEREIN. i Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT FOR A PARTICULAR PERIOD OF TIME, THE FIRM VIOLATED ARTICLE V, SECTIONS 2(C) AND 3(B) OF NASD'S BY-LAWS, AND NASD RULES 2110 AND 3010 DUE TO NOT FILING TIMELY AT LEAST 140 LATE AMENDMENTS TO FORMS U4 AND U5, WHICH REPRESENTED APPROXIMATELY 35% OF THE REQUIRED AMENDMENTS RELATING TO REPORTABLE CUSTOMER COMPLAINTS, TERMINATIONS, REGULATORY ACTIONS, AND CRIMINAL DISCLOSURES. IT WAS ALSO ALLEGED THAT ©2021 FINRA. All rights reserved. Report aboutDURING RBC CAPITAL THE RELEVANT MARKETS, LLC PERIOD, THE FIRM'S SUPERVISORY SYSTEM AND 436 PROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS ARTICLE V REPORTING OBLIGATIONS. IT WAS ALLEGED THAT FOR A PARTICULAR PERIOD OF TIME, THE FIRM VIOLATED ARTICLE V, SECTIONS 2(C) AND 3(B) OF NASD'S BY-LAWS, AND www.finra.org/brokercheck NASD RULES 2110 AND 3010 DUE TO NOT FILING TIMELY AT LEAST 140 User Guidance LATE AMENDMENTS TO FORMS U4 AND U5, WHICH REPRESENTED APPROXIMATELY 35% OF THE REQUIRED AMENDMENTS RELATING TO REPORTABLE CUSTOMER COMPLAINTS, TERMINATIONS, REGULATORY ACTIONS, AND CRIMINAL DISCLOSURES. IT WAS ALSO ALLEGED THAT DURING THE RELEVANT PERIOD, THE FIRM'S SUPERVISORY SYSTEM AND PROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS ARTICLE V REPORTING OBLIGATIONS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 11/30/2004 Docket/Case Number: CAF040105

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 AND UNDERTAKINGS Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/30/2004 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: UNDERTAKINGS Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE AWC ALONG WITH THE CENSURE AND FINE. THE FINE WAS PAID ON 12/02/2004. IN ADDITION, THE FIRM SHALL COMPLY WITH THE FOLLOWING UNDERTAKINGS: (1) PROMPTLY FOLLOWING NOTICE OF ACCEPTANCE OF THE AWC, THE FIRM'S INTERNAL AUDIT DEPARTMENT OR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE V REPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALL CONDUCT AN AUDIT TO ASSESS THE EFFECTIVENESS OF ITS SYSTEM AND PROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5 AMENDMENTS SUMMARIZING FINDINGS AND RECOMMENDATIONS AND SHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTH QUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILAR WRITTEN AUDIT REPORT. (2) NO LATER THAN 90 DAYS AFTER NOTICE OF ACCEPTANCE OF THE AWC, AN OFFICER OF THE FIRM SHALL CERFITY IN WRITING TO NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICER HAS REVIEWED THE CURRENT AUDIT REPORT. (3) NO LATER THAN 60 DAYS AFTER THE DATE OF THE CURRENT AUDIT REPORT, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS IMPLEMENTED, OR HAS BEGUN TO IMPLEMENT, ANY RECOMMENDATIONS WITHIN A SPECIFIED TIME PERIOD. (4) NO LATER THAN 60 DAYS AFTER THE LAST DAY OF THE NEXT FOUR QUARTERS, AN OFFICER SHALL CERTIFY IN ©2021 FINRA. All rights reserved. Report aboutWRITING RBC CAPITAL TO NASD MARKETS, THAT LLC AN AUDIT WAS CONDUCTED, THE CURRENT AUDIT 437 REPORT WAS REVIEWED, AND RECOMMENDATIONS IMPLEMENTED, OR BEGUN TO BE IMPLEMENTED. (5) NO LATER THAN SIX MONTHS AFTER NOTICE OF ACCEPTANCE OF THE AWC, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS REVIEWED ITS SYSTEM AND PROCEDURES FOR COMPLYING WITH ITS ARTICLE V REPORTING OBLIGATIONS AND HAS ESTABLISHED A SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REPORTING REQUIREMENTS SET THEREIN. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE AWC ALONG WITH THE CENSURE AND FINE. THE FINE WAS PAID ON 12/02/2004. IN ADDITION, THE FIRM SHALL COMPLY WITH THE FOLLOWING UNDERTAKINGS: (1) PROMPTLY FOLLOWING NOTICE OF ACCEPTANCE OF THE AWC, THE FIRM'S INTERNAL AUDIT DEPARTMENT OR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE V REPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALL CONDUCT AN AUDIT TO ASSESS THE EFFECTIVENESS OF ITS SYSTEM AND PROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5 AMENDMENTS SUMMARIZING FINDINGS AND RECOMMENDATIONS AND SHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTH QUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILAR WRITTEN AUDIT REPORT. (2) NO LATER THAN 90 DAYS AFTER NOTICE OF ACCEPTANCE OF THE AWC, AN OFFICER OF THE FIRM SHALL CERFITY IN WRITING TO NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICER HAS REVIEWED THE CURRENT AUDIT REPORT. (3) NO LATER THAN 60 www.finra.org/brokercheck DAYS AFTER THE DATE OF THE CURRENT AUDIT REPORT, AN OFFICER User Guidance SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS IMPLEMENTED, OR HAS BEGUN TO IMPLEMENT, ANY RECOMMENDATIONS WITHIN A SPECIFIED TIME PERIOD. (4) NO LATER THAN 60 DAYS AFTER THE LAST DAY OF THE NEXT FOUR QUARTERS, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT AN AUDIT WAS CONDUCTED, THE CURRENT AUDIT REPORT WAS REVIEWED, AND RECOMMENDATIONS IMPLEMENTED, OR BEGUN TO BE IMPLEMENTED. (5) NO LATER THAN SIX MONTHS AFTER NOTICE OF ACCEPTANCE OF THE AWC, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS REVIEWED ITS SYSTEM AND PROCEDURES FOR COMPLYING WITH ITS ARTICLE V REPORTING OBLIGATIONS AND HAS ESTABLISHED A SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REPORTING REQUIREMENTS SET THEREIN. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE AWC ALONG WITH THE CENSURE AND FINE. THE FINE WAS PAID ON 12/02/2004. IN ADDITION, THE FIRM SHALL COMPLY WITH THE FOLLOWING UNDERTAKINGS: (1) PROMPTLY FOLLOWING NOTICE OF ACCEPTANCE OF THE AWC, THE FIRM'S INTERNAL AUDIT DEPARTMENT OR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE V REPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALL CONDUCT AN AUDIT TO ASSESS THE EFFECTIVENESS OF ITS SYSTEM AND PROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5 AMENDMENTS SUMMARIZING FINDINGS AND RECOMMENDATIONS AND SHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTH QUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILAR WRITTEN AUDIT REPORT. (2) NO LATER THAN 90 DAYS AFTER NOTICE OF ACCEPTANCE OF THE AWC, AN OFFICER OF THE FIRM SHALL CERFITY IN WRITING TO NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICER HAS REVIEWED THE CURRENT AUDIT REPORT. (3) NO LATER THAN 60 DAYS AFTER THE DATE OF THE CURRENT AUDIT REPORT, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS IMPLEMENTED, OR HAS BEGUN TO IMPLEMENT, ANY RECOMMENDATIONS WITHIN A SPECIFIED TIME PERIOD. (4) NO LATER THAN 60 DAYS AFTER THE LAST DAY OF THE NEXT FOUR QUARTERS, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT AN AUDIT WAS CONDUCTED, THE CURRENT AUDIT REPORT WAS REVIEWED, AND RECOMMENDATIONS IMPLEMENTED, OR BEGUN TO BE IMPLEMENTED. (5) NO LATER THAN SIX MONTHS AFTER NOTICE OF ACCEPTANCE OF THE AWC, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS REVIEWED ITS SYSTEM AND PROCEDURES FOR COMPLYING WITH ITS ARTICLE V REPORTING OBLIGATIONS AND HAS ESTABLISHED A SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REPORTING REQUIREMENTS SET THEREIN. i Disclosure 207 of 336 Reporting Source: Regulator

Current Status: Final Allegations: **8/16/04**STIPULATION AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT.CONSENTED TO FINDINGS: AS SET FORTH IN THE STIPULATION AND CONSENT TO PENALTY, THE FIRM, WITHOUT ADMITTING OR DENYING GUILT, VIOLATED SEC RULE 15C3-3 BY FAILING TO FUND ITS PROPRIETARY ACCOUNT FOR INTRODUCING BROKERS, THEREBY, ON ONE OR MORE OCCASIONS, CAUSING A HINDSIGHT DEFICIENCY; VIOLATED EXCHANGE RULE 92(B) BY, ON ONE OR MORE OCCASIONS, ENTERING PROPRIETARY ORDERS WHILE REPRESENTING CUSTOMER ORDERS THAT COULD BE EXECUTED AT THE SAME PRICE, WITHOUT USING SEPARATE PROPRIETARY FACILITATION ACCOUNTS FOR SUCH TRADES; VIOLATED SEC RULES 17A-3(A)(6) AND 17A-4(B)(1) AND EXCHANGE RULE 440 BY FAILING TO MAKE, MAINTAIN AND PRESERVE CERTAIN REQUIRED RECORDS OF CUSTOMER ORDERS; AND VIOLATED EXCHANGE RULES 342(A) AND (B) BY FAILING TO PROVIDE FOR APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND TO ESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEW TO PREVENT THE AFOREMENTIONED VIOLATIONS. THE FIRM HAS CONSENTED TO A CENSURE AND A FINE OF $80,000. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 08/13/2004 Docket/Case Number: HPD#: 04-148

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

Resolution: Decision Resolution Date: 10/22/2004 Sanctions Ordered: Censure Monetary/Fine $80,000.00 Other Sanctions Ordered: Sanction Details: **9/21/04**04-148 ISSUED BY NYSE HEARING PANEL. DECISION: AS SET FORTH IN THE HEARING PANEL DECISION, WHICH WAS BASED ON A STIPULATION OF FACTS AND CONSENT TO PENALTY, THE FIRM, WITHOUT ADMITTING OR DENYING GUILT, VIOLATED SEC RULE 15C3-3 BY FAILING TO FUND ITS PROPRIETARY ACCOUNT FOR ©2021 FINRA. All rights reserved. Report aboutINTRODUCING RBC CAPITAL BROKERS,MARKETS, LLC THEREBY CAUSING HINDSIGHT DEFICIENCIES; 439 VIOLATED EXCHANGE RULE 92(B) BY ENTERING PROPRIETARY ORDERS WHILE REPRESENTING CUSTOMER ORDERS THAT COULD BE EXECUTED AT THE SAME PRICE, WITHOUT USING SEPARATE PROPRIETARY FACILITATION ACCOUNTS; VIOLATED SEC RULES 17A-3(A)(6) AND 17A- 4(B)(1) AND EXCHANGE RULE 440 BY FAILING TO MAINTAIN CERTAIN REQUIRED RECORDS OF CUSTOMER ORDERS; VIOLATED EXCHANGE RULE 342(A) AND (B) BY FAILING TO PREVENT THE AFOREMENTIONED VIOLATIONS. THE FIRM CONSENTED TO A CENSURE AND $80,000 FINE. **9/21/04**04-148 ISSUED BY NYSE HEARING PANEL. www.finra.org/brokercheck DECISION: AS SET FORTH IN THE HEARING PANEL DECISION, WHICH WAS User Guidance BASED ON A STIPULATION OF FACTS AND CONSENT TO PENALTY, THE FIRM, WITHOUT ADMITTING OR DENYING GUILT, VIOLATED SEC RULE 15C3-3 BY FAILING TO FUND ITS PROPRIETARY ACCOUNT FOR INTRODUCING BROKERS, THEREBY CAUSING HINDSIGHT DEFICIENCIES; VIOLATED EXCHANGE RULE 92(B) BY ENTERING PROPRIETARY ORDERS WHILE REPRESENTING CUSTOMER ORDERS THAT COULD BE EXECUTED AT THE SAME PRICE, WITHOUT USING SEPARATE PROPRIETARY FACILITATION ACCOUNTS; VIOLATED SEC RULES 17A-3(A)(6) AND 17A- 4(B)(1) AND EXCHANGE RULE 440 BY FAILING TO MAINTAIN CERTAIN REQUIRED RECORDS OF CUSTOMER ORDERS; VIOLATED EXCHANGE RULE 342(A) AND (B) BY FAILING TO PREVENT THE AFOREMENTIONED VIOLATIONS. THE FIRM CONSENTED TO A CENSURE AND $80,000 FINE. Regulator Statement **10/22/04**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT:MICHELE VAN TASSEL 212-656-5340. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF SEC RULE 15C3-3 FOR FAILING TO FUND THE FIRMS PROPRIETARY ACCOUNT FOR INTRODUCING BROKERS CAUSING A HINDSIGHT DEFICIENCY. ALLEGED VIOLATIONS OF NYSE RULE 92(B) BY ENTERING PROPRIETARY ORDERS WHILE REPRESENTING CUSTOMER ORDERS WITHOUT USING SEPARATE PROPRIETARY ACCOUNTS. ALLEGED VIOLATIONS OF SEC RULES 17A-3(A)(6) AND 17A-4(B)(1) AND NYSE RULE 440 FOR FAILING TO MAKE, MAINTAIN AND PERSERVE CERTAIN REQUIRED RECORDS OF CUSTOMER ORDERS. ALLEGED VIOLATIONS OF NYSE RULES 342(A) AND (B) FOR FAILING TO PROVIDE APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND ESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEW TO PREVENT SUCH VIOLATIONS. Initiated By: NEW YORK STOCK EXACHANGE, INC. DIVISION OF ENFORCEMENT Date Initiated: 12/13/2002 Docket/Case Number: HPD#: 04-148

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

Resolution: Stipulation and Consent Resolution Date: 09/21/2004 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine RBC CAPITAL $80,000.00 MARKETS, LLC 440 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $80,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE STIPULATION AND CONSENT ALONG WITH THE $80,000 FINE. THE FULL PAYMENT FOR THE FINE WAS SENT TO THE NYSE ON 10/29/2004. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE STIPULATION AND CONSENT ALONG WITH THE $80,000 FINE. THE FULL PAYMENT FOR THE FINE WAS SENT TO THE NYSE ON 10/29/2004. i Disclosure 208 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 1021(A), 2110 - RBC DAIN RAUSCHER, INC. PERMITTED AN INDIVIDUAL TO ENGAGE IN ACTIVITIES REQUIRING REGISTRATION AS A GENERAL SECURITIES PRINCIPAL WHEN HE WAS NOT SO REGISTERED. Initiated By: NASD Date Initiated: 10/15/2004 Docket/Case Number: CMS040166

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: 10/15/2004 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 $5,000.00 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 441 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RBC DAIN RAUSCHER, INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, HE IS CENSURED AND FINED $5,000. i Reporting Source: Firm Current Status: Final Allegations: IT IS ALLEGED THAT THE FIRM VIOLATED NASD CONDUCT RULE 2110 AND 1021(A) HAVING PERMITTED AN INDIVIDUAL TO ENGAGE IN ACTIVITIES REQUIRING REGISTRATION AS A GENERAL SECURITIES PRINCIPAL WHEN HE WAS NOT SO REGISTERED. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 10/14/2004 Docket/Case Number: CMS040166

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/14/2004 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE AWC ALONG WITH A CENSURE AND FINE OF $5,000. PAYMENT OF THE FINE WAS SENT TO THE NASD ON 11/11/2004. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE AWC ALONG WITH A CENSURE AND FINE OF $5,000. i Disclosure 209 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 442 www.finra.org/brokercheck User Guidance

Disclosure 209 of 336 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULES G-17 AND G-30(A) - BASED ON BIDS OBTAINED FROM A BROKER, RESPONDENT MEMBER PURCHASED SECURITIES FROM PUBLIC CUSTOMERS FOR ITS OWN ACCOUNT AND THEN SOLD THE SECURITIES TO A BROKER AT A NOMINAL GAIN, WHICH WERE BELOW THE FAIR MARKET VALUE. BY RELYING ON THE BIDS RESPONDENT MEMBER FAILED TO ENSURE THAT THE TRANSACTIONS WERE EXECUTED AT AGGREGATE PRICES THAT WERE FAIR AND REASONABLE. Initiated By: NASD Date Initiated: 09/23/2004 Docket/Case Number: C05040068

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/23/2004 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 $10,000.00 Disgorgement/Restitution Other Sanctions Ordered: 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 $10,000, REQUIRED TO PAY $8,714.50, PLUS INTEREST IN RESTITUTION TO PUBLIC CUSTOMERS, AND SHALL PROVIDE TO NASD A COPY OF ITS UPDATED WRITTEN SUPERVISORY PROCEDURES AS THEY RELATE TO THE DETERMINATION OF THE FAIR MARKET VALUE OF MUNICIPAL SECURITIES BEING BOUGHT OR SOLD FROM A PUBLIC CUSTOMER. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 443 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 www.finra.org/brokercheck $10,000, REQUIRED TO PAY $8,714.50, PLUS INTEREST IN RESTITUTION TO User Guidance PUBLIC CUSTOMERS, AND SHALL PROVIDE TO NASD A COPY OF ITS UPDATED WRITTEN SUPERVISORY PROCEDURES AS THEY RELATE TO THE DETERMINATION OF THE FAIR MARKET VALUE OF MUNICIPAL SECURITIES BEING BOUGHT OR SOLD FROM A PUBLIC CUSTOMER. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF MSRB RULES G-17 AND G-30(A). Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 09/23/2004 Docket/Case Number: C05040068

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: 10/21/2004 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Disgorgement/Restitution Other Sanctions Ordered: WITHIN 90 DAYS OF THE ACCEPTANCE OF THE AWC, THE FIRM MUST PROVIDE THE NASD A COPY OF ITS UPDATED WRITTEN SUPERVISORY PROCEDURES AS THEY RELATE TO THE DETERMINATION OF THE FAIR MARKET VALUE OF MUNICIPAL SECURITIES BOUGHT AND SOLD FROM A PUBLIC CUSTOMER. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE AWC ALONG WITH THE $10,000 FINE AND CENSURE. THE FINE WAS PAID ON 10/21/04. THE FIRM ALSO PAID $8,714.50 PLUS INTEREST IN RESTITUTION ON 10/8/04 TO THE CLIENT. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE AWC ALONG WITH THE $10,000 FINE AND CENSURE. THE FINE WAS PAID ON 10/21/04. THE FIRM ALSO PAID $8,714.50 PLUS INTEREST IN RESTITUTION ON 10/8/04 TO THE CLIENT. i Disclosure 210 of 336

Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULE 2110, AND NASD MARKETPLACE RULE 6130(B) - RESPONDENT MEMBER ("FIRM") FAILED TO ACCEPT OR DECLINE IN AUTOMATED CONFIRMATION TRANSACTION SERVICE ("ACT") TRANSACTIONS IN ELIGIBLE SECURITIES WITHIN TWENTY MINUTES AFTER EXECUTION. Initiated By: NASD Date Initiated: 08/27/2003 Docket/Case Number: CMS030189

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: 08/27/2003 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRM 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: IT IS ALLEGED THAT RAUSCHER PIERCE SECURITIES CORPORATION, A DIVISION OF RBC DAIN RAUSCHER INC., VIOLATED NASD MARKETPLACE RULE 6130(B) AND NASD CONDUCT RULE 2110 RELATING TO VIOLATIONS OF THE AUTOMATED CONFIRMATION TRANSACTION SERVICE (ACT). Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 06/25/2003 Docket/Case Number: CMS030189 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 445 www.finra.org/brokercheck User Guidance

Docket/Case Number: CMS030189

Principal Product Type: Other 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: 08/27/2003 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE CENSURE AND FINE OF $7,500.00. i Disclosure 211 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD MARKETPLACE RULE 4613(E)(1)(C) - RESPONDENT MEMBER ("FIRM"), A MARKET MAKER IN THE SECURITIES, WAS A PARTY TO A LOCKED OR CROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING AND ENTERED A PRE-OPENING BID (OFFER) QUOTATION THAT WAS EQUAL TO OR GREATER (LESS) THAN THE PRE-OPENING ASKED (BID) QUOTATION OF ANOTHER MARKET MAKER ENTERING QUOTATIONS IN THE SALE SECURITIES AND FAILED TO SEND IMMEDIATELY THROUGH SELECTNET A TRADE-OR-MOVE MESSAGE TO THE MARKET MAKER WHOSE QUOTATIONS IT LOCKED OR CROSSED FOR AT LEAST 5,000 SHARES IN AGGREGATE. IN ADDITION, THE FIRM WAS A PARTY TO A LOCKED OR CROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING AND FAILED, WITHIN 30 SECONDS OF RECEIVING A TRADE-OR- MOVE MESSAGE, EITHER TO FILL THE INCOMING TRADE-OR-MOVE MESSAGE FOR THE FULL SIZE OF THE MESSAGE OR TO MOVE ITS BID DOWN (OFFER UP) BY A QUOTATION INCREMENT THAT WOULD UNLOCK/UNCROSS THE MARKET. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/26/2003 Docket/Case Number: CMS030147 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 446 www.finra.org/brokercheck User Guidance

Docket/Case Number: CMS030147

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: 06/26/2003 Sanctions Ordered: Censure Monetary/Fine $17,500.00 Other Sanctions Ordered: 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 AND FINED $17,500. i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGED VIOLATIONS OF NASD MARKETPLACE RULE 4613(E)(1)(C) IN THAT IT WAS ALLEGED THE FIRM LOCKED OR CROSSED THE MARKET PRE-OPEN WITHOUT SENDING THE REQUISITE "TRADE OR MOVE" SELECTNET MESSAGE AND WAS THE RECIPIENT OF SUCH MESSAGES AND FAILED TO TAKE THE APPROPRIATE ACTIONS WITHIN THE REQUIRED TIMEFRAME. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/26/2003 Docket/Case Number: CMS030147

Principal Product Type: Other Other Product Type(s): UNKNOWN TYPE OF SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 447 www.finra.org/brokercheck User Guidance

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/26/2003 Sanctions Ordered: Censure Monetary/Fine $17,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE AWC ALONG WITH THE CENSURE AND FINE OF $17,500. i Disclosure 212 of 336 Reporting Source: Regulator Current Status: Final Allegations: **6/3/03**STIPULATION AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILTY, CONSENTED TO FINDINGS:THAT THE FIRM ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE IN THAT THE FIRM FAILED TO MAKE AND PRESERVE TIMELY RECORDS RELATING TO THE DESIGNATION AND EXECUTION OF CUSTOMER ORDERS; THAT THE FIRM VIOLATED EXCHANGE RULE 440 AND SEC REGS. 240.17A-3 AND 17A-4 BY FAILING TO PRESERVE REQUIRED RECORDS RELATING TO RECEIPT AND EXECUTION OF CUSTOMER ORDERS; AND THAT THE FIRM VIOLATED EXCHANGE RULE 342 IN THAT THE FIRM FAILED TO REASONABLY SUPERVISE AND CONTROL THE ACTIONS OF ITS EMPLOYEES, AND FAILED TO ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, TO ASSURE COMPLIANCE WITH EXCHANGE RULES AND THE FEDERAL SECURITIES LAWS, WITH RESPECT TO: (A) THE PROPER EXECUTION OF CUSTOMER ORDERS WITH THE ACCOUNT DESIGNATION INFORMATION REQUIRED BY EXCHANGE RULES AND THE FEDERAL SECURITIES LAWS; (B) MAKING AND PRESERVING REQUIRED AND TIMELY RECORDS RELATING TO DESIGNATION AND EXECUTION OF CUSTOMER ORDERS; AND (C) SUPERVISION OF A BRANCH OFFICE MANAGER WHOM THE FIRM KNEW WAS THE SUBJECT OF AN ENFORCEMENT INVESTIGATION RELATED TO HIS RESPONSIBILITIES AS A BRANCH OFFICE MANAGER.CONSENTED TO SANCTION: THE IMPOSITION BY THE EXCHANGE OF THE PENALTY OF A CENSURE, A FINE OF $275,000, AND AN UNDERTAKING.

Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 06/03/2003 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 448 www.finra.org/brokercheck User Guidance

Date Initiated: 06/03/2003 Docket/Case Number: HPD#: 03-139

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

Resolution: Decision Resolution Date: 08/22/2003 Sanctions Ordered: Censure Monetary/Fine $275,000.00 Other Sanctions Ordered: CONSENT TO CENSURE, $275,000 FINE, AND SPECIAL UNDERTAKING. Sanction Details: **7/25/03**HEARING PANEL DECISION EVENT: JULY 25, 2003 VIOLATIONS FOUND: VIOLATIONS: FAILED TO MAKE AND PRESERVE TIMELY RECORDS RELATING TO THE DESIGNATION AND EXECUTION OF CUSTOMER ORDERS; FAILED TO PRESERVE RECORDS REQUIRED BY EXCHANGE RULE 440 AND SEC REGS. 240.17A-3 AND 17A-4 RELATING TO RECEIPT AND EXECUTION OF CUSTOMER ORDERS; FAILED TO REASONABLY SUPERVISE AND CONTROL THE ACTIONS OF ITS EMPLOYEES AND TO ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO ASSURE COMPLIANCE WITH EXCHANGE RULES AND FEDERAL SECURITIES LAWS WITH RESPECT TO: THE PROPER EXECUTION OF CUSTOMER ORDERS WITH THE ACCOUNT DESIGNATION INFORMATION REQUIRED BY EXCHANGE RULES AND FEDERAL SECURITIES LAWS, MAKING AND PRESERVING REQUIRED AND TIMELY RECORDS RELATING TO THE DESIGNATION AND EXECUTION OF CUSTOMER ORDERS; AND SUPERVISION OF A BRANCH OFFICE MANAGER WHOM THE FIRM KNEW WAS THE SUBJECT OF AN ENFORCEMENT INVESTIGATION RELATED TO HIS RESPONSIBILITIES AS A BRANCH OFFICE MANAGER. SANCTION: CENSURE, FINE OF $275,000 AND SPECIAL UNDERTAKING. Regulator Statement **8/22/03**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY .EVELYN PENA 212-656-5211 i Reporting Source: Firm Current Status: Final Allegations: ALLEGATIONS THAT THE FIRM FAILED TO MAKE AND PRESERVE TIMELY ©2021 FINRA. All rights reserved. Report aboutRECORDS RBC CAPITAL RELATING MARKETS, TO LLC THE DESIGNATION AND EXECUTION OF 449 CUSTOMER ORDERS; VIOLATION OF EXCHANGE RULE 440 AND SEC REGS. 240.17A-3 AND 17A-4; VIOLATION OF EXCHANGE RULE 342. www.finra.org/brokercheck User Guidance

Allegations: ALLEGATIONS THAT THE FIRM FAILED TO MAKE AND PRESERVE TIMELY RECORDS RELATING TO THE DESIGNATION AND EXECUTION OF CUSTOMER ORDERS; VIOLATION OF EXCHANGE RULE 440 AND SEC REGS. 240.17A-3 AND 17A-4; VIOLATION OF EXCHANGE RULE 342. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 06/03/2003 Docket/Case Number: HPD#: 03-139

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

Resolution: Stipulation and Consent Resolution Date: 08/22/2003 Sanctions Ordered: Censure Monetary/Fine $275,000.00 Other Sanctions Ordered: THE FIRM HAS AGREED TO AN UNDERTAKING WHEREBY AN INDEPENDENT CONSULTANT SHALL BE RETAINED TO REVIEW THE FIRMS BLOCK ORDER ALLOCATION PROCEDURES. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ACCEPTED THE CENSURE AND FINE OF $275,000. i Disclosure 213 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY INC MERGING INTO APPLICANT, TUCKER WAS ALLEGED TO HAVE INCORRECTLY REPORTED TO FIPS TRANSACTIONS DURING THE PERIOD OF 2/28/00 THROUGH 6/8/00. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 04/02/2002 Docket/Case Number: CMS020051 AWC

Principal Product Type: Debt - Corporate Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 450 Sought: 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: 04/02/2002 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM ACCEPTED THE CENSURE AND PAID THE FINE OF $7500.00 Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, TUCKER CONSENTED TO A FINE OF $7500 AND FINDINGS BY NASDR THAT IT VIOLATED MARKETPLACE RULES 6240(A)(3) AND 6240(B)(3) IN THAT IT MADE INCORRECT REPORTS INTO THE FIPS SYSTEM. i Disclosure 214 of 336 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT SUTRO & CO., INC AND TUCKER ANTHONY INCORPORATED (AFFILIATED COMPANIES) VIOLATED NYSE RULE 342, 410 AND 440A WITH RESPECT TO THE SUPERVISION OF THEIR JOINT NYSE FLOOR TRADING ACTIVITY. IT IS FURTHER ALLEGED THAT SUTRO & CO. VIOLATED NYSE RULES 407(B) WITH RESPECT TO THE MAINTENANCE OF OUTSIDE ACCOUNTS AND 345A WITH RESPECT TO CONTINUING EDUCATION REQUIREMENTS. Initiated By: NEW YORK STOCK EXCHANGE, INC. Date Initiated: 12/20/2002 Docket/Case Number: 02-216

Resolution: Stipulation and Consent Resolution Date: 02/05/2003 Sanctions Ordered: Censure Monetary/Fine $125,000.00 Other Sanctions Ordered: Sanction Details: FINE WAS APPORTIONED $75,000 TO SUTRO & CO. AND $50,000 TO TUCKER ANTHONY. THE FINES WERE PAID AS OF 2/5/03. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO AND TUCKER CONSENTED TO THE ENTRY BY THE NYSE OF A STIPULATION TO FACTS AND CONSENT TO PENALTY AS DESCRIBED ABOVE. i Disclosure 215 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULE 2110 AND NASD MARKETPLACE RULE 6240(A)(2) - RESPONDENT MEMBER FAILED TO REPORT TO FIXED INCOME PRICING SYSTEM ("FIPS") TRANSACTIONS IN FIPS SECURITIES WITHIN FIVE MINUTES AFTER EXECUTION DURING THE REVIEW PERIOD. SUCH CONDUCT CONSTITUTES A PATTERN OR PRACTICE OF LATE REPORTING AND IS CONSIDERED CONDUCT INCONSISTENT WITH HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EUITABLE PRINCIPLES OF TRADE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/30/2003 Docket/Case Number: CMS030008

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: 01/30/2003 Sanctions Ordered: Censure Monetary/Fine $12,500.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 452 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS AND THEREFORE, THE FIRM IS CENSURED AND FINED $12,500.00.

i Reporting Source: Firm Current Status: Final Allegations: ALLEGATIONS OF THE FIRM FAILING TO REPORT TO FIPS TRANSACTIONS IN FIPS SECURITIES WITHIN FIVE MINUTES AFTER EXECUTION. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 05/22/2002 Docket/Case Number: MRD200235334

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: 01/30/2003 Sanctions Ordered: Censure Monetary/Fine $12,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ALLEGATIONS, THE FIRM ACCEPTED THE AWC AND A FINE OF $12,500. Firm Statement WITHOUT ADMITTING OR DENYING ALLEGATIONS, THE FIRM ACCEPTED THE AWC AND A FINE OF $12,500. i Disclosure 216 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULE 3320, NASD MARKETPLACE RULE 4613(B) AND ©2021 FINRA. All rights reserved. Report about4613(E)(1)(C), RBC CAPITAL AND MARKETS, SEC RULE LLC 11AC1-1 - WITHOUT ADMITTING OR DENYING 453 THE ALLEGATIONS, THE RESPONDENT MEMBER FIRM CONSENTED TO THE ENTRY OF FINDINGS THAT IT, A MARKET MAKER IN SECURITIES, CAUSED A LOCKED/CROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING BY ENTERING A BID (ASK) QUOTATION THAT LOCKED/CROSSED ANOTHER MARKET MAKER'S QUOTATIONS WITHOUT IMMEDIATELY THEREAFTER SENDING THROUGH SELECTNET TO THE MARKET MAKER(S) WHOSE QUOTE(S) IT LOCKED OR CROSSED A TRADE-OR-MOVE MESSAGE(S) THAT WAS AT THE RECEIVING MARKET MAKER'S QUOTED PRICE AND WHOSE AGGREGATE SIZE WAS AT LEAST 5000 SHARES. THE MEMBER FIRM, A MARKET MAKER IN SECURITIES, WAS A PARTY TO A LOCKED OR CROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING AND RECEIVED A TRADE-OR-MOVE MESSAGE IN EACH INSTANCE THROUGH SELECTNET AND WITHIN 30 SECONDS OF RECEIVING SUCH MESSAGES, FAILED 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. THE MEMBER FIRM WAS A REGISTERED MARKET MAKER IN THE SECURITIES, AND AN ORDER WAS PRESENTED TO THE FIRM AT THE FIRM'S PUBLISHED BID OR PUBLISHED OFFER IN AN AMOUNT UP TO ITS PUBLISHED QUOTATION SIZE. THE MEMBER FIRM FAILED TO EXECUTE THE ORDERS UPON PRESENTMENT AND THEREBY FAILED TO HONOR ITS PUBLISHED QUOTATION. www.finra.org/brokercheck User Guidance

Allegations: NASD CONDUCT RULE 3320, NASD MARKETPLACE RULE 4613(B) AND 4613(E)(1)(C), AND SEC RULE 11AC1-1 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER FIRM CONSENTED TO THE ENTRY OF FINDINGS THAT IT, A MARKET MAKER IN SECURITIES, CAUSED A LOCKED/CROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING BY ENTERING A BID (ASK) QUOTATION THAT LOCKED/CROSSED ANOTHER MARKET MAKER'S QUOTATIONS WITHOUT IMMEDIATELY THEREAFTER SENDING THROUGH SELECTNET TO THE MARKET MAKER(S) WHOSE QUOTE(S) IT LOCKED OR CROSSED A TRADE-OR-MOVE MESSAGE(S) THAT WAS AT THE RECEIVING MARKET MAKER'S QUOTED PRICE AND WHOSE AGGREGATE SIZE WAS AT LEAST 5000 SHARES. THE MEMBER FIRM, A MARKET MAKER IN SECURITIES, WAS A PARTY TO A LOCKED OR CROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING AND RECEIVED A TRADE-OR-MOVE MESSAGE IN EACH INSTANCE THROUGH SELECTNET AND WITHIN 30 SECONDS OF RECEIVING SUCH MESSAGES, FAILED 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. THE MEMBER FIRM WAS A REGISTERED MARKET MAKER IN THE SECURITIES, AND AN ORDER WAS PRESENTED TO THE FIRM AT THE FIRM'S PUBLISHED BID OR PUBLISHED OFFER IN AN AMOUNT UP TO ITS PUBLISHED QUOTATION SIZE. THE MEMBER FIRM 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: 08/05/2002 Docket/Case Number: CMS020138

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: 08/05/2002 Sanctions Ordered: Censure Monetary/Fine $35,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $35,000 (COMPOSED OF A $25,000 FINE FOR THE TRADE-OR-MOVE VIOLATIONS AND A $10,000 FINE FOR THE FIRM ©2021 FINRA. All rights reserved. Report aboutQUOTE RBC VIOLATIONS).CAPITAL MARKETS, LLC 454 www.finra.org/brokercheck User Guidance

Sanction Details: A CENSURE AND A FINE OF $35,000 (COMPOSED OF A $25,000 FINE FOR THE TRADE-OR-MOVE VIOLATIONS AND A $10,000 FINE FOR THE FIRM QUOTE VIOLATIONS). i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGED THAT RBC DAIN RAUSCHER INC.: I)CAUSED A LOCKED/CROSSED MARKET IN 95 INSTANCES DURING THE 2ND QUARTER 2001 WITHOUT SENDING THE REQUISITE "TRADE-OR-MOVE" MESSAGE, II) FAILED TO RESPOND TO A "TRADE-OR-MOVE" MESSAGE IN A TIMELY MANNER IN 84 INSTANCES DURING THE 3RD QUARTER 2001, III) FAILED TO MEET THE FIRM'S FIRM QUOTE OBLIGATED IN 118 INSTANCES DURING 3RD QUARTER 2000 AND IN 48 INSTANCES DURING 2ND QUARTER 2001. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 08/05/2002 Docket/Case Number: MRD200130434 **SEE SUMMARY BELOW

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: 08/05/2002 Sanctions Ordered: Censure Monetary/Fine $35,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND $35,000.00 LEVIED AGAINST APPLICANT. PAYMENT OF FINE PENDING. Firm Statement THE RESOLUTION TO CASE NUMBERS MRD200131939, MRD200127546 AND MRD200130685 ARE ALSO INCLUDED IN THIS FILING. i Disclosure 217 of 336 Reporting Source: Firm Current Status: Final ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 455 www.finra.org/brokercheck User Guidance

Allegations: ALLEGED VIOLATIONS OF PART I, SECTION C.3(C) OF SCHEDULE D OF THE ASSOCIATION'S BY-LAWS IN THAT SUTRO FAILED TO REPORT ITS NASDAQ VOLUME IN ONE SECURITY ON 10/24/1986. Initiated By: NASD Date Initiated: 02/05/1987 Docket/Case Number: MS-498-AWC

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: 04/07/1987 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: NOT PROVIDED Firm Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-498-AWC: LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WAS FILED ON FEBRUARY 5, 1987,WHEREIN, WIHTOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO CONSENTED TO FINDINGS OF FAILURE TO REPORT ITS NASDAQ VOLUME IN ONE SECURITY ON 10/24/1986. THE AWC WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON MARCH 6, 1987 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON APRIL 7, 1987. FINE OF $250. i Disclosure 218 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: ALLEGED A PROBABLE CAUSE FOR FINDING A VIOLATION WITHIN THE DISCIPLINARY JURISDICTION OF THE EXCHANGE. Initiated By: CBOE Date Initiated: 05/04/1987

Docket/Case Number: 87-0022

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 FINE $500 JOINT AND SEVERALLY Sought:

Resolution: Consent Resolution Date: 05/04/1987 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: NOT PROVIDED Firm Statement 07/20/1987: CBOE DECISION ACCEPTING OFFER OF SETTLEMENT IN THE MATTER OF: JEFFREY DAFT AND SUTRO & CO., INC., RESPONDENTS; FILED NO. 87-0022. IN SUBMITTING THIS OFFER OF SETTLEMENT, SUTRO NEITHER ADMIT NOR DENY THE VIOLATIONS ALLEGED IN THE STATEMENT OF CHARGES, AND SUTRO CONSENTED TO A $500 JOINT AND SEVERALLY FINE. i Disclosure 219 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: ALLEGED VIOLATIONS OF PART VI, SECTION 4(A) OF SCHEDULE D IN THAT SUTRO FAILED TO REPORT NASDAQ VOLUME. Initiated By: NASD Date Initiated: 07/18/1989 Docket/Case Number: MS-822-AWC

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 $250 FINE Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 457 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief $250 FINE Sought:

Resolution: Consent Resolution Date: 09/25/1989 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: SUTRO WAS FINED OF $250.00 Firm Statement 11/04/1989: MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-822- AWC: LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WAS FILED ON JULY 18, 1989,ALLEGING VIOLATIONS OF PART VI, SECTION 4(A) OF SCHEDULE D IN THAT SUTRO FAILED TO REPORT NASDAQ VOLUME. THE AWC WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON AUGUST 30, 1989 AND BY THE NBCC ON ON SEPTEMBER 25, 1989. SUTRO WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, CONSENTED TO THE ASSOCIATION'S FINDINGS AND WAS FINED IN THE AMOUNT OF $250. i Disclosure 220 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: ALLEGED VIOLATIONS OF PART VI, SECTION 5(A) OF SCHEDULE D IN THAT SUTRO TO REPORT THEIR NASDAQ VOLUME. Initiated By: NASD Date Initiated: 09/09/1989 Docket/Case Number: MS-846-AWC

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 $250 FINE Sought:

Resolution: Consent Resolution Date: 12/12/1989 Sanctions Ordered: Monetary/Fine $250.00 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 458 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: FINE OF $250.00 Firm Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-846-AWC: LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED SEPTEMBER 19, 1989 WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO & CO., INC. CONSENTED TO FINDINGS OF FAILURE TO REPORT THE NASDAQ VOLUME. THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTE ON NOVEMBER 10, 1989 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE DECEMBER 12, 1989. $250 FINE AND PAID ON 3/12/1990. i Disclosure 221 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: THE NASD ALLEGED THAT SUTRO VIOLATED ARTICLE III, SECTION 1 AND SEC RULE 15C2-11. Initiated By: NASD Date Initiated: 07/12/1991 Docket/Case Number: MS-1142-AWC

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/23/1991 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: SUTRO CONSENTED TO A $500 FINE. Firm Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-1142-AWC (A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED JULY 12, 1991 WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO & ©2021 FINRA. All rights reserved. Report aboutCO., RBC INC. CAPITAL CONSENTED MARKETS, TO LLC FINDINGS. ALLEGING VIOLATIONS OF ARTICLE 459 III, SECTION 1 AND SEC RULE 15C2-11. THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED ON SEPTEMBER 6, 1991 BY THE MARKET SURVEILLANCE COMMITTEE AND ON OCTOBER 23, 1991 BY THE NATIONAL BUSINESS CONDUCT COMMITTEE. SUTRO CONSENTED TO A $500 FINE. www.finra.org/brokercheck User Guidance MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-1142-AWC (A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED JULY 12, 1991 WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO & CO., INC. CONSENTED TO FINDINGS. ALLEGING VIOLATIONS OF ARTICLE III, SECTION 1 AND SEC RULE 15C2-11. THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED ON SEPTEMBER 6, 1991 BY THE MARKET SURVEILLANCE COMMITTEE AND ON OCTOBER 23, 1991 BY THE NATIONAL BUSINESS CONDUCT COMMITTEE. SUTRO CONSENTED TO A $500 FINE. i Disclosure 222 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: SUTRO WAS ALLEGED TO HAVE VIOLATED SECTION (C)2(D) OF THE RULES OF PRACTICE AND PROCEDURE FOR SOES AND ACTICLE III, SECTION I OF THE ASSOCIATION'S RULES OF FAIR PRACTICE IN WHICH SUTRO, ON 22 OCCASIONS, ENTERED ORDERS ON A AGENCY BASIS INTO SOES FOR WHICH SUTRO WAS A REGISTERED MARKET MARKER DURING PERIOD MAY 25, 1993 THROUGH JUNE 3, 1993. Initiated By: NASD Date Initiated: 09/23/1993 Docket/Case Number: CMS930047-AWC

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/10/1993 Sanctions Ordered: Monetary/Fine $1,500.00 Other Sanctions Ordered: Sanction Details: FINE OF $1,500 Firm Statement ON 2/15/1994: MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS930047 AWC (A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED SEPTEMBER 23, 19993 WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO & CO., INC. CONSENTED TO FINDINGS THAT RESPONDENTS ENTERED ORDERS ON AN AGENCY BASIS INTO SOES FOR ©2021 FINRA. All rights reserved. Report aboutSECURITIES RBC CAPITAL IN MARKETS,WHICH THEY LLC WERE REGISTERED MARKET MAKERS, 460 CONTRARY TO THE PROVISIONS OF THE ASSOCIATION'S FULES OF PRACTICE AND PROCEDURE FOR SOES: THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON DECEMBER 10, 1993 AND BY NATIONAL BUSINESS CONDUCT COMMITTE ON FEBRUARY 14, 1994. SUTRO & CO. PAID A #1,500 FINE. www.finra.org/brokercheck ON 2/15/1994: MARKET SURVEILLANCE COMMITTEE COMPLAINT User Guidance #CMS930047 AWC (A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED SEPTEMBER 23, 19993 WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO & CO., INC. CONSENTED TO FINDINGS THAT RESPONDENTS ENTERED ORDERS ON AN AGENCY BASIS INTO SOES FOR SECURITIES IN WHICH THEY WERE REGISTERED MARKET MAKERS, CONTRARY TO THE PROVISIONS OF THE ASSOCIATION'S FULES OF PRACTICE AND PROCEDURE FOR SOES: THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON DECEMBER 10, 1993 AND BY NATIONAL BUSINESS CONDUCT COMMITTE ON FEBRUARY 14, 1994. SUTRO & CO. PAID A #1,500 FINE. i Disclosure 223 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIR TO SUTRO MERGING INTO APPLICANT: THE NASD ALLEGED VIOLATIONS OF SECTION (C)2(E) OF THE RULES OF FAIR PRACTICE AND PROCEDURES FOR SOES. Initiated By: NASD Date Initiated: 07/13/1994 Docket/Case Number: CMS940060-AWC

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/25/1994 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: SUTRO WAS FINED $1,000. Firm Statement MARKET SURVEILLANCE COMMITTE COMPLAINT #CMS940060 AWC. LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC)WHEREBY, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO CONSENTED TO A FINE OF $1,000. i Disclosure 224 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 461 www.finra.org/brokercheck User Guidance

Disclosure 224 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: SUTRO & CO. WAS SUSPENDED FROM THE NEW YORK STOCK EXCHANGE. Initiated By: NYSE Date Initiated: 07/09/1930 Docket/Case Number: UNKNOWN

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

Resolution: Other Resolution Date: 01/22/1931 Sanctions Ordered: Suspension Other Sanctions Ordered: Sanction Details: SUPENDED FROM THE NYSE. Firm Statement SUTRO & CO. WAS REINSTATED. ALL CHARGES WERE RETRACTED BY THE NEW YORK STOCK EXCHANGE. RICHARD WHITNEY, THE EXCHANGE PRESIDENT, TESTIFIED BEFORE A CONGRESSIONAL COMMITTEE THAT SUTRO WAS BLAMELESS OF ANY VIOLATION AND THAT THE EXCHANGE ERRED IN SUSPENDING IT. i Disclosure 225 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: NOT PROVIDED Initiated By: NASD Date Initiated: 04/25/1975 Docket/Case Number: N-VS-126

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: 06/09/1975 Sanctions Ordered: Other Sanctions Ordered: Sanction Details: NOT PROVIDED Firm Statement PRIOR TO SUTRO MERGING INTO APPLICANT: NASDAQ COMPLAINT N-VS- 126 FILED 04/25/1975 ACCTPED 05/08/1975 FINAL 06/09/1975. i Disclosure 226 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: NOT PROVIDED Initiated By: NASD Date Initiated: 01/21/1976 Docket/Case Number: N-VS-189

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 EXACT SANCTION UNKNOWN01/21/1976 Sought:

Resolution: Other Resolution Date: 01/21/1976 Sanctions Ordered: Other Sanctions Ordered: NOT PROVIDED

Sanction Details: NOT PROVIDED Firm Statement NASDAQ COMPLAINT N-VS-189 FILED ON 01/21/1976. FURTHER INFORMATION IS UNAVAILABLE DUE TO PURGING OF RECORDS. i Disclosure 227 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: ALLEGATION THAT DURING 1976 - 1977, SUTRO PERMITTED OPTIONS ACCOUNTS TO BE MAINTAINED IN ONE OF ITS OFFICES IN VIOLATION OF MARGIN REQUIREMENTS. Initiated By: ASE Date Initiated: 03/23/1979 Docket/Case Number: UNKNOWN

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: 03/23/1979 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: SUTRO WAS FINED $20,000. ROSELAUF WAS FINED $7,500, HICKMAN WAS FINED $1,000 AND IRVINE WAS FINED $4,000 AND SUSPENDED FOR 15 DAYS FROM EMPLOYMENT IN ANY SUPERVISORY CAPACITY WITH ANY MEMBER OR MEMBER ORGANIZATION OF A NATIONAL SECURITIES EXCHANGE. IN ADDITION, ALL WERE CENSURED. Firm Statement SUTRO, ROSELAUF, HICKMAN AND IRVINE SETTLED THE CHARGES WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. THE EXCHANGE FOUND THAT FROM LATE 1976 THROUGH EARLY 1977 SUTRO PERMITTED CUSTOMER OPTIONS ACCOUNTS AT ONE OF ITS BRANCH OFFICES TO BE MAINTAINED IN VIOLATION OF EXCHANGE MARGIN REQUIREMENTS. THE EXCHANGE FURTHER DETERMINED THAT THESE VIOLATIONS RESULTED FROM THE FAILURE OF ROSELAUF, HICKMAN, AND IRVINE TO ©2021 FINRA. All rights reserved. Report aboutREASONABLY RBC CAPITAL DISCHARGE MARKETS, LLC THEIR SUPERVISORY RESPONSIBILITIES. 464 SUTRO WAS FINED $20,000, ROSELAUF WAS FINED $7,500, HICKMAN WAS FINED $1,000, AND IRVINE WAS FINED $4,000 AND SUSPENDED FOR 15 DAYS FROM EMPLOYMENT IN ANY SUPERVISORY CAPACITY WITH ANY MEMBER OR MEMBER ORGANIZATION OF A NATIONAL SECURITIES EXCHANGE. IN ADDITION ALL WERE CENSURED. SUTRO, ROSELAUF, HICKMAN AND IRVINE SETTLED THE CHARGES WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. THE EXCHANGE www.finra.org/brokercheck FOUND THAT FROM LATE 1976 THROUGH EARLY 1977 SUTRO PERMITTED User Guidance CUSTOMER OPTIONS ACCOUNTS AT ONE OF ITS BRANCH OFFICES TO BE MAINTAINED IN VIOLATION OF EXCHANGE MARGIN REQUIREMENTS. THE EXCHANGE FURTHER DETERMINED THAT THESE VIOLATIONS RESULTED FROM THE FAILURE OF ROSELAUF, HICKMAN, AND IRVINE TO REASONABLY DISCHARGE THEIR SUPERVISORY RESPONSIBILITIES. SUTRO WAS FINED $20,000, ROSELAUF WAS FINED $7,500, HICKMAN WAS FINED $1,000, AND IRVINE WAS FINED $4,000 AND SUSPENDED FOR 15 DAYS FROM EMPLOYMENT IN ANY SUPERVISORY CAPACITY WITH ANY MEMBER OR MEMBER ORGANIZATION OF A NATIONAL SECURITIES EXCHANGE. IN ADDITION ALL WERE CENSURED. i Disclosure 228 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: THE NASD ALLEGED THAT 32 SALES OF SECURITIES WERE MADE TO CUSTOMERS AT A PRICE IN EXCESS OF THE NASD'S GUIDELINES DURING A PERIOD OF APPROXIMATELY 7 WEEKS DURING MID 1983. Initiated By: NASD Date Initiated: 06/15/1984 Docket/Case Number: SF-1048

Principal Product Type: Other Other Product Type(s): EXACT PRODUCT TYPE UNKNOWN Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 05/09/1986 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: SUTRO WAS CENSURED & FINED $1,000. TWO OF THE OFFICERS, SCOTT FLANAGAN & JOSEPH GRASSO, WERE CENSURED. Firm Statement DECISION RENDERED ON 10/2/1985, WHEREIN RESPONDENT MEMBER IS CENSURED AND FINED $1,000, RESPONDENTS GRASSO AND FLANAGAN ARE CENSURED, AND THE MEMBER IS ASSESSED COSTS OF $618.00. THE COMPLAINT IS DISMISSED WITH REGARD TO RESPONDENT AGUER IN THAT ALLEGATIONS AS CONTAINED IN THE SECOND CAUSE OF ©2021 FINRA. All rights reserved. Report aboutCOMPLAINT, RBC CAPITAL THE MARKETS, ONLY CAUSELLC IN WHICH HE IS NAMED, WERE DISMISSED 465 WITH REGARD TO HIM. OCTOBER 25, 1985 - APPEALED TO THE BOARD OF GOVERNORS. BOARD OF GOVERNORS' DECISION RENDERED APRIL 10, 1986, WHEREIN THE FINDINGS ARE AFFIRMED WITH THE EXCEPTION OF CERTAIN OF THE TRANSACTIONS WITH REGARD TO RESPONDENT GRASSO AND THE SANCTIONS ARE AFFIRMED; THEREFORE, RESPONDENT MEMBER IS CENSURED, FINED $1,000 AND ASSESSED COSTS OF $618.00, RESPONDENTS GRASSO AND FLANAGAN ARE CENSURED AND RESPONDENT GRASSO IS ASSESSED COSTS OF THE APPEAL OF $756.08, AND THE COMPLAINT IS DISMISSED WITH REGARD TO RESPONDENT AGUER. IF NO FURTHER ACTION, DECISION IS FINAL MAY 9, 1986. MAY 9, 1986 - BOARD OF GOVERNORS' DECISION FINAL. $1,618 PAID ON 11/5/1985. WITHOUT ADMITTING OR DENYING LIABILITY, SUTRO WAS CENSURED & FINED $1,000. TWO OF ITS OFFICERS, SCOTT FLANAGAN & JOSEPH GRASSO, WERE CENSURED. DECISION RENDERED ON 10/2/1985, WHEREIN RESPONDENT MEMBER IS www.finra.org/brokercheck CENSURED AND FINED $1,000, RESPONDENTS GRASSO AND FLANAGAN User Guidance ARE CENSURED, AND THE MEMBER IS ASSESSED COSTS OF $618.00. THE COMPLAINT IS DISMISSED WITH REGARD TO RESPONDENT AGUER IN THAT ALLEGATIONS AS CONTAINED IN THE SECOND CAUSE OF COMPLAINT, THE ONLY CAUSE IN WHICH HE IS NAMED, WERE DISMISSED WITH REGARD TO HIM. OCTOBER 25, 1985 - APPEALED TO THE BOARD OF GOVERNORS. BOARD OF GOVERNORS' DECISION RENDERED APRIL 10, 1986, WHEREIN THE FINDINGS ARE AFFIRMED WITH THE EXCEPTION OF CERTAIN OF THE TRANSACTIONS WITH REGARD TO RESPONDENT GRASSO AND THE SANCTIONS ARE AFFIRMED; THEREFORE, RESPONDENT MEMBER IS CENSURED, FINED $1,000 AND ASSESSED COSTS OF $618.00, RESPONDENTS GRASSO AND FLANAGAN ARE CENSURED AND RESPONDENT GRASSO IS ASSESSED COSTS OF THE APPEAL OF $756.08, AND THE COMPLAINT IS DISMISSED WITH REGARD TO RESPONDENT AGUER. IF NO FURTHER ACTION, DECISION IS FINAL MAY 9, 1986. MAY 9, 1986 - BOARD OF GOVERNORS' DECISION FINAL. $1,618 PAID ON 11/5/1985. WITHOUT ADMITTING OR DENYING LIABILITY, SUTRO WAS CENSURED & FINED $1,000. TWO OF ITS OFFICERS, SCOTT FLANAGAN & JOSEPH GRASSO, WERE CENSURED. i Disclosure 229 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: THE ASE ALLEGED THAT SUTRO & CO. HAD CROSSED LISTED OPTIONS FOR THE SAME AMOUNT. Initiated By: ASE Date Initiated: 12/13/1985 Docket/Case Number: UNKNOWN

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE OF $10,000 Sought:

Resolution: Settled Resolution Date: 12/13/1985 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: CONCENTED TO A $10,000 FINE AND CESNURE.

©2021Firm StatementFINRA. All rights reserved. Report aboutWITHOUT RBC CAPITAL ADMITTING MARKETS, OR LLC DENYING LIABILITY, SUTRO CONSENTED TO A 466 $10,000.00 FINE AND CENSURE. www.finra.org/brokercheck User Guidance

Firm Statement WITHOUT ADMITTING OR DENYING LIABILITY, SUTRO CONSENTED TO A $10,000.00 FINE AND CENSURE. i Disclosure 230 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: THE NYSE ALLEGED VIOLATIONS OF NYSE BOOKKEEPING REGULATIONS BETWEEN 1981-1985. Initiated By: NYSE Date Initiated: 05/28/1986 Docket/Case Number: UNKNOWN

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FINE OF $50,000 Sought:

Resolution: Settled Resolution Date: 05/28/1986 Sanctions Ordered: Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: FINE OF $50,000 Firm Statement SUTRO & CO. WAS SANCTIONED IN THE AMOUNT OF $50,000.00 i Disclosure 231 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: THE CBOE ALLEGED THAT SUTRO & CO. HAD CROSSED LISTED OPTIONS IN A TRANSACTION THAT INVOLVED NO CHANGE IN BENEFICIAL OWNERSHIP. Initiated By: CBOE Date Initiated: 08/25/1986

Docket/Case Number: UNKNOWN

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: 08/25/1986 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: CONSENTED TO A $1,000 FINE AND CENSURE. Firm Statement WITHOUT ADMITTING OR DENYING LIABILITY THE FIRM CONSENTED TO A $1,000 FINE AND CENSURE. i Disclosure 232 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: THE NASD DISTRICT 2 FILED A COMPLIANT AGAINST SUTRO & CO., KIRK AUGER AND DAVID LEIN ALLEGING UNAUTHORIZED OPTION AND STOCK TRANSACTIONS IN CUSTOMER ACCOUNTS WITHOUT CUSTOMER'S KNOWLEDGE, WITHOUT DETERMINING SUITABILITY FOR CUSTOMER AND THAT SUTRO AND AGUER FAILED TO IMPLEMENT WRITTEN SUPERVISORY PROCEDURES TO DETECT AND PREVENT SUCH VIOLATIONS. Initiated By: NASD Date Initiated: 08/28/1986 Docket/Case Number: NO. SF-1173

Principal Product Type: Options Other Product Type(s): OPTIONS AND OTC EQUITY Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 468 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 07/21/1987 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: SUTRO & CO. AND AGUER WERE CENSURED AND FINED $5,000 JOINTLY AND SEVERALLY, AND LEIN WAS FINED $5,000 AND SUSPENDED FOR NINETY DAYS. Firm Statement DECISION RENDERED ON JULY 21, 1987 WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BY THE RESPONDENTS WAS ACCEPTED; THEREFORE, RESPONDENTS MEMBER AND AGUER ARE CENSURED AND FINED $5,000, JOINTLY AND SEVERALLY AND RESPONDENT LEIN IS CENSURED, FINED $5,000, AND SUSPENDED FROM ASSOCIATION WITH ANY MEMBER OF THE ASSOCIATION IN ANY CAPACITY FOR NINETY (90) DAYS. i Disclosure 233 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: ALLEGED SUTRO FAILED TO PROPERLY SUPERVISE CERTAIN REGISTERED REPRESENTATIVES WHO VIOLATED THE ANTI FRAUD PROVISIONS BY EXECUTING TRANSACTIONS AT UNDISCLOSED MARK-UPS OR MARK-DOWNS OF 10-34% ON TRANSACTION IN DETATCHES COUPON BONDS WITHIN THE MEANING OF SECTION 15(B)(E) OF THE SECURITIES ACT OF 1934. Initiated By: SEC Date Initiated: 10/21/1986 Docket/Case Number: REL 34-23663

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 469 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 10/21/1986 Sanctions Ordered: Censure Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: CENSURE Firm Statement THE COMMISSION ACCEPTED AN OFFER OF SETTLEMENT SUBMITED BY SUTRO & CO., INC. WITHOUT ADMITTING OR DENYING THE VIOLATION ALLEGED, SUTRO CONSENTED TO AN ORDER FINDING THAT IT FAILED REASONABLY TO SUPERVISE CERTAIN REGISTERED REPRESENTATIVES IN ITS LOS ANGELES AND SANTA BARBARA OFFICES, WHO VIOLATED THE FRAUD PROVISIONS BY EXECUTING TRANSACTIONS AT UNDISCLOSED MARKUPS AND MARKDOWNS OF BETWEEN 10 AND 34% ON CERTAIN TRNSACTIONS IN DETACHED COUPON BONDS. THE COMMISSION ORDERED THAT SUTRO BE CENSURED AND THAT IT COMPLY WITH CERTAIN UNDERTAKINGS REGARDING ITS POLICIES AND PROCEDURES RELATING TO MARKUPS AND MARKDOWNS IN PRINCIPAL TRANSACTIONS IN FIXED INCOME SECURITIES. SUTRO AGREED TO REIMBURSE INVESTORS WHO WERE CHARGED EXECESSIVE COMMISSIONS. i Disclosure 234 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: THE STATE OF INDIANA ISSUED AN ORDER TO SHOW CAUSE ON FEBRUARY 1, 1988, ALLEGING THAT SUTRO & CO., INC. FAILED TO EXERCISE A REASONABLE AND PROPER DEGREE OF SUPERVISON. Initiated By: STATE OF INDIANA Date Initiated: 02/01/1988 Docket/Case Number: UNKNOWN

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 EXACT SANCTION UNKNOWN Sought:

Resolution: Order Resolution Date: 02/01/1988 Sanctions Ordered: Other Sanctions Ordered: Sanction Details: NOT PROVIDED Firm Statement NO RECORD OF THE ULTIMATE DISPOSITION OF THIS MATTER. i Disclosure 235 of 336 Reporting Source: Firm Current Status: Final Allegations: SUTRO PRIOR TO MERGING INTO APPLICANT: THE NASD ALLEGED VIOLATIONS OF PART VI, SECTION (C)2(E) OF THE RULES OF FAIR PRACTICE AND PROCEDURE FOR SOES. Initiated By: NASD Date Initiated: 10/02/1995 Docket/Case Number: CMS950119 AWC

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/28/1995 Sanctions Ordered: Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: THE MSC IMPOSED A SANCTION OF A $3,000 FINE AGAINST SUTRO. Firm Statement MARKET SURVEILLANCE COMMITTEE (MSC) LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS950119 AWC (AWC) FILED ON OCTOBER 2, 1995 WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, ©2021 FINRA. All rights reserved. Report aboutSUTRO RBC &CAPITAL CO., INCORPORATED MARKETS, LLC ("SUTRO") CONSENTED TO FINDINGS. 471 SUTRO ON 6 OCCASIONS ENTERED ORDERS ON A AGENCY BASIS INTO SOES FOR SECURITIES FOR WHICH SUTRO WAS A REGISTERED MARKET MAKER, CONTRARY TO THE PROVISIONS OF THE SOES RULES. THE MSC IMPOSED A SANCTION OF A $3,000 FINE AGAINST SUTRO. THE AWC BECAME FINAL ON DECEMBER 28, 1995. www.finra.org/brokercheck User Guidance MARKET SURVEILLANCE COMMITTEE (MSC) LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS950119 AWC (AWC) FILED ON OCTOBER 2, 1995 WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO & CO., INCORPORATED ("SUTRO") CONSENTED TO FINDINGS. SUTRO ON 6 OCCASIONS ENTERED ORDERS ON A AGENCY BASIS INTO SOES FOR SECURITIES FOR WHICH SUTRO WAS A REGISTERED MARKET MAKER, CONTRARY TO THE PROVISIONS OF THE SOES RULES. THE MSC IMPOSED A SANCTION OF A $3,000 FINE AGAINST SUTRO. THE AWC BECAME FINAL ON DECEMBER 28, 1995. i Disclosure 236 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: ALLEGED THAT SUTRO VIOLATED NASD CONDUCT RULE 3320 AND MARKET PLACE RULE 4613(B) WITH RESPECT TO FIRM QUOTE COMPLIANCE FOR SEVERAL TRADES, FAILURE TO ADHERE TO MINIMUM QUOATATION SIZE IN BIDS AND/OR OFFERS ENTERED INTO AN ECN, FAILURE TO DISPLAY FOUR CUSTOMER LIMIT ORDERS, AND FAILURE TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES TO PREVENT THE AFOREMENTIONED VIOLATIONS. Initiated By: NASD Date Initiated: 01/01/1997 Docket/Case Number: CMS990085 & CMS990082

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: 01/01/1997 Sanctions Ordered: Censure Monetary/Fine $12,000.00 Other Sanctions Ordered: Sanction Details: CENSURED AND FINE OF $12,000. Firm Statement SUTRO HAS ENTERED INTO TWO LETTERS OF ACCEPTANCE, WAIVERS AND CONSENT WITH NASD (CMS990085 RESULTING IN A CENSURE AND FINE OF $5,000 AND CMS990082, RESULTING IN A CENSURE AND FINE OF ©2021 FINRA. All rights reserved. Report about$7,000, RBC RESPECTIVELY) CAPITAL MARKETS, LLCTO RESOLVE ALLEGATIONS THAT, IN 1997, SUTRO 472 VIOLATED NASD CONDUCT RULE 3320 AND MARKET PLACE RULE 4613(B) WITH RESPECT TO FIRM QUOTE COMPLIANCE FOR SEVERAL TRADES, FAILURE TO ADHERE TO MINIMUM QUOATATION SIZE IN BIDS AND/OR OFFERS ENTERED INTO AN ECN, FAILURE TO DISPLAY FOUR CUSTOMER LIMIT ORDERS, AND FAILURE TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES TO PREVENT THE AFOREMENTIONED VIOLATIONS. www.finra.org/brokercheck User Guidance SUTRO HAS ENTERED INTO TWO LETTERS OF ACCEPTANCE, WAIVERS AND CONSENT WITH NASD (CMS990085 RESULTING IN A CENSURE AND FINE OF $5,000 AND CMS990082, RESULTING IN A CENSURE AND FINE OF $7,000, RESPECTIVELY) TO RESOLVE ALLEGATIONS THAT, IN 1997, SUTRO VIOLATED NASD CONDUCT RULE 3320 AND MARKET PLACE RULE 4613(B) WITH RESPECT TO FIRM QUOTE COMPLIANCE FOR SEVERAL TRADES, FAILURE TO ADHERE TO MINIMUM QUOATATION SIZE IN BIDS AND/OR OFFERS ENTERED INTO AN ECN, FAILURE TO DISPLAY FOUR CUSTOMER LIMIT ORDERS, AND FAILURE TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES TO PREVENT THE AFOREMENTIONED VIOLATIONS. i Disclosure 237 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: THE NYSE ALLEGED (1) SUTRO FAILED TO REPORT AND FAILED TO REPORT TIMELY CERTAIN SETTLEMENTS, AWARDS AND JUDGEMENTS AND CERTAIN RELATED EMPLOYEE TERMINATIONS IN CONNECTION WITH CUSTOMER COMPLAINTS DURING THE YEARS 1992 THROUGH 1994, AND, (2) SUTRO EMPLOYED A PERSON SUBJECT TO A STATUTORY DISQUALIFICATION IN A MANNER WHICH HAD NOT BEEN APPROVED BY THE EXCHANGE. Initiated By: NYSE Date Initiated: 06/18/1997 Docket/Case Number: 97-105

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RETENTION OF INDEPENDENT CONSULTANT TO REVIEW PROCEDURES Sought: AND FINE OF $115,000.

Resolution: Consent Resolution Date: 10/14/1997 Sanctions Ordered: Censure Monetary/Fine $115,000.00 Other Sanctions Ordered: Sanction Details: NOT PROVIDED. Firm Statement ON AUGUST 12, 1997, THE NYSE HEARING PANEL ACCEPTED A STIPULATION OF FACTS AND CONSENT TO PENALTY BY SUTRO RELATING ©2021 FINRA. All rights reserved. Report aboutTO ALLEGATIONS RBC CAPITAL MARKETS, OF (1) LLC SUTRO'S HAVING FAILED TO REPORT AND HAVING 473 FAILED TO REPORT TIMELY CERTAIN SETTLEMENTS, AWARDS AND JUDGEMENTS AND CERTAIN RELATED EMPLOYEE TERMINATIONS IN CONNECTION WITH CUSTOMER COMPLAINTS DURING THE YEARS 1992 THROUGH 1994, AND (2) SUTRO'S HAVING EMPLOYED A PERSON SUBJECT TO A STATUTORY DISQUALIFICATION IN A MANNER WHICH HAD NOT BEEN APPROVED BY THE EXCHANGE. THE HEARING PANEL FINED SUTRO $115,000 AND IMPOSED UPON STURO THE REQUIREMENT THAT IT CAUSE AN INDEPENDENT REVIEW OF ITS REPORTING SYSTEMS AND PROCEDURES TO BE DONE BY AN INDEPENDENT PERSON ACCEPTABLE TO THE EXCHANGE. www.finra.org/brokercheck User Guidance

ON AUGUST 12, 1997, THE NYSE HEARING PANEL ACCEPTED A STIPULATION OF FACTS AND CONSENT TO PENALTY BY SUTRO RELATING TO ALLEGATIONS OF (1) SUTRO'S HAVING FAILED TO REPORT AND HAVING FAILED TO REPORT TIMELY CERTAIN SETTLEMENTS, AWARDS AND JUDGEMENTS AND CERTAIN RELATED EMPLOYEE TERMINATIONS IN CONNECTION WITH CUSTOMER COMPLAINTS DURING THE YEARS 1992 THROUGH 1994, AND (2) SUTRO'S HAVING EMPLOYED A PERSON SUBJECT TO A STATUTORY DISQUALIFICATION IN A MANNER WHICH HAD NOT BEEN APPROVED BY THE EXCHANGE. THE HEARING PANEL FINED SUTRO $115,000 AND IMPOSED UPON STURO THE REQUIREMENT THAT IT CAUSE AN INDEPENDENT REVIEW OF ITS REPORTING SYSTEMS AND PROCEDURES TO BE DONE BY AN INDEPENDENT PERSON ACCEPTABLE TO THE EXCHANGE. i Disclosure 238 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: IT WAS ALLEGED THAT SUTRO VIOLATED CERTAIN SECTIONS OF THE SEC'S ORDER HANDLING RULES AND RELATED NASD RULES GOVERNING TRADING AND MARKET MAKING. Initiated By: NASD Date Initiated: 10/03/1997 Docket/Case Number: CMS980003

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/18/1998 Sanctions Ordered: Censure Monetary/Fine $17,000.00 Other Sanctions Ordered: Sanction Details: CENSURED AND FINED OF $17,000. Firm Statement ON FEBRUARY 18, 1998, THE NATIONAL BUSINESS CONDUCT COMMITTEE ACCEPTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT FROM ©2021 FINRA. All rights reserved. Report aboutSUTRO RBC &CAPITAL CO., INCORPORATED MARKETS, LLC ("SUTRO") IN WHICH SUTRO, WITHOUT 474 ADMITTING OR DENYING THE ALLEGED VIOLATIONS, CONSENTED TO THE IMPOSITION OF A CENSURE AND FINE IN THE AMOUNT OF $17,000. www.finra.org/brokercheck User Guidance

ON FEBRUARY 18, 1998, THE NATIONAL BUSINESS CONDUCT COMMITTEE ACCEPTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT FROM SUTRO & CO., INCORPORATED ("SUTRO") IN WHICH SUTRO, WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, CONSENTED TO THE IMPOSITION OF A CENSURE AND FINE IN THE AMOUNT OF $17,000. i Disclosure 239 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: THE NASD ALLEGED THAT FROM JULY 1, 1995 THROUGH JUNE 30, 1996, SUTRO FAILED TO SUBMIT, FAILED TO TIMELY SUBMIT OR FAILED TO SUBMIT BY CERTIFIED OR REGISTERED MAIL, OFFICIAL STATEMENTS & ADVANCE REFUNDING DOCUMENTS TO THE MSRB AS REQUIRED BY MSRB RULE G36. IN ADDITION, SUTRO FAILED TO MAINTAIN CERTAIN RECORDS AS REQUIRED BY MSRB RULE G8. Initiated By: NASD Date Initiated: 11/19/1997 Docket/Case Number: CAF97008

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/15/1997 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, SUTRO ACCEPTED & CONSENTED TO THE NASD'S FINDINGS AND WAS CENSURED AND FINED IN THE AMOUNT OF $25,000. Firm Statement ON DECEMBER 15, 1997, THE DEPARTMENT OF ENFORCEMENT NOTIFIED RESPONDENT SUTRO & CO., INC. THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CAF970008 WAS ACCEPTED; WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO CONSENTED TO A CENSURE AND FINE OF $25,000 (AND CONSENTED TO ©2021 FINRA. All rights reserved. Report aboutFINDINGS RBC CAPITAL THAT MARKETS, RESPONDENT LLC MEMBER SERVED AS SOLE OR MANAGING 475 UNDERWRITTER IN PRIMARY OFFERINGS OR MUNICIPAL SECURITIES AND FAILED TO SUBMIT OFFICIAL STATEMENTS AND ADVANCE REFUNDING DOCUMENTS TO THE MSRB; FAILED TO TIMELY SUBMIT OFFICIAL STATEMENTS AND/OR OTHER DOCUMENTS TO THE MSRB; FAILED TO SEND THE REQUIRED DOCUMENTS BY SOME MEANS THAT PROVIDES A RECORD OF SENDING; AND FAILED TO MAINTAIN RECORDS). ON DECEMBER 15, 1997, THE DEPARTMENT OF ENFORCEMENT NOTIFIED www.finra.org/brokercheck RESPONDENT SUTRO & CO., INC. THAT THE LETTER OF ACCEPTANCE, User Guidance WAIVER AND CONSENT NO. CAF970008 WAS ACCEPTED; WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO CONSENTED TO A CENSURE AND FINE OF $25,000 (AND CONSENTED TO FINDINGS THAT RESPONDENT MEMBER SERVED AS SOLE OR MANAGING UNDERWRITTER IN PRIMARY OFFERINGS OR MUNICIPAL SECURITIES AND FAILED TO SUBMIT OFFICIAL STATEMENTS AND ADVANCE REFUNDING DOCUMENTS TO THE MSRB; FAILED TO TIMELY SUBMIT OFFICIAL STATEMENTS AND/OR OTHER DOCUMENTS TO THE MSRB; FAILED TO SEND THE REQUIRED DOCUMENTS BY SOME MEANS THAT PROVIDES A RECORD OF SENDING; AND FAILED TO MAINTAIN RECORDS). i Disclosure 240 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: IT WAS ALLEGED BY NASD THAT SUTRO, ON CERTAIN OCCASIONS DURING THE PERIOD FROM APRIL 25, 1994 TO JULY 1996, FAILED TO SUBMIT FORMS G-37 TO THE MSRB AS REQUIRED BY MSRB RULE G-37. IN ADDITION, IT WAS ALLEGED THAT SUTRO FAILED TO ESTABLISH AND IMPLEMENT ADEQUATE WRITTEN SUPERVISORY PROCEDURES AS REQUIRED BY MSRB RULE G-37/SUTRO ALSO WAS ALLEGED TO HAVE FAILED TO MAINTAIN DOCUMENTATION AS REQUIRED BY THE MSRB RULE G-8. Initiated By: NASD Date Initiated: 11/19/1997 Docket/Case Number: C01970010

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: 04/20/1998 Sanctions Ordered: Censure Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: CENSURED AND FINED IN THE AMOUNT OF $2,500. Firm Statement IN DECEMBER 1997, THE NASD'S NATIONAL BUSINESS CONDUCT COMMITTEE ACCEPTED A LETTER OF ACCEPTANCE, WAIVER AND ©2021 FINRA. All rights reserved. Report aboutCONSENT RBC CAPITAL (NUMBER MARKETS, C01970010) LLC FROM SUTRO IN WHICH SUTRO, WITHOUT 476 ADMITTING OR DENYING THE ALLEGED VIOLATIONS, ACCEPTED AND CONSENTED TO THE NASD'S FINDINGS THAT SUTRO, ON CERTAIN OCCASIONS DURING THE PERIOD FROM APRIL 25, 1994 TO JULY 1996, FAILED TO SUBMIT FORMS G-37 TO THE MSRB AS REQUIRED BY MSRB RULE G-37. IN ADDITION, IT WAS ALLEGED THAT SUTRO FAILED TO ESTABLISH AND IMPLEMENT ADEQUATE WRITTEN SUPERVISORY PROCEDURES AS REQUIRED BY MSRV RULE G-37/ SUTRO ALSO WAS ALLEGED TO HAVE FAILED TO MAINTAIN DOCUMENTATION AS REQUIRED BY THE MSRB RULE G-8. AS A RESULT OF THESE FINDINGS, SUTRO ACCEPTED A CENSURE AND FINE IN THE AMOUNT OF $2,500. www.finra.org/brokercheck User Guidance

IN DECEMBER 1997, THE NASD'S NATIONAL BUSINESS CONDUCT COMMITTEE ACCEPTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (NUMBER C01970010) FROM SUTRO IN WHICH SUTRO, WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, ACCEPTED AND CONSENTED TO THE NASD'S FINDINGS THAT SUTRO, ON CERTAIN OCCASIONS DURING THE PERIOD FROM APRIL 25, 1994 TO JULY 1996, FAILED TO SUBMIT FORMS G-37 TO THE MSRB AS REQUIRED BY MSRB RULE G-37. IN ADDITION, IT WAS ALLEGED THAT SUTRO FAILED TO ESTABLISH AND IMPLEMENT ADEQUATE WRITTEN SUPERVISORY PROCEDURES AS REQUIRED BY MSRV RULE G-37/ SUTRO ALSO WAS ALLEGED TO HAVE FAILED TO MAINTAIN DOCUMENTATION AS REQUIRED BY THE MSRB RULE G-8. AS A RESULT OF THESE FINDINGS, SUTRO ACCEPTED A CENSURE AND FINE IN THE AMOUNT OF $2,500. i Disclosure 241 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING INTO APPLICANT: COMPLAINT #C02980024 AGAINST RESPONDENTS SUTRO & COMPANY, INC., ROBERT KERNWEIS, GLENN KERNWEIS, GREG SKLAR, WILLIAM WILLIS, KEITH DIETERICH, AND ARNOLD KRAUS ALLEGING VIOLATIONS OF NASD RULES 2110, 2120, 2310 & 3010 IN THAT IT IS ALLEGED RESPONDENT R. KERNWEIS RECOMMENDED NUMEROUS PURCHASE & SALE TRANSACTIONS IN THE ACCOUNTS OF A PUBLIC CUSTOMER WITHOUT HAVING GROUNDS FOR BELIEVING SUCH RECOMMENDATIONS WERE SUITABLE FOR THE CUSTOMER IN VIEW OF THE SIZE, FREQUENCY AND NATURE OF THE RECOMMENDED TRANSACTIONS AND THE FACTS DISCLOSED BY THE CUSTOMER AS TO HIS FINANCIAL SITUATION, OBJECTIVES, AND CIRCUMSTANCES; INDUCED THE PURCHASE AND SALE TRANSACTIONS BY MEANS OF MANIPULATIVE OR OTHER FRAUDULENT DEVICES OR CONTRIVANCES; RESPONDENTS G. KERNWEIS AND SKALR KNEW OR SHOULD HAVE KNOWN THAT THE RECOMMENDATIONS IN THE ACCOUNT WERE UNSUITABLE FOR THE CUSTOMER & THAT THE ACCOUNT WAS EXCESSIVELY TRADED AND FAILED TO TAKE APPROPRIATE ACTION TO PREVENT THE VIOLATIVE ACTIVITY IN THE ACCOUNT; RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS WILLIS, KRAUS AND DIETERICH, FAILED TO TAKE APPROPRIATE ACTION TO SUPERVISE TO PREVENT THE VIOLATIONS AND ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS & REGULATIONS, AND THE RULES OF THE NASD; AND, RESPONDENT MEMBER, ACTIVNG THROUGH RESPONDENT DIETERICH, FAILED TO ESTABLISH, MAINTAIN, AND/OR ENFORCE ADEQUATE PROCEDURES TO SUPERVISE THE TYPE OF BUSINESS ENGAGED IN BY RESPONDENTS R. KERNWEIS, G. KERNWEIS AND SKLAR, TO RESPOND TO THE FINDINGS OF THE NYSE REGARDING COMPLIANCE WITH NYSE RULES 342 AND 405, TO ENFORCE CLEAR LINES OF AUTHORITY/RESPONSBILITY FOR THE SUPERVISION OF THE HANDLING OF CUSTOMER ACCOUNTS. 3/29/99 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 477 PRIOR TO SUTRO MERGING INTO APPLICANT: COMPLAINT #C02980024 AGAINST RESPONDENTS SUTRO & COMPANY, INC., ROBERT KERNWEIS, GLENN KERNWEIS, GREG SKLAR, WILLIAM WILLIS, KEITH DIETERICH, AND ARNOLD KRAUS ALLEGING VIOLATIONS OF NASD RULES 2110, 2120, 2310 & 3010 IN THAT IT IS ALLEGED RESPONDENT R. KERNWEIS RECOMMENDED NUMEROUS PURCHASE & SALE TRANSACTIONS IN THE ACCOUNTS OF A PUBLIC CUSTOMER WITHOUT HAVING GROUNDS FOR BELIEVING SUCH RECOMMENDATIONS WERE SUITABLE FOR THE CUSTOMER IN VIEW OF THE SIZE, FREQUENCY AND NATURE OF THE RECOMMENDED TRANSACTIONS AND THE FACTS DISCLOSED BY THE CUSTOMER AS TO HIS FINANCIAL SITUATION, OBJECTIVES, AND CIRCUMSTANCES; INDUCED THE PURCHASE AND SALE TRANSACTIONS BY MEANS OF MANIPULATIVE OR OTHER FRAUDULENT DEVICES OR CONTRIVANCES; RESPONDENTS G. KERNWEIS AND SKALR KNEW OR SHOULD HAVE KNOWN THAT THE RECOMMENDATIONS IN THE ACCOUNT WERE UNSUITABLE FOR THE CUSTOMER & THAT THE ACCOUNT WAS EXCESSIVELY TRADED AND FAILED TO TAKE APPROPRIATE ACTION TO PREVENT THE VIOLATIVE ACTIVITY IN THE ACCOUNT; RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS WILLIS, KRAUS AND DIETERICH, FAILED TO TAKE APPROPRIATE ACTION TO SUPERVISE TO PREVENT THE VIOLATIONS AND ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS & REGULATIONS, AND THE RULES OF THE NASD; AND, RESPONDENT MEMBER, ACTIVNG THROUGH RESPONDENT DIETERICH, FAILED TO ESTABLISH, MAINTAIN, AND/OR ENFORCE ADEQUATE PROCEDURES TO www.finra.org/brokercheck SUPERVISE THE TYPE OF BUSINESS ENGAGED IN BY RESPONDENTS R. User Guidance KERNWEIS, G. KERNWEIS AND SKLAR, TO RESPOND TO THE FINDINGS OF THE NYSE REGARDING COMPLIANCE WITH NYSE RULES 342 AND 405, TO ENFORCE CLEAR LINES OF AUTHORITY/RESPONSBILITY FOR THE SUPERVISION OF THE HANDLING OF CUSTOMER ACCOUNTS. 3/29/99 Initiated By: NASD Date Initiated: 05/29/1998 Docket/Case Number: C02980024

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief $60,000 FINE AND CENSURE Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 03/25/1999 Sanctions Ordered: Censure Monetary/Fine $60,000.00 Other Sanctions Ordered: Sanction Details: SUTRO WAS CENSURED AND FINED $60,000. Firm Statement IN MARCH 1999, NASD REGULATION ACCEPTED AN OFFER OF SETTLEMENT SUBMITTED ON BEHALF OF SUTRO, WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SUTRO CONSENTED TO FINDINGS THAT SUTRO FAILED TO ESTABLISH, MAINTAIN AND/OR ENFORCE CLEAR LINES OF AUTHORITY AND RESPONSIBLITY IN RESPONSE TO CERTAIN FINDINGS RELATING TO SUTRO'S SUPVERVISION OF A GROUP OF REGISTERED REPRESENTATIVES IN VIOLATION OF NASD CONDUCT RULES 2110 AND 3010. SUTRO WAS CENSURED AND FINED $60,000. i Disclosure 242 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO SUTRO MERGING WITH APPLICANT: IT WAS ALLEGED THAT SUTRO ENTERED PRICED ORDERS INTO SELECTNET BROADCAST, AN ELECTRONIC COMMUNICATIONS NETWORK, WHICH WERE DEEMED TO BE A BID OR OFFER FOR THE PURPOSES OF THE SEC, WITHOUT COMMUNICATING TO THE NASD SUCH PRICED ORDERS FOR AT LEAST THE MINIMUM QUOTATION SIZE THAT IS REQUIRED BY THE NASD IF THE PRICED ORDERS WERE FOR THE ACCOUNT OF THE FIRM, OR THE ACTUAL ©2021 FINRA. All rights reserved. Report aboutSIZE RBC OF CAPITAL THE ORDERS MARKETS, IF LLC THE PRICED ORDERS WERE FOR THE ACCOUNT 478 OF A CUSTOMER; 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; FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS, AND WITH THE APPLICABLE RULES OF THE NASD RELATING TO TRADE REPORTING, ACT RULES, BEST EXECUTION, ANTI- COMPETITIVE PRACTICES. THE LIMIT ORDER PROTECTION INTERPRETATION, THE NASD AND SEC FIRM QUOTE RULES AND THE SEC'S ORDER HANDLING RULES. (SEC RULE 11AC1-4, NASD RULES 2110, 3010). PRIOR TO SUTRO MERGING WITH APPLICANT: IT WAS ALLEGED THAT SUTRO ENTERED PRICED ORDERS INTO SELECTNET BROADCAST, AN ELECTRONIC COMMUNICATIONS NETWORK, WHICH WERE DEEMED TO BE www.finra.org/brokercheck A BID OR OFFER FOR THE PURPOSES OF THE SEC, WITHOUT User Guidance COMMUNICATING TO THE NASD SUCH PRICED ORDERS FOR AT LEAST THE MINIMUM QUOTATION SIZE THAT IS REQUIRED BY THE NASD IF THE PRICED ORDERS WERE FOR THE ACCOUNT OF THE FIRM, OR THE ACTUAL SIZE OF THE ORDERS IF THE PRICED ORDERS WERE FOR THE ACCOUNT OF A CUSTOMER; 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; FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS, AND WITH THE APPLICABLE RULES OF THE NASD RELATING TO TRADE REPORTING, ACT RULES, BEST EXECUTION, ANTI- COMPETITIVE PRACTICES. THE LIMIT ORDER PROTECTION INTERPRETATION, THE NASD AND SEC FIRM QUOTE RULES AND THE SEC'S ORDER HANDLING RULES. (SEC RULE 11AC1-4, NASD RULES 2110, 3010). Initiated By: NASD Date Initiated: 07/26/1999 Docket/Case Number: CMS990082

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief $7,000 FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/26/1999 Sanctions Ordered: Censure Monetary/Fine $7,000.00 Other Sanctions Ordered: Sanction Details: $7,000.00 FINE AND CENSURE Firm Statement SUTRO ENTERED INTO AN AWC WITH THE ASSOCIATION WHEREIN, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, IT CONSENTED TO THE ASSOCIATION'S FINDINGS, TO A CENSURE AND A FINE OF $7,000. i Disclosure 243 of 336 Reporting Source: Firm Current Status: Final Allegations: SUTRO, PRIOR TO MERGING INTO APPLICANT, FAILED TO EXECUTE ©2021 FINRA. All rights reserved. Report aboutORDERS RBC CAPITAL AT ITS MARKETS, PUBLISHED LLC BID OR PUBLISHED OFFER, AND THEREBY 479 FAILED TO HONOR ITS PUBLISHED QUOTATION. (SECURITIES EXCHANGE ACT FULE 11AC1-1; NASD CONDUCT RULE 3320; NASD MARKETPLACE RULE 4613(B). www.finra.org/brokercheck User Guidance

Allegations: SUTRO, PRIOR TO MERGING INTO APPLICANT, FAILED TO EXECUTE ORDERS AT ITS PUBLISHED BID OR PUBLISHED OFFER, AND THEREBY FAILED TO HONOR ITS PUBLISHED QUOTATION. (SECURITIES EXCHANGE ACT FULE 11AC1-1; NASD CONDUCT RULE 3320; NASD MARKETPLACE RULE 4613(B). Initiated By: NASD Date Initiated: 07/26/1999 Docket/Case Number: CMS990085

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $5,000.00 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/26/1999 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: CENSURE; FINE OF $5000.00. Firm Statement 02-08-00, $5,000 PAID ON 8/30/99, INVOICE #99-MS-707 i Disclosure 244 of 336 Reporting Source: Firm Current Status: Final Allegations: UNKNOWN Initiated By: NASD Date Initiated: 02/24/1972 Docket/Case Number: N-V-38

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: 06/17/1972 Sanctions Ordered: Monetary/Fine $25.00 Other Sanctions Ordered: Sanction Details: 06/17/1972 TOTAL AMOUNT PAID $25.00. NO WAIVER. i Disclosure 245 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, ALLEGEDLY WAS IN VIOLATION OF SECTION 27(A) AND SECTION 21(B) OF RFP Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/15/1972 Docket/Case Number: SC-18

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: Stipulation and Consent Resolution Date: 07/21/1972 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: FINE OF $1,000.00 AND CENSURE WAS ENTERED ON 7/21/1972 i Disclosure 246 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 481 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: BRANCH CABELL NOW A DIVISION OF THE APPLICANT ALLEGEDLY WAS IN VIOLATION OF SEC RULES 240-17A-3 AND 240.17A-13(B)(5) Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 02/01/1978 Docket/Case Number: 78-4

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: Stipulation and Consent Resolution Date: 11/11/1978 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: FINE OF $3,000.00 WAS PAID ON 11/11/1978. i Disclosure 247 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, WAS ALLEGEDLY IN VIOLATION OF CERTAIN EXCHANGE RULES AND CONSTITUTION SECTIONS CONCERNING OPTIONS TRANSACTIONS. Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 07/18/1979 Docket/Case Number: 79-D-3

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

Resolution: Stipulation and Consent Resolution Date: 08/27/1979 Sanctions Ordered: Monetary/Fine $3,500.00 Other Sanctions Ordered: Sanction Details: FINE OF $3,500 WAS PAID ON 08/27/1979. i Disclosure 248 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF THE APPLICANT, WAS ALLEGEDLY IN VIOLATION OF FREE RIDING AND WITHHOLDING INTERPRETATION OF THE BOARD OF GOVERNORS AS CONTAINED IN ARTICLE 111, SECTION 1 OF THE RULES OF FAIR PRACTICE Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/26/1980 Docket/Case Number: UNKNOWN

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/27/1980 Sanctions Ordered: Censure Monetary/Fine $300.00 Other Sanctions Ordered: Sanction Details: A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS SIGNED AND ©2021 FINRA. All rights reserved. Report aboutFINE RBC OF CAPITAL $300.00 MARKETS, WAS PAID LLC ON 8/27/1980. 483 www.finra.org/brokercheck User Guidance

Sanction Details: A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS SIGNED AND FINE OF $300.00 WAS PAID ON 8/27/1980. Firm Statement THIS CONSENT PROCEEDING WAS DONE TO AVOID THE DELAY AND EXPENSE OF A FORMAL COMPLAINT. i Disclosure 249 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: TUCKER ANTHONY & R.L.DAY, INC. WAS FINED BY THE AMEX FOR FAILURE ON FEBRUARY 24, 1981 TO SUBMIT OPTION TRADE COMPARISON INPUT FOR THE PRELIMINARY PROCESSING RUN TO THE TRADE COMPARISON SYSTEM AT THE SCHEDULED TIME 7:30 P.M. THE AMEX IMPOSED A $10,000 FINE PURSUANT TO A STIPULATION OF FACT AND CONSENT TO PENALTY FOR CROSSING LISTED OPTIONS TO THE SAME ACCOUNT. Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 02/24/1981 Docket/Case Number: UNKNOWN

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

Resolution: Stipulation and Consent Resolution Date: 02/24/1981 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: TUCKER ANTHONY & R.L.DAY, INC. WAS FINED BY THE AMEX FOR FAILURE ON FEBRUARY 24, 1981 TO SUBMIT OPTION TRADE COMPARISON INPUT FOR THE PRELIMINARY PROCESSING RUN TO THE TRADE COMPARISON SYSTEM AT THE SCHEDULED TIME 7:30 P.M. THE AMEX IMPOSED A $10,000 FINE PURSUANT TO A STIPULATION OF FACT AND CONSENT TO PENALTY FOR CROSSING LISTED OPTIONS TO THE SAME ACCOUNT. i

Disclosure 250 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE EXCHANGE ALLEGED THAT TUCKER ANTHONY VIOLATED EXCHANGE RULES BY EXECUTING CERTAIN CROSSING TRANSACTIONS IN LISTED OPTIONS FOR THE SAME ACCOUNT. Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 09/28/1984 Docket/Case Number: UNKNOWN

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: Stipulation and Consent Resolution Date: 05/28/1985 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: 04/04/1986 TOTAL AMOUNT PAID $10,000.00. NO WAIVER. i Disclosure 251 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE NASD ALLEGED THAT TUCKER ANTHONY VIOLATED PART I SECTION (C)(3)(A) OF SCHEDULE D OR THE NASD BY-LAWS IN CONNECTION WITH PRICE SPREAD QUOTATIONS IN THE NASDAQ SYSTEM. Initiated By: NASD Date Initiated: 04/09/1985 Docket/Case Number: MS-130

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: 05/16/1985 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: 05/16/1985 TOTAL AMOUNT PAID $250.00. NO WAIVER. i Disclosure 252 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, ALLEGEDLY FAILED TO COMPLY WITH POST REGISTRATION REQUIREMENTS BY FILING BD AMENDMENTS IN TIMELY MANNER. Initiated By: NORTH CAROLINA SECURITIES DIVISION Date Initiated: 06/05/1985 Docket/Case Number: OR-84-025

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: 06/05/1985 Sanctions Ordered: Censure Other Sanctions Ordered:

Sanction Details: CENSURE WAS ENTERED ON 6/5/1985 i Disclosure 253 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF THE APPLICANT, ALLEGEDLY MARKETED SINGLE PREMIUM DEFERRED ANNUITIES OF NATIONAL INVESTORS LIFE INSURANCE COMPANY, AN AFFILIATE OF BALDWIN UNITED CORPORATION. Initiated By: VIRGINIA STATE CORPORATION COMMISSION Date Initiated: 11/15/1985 Docket/Case Number: INS850095

Principal Product Type: Annuity(ies) - Fixed 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: 11/15/1985 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: OFFER OF SETTLEMENT ACCEPTED AND FINE OF $10,000 WAS PAID ON 11/15/1985. i Disclosure 254 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE CBOE ALLEGED THAT TUCKER ANTHONY VIOLATED RULE 4.2 BY EXECUTING CERTAIN CROSSING TRANSACTIONS IN LISTED OPTIONS FOR THE SAME ACCOUNT. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 487 www.finra.org/brokercheck User Guidance

Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 07/11/1986 Docket/Case Number: 86-0055

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: 07/11/1986 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: 07/11/1986 TOTAL AMOUNT PAID $7,500.00. NO WAIVER. i Disclosure 255 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, ALLEGEDLY WAS IN VIOLATION OF PART V1, SECTION 4(A) OF SCHEDULE D FAILING TO REPORT NASDAQ VOLUME. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/09/1987 Docket/Case Number: MS-586-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: 11/09/1987 Sanctions Ordered: Monetary/Fine $300.00 Other Sanctions Ordered: Sanction Details: FIRM SIGNED LETTER OF ADMISSION AND CONSENT AND PAID A FINE OF $300 ON 8/27/1980. i Disclosure 256 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE NASD ALLEGED THAT TUCKER ANTHONY VIOLATED PART IV SECTION 4(A) OF SCHEDULE D OF THE NASD BY-LAWS FOR FAILING TO REPORT NASDAQ TRADING VOLUME IN CERTAIN SECURITIES. Initiated By: NASD Date Initiated: 12/03/1987 Docket/Case Number: MS-648-AWC

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/22/1988 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: 02/22/1988 TOTAL AMOUNT PAID $250.00. NO WAIVER. i Disclosure 257 of 336 Reporting Source: Firm Current Status: Final ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 489 www.finra.org/brokercheck User Guidance

Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE COMMISSION ALLEGED THAT TUCKER ANTHONY SOLD A UNIT INVESTMENT TRUST TO FIVE ARIZONA RESIDENTS IN EXCESS OF THE AMOUNT OF SUCH SECURITIES REGISTERED FOR SALE IN ARIZONA. Initiated By: ARIZONA CORPORATION COMMISSION Date Initiated: 06/06/1988 Docket/Case Number: UNKNOWN

Principal Product Type: Unit Investment Trust(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: 06/06/1988 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: 06/06/1988 TOTAL AMOUNT PAID $5,000.00. NO WAIVER. i Disclosure 258 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, ALLEGEDLY WAS IN VIOLATION OF CERTAIN SEC REGULATIONS. Initiated By: VIRGINIA STATE CORPORATION COMMISSION Date Initiated: 11/11/1988 Docket/Case Number: 88-46

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 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 490 Sought: www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 11/11/1988 i Disclosure 259 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOT TO BECOMING A DIVISION OF TUCKER ANTHONY, ALLEGEDLY AN EMPLOYEE MADE UNAUTHORIZED WITHDRAWELS FROM CUSTOMERS ACCOUNTS IN THE AMOUNT OF $133,000; PREPARED FALSE ACCOUNT STATEMENTS TO MISLEAD CUSTOMER; AND CHANGE CUSTOMER ADDRESSES. FIRM FAILED TO SUPERVISE EMPLOYEE IN SECURITIES ACT RULE 303(A) AND VA CODE 13.3-523. Initiated By: VIRGINIA CORPORATION COMMISSION Date Initiated: 12/20/1988 Docket/Case Number: SEC 880152

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/31/1989 Sanctions Ordered: Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ALLEGATIONS, FIRM CONSENTED TO THE SUBSTANCE AND ENTRY OF THE ORDER ACCEPTING OFFER, COMPROMISE AND SETTLEMENT, FULL RESITUTION OF $142,368.92 WAS MADE. i Disclosure 260 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 491 www.finra.org/brokercheck User Guidance

Disclosure 260 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, ALLEGEDLY WAS IN VIOLATION OF SEC REGULATION 240.15C3(E)(1) AND SEC REGULATION 240.15C3-3(E)93. Initiated By: NEW YORK STOCK EXCHANGE Date Initiated: 04/14/1989 Docket/Case Number: D-NYSE 89-9

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: Stipulation and Consent Resolution Date: 04/14/1989 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: ADDITIONAL DEPOSIT REQUIREMENT FOR A FIVE-YEAR PERIOD. i Disclosure 261 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE DEPARTMENT ALLEGED THAT HOPPER SOLIDAY & CO., INCORPORATED, PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, FAILED TO FILE CERTAIN FINANCIAL REPORTS. Initiated By: STATE OF ILLINOIS SECURITIES DEPARTMENT Date Initiated: 04/28/1989 Docket/Case Number: H8900194

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

Resolution: Settled Resolution Date: 04/28/1989 Sanctions Ordered: Censure Monetary/Fine $500.00 Other Sanctions Ordered: Sanction Details: 04/28/1989 TOTAL AMOUNT PAID $500.00. NO WAIVER. i Disclosure 262 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, ALLEGEDLY OFFERED FOR SALE AND SOLD MUNICIPAL INSURANCE NATIONAL TRUST #10 , UNREGISTERED SECURITIES. Initiated By: VIRGINIA CORPORATION COMMISSION Date Initiated: 05/03/1989 Docket/Case Number: SEC-890026

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: Decision & Order of Offer of Settlement Resolution Date: 05/03/1989 Sanctions Ordered: Monetary/Fine $1,260.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 493 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: FINE OF $1,260 WAS PAID ON 5/3/1989. i Disclosure 263 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING WITH APPLICANT: THE DIVISION ALLEGED THAT HOPPER SOLIDAY CAPITAL MARKETS, A PREDECESSOR TO HOPPER SOLIDAY & CO., INCORPORATED, PRIRO TO BECOMING A DIVISION OF TUCKER ANTHONY, FAILED TO FILE CERTAIN FINANCIAL REPORTS. Initiated By: COMMONWEALTH OF VIRGINIA CORP. COMMISSION DIV. OF SECURITIES Date Initiated: 12/05/1989 Docket/Case Number: SEC89013

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: 12/05/1989 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: 12/05/1989 TOTAL AMOUNT PAID $2,000.00. NO WAIVER. i Disclosure 264 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGER WITH APPLICANT: THE NASD ALLEGED THAT TUCKER ANTHONY VIOLATED THE FREE-RIDING AND WITHHOLDING RULES AND THE SETTLEMENT AND PAYMENT REQUIREMENTS OF MSRB RULES G-12(J) AND A-13. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 494 www.finra.org/brokercheck User Guidance

Initiated By: NASD Date Initiated: 01/01/1990 Docket/Case Number: UNKNOWN

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: 07/17/1990 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: 07/17/1990 TOTAL AMOUNT PAID $5,000.00. NO WAIVER. i Disclosure 265 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE CBOE ALLEGED THAT TUCKER ANTHONY VIOLATED RULES 4.2 AND 9.8 FOR FAILURE TO SUPERVISE A REGISTERED REPRESENTATIVE. Initiated By: CHICAGO BOARD OPTIONS EXCHANGE Date Initiated: 09/24/1990 Docket/Case Number: 90-0075

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: Consent Resolution Date: 09/24/1990 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: 09/24/1990 TOTAL AMOUNT PAID $7,500.00. NO WAIVER. i Disclosure 266 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE STATE ALLEGED THAT TUCKER ANTHONY CONDUCTED INVESTMENT ADVISORY BUSINESS PRIOR TO EFFECTIVE REGISTRATION. Initiated By: STATE OF CONNECTICUT Date Initiated: 02/28/1991 Docket/Case Number: UNKNOWN

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: 02/28/1991 Sanctions Ordered: Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: 02/28/1991 TOTAL AMOUNT PAID $7,500.00. NO WAIVER. i Disclosure 267 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, ©2021 FINRA. All rights reserved. Report aboutALLEGEDLY RBC CAPITAL VIOLATED MARKETS, ARTICLE LLC 111, SECTION 1 OF THE RULES OF FAIR 496 PRACTICE BY FAILING TO DISTRIBUTE SHARES OF A NEW ISSUE THAT TRADED AT A PREMIUM IN THE IMMEDIATE AFTERMARKET. www.finra.org/brokercheck User Guidance

Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, ALLEGEDLY VIOLATED ARTICLE 111, SECTION 1 OF THE RULES OF FAIR PRACTICE BY FAILING TO DISTRIBUTE SHARES OF A NEW ISSUE THAT TRADED AT A PREMIUM IN THE IMMEDIATE AFTERMARKET. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 09/30/1991 Docket/Case Number: C9B910028

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: 03/10/1992 Sanctions Ordered: Censure Monetary/Fine $3,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ALLEGATIONS, FIRM WAS CENSURED AND FINED $3,500.00 ON 2/28/1992. i Disclosure 268 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: BRANCH CABELL, PRIOR TO BECOMING A DIVISION OF THE APPLICANT, ALLEGEDLY TRANSACTED BUSINESS IN COMMONWEALTH PRIOR TO REGISTRATION Initiated By: PENNSYLVANIA SECURITIES COMMISSION Date Initiated: 11/05/1984 Docket/Case Number: 8405-20

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

Resolution: Stipulation and Consent Resolution Date: 11/16/1984 Sanctions Ordered: Suspension Other Sanctions Ordered: Sanction Details: TRANSACTING NEW ACCOUNTS SUSPENDED FOR THIRTY DAYS FROM 11/05/1984 TO 12/05/1984 AND TRANSACTING CURRENT ACCOUNTS SUSPENDED FOR FIFTEEN DAYS FROM 11/05/1984 TO 11/20/1984. SUSPENSIONS FOR PENNSYLVANIA ONLY. i Disclosure 269 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE SEC ALLEGED THAT TUCKER ANTHONY VIOLATED SECTION 17(A) OF THE SECURITIES EXCHANGE ACT AND RULES 17A-4 AND 17A-3 THEREUNDER IN THAT ITS RECORDS OF CUSTOMER ORDERS RELATING TO SECURITIES OF GOVERNMENT SPONSORED AGENCIES WERE INACCURATE. Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 01/16/1992 Docket/Case Number: ADMIN. PROC. #3-7646

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

Resolution: Consent Resolution Date: 01/28/1992 Sanctions Ordered: Monetary/Fine $25,000.00 Other Sanctions Ordered: TUCKER ANTHONY ALSO AGREED TO MAINTAIN OR DEVELOP AND ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 498 IMPLEMENT APPROPRIATE POLICIES AND PROCEDURES TO ASSURE COMPLIANCE IN THE FUTURE WITH SEC RULES. www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: TUCKER ANTHONY ALSO AGREED TO MAINTAIN OR DEVELOP AND IMPLEMENT APPROPRIATE POLICIES AND PROCEDURES TO ASSURE COMPLIANCE IN THE FUTURE WITH SEC RULES. Sanction Details: 01/28/1992 TOTAL AMOUNT PAID $25,000.00. NO WAIVER. i Disclosure 270 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGER WITH APPLICANT: THE DIVISION ALLEGED THAT TUCKER ANTHONY VIOLATED MASSACHUSETTS GENERAL L. CH. 110A, SECTIONS 201, 204(A) AND 404. Initiated By: MASSACHUSETTS SECURITIES DIVISION Date Initiated: 02/17/1993 Docket/Case Number: E-93-023

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: 10/08/1993 Sanctions Ordered: Monetary/Fine $37,054.00 Other Sanctions Ordered: Sanction Details: 10/08/1993 TOTAL AMOUNT PAID $37,054.00. NO WAIVER. i Disclosure 271 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGER INTO APPLICANT: THE NASD ALLEGED THAT TUCKER ANTHONY VIOLATED ARTICLE III, SECTIONS 1 AND 27(A) OF THE RULES OF FAIR PRACTICE FOR FAILING TO SUPERVISE A FORMER REGISTERED REPRESENTATIVE'S HANDLING OF MUTUAL FUND TRANSACTIONS. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 499 www.finra.org/brokercheck PRIOR TO TUCKER ANTHONY MERGER INTO APPLICANT: THE NASD User Guidance ALLEGED THAT TUCKER ANTHONY VIOLATED ARTICLE III, SECTIONS 1 AND 27(A) OF THE RULES OF FAIR PRACTICE FOR FAILING TO SUPERVISE A FORMER REGISTERED REPRESENTATIVE'S HANDLING OF MUTUAL FUND TRANSACTIONS. Initiated By: NASD Date Initiated: 07/23/1993 Docket/Case Number: C11 930007

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 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/23/1993 Sanctions Ordered: Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: 07/23/1993 TOTAL AMOUNT PAID $7,500.00. NO WAIVER. i Disclosure 272 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGER INTO APPLICANT: THE NASD ALLEGED THAT TUCKER ANTHONY VIOLATED SECTION C-2(D) OF THE RULES OF FAIR PRACTICE AND PROCEDURE FOR SOES AND ARTICLE 111, SECTION 1 OF THE NASD RULES OF FAIR PRACTICE BY ENTERING ORDERS ON AN AGENCY BASIS FOR SECURITIES IN WHICH THE APPLICANT WAS A MARKET MAKER. Initiated By: NASD Date Initiated: 09/23/1993 Docket/Case Number: CMS9300049-AWC

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 ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 500 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/03/1994 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: 01/03/1994 TOTAL AMOUNT PAID $2,500.00. NO WAIVER. i Disclosure 273 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE DEPT. ALLEGED THAT TUCKER ANTHONY VIOLATED SECTION 203 OF THE RHODE ISLAND UNIFORM STATUTES FOR FAILURE TO OBTAIN PROPER LICENSING. Initiated By: RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION Date Initiated: 02/10/1994 Docket/Case Number: 94-0028

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: 02/10/1994 Sanctions Ordered: Monetary/Fine $4,000.00 Other Sanctions Ordered: DISGORGED $700.00 IN FEES COLLECTED Sanction Details: 02/10/1994 TOTAL AMOUNT PAID $4,000.00. NO WAIVER. i Disclosure 274 of 336

Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE DIVISION ALLEGED THAT TUCKER ANTHONY EFFECTED INVESTMENT ADVISORY TRANSACTIONS PRIOR TO ITS REGISTRATION WITH THE STATE AS AN INVESTMENT ADVISOR. Initiated By: MARYLAND SECURITIES DIVISION Date Initiated: 03/01/1994 Docket/Case Number: UNKNOWN

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: 03/01/1994 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: 03/01/1994 TOTAL AMOUNT PAID $2,500.00. NO WAIVER. i Disclosure 275 of 336 Reporting Source: Firm Current Status: Final Allegations: THE COMMONWEALTH ALLEGED THAT THE APPLICANT FAILED TO FILE CERTAIN FINANCIAL REPORTS. Initiated By: COMMENWEALTH OF VIRGINIA Date Initiated: 07/07/1994 Docket/Case Number: SEC940067

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

Resolution: Consent Resolution Date: 07/07/1994 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: 07/07/1994 TOTAL AMOUNT PAID $250.00. NO WAIVER. i Disclosure 276 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: THE NASD ALLEGED THAT THE APPLICANT VIOLATED SECTION C-2(D) OF THE RULES OF PRACTICE AND PROCEDURE FOR SOES AND ARTICLE III, SECTION I, OF THE NASD RULES OF FAIR PRACTICE BY ENTERING ORDERS ON AN AGENCY BASIS FOR SECURITIES IN WHICH THE APPLICANT WAS A MARKET MAKER. Initiated By: NASD Date Initiated: 10/03/1994 Docket/Case Number: CMS940101-AWC

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: 03/31/1995 Sanctions Ordered: Monetary/Fine $750.00 Other Sanctions Ordered: Sanction Details: 03/31/1995 TOTAL AMOUNT PAID $750.00 NO WAIVER. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 503 www.finra.org/brokercheck User Guidance

Sanction Details: 03/31/1995 TOTAL AMOUNT PAID $750.00 NO WAIVER. i Disclosure 277 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: GIBRALTAR SECURITIES CO., PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, ALLOWED ONE OF ITS REPRESENTATIVES TO SELL SECURITIES TO FLORIDA INVESTORS WITHOUT BEING REGISTERED IN FLORIDA. Initiated By: STATE OF FLORIDA - DIVISION OF SECURITIES Date Initiated: 12/29/1994 Docket/Case Number: #1709-5-5/92

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 CEASE AND DESIST Sought:

Resolution: Consent Resolution Date: 12/29/1994 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: 12/29/1994 TOTAL AMOUNT PAID $5,000.00 NO WAIVER i Disclosure 278 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: GIBRALTAR SECURITIES CO., PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, ALLEGEDLY ENGAGED IN UNLICENSED BROKER/DEALER ACTIVITY IN MINNESOTA, OFFERED OR SOLD SECURITIES THROUGH UNLICENSED AGENTS, AND FAILED TO PROPERLY SUPERVISE ITS AGENTS BY ALLOWING THEM TO EFFECT TRANSACTIONS FOR MINNESOTA CUSTOMERS WITHOUT BEING LICENSED. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 504 PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: GIBRALTAR SECURITIES CO., PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, www.finra.org/brokercheck ALLEGEDLY ENGAGED IN UNLICENSED BROKER/DEALER ACTIVITY IN User Guidance MINNESOTA, OFFERED OR SOLD SECURITIES THROUGH UNLICENSED AGENTS, AND FAILED TO PROPERLY SUPERVISE ITS AGENTS BY ALLOWING THEM TO EFFECT TRANSACTIONS FOR MINNESOTA CUSTOMERS WITHOUT BEING LICENSED. Initiated By: STATE OF MINNESOTA - COMMISSIONER OF COMMERCE Date Initiated: 02/09/1995 Docket/Case Number: FILE SE 9406528

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

Resolution: Settled Resolution Date: 02/09/1995 Sanctions Ordered: Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: 02/09/1995 TOTAL AMOUNT PAID $3,000. NO WAIVER i Disclosure 279 of 336 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING WITH APPLICANT: THE COMMISSIONER ALLEGED THAT GIBRALTAR SECURITIES CO., PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, WITHOUT BEING LICENSED AS A DEALER OR AGENT, MADE A TOTAL OF SIX OFFERS AND SALES OF SECURITIES TO ALABAMA RESIDENTS WHICH DID NOT QUALIFY FOR EXCEPTIONS FROM DEALER AND AGENT LICENSING REQUIREMENTS UNDER ALABAMA LAW. Initiated By: ALABAMA SECURITIES CORPORATION Date Initiated: 03/01/1995 Docket/Case Number: CD-95-0012

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

Resolution: Consent Resolution Date: 09/13/1995 Sanctions Ordered: Monetary/Fine $1,500.00 Other Sanctions Ordered: Sanction Details: 09/13/1995 TOTAL AMOUNT PAID $1,500. NO WAIVER. Firm Statement THIS OCCURRENCE IS NOT REPORTABLE UNDER 11D5 SINCE THE FIRMS ACTIVITIES WERE NOT RESTRICTED. i Disclosure 280 of 336 Reporting Source: Firm Current Status: Final Allegations: THE DIVISION ALLEGED THAT TUCKER ANTHONY INCORPORATED EMPLOYED SALES REPRESENTATIVES AND SUPERVISORS THAT HAD NOT MET EXAM REQUIREMENTS. Initiated By: RHODE ISLAND SECURITIES DIVISION Date Initiated: 04/01/1995 Docket/Case Number: UNKNOWN

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: 04/26/1995 Sanctions Ordered: Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: 04/26/1995 TOTAL AMOUNT PAID $3,000. NO WAIVER ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 506 www.finra.org/brokercheck User Guidance

i Disclosure 281 of 336 Reporting Source: Firm Current Status: Final Allegations: THE COMMISSION ALLEGED THAT GIBRALTAR SECURITIES CO., A DIVISION OF TUCKER ANTHONY INCORPORATED, EFFECTED TWO SECURITIES TRANSACTIONS WITH NORTH DAKOTA CITIZENS BEFORE BECOMING LICENSED AS A DEALER IN THE STATE. Initiated By: NORTH DAKOTA SECURITIES COMMISSION Date Initiated: 04/20/1995 Docket/Case Number: UNKNOWN

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

Resolution: Consent Resolution Date: 04/20/1995 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: 04/20/1995 TOTAL AMOUNT PAID $2,500. NO WAIVER. i Disclosure 282 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT GIBRALTAR SECURITIES CO., A DIVISION OF TUCKER ANTHONY INCORPORATED, VIOLATED CERTAIN RULES RELATING TO TRADE REPORTING OF CERTAIN HIGH YIELD CORPORATE BOND TRANSACTIONS (FIPS BONDS). SPECIFICALLY, THE NASD ALLEGED GIBRALTAR VIOLATED PART IV(A)2A, PART IV(B)2A AND PART III (A) AND (B) OF THE FIPS RULES AND ARTICLE III SECTION I OF THE NASD RULES OF FAIR PRACTICE. Initiated By: NASD ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 507 www.finra.org/brokercheck User Guidance

Initiated By: NASD Date Initiated: 10/01/1995 Docket/Case Number: CMS950120 AWC

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 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/26/1996 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: 08/26/1996 TOTAL AMOUNT PAID $2,500 NO WAIVER i Disclosure 283 of 336 Reporting Source: Firm Current Status: Final Allegations: THE COMMISSION ALLEGED THAT GIBRALTAR SECURITIES CO., A DIVISION OF TUCKER ANTHONY INCORPORATED, EFFECTED SECURITIES TRANSACTIONS ON BEHALF OF APPROXIMATELY 70 ACCOUNTS IN VERMONT WITHOUT BEING REGISTERED OR EXEMPTED FROM THE VERMONT SECURITIES ACT. Initiated By: VERMONT SECURITIES COMMISSION Date Initiated: 10/05/1995 Docket/Case Number: 95-082-5

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: 10/05/1995 Sanctions Ordered: Monetary/Fine $17,500.00 Other Sanctions Ordered: Sanction Details: 10/05/1995 TOTAL AMOUNT PAID $17,500.00 NO WAIVER i Disclosure 284 of 336 Reporting Source: Firm Current Status: Final Allegations: BRANCH CABELL, A DIVISION OF TUCKER ANTHONY INCORPORATED, ALLEGEDLY OFFERED AND SOLD SECURITIES TO 14 ARIZONA RESIDENTS WHILE NOT REGISTERED ASA DEALER. Initiated By: ARIZONA CORPORATION COMMISSION Date Initiated: 12/26/1995 Docket/Case Number: 5-3117-I

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: 12/26/1995 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: $5000 FINE PAID UPON ENTRY OF THE ORDER. REGISTRATION GRANTED UPON ENTRY OF THE ORDER. i Disclosure 285 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT THE APPLICANT VIOLATED ARTICLE III SECTION I ©2021 FINRA. All rights reserved. Report aboutOF THE RBC CAPITALRULES MARKETS,OF FAIR LLCPRACTICE BY ENTERING ORDERS ON AN AGENCY 509 BASIS INTO SOES FOR SECURITIES IN WHICH THE APPLICANT WAS A MARKET MAKER. www.finra.org/brokercheck User Guidance

Allegations: THE NASD ALLEGED THAT THE APPLICANT VIOLATED ARTICLE III SECTION I OF THE RULES OF FAIR PRACTICE BY ENTERING ORDERS ON AN AGENCY BASIS INTO SOES FOR SECURITIES IN WHICH THE APPLICANT WAS A MARKET MAKER. Initiated By: NASD Date Initiated: 07/01/1996 Docket/Case Number: CMS950183

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/29/1996 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: 08/29/1996 TOTAL AMOUNT PAID $5,000. NO WAIVER. i Disclosure 286 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT TUCKER ANTHONY INCORPORATED VIOLATED NASD CONDUCT RUELS 2110, 2110-2 AND 3010 MARKETPLACE RULES 4632(A) AND 6420(A), AND SECURITIES EXCHANGE ACT RULES 10B-10 AND 17A-14 IN CONNECTION WITH HANDLING OTC ORDERS. Initiated By: NASD Date Initiated: 11/07/1997 Docket/Case Number: CMS-980029 AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 510 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: 03/31/1998 Sanctions Ordered: Monetary/Fine $22,000.00 Other Sanctions Ordered: Sanction Details: 03/31/1998 TOTAL AMOUNT PAID $22,000. NO WAIVER. i Disclosure 287 of 336 Reporting Source: Firm Current Status: Final Allegations: OCCURRED UNDER TUCKER ANTHONY INCORPORATED: BRANCH CABELL, A DIVISION OF TUCKER ANTHONY, ALLEGEDLY VIOLATED SEC REGULATION 240.17A-3(6), EXCHANGE RULE 410 & EXCHANGE RULE 342- DELAY IN SUBMISSION OF ACCOUNT INFORMATION FOR BLOCK TRANSATIONS VIOLATED EXCHANGE RULE 440-FAILURE TO MAINTAIN DISCRETIONARY TRADING AUTHORIZATIONS. Initiated By: NASD Date Initiated: 05/04/1998 Docket/Case Number: C07000089

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: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/18/2000 Sanctions Ordered: Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: FINE OF $7,500.00 WAS PAID ON 12/18/00 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 511 www.finra.org/brokercheck User Guidance

Sanction Details: FINE OF $7,500.00 WAS PAID ON 12/18/00 i Disclosure 288 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASDR ALLEGED THAT THE APPLICANT VIOLATED NASD CONDUCT RULES 2110, 2320, AND 3010, AND SECURITIES EXCHANGE ACT RULE 11AC1-4 UB CONNECTION WITH ITS HANDLING OF OTC ORDERS. Initiated By: NASDR Date Initiated: 07/06/1998 Docket/Case Number: CMS990055

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: 06/11/1999 Sanctions Ordered: Censure Monetary/Fine $16,000.00 Other Sanctions Ordered: Sanction Details: 06/11/99 TOTAL AMOUNT PAID $16,000.00. NO WAIVER. i Disclosure 289 of 336 Reporting Source: Firm Current Status: Final Allegations: IN AN ACTION BROUGHT AGAINST TUCKER ANTHONY INCORPORATED, AND TWENTY-NINE OTHER NASDAQ MARKET MAKERS, THE SEC FOUND THAT IN 1994 THE APPLICANT VIOLATED SECTIONS 15C(1) AND 15C(2) OF THE SECURITIES EXCHANGE ACT AND RULES PROMULGATED THEREUNDER, IN CONNECTION WITH ITS MARKET MAKING ACTIVITIES IN THREE NASDAQ SECURITIES. Initiated By: SECURITIES AND EXCHANGE COMMISSION ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 512 www.finra.org/brokercheck User Guidance

Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 01/11/1999 Docket/Case Number: 3-9803

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 CEASE AND DESIST Sought:

Resolution: Settled Resolution Date: 01/11/1999 Sanctions Ordered: Monetary/Fine $100,000.00 Other Sanctions Ordered: Sanction Details: 01/11/99, TOTAL AMOUNT PAID WAS $100,000. NO WAIVER. i Disclosure 290 of 336 Reporting Source: Firm Current Status: Final Allegations: NMSD ALLEGED THAT GIBRALTAR SECURITIES CO., PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY INCORPORATED, ENGAGED IN BROKER- DEALER ACTIVITIES IN THE STATE WITHOUT BEING LICENSED TO CONDUCT BUSINESS. Initiated By: STATE OF NEW MEXICO - SECURITIES DIVISION (NMSD) Date Initiated: 01/14/1999 Docket/Case Number: 99-99-998-125 (FO)

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 CEASE AND DESIST Sought:

Resolution: Consent Resolution Date: 03/29/1999 Sanctions Ordered: Monetary/Fine $22,146.00 Other Sanctions Ordered: Sanction Details: 03/29/1999 TOTAL AMOUNT PAID WAS $22,146.00. NO WAIVER. i Disclosure 291 of 336 Reporting Source: Firm Current Status: Final Allegations: BRANCH CABELL, PRIOR TO BECOMING AN AFFILIATE OF TUCKER ANTHONY INCORPORATED, ALLEDGEDLY VIOLATED SECTION 13.1-507, OFFERED AND SOLD UNREGISTERED SECURITIES IN THE STATE OF VIRGINIA Initiated By: VIRGINIA STATE CORPORATION COMMISSION Date Initiated: 10/26/1999 Docket/Case Number: SEC 99052

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: 10/26/1999 Sanctions Ordered: Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: FINE OF $50,000 WAS PAID ON 10/26/1999 i Disclosure 292 of 336 Reporting Source: Firm Current Status: Final Allegations: TUCKER ANTHONY INCORPORATED FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY ©2021 FINRA. All rights reserved. Report aboutDESIGNED RBC CAPITAL TO ACHIVE MARKETS, COMPLIANCE LLC WITH APPLICABLE SECURITIES LAWS 514 AND REGULATIONS, AND WITH THE RULES OF THIS ASSOCIATION CONCERNING ACT RULE COMPLIANCE, BEST EXECUTION, LIMIT ORDER PROTECTION, SEC ORDER ECXECUTION RULES, TRADE REPORTING, SOES, RECORD KEEPING, LOCKED AND CROSSED MARKETS, ANTI- COMPETITIVE PRACTICES, FRONTRUNNING AND SHORT SALES. SPECIFICALLY, THE ABOVE-REFERENCED SECTIONS OF TUCK'S WRITTEN SUPERVISORY PROCEDURES WERE FOUND TO BE DEFICIENT IN THAT THEY DID NOT PROVIDE FOR: (1) IDENTIFICATION OF THE PERSON(S) RESPONSIBLE AT TUCK FOR ENSURING COMPLIANCE SUCH LAWS, REGULATIONS, AND RULES; (2) A STATEMENT OF THE STEP(S) THAT SUCH PERSON(S) SHOULD TAKE TO ENSURE COMPLIANCE THEREWITH; (3) A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW ENFORCEMENT OF SUCH WRITTEN SUPERVISORY PROCEDURES SHOULD BE EVIDENCED AT TUCKER ANTHONY INCORPORATED. www.finra.org/brokercheck User Guidance

Allegations: TUCKER ANTHONY INCORPORATED FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS, AND WITH THE RULES OF THIS ASSOCIATION CONCERNING ACT RULE COMPLIANCE, BEST EXECUTION, LIMIT ORDER PROTECTION, SEC ORDER ECXECUTION RULES, TRADE REPORTING, SOES, RECORD KEEPING, LOCKED AND CROSSED MARKETS, ANTI- COMPETITIVE PRACTICES, FRONTRUNNING AND SHORT SALES. SPECIFICALLY, THE ABOVE-REFERENCED SECTIONS OF TUCK'S WRITTEN SUPERVISORY PROCEDURES WERE FOUND TO BE DEFICIENT IN THAT THEY DID NOT PROVIDE FOR: (1) IDENTIFICATION OF THE PERSON(S) RESPONSIBLE AT TUCK FOR ENSURING COMPLIANCE SUCH LAWS, REGULATIONS, AND RULES; (2) A STATEMENT OF THE STEP(S) THAT SUCH PERSON(S) SHOULD TAKE TO ENSURE COMPLIANCE THEREWITH; (3) A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW ENFORCEMENT OF SUCH WRITTEN SUPERVISORY PROCEDURES SHOULD BE EVIDENCED AT TUCKER ANTHONY INCORPORATED. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. (NASD) Date Initiated: 11/24/1999 Docket/Case Number: CMS010145

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/17/2001 Sanctions Ordered: Censure Monetary/Fine $78,500.00 Other Sanctions Ordered: A CENSURE, A FINE OF $78,500 ($20,000 FOR THE LIMIT ORDER DISPLAY VIOLATIONS, $5,000 FOR THE BEST EXECUTION VIOLATIONS, $1,000 FOR THE ACT RULE VIOLATIONS, $2,500 FOR THE SEC QUOTE RULE VIOLATIONS, $5,000 FOR THE FIPS RULES VIOLATIONS AND $35,000 FOR THE SUPERVISION VIOLATIONS), AN UNDERTAKING TO IMPLEMENT REVISED WRITTEN SUPERVISORY PROCEDURES IN THE AREAS DELINEATED ABOVE AND PAYMENT OF RESTITUTION TO THE CUSTOMERS DESCRIBED IN PARAGRAPH 5 HERETO IN THE TOTAL AMOUNT OF $201.99, PLUS INTEREST AT THE RATE SET FORTH IN SECTION 6621(A)(2) OF THE INTERNAL REVENUE CODE, 26 U.S.C. 6621(A)(2), FROM THE DATES OF THE ©2021 FINRA. All rights reserved. Report aboutVIOLATIVE RBC CAPITAL CONDUCT MARKETS, AS LLC INDICATED IN ATTACHMENT A, UNTIL THE DATE 515 THIS AWC IS ACCEPTED BY THE NAC. A CENSURE, A FINE OF $78,500 ($20,000 FOR THE LIMIT ORDER DISPLAY VIOLATIONS, $5,000 FOR THE BEST EXECUTION VIOLATIONS, $1,000 FOR THE ACT RULE VIOLATIONS, $2,500 FOR THE SEC QUOTE RULE VIOLATIONS, $5,000 FOR THE FIPS RULES VIOLATIONS AND $35,000 FOR THE SUPERVISION VIOLATIONS), AN UNDERTAKING TO IMPLEMENT www.finra.org/brokercheck REVISED WRITTEN SUPERVISORY PROCEDURES IN THE AREAS User Guidance DELINEATED ABOVE AND PAYMENT OF RESTITUTION TO THE CUSTOMERS DESCRIBED IN PARAGRAPH 5 HERETO IN THE TOTAL AMOUNT OF $201.99, PLUS INTEREST AT THE RATE SET FORTH IN SECTION 6621(A)(2) OF THE INTERNAL REVENUE CODE, 26 U.S.C. 6621(A)(2), FROM THE DATES OF THE VIOLATIVE CONDUCT AS INDICATED IN ATTACHMENT A, UNTIL THE DATE THIS AWC IS ACCEPTED BY THE NAC. Sanction Details: A CENSURE, A FINE OF $78,500 ($20,000 FOR THE LIMIT ORDER DISPLAY VIOLATIONS, $5,000 FOR THE BEST EXECUTION VIOLATIONS, $1,000 FOR THE ACT RULE VIOLATIONS, $2,500 FOR THE SEC QUOTE RULE VIOLATIONS, $5,000 FOR THE FIPS RULES VIOLATIONS AND $35,000 FOR THE SUPERVISION VIOLATIONS), AN UNDERTAKING TO IMPLEMENT REVISED WRITTEN SUPERVISORY PROCEDURES IN THE AREAS DELINEATED ABOVE AND PAYMENT OF RESTITUTION TO THE CUSTOMERS DESCRIBED IN PARAGRAPH 5 HERETO IN THE TOTAL AMOUNT OF $201.99, PLUS INTEREST AT THE RATE SET FORTH IN SECTION 6621(A)(2) OF THE INTERNAL REVENUE CODE, 26 U.S.C. 6621(A)(2), FROM THE DATES OF THE VIOLATIVE CONDUCT AS INDICATED IN ATTACHMENT A, UNTIL THE DATE THIS AWC IS ACCEPTED BY THE NAC. i Disclosure 293 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASDR ALLEGED THAT THE APPLICANT VIOLATED CONDUCT RULES 2110, IM 2110-2, AND SECURITIES EXCHANGE ACT RULES 10B-10 AND 11AC1-4 IN CONNECTION WITH ITS HANDLING OF OTC ORDERS. Initiated By: NASD REGULATION, INC. Date Initiated: 11/24/1999 Docket/Case Number: CMS990147

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: 11/24/1999 Sanctions Ordered: Censure Monetary/Fine $17,500.00 Other Sanctions Ordered:

Sanction Details: $17,500.00 WAS PAID ON JANUARY 13, 2000. NO WAIVER. i Disclosure 294 of 336 Reporting Source: Firm Current Status: Final Allegations: THE SEC INSTITUTED SETTLED ADMINISTRATIVE PROCEEDINGS AGAINST TUCKER ANTHONY, INC., A REGISTERED BROKER-DEALER. THE SEC ISSUED AN ORDER FINDING, AMONG OTHER THINGS, THAT ONE INDIVIDUAL, A FORMER TRADER, WHO TRADED MORTGAGE-BACKED SECURITIES IN A TUCKER ANTHONY PROPRIETARY ACCOUNT, CONCEALED APPROXIMATELY $2.6 MILLION IN TRADING LOSSES DURING 1997 BY MISMARKING, OR FALSIFYING THE "MARKET TO MARKET" PRICES OF, CERTAIN SECURITIES HELD IN THE PROPRIETARY ACCOUNT. THE ORDER FURTHER FINDS THAT TUCKER ANTHONY FAILED REASONABLY TO SUPERVISE INDIVIDUAL WITH A VIEW TOWARD PREVENTING HIS FRAUDULENT CONDUCT, THAT THE FIRM DID NOT HAVE ADEQUATE PROCEDURES DESIGNED TO ENSURE THAT SECURITIES HELD IN PROPRIETARY ACCOUNTS WERE MARKED TO MARKET ACCURATELY, AND THAT, AS A RESULT OF INDIVIDUAL'S MISMARKINGS, THE FIRM KEPT INACCURATE BOOKS AND RECORDS AND FILED INACCURATE REPORTS WITH THE SEC. BASED ON THESE FINDINGS, THE SEC CONCLUDED THAT TUCKER ANTHONY FAILEDREASONABLY TO SUPERVISE INDIVIDUAL IN ACCORDANCE WITH EXCHANGE ACT SECTION 15(B)(4)(E);THAT TUCKER ANTHONY VIOLATED THE RECORD KEEPING AND REPORTING PROVISIONS OF EXCHANGE ACT SECTION 17(A) AND RULES 17 A-3 AND 17A-5 THEREUNDER. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 12/21/2000 Docket/Case Number: RELS. 33-7930; 34-43760; FILE # 3-10396

Principal Product Type: Other Other Product Type(s): MORTGAGE-BACKED SECURITIES Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CENSURE AND CIVIL PENALTY Sought:

Resolution: Order Resolution Date: 12/21/2000 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine RBC CAPITAL $50,000.00 MARKETS, LLC 517 Cease and Desist/Injunction www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $50,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: (1) CENSURED; (2) OREDERED TO CEASE AND DESIST FROM THE VIOLATIONS OF SECTION 15(B)(4)(E) OF THE EXHANGE ACT, AND THE RECORD-KEEPING AND REPORTING PROVISIONS OF THE EXCHANGE ACT SECTION 17(A) AND RULES 17A-3 AND 17A-5 THEREUNDER; AND(3) A CIVIL PENALTY OF $50,000. Firm Statement +12/22/2000+SEC NEWS DIGEST, ISSUE #2000-244, DATED 12/21/2000, ENFORCEMENT PROCEEDINGS DISCLOSES; ON DECEMBER 21, THE SEC INSTITUTED SETTLED ADMINISTRATIVE PROCEEDINGS AGAINST TUCKER ANTHONY, INC. THE SEC CONCLUDED THAT TUCKER ANTHONY FAILED REASONABLY TO SUPERVISE ONE INDIVIDUAL, A FORMER TRADER, IN ACCORDANCE WITH EXCHANGE ACT SECTION 15(B)(4)(E); THAT TUCKER ANTHONY VIOLATED THE RECORD-KEEPING AND REPORTING PROVISIONS OF EXCHANGE ACT SECTION 17(A) AND RULES 17A-3 AND 17A-5 THEREUNDER. WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, TUCKER ANTHONY CONSENTED TO THE ISSUANCE OF THE SEC'S ORDER, WHICH CENSURES TUCKER ANTHONY; ORDERS TO CEASE AND DESIST FROM VIOLATIONS OF THE EXCHANGEACT; IMPOSES A $50,000 CIVIL PENALTY. (RELS. 33-7930; 34-43760; FILE #3-10396 i Disclosure 295 of 336 Reporting Source: Firm Current Status: Final Allegations: OCCURRED UNDER TUCKER ANTHONY INCORPORATED: RESPONSENT FAILED TO FILE WITH THE SECRETARY OF STATE, ILLINOIS SECURITIES DEPARTMENT AN ANNUAL NOTIFICATION FILING AS A FEDERAL COVERED INVESTMENT ADVISOR. Initiated By: ILLINOIS SECURITIES DEPARTMENT Date Initiated: 06/11/2001 Docket/Case Number: 0100081

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Prohibition Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 518 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 06/29/2001 Sanctions Ordered: Monetary/Fine $200.00 Other Sanctions Ordered: Sanction Details: RESPONDENT WAS FINED $200.00, AND SUBMITTED $300 FOR REIMBURSEMENT FOR COSTS OF THE INVESTIGATION. THE NOTICE OF HEARING IN THIS MATTER DIMISSED.A NOTICE Firm Statement A NOTICE OF HEARING, ISSUED JUNE 11, 2001. THE HEARING IS SCHEDULED FOR JULY 18, 2001. A SETTLEMENT AGREEMENHT ISSUED JUNE 29, 2001. CONTACT (217) 785-4948. THIS OCCURRENCE IS NOT REPORTABLE UNDER QUESTION 11D5 SINCE THE FIRMS ACTIVITIES WERE NOT RESTRICTED. i Disclosure 296 of 336 Reporting Source: Firm Current Status: Final Allegations: OCCURRED UNDER TUCKER ANTHONY INCORPORATED: SEC RULE 11AC1- 4, NASD MARKETPLACE RULE 6130(D)- WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT TRANSACTIONS IN ELIGIBLE SECURITIES TO ACT WITH A SHORT SALE MODIFIER, FAILED TO REPORT A TRANSACTION IN ELIGIBLE SECURITIES TO ACT WITH THE CORRECT NUMBER OF SHARES, AND FAILED TO REPORT TRANSACTIONS IN ELIGIBLE SECURITIES TO ACT WITH THE CORRECT SYMBOL INDICATING WHETHER THE FIRM EXECUTED TRANSACTIONS IN A PRINCIPAL OR AGENCY CAPACITY; AND FAILED TO DISPLAY IMMEDIATELY THE CUSTOMER LIMIT ORDERS 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 FOR EACH SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/02/2002

Docket/Case Number: CMS010198

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: 01/02/2002 Sanctions Ordered: Censure Monetary/Fine $16,000.00 Other Sanctions Ordered: Sanction Details: CENSURED AND FINED $16,000 i Disclosure 297 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN ADEQUATE PROCEDURES TO PROVIDE FOR THE PROMPT REVIEW OF LARGE PURCHASES OF CLASS B MUTUAL FUNDS OR OTHERWISE PROVIDE SPECIFIC TOOLS OR OTHER SUPERVISORY POLICIES AND PROCEDURES TO ASSIST ITS SALES PRACTICE SUPERVISORS IN ADEQUATELY ASSESSING THE SUITABLILITY OF CLASS B SHARE PURCHASES BY PUBLIC CUSTOMERS WHO WOULD HAVE BENEFITTED FROM PURCHASING CLASS A SHARES. THE FIRM HAD NO AUTOMATED OR MANUAL SYSTEM IN PLACE TO DETECT MUTUAL FUND BREAKPOINTS, PURCHASE LIMITATIONS, OR PROBLEMATIC PATTERNS IN CLASS B SHARE PURCHASES OF MUTUAL FUNDS AND THE FIRM'S WRITTEN SUPERVISORY PROCEDURES GAVE NO DIRECTION TO BRANCH OFFICE MANAGERS OR OTHER SUPERVISORS AS TO HOW TO DETECT AND PREVENT BREAKPOINT PROBLEMS, CLASS B SHARE PURCHASE SUITABLILITY PROBLEMS, AND HOW TO EVIDENCE THEIR SUPERVISORY REVIEW. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/14/2002 Docket/Case Number: C04020002 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 520 www.finra.org/brokercheck User Guidance

Docket/Case Number: C04020002

Principal Product Type: Other Other Product Type(s): CLASS B SHARES OF GROWTH FUNDS Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/14/2002 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: COSTS Sanction Details: CENSURED, FINED $15,000, AND JOINTLY AND SEVERALLY LIABLE WITH AN INDIVIDUAL FOR COSTS OF THE EXCHANGE OFFERED TO PUBLIC CUSTOMERS OF $82,942.87 AND WILL PROVIDE WRITTEN CONFIRMATION TO THE REASONABLE SATISFACTION OF NASDR DISTRICT 4 STAFF DEMONSTRATING HOW THE FIRM HAS EXCHANGED THE B SHARES FOR A SHARES TO EACH OF THE CUSTOMERS WHO PURCHASED CLASS B SHARES BASED UPON THE INDIVIDUAL'S RECOMMENDATIONS AND OF THE INDIVIDUAL'S PARTICIPATION IN SUCH COSTS BY NO LATER THAN FEBRUARY 15, 2002. i Reporting Source: Firm Current Status: Final Allegations: NASD RULES 2110, 3010 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN ADEQUATE PROCEDURES TO PROVIDE FOR PROMPT REVIEW OF LARGE PURCHASES OF CLASS B MUTUAL FUNDS OR OTHERWISE PROVIDE SPECIFIC TOOLS OR OTHER SUPERVISORY POLICIES AND PROCEDURES TO ASSIST ITS SALES PRACTICE SUPERVISORS IN ADEQUATELY ASSESSING THE SUITABILITY OF CLASS B SHARE PURCHASES BY PUBLIC CUSTOMERS WHO WOULD HAVE BENEFITTED FROM PURCHASING CLASS A SHARES. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/14/2002 Docket/Case Number: C04020002

Principal Product Type: Options Other Product Type(s): CLASS B SHARES OF GROWTH FUNDS Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/14/2002 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: COSTS Sanction Details: CENSURED, FINED $15,000, AND JOINTLY AND SEVERALLY LIABLE WITH AN INDIVIDUAL FOR COSTS OF THE EXCHANGE OFFERED TO PUBLIC CUSTOMERS OF $82,942.87 AND WILL PROVIDE WRITTEN CONFIRMATION TO THE REASONABLE SATISFACTION OF NASDR DISTRICT 4 STAFF DEMONSTRATING HOW THE FIRM HAS EXCHANGED THE B SHARES FOR A SHARES TO EACH OF THE CUSTOMERS WHO PURCHASED CLASS B SHARES BASED UPON THE INDIVIDUAL'S RECOMMENDATIONS AND OF THE INDIVIDUAL'S PARTICIPATION IN SUCH COSTS BY NO LATER THAN FEBRUARY 15, 2002. i Disclosure 298 of 336 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110 AND 6240(A)(2) - RESPONDENT FAILED TO REPORT TO THE FIXED INCOME PRICING SYSTEM (FIPS) TRANSACTIONS IN FIPS SECURITIES WITHIN FIVE MINUTES AFTER EXECUTION. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 10/02/2001 Docket/Case Number: CMS010146

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 522 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/02/2001 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: N/A i Reporting Source: Firm Current Status: Final Allegations: ALLEGATIONS THAT THE FIRM FAILED TO REPORT 46 TRANSACTIONS IN FIPS SECURITIES TO THE FIXED INCOME PRICING SYSTEM WITHIN FIVE MINUTES OF EXECUTION, BETWEEN THE PERIOD OF FEBRUARY 28 THROUGH JUNE 8,2000 FROM REVIEW MRD200025962. Initiated By: NASD Date Initiated: 06/08/2000 Docket/Case Number: CMS010146 AWC

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: 06/16/2001 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM ACCEPTED A CENSURE AND PAID THE FINE OF $7500.00 i Disclosure 299 of 336 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 523 www.finra.org/brokercheck User Guidance

Reporting Source: Regulator Current Status: Final Allegations: RELEASE NO. 33-8013/34-44864, DATED SEPTEMBER 27, 2001 DISCLOSES:THE SEC DEEMS IT APPROPRIATE, IN THE PUBLIC INTEREST, AND FOR THE PROTECTION OF INVESTORS TO INSTITUTE PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST RAUSCHER PIERCE REFSNES, INC., NOW KNOWN AS DAIN RAUSCHER INCORPORATED ("RAUSCHER OR RESPONDENT"), PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), SECTIONS 15(B), 19(H) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"). Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/27/2001 Docket/Case Number: RELEASE NO. 33-8013/34-44864

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

Resolution: Order Resolution Date: 09/27/2001 Sanctions Ordered: Monetary/Fine $200,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKINGS Sanction Details: IT IS ORDERED THAT, PURSUANT TO SECTION 8A OF THE SECURITIES ACT AND SECTIONS 15(B), 19(H) AND 21C OF THE EXCHANGE ACT:RESPONDENT RAUSCHER SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATION AND ANY FUTURE VIOLATION OF SECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT, AND MSRB RULE G-17.RAUSCHER SHALL, WITHIN THIRTY (30) DAYS OF THE DATE OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $200,000 TO THE UNITED STATES TREASURY. RAUSCHER SHALL COMPLY WITH THE UNDERTAKINGS SPECIFIED IN ITS OFFER OF SETTLEMENT.RELEASE NO. 33-8014, DATED SEPTEMBER 27, 2001 DISCLOSES: IT IS ORDERED, PURSUANT TO RULE 602(E) UNDER THE SECURITIES ACT, THAT A WAIVER FROM THE APPLICATION OF THE DISQUALIFICATION PROVISION OF RULE 602(C)(3) UNDER THE SECURITIES ©2021 FINRA. All rights reserved. Report aboutACT RBC RESULTING CAPITAL MARKETS, FROM THELLC ENTRY OF THE ORDER IS HEREBY GRANTED. 524 IT IS ORDERED THAT, PURSUANT TO SECTION 8A OF THE SECURITIES ACT AND SECTIONS 15(B), 19(H) AND 21C OF THE EXCHANGE ACT:RESPONDENT RAUSCHER SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATION AND ANY FUTURE VIOLATION OF SECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT, AND MSRB RULE G-17.RAUSCHER SHALL, WITHIN THIRTY (30) DAYS OF THE DATE OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $200,000 TO THE UNITED STATES TREASURY. www.finra.org/brokercheck RAUSCHER SHALL COMPLY WITH THE UNDERTAKINGS SPECIFIED IN ITS User Guidance OFFER OF SETTLEMENT.RELEASE NO. 33-8014, DATED SEPTEMBER 27, 2001 DISCLOSES: IT IS ORDERED, PURSUANT TO RULE 602(E) UNDER THE SECURITIES ACT, THAT A WAIVER FROM THE APPLICATION OF THE DISQUALIFICATION PROVISION OF RULE 602(C)(3) UNDER THE SECURITIES ACT RESULTING FROM THE ENTRY OF THE ORDER IS HEREBY GRANTED. Regulator Statement THE COMMISSION FINDS THAT RAUSCHER WILLFULLY VIOLATED, AND COMMITTED OR CAUSED VIOLATIONS OF, SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT, IN THAT, IN THE OFFER AND SALE OF CERTAIN SECURITIES, NAMELY THE PENSION BONDS, BY THE USE OF THE MEANS AND INSTRUMENTS OF TRANSPORTATION AND COMMUNICATION IN INTERSTATE COMMERCE AND BY THE USE OF THE MAILS, RESPONDENT RAUSCHER DIRECTLY AND INDIRECTLY, OBTAINED MONEY OR PROPERTY BY MEANS OF UNTRUE STATEMENTS OF MATERIAL FACTS AND OMISSIONS TO STATE MATERIAL FACTS NECESSARY IN ORDER TO MAKE STATEMENTS MADE, IN LIGHT OF THE CIRCUMSTANCES UNDER WHICH THEY WERE MADE, NOT MISLEADING; AND ENGAGED IN TRANSACTIONS, PRACTICES AND A COURSE OF BUSINESS WHICH WOULD AND DID OPERATE AS A FRAUD AND DECEIT UPON THE PURCHASERS AND PROSPECTIVE PURCHASERS OF SUCH SECURITIES.THE COMMISSION FINDS THAT RAUSCHER WILLFULLY VIOLATED, AND COMMITTED OR CAUSED VIOLATIONS OF, RULE G-17 OF THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") BY NOT DEALING FAIRLY WITH ALL PERSONS AND BY ENGAGING IN DECEPTIVE, DISHONEST OR UNFAIR PRACTICES IN THE CONDUCT OF ITS MUNICIPAL SECURITIES BUSINESS.THE COMMISSION FINDS THAT RAUSCHER WILLFULLY VIOLATED, AND COMMITTED OR CAUSED VIOLATIONS OF, SECTION 15B(C)(1) OF THE EXCHANGE ACT BY EFFECTING TRANSACTIONS IN, OR INDUCING OR ATTEMPTING TO INDUCE THE PURCHASE OR SALE OF, MUNICIPAL SECURITIES IN VIOLATION OF A RULE OF THE MSRB.

i Reporting Source: Firm Current Status: Final Allegations: RELEASE NO. 33-8013/34-44864, DATED SEPTEMBER 27, 2001 DISCLOSES:THE SEC DEEMS IT APPROPRIATE, IN THE PUBLIC INTEREST, AND FOR THE PROTECTION OF INVESTORS TO INSTITUTE PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST RAUSCHER PIERCE REFSNES, INC., NOW KNOWN AS RBC DAIN RAUSCHER INC. ("RAUSCHER OR RESPONDENT"), PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), SECTIONS 15(B), 19(H) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"). Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/27/2001 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 525 www.finra.org/brokercheck User Guidance

Date Initiated: 09/27/2001 Docket/Case Number: RELEASE NO. 33-8013/34-44864

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

Resolution: Order Resolution Date: 09/27/2001 Sanctions Ordered: Monetary/Fine $200,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKINGS Sanction Details: IT IS ORDERED THAT, PURSUANT TO SECTION 8A OF THE SECURITIES ACT AND SECTIONS 15(B), 19(H) AND 21C OF THE EXCHANGE ACT:RESPONDENT RAUSCHER SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATION AND ANY FUTURE VIOLATION OF SECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT, AND MSRB RULE G-17.RAUSCHER SHALL, WITHIN THIRTY (30) DAYS OF THE DATE OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $200,000 TO THE UNITED STATES TREASURY. RAUSCHER SHALL COMPLY WITH THE UNDERTAKINGS SPECIFIED IN ITS OFFER OF SETTLEMENT.RELEASE NO. 33-8014, DATED SEPTEMBER 27, 2001 DISCLOSES: IT IS ORDERED, PURSUANT TO RULE 602(E) UNDER THE SECURITIES ACT, THAT A WAIVER FROM THE APPLICATION OF THE DISQUALIFICATION PROVISION OF RULE 602(C)(3) UNDER THE SECURITIES ACT RESULTING FROM THE ENTRY OF THE ORDER IS HEREBY GRANTED. Firm Statement THE COMMISSION FINDS THAT RAUSCHER WILLFULLY VIOLATED, AND COMMITTED OR CAUSED VIOLATIONS OF, SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT, IN THAT, IN THE OFFER AND SALE OF CERTAIN SECURITIES, NAMELY THE PENSION BONDS, BY THE USE OF THE MEANS AND INSTRUMENTS OF TRANSPORTATION AND COMMUNICATION IN INTERSTATE COMMERCE AND BY THE USE OF THE MAILS, RESPONDENT RAUSCHER DIRECTLY AND INDIRECTLY, OBTAINED MONEY OR PROPERTY BY MEANS OF UNTRUE STATEMENTS OF MATERIAL FACTS AND OMISSIONS TO STATE MATERIAL FACTS NECESSARY IN ORDER TO MAKE STATEMENTS MADE, IN LIGHT OF THE CIRCUMSTANCES UNDER WHICH THEY WERE MADE, NOT MISLEADING; AND ENGAGED IN TRANSACTIONS, PRACTICES AND A COURSE OF BUSINESS WHICH WOULD AND DID OPERATE AS A FRAUD AND DECEIT UPON THE PURCHASERS AND ©2021 FINRA. All rights reserved. Report aboutPROSPECTIVE RBC CAPITAL PURCHASERSMARKETS, LLC OF SUCH SECURITIES.THE COMMISSION 526 FINDS THAT RAUSCHER WILLFULLY VIOLATED, AND COMMITTED OR CAUSED VIOLATIONS OF, RULE G-17 OF THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") BY NOT DEALING FAIRLY WITH ALL PERSONS AND BY ENGAGING IN DECEPTIVE, DISHONEST OR UNFAIR PRACTICES IN THE CONDUCT OF ITS MUNICIPAL SECURITIES BUSINESS.THE COMMISSION FINDS THAT RAUSCHER WILLFULLY VIOLATED, AND COMMITTED OR CAUSED VIOLATIONS OF, SECTION 15B(C)(1) OF THE EXCHANGE ACT BY EFFECTING TRANSACTIONS IN, OR INDUCING OR ATTEMPTING TO INDUCE THE PURCHASE OR SALE OF, MUNICIPAL SECURITIES IN VIOLATION OF A RULE OF THE MSRB.

------THE COMMISSION FINDS THAT RAUSCHER WILLFULLY VIOLATED, AND COMMITTED OR CAUSED VIOLATIONS OF, SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT, IN THAT, IN THE OFFER AND SALE OF CERTAIN SECURITIES, NAMELY THE PENSION BONDS, BY THE USE OF THE MEANS AND INSTRUMENTS OF TRANSPORTATION AND COMMUNICATION IN INTERSTATE COMMERCE AND BY THE USE OF THE MAILS, RESPONDENT RAUSCHER DIRECTLY AND INDIRECTLY, OBTAINED MONEY OR PROPERTY BY MEANS OF UNTRUE STATEMENTS OF MATERIAL FACTS AND www.finra.org/brokercheck OMISSIONS TO STATE MATERIAL FACTS NECESSARY IN ORDER TO MAKE User Guidance STATEMENTS MADE, IN LIGHT OF THE CIRCUMSTANCES UNDER WHICH THEY WERE MADE, NOT MISLEADING; AND ENGAGED IN TRANSACTIONS, PRACTICES AND A COURSE OF BUSINESS WHICH WOULD AND DID OPERATE AS A FRAUD AND DECEIT UPON THE PURCHASERS AND PROSPECTIVE PURCHASERS OF SUCH SECURITIES.THE COMMISSION FINDS THAT RAUSCHER WILLFULLY VIOLATED, AND COMMITTED OR CAUSED VIOLATIONS OF, RULE G-17 OF THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") BY NOT DEALING FAIRLY WITH ALL PERSONS AND BY ENGAGING IN DECEPTIVE, DISHONEST OR UNFAIR PRACTICES IN THE CONDUCT OF ITS MUNICIPAL SECURITIES BUSINESS.THE COMMISSION FINDS THAT RAUSCHER WILLFULLY VIOLATED, AND COMMITTED OR CAUSED VIOLATIONS OF, SECTION 15B(C)(1) OF THE EXCHANGE ACT BY EFFECTING TRANSACTIONS IN, OR INDUCING OR ATTEMPTING TO INDUCE THE PURCHASE OR SALE OF, MUNICIPAL SECURITIES IN VIOLATION OF A RULE OF THE MSRB.

------i Disclosure 300 of 336 Reporting Source: Regulator Current Status: Final Allegations: 11/14/00GS: NASD RULES 2110 AND 6240(A)(2) - RESPONDENT MEMBER FAILED TO REPORT TO FIPS THE CORRECT EXECUTION TIME IN TRANSACTIONS IN FIPS SECURITIES; AND, FAILED TO REPORT TO FIPS TRANSACTIONS IN FIPS SECURITIES WITHIN FIVE MINUTES AFTER EXECUTION. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 10/27/2000 Docket/Case Number: CMS000221

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: 10/27/2000 Sanctions Ordered: Monetary/Fine $5,000.00 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 527 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: 05-31-01, $5,000 PAID 11/29/00 i Reporting Source: Firm Current Status: Final Allegations: ALLEGATIONS OF FIRM FAILING TO REPORT TO FIPS THE CORRECT EXECUTION TIME IN TRANSACTIONS IN FIPS SECURITIES; AND FAILED TO REPORT TO FIPS TRANACTIONS IN FIPS SECURITIES WITHIN FIVE MINUTES AFTER EXECUTION. Initiated By: NASD Date Initiated: 10/27/2000 Docket/Case Number: CMS000221

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: 10/27/2000 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ALLEGATIONS, THE FIRM ACCEPTED AN AWC, AND A FINE OF $5,000.00 i Disclosure 301 of 336 Reporting Source: Regulator Current Status: Final Allegations: 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. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 528 www.finra.org/brokercheck User Guidance 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: 06/16/2000 Docket/Case Number: CMS990103

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: 06/16/2000 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 $2,500.00 Other Sanctions Ordered: Sanction Details: FINED $2,500. i Reporting Source: Firm Current Status: Final Allegations: ALLEGATIONS OF INACCURATE FIPS PRICING AND REPORTING TIMES IN RESPONSE TO THE NASD MARKET REGULATION REVIEW (MRD19970959). Initiated By: NASD Date Initiated: 05/27/1997 Docket/Case Number: CMS990103

Principal Product Type: Debt - Corporate Other Product Type(s): Principal Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 529 www.finra.org/brokercheck User Guidance

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/16/2000 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ALLEGATIONS DAIN ACCEPTED THE AWC AND A FINE OF $2500.00. Firm Statement WITHOUT ADMITTING OR DENYING ALLEGATIONS DAIN ACCEPTED THE AWC. i Disclosure 302 of 336 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. IN ADDITION TO FINDINGS THAT DAIN RAUSCHER CHARGED UNDISCLOSED, EXCESSIVE MARKUPS ON MUNICIPAL TRANSACTIONS, THE COMMISSION'S ORDER ALSO FOUND ©2021 FINRA. All rights reserved. Report aboutTHAT RBC A DAINCAPITAL RAUSCHER MARKETS, LLC PREDECESSOR, RAUSCHER PIERCE REFSNES, 530 INC. ("RAUSCHER PIERCE"), BREACHED ITS FIDUCIARY DUTY TO ONE OF ITS FINANCIAL ADVISORY CLIENTS, THE DEPARTMENT OF ADMINISTRATION OF THE STATE OF ARIZONA, BY MAKING FALSE STATEMENTS, FAILING TO MAKE NECESSARY DISCLOSURES, AND CHARGING EXCESSIVE, UNDISCLOSED MARKUPS IN CONNECTION WITH A 1992 REFUNDING. 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 www.finra.org/brokercheck INFLATED PRICES AND JEOPARDIZING THE TAX-EXEMPT STATUS OF User Guidance THE MUNICIPALITIES' REFUNDING BONDS. IN ADDITION TO FINDINGS THAT DAIN RAUSCHER CHARGED UNDISCLOSED, EXCESSIVE MARKUPS ON MUNICIPAL TRANSACTIONS, THE COMMISSION'S ORDER ALSO FOUND THAT A DAIN RAUSCHER PREDECESSOR, RAUSCHER PIERCE REFSNES, INC. ("RAUSCHER PIERCE"), BREACHED ITS FIDUCIARY DUTY TO ONE OF ITS FINANCIAL ADVISORY CLIENTS, THE DEPARTMENT OF ADMINISTRATION OF THE STATE OF ARIZONA, BY MAKING FALSE STATEMENTS, FAILING TO MAKE NECESSARY DISCLOSURES, AND CHARGING EXCESSIVE, UNDISCLOSED MARKUPS IN CONNECTION WITH A 1992 REFUNDING. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 04/06/2000 Docket/Case Number: RELS. 33-7846; 34-42646; FILE #3-10182

Principal Product Type: Other Other Product Type(s): MUNICIPAL BONDS Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief (1) CENSURE, (2) CIVIL PENALTY, AND (3) DISGORGEMENT Sought:

Resolution: Consent Resolution Date: 04/06/2000 Sanctions Ordered: Censure Monetary/Fine $100,000.00 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 ANTIFRAUD PROVISIONS OF THE FEDERAL SECURITIES LAWS. THE ANTIFRAUD PROVISIONS CHARGED INCLUDE: SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT OF 1933 (THE "SECURITIES ACT"), SECTION 10(B) AND RULE 10B-5 OF THE SECURITIES EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT"), AND SECTIONS 206(1), 206(2), AND 206(3) OF THE INVESTMENT ADVISERS ACT OF 1940 (THE "ADVISERS ACT"); (3) DISGORGEMENT OF $12.8 MILLION ($11.2 MILLION TO THE TREASURY AND $1.6 MILLION TO MUNICIPAL ISSUERS); AND (4) A PENALTY OF $100,000. 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 ©2021 FINRA. All rights reserved. Report aboutANNOUNCED RBC CAPITAL TODAY MARKETS, ARE LLC PART OF A GLOBAL RESOLUTION OF ALL YIELD 531 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 DAIN RAUSCHER INCORPORATED 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. 33-7846; 34-42646; FILE NO. 3-10182) +04/09/2000+ SEC NEWS DIGEST, ISSUE NO. 2000-65, DATED 04/06/2000, www.finra.org/brokercheck ENFORCEMENT PROCEEDINGS DISCLOSES: THE SEC TODAY BROUGHT User Guidance 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 DAIN RAUSCHER INCORPORATED 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. 33-7846; 34-42646; FILE NO. 3-10182)

i Reporting Source: Firm Current Status: Final Allegations: AS PART OF A GLOBAL SETTLEMENT BY SEVENTEEN BROKER-DEALERS, THE SEC INSTITUTED AND SETTLED ADMINISTRATIVE PROCEEDINGS AGAINST TEN BROKER-DEALERS, INCLUDING DAIN RAUSCHER ALLEGING UNLAWFUL, UNDISCLOSED OVERCHARGES IN CONNECTION WITH THE PRICING OF ESCROW SECURITIES SOLD TO CERTAIN MUNICIPAL BOND ISSUERS FOR USE IN ADVANCE REFUNDING TRANSACTIONS.

Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION Date Initiated: 04/06/2000 Docket/Case Number: ADMIN PROCEEDING NO. 3-10182

Principal Product Type: Debt - Government Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S) AND Sought: CEASE AND DESIST ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 532 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S) AND Sought: CEASE AND DESIST

Resolution: Settled Resolution Date: 04/06/2000 Sanctions Ordered: Monetary/Fine $100,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: DRI AGREED TO PAY DISGORGEMENT AND PRE-JUDGEMENT INTEREST OF $12.8 MILLION AND A FINE OF $100,000.00. DRI PAID THE FINE AND DISGORGEMENT ON APRIL 21,2000. Firm Statement DRI SIMULTANEOUSLY SETTLED AN ACTION THAT HAD BEEN BROUGHT UNDER THE FALSE CLAIMS ACT. THIS ACTION ALSO RELATED TO THE MARK-UPS CHARGED ON ESCROW SECURITIES SOLD TO CERTAIN MUNICPAL BOND ISSUERS. i Disclosure 303 of 336 Reporting Source: Firm Current Status: Final Allegations: THE SEC CONDUCTED AN INVESTIGATION INTO THE DISTRIBUTION OF CERTAIN GOVERNMENT SPONSORED ENTERPRISES, AND DAIN BOSWORTH, WITHOUT ADMITTING OR DENYING THE FINDINGS, ENTERED INTO A SETTLEMENT AGREEMENT. Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 01/01/1991 Docket/Case Number: HO-2513

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

Resolution: Settled Resolution Date: 01/13/1992 Sanctions Ordered: Monetary/Fine $50,000.00 ©2021 FINRA. All rights reserved. Report aboutCease RBC and CAPITAL Desist/Injunction MARKETS, LLC 533 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $50,000.00 Cease and Desist/Injunction Other Sanctions Ordered: DEVELOPMENT OF PROCEDURES TO ENSURE SUBSEQUENT COMPLIANCE. Sanction Details: CEASE AND DESIST ORDER; $50,000.00 FINE, AND DEVELOPMENT OF PROCEDURES TO ENSURE SUBSEQUENT COMPLIANCE. i Disclosure 304 of 336 Reporting Source: Firm Current Status: Final Allegations: STATE ALLEGES THE FOLLOWING: A)FAILURE TO REGISTER FOUR REPS AS INVESTMENT ADVISORS B)EXECUTION OF TRADES BY ONE REP PRIOR TO TRANSFER OF LICENSE. C)ONE REP ACTING AS INVESTMENT ADVISOR PRIOR TO EFFECTIVE DATE OF REGISTRATION. D)VARIOUS RECORD KEEPING VIOLATIONS. Initiated By: STATE OF OKLAHOMA, DEPARTMENT OF SECURITIES Date Initiated: 06/01/1996 Docket/Case Number: ODS96-7

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: 08/30/1999 Sanctions Ordered: Monetary/Fine $22,000.00 Other Sanctions Ordered: Sanction Details: FIRM ACCEPTED A FINE OF $22,000.00 i Disclosure 305 of 336 Reporting Source: Firm Current Status: Final

©2021Allegations: FINRA. All rights reserved. Report aboutALLEGES RBC CAPITAL THAT MARKETS, RESPONDENTS LLC CLARK AND GOODBREAD CONSPIRED TO 534 CIRCUMVENT INDUSTRY STANDARDS AND RESPONDENT MEMBER, RAUSCHER PIERCE REFSNES, INC., FAILED TO EXCERCISE DUE DILIGENCE IN THE EXECUTION OF TRANSACTIONS ON GOODBREAD'S ACCOUNT AND FAILED TO SUPERVISE THE TRANACTIONS OF CLARK. www.finra.org/brokercheck User Guidance

Allegations: ALLEGES THAT RESPONDENTS CLARK AND GOODBREAD CONSPIRED TO CIRCUMVENT INDUSTRY STANDARDS AND RESPONDENT MEMBER, RAUSCHER PIERCE REFSNES, INC., FAILED TO EXCERCISE DUE DILIGENCE IN THE EXECUTION OF TRANSACTIONS ON GOODBREAD'S ACCOUNT AND FAILED TO SUPERVISE THE TRANACTIONS OF CLARK. Initiated By: DISTRICT BUSINESS CONDUCT COMMITTEE #6 Date Initiated: 09/23/1970 Docket/Case Number: TEX-163

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

Resolution: Settled Resolution Date: 09/23/1970 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: RAUSCHER PIERCE REFSNES, INC ACCEPTED A CENSURE AND FINE OF $500.00. Sanction Details: DBCC RENDERED DECISION WHEREIN CLARK WAS SUSPENDED FROM ASSOCIATION WITH ANY MEMBER OF THE ASSOCIATION FOR ONE YEAR; FINED $1500.00 AND GOODBREAD WAS FINED $1500.00. ALLEGATIONS TO CIRCUMVENT INDUSTRY STANDARDS WERE DISMISSED. i Disclosure 306 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NYSE ALLEGES THAT THE MILWAUKEE COMPANY (PRIOR TO ITS ACQUISITION BY DAIN BOSWORTH,NOW KNOWN AS DAIN RAUSCHER, INC.)VIOLATED VARIOUS REGULATIONS OF THE EXCHANGE ACT OF 1934 RELATIVE TO ITS RESERVE BANK ACCOUNT, FILING INACCURATE FOCUS REPORTS, AND UNTIMLEY FILING OF A CERTIFIED AUDITED FINANCIAL STATEMENT. Initiated By: NEW YORK STOCK EXCHANGE, INC Date Initiated: 10/01/1988

Docket/Case Number: UNKNOWN

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

Resolution: Settled Resolution Date: 11/01/1989 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM CONSENTED TO A CENSURE AND $20,000.00 FINE. Firm Statement THESE ALLEGATIONS WERE NOT RELATED TO DAIN RAUSCHER, INC. (FORMERLY KNOWN AS DAIN BOSWORTH, INC.),BUT RATHER TO THE MILWAUKEE COMPANY (A FIRM ACQUIRED BY DAIN BOSWORTH, INC.),FOR ACTIONS WHICH OCCURRED PRIOR TO THE ACQUISITION. i Disclosure 307 of 336 Reporting Source: Firm Current Status: Final Allegations: THE CBOE ALLEGED THAT RAUSCHER PIERCE REFSNES, INC., FAILED TO SUPERVISE ONE OF ITS REPRESENTATIVES, WHO ALLEGEDLY EFFECTED UNSUITABLE OPTION TRANSACTIONS IN TWO CUSTOMER ACCOUNTS. Initiated By: CHICAGO BOARD OF OPTIONS EXCHANGE Date Initiated: 08/01/1989 Docket/Case Number: 89-0111

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/12/1989 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, RPR ACCEPTED A LETTER OF CONSENT IN WHICH IT AGREED TO A $250.00 FINE. Firm Statement UPON A REVIEW OF THE CRD RECORDS FOR DAIN RAUSCHER, INC., IT WAS NOTED THAT THIS INCIDENT WAS NOT TRANSFERRED FROM RAUSCHER PIERCE'S OLD CRD RECORD (6663), WHEN IT MERGED WITH ITS AFFILIATED IN EALY 1998. i Disclosure 308 of 336 Reporting Source: Firm Current Status: Final Allegations: THE CBOE ALLEGED THAT RAUSCHER PIERCE REFSNES, INC., (KNOW KNOWN AS DAIN RAUSCHER INC.)FAILED TO HAVE ROP QUALIFIED MANAGERS IN THREE BRANCH OFFICES. Initiated By: CHICAGO BOARD OF OPTIONS EXCHANGE Date Initiated: 11/08/1985 Docket/Case Number: 85-0106

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

Resolution: Settled Resolution Date: 11/08/1985 Sanctions Ordered: Censure Monetary/Fine $1,500.00 Other Sanctions Ordered: Sanction Details: THE CBOE IMPOSED A FINE OF $1500.00 Firm Statement UPON A REVIEW OF THE CRD RECORDS FOR DAIN RAUSCHER, INC., IT ©2021 FINRA. All rights reserved. Report aboutWAS RBC NOTED CAPITAL THAT MARKETS, THIS LLCINCIDENT WAS NOT TRANSFERRED FROM 537 RAUSCHER PIERCE'S OLD CRD RECORD (6663), WHEN IT MERGED WITH ITS AFFILIATED IN EALY 1998. www.finra.org/brokercheck User Guidance

Firm Statement UPON A REVIEW OF THE CRD RECORDS FOR DAIN RAUSCHER, INC., IT WAS NOTED THAT THIS INCIDENT WAS NOT TRANSFERRED FROM RAUSCHER PIERCE'S OLD CRD RECORD (6663), WHEN IT MERGED WITH ITS AFFILIATED IN EALY 1998. i Disclosure 309 of 336 Reporting Source: Firm Current Status: Final Allegations: THE CBOE ALLEGED THAT RAUCHER PIERCE REFSNES, INC (NOW KNOWN AS DAIN RAUSCHER INC.) EFFECTED OPTION TRANSACTIONS IN 11 CUSTOMER ACCOUNTS PRIOR TO RECEIPT OF THE SIGNED CUSTOMER OPTION AGREEMENTS. Initiated By: CHICAGO BOARD OF OPTIONS EXCHANGE Date Initiated: 07/19/1982 Docket/Case Number: 82-0038

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

Resolution: Other Resolution Date: 07/19/1982 Sanctions Ordered: Other Sanctions Ordered: Sanction Details: THE CBOE IMPOSED A FINE OF $1000.00. Firm Statement UPON A REVIEW OF THE CRD RECORDS FOR DAIN RAUSCHER, INC., IT WAS NOTED THAT THIS INCIDENT WAS NOT TRANSFERRED FROM RAUSCHER PIERCE'S OLD CRD RECORD (6663), WHEN IT MERGED WITH ITS AFFILIATED IN EALY 1998. i Disclosure 310 of 336 Reporting Source: Firm Current Status: Final Allegations: ALLEGATIONS THAT RAUSCHER PRIECE REFSNES, INC FAILED TO ©2021 FINRA. All rights reserved. Report aboutADEQUATELY RBC CAPITAL SUPERVISE MARKETS, LLC THE ACTIVITIES OF ONE REPRESENTATIVE 538 DURING 1984 THROUGH 1986. www.finra.org/brokercheck User Guidance

Allegations: ALLEGATIONS THAT RAUSCHER PRIECE REFSNES, INC FAILED TO ADEQUATELY SUPERVISE THE ACTIVITIES OF ONE REPRESENTATIVE DURING 1984 THROUGH 1986. Initiated By: AMERICAN STOCK EXCHANGE Date Initiated: 07/27/1993 Docket/Case Number: 92- D - 05

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

Resolution: Settled Resolution Date: 07/27/1993 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: THE ASE CENSURED AND IMPOSED A $25,000.00 FINE. Firm Statement THE AMEX STIPULATED THAT RAUSCHER PIERCE REFSNES, INC. HAD INADEQUATE SUPERVISORY PROCEDURES. THE AMEX TAKES THE POSTITION THAT ADDITIONAL, EXTRAORDIANRY STEPS COULD HAVE BEEN TAKEN AND WERE NOT REGARDING THE ACTIVITIES OF ONE REPRESENTATIVE. RPR DID NOT ADMIT TO ANY VIOLATION. THIS QUESTION WAS PREVIOUSLY REPORTED UNDER QUESTION 7G AND THEN 7E2. AS OF THIS FILING, IT NOW FALLS UNDER 11E2. AMENDMENT IS BEING FILED TO MOVE THIS DISCLOSURE UNDER QUESTION 11E2. i Disclosure 311 of 336 Reporting Source: Firm Current Status: Final Allegations: RAUSCHER PIERCE REFSNES ACTED AS A BROKER/DEALER IN MAINE PRIOR TO BEING REGISTERED AS SUCH. Initiated By: MAINE Date Initiated: 10/14/1991 Docket/Case Number: NONE ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 539 www.finra.org/brokercheck User Guidance

Docket/Case Number: NONE

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

Resolution: Settled Resolution Date: 06/16/1994 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: RAUSCHER PIERCE REFSNES WILL COMPLIY WITH ALL LICENISNG AND OTHER LEGAL REQUIREMENTS GOVERNING PERSONS ACTING AS SECURITIES BROKER/DEALERS IN THE STATE OF MAINE AND WILL PAY A FINE OF $10,000.00 i Disclosure 312 of 336 Reporting Source: Firm Current Status: Final Allegations: OKLAHOMA ISSUED A FINDING THAT RAUSCHER PIERCE REFSNES EFFECTED APPROXIMATELY 15 TRANASACTIONS IN SECURITIES WHICH WERE NEITHER REGISTERED NOR EXEMPT IN THE STATE. Initiated By: OKLAHOMA Date Initiated: 12/01/1988 Docket/Case Number: NONE

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

Resolution Date: 10/08/1990 Sanctions Ordered: Monetary/Fine $1,500.00 Other Sanctions Ordered: Sanction Details: OKLAHOMA IMPOSED A FINE OF $1500.00. i Disclosure 313 of 336 Reporting Source: Firm Current Status: Final Allegations: THE STATE ALLEDGED THAT RAUSCHER PIERCE REFSNES CONDUCTED BUSINESS IN THE NEW HAMPSHIRE PRIOR TO BECOMING LICENSED TO DO SO. Initiated By: NEW HAMPSHIRE Date Initiated: 11/03/1992 Docket/Case Number: NONE

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

Resolution: Settled Resolution Date: 12/08/1992 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: THE MATTER WAS FORMALLY RESOLVED, AND RAUSCHER PIERCE REFSNES, INC. PAID A FINE OF $5,000.00 i Disclosure 314 of 336 Reporting Source: Firm Current Status: Final Allegations: THE STATE ALLEDGED THAT DAIN BOSWORTH FAILED TO REQUEST AN EXEMPTION FROM THEIR STATUTORY DISQUALIFICATION PROVISION AT ©2021 FINRA. All rights reserved. Report aboutTHE RBC TIME CAPITAL PRIVATE MARKETS, PLACEMENT LLC PAPERWORK WAS FILED FOR THE APRIL 541 1992 SALE OF THEME PARTNERS, A LIMITED PARTNERSHIP. www.finra.org/brokercheck User Guidance

THE STATE ALLEDGED THAT DAIN BOSWORTH FAILED TO REQUEST AN EXEMPTION FROM THEIR STATUTORY DISQUALIFICATION PROVISION AT THE TIME PRIVATE PLACEMENT PAPERWORK WAS FILED FOR THE APRIL 1992 SALE OF THEME PARTNERS, A LIMITED PARTNERSHIP. Initiated By: NEBRASKA Date Initiated: 12/01/1994 Docket/Case Number: NONE

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/01/1994 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DAIN BOSWORTH SIGNED A CONSENT ORDER AND PAID A $1,000.00 FINE. i Disclosure 315 of 336 Reporting Source: Firm Current Status: Final Allegations: THE STATE ALLEGED THAT DAIN BOSWORTH IMPROPERLY ADVISED AN AGENT WITH A NON-RESIDENT MINNESOTA LIFE INSURANCE LICENSE THAT HE WAS NOT REQUIRED TO COMPLETE THE STATE'S REQUIREMENT FOR CONTINUING EDUCATION. Initiated By: MINNESOTA COMMISSIONER OF COMMERCE Date Initiated: 08/26/1997 Docket/Case Number: IN9702523

Principal Product Type: Insurance Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 542 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 09/09/1997 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: DAIN BOSWORTH, INC. SIGNED AN ORDER WHEREBY ITS INSURANCE AGENCY WAS CENSURED AND THE FIRM PAID A CIVIL PENALTY OF $1,000.00. Firm Statement THE FIRM INADVERTENTLY GAVE INCORRECT ADVICE WITH RESPECT TO RECIPROCITY OF CONTINUING EDUCATION TO ONE OF ITS AGENTS CAUSING HIM TO MISREPRESENT ON HIS LICENSE THAT HE HAD COMPLETED THE REQUIREMENTS FOR HIS NON-RESIDENT LICENSE. i Disclosure 316 of 336 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF NORTH DAKOTA ALLEGED THAT THE FIRM MAY HAVE VIOLATED THE ND SECURITIES ACT BY CONDUCTING INVESTMENT ADVISORY BUSINESS WITH THREE ND RESIDENTS BEFORE BEING PROPERLY REGISTERED AN AN INVESTMENT ADVISOR. Initiated By: NORTH DAKOTA Date Initiated: 10/01/1996 Docket/Case Number: NONE

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/10/1996 Sanctions Ordered: Monetary/Fine $3,000.00 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 543 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING TO OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO A CONSENT ORDER AND PAID A $3,000.00 FINE. i Disclosure 317 of 336 Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATION OF NASD RULES PERTAINING TO TRADE REPORTING, LIMIT ORDER PROTECTION, AND WRITTEN SUPERVISORY PROCEDURES. NO SPECIFIC DAMAGES OR CLAIMS WERE STATED OR ALLEGED. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. MARKET REGULAT Date Initiated: 09/04/1997 Docket/Case Number: NO. CNS970028

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

Resolution: Settled Resolution Date: 07/18/1998 Sanctions Ordered: Monetary/Fine $8,000.00 Other Sanctions Ordered: THE FIRM WAS ALSO ASSESSED COSTS OF $1698.90. Sanction Details: THE FIRM WAS FINED $8,000.00 AND ALSO ASSESSED COSTS OF $1698.90. Firm Statement THESE ALLEGATIONS AROSE FROM A 1996 TRADING AND MARKET MAKING EXAMINATION OF DAIN BOSWORTH INC. THIS OCCURRENCE SHOULD BE REPORTABLE UNDER QUESTION 11E2 i Disclosure 318 of 336 Reporting Source: Firm

Current Status: Final Allegations: THE COMPLAINT ALLEGED THAT THE MILWAUKEE COMPANY (MERGED WITH DAIN BOSWORTH ON 10/1988) AND RICHARD BRILLAULT CONDUCTED AN ALL OR NONE OFFERING IN CONTRAVENTION OF SEC RULES 15C2-4 AND 10B-9. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. BUS CONDUCT CO Date Initiated: 10/01/1988 Docket/Case Number: COMPLAINT CHI-756

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

Resolution: Settled Resolution Date: 10/03/1989 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: RESPONDENT RICHARD BRILLAULT WAS ALSO CENSURED. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT ACCEPTED A FINE OF $5,000.00 FOR THE MILWAUKEE COMPANY AND A CENSURE OF RICHARD BRILLAULT. i Disclosure 319 of 336 Reporting Source: Firm Current Status: Final Allegations: COMPLAINT #388 WAS FILED AGAINST DAIN KLAMAN & QUAIL INC (LATER KNOWN AS DAIN BOSWORTH) IN 1970. WE NO LONGER HAVE POSSESSION OF FILES PERTAINING TO THEIR COMPLAINT. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/20/1970 Docket/Case Number: COMPLAINT 388

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

Resolution: Settled Resolution Date: 06/20/1971 Sanctions Ordered: Censure Monetary/Fine $6,000.00 Other Sanctions Ordered: ALSO PAID ASSESSED COSTS OF $535.14. Sanction Details: THE NASD CENSURED THE DAIN KALMAN & QUAIL, INC., FINED THE FIRM $6,000.00 AND ASSESSED COSTS OF $535.14. Firm Statement THE OCCURRENCE SHOULD BE REPORTABLE UNDER QUESTION 11E2. i Disclosure 320 of 336 Reporting Source: Firm Current Status: Final Allegations: IT WAS ALLEGED THAT DAIN BOSWORTH FAILED TO ADEQUATELY SUPERVISE A FORMER BRANCH MANAGER (RONALD DUNLAP) AND A FORMER SALESPERSON (LUCILLE ARENDT)RELATING TO TRANSACTIONS IN A CUSTOMER ACCOUNT. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. DISTRICT 3 Date Initiated: 06/01/1991 Docket/Case Number: COMPLAINT NO. C3B900004

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

Resolution Date: 06/12/1991 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: RESPONDENT DUNLAP WAS CENSURED, FINED $7,500.00 AND SUSPENDED FROM A GENERAL PRINCIPAL CAPACITY FOR ONE YEAR. ARENDT WAS CENSURED, FINED $25,000.00 AND BARRED FROM ASSOCIATING WITH AN NASD MEMBER IN ANY CAPACITY. Firm Statement THIS OCCURRENCE SHOULD BE REPORTABLE UNDER QUESTION 11E2. i Disclosure 321 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEDGED THAT RAUSCHER PIERCE REFSNES, INC. SOLD SHARES OF A NEW ISSUE TO CLASSIFIED PERSONS AND FAILED TO REPORT THESE SALES ON THE NASD'S FREE-RIDING QUESTIONNAIRES. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. DISTRICT 6 Date Initiated: 04/01/1974 Docket/Case Number: UNKNOWN

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

Resolution: Settled Resolution Date: 04/11/1974 Sanctions Ordered: Monetary/Fine $4,000.00 Other Sanctions Ordered: Sanction Details: RPR WAS FINED $4000.00 AND CERTAIN EMPLOYEES WERE FINED LESSER AMOUNTS. Firm Statement THE OCCURRENCE SHOULD BE REPORTABLE UNDER QUESTION 11E2.

i Disclosure 322 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT RAUSCHER PIERCE REFSNES (RPR) VIOLATED MSRB RULES A-12)A) AND G-12(J), DELAYED SUBMISSION OF FREE-RIDING QUESTIONNAIRE AND FAILED TO REVIEW TWO OSJ OFFICES AT LEAST ANNUALLY. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 08/30/1988 Docket/Case Number: TEX-601-AWC

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

Resolution: Settled Resolution Date: 08/30/1988 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: RAUSCHER PIERCE REFSNES, INC. WAS CENSURED AND FINED $7,500.00. Firm Statement THIS OCCURRENCE SHOULD BE REPORTABLE UNDER QUESTION 11E2. i Disclosure 323 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED VIOLATIONS OF MSRB RULES A13(A), G12(J)AND G-2. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/01/1985 Docket/Case Number: COMPLAINT TEX-441-AWC ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 548 www.finra.org/brokercheck User Guidance

Docket/Case Number: COMPLAINT TEX-441-AWC

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

Resolution: Settled Resolution Date: 04/23/1987 Sanctions Ordered: Censure Monetary/Fine $12,500.00 Other Sanctions Ordered: Sanction Details: RAUSCHER PIERCE REFSNES WAS CENSURED AND FINED $12,500.00. Firm Statement RAUSCHER PIERCE REFSNES WAS CENSURED AND FINED $12,500.00. THIS OCCURRENCE SHOULD BE REPORTABLE UNDER QUESTION 11E2. i Disclosure 324 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT THE FIRM AND TWO BRANCH MANAGERS FAILED TO HAVE ADEQUATE SUPERVISORY PROCEDURES IN PLACE WITH RESPECT TO SALES OF HOT ISSUES TO RESTRICTED PERSONS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. DISTRICT 4 Date Initiated: 12/01/1994 Docket/Case Number: AWC C04950024

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/04/1995 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AND THE TWO MANAGERS ENTERED INTO AN AWC IN WHICH THEY WERE CENSURED AND FINED $5000.00, JOINTLY AND SEVERALLY. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AND THE TWO MANAGERS ENTERED INTO AN AWC IN WHICH THEY WERE CENSURED AND FINED $5000.00, JOINTLY AND SEVERALLY. THIS OCCURRENCE SHOULD BE REPORTABLE UNDER QUESTION 11E2. i Disclosure 325 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD MARKET SURVEILLANCE COMMITTEE ALLEGED VIOLATIONS OF SOES RULES AND FAILURE TO MAINTAIN WRITTEN PROCEDURES. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/01/1988 Docket/Case Number: MC-786 AWC

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

Resolution: Settled Resolution Date: 06/15/1989 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: RAUSCHER PIERCE REFSNES WAS FINED $5000.00. Firm Statement RAUSCHER PIERCE REFSNES WAS FINED $5000.00. THIS OCCURRENCE SHOULD BE REPORTABLE UNDER QUESTION 11E2. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 550 www.finra.org/brokercheck User Guidance

i Disclosure 326 of 336 Reporting Source: Firm Current Status: Final Allegations: FAILURE TO MAKE A BONAFIDE PUBLIC DISTRIBUTION. RAUSCHER PIERCE REFSNES, INC. (RPR) HELD 500 SHARES OF AN OFFERING OF 4,125,000 SHARES OF CLUB CAR, INC., IN AN INVENTORY ACCOUNT UNTIL AFTER THE INITIATION OF TRADING. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/11/1995 Docket/Case Number: C06940041

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: 01/11/1995 Sanctions Ordered: Monetary/Fine $4,000.00 Other Sanctions Ordered: Sanction Details: AN ADMIMISSION, WAIVER AND CONSENT WAS EXECUTED UNDER WHICH RPR PAID A $4,000.00 FINE. Firm Statement RPR HELD 500 SHARES OF CLUB CAR, INC. OUT OF AN OFFERING OF 4,125,000 SHARES IN AN INVENTORY ACCOUNT FOR A PERIOD OF 2 WEEKS AFTER THE OFFERING. THE OFFERING PRICE WAS $17.50 PER SHARE. ON THE FIRST DAY OF TRADING, OCTOBER 18, 1993, THE PRICE REACHED $20.50 PER SHARE. RPR SOLD THE 500 SHARES IT ISSUED ON NOVEMBER 2, 1993 AT $17.00 PER SHARE. THIS OCCURRENCE SHOULD BE REPORTABLE UNDER QUESTION 11E2. i Disclosure 327 of 336 Reporting Source: Firm Current Status: Final ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 551 www.finra.org/brokercheck User Guidance

Allegations: RAUSCHER PIERCE REFSNES, INC. (RPR)FAILED TO MAKE A BONAFIDE PUBLIC DISTRIBUTION IN CONNECTION WITH A PUBLIC OFFERING OF STB SYSTEMS, INC. RPR SOLD 3500 SHARES TO TWO PERSONS WHO WERE RESTRICTD UNDER THE INTERPRETATION VIOLATION OF ARTICLE III SECTION 1, OF THE ASSOCIATION'S RULES OF FAIR PRACTICE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC Date Initiated: 02/14/1995 Docket/Case Number: C0690013

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

Resolution: Settled Resolution Date: 08/26/1996 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: RPR WAS CENSURED AND FINED $7,500.00. Firm Statement THIS OCCURRENCE IS REPORTABLE UNDER QUESTION 11E2. i Disclosure 328 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT RPRCC, A DIVISION OF DAIN RAUSCHER, EXECUTED 2 SHORT SALES ON MAY 31, 1996 FOR BOCA RESEARCH, AN NASD NMS SECURITY, AT OR BELOW THE INSIDE BID, WHEN THE CURRENT INSIDE BID WAS BELOW THE PRECEDING INSIDE BID. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC Date Initiated: 11/01/1997 Docket/Case Number: CMS980028 AWC

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: 03/20/1998 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: AN UNDERTAKING TO IMMEDIATELY REVISE WRITTEN SUPERVISORY PROCEDURES RELATING TO SHORT SALES. Firm Statement WITHOUT ADMITTING OR DENYING ALLEGATIONS, THE FIRM SIGNED AN AWC CONSENTING TO A $2,000.00 FINE AND AN UNDERTAKING TO IMMEDIATELY REVISE WRITTEN SUPERVISORY PROCEDURES RELATING TO SHORT SALES. THIS OCCURRENCE IS REPORTABLE UNDER QUESTION 11E2. i Disclosure 329 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASDR ALLEGED THAT ON MAY 31, 1996, RPRCS, A DIVISION OF RAUSCHER PIERCE REFSNES, EXECUTED 2 SHORT SALE TRANSACTIONS IN A NASDAQ SECURITY AT OR BELOW THE INSIDE BID, WHEN THE CURRENT INSIDE BID WAS BELOW THE PRECEDING INSIDE BID, VIOLATING RULE 3350. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS REGULATION, INC Date Initiated: 08/28/1997 Docket/Case Number: SS 1997015 AWC

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: 11/18/1997 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: RPRCS AGREED TO UNDERTAKE TO IMMEDIATELY REVISE ITS SHORT SALE RULE SUPERVISORY PROCEDURES. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEDGED VIOLATIONS, RPRCS SIGNED AN AWC IN WHICH IT CONSENTED TO A $2000.00 FINE AND AN UNDERTAKING TO IMMEDIATLY REVISE ITS SHORT SALE RULE SUPERVISORY PROCEDURES. i Disclosure 330 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT MICHAEL O'BRIEN, A FORMER EMPLOYEE OF DAIN BOSWORTH (NOW KNOWN AS DAIN RAUSCHER) EFFECTED UNSUITABLE TRANSACTIONS IN 3 CUSTOMER ACCOUNTS, IN VIOLATION OF ARTICLE III, SECTIONS 1 & 2, AND THAT LOUIS BULBA FAILED TO SUPERVISE HIM. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC Date Initiated: 10/03/1989 Docket/Case Number: CHI-118

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

Resolution: Settled Resolution Date: 10/03/1989 Sanctions Ordered: Censure Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM, O'BRIEN AND BULBA ACCEPTED CENSURES. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 554 www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM, O'BRIEN AND BULBA ACCEPTED CENSURES. Firm Statement UPON A RECENT REIVEW OF THE CRD RECORDS FOR DAIN RAUSCHER, IT WAS NOTED THAT THIS INCIDENT WAS NOT TRANSFERRED FROM DAIN BOSWORTH'S OLD CRD RECORD (#7600), WHEN IT MERGED WITH ITS AFFILIATES IN EARLY 1998. PLEASE ADD THIS INCIDENT TO DICLOSURE RECORD FOR BD #31194. i Disclosure 331 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT DAIN BOSWORTH (NOW KNOW AS DAIN RAUSCHER) VIOLATED THE NASD RULES OF FAIR PRACTICE WITH REGARD TO FREE-RIDING AND WITHHOLDING BY SELLING 100 SHARES OF LSI LIGHTING SYSTEMS, INC. TO A TREASURER OF AN INSURANCE COMPANY. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC Date Initiated: 01/08/1986 Docket/Case Number: CHI-877 AWC

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: 01/08/1986 Sanctions Ordered: Monetary/Fine $275.00 Other Sanctions Ordered: Sanction Details: DAIN BOSWORTH SIGNED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC)IN WHICH IT AGREED TO A CENSURE OF THE FIRM AND ONE OF ITS REGISTERED REPS AND A $275.00 FINE. Firm Statement UPON A RECENT REIVEW OF THE CRD RECORDS FOR DAIN RAUSCHER, IT WAS NOTED THAT THIS INCIDENT WAS NOT TRANSFERRED FROM DAIN BOSWORTH'S OLD CRD RECORD (#7600), WHEN IT MERGED WITH ITS AFFILIATES IN EARLY 1998. PLEASE ADD THIS INCIDENT TO DICLOSURE RECORD FOR BD #31194. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 555 www.finra.org/brokercheck UPON A RECENT REIVEW OF THE CRD RECORDS FOR DAIN RAUSCHER, IT User Guidance WAS NOTED THAT THIS INCIDENT WAS NOT TRANSFERRED FROM DAIN BOSWORTH'S OLD CRD RECORD (#7600), WHEN IT MERGED WITH ITS AFFILIATES IN EARLY 1998. PLEASE ADD THIS INCIDENT TO DICLOSURE RECORD FOR BD #31194. i Disclosure 332 of 336 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT DAIN BOSWORTH (NOW KNOWN AS DAIN RAUSCHER) VIOLATED THE NASD RULES OF FAIR PRACTICE BY SELLING 100 SHARES OF DETECTOR ELECTRONICS CORPORATION, A HOT ISSUE, TO AN EMPLOYEE OF ANOTHER NASD FIRM. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC DBCC, DISTRICT 8 Date Initiated: 05/31/1983 Docket/Case Number: CHI 735 AWC

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: 05/31/1983 Sanctions Ordered: Monetary/Fine $400.00 Other Sanctions Ordered: Sanction Details: NASD IMPOSED A FINE OF $400.00. Firm Statement UPON A REVIEW OF DAIN RAUSCHER, INC.CRD RECORDS, IT WAS NOTED THAT THIS INCIDENT WAS NOT TRANSFERRED FROM DAIN BOSWORTH (7600) WHEN IT MERGED WITH ITS AFFILIATES IN EARLY 1998. i Disclosure 333 of 336 Reporting Source: Firm Current Status: Final Allegations: THE SEC ALLEGES VIOLATIONS OF CERTAIN ANTIFRAUD PROVISIONS OF THE SECURITIES ACT OF 1933 AND THE SECURITIES EXCHANGE ACT OF 1934, IN CONNECTION WITH 12 ONE-YEAR TAXABLE NOTE OFFERINGS AND ONE POOLED TAX AND REVENUE ANTICIPATED NOTE OFFERING. ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 556 www.finra.org/brokercheck User Guidance THE SEC ALLEGES VIOLATIONS OF CERTAIN ANTIFRAUD PROVISIONS OF THE SECURITIES ACT OF 1933 AND THE SECURITIES EXCHANGE ACT OF 1934, IN CONNECTION WITH 12 ONE-YEAR TAXABLE NOTE OFFERINGS AND ONE POOLED TAX AND REVENUE ANTICIPATED NOTE OFFERING. Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION Date Initiated: 08/03/1998 Docket/Case Number: SACV 98-639 LHM

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

Resolution: Settled Resolution Date: 08/13/2002 Sanctions Ordered: Monetary/Fine $500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: FINE OF $500,000 WAS PAID ON 9/13/02 BY FIRM. Firm Statement THE OFFERINGS WERE MADE BY CERTAIN SCHOOL DISTRICTS AND CITIES DURING 1993 AND 1994 IN ORANGE COUNTY, CALIFORNIA AND THE PROCEEDINGS WERE INVESTED IN THE ORANGE COUNTY INVESTMENT POOL. RAUSCHER PIERCE REFENES ACTED EITHER AS UNDERWRITER OR FINANCIAL ADVISOR IN CONNECTION WITH EACH OF THESE TRANSACTIONS. i Disclosure 334 of 336 Reporting Source: Regulator Current Status: Final Allegations: 10/13/1999JJM -- RESPONDENT MEMBER EXECUTED SHORT SALE TRANSACTIONS IN CERTAIN SECURITIES AND FAILED TO REPORT EACH OF THESE TRANSACTIONS TO ACT WITH A SHORT SALE INDICATOR. (NASD RULE 6130) Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 09/28/1999 Docket/Case Number: CMS990120

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: 09/28/1999 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: $5,000.00 FINE; CENSURE Regulator Statement 04-05-00, $5,000 PAID 10/21/99, INVOICE #99-MS-849 i Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGES THE FIRM EXECUTED SHORT SALE TRANSACTIONS IN CERTAIN SECURITIES AND FAILED TO REPORT EACH OF THESE TRANSACTIONS TO ACT WITH A SHORT SALE INDICATOR. Initiated By: NASD Date Initiated: 09/28/1999 Docket/Case Number: NASD CMS990120

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/28/1999 Sanctions Ordered: Censure Monetary/Fine $5,000.00

Other Sanctions Ordered: Sanction Details: THE FIRM AGREED TO AN ACCEPTANCE, WAIVER, AND CONSENT AND A FINE OF $5,000.00 i Disclosure 335 of 336 Reporting Source: Regulator Current Status: Final Allegations: 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 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; FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET SO THAT THE RESULTANT PRICE TO THE CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER THE PREVAILING MARKET CONDITIONS; FAILED TO EXECUTE A CUSTOMER'S ORDER IN A TIMELY MANNER. (SEC RULE 11AC1-4, NASD RULES 2110, 2320)

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/26/1999 Docket/Case Number: CMS990067

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Restitution Sought: Other Sanction(s)/Relief $2,000.00 FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/26/1999 Sanctions Ordered: Monetary/Fine $2,000.00 Disgorgement/Restitution Other Sanctions Ordered:

Sanction Details: $56.25 RESTITUTION PLUS INTEREST; $2,000.00 FINE Regulator Statement 02-04-00, $2,000 PAID ON 8/30/99. RESTITUTION OF $70.20 MADE TO CUSTOMER, INVOICE #99-MS-690 i Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGES DAIN FAILED TO DISPLAY IMMEDIATELY 6 CUSTOMER LIMIT ORDERS, FAILED TO USE DUE DILIGENCE TO ASCETAIN THE BEST INTER-DEALER MARKET FOR SHARES SOLD SO THE RESULTANT PRICE TO CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS, AND FAILED TO EXECUTE A CUSTOMER'S ORDER IN A TIMELY MANNER.

Initiated By: NASD REGULATION, INC. Date Initiated: 04/27/1999 Docket/Case Number: NO. CMS990067 AWC

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/23/1999 Sanctions Ordered: Monetary/Fine $2,000.00 Disgorgement/Restitution ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 560 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $2,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING ALLEGATIONS, DAIN AGREED TO ACCEPT THE AWC AND A FINE OF $2,000.00 PLUS PAYING RESTITUTION TO THE CUSTOMER OF $56.25 PLUS INTEREST. i Disclosure 336 of 336 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULES G-8 AND G-36 - RESPONDENT MEMBER FAILED TO TIMELY FILE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") FORM G-36 IN PRIMARY OFFERINGS AND AN ADVANCE REFUNDING FOR WHICH IT ACTED AS UNDERWRITER; AND, INCORRECTLY REFLECTED THE DATE OF FINAL AGREEMENT TO PURCHASE, OFFER OR SELL SECURITIES ON MSRB FORM G-36 (OS) FILINGS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/17/1999 Docket/Case Number: C04990009

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: 03/17/1999 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 $3,000.00 Other Sanctions Ordered:

Sanction Details: THE FIRM IS CENSURED AND FINED $3,000. i Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT THE FIRM FAILED TO TIMELY FILE THE MUNICIPAL SECURITIES RULEMAKING(MSRB) FORM G-36 IN AT LEAST 19 PRIMARY OFFERINGS AND ONE ADVANCE FUNDING FOR WHICH THE FIRM ACTED AS AN UNDERWRITER AND INCORRECTLY REFLECTED THE FINAL AGREEMENT TO PURCHASE, OFFER, OR SELL SECURITIES ON 36 FORM G- 36 FILINGS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. DISTRICT 4 Date Initiated: 03/17/1999 Docket/Case Number: AWC C04990009

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

Resolution: Settled Resolution Date: 03/17/1999 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF $3,000.00. Firm Statement THIS OCCURRENCE IS REPORTABLE UNDER QUESTION 11E2.

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 2 Reporting Source: Regulator Current Status: Final Allegations: SEC LITIGATION RELEASE 21066, JUNE 3, 2009: SECTION 15(C) OF THE EXCHANGE ACT OF 1934 - THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT IT HAS FILED COMPLAINTS AGAINST RBC CAPITAL MARKETS CORPORATION AND OTHER FIRMS ALLEGING THAT THE FIRMS MISLED INVESTORS REGARDING THE LIQUIDITY RISKS ASSOCIATED WITH AUCTION RATE SECURITIES (ARS) THAT THEY UNDERWROTE, MARKETED OR SOLD. ACCORDING TO THE COMMISSION'S COMPLAINTS, RBC AND THE OTHER DEFENDANTS MISREPRESENTED TO CERTAIN CUSTOMERS THAT ARS WERE SAFE, HIGHLY LIQUID INVESTMENTS THAT WERE COMPARABLE TO MONEY MARKETS. ACCORDING TO THE COMPLAINTS, IN LATE 2007 AND EARLY 2008, THE FIRMS KNEW THAT THE ARS MARKET WAS DETERIORATING, CAUSING THE FIRMS TO HAVE TO PURCHASE ADDITIONAL INVENTORY TO PREVENT FAILED AUCTIONS. AT THE SAME TIME, HOWEVER, THE FIRMS KNEW THAT THEIR ABILITY TO SUPPORT AUCTIONS BY PURCHASING MORE ARS HAD BEEN REDUCED, AS THE CREDIT CRISIS STRESSED THE FIRMS' BALANCE SHEETS. THE COMPLAINTS ALLEGE THAT RBC AND OTHER DEFENDANTS FAILED TO MAKE THEIR CUSTOMERS AWARE OF THESE RISKS. IN MID-FEBRUARY 2008, ACCORDING TO THE COMPLAINTS, RBC AND THE OTHER DEFENDANTS STOP SUPPORTING THE ARS MARKET, LEAVING CUSTOMERS HOLDING BILLIONS IN ILLIQUID ARS. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Court Details: UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, SEC V. RBC CAPITAL MARKETS CORPORATION, CIVIL ACTION NO. 09-CIV-5172 (S.D.N.Y. JUNE 3, 2009) Date Court Action Filed: 06/03/2009 Principal Product Type: Other Other Product Types: AUCTION RATE SECURITIES Relief Sought: Injunction Other Relief Sought: PERMANENT INJUNCTION, FINANCIAL PENALTY Resolution: Judgment Rendered Resolution Date: 06/09/2009 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 563 www.finra.org/brokercheck User Guidance

Resolution Date: 06/09/2009 Sanctions Ordered or Relief Cease and Desist/Injunction Granted: Other Sanctions: UNDERTAKINGS: THE FIRM WILL OFFER TO PURCHASE ARS AT PAR FROM INDIVIDUALS, CHARITIES, AND SMALL OR MEDIUM BUSINESSES THAT PURCHASED THOSE ARS FROM THE FIRM, EVEN IF THOSE CUSTOMERS MOVED THEIR ACCOUNTS. THE FIRM WILL USE ITS BEST EFFORTS TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL AND OTHER CUSTOMERS, INCLUDING, BUT NOT LIMITED TO, FACILITATING ISSUER REDEMPTIONS, RESTRUCTURINGS, AND OTHER REASONABLE MEANS, AND WILL NOT TAKE ADVANTAGE OF LIQUIDITY SOLUTIONS FOR ITS OWN INVENTORY BEFORE MAKING THOSE SOLUTIONS AVAILABLE TO THESE CUSTOMERS. THE FIRM WILL PAY ELIGIBLE CUSTOMERS WHO SOLD THEIR ARS BELOW PAR THE DIFFERENCE BETWEEN PAR AND THE SALE PRICE OF THE ARS. Sanction Details: SEC LITIGATION RELEASE 21066, JUNE 3, 2009: WITHOUT ADMITTING OR DENYING THE COMMISSION'S ALLEGATIONS, THE FIRM AND OTHER DEFENDANTS CONSENTED TO SETTLE THE ACTIONS. THESE SETTLEMENTS, COMBINED, WILL PROVIDE OR ALREADY HAVE PROVIDED NEARLY $6.7 BILLION TO APPROXIMATELY 9,600 CUSTOMERS WHO INVESTED IN AUCTION RATE SECURITIES BEFORE THE MARKET FOR THOSE SECURITIES FROZE IN FEBRUARY 2008. RBC AGREED TO BE PERMANENTLY ENJOINED FROM VIOLATING THE PROVISIONS OF SECTION 15(C) OF THE EXCHANGE ACT OF 1934, WHICH PROHIBIT THE USE OF MANIPULATIVE OR DECEPTIVE DEVICES BY BROKER-DEALERS AND TO COMPLY WITH A NUMBER OF UNDERTAKINGS. ON JUNE 9, 2009, THE JUDGE FOR THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK RENDERED HER JUDGMENT THAT RBC CAPITAL MARKETS IS PERMANENTLY ENJOINED FROM VIOLATING SECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934 AND THE COURT SHALL DETERMINE WHETHER A CIVIL PENALTY IS APPROPRIATE AND THE AMOUNT. THE JUDGE FURTHER ORDERED THAT THE FIRM SHALL COMPLY WITH ALL OF THE UNDERTAKINGS AND AGREEMENTS AND THE COURT SHALL RETAIN JURISDICTION OF THIS MATTER FOR THE PURPOSES OF ENFORCING THE TERMS OF THIS JUDGMENT. Regulator Statement SEC LITIGATION RELEASE 21585, JUNE 30, 2010: THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT RBC CAPITAL MARKETS THAT SETTLED THE COMMISSION'S AUCTION RATE SECURITIES (ARS) CHARGES AGAINST IT HAS SATISFIED ITS OBLIGATIONS UNDER THE SETTLEMENT. RBC CAPITAL MARKETS WAS REQUIRED TO OFFER TO PURCHASE ARS AT PAR FROM INDIVIDUAL, CHARITABLE, AND SMALL BUSINESS CUSTOMERS. NEARLY 100% OF THESE CUSTOMERS HAVE ACCEPTED THE OFFER. RBC PURCHASED ARS FROM ITS ELIGIBLE CUSTOMERS IN THE AMOUNT OF $759 MILLION. THE SETTLEMENT ALSO REQUIRED RBC TO USE "BEST ©2021 FINRA. All rights reserved. Report aboutEFFORTS" RBC CAPITAL TO PROVIDE MARKETS, LLCLIQUIDITY OPPORTUNITIES TO INSTITUTIONAL 564 CUSTOMERS. TO ASSIST IN ITS ANALYSIS OF WHETHER THE FIRM HAD IN FACT USED "BEST EFFORTS," THE SEC RETAINED AN OUTSIDE EXPERT WITH EXTENSIVE KNOWLEDGE OF THE ARS MARKET. FROM THE TIME OF THE ARS MARKET FAILURE IN FEBRUARY 2008 THROUGH MAY 31, 2010, RBC INSTITUTIONAL CUSTOMER HOLDINGS WERE REDUCED BY $3.2 BILLION OR 48% (FROM $6.6 BILLION TO $3.4 BILLION). IN COMPLIANCE WITH ITS OBLIGATIONS, RBC IMPLEMENTED BROAD-BASED LIQUIDITY MEASURES FOR ITS INSTITUTIONAL INVESTORS. RBC ALSO MET ITS OTHER SETTLEMENT OBLIGATIONS, INCLUDING COMPENSATING INVESTORS WHO SOLD ARS BELOW PAR, REIMBURSING INVESTORS FOR EXCESS INTEREST COSTS ASSOCIATED WITH LOANS TAKEN OUT DUE TO ARS ILLIQUIDITY, AND PARTICIPATING IN SPECIAL ARBITRATION PROCEEDINGS BEFORE THE FINANCIAL INDUSTRY REGULATORY AUTHORITY. THE FIRM ALSO SUBMITTED PERIODIC REPORTS TO, AND MET QUARTERLY WITH, SEC STAFF REGARDING ITS PROGRESS ON MEETING THE SETTLEMENT OBLIGATIONS. TO ENSURE COMPLIANCE WITH THE TERMS, THE SETTLEMENT PROVIDED FOR A POTENTIAL DEFERRED PENALTY IF THE FIRM DID NOT MEET ITS SETTLEMENT OBLIGATIONS. THE SEC HAS DETERMINED THAT BASED ON THE FIRM'S COMPLIANCE WITH THE SETTLEMENT, AS WELL AS OTHER FACTORS, NO PENALTIES WILL BE PURSUED. SEC LITIGATION RELEASE 21585, JUNE 30, 2010: THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT RBC CAPITAL MARKETS THAT SETTLED THE COMMISSION'S AUCTION RATE SECURITIES (ARS) CHARGES AGAINST IT HAS SATISFIED ITS OBLIGATIONS UNDER THE SETTLEMENT. www.finra.org/brokercheck RBC CAPITAL MARKETS WAS REQUIRED TO OFFER TO PURCHASE ARS AT User Guidance PAR FROM INDIVIDUAL, CHARITABLE, AND SMALL BUSINESS CUSTOMERS. NEARLY 100% OF THESE CUSTOMERS HAVE ACCEPTED THE OFFER. RBC PURCHASED ARS FROM ITS ELIGIBLE CUSTOMERS IN THE AMOUNT OF $759 MILLION. THE SETTLEMENT ALSO REQUIRED RBC TO USE "BEST EFFORTS" TO PROVIDE LIQUIDITY OPPORTUNITIES TO INSTITUTIONAL CUSTOMERS. TO ASSIST IN ITS ANALYSIS OF WHETHER THE FIRM HAD IN FACT USED "BEST EFFORTS," THE SEC RETAINED AN OUTSIDE EXPERT WITH EXTENSIVE KNOWLEDGE OF THE ARS MARKET. FROM THE TIME OF THE ARS MARKET FAILURE IN FEBRUARY 2008 THROUGH MAY 31, 2010, RBC INSTITUTIONAL CUSTOMER HOLDINGS WERE REDUCED BY $3.2 BILLION OR 48% (FROM $6.6 BILLION TO $3.4 BILLION). IN COMPLIANCE WITH ITS OBLIGATIONS, RBC IMPLEMENTED BROAD-BASED LIQUIDITY MEASURES FOR ITS INSTITUTIONAL INVESTORS. RBC ALSO MET ITS OTHER SETTLEMENT OBLIGATIONS, INCLUDING COMPENSATING INVESTORS WHO SOLD ARS BELOW PAR, REIMBURSING INVESTORS FOR EXCESS INTEREST COSTS ASSOCIATED WITH LOANS TAKEN OUT DUE TO ARS ILLIQUIDITY, AND PARTICIPATING IN SPECIAL ARBITRATION PROCEEDINGS BEFORE THE FINANCIAL INDUSTRY REGULATORY AUTHORITY. THE FIRM ALSO SUBMITTED PERIODIC REPORTS TO, AND MET QUARTERLY WITH, SEC STAFF REGARDING ITS PROGRESS ON MEETING THE SETTLEMENT OBLIGATIONS. TO ENSURE COMPLIANCE WITH THE TERMS, THE SETTLEMENT PROVIDED FOR A POTENTIAL DEFERRED PENALTY IF THE FIRM DID NOT MEET ITS SETTLEMENT OBLIGATIONS. THE SEC HAS DETERMINED THAT BASED ON THE FIRM'S COMPLIANCE WITH THE SETTLEMENT, AS WELL AS OTHER FACTORS, NO PENALTIES WILL BE PURSUED. i Reporting Source: Firm Current Status: Final Allegations: SEC LITIGATION RELEASE 21066, JUNE 3, 2009: SECTION 15(C) OF THE EXCHANGE ACT OF 1934 - THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT IT HAS FILED COMPLAINTS AGAINST RBC CAPITAL MARKETS CORPORATION AND OTHER FIRMS ALLEGING THAT THE FIRMS MISLED INVESTORS REGARDING THE LIQUIDITY RISKS ASSOCIATED WITH AUCTION RATE SECURITIES (ARS) THAT THEY UNDERWROTE, MARKETED OR SOLD. ACCORDING TO THE COMMISSION'S COMPLAINTS, RBC AND THE OTHER DEFENDANTS MISREPRESENTED TO CERTAIN CUSTOMERS THAT ARS WERE SAFE, HIGHLY LIQUID INVESTMENTS THAT WERE COMPARABLE TO MONEY MARKETS. ACCORDING TO THE COMPLAINTS, IN LATE 2007 AND EARLY 2008, THE FIRMS KNEW THAT THE ARS MARKET WAS DETERIORATING, CAUSING THE FIRMS TO HAVE TO PURCHASE ADDITIONAL INVENTORY TO PREVENT FAILED AUCTIONS. AT THE SAME TIME, HOWEVER, THE FIRMS KNEW THAT THEIR ABILITY TO SUPPORT AUCTIONS BY PURCHASING MORE ARS HAD BEEN REDUCED, AS THE CREDIT CRISIS STRESSED THE FIRMS' BALANCE SHEETS. THE COMPLAINTS ALLEGE THAT RBC AND OTHER DEFENDANTS FAILED TO MAKE THEIR CUSTOMERS AWARE OF THESE RISKS. IN MID-FEBRUARY ©2021 FINRA. All rights reserved. Report about2008, RBC ACCORDING CAPITAL MARKETS, TO THE LLC COMPLAINTS, RBC AND THE OTHER 565 DEFENDANTS STOP SUPPORTING THE ARS MARKET, LEAVING CUSTOMERS HOLDING BILLIONS IN ILLIQUID ARS. SEC LITIGATION RELEASE 21066, JUNE 3, 2009: SECTION 15(C) OF THE EXCHANGE ACT OF 1934 - THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT IT HAS FILED COMPLAINTS AGAINST RBC CAPITAL MARKETS CORPORATION AND OTHER FIRMS ALLEGING THAT THE FIRMS MISLED INVESTORS REGARDING THE LIQUIDITY RISKS ASSOCIATED WITH AUCTION RATE SECURITIES (ARS) THAT THEY UNDERWROTE, MARKETED OR SOLD. ACCORDING TO THE COMMISSION'S COMPLAINTS, RBC AND THE OTHER DEFENDANTS MISREPRESENTED TO CERTAIN CUSTOMERS THAT ARS WERE SAFE, HIGHLY LIQUID INVESTMENTS THAT WERE COMPARABLE TO MONEY MARKETS. ACCORDING TO THE COMPLAINTS, IN LATE 2007 AND EARLY 2008, THE FIRMS KNEW THAT THE ARS MARKET WAS DETERIORATING, CAUSING THE FIRMS TO HAVE TO PURCHASE ADDITIONAL INVENTORY TO PREVENT FAILED AUCTIONS. AT THE SAME www.finra.org/brokercheck TIME, HOWEVER, THE FIRMS KNEW THAT THEIR ABILITY TO SUPPORT User Guidance AUCTIONS BY PURCHASING MORE ARS HAD BEEN REDUCED, AS THE CREDIT CRISIS STRESSED THE FIRMS' BALANCE SHEETS. THE COMPLAINTS ALLEGE THAT RBC AND OTHER DEFENDANTS FAILED TO MAKE THEIR CUSTOMERS AWARE OF THESE RISKS. IN MID-FEBRUARY 2008, ACCORDING TO THE COMPLAINTS, RBC AND THE OTHER DEFENDANTS STOP SUPPORTING THE ARS MARKET, LEAVING CUSTOMERS HOLDING BILLIONS IN ILLIQUID ARS. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Court Details: UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, SEC V. RBC CAPITAL MARKETS CORPORATION, CIVIL ACTION NO. 09-CIV-5172 (S.D.N.Y. JUNE 3, 2009) Date Court Action Filed: 06/03/2009 Principal Product Type: Other Other Product Types: AUCTION RATE SECURITIES Relief Sought: Injunction Other Relief Sought: PERMANET INJUNCTION, FINANCIAL PENALTY Resolution: Judgment Rendered Resolution Date: 06/09/2009 Sanctions Ordered or Relief Cease and Desist/Injunction Granted: Other Sanctions: UNDERTAKINGS: THE FIRM WILL OFFER TO PURCHASE ARS AT PAR FROM INDIVIDUALS, CHARITIES, AND SMALL OR MEDIUM BUSINESSES THAT PURCHASED THOSE ARS FROM THE FIRM, EVEN IF THOSE CUSTOMERS MOVED THEIR ACCOUNTS. THE FIRM WILL USE ITS BEST EFFORTS TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL AND OTHER CUSTOMERS, INCLUDING, BUT NOT LIMITED TO, FACILITATING ISSUER REDEMPTIONS, RESTRUCTURINGS, AND OTHER REASONABLE MEANS, AND WILL NOT TAKE ADVANTAGE OF LIQUIDITY SOLUTIONS FOR ITS OWN INVENTORY BEFORE MAKING THOSE SOLUTIONS AVAILABLE TO THESE CUSTOMERS. THE FIRM WILL PAY ELIGIBLE CUSTOMERS WHO SOLD THEIR ARS BELOW PAR THE DIFFERENCE BETWEEN PAR AND THE SALE PRICE OF THE ARS. Sanction Details: SEC LITIGATION RELEASE 21066, JUNE 3, 2009: WITHOUT ADMITTING OR DENYING THE COMMISSION'S ALLEGATIONS, THE FIRM AND OTHER DEFENDANTS CONSENTED TO SETTLE THE ACTIONS. THESE SETTLEMENTS, COMBINED, WILL PROVIDE OR ALREADY HAVE PROVIDED NEARLY $6.7 BILLION TO APPROXIMATELY 9,600 CUSTOMERS WHO INVESTED IN AUCTION RATE SECURITIES BEFORE THE MARKET FOR THOSE SECURITIES FROZE IN FEBRUARY 2008. RBC AGREED TO BE PERMANENTLY ENJOINED FROM VIOLATING THE PROVISIONS OF SECTION 15(C) OF THE EXCHANGE ACT OF 1934, WHICH PROHIBIT THE USE OF MANIPULATIVE OR DECEPTIVE DEVICES BY BROKER-DEALERS AND TO COMPLY WITH A NUMBER OF UNDERTAKINGS. ON JUNE 9, 2009, THE ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 566 JUDGE FOR THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK RENDERED HER JUDGMENT THAT RBC CAPITAL MARKETS IS PERMANENTLY ENJOINED FROM VIOLATING SECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934 AND THE COURT SHALL DETERMINE WHETHER A CIVIL PENALTY IS APPROPRIATE AND THE AMOUNT. THE JUDGE FURTHER ORDERED THAT THE FIRM SHALL COMPLY WITH ALL OF THE UNDERTAKINGS AND AGREEMENTS AND THE COURT SHALL RETAIN JURISDICTION OF THIS MATTER FOR THE PURPOSES OF ENFORCING THE TERMS OF THIS JUDGMENT. SEC LITIGATION RELEASE 21066, JUNE 3, 2009: WITHOUT ADMITTING OR DENYING THE COMMISSION'S ALLEGATIONS, THE FIRM AND OTHER DEFENDANTS CONSENTED TO SETTLE THE ACTIONS. THESE SETTLEMENTS, COMBINED, WILL PROVIDE OR ALREADY HAVE PROVIDED NEARLY $6.7 BILLION TO APPROXIMATELY 9,600 CUSTOMERS WHO INVESTED IN AUCTION RATE SECURITIES BEFORE THE MARKET FOR www.finra.org/brokercheck THOSE SECURITIES FROZE IN FEBRUARY 2008. RBC AGREED TO BE User Guidance PERMANENTLY ENJOINED FROM VIOLATING THE PROVISIONS OF SECTION 15(C) OF THE EXCHANGE ACT OF 1934, WHICH PROHIBIT THE USE OF MANIPULATIVE OR DECEPTIVE DEVICES BY BROKER-DEALERS AND TO COMPLY WITH A NUMBER OF UNDERTAKINGS. ON JUNE 9, 2009, THE JUDGE FOR THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK RENDERED HER JUDGMENT THAT RBC CAPITAL MARKETS IS PERMANENTLY ENJOINED FROM VIOLATING SECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934 AND THE COURT SHALL DETERMINE WHETHER A CIVIL PENALTY IS APPROPRIATE AND THE AMOUNT. THE JUDGE FURTHER ORDERED THAT THE FIRM SHALL COMPLY WITH ALL OF THE UNDERTAKINGS AND AGREEMENTS AND THE COURT SHALL RETAIN JURISDICTION OF THIS MATTER FOR THE PURPOSES OF ENFORCING THE TERMS OF THIS JUDGMENT. Firm Statement SEC LITIGATION RELEASE 21585, JUNE 30, 2010: THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT RBC CAPITAL MARKETS THAT SETTLED THE COMMISSION'S AUCTION RATE SECURITIES (ARS) CHARGES AGAINST IT HAS SATISFIED ITS OBLIGATIONS UNDER THE SETTLEMENT. RBC CAPITAL MARKETS WAS REQUIRED TO OFFER TO PURCHASE ARS AT PAR FROM INDIVIDUAL, CHARITABLE, AND SMALL BUSINESS CUSTOMERS. NEARLY 100% OF THESE CUSTOMERS HAVE ACCEPTED THE OFFER. RBC PURCHASED ARS FROM ITS ELIGIBLE CUSTOMERS IN THE AMOUNT OF $759 MILLION. THE SETTLEMENT ALSO REQUIRED RBC TO USE "BEST EFFORTS" TO PROVIDE LIQUIDITY OPPORTUNITIES TO INSTITUTIONAL CUSTOMERS. TO ASSIST IN ITS ANALYSIS OF WHETHER THE FIRM HAD IN FACT USED "BEST EFFORTS," THE SEC RETAINED AN OUTSIDE EXPERT WITH EXTENSIVE KNOWLEDGE OF THE ARS MARKET. FROM THE TIME OF THE ARS MARKET FAILURE IN FEBRUARY 2008 THROUGH MAY 31, 2010, RBC INSTITUTIONAL CUSTOMER HOLDINGS WERE REDUCED BY $3.2 BILLION OR 48% (FROM $6.6 BILLION TO $3.4 BILLION). IN COMPLIANCE WITH ITS OBLIGATIONS, RBC IMPLEMENTED BROAD-BASED LIQUIDITY MEASURES FOR ITS INSTITUTIONAL INVESTORS. RBC ALSO MET ITS OTHER SETTLEMENT OBLIGATIONS, INCLUDING COMPENSATING INVESTORS WHO SOLD ARS BELOW PAR, REIMBURSING INVESTORS FOR EXCESS INTEREST COSTS ASSOCIATED WITH LOANS TAKEN OUT DUE TO ARS ILLIQUIDITY, AND PARTICIPATING IN SPECIAL ARBITRATION PROCEEDINGS BEFORE THE FINANCIAL INDUSTRY REGULATORY AUTHORITY. THE FIRM ALSO SUBMITTED PERIODIC REPORTS TO, AND MET QUARTERLY WITH, SEC STAFF REGARDING ITS PROGRESS ON MEETING THE SETTLEMENT OBLIGATIONS. TO ENSURE COMPLIANCE WITH THE TERMS, THE SETTLEMENT PROVIDED FOR A POTENTIAL DEFERRED PENALTY IF THE FIRM DID NOT MEET ITS SETTLEMENT OBLIGATIONS. THE SEC HAS DETERMINED THAT BASED ON THE FIRM'S COMPLIANCE WITH THE SETTLEMENT, AS WELL AS OTHER FACTORS, NO PENALTIES WILL BE PURSUED. i Disclosure 2 of 2

Reporting Source: Firm Current Status: Final Allegations: PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: FRAUD IN CONNECTION WITH THE SALE TO KNOBLAUCH PRIVATE BANK OF TAXABLE MUNICIPAL BONDS ISSUED BY THE NIAGARA FALLS BRIDGE COMMISSION. Initiated By: W.R. DIMELING, JOHN C. TUTEN, HUGH KENWORTHY AND W.T. TITHER Court Details: 80-909 Date Court Action Filed: 03/04/1980 Principal Product Type: Debt - Municipal Other Product Types: Relief Sought: Other Other Relief Sought: FINDING OF VIOLATIONS OF RULE 10B-5 UNDER THE EXCHANGE ACT AND THE PENNSYLVANIA SECURITIES ACT AS WELL AS COMMON LAW FRAUD. Resolution: Judgment Rendered Resolution Date: 04/08/1982 Sanctions Ordered or Relief Granted: Other Sanctions: Sanction Details: Firm Statement DIMELING V. TUCKER, ANTHONY & R.L. DAY, INC., DC EPA 4/8/82 U.S.D.C. FOR THE EASTERN DISTRICT OF PENNSYLVANIA FOUND VIOLATIONS OF SEC RULE 10B-5, THE PENNSYLVANIA SECURITIES ACT AND THE COMMON LAW OF FRAUD IN CONNECTION WITH THE SALE OF NON-TAX EXEMPT MUNICIPAL BONDS TO A PRIVATE COMMERCIAL BANK.

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 114 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: 07/07/2000 Case Number: 00-02796 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; PREFERRED STOCK Sum of All Relief Requested: $61,721.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/16/2001 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 2 of 114 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: 08/22/2000 Case Number: 00-03031 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 569 www.finra.org/brokercheck User Guidance

Disputed Product Type: COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $102,921.39 Disposition: AWARD AGAINST PARTY Disposition Date: 01/24/2002 Sum of All Relief Awarded: $24,859.09 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 3 of 114 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: 04/19/2001 Case Number: 01-01929 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,450,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/28/2002 Sum of All Relief Awarded: $30,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 4 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-EXECUTIONS-OTHER; TRADING DISPUTES- OTHER ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 570 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 09/10/2001 Case Number: 01-04497 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $106,365.94 Disposition: AWARD AGAINST PARTY Disposition Date: 03/11/2003 Sum of All Relief Awarded: $39,357.93 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 5 of 114 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: 10/24/2001 Case Number: 01-05603 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $400,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/22/2002 Sum of All Relief Awarded: $25,300.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 6 of 114 Reporting Source: Regulator Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/12/2001 Case Number: 01-05974 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $225,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/29/2003 Sum of All Relief Awarded: $135,000.00 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 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/31/2002 Case Number: 02-00437 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $14,258,856.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/05/2004 Sum of All Relief Awarded: $1,106,022.00 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 114 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 572 www.finra.org/brokercheck User Guidance

Disclosure 8 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 03/12/2002 Case Number: 02-01291 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $59,963.45 Disposition: AWARD AGAINST PARTY Disposition Date: 08/03/2004 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 9 of 114 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: 05/08/2002 Case Number: 02-02355 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $12,375.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/11/2002 Sum of All Relief Awarded: $10,698.33 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 573 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $10,698.33 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 10 of 114 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: 07/02/2002 Case Number: 02-03772 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $37,136,010.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/19/2004 Sum of All Relief Awarded: $3,043,630.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 11 of 114 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: 08/21/2002 Case Number: 02-04165 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,380,000.00 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 574 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $1,380,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/08/2004 Sum of All Relief Awarded: $35,375.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 12 of 114 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: 08/21/2002 Case Number: 02-04273 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $34,828,200.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/10/2005 Sum of All Relief Awarded: $62,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 13 of 114 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: 07/30/2002 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 575 www.finra.org/brokercheck User Guidance

Case Initiated: 07/30/2002 Case Number: 02-04322 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $44,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/03/2003 Sum of All Relief Awarded: $43,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 14 of 114 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: 08/13/2002 Case Number: 02-04599 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $1,394,900.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/13/2003 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 15 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ©2021 FINRA. All rights reserved. Report aboutACCOUNT RBC CAPITAL RELATED-BREACH MARKETS, LLC OF CONTRACT; ACCOUNT RELATED- 576 NEGLIGENCE www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 10/15/2002 Case Number: 02-06036 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $141,182.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/29/2004 Sum of All Relief Awarded: $4,024.10 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 16 of 114 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: 05/05/2003 Case Number: 03-03036 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: 06/24/2004 Sum of All Relief Awarded: $64,300.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 17 of 114

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: 06/12/2003 Case Number: 03-04126 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $7,402.04 Disposition: AWARD AGAINST PARTY Disposition Date: 04/28/2004 Sum of All Relief Awarded: $1,512.04 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 18 of 114 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: 06/27/2003 Case Number: 03-04202 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: 07/23/2004 Sum of All Relief Awarded: $22,369.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i

Disclosure 19 of 114 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: 06/26/2003 Case Number: 03-04399 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $782,644.09 Disposition: AWARD AGAINST PARTY Disposition Date: 11/24/2004 Sum of All Relief Awarded: $219,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 20 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/01/2003 Case Number: 03-08334 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: 09/27/2005 Sum of All Relief Awarded: $698,325.01

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 21 of 114 Reporting Source: Regulator 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: 05/18/2004 Case Number: 04-03536 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $543,070.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/24/2005 Sum of All Relief Awarded: $226,794.00 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 114 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: 09/14/2004 Case Number: 04-03970 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 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 580 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 09/25/2006 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 23 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EMPLOYMENT-DISCRIMINATION AGE; DO NOT USE- EMPLOYMENT-DISCRM GENDER; EMPLOYMENT-COMPENSATION; EMPLOYMENT-LIBEL OR SLANDER ON FORM U-5 Arbitration Forum: NASD Case Initiated: 08/09/2004 Case Number: 04-05104 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: 05/26/2005 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 24 of 114 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: 09/03/2004 Case Number: 04-06254 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 581 www.finra.org/brokercheck User Guidance

Case Number: 04-06254 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $990,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/10/2006 Sum of All Relief Awarded: $100,957.00 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 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/05/2005 Case Number: 05-06115 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $210,796.84 Disposition: AWARD AGAINST PARTY Disposition Date: 11/27/2006 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 26 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 582 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/09/2006 Case Number: 06-02145 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $3,427,049.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/04/2007 Sum of All Relief Awarded: $20,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 27 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 08/06/2007 Case Number: 07-02229 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $4,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/11/2009 Sum of All Relief Awarded: $4,423,075.97 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 114 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 583 www.finra.org/brokercheck User Guidance

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-ERRORS- CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: FINRA Case Initiated: 09/13/2007 Case Number: 07-02598 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 03/31/2009 Sum of All Relief Awarded: $36.56 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 29 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: FINRA Case Initiated: 11/30/2007 Case Number: 07-03366 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $2,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/03/2009 Sum of All Relief Awarded: $348,750.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 30 of 114 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: FINRA Case Initiated: 02/15/2008 Case Number: 08-00405 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $18,453,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/18/2010 Sum of All Relief Awarded: $1,065,600.03 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 31 of 114 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: FINRA Case Initiated: 08/14/2008 Case Number: 08-02854 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $900,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/31/2009 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 585 www.finra.org/brokercheck User Guidance

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 32 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: FINRA Case Initiated: 10/17/2008 Case Number: 08-03364 Disputed Product Type: COMMON STOCK; FUTURES (OTHER THAN COMMODITIES); MUTUAL FUNDS; OPTIONS Sum of All Relief Requested: $2,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/19/2014 Sum of All Relief Awarded: $201,240.00 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 114 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: FINRA Case Initiated: 12/03/2008 Case Number: 08-03982 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 586 www.finra.org/brokercheck User Guidance

CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK Sum of All Relief Requested: $3,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/18/2010 Sum of All Relief Awarded: $240,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 34 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 03/25/2009 Case Number: 09-01554 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $55,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/07/2009 Sum of All Relief Awarded: $40,225.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 35 of 114 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: FINRA Case Initiated: 05/04/2009 Case Number: 09-01655 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 587 www.finra.org/brokercheck User Guidance

Case Number: 09-01655 Disputed Product Type: PREFERRED STOCK Sum of All Relief Requested: $20,610.72 Disposition: AWARD AGAINST PARTY Disposition Date: 03/12/2010 Sum of All Relief Awarded: $7,664.00 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 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS Arbitration Forum: FINRA Case Initiated: 05/28/2009 Case Number: 09-02420 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; LIMITED PARTNERSHIPS; PRIVATE EQUITIES Sum of All Relief Requested: $2,400,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/02/2010 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 37 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 588 www.finra.org/brokercheck User Guidance

ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 05/27/2009 Case Number: 09-02687 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $70,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/11/2010 Sum of All Relief Awarded: $14,295.68 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 38 of 114 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: FINRA Case Initiated: 10/12/2009 Case Number: 09-05195 Disputed Product Type: PREFERRED STOCK; STRUCTURED PRODUCTS Sum of All Relief Requested: $18,053.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/13/2010 Sum of All Relief Awarded: $17,546.00 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 114 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- ERRORS-CHARGES; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE- EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: FINRA Case Initiated: 03/03/2010 Case Number: 10-00270 Disputed Product Type: MUTUAL FUNDS Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/09/2011 Sum of All Relief Awarded: $14,893.05 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 40 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: FINRA Case Initiated: 07/23/2010 Case Number: 10-03270 Disputed Product Type: COMMON STOCK; CORPORATE BONDS Sum of All Relief Requested: $200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/19/2011 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 41 of 114 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 590 www.finra.org/brokercheck User Guidance

Disclosure 41 of 114 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; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 10/24/2011 Case Number: 11-03927 Disputed Product Type: MUTUAL FUNDS; PREFERRED STOCK Sum of All Relief Requested: $1,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/29/2013 Sum of All Relief Awarded: $735,366.77 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 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION Arbitration Forum: FINRA Case Initiated: 09/05/2012 Case Number: 12-02710 Disputed Product Type: FANNIE MAE; PREFERRED STOCK Sum of All Relief Requested: $21,425.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/17/2013 Sum of All Relief Awarded: $15,273.50 There may be a non-monetary award associated with this arbitration.

Please select the Case Number above to view more detailed information. i Disclosure 43 of 114 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; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 06/20/2013 Case Number: 13-01787 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $1,607,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/12/2014 Sum of All Relief Awarded: $1,050,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 44 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED- NEGLIGENCE; TRADING DISPUTES-SELL OUTS Arbitration Forum: FINRA Case Initiated: 12/04/2013 Case Number: 13-03281 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $500.00 Disposition: AWARD AGAINST PARTY

Disposition Date: 07/14/2014 Sum of All Relief Awarded: $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 45 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: FINRA Case Initiated: 01/13/2015 Case Number: 14-03809 Disputed Product Type: Sum of All Relief Requested: $640,188.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/23/2015 Sum of All Relief Awarded: $175,425.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 46 of 114 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; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; ACCOUNT RELATED-TRANSFER; DO NOT USE- OTHER-OTHER Arbitration Forum: FINRA Case Initiated: 07/29/2015 Case Number: 15-01863 Disputed Product Type: COMMON STOCK; EXCHANGE-TRADED FUNDS; OTHER TYPES OF ©2021 FINRA. All rights reserved. Report aboutSECURITIES; RBC CAPITAL PREFERRED MARKETS, LLC STOCK 593 www.finra.org/brokercheck User Guidance

Disputed Product Type: COMMON STOCK; EXCHANGE-TRADED FUNDS; OTHER TYPES OF SECURITIES; PREFERRED STOCK Sum of All Relief Requested: $9,000,000.06 Disposition: AWARD AGAINST PARTY Disposition Date: 09/08/2017 Sum of All Relief Awarded: $212,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 47 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: FINRA Case Initiated: 09/02/2015 Case Number: 15-02212 Disputed Product Type: COMMON STOCK; OTHER TYPES OF SECURITIES; PRIVATE EQUITIES Sum of All Relief Requested: $411,750.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/05/2016 Sum of All Relief Awarded: $430,824.45 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 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 594 ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; OTHER- INDEMNIFICATION www.finra.org/brokercheck User Guidance ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; OTHER- INDEMNIFICATION Arbitration Forum: FINRA Case Initiated: 11/09/2015 Case Number: 15-02911 Disputed Product Type: EXCHANGE-TRADED FUNDS; MUTUAL FUNDS Sum of All Relief Requested: $47,771.27 Disposition: AWARD AGAINST PARTY Disposition Date: 06/23/2016 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 49 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED- ERRORS-CHARGES; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 03/08/2016 Case Number: 16-00512 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $1,041,950.84 Disposition: AWARD AGAINST PARTY Disposition Date: 07/24/2017 Sum of All Relief Awarded: $559,612.00 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 114 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 595 www.finra.org/brokercheck User Guidance

Disclosure 50 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-VIOLATE OF BLUE SKY LWS Arbitration Forum: FINRA Case Initiated: 12/15/2016 Case Number: 16-03617 Disputed Product Type: COMMON STOCK; LIMITED PARTNERSHIPS; MUTUAL FUNDS Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 12/19/2017 Sum of All Relief Awarded: $250,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 51 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 02/08/2017 Case Number: 17-00305 Disputed Product Type: LIMITED PARTNERSHIPS Sum of All Relief Requested: $500,000.01 Disposition: AWARD AGAINST PARTY Disposition Date: 10/27/2017 Sum of All Relief Awarded: $723,354.78 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 596 www.finra.org/brokercheck User Guidance

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 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-VIOLATE OF BLUE SKY LWS; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: FINRA Case Initiated: 11/09/2018 Case Number: 18-03865 Disputed Product Type: CORPORATE BONDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/05/2019 Sum of All Relief Awarded: $50,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 53 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE- NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1987 Case Number: 87-03722 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $785,000.00 Disposition: AWARD AGAINST PARTY

Disposition Date: 04/10/1990 Sum of All Relief Awarded: $151,366.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 54 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/13/1989 Case Number: 88-03204 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $622,733.02 Disposition: AWARD AGAINST PARTY Disposition Date: 10/22/1990 Sum of All Relief Awarded: $92,733.02 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 55 of 114 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: 88-03495 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $236,208.33 Disposition: AWARD AGAINST PARTY Disposition Date: 10/05/1990 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 598 www.finra.org/brokercheck User Guidance

Disposition Date: 10/05/1990 Sum of All Relief Awarded: $106,750.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 56 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/06/1989 Case Number: 88-03722 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $336,366.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/22/1990 Sum of All Relief Awarded: $151,366.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 57 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/17/1989 Case Number: 89-02408 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $30,093.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/31/1990 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 599 www.finra.org/brokercheck User Guidance

Disposition Date: 08/31/1990 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 58 of 114 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: 89-03093 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $6,351.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/25/1990 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 59 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/09/1989 Case Number: 89-03097 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $53,000.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 600 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 09/10/1990 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 60 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/08/1990 Case Number: 90-00263 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $25,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/26/1991 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 61 of 114 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: 05/18/1990 Case Number: 90-01398 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $200,000.00 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 601 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/09/1992 Sum of All Relief Awarded: $42,008.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 62 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 06/18/1990 Case Number: 90-01577 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: 04/19/1991 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 63 of 114 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: 90-01580 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

Sum of All Relief Requested: $59,888.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/06/1991 Sum of All Relief Awarded: $31,100.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 64 of 114 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: 06/29/1990 Case Number: 90-01715 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $54,640.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/24/1991 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 65 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/11/1991 Case Number: 90-02995 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 603 www.finra.org/brokercheck User Guidance

Case Number: 90-02995 Disputed Product Type: CORPORATE BONDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $5,663.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/19/1991 Sum of All Relief Awarded: $5,494.00 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 114 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: 12/27/1990 Case Number: 90-03071 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $8,005.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/25/1991 Sum of All Relief Awarded: $5,005.00 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 114 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: 03/12/1991 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 604 www.finra.org/brokercheck User Guidance

Case Initiated: 03/12/1991 Case Number: 91-00005 Disputed Product Type: PREFERRED STOCK; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $11,550.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/26/1991 Sum of All Relief Awarded: $1,487.83 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 68 of 114 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: 04/08/1991 Case Number: 91-00995 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES Sum of All Relief Requested: $117,167.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/06/1992 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 69 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY ©2021 FINRA. All rights reserved. Report aboutINVOLVED RBC CAPITAL MARKETS, LLC 605 www.finra.org/brokercheck User Guidance

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/22/1991 Case Number: 91-02018 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: 03/23/1992 Sum of All Relief Awarded: $7,348.78 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 70 of 114 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: 10/17/1991 Case Number: 91-02591 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $258,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/26/1993 Sum of All Relief Awarded: $66,700.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 71 of 114 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: 09/27/1991 Case Number: 91-02660 Disputed Product Type: UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $260,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/03/1993 Sum of All Relief Awarded: $9,750.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 72 of 114 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: 09/24/1991 Case Number: 91-02665 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/22/1993 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 73 of 114 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: 01/23/1992 Case Number: 91-04002 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/09/1993 Sum of All Relief Awarded: $51,487.00 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 114 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: 01/28/1992 Case Number: 92-00198 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $77,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/10/1992 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 608 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $79,880.00 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 114 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: 04/09/1992 Case Number: 92-00858 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,644.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/13/1992 Sum of All Relief Awarded: $2,544.03 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 76 of 114 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: 05/21/1992 Case Number: 92-01359 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS Sum of All Relief Requested: $102,839.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 609 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 10/08/1993 Sum of All Relief Awarded: $47,183.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 77 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE- NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/20/1992 Case Number: 92-01513 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $26,850.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/21/1993 Sum of All Relief Awarded: $12,400.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 78 of 114 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: 07/07/1992 Case Number: 92-01986

©2021Disputed FINRA. Product All rights Type:reserved. Report aboutCOMMON RBC CAPITAL STOCK; MARKETS, DO NOT LLC USE-NO OTHER TYPE OF SEC INVOLVE; REAL 610 ESTATE INVESTMENT TRUST www.finra.org/brokercheck User Guidance

Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $520,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/14/1994 Sum of All Relief Awarded: $178,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 79 of 114 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: 01/26/1993 Case Number: 93-00197 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $166,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/31/1993 Sum of All Relief Awarded: $200,291.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 80 of 114 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: 09/02/1993 Case Number: 93-03065 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $56,154.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/20/1994 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 81 of 114 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 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 82 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION ©2021 FINRA. All rights reserved. Report aboutOF FACTS; RBC CAPITAL ACCOUNT MARKETS, ACTIVITY-SUITABILITY; LLC ACCOUNT RELATED- 612 NEGLIGENCE www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 10/15/1993 Case Number: 93-03539 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $102,011.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/29/1994 Sum of All Relief Awarded: $30,889.27 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 114 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: 11/16/1993 Case Number: 93-04179 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $750,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/14/1994 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 84 of 114 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 613 www.finra.org/brokercheck User Guidance

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-TRANSFER Arbitration Forum: NASD Case Initiated: 08/15/1994 Case Number: 94-01956 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $80,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/18/1995 Sum of All Relief Awarded: $5,375.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 85 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/02/1994 Case Number: 94-03716 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,218.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/21/1995 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 86 of 114 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: 12/20/1994 Case Number: 94-04575 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS Sum of All Relief Requested: $1,800,000.02 Disposition: AWARD AGAINST PARTY Disposition Date: 03/25/1996 Sum of All Relief Awarded: $2,331,743.78 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 87 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/05/1995 Case Number: 94-04897 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $5,105.07 Disposition: AWARD AGAINST PARTY Disposition Date: 06/29/1995 Sum of All Relief Awarded: $195.00

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 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/01/1995 Case Number: 95-03795 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FANNIE MAE; GOVERNMENT SECURITIES Sum of All Relief Requested: $60,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/16/1997 Sum of All Relief Awarded: $10,933.80 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 89 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- COLLECTION; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE- EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 09/07/1995 Case Number: 95-03975 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $440,358.75 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 616 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 12/02/1996 Sum of All Relief Awarded: $404,197.45 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 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/05/1995 Case Number: 95-05211 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $400,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/01/1996 Sum of All Relief Awarded: $108,250.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 91 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/11/1996 Case Number: 95-05402 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 617 www.finra.org/brokercheck User Guidance

Case Number: 95-05402 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $32,058.20 Disposition: AWARD AGAINST PARTY Disposition Date: 12/19/1996 Sum of All Relief Awarded: $3,271.99 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 92 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/12/1996 Case Number: 96-00368 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $26,763.50 Disposition: AWARD AGAINST PARTY Disposition Date: 11/19/1996 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 93 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE

Arbitration Forum: NASD Case Initiated: 03/28/1996 Case Number: 96-01241 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $320,944.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/26/1997 Sum of All Relief Awarded: $32,700.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 94 of 114 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: 04/29/1996 Case Number: 96-01642 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS Sum of All Relief Requested: $5,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/02/1997 Sum of All Relief Awarded: $16,200.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 95 of 114 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: 05/22/1996 Case Number: 96-01995 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $297,884.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/30/1997 Sum of All Relief Awarded: $319,037.00 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 114 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: 10/09/1996 Case Number: 96-03648 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; OPTIONS; WARRANTS/RIGHTS Sum of All Relief Requested: $707,325.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/12/1998 Sum of All Relief Awarded: $271,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 97 of 114 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: 09/23/1996 Case Number: 96-04118 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: 03/09/1998 Sum of All Relief Awarded: $29,027.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 98 of 114 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: 09/25/1996 Case Number: 96-04194 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $6,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/01/1997 Sum of All Relief Awarded: $2,550.00 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 621 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $2,550.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 99 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 07/22/1997 Case Number: 97-03013 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $1,175,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/06/1998 Sum of All Relief Awarded: $106,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 100 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/15/1997 Case Number: 97-03675 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $350,000.00

Disposition: AWARD AGAINST PARTY Disposition Date: 12/18/1998 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 101 of 114 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: 10/08/1997 Case Number: 97-04181 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $48,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/13/1998 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 102 of 114 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: 01/21/1998 Case Number: 97-05691

©2021Disputed FINRA. Product All rights Type:reserved. Report aboutCOMMON RBC CAPITAL STOCK; MARKETS, LIMITED LLC PARTNERSHIPS; OTHER TYPES OF SECURITIES; 623 REAL ESTATE INVESTMENT TRUST www.finra.org/brokercheck User Guidance

Disputed Product Type: COMMON STOCK; LIMITED PARTNERSHIPS; OTHER TYPES OF SECURITIES; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/04/1999 Sum of All Relief Awarded: $16,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 103 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-INCORRECT QUANTITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/28/1998 Case Number: 98-01185 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $5,863.30 Disposition: AWARD AGAINST PARTY Disposition Date: 12/14/1998 Sum of All Relief Awarded: $1,342.37 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 104 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD

Case Initiated: 05/26/1998 Case Number: 98-01758 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $93,565.45 Disposition: AWARD AGAINST PARTY Disposition Date: 04/09/1999 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 105 of 114 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: 09/08/1998 Case Number: 98-02889 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $675,795.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/07/1999 Sum of All Relief Awarded: $62,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 106 of 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report aboutCHURNING; RBC CAPITAL ACCOUNT MARKETS, ACTIVITY-SUITABILITY; LLC ACCOUNT RELATED-FAILURE 625 TO SUPERVISE www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 12/15/1998 Case Number: 98-04198 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; WARRANTS/RIGHTS Sum of All Relief Requested: $315,000.01 Disposition: AWARD AGAINST PARTY Disposition Date: 05/30/2000 Sum of All Relief Awarded: $55,560.47 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 107 of 114 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: 12/09/1998 Case Number: 98-04458 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $750,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/18/2000 Sum of All Relief Awarded: $37,800.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 108 of 114

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/30/1999 Case Number: 98-04653 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $7,040.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/30/1999 Sum of All Relief Awarded: $1,912.00 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 114 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: 02/04/1999 Case Number: 98-04903 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $3,027,868.43 Disposition: AWARD AGAINST PARTY Disposition Date: 01/20/2000 Sum of All Relief Awarded: $388,001.00 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 RBC CAPITAL MARKETS, LLC 627 www.finra.org/brokercheck User Guidance

i Disclosure 110 of 114 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: 03/01/1999 Case Number: 99-00433 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $688,792.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/08/2000 Sum of All Relief Awarded: $101,100.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 111 of 114 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: 04/26/1999 Case Number: 99-00867 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $17,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/26/2000 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 628 www.finra.org/brokercheck User Guidance

Disposition Date: 04/26/2000 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 112 of 114 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: 06/24/1999 Case Number: 99-02381 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $77,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/05/2000 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 113 of 114 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: 08/24/1999 Case Number: 99-03403 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $75,105.52 ©2021 FINRA. All rights reserved. Report about RBC CAPITAL MARKETS, LLC 629 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $75,105.52 Disposition: AWARD AGAINST PARTY Disposition Date: 12/06/2000 Sum of All Relief Awarded: $54,167.00 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 114 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/16/1999 Case Number: 99-04580 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $19,510.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/02/2001 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.

Civil Bond This type of disclosure event involves a civil bond for the brokerage firm that has been denied, paid, or revoked by a bonding company. Disclosure 1 of 7 Reporting Source: Firm Policy Holder: SUTRO & COMPANY, INCORPORATED Bonding Company Name: BONDING COMPANY Disposition: Payout Disposition Date: 10/01/1978 Payout Details: PAID OUT OF $54,000.00 ON 10/1987. Firm Statement PRIOR TO SUTRO MERGING INTO APPLICANT: A BONDING COMPNAY PAID OUT OF $54,000 IN A CLIAM WHERE A FORMER REGISTERED REPRESENTATIVE SUBMITTED TWO FALSE SALES TICKETS AND ENTERED INTO A REPURCHASE AGREEMENT WITHOUT NOTIFICATION TO SUTRO & CO. OF SUCH A COMMITMENT. i Disclosure 2 of 7 Reporting Source: Firm Policy Holder: TUCKER ANTHONY INCORPORATED Bonding Company Name: FIREMAN'S FUND INSURANCE Disposition: Payout Disposition Date: 08/01/1978 Payout Details: FIREMAN'S FUND INSURANCE PAID $278,051.11 FOR THE LOSS Firm Statement PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: LOSS OF TVA BEARER BONDS. i Disclosure 3 of 7 Reporting Source: Firm Policy Holder: GIBRALTAR SECURITIES CO. Bonding Company Name: NOT ON RECORD Disposition: Payout Disposition Date: 05/02/1985

Payout Details: UNKNOWN Firm Statement PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: GIBRALTAR SECURITIES CO., PRIOR TO BECOMING A DIVISION OF TUCKER ANTHONY, REPLACED TWO LOST SECURITIES WHICH REQUIRED THE PAYMENT OF CERTAIN REPLACEMENT COSTS AS WELL AS AN INSURANCE DEDUCTIBLE. i Disclosure 4 of 7 Reporting Source: Firm Policy Holder: TUCKER ANTHONY INCORPORATED Bonding Company Name: VIGILANT INSURANCE COMPANY Disposition: Payout Disposition Date: 06/01/1985 Payout Details: VIGILANT INSURANCE COMPANY PAID $5,625.00 IN SETTLEMENT OF THE LOSS. Firm Statement PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: ADMINISTRATOR OF THE CLIENT'S ESTATE CLAIMED THE LOSS. i Disclosure 5 of 7 Reporting Source: Firm Policy Holder: TUCKER ANTHONY INCORPORATED Bonding Company Name: NOT ON RECORD Disposition: Payout Disposition Date: 05/01/1989 Payout Details: TUCKER ANTHONY'S FIDELITY BOND CARRIER PAID $800,000.00 IN SETTLEMENT OF THE CLAIMS. Firm Statement PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: CERTAIN CUSTOMERS CLAIMED LOSSES AS A RESULT OF UNAUTHORIZED TRADING IN THEIR ACCOUNTS. i Disclosure 6 of 7 Reporting Source: Firm Policy Holder: TUCKER ANTHONY INCORPORATED Bonding Company Name: NOT ON RECORD

Disposition: Payout Disposition Date: 09/01/1996 Payout Details: TUCKER ANTHONY'S FIDELITY BOND CARRIER PAID $6,250,000 IN SETTLEMENT OF THE CLAIMS. Firm Statement PRIOR TO TUCKER ANTHONY MERGING INTO APPLICANT: CERTAIN CUSTOMERS CLAIMED LOSSES AS A RESULT OF UNAUTHORIZED AND UNSUITABLE TRADING BY A REGISTERED REPRESENTATIVE. i Disclosure 7 of 7 Reporting Source: Firm Policy Holder: RBC DAIN RAUSCHER INC. Bonding Company Name: RELIANCE INSURANCE COMPANY Disposition: Payout Disposition Date: 01/01/1981 Payout Details: 02/01/1983 $225,000.00 Firm Statement RAUSCHER PIERCE REFSNES, INC., WAS PAID $225,00 BY ITS BONDING COMPANY, RELIANCE INSURANCE COMPANY. RAUSCHER PIERCE REFSNES, INC MERGED INTO DAIN RAUSCHER (1998) WHO SUBSEQUENTLY CHANGED THEIR NAME TO RBC DAIN RAUSCHER INC.

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