Legal Notice To All Persons in Canada Who, Between January 1, 2003 and December 31, 2013, Entered Into an FX Instrument*, Either Directly or Indirectly Through an Intermediary, and/or Purchased or Otherwise Participated in an Investment or Equity Fund, Mutual Fund, Hedge Fund, Pension Fund Or Any Other Investment Vehicle that Entered into an FX Instrument.

*FX Instruments includes FX spot transactions, outright forwards, FX swaps, FX options, FX futures contracts, options on FX futures contracts, and other instruments traded in the FX Market

Settlements May Affect Your Rights. Please Read this Notice Carefully

This notice is about a class action relating to Foreign and/or purchased or otherwise participated in an Exchange (“FX”) transactions. investment or equity fund, mutual fund, hedge fund, pension fund or any other investment vehicle that The Plaintiffs, Joseph S. Mancinelli, Carmen entered into an FX Instrument (the “Class”). An “FX Principato, Douglas Serroul, Luigi Carrozzi, Manuel Instrument” includes FX spot transactions, outright Bastos, and Jack Oliveira in their capacity as The forwards, FX swaps, FX options, FX futures contracts, Trustees of the Labourers’ Pension Fund of Central and options on FX futures contracts, and other instruments Eastern Canada and Christopher Staines, in Ontario, traded in the FX Market. and the Plaintiff Christine Béland, in Quebec, have undertaken legal procedures under applicable laws What are the settlements benefits? related to class actions against the following Settlements have been reached with The Goldman defendants: Bank of America Corporation, Bank of Sachs Group, Inc., Goldman, Sachs & Co., Goldman America, N.A., Bank of America Canada, Bank of Sachs Canada Inc. (collectively, “Goldman Sachs”); America, National Association, Bank of Tokyo JPMorgan Chase & Co., J.P. Morgan Bank Canada, J.P. Mitsubishi UFJ Ltd., Bank of Tokyo-Mitsubishi UFJ Morgan Canada, JPMorgan Chase Bank National (Canada), Barclays Bank PLC, Barclays Capital Inc., Association (collectively, “JPMorgan”); and Citigroup Barclays Capital Canada Inc., BNP Paribas Group, Inc., Citibank, N.A., Citibank Canada, and Citigroup BNP Paribas North America, Inc., BNP Paribas Global Markets Canada Inc. (collectively, “Citi” and, (Canada), BNP Paribas, Citigroup, Inc., Citibank, N.A., together with Goldman Sachs and JPMorgan, the Citibank Canada, Citigroup Global Markets Canada “Settlement Agreements”). The Settlement Agreements, Inc., Credit Suisse Group AG, Credit Suisse Securities if approved and their conditions fulfilled, will settle, (USA) LLC, Credit Suisse AG, Credit Suisse Securities extinguish and bar all claims relating in any way to or (Canada) Inc, Deutsche Bank AG, The Goldman Sachs arising out of the Proceedings against Goldman Sachs, Group, Inc., Goldman, Sachs & Co., Goldman Sachs JPMorgan, and Citi. Canada Inc., HSBC Holdings PLC, HSBC Bank PLC,

HSBC North America Holdings Inc., HSBC Bank If the Settlement Agreements are approved, Goldman USA, N.A., HSBC Bank Canada, JPMorgan Chase & Sachs has agreed to pay $6,750,000, JPMorgan has Co., J.P. Morgan Bank Canada, J.P. Morgan Canada, agreed to pay $11,500,000, and Citi has agreed to pay JPMorgan Chase Bank, National Association, Morgan $21,000,000 (the “Settlement Amounts”) to settle the Stanley, Morgan Stanley Canada Limited, Royal Bank class action and to provide co-operation to the plaintiffs of Canada, RBC Capital Markets LLC, Royal Bank of in order to continue the case against the other Scotland Group PLC, RBS Securities, Inc., Royal Bank defendants. The settlements are a compromise of of Scotland N.V., Royal Bank of Scotland plc, Société disputed claims and Goldman Sachs, JPMorgan, and Générale S.A., Société Générale (Canada), Société Citi do not admit any wrongdoing or liability. Générale, Standard Charter plc, UBS AG, UBS

Securities LLC and UBS Bank (Canada). Prior settlements with UBS AG, UBS Securities LLC The Ontario action is brought on behalf of anyone in and UBS Bank (Canada) (collectively, “UBS”); BNP Canada, while the Quebec action is brought on behalf Paribas Group, BNP Paribas North America, Inc., BNP of anyone in Quebec who, between January 1, 2003 and Paribas (Canada), and BNP Paribas (collectively, December 31, 2013, entered into an FX Instrument “BNP”); and Bank of America Corporation, Bank of either directly or indirectly through an intermediary, America, N.A., Bank of America Canada, and Bank of

This Notice is a Summary. For more information about these class actions, please visit www.kmlaw.ca/fxclassaction or contact Class Counsel.

America National Association (collectively “Bank of Counsel”). The lawyers will be paid on a contingency America”), totalling $15,950,000 were approved by the fee basis. courts. Hearing to Approve Settlement Agreements and At this time, the Settlement Amounts will not be Class Counsel Fees distributed to the Class. Rather, the Settlement Hearings will be held during which Class Counsel will Amounts will be paid into an interest bearing account seek the Court’s approval of (i) the Settlement for the benefit of the Class and may be used in part to Agreements; and (ii) the fees and expense fund the disbursements and any adverse costs awards reimbursement of Class Counsel (The “Approval made in the case. Hearings”). The hearing before the Ontario Superior

Court of Justice will be held on April 13, 2017 at 11AM What is this case about? (ET) at Osgoode Hall, 130 Queen Street West, Toronto, These actions allege that beginning at least as early as Ontario. The hearing before the Quebec Superior Court 2003 and continuing through 2013, the Defendant will be held on May 2, 2017 at 10:00am at the Quebec Banks conspired with each other to fix prices in the FX City Court house, 300, Jean Lesage boulevard, Quebec Market. It is alleged that the Defendant Banks City, Quebec. communicated directly with each other to coordinate their: (i) fixing of spot prices; (ii) controlling or At the Approval Hearings, the Courts will determine manipulating FX benchmark rates; and (iii) exchanging whether the Settlement Agreements are fair, reasonable key confidential customer information in an effort to and in the best interest of the Class. At the hearings, trigger client stop loss orders and limit orders. It is Class Counsel will also seek court approval of its alleged that the Defendant Banks’ alleged conspiracy request for fees equal to 25% of the Settlement affected dozens of currency pairs, including the U.S. Amounts and expense reimbursement. Class Counsel and Canadian dollar (USD/CAD) currency pair, which will be requesting the fees and disbursements to be is one of the world’s highest volume trading currency deducted directly from the Settlement Amounts. pairs. Due to the importance of spot prices, it is alleged that the Defendant Banks’ alleged conspiracy impacted All members of the proposed Class may attend the all manner of FX Instruments, including those trading Approval Hearings and ask to make submissions both over-the-counter and on exchanges. regarding the proposed settlements. Persons intending to object to one or more of the Settlement Are you included? Agreements should provide their objection in writing to Class Counsel at the address below by You are included in this lawsuit if: March 31, 2017.  you are a Person in Canada who, between January

1, 2003 and December 31, 2013, entered into an What are your options? FX Instrument[1] either directly or indirectly through an intermediary, and/or purchased or Take no Steps: You do not have to do anything to stay otherwise participated in an investment or equity in the class action. The opt-out period has expired. If fund, mutual fund, hedge fund, pension fund or any you opted out, you cannot rejoin the class action. If any other investment vehicle that entered into an FX benefits, including settlement funds, become available Instrument and you did not opt-out of the action on for distribution to the Class, you will be notified about or before December 5, 2016. how to ask for a share. You will be legally bound by all [1] “FX Instruments” includes FX spot orders and judgments of the Court, and you will not be transactions, outright forwards, FX swaps, FX able to sue the Defendant about the legal claims in this options, FX futures contracts, options on FX case. futures contracts, and other instruments traded in the FX Market. Object to the Settlement Agreement or Class Counsel Fees: If you want to object to the proposed Who are the lawyers who represent the class? settlements with Goldman Sachs, JPMorgan, and/or Citi or the payment of Class Counsel’s fees and expenses, The law firms of Sotos LLP, Koskie Minsky LLP, you should do so by setting out your objection in Siskinds LLP, and Camp Fiorante Matthews Mogerman writing addressed to the FX Class Counsel at the represent the Plaintiffs and the class in the Ontario address below. action and Siskinds Desmeules, s.e.n.c.r.l. represent the

Plaintiff and the class in the Quebec action (“Class

This Notice is a Summary. For more information about these class actions, please visit www.kmlaw.ca/fxclassaction or contact Class Counsel.

More Information? If there is a conflict between the provisions of this Go to www.kmlaw.ca/fxclassaction or call toll-free 1- notice and any of the Settlement Agreements, the terms 855-595-2624 or write to Class Counsel at of the Settlement Agreement(s) will prevail with [email protected]. respect to that(these) Settling Defendant(s).

Interpretation

DISTRIBUTION OF THIS NOTICE HAS BEEN AUTHORIZED BY THE ONTARIO SUPERIOR COURT OF JUSTICE AND BY THE QUEBEC SUPERIOR COURT

This Notice is a Summary. For more information about these class actions, please visit www.kmlaw.ca/fxclassaction or contact Class Counsel.