Brokercheck Report WELLS FARGO CLEARING SERVICES, LLC CRD# 19616

BrokerCheck Report WELLS FARGO CLEARING SERVICES, LLC CRD# 19616

Section Title Page(s) Report Summary 1

Firm Profile 2 - 11

Firm History 12

Firm Operations 13 - 27

Disclosure Events 28

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CRD# 19616 This report summary provides an overview of the brokerage firm. Additional information for this firm can be found in the detailed report. SEC# 8-37180 Firm Profile Disclosure Events Main Office Location This firm is classified as a limited liability company. ONE NORTH JEFFERSON AVENUE This firm was formed in Delaware on 03/12/2003. Brokerage firms are required to disclose certain MAIL CODE: H0004-050 Its fiscal year ends in December. criminal matters, regulatory actions, civil judicial ST. LOUIS, MO 63103 proceedings and financial matters in which the firm or Regulated by FINRA Kansas City Office Firm History one of its control affiliates has been involved. Mailing Address Information relating to the brokerage firm's history Are there events disclosed about this firm? Yes ONE NORTH JEFFERSON AVENUE such as other business names and successions MAIL CODE: H0004-050 (e.g., mergers, acquisitions) can be found in the ST. LOUIS, MO 63103 detailed report. The following types of disclosures have been reported: Business Telephone Number Firm Operations Type Count 314-875-3000 This firm is registered with: Regulatory Event 167 • the SEC Civil Event 2 This firm is a brokerage firm and an investment • 11 Self-Regulatory Organizations Arbitration 296 adviser firm. For more information about • 53 U.S. states and territories investment adviser firms, visit the SEC's Investment Adviser Public Disclosure website at: Is this brokerage firm currently suspended with any regulator? No https://www.adviserinfo.sec.gov This firm conducts 24 types of businesses. This firm is affiliated with financial or investment institutions. This firm has referral or financial arrangements with other brokers or dealers.

This firm is classified as a limited liability company. This firm was formed in Delaware on 03/12/2003. Its fiscal year ends in December.

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.

WELLS FARGO CLEARING SERVICES, LLC Doing business as WELLS FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180

Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated by FINRA Kansas City Office

Mailing Address ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103

Business Telephone Number 314-875-3000

Other Names of this Firm

Name Where is it used FIRST CLEARING 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 WELLS FARGO CLEARING SERVICES, 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 WELLS FARGO ADVISORS 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 WELLS FARGO CLEARING SERVICES, 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): WACHOVIA SECURITIES FINANCIAL HOLDINGS, LLC Is this a domestic or foreign Domestic Entity entity or an individual?

Position SOLE MEMBER Position Start Date 12/2003 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): ALEXANDER, JOHN WADE 2327561 Is this a domestic or foreign Individual entity or an individual?

Position HEAD OF INTEGRATED BROKERAGE Position Start Date 03/2017 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): CAPERTON, JULIE CIRCIO 5166947 Is this a domestic or foreign Individual entity or an individual?

Position HEAD OF BANKING, LENDING AND TRUST/BOARD OF MANAGERS Position Start Date 01/2021 Percentage of Ownership Less than 5% ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, 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): CRONK, DARRELL 2498892 Is this a domestic or foreign Individual entity or an individual?

Position HEAD OF INVESTMENT SOLUTIONS / WIM CHIEF INVESTMENT OFFICER / BOARD OF MANAGERS Position Start Date 01/2021 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): GINDI, SOL 4903526 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF FINANCIAL OFFICER / BOARD OF MANAGERS Position Start Date 01/2021 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?

Direct Owners and Executive Officers (continued) Legal Name & CRD# (if any): GONZALEZSAINTGEOURS, ALBERTO 4903516 Is this a domestic or foreign Individual entity or an individual?

Position DESIGNATED STATE PRINCIPAL Position Start Date 06/2021 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): HAYS, JAMES 1569212 Is this a domestic or foreign Individual entity or an individual?

Position PRESIDENT / BOARD OF MANAGERS Position Start Date 11/2012 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): HUBBERT, MARK WILLIAM 1802805 Is this a domestic or foreign Individual entity or an individual?

Position BUSINESS CONTROL LEADER Position Start Date 05/2020 Percentage of Ownership Less than 5% ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 6 www.finra.org/brokercheck User Guidance Firm Profile

PercentageDirect Owners of Ownership and ExecutiveLess Officers than 5% (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): HURLEY, KEVIN BRADY 1293748 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF COMPLIANCE OFFICER (IA ONLY) Position Start Date 12/2008 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): KARANIK, ERIK ANTHONY 2260890 Is this a domestic or foreign Individual entity or an individual?

Position CONTROL MANAGEMENT EXECUTIVE / BOARD OF MANAGERS Position Start Date 03/2017 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?

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

Position HEAD OF ADVICE / GROWTH STRATEGY / BOARD OF MANAGERS Position Start Date 01/2021 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): MCHALE, JAMES 6052977 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF COMPLIANCE OFFICER / CONTROL PRINCIPAL Position Start Date 02/2021 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): METZ, KELLY 2251657 Is this a domestic or foreign Individual entity or an individual?

Position PRINCIPAL OPERATIONS OFFICER/CHIEF OPERATIONS OFFICER/BACK OFFICE OPERATIONS Position Start Date 06/2018 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 WELLS FARGO CLEARING SERVICES, 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?

Legal Name & CRD# (if any): SOMMERS, BARRY 2301454 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF EXECUTIVE OFFICER / BOARD OF MANAGERS Position Start Date 01/2021 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?

©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, 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): EVEREN CAPITAL CORPORATION Is this a domestic or foreign Domestic Entity entity or an individual?

Company through which WACHOVIA SECURITIES FINANCIAL HOLDINGS, LLC indirect ownership is established Relationship to Direct Owner SHARE HOLDER Relationship Established 08/2010 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): WELLS FARGO & COMPANY Is this a domestic or foreign Domestic Entity entity or an individual?

Company through which WFC HOLDINGS, LLC indirect ownership is established Relationship to Direct Owner SHARE HOLDER Relationship Established 09/1998 Percentage of Ownership 75% or more Does this owner direct the Yes management or policies of the firm? Is this a public reporting Yes company?

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

Company through which EVEREN CAPITAL CORPORATION indirect©2021 FINRA. ownership All rights reserved. is Report about WELLS FARGO CLEARING SERVICES, LLC 10 established www.finra.org/brokercheck User Guidance Firm Profile

Indirect Owners (continued) Company through which EVEREN CAPITAL CORPORATION indirect ownership is established Relationship to Direct Owner SHARE HOLDER Relationship Established 12/2017 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?

©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 11 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, 11 SROs and 53 U.S. states and territories. Federal Regulator Status Date Effective SEC Approved 04/03/1987

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 07/09/1987 Cboe BZX Exchange, Inc. Approved 07/01/2016 Cboe Exchange, Inc. Approved 11/14/2016 NYSE American LLC Approved 12/31/2008 NYSE Arca, Inc. Approved 08/03/2016 NYSE Chicago, Inc. Approved 09/05/1990 Nasdaq GEMX, LLC Approved 09/16/2016 Nasdaq ISE, LLC Approved 03/12/2003 Nasdaq PHLX LLC Approved 04/03/1987 Nasdaq Stock Market Approved 07/12/2006 New York Stock Exchange Approved 08/31/1990

Registrations (continued) U.S. States & Status Date Effective U.S. States & Status Date Effective Territories Territories Alabama Approved 07/28/1989 North Carolina Approved 09/21/1989 Alaska Approved 08/21/1989 North Dakota Approved 11/06/1989 Arizona Approved 09/04/1990 Ohio Approved 04/11/1989 Arkansas Approved 01/05/1990 Oklahoma Approved 04/11/1989 California Approved 07/11/1989 Oregon Approved 09/06/1989 Colorado Approved 02/13/1989 Pennsylvania Approved 06/01/1989 Connecticut Approved 05/16/1989 Puerto Rico Approved 01/16/1990 Delaware Approved 04/17/1989 Rhode Island Approved 05/17/1989 District of Columbia Approved 03/15/1989 South Carolina Approved 12/08/1989 Florida Approved 04/09/1990 South Dakota Approved 05/04/1989 Georgia Approved 04/11/1989 Tennessee Approved 04/03/1989 Hawaii Approved 08/30/1990 Texas Approved 11/01/1989 Idaho Approved 06/16/1989 Utah Approved 02/16/1990 Illinois Approved 06/14/1989 Vermont Approved 05/01/1990 Indiana Approved 11/15/1989 Virgin Islands Approved 06/14/2005 Iowa Approved 05/22/1989 Virginia Approved 12/01/1989 Kansas Approved 08/03/1989 Washington Approved 08/31/1989 Kentucky Approved 12/07/1989 West Virginia Approved 01/10/1990 Louisiana Approved 04/04/1989 Wisconsin Approved 08/31/1990 Maine Approved 01/16/1990 Wyoming Approved 10/05/1989 Maryland Approved 07/05/1989 Massachusetts Approved 01/09/1990 Michigan Approved 01/02/1990 Minnesota Approved 11/09/1989 Mississippi Approved 09/28/1989 Missouri Approved 04/16/1990 Montana Approved 04/11/1989 Nebraska Approved 05/07/1990 Nevada Approved 08/30/1989 New Hampshire Approved 01/01/1990 New Jersey Approved 09/07/1990 New Mexico Approved 07/12/1989 New York Approved 12/19/1989

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 24 types of businesses. Types of Business

Exchange member engaged in exchange commission business other than floor activities Exchange member engaged in floor activities Broker or dealer making inter-dealer markets in corporation securities over-the-counter Broker or dealer retailing corporate equity securities over-the-counter Broker or dealer selling corporate debt securities Underwriter or selling group participant (corporate securities other than mutual funds) Mutual fund 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 Solicitor of time deposits in a financial institution Broker or dealer selling oil and gas interests Put and call broker or dealer or option writer Broker or dealer selling securities of non-profit organizations (e.g., churches, hospitals) Investment advisory services Broker or dealer selling tax shelters or limited partnerships in primary distributions Non-exchange member arranging for transactions in listed securities by exchange member 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 - APPLICANT SOLICITS AND EFFECTS TRANSACTIONS IN REPURCHASE AGREEMENTS, REVERSE PURCHASE AGREEMENTS, CERTIFICATES OF DEPOSIT, BANKER'S ACCEPTANCE, DEPOSIT NOTES AND OTHER EXEMPT SECURITIES TRANSACTIONS FOR AFFILIATED AND NON-AFFILIATED ENTITIES. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 15 ENGAGING IN MULTI-CURRENCY FIXED INCOME BUSINESS AND FOREIGN EXCHANGE TRANSACTIONS ANCILLARY TO THIS BUSINESS.

TRADE SETTLEMENT AND SECURITIES CLEARANCE, AND CORRESPONDENT CLEARING SERVICES; PRIME BROKERAGE SERVICES; AND SECURITIES LENDING. Other - APPLICANT SOLICITS AND EFFECTS TRANSACTIONS IN REPURCHASE AGREEMENTS, REVERSE www.finra.org/brokercheckPURCHASE AGREEMENTS, CERTIFICATES OF DEPOSIT, BANKER'S ACCEPTANCE, DEPOSIT NOTES AND User Guidance OTHER EXEMPT SECURITIES TRANSACTIONS FOR AFFILIATED AND NON-AFFILIATED ENTITIES.

ENGAGING IN MULTI-CURRENCY FIXED INCOME BUSINESS AND FOREIGN EXCHANGE TRANSACTIONS ANCILLARY TO THIS BUSINESS.

TRADE SETTLEMENT AND SECURITIES CLEARANCE, AND CORRESPONDENT CLEARING SERVICES; PRIME BROKERAGE SERVICES; AND SECURITIES LENDING.

Other Types of Business 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: APPICANT SOLICITS AND EFFECTS TRANSACTIONS IN REPURCHASE AGREEMENTS, REVERSE PURCHASE AGREEMENTS, CERTIFICATES OF DEPOSIT, BANKER'S ACCEPTANCES, DEPOSIT NOTES AND OTHER EXEMPT SECURITIES TRANSACTIONS FOR AFFILATED AND NON- AFFILIATED ENTITIES.

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 refer or introduce customers to other brokers and dealers. Name: ADM INVESTOR SERVICES, INC. Business Address: CHICAGO BOARD OF TRADE BUILDING 141 WEST JACKSON BOULEVARD CHICAGO, IL 60604 Effective Date: 07/13/2012 Description: TRANSACTIONS EFFECTED IN FUTURES OR COMMODITIES FOR RETAIL CUSTOMER ACCOUNTS OF WELLS FARGO ADVISORS WILL BE CARRIED, CLEARED AND SETTLED ON A FULLY DISCLOSED BASIS.

This firm does have books or records maintained by a third party. Name: WELLS FARGO BANK, N.A. Business Address: 1 N JEFFERSON AVE ST. LOUIS, MO 63103 Effective Date: 07/15/2020 Description: WELLS FARGO BANK, N.A. PROVIDES OPERATIONAL FACILITIES AND SUPPORT, DATA PROCESSING AND RECORDKEEPING FUNCTIONS FOR APPLICANT. Name: ADM INVESTOR SERVICES, INC. Business Address: CHICAGO BOARD OF TRADE BUILDING 141 WEST JACKSON BOULEVARD CHICAGO, IL 60604 Effective Date: 07/13/2012 Description: TRANSACTIONS EFFECTED IN FUTURES OR COMMODITIES FOR RETAIL CUSTOMER ACCOUNTS OF WELLS FARGO ADVISORS WILL BE CARRIED, CLEARED AND SETTLED ON A FULLY DISCLOSED BASIS. Name: WELLS FARGO & COMPANY Business Address: 1 NORTH JEFFERSON ST. LOUIS, MO 63103 Effective Date: 03/20/2010 Description: WELLS FARGO & COMPANY PROVIDES OPERATIONAL FACILITIES AND SUPPORT, DATA PROCESSING AND RECORDKEEPING FUNCTIONS FOR APPLICANT. This firm does not have accounts, funds, or securities maintained by a third party.

This firm does have customer accounts, funds, or securities maintained by a third party. Name: ADM INVESTOR SERVICES, INC. Business Address: CHICAGO BOARD OF TRADE BUILDING 141 WEST JACKSON BOULEVARD CHICAGO, IL 60604 Effective Date: 07/13/2012 Description: TRANSACTIONS EFFECTED IN FUTURES OR COMMODITIES FOR RETAIL CUSTOMER ACCOUNTS OF WELLS FARGO ADVISORS WILL BE CARRIED, CLEARED AND SETTLED ON A FULLY DISCLOSED BASIS. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 18 www.finra.org/brokercheck User Guidance Firm Operations TRANSACTIONS EFFECTED IN FUTURES OR COMMODITIES FOR RETAIL Industry Arrangements (continued)CUSTOMER ACCOUNTS OF WELLS FARGO ADVISORS WILL BE CARRIED, CLEARED AND SETTLED ON A FULLY DISCLOSED BASIS.

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. WELLS CAPITAL MANAGEMENT SINGAPORE is under common control with the firm. CRD #: 165024 Business Address: 80 RAFFLES PLACE #26-20/21 UOB PLAZA 2 SINGAPORE, SINGAPORE 048624 Effective Date: 08/30/2012 Foreign Entity: Yes Country: REPUBLIC OF SINGAPORE Securities Activities: No Investment Advisory Yes Activities: Description: WELLS CAPITAL MANAGEMENT SINGAPORE IS OWNED BY WELLS CAPITAL MANAGEMENT, AN AFFILIATE OF WELLS FARGO CLEARING SERVICES AND WHOLLY OWNED SUBSIDIARY OF WELLS FARGO & COMPANY

WELLS FARGO SECURITIES CANADA, LTD. is under common control with the firm. Business Address: 1235 BAY STREET SUITE 400 TORONTO, CANADA M5R 3K4 Effective Date: 08/01/2012 Foreign Entity: Yes Country: CANADA Securities Activities: Yes Investment Advisory No Activities: Description: WELLS FARGO SECURITIES CANADA, LTD. IS WHOLLY OWNED BY EVEREN CAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 20 WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT. www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Description: WELLS FARGO SECURITIES CANADA, LTD. IS WHOLLY OWNED BY EVEREN CAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

WELLS FARGO PRIME SERVICES, LLC is under common control with the firm. CRD #: 133068 Business Address: 101 CALIFORNIA STREET SUITE 3050 SAN FRANCISCO, CA 94111 Effective Date: 08/01/2012 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: THE AFFILIATE IS 100% OWNED BY EVEREN CAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

WELLS FARGO SECURITIES (JAPAN) CO., LTD. is under common control with the firm. Business Address: MARUNOUCHI TRUST TOWER MAIN, 24TH FLOOR 1-8-3, MARUNOUCHI, CHIYODA-KU TOKYO, JAPAN Effective Date: 05/11/2007 Foreign Entity: No Country: JAPAN Securities Activities: Yes Investment Advisory Yes Activities: Description: THE AFFILIATE IS 100% OWNED BY WELLS FARGO INTERNATIONAL BANKING CORPORATION, WHICH IS 100% OWNED BY WELLS FARGO BANK, N.A., WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

Organization Affiliates (continued)

WELLS FARGO SECURITIES ASIA LIMITED is under common control with the firm. Business Address: 23F/AIA CENTRAL 1 CONNAUGHT ROAD, CENTRAL HONG KONG, HONG KONG Effective Date: 09/18/2007 Foreign Entity: Yes Country: CHINA Securities Activities: Yes Investment Advisory Yes Activities: Description: THE AFFILIATE IS 100% OWNED BY WELLS FARGO INTERNATIONAL BANKING CORPORATION, WHICH IS 100% OWNED BY WELLS FARGO BANK, N.A., WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

WELLS FARGO FUNDS DISTRIBUTOR, LLC is under common control with the firm. CRD #: 133366 Business Address: 525 MARKET STREET 12TH FLOOR SAN FRANCISCO, CA 94105 Effective Date: 01/01/2009 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENT HOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

GALLIARD CAPITAL MANAGEMENT INC is under common control with the firm. CRD #: 106487

Organization Affiliates (continued)

Business Address: SIXTH & MARQUETTE MINNEAPOLIS, MN 55479 Effective Date: 01/01/2009 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENT HOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

WELLS CAPITAL MANAGEMENT INC is under common control with the firm. CRD #: 104973 Business Address: 525 MARKET STREET 10TH FLOOR SAN FRANCISCO, CA 94105 Effective Date: 01/01/2009 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENT HOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

WELLS FARGO FUNDS MANAGEMENT, LLC is under common control with the firm. CRD #: 110841 Business Address: 525 MARKET STREET 12TH FLOOR SAN FRANCISCO, CA 94105 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 23 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)525 MARKET STREET 12TH FLOOR SAN FRANCISCO, CA 94105 Effective Date: 01/01/2009 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENT HOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

WELLS FARGO ASSET MANAGEMENT (INTERNATIONAL) LIMITED is under common control with the firm. CRD #: 132377 Business Address: 34 GROSVENOR STREET LONDON, ENGLAND W1K 4QU Effective Date: 03/20/2010 Foreign Entity: Yes Country: ENGLAND Securities Activities: No Investment Advisory Yes Activities: Description: THE AFFILIATE IS OWNED 25% BY HADBO INVESTMENTS C.V. AND 75% BY ISLAND FINANCE HOLDING COMPANY, BOTH OF WHICH ARE OWNED DIRECTLY AND INDIRECTLY BY WELLS FARGO FINANCIAL, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE SUBSIDIARY AND THE APPLICANT.

WELLS FARGO INVESTMENT INSTITUTE, INC. is under common control with the firm. CRD #: 133204 Business Address: 401 SOUTH TRYON STREET CHARLOTTE, NC 28202 Effective Date: 03/20/2010 Foreign Entity: No ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 24 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: THE AFFILIATE IS OWNED 100% BY WELLS FARGO BANK, N.A., WHICH IS OWNED 100% BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

WELLS FARGO SECURITIES, LLC is under common control with the firm. CRD #: 126292 Business Address: 301 S COLLEGE STREET CHARLOTTE, NC 28288-0601 Effective Date: 03/20/2010 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: THE AFFILIATE IS WHOLLY OWNED BY EVEREN CAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

WELLS FARGO SECURITIES INTERNATIONAL LIMITED is under common control with the firm. Business Address: LECONFIELD HOUSE CURZON STREET LONDON, ENGLAND WIJ-5JA Effective Date: 03/20/2010 Foreign Entity: Yes Country: ENGLAND Securities Activities: Yes Investment Advisory No Activities: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 25 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Investment Advisory No Activities: Description: THE AFFILIATE IS 100% OWNED BY WELLS FARGO INTERNATIONAL BANKING CORPORATION, WHICH IS 100% OWNED BY WELLS FARGO BANK, N.A., WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC is under common control with the firm. CRD #: 11025 Business Address: ONE NORTH JEFFERSON AVENUE ST. LOUIS, MO 63103 Effective Date: 08/01/2010 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: THE AFFILIATE IS 100% OWNED BY WACHOVIA SECURITIES FINANCIAL HOLDINGS, LLC WHICH IS 100% OWNED BY EVEREN CAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

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

WELLS FARGO BANK, N. A. is a National Bank and controls the firm. Business Address: 420 MONTGAMERY STREET SAN FRANCISCO, CA 94104 Effective Date: 01/01/2008 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 26 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Effective Date: 01/01/2008 Description: THE AFFILIATE IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, THE ULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

WELLS FARGO & COMPANY is a Bank Holding Company and controls the firm. Business Address: 420 MONTGOMERY STREET SAN FRANCISCO, CA 94163 Effective Date: 01/01/2009 Description: ULTIMATE PARENT OF 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 0 167 0 Civil Event 0 2 0 Arbitration N/A 296 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 167 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED ©2021 FINRA. All rights reserved. Report aboutTO THE WELLS SANCTIONS FARGO CLEARING AND SERVICES,TO THE ENTRY LLC OF FINDINGS THAT IT FAILED TO 29 MAKE AND PRESERVE ACCURATE BOOKS AND RECORDS. THE FINDINGS STATED THAT THE FIRM FAILED TO RECORD AN ACCURATE ORDER RECEIPT TIME IN CERTAIN SITUATIONS WHEN REGISTERED REPRESENTATIVES ENTERED THE ORDER RECEIPT TIME MANUALLY. THE MOST COMMON EXAMPLES OF THESE INSTANCES OCCURRED WHEN LARGE ORDERS REQUIRED APPROVAL, OR OTHER UNIQUE SITUATIONS WHERE, AFTER RECEIVING THE ORDER FROM THE CUSTOMER, THE REPRESENTATIVE HAD TO SEEK APPROVAL FROM HIS OR HER MANAGER OR OTHERS BEFORE ENTERING THE ORDER INTO THE FIRM'S SYSTEM. THE FIRM'S REPRESENTATIVES ENTERED INACCURATE ORDER RECEIPT TIMES IN DIFFERENT WAYS. ALTHOUGH OATS REQUIRES REPORTING IN EASTERN MILITARY TIME, SOME OF THE FIRM'S REPRESENTATIVES ENTERED ORDER TIMES REFLECTING ANOTHER TIME ZONE OR IN 12- HOUR TIME. IN ADDITION, SOME OF THE FIRM'S REPRESENTATIVES ENTERED ORDERS WITH "00" SECONDS IN THE TIME STAMP WHEN "00" SECONDS WAS INACCURATE. THE FINDINGS ALSO STATED THAT THE FIRM POPULATED THE ORDER RECEIPT TIME FIELD IN ITS OATS SUBMISSIONS WITH THE TIME THAT WAS ENTERED IN ITS ORDER MANAGEMENT SYSTEM. THUS, THE INCLUSION OF INACCURATE RECEIPT TIMES IN THE FIRM'S SYSTEM ALSO CAUSED THE FIRM TO SUBMIT INACCURATE SUBMISSIONS TO OATS. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO REPORT A DESK RECEIPT TIME STAMP TO OATS. THE FAILURE TO REPORT WAS CAUSED BY AN AUTOMATION ISSUE; THE FIRM'S SYSTEM WAS NOT SET UP TO REPORT DESK RECEIPT TIMES TO OATS. FINRA FOUND THAT THE FIRM REPORTED ORDERS TO OATS WITH AN ACCOUNT TYPE CODE THAT IS USED WHEN AN ORDER IS ORIGINATED IN A FIRM'S ERROR ACCOUNT. THESE INSTANCES INVOLVED TRADE CORRECTIONS OF CUSTOMER ORDERS, BUT THE FIRM FAILED TO SUBMIT REPORTS WITH THE ACCOUNT TYPE CODE FOR THE CUSTOMER ORDERS THAT WERE CORRECTED. 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 MAKE AND PRESERVE ACCURATE BOOKS AND RECORDS. THE FINDINGS STATED THAT THE FIRM FAILED TO RECORD AN ACCURATE ORDER RECEIPT TIME IN CERTAIN SITUATIONS WHEN REGISTERED REPRESENTATIVES ENTERED THE ORDER RECEIPT TIME MANUALLY. THE MOST COMMON EXAMPLES OF THESE INSTANCES OCCURRED WHEN LARGE ORDERS REQUIRED APPROVAL, OR OTHER UNIQUE SITUATIONS WHERE, AFTER RECEIVING THE ORDER FROM THE CUSTOMER, THE REPRESENTATIVE HAD TO SEEK APPROVAL FROM HIS OR HER MANAGER OR OTHERS BEFORE ENTERING THE ORDER INTO THE FIRM'S SYSTEM. THE FIRM'S REPRESENTATIVES ENTERED INACCURATE ORDER RECEIPT TIMES IN DIFFERENT WAYS. ALTHOUGH OATS REQUIRES REPORTING IN EASTERN MILITARY TIME, SOME OF THE FIRM'S REPRESENTATIVES ENTERED ORDER TIMES REFLECTING ANOTHER TIME ZONE OR IN 12- HOUR TIME. IN ADDITION, SOME OF THE FIRM'S REPRESENTATIVES ENTERED ORDERS WITH "00" SECONDS IN THE TIME STAMP WHEN "00" SECONDS WAS INACCURATE. THE FINDINGS ALSO STATED THAT THE FIRM POPULATED THE ORDER RECEIPT TIME FIELD IN ITS OATS SUBMISSIONS WITH THE TIME THAT WAS ENTERED IN ITS ORDER MANAGEMENT SYSTEM. THUS, THE INCLUSION OF INACCURATE RECEIPT TIMES IN THE FIRM'S SYSTEM ALSO CAUSED THE FIRM TO SUBMIT INACCURATE SUBMISSIONS TO OATS. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO REPORT A DESK RECEIPT TIME STAMP TO OATS. THE FAILURE TO REPORT WAS CAUSED BY AN AUTOMATION ISSUE; THE FIRM'S SYSTEM WAS NOT SET UP TO REPORT DESK RECEIPT TIMES TO OATS. FINRA FOUND THAT THE FIRM REPORTED ORDERS TO OATS WITH AN ACCOUNT TYPE CODE THAT IS USED WHEN AN ORDER IS ORIGINATED IN A FIRM'S ERROR ACCOUNT. THESE INSTANCES INVOLVED TRADE CORRECTIONS OF CUSTOMER ORDERS, BUT THE FIRM FAILED TO SUBMIT REPORTS WITH THE ACCOUNT TYPE CODE FOR THE CUSTOMER ORDERS THAT WERE CORRECTED. Initiated By: FINRA Date Initiated: 11/25/2020 Docket/Case Number: 2017054001501

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: 11/25/2020 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 Monetary/Fine $75,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $75,000. FINE PAID IN FULL ON DECEMBER 10, 2020. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, FAILED TO MAKE ACCURATE ORDER MEMORANDA IN VIOLATION OF RULE 17A-3(A)(6) UNDER THE SECURITIES EXCHANGE ACT OF 1934 AND FINRA RULES 4511 AND 2010, AND TRANSMITTED INACCURATE REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) IN VIOLATION OF FINRA RULES 7450 AND 2010. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 11/25/2020 Docket/Case Number: 2017054001501

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: 11/25/2020 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine WELLS FARGO $75,000.00 CLEARING SERVICES, LLC 31 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $75,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM PAID A FINE TO FINRA IN THE AMOUNT OF $75,000, AND THE FIRM WAS ALSO CENSURED BY FINRA. Firm Statement THE FIRM ENTERED INTO AN AWC AGREEMENT WITH FINRA ON NOVEMBER 25, 2020, FULLY RESOLVING THIS MATTER, WHICH INCLUDED AGREEMENT TO THE ENTRY OF A CENSURE AGAINST THE FIRM AND A FINE PAYABLE TO FINRA IN THE AMOUNT OF $75,000. FINRA RECEIVED THE FINE ON DECEMBER 10, 2020. i Disclosure 2 of 167 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 DISTRIBUTED 6,851 ACCOUNT STATEMENTS TO CUSTOMERS CONTAINING VALUATION INFORMATION FOR ONE OR MORE DIRECT PARTICIPATION PROGRAMS (DPPS) OR REAL ESTATE INVESTMENT TRUSTS (REITS) THAT DID NOT COMPLY WITH NASD RULE 2340(C). THE FINDINGS STATED THAT BEGINNING WITH AMENDMENTS THAT TOOK EFFECT ON APRIL 11, 2016, NASD RULE 2340(C) REQUIRED FINRA MEMBERS TO USE EITHER OF TWO APPROVED METHODOLOGIES WHEN PROVIDING PER-SHARE ESTIMATED VALUES FOR DPP AND UNLISTED REIT SECURITIES ON CUSTOMER ACCOUNT STATEMENTS. THE FIRM OBTAINED MUCH OF ITS VALUATION DATA REGARDING DPP AND REIT SECURITIES FROM THIRD-PARTY VENDORS. ONE OF THE FIRM'S THIRD-PARTY VALUATION VENDORS SENT IT A LETTER IDENTIFYING SEVERAL DOZEN DPP AND REIT SECURITIES FOR WHICH IT WAS UNABLE TO PROVIDE RULE-COMPLIANT, PER SHARE ESTIMATED VALUES. THAT VENDOR PROVIDED THE FIRM WITH APRIL 2016 VALUATION DATA, WHICH INCLUDED ZEROS AS VALUATIONS FOR THOSE DPPS AND REITS FOR WHICH COMPLIANT VALUATIONS WERE UNAVAILABLE. WHEN THE FIRM CREATED ITS CUSTOMER ACCOUNT STATEMENTS AT THE END OF APRIL 2016, HOWEVER, THE FIRM'S SECURITY PRICING TEAM MANUALLY OVERRODE THE ZEROS THAT THE FIRM'S THIRD-PARTY VALUATION VENDOR HAD PROVIDED FOR 33 DPP AND REIT SECURITIES, AND INSTEAD POPULATED THE APRIL 2016 STATEMENTS FOR CUSTOMERS HOLDING THOSE SECURITIES WITH THE VALUATIONS THAT THE VENDOR SUPPLIED FOR THOSE POSITIONS THE PREVIOUS MONTH, BEFORE THE RULE CHANGE. THUS, RATHER THAN LEARNING THAT COMPLIANT VALUATIONS WERE NOT AVAILABLE, CUSTOMERS WHO OWNED ONE OR MORE OF THE AFFECTED DPPS OR REITS RECEIVED ACCOUNT STATEMENTS SHOWING OUTDATED ©2021 FINRA. All rights reserved. Report aboutVALUATIONS WELLS FARGO FOR CLEARING THOSE SERVICES, HOLDINGS. LLC BECAUSE THOSE EARLIER 32 VALUATIONS DID NOT DERIVE FROM EITHER APPROVED METHODOLOGY, THEY DID NOT COMPLY WITH RULE 2340(C). THE FIRM'S DISTRIBUTION OF MONTHLY AND QUARTERLY CUSTOMER ACCOUNT STATEMENTS WITH NONCOMPLIANT VALUATIONS FOR SOME DPP AND REIT SECURITIES CONTINUED THROUGH OCTOBER 2016, ALTHOUGH THE NUMBER OF SECURITIES WITH NONCOMPLIANT VALUATIONS APPEARING ON SUCH STATEMENTS DECLINED TO EITHER FIVE OR SIX PER MONTH AFTER MAY 2016, AS THE FIRM NO LONGER HELD CERTAIN DPP AND REIT POSITIONS WITH NON-COMPLIANT VALUATIONS ON ITS BOOKS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH NASD RULE 2340(C). THE FIRM FAILED TO ENSURE THAT APPROPRIATE SUPERVISORY PERSONNEL OVERSAW AND REVIEWED THE SECURITY PRICING TEAM'S ACTIVITIES REGARDING DPP AND REIT SECURITIES. IN PARTICULAR, THE FIRM FAILED TO REQUIRE ANY SUPERVISORY REVIEW OF INSTANCES IN WHICH THE SECURITY PRICING TEAM MANUALLY OVERRODE VENDOR-SUPPLIED VALUATION DATA FOR DPPS AND REITS. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO MAINTAIN ACCURATE BOOKS AND RECORDS WHEN IT CREATED AND DISTRIBUTED MONTHLY AND QUARTERLY ACCOUNT STATEMENTS THAT CONTAINED NONCOMPLIANT VALUATIONS FOR DPP AND REIT SECURITIES. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DISTRIBUTED 6,851 ACCOUNT STATEMENTS TO CUSTOMERS CONTAINING VALUATION INFORMATION FOR ONE OR MORE DIRECT PARTICIPATION PROGRAMS (DPPS) OR REAL ESTATE INVESTMENT TRUSTS (REITS) THAT DID NOT COMPLY WITH NASD RULE 2340(C). THE FINDINGS STATED THAT BEGINNING WITH AMENDMENTS THAT TOOK EFFECT ON APRIL 11, 2016, NASD RULE 2340(C) REQUIRED FINRA MEMBERS TO USE EITHER OF TWO APPROVED METHODOLOGIES WHEN PROVIDING PER-SHARE ESTIMATED VALUES FOR DPP AND UNLISTED REIT SECURITIES ON CUSTOMER ACCOUNT STATEMENTS. THE FIRM OBTAINED MUCH OF ITS VALUATION DATA REGARDING DPP AND REIT SECURITIES FROM THIRD-PARTY VENDORS. ONE OF THE FIRM'S THIRD-PARTY VALUATION VENDORS SENT IT A LETTER IDENTIFYING SEVERAL DOZEN DPP AND REIT SECURITIES FOR WHICH IT WAS UNABLE TO PROVIDE RULE-COMPLIANT, PER SHARE ESTIMATED VALUES. THAT VENDOR PROVIDED THE FIRM WITH APRIL 2016 VALUATION DATA, WHICH INCLUDED ZEROS AS VALUATIONS FOR THOSE DPPS AND REITS FOR WHICH COMPLIANT VALUATIONS WERE UNAVAILABLE. WHEN THE FIRM CREATED ITS CUSTOMER ACCOUNT STATEMENTS AT THE END OF APRIL 2016, HOWEVER, THE FIRM'S SECURITY PRICING TEAM MANUALLY OVERRODE THE ZEROS THAT THE FIRM'S THIRD-PARTY VALUATION VENDOR HAD PROVIDED FOR 33 DPP AND REIT SECURITIES, AND INSTEAD POPULATED THE APRIL 2016 STATEMENTS FOR CUSTOMERS HOLDING THOSE SECURITIES WITH THE www.finra.org/brokercheck VALUATIONS THAT THE VENDOR SUPPLIED FOR THOSE POSITIONS THE User Guidance PREVIOUS MONTH, BEFORE THE RULE CHANGE. THUS, RATHER THAN LEARNING THAT COMPLIANT VALUATIONS WERE NOT AVAILABLE, CUSTOMERS WHO OWNED ONE OR MORE OF THE AFFECTED DPPS OR REITS RECEIVED ACCOUNT STATEMENTS SHOWING OUTDATED VALUATIONS FOR THOSE HOLDINGS. BECAUSE THOSE EARLIER VALUATIONS DID NOT DERIVE FROM EITHER APPROVED METHODOLOGY, THEY DID NOT COMPLY WITH RULE 2340(C). THE FIRM'S DISTRIBUTION OF MONTHLY AND QUARTERLY CUSTOMER ACCOUNT STATEMENTS WITH NONCOMPLIANT VALUATIONS FOR SOME DPP AND REIT SECURITIES CONTINUED THROUGH OCTOBER 2016, ALTHOUGH THE NUMBER OF SECURITIES WITH NONCOMPLIANT VALUATIONS APPEARING ON SUCH STATEMENTS DECLINED TO EITHER FIVE OR SIX PER MONTH AFTER MAY 2016, AS THE FIRM NO LONGER HELD CERTAIN DPP AND REIT POSITIONS WITH NON-COMPLIANT VALUATIONS ON ITS BOOKS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH NASD RULE 2340(C). THE FIRM FAILED TO ENSURE THAT APPROPRIATE SUPERVISORY PERSONNEL OVERSAW AND REVIEWED THE SECURITY PRICING TEAM'S ACTIVITIES REGARDING DPP AND REIT SECURITIES. IN PARTICULAR, THE FIRM FAILED TO REQUIRE ANY SUPERVISORY REVIEW OF INSTANCES IN WHICH THE SECURITY PRICING TEAM MANUALLY OVERRODE VENDOR-SUPPLIED VALUATION DATA FOR DPPS AND REITS. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO MAINTAIN ACCURATE BOOKS AND RECORDS WHEN IT CREATED AND DISTRIBUTED MONTHLY AND QUARTERLY ACCOUNT STATEMENTS THAT CONTAINED NONCOMPLIANT VALUATIONS FOR DPP AND REIT SECURITIES. Initiated By: FINRA Date Initiated: 11/04/2020 Docket/Case Number: 2016051352401

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/04/2020 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 WELLS FARGO CLEARING SERVICES, LLC 33 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 $300,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $300,000. FINE PAID IN FULL ON NOVEMBER 25, 2020. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT, FROM APRIL 2016 THROUGH OCTOBER OF 2016, THE FIRM DISTRIBUTED 6,851 ACCOUNT STATEMENTS TO CUSTOMERS CONTAINING VALUATION INFORMATION FOR ONE OR MORE DIRECT PARTICIPATION PROGRAMS (DPPS) OR REAL ESTATE INVESTMENT TRUSTS (REITS) THAT DID NOT COMPLY WITH NASD RULE 2340(C). THE FIRM ALSO FAILED TO ESTABLISH AND MAINTAIN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ENSURE THAT ITS CUSTOMER ACCOUNT STATEMENTS REFLECTED DPP AND REIT PRICES DERIVED FROM A VALUATION METHODOLOGY ALLOWED BY NASD RULE 2340 (C). FOR THE SAME REASONS THE FIRM ALSO FAILED TO MAINTAIN ACCURATE BOOKS AND RECORDS VIOLATING FINRA RULES 3110(A) AND (B), 4511 AND 2010 Initiated By: FINRA Date Initiated: 11/04/2020 Docket/Case Number: 2016051352401

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

Resolution: Acceptance, Waiver & Consent(AWC)

Resolution Date: 11/04/2020 Sanctions Ordered: Censure Monetary/Fine $300,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM IS ORDERED TO PAY A FINE TO FINRA IN THE AMOUNT OF $300,000, AND, THE FIRM WAS CENSURED BY FINRA. (13) THE FIRM ENTERED INTO AN AWC AGREEMENT WITH FINRA ON NOVEMBER 4, 2020, FULLY RESOLVING THIS MATTER, WHICH INCLUDED AN AGREEMENT TO THE ENTRY OF A CENSURE AGAINST THE FIRM, AND AN AGREEMENT TO PAY A FINE TO FINRA IN THE AMOUNT OF $300,000, AS SET FORTH IN THE AGREEMENT. i Disclosure 3 of 167 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, TOGETHER WITH ANOTHER MEMBER FIRM, FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND FAILED TO ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS), THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA'S SUITABILITY RULE AS IT PERTAINS TO SWITCHES FROM VARIABLE ANNUITIES TO INVESTMENT COMPANY PRODUCTS. THE FINDINGS STATED THAT IN SPITE OF THE WSPS' DIRECTIVE THAT SUPERVISORS REVIEW THE SUITABILITY OF PRODUCT SWITCHES, THE FIRMS FAILED TO ENSURE THAT SUCH REVIEWS HAPPENED WHEN ITS REPRESENTATIVES RECOMMENDED THAT CUSTOMERS SWITCH FROM A VARIABLE ANNUITY TO AN INVESTMENT COMPANY PRODUCT. NOTWITHSTANDING THE REFERENCE IN THE WSPS TO SWITCH ALERTS GENERATED BY THE FIRM'S SUPERVISORY SYSTEM, THERE WAS NO SWITCH ALERT TO IDENTIFY SWITCHES FROM VARIABLE ANNUITIES TO INVESTMENT COMPANY PRODUCTS AND THEREFORE THE FIRM DID NOT SEND SWITCH LETTERS. INDEED, THE FIRM DID NOT OBTAIN FROM VARIABLE ANNUITY ISSUERS DATA SUFFICIENT TO REVIEW THE SUITABILITY OF VARIABLE ANNUITY SURRENDERS AND SUBSEQUENT SWITCHES, INCLUDING SURRENDER FEES. THE FIRMS' REGISTERED REPRESENTATIVES RECOMMENDED POTENTIALLY UNSUITABLE SWITCHES INVOLVING THE SALE OF A VARIABLE ANNUITY TO PURCHASE INVESTMENT COMPANY PRODUCTS. BECAUSE THE FIRMS DID NOT HAVE AN ALERT TO FLAG SWITCHES, NO QUALIFIED SUPERVISOR REVIEWED THE SWITCHES TO DETERMINE IF THEY WERE SUITABLE AND BASED ON CUSTOMERS' FINANCIAL NEEDS AND INVESTMENT OBJECTIVES. COLLECTIVELY, THE POTENTIALLY UNSUITABLE SWITCHES CAUSED ©2021 FINRA. All rights reserved. Report aboutCUSTOMERS WELLS FARGO TO CLEARING PAY $1,445,167.50 SERVICES, LLC IN UNNECESSARY SURRENDER FEES 35 (FROM SURRENDERING THE VARIABLE ANNUITY) AND UPFRONT SALES CHARGES (ASSOCIATED WITH THE PURCHASE OF THE INVESTMENT COMPANY PRODUCT). FOLLOWING THE FIRMS' DISCOVERY OF THE DEFICIENCIES IN ITS SUPERVISION OF SWITCHES INVOLVING VARIABLE ANNUITIES, THEY TOOK SEVERAL STEPS TO IMPROVE THEIR SUPERVISION OF SUCH TRANSACTIONS, INCLUDING DEVELOPING A SWITCH ALERT TO IDENTIFY WHEN THE PROCEEDS FROM A VARIABLE ANNUITY LIQUIDATION ARE USED TO PURCHASE AN INVESTMENT COMPANY PRODUCT. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, TOGETHER WITH ANOTHER MEMBER FIRM, FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND FAILED TO ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS), THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA'S SUITABILITY RULE AS IT PERTAINS TO SWITCHES FROM VARIABLE ANNUITIES TO INVESTMENT COMPANY PRODUCTS. THE FINDINGS STATED THAT IN SPITE OF THE WSPS' DIRECTIVE THAT SUPERVISORS REVIEW THE SUITABILITY OF PRODUCT SWITCHES, THE FIRMS FAILED TO ENSURE THAT SUCH REVIEWS HAPPENED WHEN ITS REPRESENTATIVES RECOMMENDED THAT CUSTOMERS SWITCH FROM A VARIABLE ANNUITY TO AN INVESTMENT COMPANY PRODUCT. NOTWITHSTANDING THE REFERENCE IN THE WSPS TO SWITCH ALERTS GENERATED BY THE FIRM'S SUPERVISORY SYSTEM, THERE WAS NO SWITCH ALERT TO IDENTIFY SWITCHES FROM VARIABLE ANNUITIES TO INVESTMENT COMPANY PRODUCTS AND THEREFORE THE FIRM DID NOT SEND SWITCH LETTERS. INDEED, THE FIRM DID NOT OBTAIN FROM VARIABLE ANNUITY ISSUERS DATA SUFFICIENT TO REVIEW THE SUITABILITY OF VARIABLE ANNUITY SURRENDERS AND SUBSEQUENT SWITCHES, INCLUDING SURRENDER FEES. THE FIRMS' REGISTERED REPRESENTATIVES RECOMMENDED POTENTIALLY UNSUITABLE SWITCHES INVOLVING THE SALE OF A VARIABLE ANNUITY TO PURCHASE www.finra.org/brokercheck INVESTMENT COMPANY PRODUCTS. BECAUSE THE FIRMS DID NOT HAVE User Guidance AN ALERT TO FLAG SWITCHES, NO QUALIFIED SUPERVISOR REVIEWED THE SWITCHES TO DETERMINE IF THEY WERE SUITABLE AND BASED ON CUSTOMERS' FINANCIAL NEEDS AND INVESTMENT OBJECTIVES. COLLECTIVELY, THE POTENTIALLY UNSUITABLE SWITCHES CAUSED CUSTOMERS TO PAY $1,445,167.50 IN UNNECESSARY SURRENDER FEES (FROM SURRENDERING THE VARIABLE ANNUITY) AND UPFRONT SALES CHARGES (ASSOCIATED WITH THE PURCHASE OF THE INVESTMENT COMPANY PRODUCT). FOLLOWING THE FIRMS' DISCOVERY OF THE DEFICIENCIES IN ITS SUPERVISION OF SWITCHES INVOLVING VARIABLE ANNUITIES, THEY TOOK SEVERAL STEPS TO IMPROVE THEIR SUPERVISION OF SUCH TRANSACTIONS, INCLUDING DEVELOPING A SWITCH ALERT TO IDENTIFY WHEN THE PROCEEDS FROM A VARIABLE ANNUITY LIQUIDATION ARE USED TO PURCHASE AN INVESTMENT COMPANY PRODUCT. Initiated By: FINRA Date Initiated: 09/02/2020 Docket/Case Number: 2016052124001

Principal Product Type: Annuity(ies) - Variable Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/02/2020 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 Monetary/Fine $625,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED, FINED $625,000 AND ORDERED TO PAY $1,355,499.19, PLUS INTEREST IN RESTITUTION TO CUSTOMERS. FINES PAID IN FULL ON SEPTEMBER 16, 2020. i Reporting Source: Firm

Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, TOGETHER WITH ANOTHER MEMBER FIRM, FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND FAILED TO ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS), THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA'S SUITABILITY RULE AS IT PERTAINS TO SWITCHES FROM VARIABLE ANNUITIES TO INVESTMENT COMPANY PRODUCTS. AS A RESULT THE FIRM IS ALLEGED TO HAVE VIOLATED NASD RULE 3010 AND FINRA RULES 3110 AND 2010 Initiated By: FINRA Date Initiated: 09/02/2020 Docket/Case Number: 2016052124001

Principal Product Type: Annuity(ies) - Variable Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief RESTITUTION, OTHER, AND CIVIL AND ADMINISTRATIVE PENALTY/FINES Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/02/2020 Sanctions Ordered: Censure Monetary/Fine $625,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE FIRM PAID A FINE TO FINRA IN THE AMOUNT OF $625,000, AND IS TO PAY RESTITUTION TO CUSTOMERS IN THE AMOUNT OF $1,355,499.19, PLUS INTEREST ON THAT AMOUNT, AND THE FIRM WAS ALSO CENSURED BY FINRA. Firm Statement THE FIRM ENTERED INTO AN AWC AGREEMENT WITH FINRA ON SEPTEMBER 2, 2020, FULLY RESOLVING THIS MATTER, WHICH INCLUDED AGREEMENT TO THE ENTRY OF A CENSURE AGAINST THE FIRM, A FINE PAYABLE TO FINRA IN THE AMOUNT OF $625,000, AND RESTITUTION TO THE CUSTOMERS IN THE AMOUNT OF $1,355,499.19, PLUS INTEREST ON THAT AMOUNT, AS SET FORTH IN THE AGREEMENT. FINE RECEIVED BY FINRA SEPTEMBER 16, 2020. i ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 37 www.finra.org/brokercheck User Guidance

i Disclosure 4 of 167 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 REASONABLY SUPERVISE THE ACTIVITIES OF TWO FORMER FIRM REPRESENTATIVES, WHO RECOMMENDED THAT MANY OF THEIR CUSTOMERS INVEST A SUBSTANTIAL PORTION OF THEIR ASSETS AT THE FIRM IN HIGH-RISK ENERGY SECURITIES. THE FINDINGS STATED THAT THE REPRESENTATIVES' CONDUCT GENERATED MULTIPLE RED FLAGS REGARDING OVERCONCENTRATION IN THEIR CUSTOMERS' ACCOUNT THAT RAISED SUITABILITY CONCERNS THAT THE FIRM FAILED TO REASONABLY INVESTIGATE. THE FIRM'S TRADE-REVIEW SYSTEM ISSUED ALERTS THAT CUSTOMERS OF THE REPRESENTATIVES WERE CONCENTRATED IN THE SAME LOW-PRICED, ENERGY SECURITY. THE FIRM'S WSPS ADDRESSED HOW TO INVESTIGATE THESE ALERTS, BUT THE FIRM DID NOT FOLLOW ITS PROCEDURES IN RESPONDING TO THEM. SPECIFICALLY, THE WSPS REQUIRED REVIEWERS TO LOOK FOR ANY TRENDS OF CONCENTRATION ISSUES IN OTHER ACCOUNTS SERVICED BY THE ACCOUNT'S REPRESENTATIVE, REVIEW THE REPRESENTATIVE'S SUITABILITY DETERMINATION, WHICH THE WSPS SAY THE REPRESENTATIVE SHOULD DOCUMENT, AND CONSIDER CLIENT CONTACT. BUT THE FIRM DID NOT REVIEW THE REPRESENTATIVES' OTHER CUSTOMER ACCOUNTS FOR CONCENTRATION TRENDS, AND IN CERTAIN INSTANCES, DID NOT CONSIDER CONTACTING CUSTOMERS DESPITE THE NUMBER OF ALERTS OR CONCERNS ABOUT WHETHER THE CUSTOMERS WERE AWARE OF THE RISKS ASSOCIATED WITH CONCENTRATION. RATHER, IT RESOLVED ALERTS BASED ON THE REPRESENTATIVES' UNCORROBORATED ASSURANCES THAT THEIR CUSTOMERS WERE AWARE OF THE CONCENTRATIONS IN THEIR ACCOUNTS. IN ADDITION, THE FIRM WAS AWARE THAT THE REPRESENTATIVES HAD NOT DOCUMENTED THE CONCENTRATION-SUITABILITY DETERMINATION FOR CERTAIN CUSTOMERS, AS THE FIRM'S WSPS REQUIRED, RAISING A CONCERN REGARDING THE UNDERLYING SUITABILITY OF THEIR RECOMMENDATIONS. THE FIRM KNEW, BUT DID NOT INVESTIGATE, THAT THE REPRESENTATIVES WERE MOVING ENERGY SECURITIES FROM CUSTOMERS' ADVISORY ACCOUNTS INTO BROKERAGE ACCOUNTS TO AVOID THE FIRM'S CONCENTRATION LIMITS IN ADVISORY ACCOUNTS. THIS ATTEMPT TO CIRCUMVENT THE FIRM'S OWN LIMITS WAS A RED FLAG THAT THE REPRESENTATIVES MIGHT BE UNSUITABLY OVERCONCENTRATING CUSTOMER ACCOUNTS IN ENERGY SECURITIES. THE FIRM'S WSPS REQUIRED A DAILY BLOTTER REVIEW TO DETECT UNUSUAL TRADING ACTIVITY OR PATTERNS AND [C]ONCENTRATION. THE TRADE BLOTTERS FOR THE REPRESENTATIVES CONSISTENTLY EVIDENCED THAT THEY ©2021 FINRA. All rights reserved. Report aboutWERE WELLS EFFECTING FARGO CLEARING A HIGH SERVICES, VOLUME LLC OF SALES OF THE HIGH-RISK ENERGY 38 SECURITIES IN CERTAIN OF THEIR CUSTOMERS' ACCOUNTS. YET THE FIRM FAILED TO FOLLOW-UP ON THIS RED FLAG CONCERNING THE REPRESENTATIVES' TRADING. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF TWO FORMER FIRM REPRESENTATIVES, WHO RECOMMENDED THAT MANY OF THEIR CUSTOMERS INVEST A SUBSTANTIAL PORTION OF THEIR ASSETS AT THE FIRM IN HIGH-RISK ENERGY SECURITIES. THE FINDINGS STATED THAT THE REPRESENTATIVES' CONDUCT GENERATED MULTIPLE RED FLAGS REGARDING OVERCONCENTRATION IN THEIR CUSTOMERS' ACCOUNT THAT RAISED SUITABILITY CONCERNS THAT THE FIRM FAILED TO REASONABLY INVESTIGATE. THE FIRM'S TRADE-REVIEW SYSTEM ISSUED ALERTS THAT CUSTOMERS OF THE REPRESENTATIVES WERE CONCENTRATED IN THE SAME LOW-PRICED, ENERGY SECURITY. THE FIRM'S WSPS ADDRESSED HOW TO INVESTIGATE THESE ALERTS, BUT THE FIRM DID NOT FOLLOW ITS PROCEDURES IN RESPONDING TO THEM. SPECIFICALLY, THE WSPS REQUIRED REVIEWERS TO LOOK FOR ANY TRENDS OF CONCENTRATION ISSUES IN OTHER ACCOUNTS SERVICED BY THE ACCOUNT'S REPRESENTATIVE, REVIEW THE REPRESENTATIVE'S SUITABILITY DETERMINATION, WHICH THE WSPS SAY THE REPRESENTATIVE SHOULD DOCUMENT, AND CONSIDER CLIENT CONTACT. BUT THE FIRM DID NOT REVIEW THE REPRESENTATIVES' OTHER CUSTOMER ACCOUNTS FOR CONCENTRATION TRENDS, AND IN CERTAIN INSTANCES, DID NOT CONSIDER CONTACTING CUSTOMERS DESPITE THE NUMBER OF ALERTS OR CONCERNS ABOUT WHETHER THE CUSTOMERS WERE AWARE OF THE RISKS ASSOCIATED WITH CONCENTRATION. RATHER, IT RESOLVED ALERTS BASED ON THE REPRESENTATIVES' UNCORROBORATED ASSURANCES THAT THEIR CUSTOMERS WERE AWARE OF THE CONCENTRATIONS IN THEIR ACCOUNTS. IN ADDITION, THE FIRM WAS AWARE THAT THE REPRESENTATIVES HAD NOT DOCUMENTED THE CONCENTRATION-SUITABILITY DETERMINATION FOR CERTAIN CUSTOMERS, AS THE FIRM'S WSPS REQUIRED, RAISING A CONCERN REGARDING THE UNDERLYING SUITABILITY OF THEIR RECOMMENDATIONS. THE FIRM KNEW, BUT DID NOT INVESTIGATE, THAT THE REPRESENTATIVES WERE MOVING ENERGY SECURITIES FROM CUSTOMERS' ADVISORY ACCOUNTS INTO BROKERAGE ACCOUNTS TO AVOID THE FIRM'S CONCENTRATION LIMITS IN ADVISORY ACCOUNTS. THIS ATTEMPT TO CIRCUMVENT THE FIRM'S OWN LIMITS WAS A RED FLAG THAT THE REPRESENTATIVES MIGHT BE UNSUITABLY OVERCONCENTRATING www.finra.org/brokercheck CUSTOMER ACCOUNTS IN ENERGY SECURITIES. THE FIRM'S WSPS User Guidance REQUIRED A DAILY BLOTTER REVIEW TO DETECT UNUSUAL TRADING ACTIVITY OR PATTERNS AND [C]ONCENTRATION. THE TRADE BLOTTERS FOR THE REPRESENTATIVES CONSISTENTLY EVIDENCED THAT THEY WERE EFFECTING A HIGH VOLUME OF SALES OF THE HIGH-RISK ENERGY SECURITIES IN CERTAIN OF THEIR CUSTOMERS' ACCOUNTS. YET THE FIRM FAILED TO FOLLOW-UP ON THIS RED FLAG CONCERNING THE REPRESENTATIVES' TRADING. Initiated By: FINRA Date Initiated: 08/28/2020 Docket/Case Number: 2015045713304

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: 08/28/2020 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 Monetary/Fine $350,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED, FINED $350,000, AND ORDERED TO PAY $201,498.00, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. FINES PAID IN FULL ON SEPTEMBER 4, 2020. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF TWO FORMER FIRM REPRESENTATIVES, WHO RECOMMENDED THAT MANY OF THEIR CUSTOMERS INVEST A SUBSTANTIAL PORTION OF THEIR ASSETS AT THE FIRM IN HIGH-RISK ENERGY SECURITIES. THE REPRESENTATIVES' ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 39 CONDUCT GENERATED MULTIPLE RED FLAGS REGARDING OVERCONCENTRATION IN THE FIRM'S CUSTOMER ACCOUNTS THAT RAISED SUITABILITY CONCERNS THAT THE FIRM FAILED TO REASONABLY INVESTIGATE. AS A RESULT THE FIRM IS ALLEGED TO HAVE VIOLATED NASD RULE 3010(A) AND FINRA RULES 3110(A) AND 2010 WITHOUT ADMITTING OR DENYING FINDINGS, THE FIRM CONSENTED TO www.finra.org/brokercheck THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO User Guidance REASONABLY SUPERVISE THE ACTIVITIES OF TWO FORMER FIRM REPRESENTATIVES, WHO RECOMMENDED THAT MANY OF THEIR CUSTOMERS INVEST A SUBSTANTIAL PORTION OF THEIR ASSETS AT THE FIRM IN HIGH-RISK ENERGY SECURITIES. THE REPRESENTATIVES' CONDUCT GENERATED MULTIPLE RED FLAGS REGARDING OVERCONCENTRATION IN THE FIRM'S CUSTOMER ACCOUNTS THAT RAISED SUITABILITY CONCERNS THAT THE FIRM FAILED TO REASONABLY INVESTIGATE. AS A RESULT THE FIRM IS ALLEGED TO HAVE VIOLATED NASD RULE 3010(A) AND FINRA RULES 3110(A) AND 2010 Initiated By: FINRA Date Initiated: 08/28/2020 Docket/Case Number: 2015045713304

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/28/2020 Sanctions Ordered: Censure Monetary/Fine $350,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: TOTAL FINE $300,000, 100 PERCENT TO APPLICANT, NO PORTION OF PENALTY WAIVED, AND DATE PAID (DELIVERED TO FINRA) 9/4/2020. Firm Statement THE FIRM ENTERED INTO AN AWC AGREEMENT WITH FINRA ON AUGUST 28, 2020, FULLY RESOLVING THIS MATTER, WHICH INCLUDED AGREEMENT TO THE ENTRY OF A CENSURE AGAINST THE FIRM, A FINE PAYABLE TO FINRA IN THE AMOUNT OF $350,000, AND RESTITUTION IN THE AMOUNT OF $201,498 PLUS INTEREST AS SET FORTH IN THE AGREEMENT. THIS MATTER IS NOW FINAL. i Disclosure 5 of 167 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASE 34-88295; IA RELEASE 5451, FEBRUARY 27, 2020: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ©2021 FINRA. All rights reserved. Report aboutADMINISTRATIVE WELLS FARGO CLEARING AND CEASE-AND-DESIST SERVICES, LLC PROCEEDINGS BE, AND 40 HEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(B)(4) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST WELLS FARGO CLEARING SERVICES, LLC ("WELLS FARGO CLEARING") AND WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC ("WELLS FARGO FINET") (COLLECTIVELY, THE "RESPONDENTS" OR "WELLS FARGO"). WELLS FARGO RECOMMENDED THAT MANY RETAIL INVESTMENT ADVISORY CLIENTS AND BROKERAGE CUSTOMERS (COLLECTIVELY, "CLIENTS") BUY AND HOLD SINGLE-INVERSE EXCHANGE-TRADED FUNDS ("SINGLE-INVERSE ETFS") WITHOUT HAVING ADEQUATE COMPLIANCE POLICIES AND PROCEDURES AND WITHOUT PROVIDING FINANCIAL ADVISORS PROPER TRAINING AND SUPERVISION OF SINGLE-INVERSE ETFS. AS A RESULT, CERTAIN INVESTMENT ADVISER REPRESENTATIVES AND REGISTERED REPRESENTATIVES (REFERRED TO BY WELLS FARGO AS "FINANCIAL ADVISORS") MADE UNSUITABLE RECOMMENDATIONS TO CERTAIN CLIENTS. WELLS FARGO RECOMMENDED THAT CERTAIN RETAIL CLIENTS BUY AND HOLD, IN MANY CASES FOR MONTHS OR YEARS, SINGLE-INVERSE ETFS WITH DAILY RESET FEATURES, INCLUDING IN RETIREMENT ACCOUNTS. SOME OF THESE CLIENTS HAD LITTLE OR NO RELEVANT INVESTING EXPERIENCE AND HAD BEEN IDENTIFIED TO WELLS FARGO AS CLIENTS WITH MODERATE OR CONSERVATIVE RISK TOLERANCES. MOREOVER, SOME OF THESE CLIENTS DID NOT FULLY UNDERSTAND THE RISK OF LOSSES WHEN HOLDING THESE INVERSE ETFS LONG TERM AND WERE NOT AWARE OF THE NEED TO, AND THEREFORE DID NOT, ACTIVELY MONITOR THE POSITIONS. SIMILARLY, SOME WELLS FARGO FINANCIAL ADVISORS WHO RECOMMENDED SINGLE-INVERSE ETFS ALSO DID NOT ADEQUATELY UNDERSTAND THE PRODUCTS OR PROPERLY MONITOR THE POSITIONS. DURING THE RELEVANT PERIOD, THE CLIENTS COLLECTIVELY SUSTAINED MILLIONS OF DOLLARS OF LOSSES IN THE PRODUCT BY HOLDING THE POSITIONS. WELLS FARGO'S POLICIES AND PROCEDURES RELATING TO SINGLE-INVERSE ETFS, WHICH APPLIED TO BOTH ADVISORY AND BROKERAGE ACCOUNTS, WERE NOT REASONABLY DESIGNED TO PREVENT AND DETECT UNSUITABLE RECOMMENDATIONS OF THESE COMPLEX PRODUCTS TO BUY AND HOLD RETAIL INVESTORS. FOR EXAMPLE, WELLS FARGO DID NOT REQUIRE TRAINING ON THESE PRODUCTS FOR ITS FINANCIAL ADVISORS AND SUPERVISORS, OR TAKE OTHER REASONABLE STEPS TO EDUCATE FINANCIAL ADVISORS SO THEY SUFFICIENTLY UNDERSTOOD THE PRODUCTS TO RECOMMEND THEM TO CLIENTS. WELLS FARGO DID NOT ESTABLISH PROCEDURES FOR SUPERVISORS SO THEY COULD REVIEW SINGLE-INVERSE ETF RECOMMENDATIONS AND MONITOR POSITIONS OVER TIME. WELLS FARGO ALSO FAILED TO ADEQUATELY IMPLEMENT THE POLICIES AND PROCEDURES IT HAD IN PLACE. WELLS FARGO WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER BY FAILING TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT UNSUITABLE RECOMMENDATIONS IN VIOLATION OF THE ADVISERS ACT. BECAUSE OF WELLS FARGO'S INADEQUATE TRAINING, COMPLIANCE POLICIES AND PROCEDURES, AND SUPERVISION, CERTAIN WELLS FARGO FINANCIAL ADVISORS MADE UNSUITABLE RECOMMENDATIONS TO THEIR CLIENTS TO BUY AND HOLD SINGLE-INVERSE ETFS IN VIOLATION OF SECTION 17(A)(3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"). ACCORDINGLY, PURSUANT TO ADVISERS ACT SECTION 203(E)(6) AND EXCHANGE ACT SECTION 15(B)(4)(E), WELLS FARGO FAILED REASONABLY TO SUPERVISE ITS FINANCIAL ADVISORS WITH A VIEW TO PREVENTING THE FINANCIAL ADVISORS' VIOLATIONS OF THE ANTIFRAUD PROVISION. www.finra.org/brokercheck User Guidance SEC ADMIN RELEASE 34-88295; IA RELEASE 5451, FEBRUARY 27, 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 15(B)(4) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST WELLS FARGO CLEARING SERVICES, LLC ("WELLS FARGO CLEARING") AND WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC ("WELLS FARGO FINET") (COLLECTIVELY, THE "RESPONDENTS" OR "WELLS FARGO"). WELLS FARGO RECOMMENDED THAT MANY RETAIL INVESTMENT ADVISORY CLIENTS AND BROKERAGE CUSTOMERS (COLLECTIVELY, "CLIENTS") BUY AND HOLD SINGLE-INVERSE EXCHANGE-TRADED FUNDS ("SINGLE-INVERSE ETFS") WITHOUT HAVING ADEQUATE COMPLIANCE POLICIES AND PROCEDURES AND WITHOUT PROVIDING FINANCIAL ADVISORS PROPER TRAINING AND SUPERVISION OF SINGLE-INVERSE ETFS. AS A RESULT, CERTAIN INVESTMENT ADVISER REPRESENTATIVES AND REGISTERED REPRESENTATIVES (REFERRED TO BY WELLS FARGO AS "FINANCIAL ADVISORS") MADE UNSUITABLE RECOMMENDATIONS TO CERTAIN CLIENTS. WELLS FARGO RECOMMENDED THAT CERTAIN RETAIL CLIENTS BUY AND HOLD, IN MANY CASES FOR MONTHS OR YEARS, SINGLE-INVERSE ETFS WITH DAILY RESET FEATURES, INCLUDING IN RETIREMENT ACCOUNTS. SOME OF THESE CLIENTS HAD LITTLE OR NO RELEVANT INVESTING EXPERIENCE AND HAD BEEN IDENTIFIED TO WELLS FARGO AS CLIENTS WITH MODERATE OR CONSERVATIVE RISK TOLERANCES. MOREOVER, SOME OF THESE CLIENTS DID NOT FULLY UNDERSTAND THE RISK OF LOSSES WHEN HOLDING THESE INVERSE ETFS LONG TERM AND WERE NOT AWARE OF THE NEED TO, AND THEREFORE DID NOT, ACTIVELY MONITOR THE POSITIONS. SIMILARLY, SOME WELLS FARGO FINANCIAL ADVISORS WHO RECOMMENDED SINGLE-INVERSE ETFS ALSO DID NOT ADEQUATELY UNDERSTAND THE PRODUCTS OR PROPERLY MONITOR THE POSITIONS. DURING THE RELEVANT PERIOD, THE CLIENTS COLLECTIVELY SUSTAINED MILLIONS OF DOLLARS OF LOSSES IN THE PRODUCT BY HOLDING THE POSITIONS. WELLS FARGO'S POLICIES AND PROCEDURES RELATING TO SINGLE-INVERSE ETFS, WHICH APPLIED TO BOTH ADVISORY AND BROKERAGE ACCOUNTS, WERE NOT REASONABLY DESIGNED TO PREVENT AND DETECT UNSUITABLE RECOMMENDATIONS OF THESE COMPLEX PRODUCTS TO BUY AND HOLD RETAIL INVESTORS. FOR EXAMPLE, WELLS FARGO DID NOT REQUIRE TRAINING ON THESE PRODUCTS FOR ITS FINANCIAL ADVISORS AND SUPERVISORS, OR TAKE OTHER REASONABLE STEPS TO EDUCATE FINANCIAL ADVISORS SO THEY SUFFICIENTLY UNDERSTOOD THE PRODUCTS TO RECOMMEND THEM TO CLIENTS. WELLS FARGO DID NOT ESTABLISH PROCEDURES FOR SUPERVISORS SO THEY COULD REVIEW SINGLE-INVERSE ETF RECOMMENDATIONS AND MONITOR POSITIONS OVER TIME. WELLS FARGO ALSO FAILED TO ADEQUATELY IMPLEMENT THE POLICIES AND PROCEDURES IT HAD IN PLACE. WELLS FARGO WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER ©2021 FINRA. All rights reserved. Report aboutBY FAILING WELLS FARGO TO ADOPT CLEARING AND SERVICES, IMPLEMENT LLC POLICIES AND PROCEDURES 41 REASONABLY DESIGNED TO PREVENT UNSUITABLE RECOMMENDATIONS IN VIOLATION OF THE ADVISERS ACT. BECAUSE OF WELLS FARGO'S INADEQUATE TRAINING, COMPLIANCE POLICIES AND PROCEDURES, AND SUPERVISION, CERTAIN WELLS FARGO FINANCIAL ADVISORS MADE UNSUITABLE RECOMMENDATIONS TO THEIR CLIENTS TO BUY AND HOLD SINGLE-INVERSE ETFS IN VIOLATION OF SECTION 17(A)(3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"). ACCORDINGLY, PURSUANT TO ADVISERS ACT SECTION 203(E)(6) AND EXCHANGE ACT SECTION 15(B)(4)(E), WELLS FARGO FAILED REASONABLY TO SUPERVISE ITS FINANCIAL ADVISORS WITH A VIEW TO PREVENTING THE FINANCIAL ADVISORS' VIOLATIONS OF THE ANTIFRAUD PROVISION. SEC ADMIN RELEASE 34-88295; IA RELEASE 5451, FEBRUARY 27, 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 15(B)(4) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST WELLS FARGO CLEARING SERVICES, LLC ("WELLS FARGO CLEARING") AND WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC ("WELLS FARGO FINET") (COLLECTIVELY, THE "RESPONDENTS" OR "WELLS FARGO"). WELLS FARGO RECOMMENDED THAT MANY RETAIL INVESTMENT ADVISORY CLIENTS AND BROKERAGE CUSTOMERS (COLLECTIVELY, "CLIENTS") BUY AND HOLD SINGLE-INVERSE EXCHANGE-TRADED FUNDS ("SINGLE-INVERSE ETFS") WITHOUT HAVING ADEQUATE COMPLIANCE POLICIES AND PROCEDURES AND WITHOUT PROVIDING FINANCIAL ADVISORS PROPER TRAINING AND SUPERVISION OF SINGLE-INVERSE ETFS. AS A RESULT, CERTAIN INVESTMENT ADVISER REPRESENTATIVES AND REGISTERED REPRESENTATIVES (REFERRED TO BY WELLS FARGO AS "FINANCIAL ADVISORS") MADE UNSUITABLE RECOMMENDATIONS TO CERTAIN CLIENTS. WELLS FARGO RECOMMENDED THAT CERTAIN RETAIL CLIENTS BUY AND HOLD, IN MANY CASES FOR MONTHS OR YEARS, SINGLE-INVERSE ETFS WITH DAILY RESET FEATURES, INCLUDING IN RETIREMENT ACCOUNTS. SOME OF THESE CLIENTS HAD LITTLE OR NO RELEVANT INVESTING EXPERIENCE AND HAD BEEN IDENTIFIED TO WELLS FARGO AS CLIENTS WITH MODERATE OR CONSERVATIVE RISK TOLERANCES. MOREOVER, SOME OF THESE CLIENTS DID NOT FULLY UNDERSTAND THE RISK OF LOSSES WHEN HOLDING THESE INVERSE ETFS LONG TERM AND WERE NOT AWARE OF THE NEED TO, AND THEREFORE DID NOT, ACTIVELY MONITOR THE POSITIONS. SIMILARLY, SOME WELLS FARGO FINANCIAL ADVISORS WHO RECOMMENDED SINGLE-INVERSE ETFS ALSO DID NOT ADEQUATELY UNDERSTAND THE PRODUCTS OR PROPERLY MONITOR THE POSITIONS. DURING THE RELEVANT PERIOD, THE CLIENTS COLLECTIVELY SUSTAINED MILLIONS OF DOLLARS OF LOSSES IN THE PRODUCT BY HOLDING THE POSITIONS. WELLS FARGO'S POLICIES AND PROCEDURES RELATING TO SINGLE-INVERSE ETFS, WHICH APPLIED TO BOTH ADVISORY AND BROKERAGE ACCOUNTS, WERE NOT REASONABLY DESIGNED TO PREVENT AND DETECT UNSUITABLE RECOMMENDATIONS OF THESE COMPLEX PRODUCTS TO BUY AND HOLD RETAIL INVESTORS. FOR EXAMPLE, WELLS FARGO DID NOT REQUIRE TRAINING ON THESE PRODUCTS FOR ITS FINANCIAL ADVISORS AND SUPERVISORS, OR TAKE OTHER REASONABLE STEPS TO EDUCATE FINANCIAL ADVISORS SO THEY SUFFICIENTLY UNDERSTOOD THE PRODUCTS TO RECOMMEND THEM TO CLIENTS. WELLS FARGO DID NOT ESTABLISH PROCEDURES FOR www.finra.org/brokercheck SUPERVISORS SO THEY COULD REVIEW SINGLE-INVERSE ETF User Guidance RECOMMENDATIONS AND MONITOR POSITIONS OVER TIME. WELLS FARGO ALSO FAILED TO ADEQUATELY IMPLEMENT THE POLICIES AND PROCEDURES IT HAD IN PLACE. WELLS FARGO WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER BY FAILING TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT UNSUITABLE RECOMMENDATIONS IN VIOLATION OF THE ADVISERS ACT. BECAUSE OF WELLS FARGO'S INADEQUATE TRAINING, COMPLIANCE POLICIES AND PROCEDURES, AND SUPERVISION, CERTAIN WELLS FARGO FINANCIAL ADVISORS MADE UNSUITABLE RECOMMENDATIONS TO THEIR CLIENTS TO BUY AND HOLD SINGLE-INVERSE ETFS IN VIOLATION OF SECTION 17(A)(3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"). ACCORDINGLY, PURSUANT TO ADVISERS ACT SECTION 203(E)(6) AND EXCHANGE ACT SECTION 15(B)(4)(E), WELLS FARGO FAILED REASONABLY TO SUPERVISE ITS FINANCIAL ADVISORS WITH A VIEW TO PREVENTING THE FINANCIAL ADVISORS' VIOLATIONS OF THE ANTIFRAUD PROVISION. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 02/27/2020 Docket/Case Number: 3-19714

Principal Product Type: Other Other Product Type(s): SINGLE-INVERSE EXCHANGE-TRADED FUNDS Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Order Resolution Date: 02/27/2020 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 $35,000,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: THE FIRM IS CENSURED, FINED, JOINTLY AND SEVERALLY, $35,000,000 AND ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER.

©2021Regulator FINRA. Statement All rights reserved. Report aboutRESPONDENT WELLS FARGO HAS CLEARING SUBMITTED SERVICES, AN LLC OFFER OF SETTLEMENT (THE "OFFER") 42 THAT THE COMMISSION HAS DETERMINED TO ACCEPT. THE FIRM WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, IT IS HEREBY ORDERED THAT THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER, IS CENSURED, AND SHALL PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $35,000,000, ON A JOINT AND SEVERAL BASIS. www.finra.org/brokercheck User Guidance

Regulator Statement RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") THAT THE COMMISSION HAS DETERMINED TO ACCEPT. THE FIRM WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, IT IS HEREBY ORDERED THAT THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER, IS CENSURED, AND SHALL PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $35,000,000, ON A JOINT AND SEVERAL BASIS. i Reporting Source: Firm Current Status: Final Allegations: THE SECURITIES AND EXCHANGE COMMISSION (SEC) CHARGED WELLS FARGO CLEARING SERVICES, LLC AND WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC WITH WILLFULLY VIOLATING SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AND RULE 206(4)-7 THEREUNDER, FAILING REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT AND FAILING REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT). Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 02/27/2020 Docket/Case Number: FILE NO. 3-19714

Principal Product Type: Other Other Product Type(s): SINGLE-INVERSE EXCHANGE-TRADED FUNDS Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 02/27/2020 Sanctions Ordered: Censure Monetary/Fine $35,000,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 43 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: THE CIVIL PENALTY WILL BE PAID OUT WITHIN THE TIMELINE SPECIFIED BY THE ORDER Firm Statement THE COMMISSION FOUND THAT, FROM APRIL 2012 THROUGH SEPTEMBER 2019, THE FIRMS RECOMMENDED THAT MANY RETAIL INVESTMENT ADVISORY CLIENTS AND BROKERAGE CUSTOMERS BUY AND HOLD SINGLE-INVERSE EXCHANGE-TRADED FUNDS (ETFS) WITHOUT HAVING ADEQUATE COMPLIANCE POLICIES AND PROCEDURES AND WITHOUT PROVIDING FINANCIAL ADVISORS PROPER TRAINING AND SUPERVISION OF SINGLE-INVERSE ETFS. THE COMMISSION FOUND THAT, AS A RESULT, CERTAIN INVESTMENT ADVISER REPRESENTATIVES AND REGISTERED REPRESENTATIVES MADE UNSUITABLE RECOMMENDATIONS TO CERTAIN CLIENTS. THE COMMISSION FOUND THAT THE FIRMS WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, FAILED REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT AND FAILED REASONABLY TO FULFILL THEIR SUPERVISORY RESPONSIBILITIES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. THE FIRMS CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE ORDER, TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, (B) BE CENSURED, AND (C) JOINTLY AND SEVERALLY PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $35,000,000. i Disclosure 6 of 167 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 REASONABLY SUPERVISE A FORMER REGISTERED REPRESENTATIVE WHO EXCESSIVELY TRADED EQUITY POSITIONS IN ACCOUNTS BELONG TO AN ELDERLY CUSTOMER. THE FINDINGS STATED THAT THE CUSTOMER WAS 88 YEARS OLD WHEN THE TRADING COMMENCED AND THAT AS A RESULT OF THE EXCESSIVE TRADING SHE PAID AT LEAST $300,000 IN COMMISSIONS AND OTHER FEES. THE FIRM'S COMPUTER PROGRAM FLAGGED THE CUSTOMER'S ACCOUNTS FOR HIGH VELOCITY; HOWEVER, THE FIRM DID NOT REASONABLY ADDRESS THESE FLAGS. FOLLOWING ITS INVESTIGATION, THE FIRM DISCHARGED THE REPRESENTATIVE RESPONSIBLE FOR THE CUSTOMER'S ACCOUNTS. ULTIMATELY, THE FIRM PAID $1 MILLION IN RESTITUTION TO THE CUSTOMER IN SETTLEMENT OF A COMPLAINT THAT SHE FILED REGARDING THE ACTIVITY IN HER ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 44 ACCOUNTS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REASONABLY SUPERVISE A FORMER REGISTERED REPRESENTATIVE WHO EXCESSIVELY TRADED EQUITY POSITIONS IN ACCOUNTS BELONG TO AN ELDERLY CUSTOMER. THE FINDINGS STATED THAT THE CUSTOMER WAS 88 YEARS OLD WHEN THE TRADING COMMENCED AND THAT AS A RESULT OF THE EXCESSIVE TRADING SHE PAID AT LEAST $300,000 IN COMMISSIONS AND OTHER FEES. THE FIRM'S COMPUTER PROGRAM FLAGGED THE CUSTOMER'S ACCOUNTS FOR HIGH VELOCITY; HOWEVER, www.finra.org/brokercheck THE FIRM DID NOT REASONABLY ADDRESS THESE FLAGS. FOLLOWING ITS User Guidance INVESTIGATION, THE FIRM DISCHARGED THE REPRESENTATIVE RESPONSIBLE FOR THE CUSTOMER'S ACCOUNTS. ULTIMATELY, THE FIRM PAID $1 MILLION IN RESTITUTION TO THE CUSTOMER IN SETTLEMENT OF A COMPLAINT THAT SHE FILED REGARDING THE ACTIVITY IN HER ACCOUNTS. Initiated By: FINRA Date Initiated: 01/29/2020 Docket/Case Number: 2017053034301

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/29/2020 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 Monetary/Fine $175,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $175,000. FINE PAID IN FULL ON 2/14/2020. 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 REASONABLY SUPERVISE A FORMER REGISTERED REPRESENTATIVE WHO EXCESSIVELY TRADED EQUITY POSITIONS IN ACCOUNTS BELONG TO AN ELDERLY CUSTOMER. THE FINDINGS STATED THAT THE CUSTOMER WAS 88 YEARS OLD WHEN THE TRADING COMMENCED AND THAT AS A RESULT OF THE EXCESSIVE TRADING SHE PAID AT LEAST $300,000 IN COMMISSIONS AND OTHER FEES. THE FIRM'S COMPUTER PROGRAM FLAGGED THE CUSTOMER'S ACCOUNTS FOR HIGH VELOCITY; HOWEVER, THE FIRM DID NOT REASONABLY ADDRESS THESE FLAGS. FOLLOWING ITS ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 45 INVESTIGATION, THE FIRM DISCHARGED THE REPRESENTATIVE RESPONSIBLE FOR THE CUSTOMER'S ACCOUNTS. ULTIMATELY, THE FIRM PAID $1 MILLION IN RESTITUTION TO THE CUSTOMER IN SETTLEMENT OF A COMPLAINT THAT SHE FILED REGARDING THE ACTIVITY IN HER ACCOUNTS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REASONABLY SUPERVISE A FORMER REGISTERED REPRESENTATIVE WHO EXCESSIVELY TRADED EQUITY POSITIONS IN ACCOUNTS BELONG TO AN ELDERLY CUSTOMER. THE FINDINGS STATED THAT THE CUSTOMER www.finra.org/brokercheck WAS 88 YEARS OLD WHEN THE TRADING COMMENCED AND THAT AS A User Guidance RESULT OF THE EXCESSIVE TRADING SHE PAID AT LEAST $300,000 IN COMMISSIONS AND OTHER FEES. THE FIRM'S COMPUTER PROGRAM FLAGGED THE CUSTOMER'S ACCOUNTS FOR HIGH VELOCITY; HOWEVER, THE FIRM DID NOT REASONABLY ADDRESS THESE FLAGS. FOLLOWING ITS INVESTIGATION, THE FIRM DISCHARGED THE REPRESENTATIVE RESPONSIBLE FOR THE CUSTOMER'S ACCOUNTS. ULTIMATELY, THE FIRM PAID $1 MILLION IN RESTITUTION TO THE CUSTOMER IN SETTLEMENT OF A COMPLAINT THAT SHE FILED REGARDING THE ACTIVITY IN HER ACCOUNTS. Initiated By: FINRA Date Initiated: 01/29/2020 Docket/Case Number: 2017053034301

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/29/2020 Sanctions Ordered: Censure Monetary/Fine $175,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $175,000. i Disclosure 7 of 167 Reporting Source: Firm Current Status: Final Allegations: THE MASSACHUSETTS SECURITIES DIVISION ALLEGED CERTAIN WFCS SUPERVISORS REQUIRED TO BE REGISTERED IN MASSACHUSETTS AND WFCS AGENTS HAD A LAPSE IN MASSACHUSETTS REGISTRATION FOR SOME PERIOD DURING THE RELEVANT TIME PERIOD OF JANUARY 1, 2016 TO JUNE 28, 2018. Initiated By: MASSACHUSETTS SECURITIES DIVISION Date Initiated: 08/26/2019 Docket/Case Number: 2018-0090

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Undertaking Sought: Other Sanction(s)/Relief CEASE AND DESIST, CENSURE, CIVIL AND ADMINISTRATIVE FINE Sought:

Resolution: Consent Resolution Date: 08/26/2019 Sanctions Ordered: Censure Monetary/Fine $450,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ADDITIONAL UNDERTAKINGS Sanction Details: WFCS NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS OR CONCLUSIONS OF LAW CONTAINED IN THE ADMINISTRATIVE CONSENT ORDER, AND CONSENTED TO THE ENTRYOF THE ORDER BY THE DIVISION. WFCS ALSO AGREED TO (1) CEASE AND DESIST, (2) CENSURE BY THE DIVISION, (3) ADDITIONAL UNDERTAKINGS, AND (4) PAY THE DIVISION AN ADMINISTRATIVE FINE IN THE AMOUNT OF $450,000. i Disclosure 8 of 167 Reporting Source: Regulator Current Status: Final Allegations: UNLICENSED BRANCHES Initiated By: NEVADA Date Initiated: 04/13/2018 Docket/Case Number: CI15-011; CI15-013 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: 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: Monetary/Fine $8,000.00 Other Sanctions Ordered: Sanction Details: RESPONDENT ORDERED TO OBTAIN A BRANCH OFFICE LICENSE FOR ALL PLACES OF BUSINESS IN NEVADA FROM WHICH ONE OR MORE SALES REPRESENTATIVES TRANSACT BUSINESS IN ACCORDANCE WITH NRS 90.360(2) AND NAC 90.392. RESPONDENT ORDERED TO PAY A CIVIL PENALTY IN THE AMOUNT OF $8,000.00, AND A TOTAL INSPECTION RECORD FEE OF $1,446.13. Regulator Statement RESPONDENT MAINTAINED UNLICENSED BRANCH OFFICES IN VIOLATION OF NRS 90.360(2) AND NAC 90.392. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED THAT WFCS HAS VIOLATED NRS 90.360(2) AND NAC 90.392 BY MAINTAINING THREE (3) BRANCH OFFICE LOCATIONS IN THE STATE OF NEVADA WITHOUT OBTAINING A LICENSE FROM THE DIVISION Initiated By: STATE OF NEVADA SECURITIES DIVISION Date Initiated: 04/13/2018 Docket/Case Number: CI15-011 AND CI15-013

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: 04/13/2018 Sanctions Ordered: Monetary/Fine $8,000.00 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 48 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $8,000.00 Other Sanctions Ordered: Sanction Details: IN ADDITION TO THE MONETARY PENALTY OF $8500, WFCS IS ORDERED TO PAY $1446.13 FOR COSTS OF INSPECTING TWO BRANCH OFFICES i Disclosure 9 of 167 Reporting Source: Regulator Current Status: Final Allegations: IA RELEASE 40-5199, 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 WELLS FARGO CLEARING SERVICES, 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: 3-19102

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 49 www.finra.org/brokercheck User Guidance

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 deceptive conduct? Sanctions Ordered: Censure Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKINGS AND PREJUDGMENT INTEREST Sanction Details: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL JOINTLY AND SEVERALLY PAY DISGORGEMENT OF $15,037,298.87 AND PREJUDGMENT INTEREST OF $2,326,548.42, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. Regulator Statement RESPONDENT 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 Reporting Source: Firm Current Status: Final Allegations: PURSUANT TO THE SEC SHARE CLASS SELECTION DISCLOSURE INITIATIVE AND WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, WELLS FARGO CLEARING SERVICES LLC ("WCFS") AND WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC ("RESPONDENTS"), JOINTLY AND SEVERALLY, CONSENTED TO THE ENTRY OF A SEC ORDER ALLEGING THAT RESPONDENTS WILLFULLY VIOLATED SECTION 206(2) OF THE ©2021 FINRA. All rights reserved. Report aboutINVESTMENT WELLS FARGO ADVISERS CLEARING ACTSERVICES, OF 1940 LLC ("ADVISERS ACT") AND SECTION 207 50 OF THE ADVISERS ACT, IN THAT RESPONDENTS DID NOT ADEQUATELY DISCLOSE TO THEIR CLIENTS IN EITHER THEIR FORMS ADV OR OTHERWISE THEIR CONFLICTS OF INTEREST RELATING TO (A) THEIR RECEIPT OF 12B-1 FEES AND (B) THEIR SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. PURSUANT TO THE SEC SHARE CLASS SELECTION DISCLOSURE www.finra.org/brokercheck INITIATIVE AND WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, User Guidance WELLS FARGO CLEARING SERVICES LLC ("WCFS") AND WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC ("RESPONDENTS"), JOINTLY AND SEVERALLY, CONSENTED TO THE ENTRY OF A SEC ORDER ALLEGING THAT RESPONDENTS WILLFULLY VIOLATED SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AND SECTION 207 OF THE ADVISERS ACT, IN THAT RESPONDENTS DID NOT ADEQUATELY DISCLOSE TO THEIR CLIENTS IN EITHER THEIR FORMS ADV OR OTHERWISE THEIR CONFLICTS OF INTEREST RELATING TO (A) THEIR RECEIPT OF 12B-1 FEES AND (B) THEIR SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 03/11/2019 Docket/Case Number: 3-19102

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Disgorgement Sought: Other Sanction(s)/Relief CENSURE, CEASE AND DESIST Sought:

Resolution: Order Resolution Date: 03/11/2019 Sanctions Ordered: Censure Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: WITHIN 30-DAYS OF THE ENTRY OF THE ORDER; REVIEW AND UPDATE DISCLOSURES, EVALUATE WHETHER CLIENTS SHOULD BE MOVED TO A LOWER COST SHARE CLASS AND MOVE CLIENT HOLDINGS IF APPROPRIATE, REVIEW EFFECTIVENESS OF APPLICABLE POLICIES AND PROCEDURES, NOTIFY AFFECTED INVESTORS OF THE TERMS OF THE ORDER. WITHIN 40-DAYS OF ENTRY OF THE ORDER, CERTIFY COMPLETION OF ALL SANCTIONS. AS STATED IN THE ORDER, THESE OTHER SANCTIONS WERE CERTIFIED AS COMPLETED PRIOR TO ENTRY OF THE ORDER, EXCEPT THE NOTICE TO AFFECTED INVESTORS AND CERTIFICATION OF THE COMPLETION THEREOF. Sanction Details: WITHIN TEN DAYS OF THE ENTRY OF THE ORDER, PAYMENT OF DISGORGEMENT AND PREJUDGEMENT INTEREST, IN THE AMOUNT OF $17,363,847.29 IS REQUIRED TO BE PAID INTO AN ESCROW FUND FOR DISTRIBUTION TO AFFECTED INVESTORS PURSUANT TO THE TERMS OF THE ORDER Firm Statement THE FIRM SELF-REPORTED TO THE COMMISSION THE VIOLATIONS IN THE ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") SHARE CLASS SELECTION DISCLOSURE INITIATIVE. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 51 www.finra.org/brokercheck User Guidance

THE FIRM SELF-REPORTED TO THE COMMISSION THE VIOLATIONS IN THE ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") SHARE CLASS SELECTION DISCLOSURE INITIATIVE. i Disclosure 10 of 167 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASE 33-10511; 34-83508; IA RELEASE 4947, JUNE 25, 2018: 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 WELLS FARGO ADVISORS, LLC. FROM AT LEAST JANUARY 2009 THROUGH JUNE 2013, CERTAIN REGISTERED REPRESENTATIVES AT WELLS FARGO ADVISORS, LLC (WFA) AND ITS PREDECESSOR WELLS FARGO INVESTMENTS, LLC (WFI) IMPROPERLY SOLICITED CUSTOMERS TO REDEEM THEIR MARKET-LINKED INVESTMENTS (MLI) EARLY AND PURCHASE NEW MLIS WITHOUT ADEQUATE ANALYSIS OR CONSIDERATION OF THE SUBSTANTIAL COSTS ASSOCIATED WITH SUCH TRANSACTIONS. AN MLI IS A FIXED MATURITY FINANCIAL PRODUCT WHOSE INTEREST IS DETERMINED BY THE PERFORMANCE OF A REFERENCE ASSET OR MARKET MEASURE SUCH AS AN EQUITY OR COMMODITY INDEX OVER THE TERM OF THE PRODUCT. MLIS HAVE LIMITED LIQUIDITY AND SIGNIFICANT UPFRONT FEES, AND ACCORDINGLY WFA CONSIDERED THEM TO BE PRODUCTS INTENDED TO BE HELD TO MATURITY AND IN 2011 IMPLEMENTED A POLICY PROHIBITING REPRESENTATIVES FROM ENGAGING IN "SHORT-TERM TRADING" OR "FLIPPING" OF MLIS. NOTWITHSTANDING WFA'S INTERNAL GUIDANCE AND POLICY, AND DESPITE THE ADVERSE ECONOMIC CONSEQUENCES TO WFA CUSTOMERS, CERTAIN WFA REPRESENTATIVES DID NOT REASONABLY INVESTIGATE OR UNDERSTAND THE SIGNIFICANT COSTS OF MLI EXCHANGES. NEVERTHELESS, THEY RECOMMENDED TO THEIR CUSTOMERS THAT THEY REDEEM THEIR MLIS EARLY, TYPICALLY TO REALIZE PROFITS, AND TO USE THE PROCEEDS FROM THOSE REDEMPTIONS TO PURCHASE NEW MLIS. SUPERVISORS ROUTINELY APPROVED THE RECOMMENDATIONS OR THE EXCHANGES. THIS PRACTICE CAUSED CERTAIN WFA CUSTOMERS TO INCUR SIGNIFICANT COSTS AND IMPAIRED THE CUSTOMERS' ABILITY TO ACHIEVE THEIR INVESTMENT OBJECTIVES. AS A CONSEQUENCE, WFA OBTAINED COMMISSIONS BY MEANS OF RECOMMENDATIONS THAT CONTAINED IMPLIED REPRESENTATIONS THAT WFA PERSONNEL HAD FORMED A REASONABLE BASIS FOR THE RECOMMENDATIONS WHEN THEY HAD NOT, IN FACT, DONE SO. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, ©2021 FINRA. All rights reserved. Report aboutWFA WELLS WILLFULLY FARGO CLEARING VIOLATED SERVICES, SECTIONS LLC 17(A)(2) AND 17(A)(3) OF THE 52 SECURITIES ACT. SEC ADMIN RELEASE 33-10511; 34-83508; IA RELEASE 4947, JUNE 25, 2018: 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 WELLS FARGO ADVISORS, LLC. FROM AT LEAST JANUARY 2009 THROUGH JUNE 2013, CERTAIN REGISTERED REPRESENTATIVES AT WELLS FARGO ADVISORS, LLC (WFA) AND ITS PREDECESSOR WELLS FARGO INVESTMENTS, LLC (WFI) IMPROPERLY SOLICITED CUSTOMERS TO REDEEM THEIR MARKET-LINKED INVESTMENTS (MLI) EARLY AND PURCHASE NEW MLIS WITHOUT ADEQUATE ANALYSIS OR CONSIDERATION OF THE SUBSTANTIAL COSTS ASSOCIATED WITH SUCH TRANSACTIONS. AN MLI IS A FIXED MATURITY FINANCIAL PRODUCT WHOSE INTEREST IS DETERMINED BY THE PERFORMANCE OF A REFERENCE ASSET OR MARKET MEASURE SUCH AS AN EQUITY OR COMMODITY INDEX OVER THE TERM OF THE PRODUCT. MLIS HAVE LIMITED LIQUIDITY AND SIGNIFICANT UPFRONT FEES, AND ACCORDINGLY WFA CONSIDERED THEM TO BE PRODUCTS INTENDED TO BE HELD TO MATURITY AND IN 2011 IMPLEMENTED A POLICY PROHIBITING REPRESENTATIVES FROM ENGAGING IN "SHORT-TERM TRADING" OR "FLIPPING" OF MLIS. NOTWITHSTANDING WFA'S INTERNAL GUIDANCE AND POLICY, AND DESPITE THE ADVERSE ECONOMIC CONSEQUENCES TO WFA CUSTOMERS, CERTAIN WFA REPRESENTATIVES DID NOT REASONABLY INVESTIGATE OR UNDERSTAND THE SIGNIFICANT COSTS OF MLI EXCHANGES. NEVERTHELESS, THEY RECOMMENDED TO THEIR CUSTOMERS THAT THEY REDEEM THEIR MLIS EARLY, TYPICALLY TO REALIZE PROFITS, AND TO USE THE PROCEEDS FROM THOSE REDEMPTIONS TO PURCHASE NEW MLIS. SUPERVISORS ROUTINELY APPROVED THE RECOMMENDATIONS OR THE EXCHANGES. THIS PRACTICE CAUSED CERTAIN WFA CUSTOMERS TO INCUR SIGNIFICANT COSTS AND IMPAIRED THE CUSTOMERS' ABILITY TO ACHIEVE THEIR www.finra.org/brokercheck INVESTMENT OBJECTIVES. AS A CONSEQUENCE, WFA OBTAINED User Guidance COMMISSIONS BY MEANS OF RECOMMENDATIONS THAT CONTAINED IMPLIED REPRESENTATIONS THAT WFA PERSONNEL HAD FORMED A REASONABLE BASIS FOR THE RECOMMENDATIONS WHEN THEY HAD NOT, IN FACT, DONE SO. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, WFA WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 06/25/2018 Docket/Case Number: 3-18556

Principal Product Type: Other Other Product Type(s): MARKET-LINKED INVESTMENTS Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Order Resolution Date: 06/25/2018 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 $4,000,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: PREJUDGMENT INTEREST Sanction Details: WFA IS CENSURED, ORDERED TO 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, AND SHALL PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL MONETARY PENALTY TOTALING $5,108,441.27. Regulator Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, 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 HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ©2021 FINRA. All rights reserved. Report aboutARE WELLS ADMITTED, FARGO CLEARINGTHE FIRM SERVICES, CONSENTS LLC TO THE ENTRY OF THIS ORDER 53 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 (ORDER). AS A RESULT OF THE CONDUCT DESCRIBED, WFA WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN WFA'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 WFA IS CENSURED, ORDERED TO 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, AND SHALL PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL MONETARY PENALTY TOTALING $5,108,441.27 AS FOLLOWS: WFA SHALL PAY DISGORGEMENT OF $930,377, WHICH REPRESENTS THE COMMISSIONS WFA EARNED ON REPRESENTATIVES RECURRENT MLI EXCHANGES BETWEEN JANUARY 1, 2009 AND AUGUST 31, 2012, PREJUDGMENT INTEREST THEREON OF $178,064.27, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $4,000,000, CONSISTENT WITH THE PROVISIONS OF THE ORDER. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, 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 www.finra.org/brokercheck BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE User Guidance COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTS TO THE ENTRY OF THIS 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 (ORDER). AS A RESULT OF THE CONDUCT DESCRIBED, WFA WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN WFA'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 WFA IS CENSURED, ORDERED TO 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, AND SHALL PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL MONETARY PENALTY TOTALING $5,108,441.27 AS FOLLOWS: WFA SHALL PAY DISGORGEMENT OF $930,377, WHICH REPRESENTS THE COMMISSIONS WFA EARNED ON REPRESENTATIVES RECURRENT MLI EXCHANGES BETWEEN JANUARY 1, 2009 AND AUGUST 31, 2012, PREJUDGMENT INTEREST THEREON OF $178,064.27, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $4,000,000, CONSISTENT WITH THE PROVISIONS OF THE ORDER. i Reporting Source: Firm Current Status: Final Allegations: SEC ADMIN RELEASE 33-10511; 34-83508; IA RELEASE 4947, JUNE 25, 2018: 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 WELLS FARGO ADVISORS, LLC. FROM AT LEAST JANUARY 2009 THROUGH JUNE 2013, CERTAIN REGISTERED REPRESENTATIVES AT WELLS FARGO ADVISORS, LLC (WFA) AND ITS PREDECESSOR WELLS FARGO INVESTMENTS, LLC (WFI) IMPROPERLY SOLICITED CUSTOMERS TO REDEEM THEIR MARKET-LINKED INVESTMENTS (MLI) EARLY AND PURCHASE NEW MLIS WITHOUT ADEQUATE ANALYSIS OR CONSIDERATION OF THE SUBSTANTIAL COSTS ASSOCIATED WITH SUCH TRANSACTIONS. AN MLI IS A FIXED MATURITY FINANCIAL PRODUCT WHOSE INTEREST IS DETERMINED BY THE PERFORMANCE OF A ©2021 FINRA. All rights reserved. Report aboutREFERENCE WELLS FARGO ASSET CLEARING OR MARKET SERVICES, MEASURE LLC SUCH AS AN EQUITY OR 54 COMMODITY INDEX OVER THE TERM OF THE PRODUCT. MLIS HAVE LIMITED LIQUIDITY AND SIGNIFICANT UPFRONT FEES, AND ACCORDINGLY WFA CONSIDERED THEM TO BE PRODUCTS INTENDED TO BE HELD TO MATURITY AND IN 2011 IMPLEMENTED A POLICY PROHIBITING REPRESENTATIVES FROM ENGAGING IN "SHORT-TERM TRADING" OR "FLIPPING" OF MLIS. NOTWITHSTANDING WFA'S INTERNAL GUIDANCE AND POLICY, AND DESPITE THE ADVERSE ECONOMIC CONSEQUENCES TO WFA CUSTOMERS, CERTAIN WFA REPRESENTATIVES DID NOT REASONABLY INVESTIGATE OR UNDERSTAND THE SIGNIFICANT COSTS OF MLI EXCHANGES. NEVERTHELESS, THEY RECOMMENDED TO THEIR CUSTOMERS THAT THEY REDEEM THEIR MLIS EARLY, TYPICALLY TO REALIZE PROFITS, AND TO USE THE PROCEEDS FROM THOSE REDEMPTIONS TO PURCHASE NEW MLIS. SUPERVISORS ROUTINELY APPROVED THE RECOMMENDATIONS OR THE EXCHANGES. THIS PRACTICE CAUSED CERTAIN WFA CUSTOMERS TO INCUR SIGNIFICANT COSTS AND IMPAIRED THE CUSTOMERS' ABILITY TO ACHIEVE THEIR INVESTMENT OBJECTIVES. AS A CONSEQUENCE, WFA OBTAINED COMMISSIONS BY MEANS OF RECOMMENDATIONS THAT CONTAINED IMPLIED REPRESENTATIONS THAT WFA PERSONNEL HAD FORMED A REASONABLE BASIS FOR THE RECOMMENDATIONS WHEN THEY HAD NOT, IN FACT, DONE SO. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, WFA WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. SEC ADMIN RELEASE 33-10511; 34-83508; IA RELEASE 4947, JUNE 25, 2018: 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 WELLS FARGO ADVISORS, LLC. FROM AT LEAST JANUARY 2009 THROUGH JUNE 2013, CERTAIN REGISTERED REPRESENTATIVES AT WELLS FARGO ADVISORS, LLC (WFA) AND ITS PREDECESSOR WELLS FARGO INVESTMENTS, LLC (WFI) IMPROPERLY SOLICITED CUSTOMERS TO www.finra.org/brokercheck REDEEM THEIR MARKET-LINKED INVESTMENTS (MLI) EARLY AND User Guidance PURCHASE NEW MLIS WITHOUT ADEQUATE ANALYSIS OR CONSIDERATION OF THE SUBSTANTIAL COSTS ASSOCIATED WITH SUCH TRANSACTIONS. AN MLI IS A FIXED MATURITY FINANCIAL PRODUCT WHOSE INTEREST IS DETERMINED BY THE PERFORMANCE OF A REFERENCE ASSET OR MARKET MEASURE SUCH AS AN EQUITY OR COMMODITY INDEX OVER THE TERM OF THE PRODUCT. MLIS HAVE LIMITED LIQUIDITY AND SIGNIFICANT UPFRONT FEES, AND ACCORDINGLY WFA CONSIDERED THEM TO BE PRODUCTS INTENDED TO BE HELD TO MATURITY AND IN 2011 IMPLEMENTED A POLICY PROHIBITING REPRESENTATIVES FROM ENGAGING IN "SHORT-TERM TRADING" OR "FLIPPING" OF MLIS. NOTWITHSTANDING WFA'S INTERNAL GUIDANCE AND POLICY, AND DESPITE THE ADVERSE ECONOMIC CONSEQUENCES TO WFA CUSTOMERS, CERTAIN WFA REPRESENTATIVES DID NOT REASONABLY INVESTIGATE OR UNDERSTAND THE SIGNIFICANT COSTS OF MLI EXCHANGES. NEVERTHELESS, THEY RECOMMENDED TO THEIR CUSTOMERS THAT THEY REDEEM THEIR MLIS EARLY, TYPICALLY TO REALIZE PROFITS, AND TO USE THE PROCEEDS FROM THOSE REDEMPTIONS TO PURCHASE NEW MLIS. SUPERVISORS ROUTINELY APPROVED THE RECOMMENDATIONS OR THE EXCHANGES. THIS PRACTICE CAUSED CERTAIN WFA CUSTOMERS TO INCUR SIGNIFICANT COSTS AND IMPAIRED THE CUSTOMERS' ABILITY TO ACHIEVE THEIR INVESTMENT OBJECTIVES. AS A CONSEQUENCE, WFA OBTAINED COMMISSIONS BY MEANS OF RECOMMENDATIONS THAT CONTAINED IMPLIED REPRESENTATIONS THAT WFA PERSONNEL HAD FORMED A REASONABLE BASIS FOR THE RECOMMENDATIONS WHEN THEY HAD NOT, IN FACT, DONE SO. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, WFA WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 06/25/2018 Docket/Case Number: 3-18556

Principal Product Type: Other Other Product Type(s): MARKET-LINKED INVESTMENTS Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Order Resolution Date: 06/25/2018 Sanctions Ordered: Censure Monetary/Fine $4,000,000.00 Disgorgement/Restitution Cease and Desist/Injunction ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 55 www.finra.org/brokercheck Censure User Guidance Monetary/Fine $4,000,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: PREJUDGMENT INTEREST Sanction Details: WFA IS CENSURED, ORDERED TO 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, AND SHALL PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL MONETARY PENALTY TOTALING $5,108,441.27. Firm Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, 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 HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTS TO THE ENTRY OF THIS 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 (ORDER). AS A RESULT OF THE CONDUCT DESCRIBED, WFA WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN WFA'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 WFA IS CENSURED, ORDERED TO 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, AND SHALL PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL MONETARY PENALTY TOTALING $5,108,441.27 AS FOLLOWS: WFA SHALL PAY DISGORGEMENT OF $930,377, WHICH REPRESENTS THE COMMISSIONS WFA EARNED ON REPRESENTATIVES RECURRENT MLI EXCHANGES BETWEEN JANUARY 1, 2009 AND AUGUST 31, 2012, PREJUDGMENT INTEREST THEREON OF $178,064.27, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $4,000,000, CONSISTENT WITH THE PROVISIONS OF THE ORDER. i Disclosure 11 of 167 Reporting Source: Regulator Current Status: Final

Allegations: SEEING NOTICE OF HEARING AND CONSENT ORDER. Initiated By: STATE OF ILLINOIS, ILLINOIS SECURITIES DEPARTMENT Date Initiated: 12/17/2017 Docket/Case Number: 1500252 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): SEPARATELY MANAGED ACCOUNT PRODUCT Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief NOTICE OF HEARING Sought:

Resolution: Consent Resolution Date: 12/21/2017 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: Other Sanctions Ordered: Sanction Details: MONETARY PAYMENT $270,000.00 Regulator Statement NOTICE OF HEARING WAS ISSUED DECEMBER 21, 2017. CONSENT ORDER WAS ISSUED DECEMBER 21, 2017. CONTACT 217-782-2256. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND THE ENTRY OF FINDINGS THAT IT RECEIVED, REVIEWED AND/OR ANALYZED DOCUMENTS AND INFORMATION FROM A FINANCIAL ADVISORY FIRM CONCERNING CERTAIN MONEY MANAGER STRATEGIES THAT CONTAINED INFORMATION THAT WAS LATER FOUND TO BE FALSE AND MISLEADING. THE FINDINGS STATED THAT THE FIRM INCLUDED THE FINANCIAL ADVISORY FIRM'S MONEY MANAGER STRATEGIES IN CERTAIN OF ITS EXTERNALLY MANAGED SEPARATELY MANAGED ACCOUNT PROGRAMS, BUT THE FIRM DID NOT UTILIZE ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 57 INACCURATE HISTORICAL PERFORMANCE DATA IN CONNECTION WITH ITS DECISION TO ONBOARD THE MONEY MANAGER STRATEGIES AND THE FIRM DID NOT INCORPORATE INACCURATE PERFORMANCE DATA IN ITS ADVERTISEMENTS OR PROGRAM MARKETING MATERIALS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND THE ENTRY OF FINDINGS THAT IT RECEIVED, REVIEWED AND/OR ANALYZED DOCUMENTS AND INFORMATION FROM A FINANCIAL ADVISORY FIRM CONCERNING CERTAIN MONEY MANAGER www.finra.org/brokercheck STRATEGIES THAT CONTAINED INFORMATION THAT WAS LATER FOUND TO User Guidance BE FALSE AND MISLEADING. THE FINDINGS STATED THAT THE FIRM INCLUDED THE FINANCIAL ADVISORY FIRM'S MONEY MANAGER STRATEGIES IN CERTAIN OF ITS EXTERNALLY MANAGED SEPARATELY MANAGED ACCOUNT PROGRAMS, BUT THE FIRM DID NOT UTILIZE INACCURATE HISTORICAL PERFORMANCE DATA IN CONNECTION WITH ITS DECISION TO ONBOARD THE MONEY MANAGER STRATEGIES AND THE FIRM DID NOT INCORPORATE INACCURATE PERFORMANCE DATA IN ITS ADVERTISEMENTS OR PROGRAM MARKETING MATERIALS. Initiated By: STATE OF ILLINOIS, ILLINOIS SECURITIES DEPARTMENT Date Initiated: 12/17/2017 Docket/Case Number: 1500252

Principal Product Type: Other Other Product Type(s): SEPARATELY MANAGED ACCOUNT PRODUCT Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief NOTICE OF HEARING Sought:

Resolution: Consent Resolution Date: 12/21/2017 Sanctions Ordered: Other Sanctions Ordered: Sanction Details: MONETARY PAYMENT $270,000.00 Firm Statement NOTICE OF HEARING WAS ISSUED DECEMBER 21, 2017. CONSENT ORDER WAS ISSUED DECEMBER 21, 2017. i Disclosure 12 of 167 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 EXECUTED SHORT SALE ORDERS IN OVER-THE-COUNTER (OTC) EQUITY SECURITIES AND IMPROPERLY MARKED THE ORDERS AS SHORT EXEMPT. THE FINDINGS STATED THAT THE FIRM EXECUTED SHORT SALE TRANSACTIONS IN OTC EQUITY SECURITIES AND INCORRECTLY REPORTED THE TRANSACTIONS TO THE OTC REPORTING FACILITY WITH SHORT EXEMPT MODIFIERS. Initiated By: FINRA Date Initiated: 12/07/2017 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 58 www.finra.org/brokercheck User Guidance

Date Initiated: 12/07/2017 Docket/Case Number: 2016049334801

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: 12/07/2017 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 $20,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $20,000. FINES PAID IN FULL ON JANUARY 6, 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 IT EXECUTED SHORT SALE ORDERS IN OVER-THE-COUNTER (OTC) EQUITY SECURITIES AND IMPROPERLY MARKED THE ORDERS AS SHORT EXEMPT. THE FINDINGS STATED THAT THE FIRM EXECUTED SHORT SALE TRANSACTIONS IN OTC EQUITY SECURITIES AND INCORRECTLY REPORTED THE TRANSACTIONS TO THE OTC REPORTING FACILITY WITH SHORT EXEMPT MODIFIERS. Initiated By: FINRA Date Initiated: 12/07/2017 Docket/Case Number: 2016049334801

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: 12/07/2017 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $20,000. Firm Statement THE FIRM WAS CENSURED AND FINED $20,000. i Disclosure 13 of 167 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASE 34-82054, NOVEMBER 13, 2017: THE SEC DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AGAINST WELLS FARGO ADVISORS, LLC. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT 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 HEREIN, 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 SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE- AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF WELLS FARGO ADVISORS' FAILURE TO FILE OR TIMELY FILE A NUMBER OF SUSPICIOUS ACTIVITY REPORTS ("SARS") FROM APPROXIMATELY ©2021 FINRA. All rights reserved. Report aboutMARCH WELLS 2012 FARGO THROUGH CLEARING JUNE SERVICES, 2013. LLC THE MAJORITY OF THESE FAILURES 60 INVOLVED THE FAILURE TO TIMELY FILE SARS ON ONGOING SUSPICIOUS ACTIVITY THAT CONTINUED AFTER AN INITIAL SAR FILING BY WELLS FARGO ADVISORS ON RELATED SUSPICIOUS ACTIVITY. AT THE TIME, WELLS FARGO ADVISORS' ANTI-MONEY LAUNDERING ("AML") POLICIES AND PROCEDURES REQUIRED THE FILING OF SARS PURSUANT TO THE REQUIREMENTS OF THE BANK SECRECY ACT ("BSA"), INCLUDING THE FILING OF SARS RELATED TO CONTINUING SUSPICIOUS ACTIVITY. DESPITE THESE REQUIREMENTS, WELLS FARGO ADVISORS FAILED TO FILE OR TIMELY FILE AT LEAST 50 SARS, A MAJORITY OF WHICH RELATED TO CONTINUING SUSPICIOUS ACTIVITY OCCURRING IN ACCOUNTS HELD AT WELLS FARGO ADVISORS' U.S. BRANCH OFFICES THAT FOCUSED ON INTERNATIONAL CUSTOMERS. AS A RESULT OF THIS CONDUCT, WELLS FARGO ADVISORS WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8 THEREUNDER. SEC ADMIN RELEASE 34-82054, NOVEMBER 13, 2017: THE SEC DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AGAINST WELLS FARGO ADVISORS, LLC. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT 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 HEREIN, 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 SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE- www.finra.org/brokercheck AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND RESPONDENT'S User Guidance OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF WELLS FARGO ADVISORS' FAILURE TO FILE OR TIMELY FILE A NUMBER OF SUSPICIOUS ACTIVITY REPORTS ("SARS") FROM APPROXIMATELY MARCH 2012 THROUGH JUNE 2013. THE MAJORITY OF THESE FAILURES INVOLVED THE FAILURE TO TIMELY FILE SARS ON ONGOING SUSPICIOUS ACTIVITY THAT CONTINUED AFTER AN INITIAL SAR FILING BY WELLS FARGO ADVISORS ON RELATED SUSPICIOUS ACTIVITY. AT THE TIME, WELLS FARGO ADVISORS' ANTI-MONEY LAUNDERING ("AML") POLICIES AND PROCEDURES REQUIRED THE FILING OF SARS PURSUANT TO THE REQUIREMENTS OF THE BANK SECRECY ACT ("BSA"), INCLUDING THE FILING OF SARS RELATED TO CONTINUING SUSPICIOUS ACTIVITY. DESPITE THESE REQUIREMENTS, WELLS FARGO ADVISORS FAILED TO FILE OR TIMELY FILE AT LEAST 50 SARS, A MAJORITY OF WHICH RELATED TO CONTINUING SUSPICIOUS ACTIVITY OCCURRING IN ACCOUNTS HELD AT WELLS FARGO ADVISORS' U.S. BRANCH OFFICES THAT FOCUSED ON INTERNATIONAL CUSTOMERS. AS A RESULT OF THIS CONDUCT, WELLS FARGO ADVISORS WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8 THEREUNDER. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 11/13/2017 Docket/Case Number: 3-18279

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

Resolution: Order Resolution Date: 11/13/2017 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 $3,500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: RESPONDENT IS ORDERED TO CEASE AND DESIST; IS CENSURED; AND SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $3,500,000.00.

©2021Regulator FINRA. Statement All rights reserved. Report aboutIN DETERMINING WELLS FARGO CLEARING TO ACCEPT SERVICES, WELLS LLC FARGO ADVISORS' OFFER, THE 61 COMMISSION CONSIDERED VOLUNTARY REMEDIAL ACTS PROMPTLY UNDERTAKEN BY RESPONDENT, INCLUDING THE FIRM'S RETAINING A THIRD PARTY AML COMPLIANCE FIRM TO REVIEW CERTAIN OF ITS SAR INVESTIGATIONS DURING THE SUMMER OF 2014. IN DETERMINING WHETHER TO ACCEPT THE OFFER, THE COMMISSION HAS ALSO CONSIDERED THE UNDERTAKINGS ENUMERATED IN THE ORDER.

Regulator Statement IN DETERMINING TO ACCEPT WELLS FARGO ADVISORS' OFFER, THE COMMISSION CONSIDERED VOLUNTARY REMEDIAL ACTS PROMPTLY UNDERTAKEN BY RESPONDENT, INCLUDING THE FIRM'S RETAINING A THIRD PARTY AML COMPLIANCE FIRM TO REVIEW CERTAIN OF ITS SAR INVESTIGATIONS DURING THE SUMMER OF 2014. IN DETERMINING WHETHER TO ACCEPT THE OFFER, THE COMMISSION HAS ALSO CONSIDERED THE UNDERTAKINGS ENUMERATED IN THE ORDER.

IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT WELLS FARGO ADVISORS' OFFER. ACCORDINGLY, PURSUANT TO SECTIONS 15(B) AND 21C OF THE EXCHANGE ACT IT IS HEREBY ORDERED THAT: RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8 PROMULGATED THEREUNDER; RESPONDENT IS CENSURED; AND RESPONDENT SHALL, WITHIN 30 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $3,500,000.00 TO THE SEC. i Reporting Source: Firm Current Status: Final Allegations: SEC ADMIN RELEASE 34-82054, NOVEMBER 13, 2017: THE SEC DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AGAINST WELLS FARGO ADVISORS, LLC. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT 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 HEREIN, 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 SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE- AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF WELLS FARGO ADVISORS' FAILURE TO FILE OR TIMELY FILE A NUMBER OF SUSPICIOUS ACTIVITY REPORTS ("SARS") FROM APPROXIMATELY MARCH 2012 THROUGH JUNE 2013. THE MAJORITY OF THESE FAILURES ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 62 INVOLVED THE FAILURE TO TIMELY FILE SARS ON ONGOING SUSPICIOUS ACTIVITY THAT CONTINUED AFTER AN INITIAL SAR FILING BY WELLS FARGO ADVISORS ON RELATED SUSPICIOUS ACTIVITY. AT THE TIME, WELLS FARGO ADVISORS' ANTI-MONEY LAUNDERING ("AML") POLICIES AND PROCEDURES REQUIRED THE FILING OF SARS PURSUANT TO THE REQUIREMENTS OF THE BANK SECRECY ACT ("BSA"), INCLUDING THE FILING OF SARS RELATED TO CONTINUING SUSPICIOUS ACTIVITY. DESPITE THESE REQUIREMENTS, WELLS FARGO ADVISORS FAILED TO FILE OR TIMELY FILE AT LEAST 50 SARS, A MAJORITY OF WHICH RELATED TO CONTINUING SUSPICIOUS ACTIVITY OCCURRING IN ACCOUNTS HELD AT WELLS FARGO ADVISORS' U.S. BRANCH OFFICES THAT FOCUSED ON INTERNATIONAL CUSTOMERS. AS A RESULT OF THIS CONDUCT, WELLS FARGO ADVISORS WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8 THEREUNDER. SEC ADMIN RELEASE 34-82054, NOVEMBER 13, 2017: THE SEC DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AGAINST WELLS FARGO ADVISORS, LLC. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT 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 HEREIN, 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 SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE- www.finra.org/brokercheck AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND RESPONDENT'S User Guidance OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF WELLS FARGO ADVISORS' FAILURE TO FILE OR TIMELY FILE A NUMBER OF SUSPICIOUS ACTIVITY REPORTS ("SARS") FROM APPROXIMATELY MARCH 2012 THROUGH JUNE 2013. THE MAJORITY OF THESE FAILURES INVOLVED THE FAILURE TO TIMELY FILE SARS ON ONGOING SUSPICIOUS ACTIVITY THAT CONTINUED AFTER AN INITIAL SAR FILING BY WELLS FARGO ADVISORS ON RELATED SUSPICIOUS ACTIVITY. AT THE TIME, WELLS FARGO ADVISORS' ANTI-MONEY LAUNDERING ("AML") POLICIES AND PROCEDURES REQUIRED THE FILING OF SARS PURSUANT TO THE REQUIREMENTS OF THE BANK SECRECY ACT ("BSA"), INCLUDING THE FILING OF SARS RELATED TO CONTINUING SUSPICIOUS ACTIVITY. DESPITE THESE REQUIREMENTS, WELLS FARGO ADVISORS FAILED TO FILE OR TIMELY FILE AT LEAST 50 SARS, A MAJORITY OF WHICH RELATED TO CONTINUING SUSPICIOUS ACTIVITY OCCURRING IN ACCOUNTS HELD AT WELLS FARGO ADVISORS' U.S. BRANCH OFFICES THAT FOCUSED ON INTERNATIONAL CUSTOMERS. AS A RESULT OF THIS CONDUCT, WELLS FARGO ADVISORS WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8 THEREUNDER. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 11/13/2017 Docket/Case Number: 3-18279

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CENSURE, CIVIL MONEY PENALTY Sought:

Resolution: Order Resolution Date: 11/13/2017 Sanctions Ordered: Censure Monetary/Fine $3,500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: RESPONDENT IS ORDERED TO CEASE AND DESIST; IS CENSURED; AND SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $3,500,000.00. Firm Statement IN DETERMINING TO ACCEPT WELLS FARGO ADVISORS' OFFER, THE COMMISSION CONSIDERED VOLUNTARY REMEDIAL ACTS PROMPTLY UNDERTAKEN BY RESPONDENT, INCLUDING THE FIRM'S RETAINING A THIRD PARTY AML COMPLIANCE FIRM TO REVIEW CERTAIN OF ITS SAR INVESTIGATIONS DURING THE SUMMER OF 2014. IN DETERMINING WHETHER TO ACCEPT THE OFFER, THE COMMISSION HAS ALSO CONSIDERED THE UNDERTAKINGS ENUMERATED IN THE ORDER. IN VIEW ©2021 FINRA. All rights reserved. Report aboutOF THE WELLS FOREGOING, FARGO CLEARING THE SERVICES, COMMISSION LLC DEEMS IT APPROPRIATE AND IN 63 THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT WELLS FARGO ADVISORS' OFFER. ACCORDINGLY, PURSUANT TO SECTIONS 15(B) AND 21C OF THE EXCHANGE ACT IT IS HEREBY ORDERED THAT: RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8 PROMULGATED THEREUNDER; RESPONDENT IS CENSURED; AND RESPONDENT SHALL, WITHIN 30 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $3,500,000.00 TO THE SEC. IN DETERMINING TO ACCEPT WELLS FARGO ADVISORS' OFFER, THE COMMISSION CONSIDERED VOLUNTARY REMEDIAL ACTS PROMPTLY www.finra.org/brokercheck UNDERTAKEN BY RESPONDENT, INCLUDING THE FIRM'S RETAINING A User Guidance THIRD PARTY AML COMPLIANCE FIRM TO REVIEW CERTAIN OF ITS SAR INVESTIGATIONS DURING THE SUMMER OF 2014. IN DETERMINING WHETHER TO ACCEPT THE OFFER, THE COMMISSION HAS ALSO CONSIDERED THE UNDERTAKINGS ENUMERATED IN THE ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT WELLS FARGO ADVISORS' OFFER. ACCORDINGLY, PURSUANT TO SECTIONS 15(B) AND 21C OF THE EXCHANGE ACT IT IS HEREBY ORDERED THAT: RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8 PROMULGATED THEREUNDER; RESPONDENT IS CENSURED; AND RESPONDENT SHALL, WITHIN 30 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $3,500,000.00 TO THE SEC. i Disclosure 14 of 167 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 TRACE THE CORRECT TIME OF TRADE EXECUTION FOR 88 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT TO TRACE 148 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS WITHIN 15 MINUTES OF THE TIME OF EXECUTION. Initiated By: FINRA Date Initiated: 11/06/2017 Docket/Case Number: 2016051812801

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/06/2017 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 WELLS FARGO CLEARING SERVICES, LLC 64 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 $30,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $30,000. FINES PAID IN FULL ON NOVEMBER 17, 2017. 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 REPORT TO TRACE THE CORRECT TIME OF TRADE EXECUTION FOR 88 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT TO TRACE 148 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS WITHIN 15 MINUTES OF THE TIME OF EXECUTION. Initiated By: FINRA Date Initiated: 11/06/2017 Docket/Case Number: 2016051812801

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/06/2017 Sanctions Ordered: Censure Monetary/Fine $30,000.00 Other Sanctions Ordered:

©2021Sanction FINRA. Details: All rights reserved. Report aboutTHE WELLS FIRM FARGOWAS CENSURED CLEARING SERVICES, AND FINED LLC $30,000. FINES PAID IN FULL ON 65 NOVEMBER 17, 2017. www.finra.org/brokercheck User Guidance

Sanction Details: THE FIRM WAS CENSURED AND FINED $30,000. FINES PAID IN FULL ON NOVEMBER 17, 2017. Firm Statement THE FIRM WAS CENSURED AND FINED $30,000. FINES PAID IN FULL ON NOVEMBER 17, 2017. i Disclosure 15 of 167 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 CERTAIN FIRM REGISTERED REPRESENTATIVES RECOMMENDED VOLATILITY-LINKED EXCHANGE-TRADED PRODUCTS (VOLATILITY ETPS) TO BROKERAGE CUSTOMERS WITHOUT FULLY UNDERSTANDING THEIR RISKS AND FEATURES. THE FINDINGS STATED THAT THE FIRM FAILED TO VET OR PLACE RESTRICTIONS ON RECOMMENDATIONS AND PURCHASES OF VOLATILITY ETPS, AND AS A RESULT, THESE PRODUCTS WERE MADE AVAILABLE TO RETAIL BROKERAGE CUSTOMERS REGARDLESS OF RISK PROFILE AND INVESTMENT OBJECTIVE. CERTAIN FIRM REPRESENTATIVES MISTAKENLY BELIEVED THAT VOLATILITY ETPS COULD BE USED AS A LONG-TERM HEDGE ON THEIR CUSTOMERS' EQUITY POSITIONS IN THE EVENT OF A MARKET DOWNTURN. IN FACT, VOLATILITY ETPS ARE GENERALLY SHORT-TERM TRADING PRODUCTS THAT DEGRADE SIGNIFICANTLY OVER TIME AND SHOULD NOT BE USED AS PART OF A LONG-TERM BUY-AND-HOLD INVESTMENT STRATEGY. ACCORDINGLY, IN THOSE INSTANCES, THE REPRESENTATIVES DID NOT HAVE A REASONABLE BASIS TO RECOMMEND VOLATILITY ETPS AS SUITABLE TO CUSTOMERS WITH CONSERVATIVE OR MODERATE RISK PROFILES AND INVESTMENT OBJECTIVES AND THE REPRESENTATIVES FURTHER FAILED TO APPROPRIATELY RECOMMEND THE EXIT OF THESE POSITIONS WITHIN A TIMELY MANNER. IN SOME INSTANCES, CUSTOMERS INCURRED SIGNIFICANT LOSSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN POLICIES AND PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULE 2310 IN CONNECTION WITH ITS SALE OF VOLATILITY ETPS. ALTHOUGH THE FIRM SHOULD HAVE BEEN AWARE OF THE COMPLEXITY AND UNIQUE RISKS AND FEATURES ASSOCIATED WITH VOLATILITY ETPS, THE FIRM FAILED TO IMPLEMENT A REASONABLE SYSTEM TO SUPERVISE ITS REPRESENTATIVES' SOLICITED SALES OF VOLATILITY ETPS. THE FINDINGS ALSO INCLUDED THAT THE FIRM'S SUPERVISORY SYSTEMS ALSO DID NOT INCLUDE REASONABLE TRAINING FOR REGISTERED REPRESENTATIVES AND SUPERVISORS REGARDING THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPS. BECAUSE THE FIRM FAILED TO ESTABLISH AND PROVIDE ©2021 FINRA. All rights reserved. Report aboutREASONABLE WELLS FARGO GUIDANCE, CLEARING SERVICES, TRAINING LLC OR TOOLS TO EDUCATE ITS 66 REGISTERED REPRESENTATIVES AND SUPERVISORS ABOUT VOLATILITY ETPS, CERTAIN RETAIL BROKERAGE CUSTOMERS WERE UNINFORMED ABOUT THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPS PRIOR TO PURCHASING THEM. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT CERTAIN FIRM REGISTERED REPRESENTATIVES RECOMMENDED VOLATILITY-LINKED EXCHANGE-TRADED PRODUCTS (VOLATILITY ETPS) TO BROKERAGE CUSTOMERS WITHOUT FULLY UNDERSTANDING THEIR RISKS AND FEATURES. THE FINDINGS STATED THAT THE FIRM FAILED TO VET OR PLACE RESTRICTIONS ON RECOMMENDATIONS AND PURCHASES OF VOLATILITY ETPS, AND AS A RESULT, THESE PRODUCTS WERE MADE AVAILABLE TO RETAIL BROKERAGE CUSTOMERS REGARDLESS OF RISK PROFILE AND INVESTMENT OBJECTIVE. CERTAIN FIRM REPRESENTATIVES MISTAKENLY BELIEVED THAT VOLATILITY ETPS COULD BE USED AS A LONG-TERM HEDGE ON THEIR CUSTOMERS' EQUITY POSITIONS IN THE EVENT OF A MARKET DOWNTURN. IN FACT, VOLATILITY ETPS ARE GENERALLY SHORT-TERM TRADING PRODUCTS THAT DEGRADE SIGNIFICANTLY OVER TIME AND SHOULD NOT BE USED AS PART OF A LONG-TERM BUY-AND-HOLD INVESTMENT STRATEGY. ACCORDINGLY, IN THOSE INSTANCES, THE REPRESENTATIVES DID NOT HAVE A REASONABLE BASIS TO RECOMMEND VOLATILITY ETPS AS SUITABLE TO CUSTOMERS WITH CONSERVATIVE OR MODERATE RISK PROFILES AND INVESTMENT OBJECTIVES AND THE REPRESENTATIVES FURTHER FAILED TO APPROPRIATELY RECOMMEND THE EXIT OF THESE POSITIONS WITHIN A TIMELY MANNER. IN SOME INSTANCES, CUSTOMERS INCURRED SIGNIFICANT LOSSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN POLICIES AND PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULE 2310 IN CONNECTION WITH ITS SALE OF VOLATILITY ETPS. ALTHOUGH THE FIRM SHOULD HAVE BEEN AWARE OF THE COMPLEXITY AND UNIQUE RISKS AND FEATURES ASSOCIATED WITH VOLATILITY ETPS, THE FIRM FAILED TO IMPLEMENT A REASONABLE SYSTEM TO SUPERVISE ITS REPRESENTATIVES' SOLICITED www.finra.org/brokercheck SALES OF VOLATILITY ETPS. THE FINDINGS ALSO INCLUDED THAT THE User Guidance FIRM'S SUPERVISORY SYSTEMS ALSO DID NOT INCLUDE REASONABLE TRAINING FOR REGISTERED REPRESENTATIVES AND SUPERVISORS REGARDING THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPS. BECAUSE THE FIRM FAILED TO ESTABLISH AND PROVIDE REASONABLE GUIDANCE, TRAINING OR TOOLS TO EDUCATE ITS REGISTERED REPRESENTATIVES AND SUPERVISORS ABOUT VOLATILITY ETPS, CERTAIN RETAIL BROKERAGE CUSTOMERS WERE UNINFORMED ABOUT THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPS PRIOR TO PURCHASING THEM. Initiated By: FINRA Date Initiated: 10/16/2017 Docket/Case Number: 2014042465601

Principal Product Type: Other Other Product Type(s): VOLATILITY-LINKED EXCHANGE-TRADED PRODUCTS Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/16/2017 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 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND ORDERED TO JOINTLY AND SEVERALLY PAY $3,411,478.78 IN RESTITUTION TO CUSTOMERS. Regulator Statement IN DETERMINING TO RESOLVE THIS MATTER WITHOUT THE IMPOSITION OF A FINE, FINRA TOOK THE FOLLOWING INTO CONSIDERATION: (I) PRIOR TO DETECTION BY FINRA, THE FIRM CORRECTED ITS SUPERVISORY DEFICIENCIES RELATING TO VOLATILITY ETPS; (II) THE FIRM WAS PREVIOUSLY FINED $2.1 MILLION - AFTER THE MISCONDUCT AND ITS REMEDIATION HEREIN - FOR SIMILAR VIOLATIONS RELATING TO NON- TRADITIONAL ETPS; AND, (III) THE FIRM PROVIDED SUBSTANTIAL ASSISTANCE TO FINRA BY, AMONG OTHER THINGS, ENGAGING AT ITS OWN EXPENSE A CONSULTING FIRM TO REVIEW, COMPILE, AND CALCULATE LARGE AMOUNTS OF DATA PERTAINING TO SALES OF VOLATILITY ETPS ©2021 FINRA. All rights reserved. Report aboutFOR WELLS USE INFARGO DETERMINING CLEARING SERVICES, THE APPROPRIATE LLC RESTITUTION TO BE 67 PROVIDED. IN DETERMINING TO RESOLVE THIS MATTER WITHOUT THE IMPOSITION OF A FINE, FINRA TOOK THE FOLLOWING INTO CONSIDERATION: (I) PRIOR TO DETECTION BY FINRA, THE FIRM CORRECTED ITS SUPERVISORY DEFICIENCIES RELATING TO VOLATILITY ETPS; (II) THE FIRM WAS PREVIOUSLY FINED $2.1 MILLION - AFTER THE MISCONDUCT AND ITS REMEDIATION HEREIN - FOR SIMILAR VIOLATIONS RELATING TO NON- www.finra.org/brokercheck TRADITIONAL ETPS; AND, (III) THE FIRM PROVIDED SUBSTANTIAL User Guidance ASSISTANCE TO FINRA BY, AMONG OTHER THINGS, ENGAGING AT ITS OWN EXPENSE A CONSULTING FIRM TO REVIEW, COMPILE, AND CALCULATE LARGE AMOUNTS OF DATA PERTAINING TO SALES OF VOLATILITY ETPS FOR USE IN DETERMINING THE APPROPRIATE RESTITUTION TO BE PROVIDED. 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 CERTAIN FIRM REGISTERED REPRESENTATIVES RECOMMENDED VOLATILITY-LINKED EXCHANGE-TRADED PRODUCTS (VOLATILITY ETPS) TO BROKERAGE CUSTOMERS WITHOUT FULLY UNDERSTANDING THEIR RISKS AND FEATURES. THE FINDINGS STATED THAT THE FIRM FAILED TO VET OR PLACE RESTRICTIONS ON RECOMMENDATIONS AND PURCHASES OF VOLATILITY ETPS, AND AS A RESULT, THESE PRODUCTS WERE MADE AVAILABLE TO RETAIL BROKERAGE CUSTOMERS REGARDLESS OF RISK PROFILE AND INVESTMENT OBJECTIVE. CERTAIN FIRM REPRESENTATIVES MISTAKENLY BELIEVED THAT VOLATILITY ETPS COULD BE USED AS A LONG-TERM HEDGE ON THEIR CUSTOMERS' EQUITY POSITIONS IN THE EVENT OF A MARKET DOWNTURN. IN FACT, VOLATILITY ETPS ARE GENERALLY SHORT-TERM TRADING PRODUCTS THAT DEGRADE SIGNIFICANTLY OVER TIME AND SHOULD NOT BE USED AS PART OF A LONG-TERM BUY-AND-HOLD INVESTMENT STRATEGY. ACCORDINGLY, IN THOSE INSTANCES, THE REPRESENTATIVES DID NOT HAVE A REASONABLE BASIS TO RECOMMEND VOLATILITY ETPS AS SUITABLE TO CUSTOMERS WITH CONSERVATIVE OR MODERATE RISK PROFILES AND INVESTMENT OBJECTIVES AND THE REPRESENTATIVES FURTHER FAILED TO APPROPRIATELY RECOMMEND THE EXIT OF THESE POSITIONS WITHIN A TIMELY MANNER. IN SOME INSTANCES, CUSTOMERS INCURRED SIGNIFICANT LOSSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN POLICIES AND PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULE 2310 IN CONNECTION WITH ITS SALE OF VOLATILITY ETPS. ALTHOUGH THE FIRM SHOULD HAVE BEEN AWARE OF THE COMPLEXITY AND UNIQUE RISKS AND FEATURES ASSOCIATED WITH VOLATILITY ETPS, THE FIRM FAILED TO IMPLEMENT A REASONABLE SYSTEM TO SUPERVISE ITS REPRESENTATIVES' SOLICITED SALES OF VOLATILITY ETPS. THE FINDINGS ALSO INCLUDED THAT THE FIRM'S SUPERVISORY SYSTEMS ALSO DID NOT INCLUDE REASONABLE TRAINING FOR REGISTERED REPRESENTATIVES AND SUPERVISORS REGARDING THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPS. BECAUSE THE FIRM FAILED TO ESTABLISH AND PROVIDE REASONABLE GUIDANCE, TRAINING OR TOOLS TO EDUCATE ITS REGISTERED REPRESENTATIVES AND SUPERVISORS ABOUT VOLATILITY ETPS, CERTAIN RETAIL BROKERAGE CUSTOMERS WERE UNINFORMED ABOUT THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPS ©2021 FINRA. All rights reserved. Report aboutPRIOR WELLS TO FARGOPURCHASING CLEARING THEM.SERVICES, LLC 68 WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT CERTAIN FIRM REGISTERED REPRESENTATIVES RECOMMENDED VOLATILITY-LINKED EXCHANGE-TRADED PRODUCTS (VOLATILITY ETPS) TO BROKERAGE CUSTOMERS WITHOUT FULLY UNDERSTANDING THEIR RISKS AND FEATURES. THE FINDINGS STATED THAT THE FIRM FAILED TO VET OR PLACE RESTRICTIONS ON RECOMMENDATIONS AND PURCHASES OF VOLATILITY ETPS, AND AS A RESULT, THESE PRODUCTS WERE MADE AVAILABLE TO RETAIL BROKERAGE CUSTOMERS REGARDLESS OF RISK PROFILE AND INVESTMENT OBJECTIVE. CERTAIN FIRM REPRESENTATIVES MISTAKENLY BELIEVED THAT VOLATILITY ETPS COULD BE USED AS A LONG-TERM HEDGE ON THEIR CUSTOMERS' EQUITY POSITIONS IN THE EVENT OF A MARKET DOWNTURN. IN FACT, VOLATILITY ETPS ARE GENERALLY SHORT-TERM TRADING PRODUCTS THAT DEGRADE SIGNIFICANTLY OVER TIME AND SHOULD NOT BE USED AS PART OF A LONG-TERM BUY-AND-HOLD INVESTMENT STRATEGY. ACCORDINGLY, IN THOSE INSTANCES, THE REPRESENTATIVES DID NOT HAVE A REASONABLE BASIS TO RECOMMEND VOLATILITY ETPS AS SUITABLE TO CUSTOMERS WITH CONSERVATIVE OR MODERATE RISK PROFILES AND INVESTMENT OBJECTIVES AND THE REPRESENTATIVES FURTHER FAILED TO APPROPRIATELY RECOMMEND THE EXIT OF THESE POSITIONS WITHIN A TIMELY MANNER. IN SOME INSTANCES, CUSTOMERS INCURRED SIGNIFICANT LOSSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN POLICIES AND PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULE 2310 IN CONNECTION WITH ITS SALE OF VOLATILITY ETPS. ALTHOUGH THE FIRM SHOULD HAVE BEEN AWARE OF THE COMPLEXITY AND UNIQUE RISKS AND FEATURES ASSOCIATED WITH VOLATILITY ETPS, THE FIRM FAILED TO IMPLEMENT A REASONABLE SYSTEM TO SUPERVISE ITS REPRESENTATIVES' SOLICITED SALES OF VOLATILITY ETPS. THE FINDINGS ALSO INCLUDED THAT THE FIRM'S SUPERVISORY SYSTEMS ALSO DID NOT INCLUDE REASONABLE TRAINING FOR REGISTERED REPRESENTATIVES AND SUPERVISORS REGARDING THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY www.finra.org/brokercheck ETPS. BECAUSE THE FIRM FAILED TO ESTABLISH AND PROVIDE User Guidance REASONABLE GUIDANCE, TRAINING OR TOOLS TO EDUCATE ITS REGISTERED REPRESENTATIVES AND SUPERVISORS ABOUT VOLATILITY ETPS, CERTAIN RETAIL BROKERAGE CUSTOMERS WERE UNINFORMED ABOUT THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPS PRIOR TO PURCHASING THEM. Initiated By: FINRA Date Initiated: 10/16/2017 Docket/Case Number: 2014042465601

Principal Product Type: Other Other Product Type(s): VOLATILITY-LINKED EXCHANGE-TRADED PRODUCTS Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/16/2017 Sanctions Ordered: Censure Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND ORDERED TO JOINTLY AND SEVERALLY PAY $3,411,478.78 IN RESTITUTION TO CUSTOMERS. Firm Statement IN DETERMINING TO RESOLVE THIS MATTER WITHOUT THE IMPOSITION OF A FINE, FINRA TOOK THE FOLLOWING INTO CONSIDERATION: (I) PRIOR TO DETECTION BY FINRA, THE FIRM CORRECTED ITS SUPERVISORY DEFICIENCIES RELATING TO VOLATILITY ETPS; (II) THE FIRM WAS PREVIOUSLY FINED $2.1 MILLION - AFTER THE MISCONDUCT AND ITS REMEDIATION HEREIN - FOR SIMILAR VIOLATIONS RELATING TO NON- TRADITIONAL ETPS; AND, (III) THE FIRM PROVIDED SUBSTANTIAL ASSISTANCE TO FINRA BY, AMONG OTHER THINGS, ENGAGING AT ITS OWN EXPENSE A CONSULTING FIRM TO REVIEW, COMPILE, AND CALCULATE LARGE AMOUNTS OF DATA PERTAINING TO SALES OF VOLATILITY ETPS FOR USE IN DETERMINING THE APPROPRIATE RESTITUTION TO BE PROVIDED. i Disclosure 16 of 167 Reporting Source: Regulator Current Status: Final Allegations: RESPONDENT FAILED TO REASONABLY SUPERVISE THE IRA DISTRIBUTIONS IN VIOLATION OF SECTION 409.4-412(D)(9) ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 69 www.finra.org/brokercheck User Guidance

RESPONDENT FAILED TO REASONABLY SUPERVISE THE IRA DISTRIBUTIONS IN VIOLATION OF SECTION 409.4-412(D)(9) Initiated By: MISSOURI Date Initiated: 02/16/2017 Docket/Case Number: AP-17-01 URL for Regulatory Action: HTTP://WWW.SOS.MO.GOV/CMSIMAGES/SECURITIES/ORDERS/AP-17- 01.PDF Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief MONETARY FINE - $24,672.17 TO THE MISSOURI SECRETARY OF STATE Sought: INVESTOR EDUCATION AND PROTECTION FUND

Resolution: Consent Resolution Date: 02/16/2017 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 $25,672.17 Other Sanctions Ordered: Sanction Details: RESPONDENT SHALL MAINTAIN AND ENFORCE PROCEDURES AND SYSTEMS FOR SUPERVISING THE ACTIVITIES OF AGENTS, EMPLOYEES, AND MISSOURI OFFICE OPERATIONS IN A MANNER REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE STATE AND FEDERAL SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE FINANCIAL INDUSTRY REGULATORY AUTHORITY. i Reporting Source: Firm Current Status: Final Allegations: RESPONDENT FAILED TO REASONABLY SUPERVISE THE IRA DISTRIBUTIONS FROM 08/07/2001 TO 07/29/2007 IN VIOLATION OF SECTION 409.4-412(D)(9) Initiated By: MISSOURI

Date Initiated: 02/16/2017 Docket/Case Number: AP-17-01

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief MONETARY FINE - $24,672.17 TO THE MISSOURI SECRETARY OF STATE Sought: INVESTOR EDUCATION AND PROTECTION FUND

Resolution: Consent Resolution Date: 02/16/2017 Sanctions Ordered: Censure Monetary/Fine $25,672.17 Other Sanctions Ordered: Sanction Details: RESPONDENT SHALL MAINTAIN AND ENFORCE PROCEDURES AND SYSTEMS FOR SUPERVISING THE ACTIVITIES OF AGENTS, EMPLOYEES, AND MISSOURI OFFICE OPERATIONS IN A MANNER REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE STATE AND FEDERAL SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE FINANCIAL INDUSTRY REGULATORY AUTHORITY. Firm Statement RESPONDENT SHALL MAINTAIN AND ENFORCE PROCEDURES AND SYSTEMS FOR SUPERVISING THE ACTIVITIES OF AGENTS, EMPLOYEES, AND MISSOURI OFFICE OPERATIONS IN A MANNER REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE STATE AND FEDERAL SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE FINANCIAL INDUSTRY REGULATORY AUTHORITY. i Disclosure 17 of 167 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 EXECUTE 50 MARKET ORDERS IN PREFERRED SECURITIES FULLY AND PROMPTLY. THE FINDINGS STATED THAT IN 19 OF THOSE 50 TRANSACTIONS, 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 ©2021 FINRA. All rights reserved. Report aboutMARKET WELLS CONDITIONS. FARGO CLEARING SERVICES, LLC 71 WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO EXECUTE 50 MARKET ORDERS IN PREFERRED SECURITIES FULLY AND PROMPTLY. THE FINDINGS STATED THAT IN 19 OF THOSE 50 www.finra.org/brokercheck TRANSACTIONS, THE FIRM FAILED TO USE REASONABLE DILIGENCE TO User Guidance 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. Initiated By: FINRA Date Initiated: 04/07/2017 Docket/Case Number: 2016049925401

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: 04/07/2017 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 $20,000.00 Disgorgement/Restitution Other Sanctions Ordered: INTEREST Sanction Details: THE FIRM WAS CENSURED, FINED $20,000 AND REQUIRED TO PAY RESTITUTION IN THE TOTAL AMOUNT OF $4,543.08, PLUS INTEREST. FINES PAID IN FULL ON MAY 11, 2017. 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 EXECUTE 50 MARKET ORDERS IN PREFERRED SECURITIES FULLY AND PROMPTLY. THE FINDINGS STATED THAT IN 19 OF THOSE 50 TRANSACTIONS, 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. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 72 WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO EXECUTE 50 MARKET ORDERS IN PREFERRED SECURITIES FULLY AND PROMPTLY. THE FINDINGS STATED THAT IN 19 OF THOSE 50 www.finra.org/brokercheck TRANSACTIONS, THE FIRM FAILED TO USE REASONABLE DILIGENCE TO User Guidance 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. Initiated By: FINRA Date Initiated: 04/07/2017 Docket/Case Number: 2016049925401

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: 04/07/2017 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Disgorgement/Restitution Other Sanctions Ordered: INTEREST Sanction Details: THE FIRM WAS CENSURED, FINED $20,000 AND REQUIRED TO PAY RESTITUTION IN THE TOTAL AMOUNT OF $4,543.08, PLUS INTEREST. Firm Statement THE FIRM WAS CENSURED, FINED $20,000 AND REQUIRED TO PAY RESTITUTION IN THE TOTAL AMOUNT OF $4,543.08, PLUS INTEREST. i Disclosure 18 of 167 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, WITH TWO OTHER FIRMS, FAILED TO MAINTAIN APPROXIMATELY ONE MILLION ELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON- REWRITABLE FORMAT, KNOWN AS WORM "WRITE ONCE, READ MANY" FORMAT. THE FINDINGS STATED THAT WORM IS INTENDED TO PREVENT THE ALTERATION OR DESTRUCTION OF BROKER-DEALER RECORDS STORED ELECTRONICALLY. THE FINDINGS ALSO STATED THAT FOR APPROXIMATELY 1.5 MILLION ACCOUNTS, THE FIRM, WITH THE OTHER TWO FIRMS, FAILED TO PRESERVE CUSTOMER ACCOUNT FORM TEMPLATES CONTAINING THE TERMS AND CONDITIONS RELATED TO THE OPENING AND MAINTENANCE OF THE ACCOUNTS. THE FINDINGS ALSO ©2021 FINRA. All rights reserved. Report aboutINCLUDED WELLS FARGO THAT CLEARING THE FIRM, SERVICES, WITH ONE LLC OF THE OTHER FIRMS, FAILED TO 73 RETAIN CERTAIN COMMUNICATIONS, INCLUDING 77,280 REJECT LETTERS AND 78,200 FULFILLMENT LETTERS. FINRA FOUND THAT THE FIRM FAILED TO NOTIFY FINRA, ITS DESIGNATED EXAMINING AUTHORITY, AT LEAST 90 DAYS PRIOR TO USING NEW STORAGE MEDIA TO STORE ELECTRONIC BROKER-DEALER RECORDS. FINRA ALSO FOUND THAT THE FIRM FAILED TO IMPLEMENT AN AUDIT SYSTEM FOR THOSE RECORDS THEY FAILED TO MAINTAIN IN WORM FORMAT. IN ADDITION, FINRA DETERMINED THAT THE FIRM FAILED TO PROVIDE ITS THIRD-PARTY VENDORS FULL ACCESS TO, AND THE ABILITY TO DOWNLOAD INFORMATION FROM, ITS ELECTRONIC STORAGE SYSTEMS. MOREOVER, FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT AN ADEQUATE SUPERVISORY SYSTEM, AND FAILED TO ENFORCE WRITTEN PROCEDURES, CONCERNING THE FIRM'S READY ACCESS TO ELECTRONIC BROKER-DEALER RECORDS AND ITS STORAGE OF SUCH RECORDS IN WORM FORMAT. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, WITH TWO OTHER FIRMS, FAILED TO MAINTAIN APPROXIMATELY ONE MILLION ELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON- REWRITABLE FORMAT, KNOWN AS WORM "WRITE ONCE, READ MANY" FORMAT. THE FINDINGS STATED THAT WORM IS INTENDED TO PREVENT THE ALTERATION OR DESTRUCTION OF BROKER-DEALER RECORDS STORED ELECTRONICALLY. THE FINDINGS ALSO STATED THAT FOR www.finra.org/brokercheck APPROXIMATELY 1.5 MILLION ACCOUNTS, THE FIRM, WITH THE OTHER User Guidance TWO FIRMS, FAILED TO PRESERVE CUSTOMER ACCOUNT FORM TEMPLATES CONTAINING THE TERMS AND CONDITIONS RELATED TO THE OPENING AND MAINTENANCE OF THE ACCOUNTS. THE FINDINGS ALSO INCLUDED THAT THE FIRM, WITH ONE OF THE OTHER FIRMS, FAILED TO RETAIN CERTAIN COMMUNICATIONS, INCLUDING 77,280 REJECT LETTERS AND 78,200 FULFILLMENT LETTERS. FINRA FOUND THAT THE FIRM FAILED TO NOTIFY FINRA, ITS DESIGNATED EXAMINING AUTHORITY, AT LEAST 90 DAYS PRIOR TO USING NEW STORAGE MEDIA TO STORE ELECTRONIC BROKER-DEALER RECORDS. FINRA ALSO FOUND THAT THE FIRM FAILED TO IMPLEMENT AN AUDIT SYSTEM FOR THOSE RECORDS THEY FAILED TO MAINTAIN IN WORM FORMAT. IN ADDITION, FINRA DETERMINED THAT THE FIRM FAILED TO PROVIDE ITS THIRD-PARTY VENDORS FULL ACCESS TO, AND THE ABILITY TO DOWNLOAD INFORMATION FROM, ITS ELECTRONIC STORAGE SYSTEMS. MOREOVER, FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT AN ADEQUATE SUPERVISORY SYSTEM, AND FAILED TO ENFORCE WRITTEN PROCEDURES, CONCERNING THE FIRM'S READY ACCESS TO ELECTRONIC BROKER-DEALER RECORDS AND ITS STORAGE OF SUCH RECORDS IN WORM FORMAT. Initiated By: FINRA Date Initiated: 12/21/2016 Docket/Case Number: 2016050274801

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 $1,500,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $1,500,000, 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 ©2021 FINRA. All rights reserved. Report aboutMEASURES WELLS FARGO LEADING CLEARING TO FULLSERVICES, COMPLIANCE, LLC RELATING TO THE CONDUCT 74 ADDRESSED IN THE AWC. FINES PAID IN FULL ON 12/28/16. www.finra.org/brokercheck User Guidance THE FIRM WAS CENSURED, FINED $1,500,000, 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 12/28/16. 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, WITH TWO OTHER FIRMS, FAILED TO MAINTAIN APPROXIMATELY ONE MILLION ELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON- REWRITABLE FORMAT, KNOWN AS WORM "WRITE ONCE, READ MANY" FORMAT. THE FINDINGS STATED THAT WORM IS INTENDED TO PREVENT THE ALTERATION OR DESTRUCTION OF BROKER-DEALER RECORDS STORED ELECTRONICALLY. THE FINDINGS ALSO STATED THAT FOR APPROXIMATELY 1.5 MILLION ACCOUNTS, THE FIRM, WITH THE OTHER TWO FIRMS, FAILED TO PRESERVE CUSTOMER ACCOUNT FORM TEMPLATES CONTAINING THE TERMS AND CONDITIONS RELATED TO THE OPENING AND MAINTENANCE OF THE ACCOUNTS. THE FINDINGS ALSO INCLUDED THAT THE FIRM, WITH ONE OF THE OTHER FIRMS, FAILED TO RETAIN CERTAIN COMMUNICATIONS, INCLUDING 77,280 REJECT LETTERS AND 78,200 FULFILLMENT LETTERS. FINRA FOUND THAT THE FIRM FAILED TO NOTIFY FINRA, ITS DESIGNATED EXAMINING AUTHORITY, AT LEAST 90 DAYS PRIOR TO USING NEW STORAGE MEDIA TO STORE ELECTRONIC BROKER-DEALER RECORDS. FINRA ALSO FOUND THAT THE FIRM FAILED TO IMPLEMENT AN AUDIT SYSTEM FOR THOSE RECORDS THEY FAILED TO MAINTAIN IN WORM FORMAT. IN ADDITION, FINRA DETERMINED THAT THE FIRM FAILED TO PROVIDE ITS THIRD-PARTY VENDORS FULL ACCESS TO, AND THE ABILITY TO DOWNLOAD INFORMATION FROM, ITS ELECTRONIC STORAGE SYSTEMS. MOREOVER, FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT AN ADEQUATE SUPERVISORY SYSTEM, AND FAILED TO ENFORCE WRITTEN PROCEDURES, CONCERNING THE FIRM'S READY ACCESS TO ELECTRONIC BROKER-DEALER RECORDS AND ITS STORAGE OF SUCH RECORDS IN WORM FORMAT. Initiated By: FINRA Date Initiated: 12/21/2016 Docket/Case Number: 2016050274801

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 75 www.finra.org/brokercheck User Guidance

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/21/2016 Sanctions Ordered: Censure Monetary/Fine $1,500,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $1,500,000, 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 i Disclosure 19 of 167 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AND ITS AFFILIATE CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THEY FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE REASONABLE SUPERVISORY SYSTEMS FOR THE USE OF CONSOLIDATED REPORTS GENERATED BY THEIR REGISTERED REPRESENTATIVES THROUGH A PARTICULAR APPLICATION (THE APPLICATION) THAT THE FIRMS MADE AVAILABLE TO THEIR REGISTERED REPRESENTATIVES. THE FINDINGS STATED THAT THE FIRM AND ITS AFFILIATE PERMITTED THEIR REGISTERED REPRESENTATIVES TO USE UP TO 10 OR MORE DIFFERENT APPLICATIONS TO CREATE CONSOLIDATED REPORTS, INCLUDING THE APPLICATION. THE APPLICATION WAS THE MOST WIDELY USED CONSOLIDATED REPORTING APPLICATION AT THE FIRMS. THE FINDINGS ALSO STATED THAT WHEN PREPARING APPLICATION REPORTS, THE FIRMS' REPRESENTATIVES WERE PERMITTED TO MANUALLY ENTER INFORMATION REGARDING CUSTOMERS' EXTERNAL ACCOUNTS, ASSETS AND LIABILITIES INTO A CENTRALIZED ASSETS AND LIABILITIES TABLE, WHICH THE FIRMS MAINTAINED. THE APPLICATION WOULD PULL THAT INFORMATION FROM THE TABLE TO POPULATE THE APPLICATION REPORTS, INCLUDING THOSE THAT WERE THEN SENT TO THE FIRMS' CUSTOMERS. THE FIRMS REVIEWED A RANDOM SAMPLING OF ONLY 2 PERCENT OF THE APPLICATION REPORTS. THE FIRM AND ITS AFFILIATE DID NOT, AND HAD NO SYSTEM IN PLACE TO, REVIEW THE CONTENTS OF THE APPLICATION REPORTS, INCLUDING INFORMATION ABOUT ©2021 FINRA. All rights reserved. Report aboutCUSTOMERS' WELLS FARGO HOLDINGS CLEARING SERVICES,AWAY FROM LLC THE FIRMS. THE FINDINGS ALSO 76 INCLUDED THAT THE FIRMS' SUPERVISORY SYSTEMS AND PROCEDURES WERE INADEQUATE BECAUSE THERE WAS NO MECHANISM ALLOWING THEIR REPRESENTATIVES TO DESIGNATE WHICH APPLICATION REPORTS WERE ACTUALLY PROVIDED TO CUSTOMERS. THE FIRMS COULD NOT DISTINGUISH BETWEEN DRAFT APPLICATION REPORTS AND REPORTS THAT WERE COMPLETED AND SENT TO CUSTOMERS, WHICH SHOULD HAVE BEEN SUBJECTED TO THE FIRMS' SUPERVISORY SYSTEMS DESIGNED TO REVIEW CUSTOMER COMMUNICATIONS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AND ITS AFFILIATE CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THEY FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE REASONABLE SUPERVISORY SYSTEMS FOR THE USE OF CONSOLIDATED REPORTS GENERATED BY THEIR REGISTERED REPRESENTATIVES THROUGH A PARTICULAR APPLICATION (THE APPLICATION) THAT THE FIRMS MADE AVAILABLE TO THEIR REGISTERED REPRESENTATIVES. THE FINDINGS STATED THAT THE FIRM AND ITS AFFILIATE PERMITTED THEIR REGISTERED REPRESENTATIVES TO USE UP TO 10 OR MORE DIFFERENT APPLICATIONS TO CREATE CONSOLIDATED REPORTS, INCLUDING THE APPLICATION. THE APPLICATION WAS THE MOST WIDELY USED CONSOLIDATED REPORTING APPLICATION AT THE FIRMS. THE FINDINGS ALSO STATED THAT WHEN PREPARING APPLICATION REPORTS, THE FIRMS' REPRESENTATIVES WERE PERMITTED TO MANUALLY ENTER INFORMATION REGARDING CUSTOMERS' EXTERNAL ACCOUNTS, ASSETS AND LIABILITIES INTO A CENTRALIZED ASSETS AND LIABILITIES TABLE, WHICH THE FIRMS MAINTAINED. THE APPLICATION WOULD PULL THAT INFORMATION FROM THE TABLE TO POPULATE THE APPLICATION www.finra.org/brokercheck REPORTS, INCLUDING THOSE THAT WERE THEN SENT TO THE FIRMS' User Guidance CUSTOMERS. THE FIRMS REVIEWED A RANDOM SAMPLING OF ONLY 2 PERCENT OF THE APPLICATION REPORTS. THE FIRM AND ITS AFFILIATE DID NOT, AND HAD NO SYSTEM IN PLACE TO, REVIEW THE CONTENTS OF THE APPLICATION REPORTS, INCLUDING INFORMATION ABOUT CUSTOMERS' HOLDINGS AWAY FROM THE FIRMS. THE FINDINGS ALSO INCLUDED THAT THE FIRMS' SUPERVISORY SYSTEMS AND PROCEDURES WERE INADEQUATE BECAUSE THERE WAS NO MECHANISM ALLOWING THEIR REPRESENTATIVES TO DESIGNATE WHICH APPLICATION REPORTS WERE ACTUALLY PROVIDED TO CUSTOMERS. THE FIRMS COULD NOT DISTINGUISH BETWEEN DRAFT APPLICATION REPORTS AND REPORTS THAT WERE COMPLETED AND SENT TO CUSTOMERS, WHICH SHOULD HAVE BEEN SUBJECTED TO THE FIRMS' SUPERVISORY SYSTEMS DESIGNED TO REVIEW CUSTOMER COMMUNICATIONS. Initiated By: FINRA Date Initiated: 12/05/2016 Docket/Case Number: 2015043740201

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: 12/05/2016 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 $1,000,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $1,000,000, JOINTLY AND SEVERALLY. FINES PAID IN FULL ON 12/23/16. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AND ITS AFFILIATE CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 77 FINDINGS THAT THEY FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE REASONABLE SUPERVISORY SYSTEMS FOR THE USE OF CONSOLIDATED REPORTS GENERATED BY THEIR REGISTERED REPRESENTATIVES THROUGH A PARTICULAR APPLICATION (THE APPLICATION) THAT THE FIRMS MADE AVAILABLE TO THEIR REGISTERED REPRESENTATIVES. THE FINDINGS STATED THAT THE FIRM AND ITS AFFILIATE PERMITTED THEIR REGISTERED REPRESENTATIVES TO USE UP TO 10 OR MORE DIFFERENT APPLICATIONS TO CREATE CONSOLIDATED REPORTS, INCLUDING THE APPLICATION. THE APPLICATION WAS THE MOST WIDELY USED CONSOLIDATED REPORTING APPLICATION AT THE FIRMS. THE FINDINGS ALSO STATED THAT WHEN PREPARING APPLICATION REPORTS, THE FIRMS' REPRESENTATIVES WERE PERMITTED TO MANUALLY ENTER INFORMATION REGARDING CUSTOMERS' EXTERNAL ACCOUNTS, ASSETS AND LIABILITIES INTO A CENTRALIZED ASSETS AND LIABILITIES TABLE, WHICH THE FIRMS MAINTAINED. THE APPLICATION WOULD PULL THAT INFORMATION FROM THE TABLE TO POPULATE THE APPLICATION REPORTS, INCLUDING THOSE THAT WERE THEN SENT TO THE FIRMS' CUSTOMERS. THE FIRMS REVIEWED A RANDOM SAMPLING OF ONLY 2 PERCENT OF THE APPLICATION REPORTS. THE FIRM AND ITS AFFILIATE DID NOT, AND HAD NO SYSTEM IN PLACE TO, REVIEW THE CONTENTS OF THE APPLICATION REPORTS, INCLUDING INFORMATION ABOUT CUSTOMERS' HOLDINGS AWAY FROM THE FIRMS. THE FINDINGS ALSO INCLUDED THAT THE FIRMS' SUPERVISORY SYSTEMS AND PROCEDURES WERE INADEQUATE BECAUSE THERE WAS NO MECHANISM ALLOWING THEIR REPRESENTATIVES TO DESIGNATE WHICH APPLICATION REPORTS WERE ACTUALLY PROVIDED TO CUSTOMERS. THE FIRMS COULD NOT DISTINGUISH BETWEEN DRAFT APPLICATION REPORTS AND REPORTS THAT WERE COMPLETED AND SENT TO CUSTOMERS, WHICH SHOULD HAVE BEEN SUBJECTED TO THE FIRMS' SUPERVISORY SYSTEMS DESIGNED TO REVIEW CUSTOMER COMMUNICATIONS. www.finra.org/brokercheck User Guidance

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AND ITS AFFILIATE CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THEY FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE REASONABLE SUPERVISORY SYSTEMS FOR THE USE OF CONSOLIDATED REPORTS GENERATED BY THEIR REGISTERED REPRESENTATIVES THROUGH A PARTICULAR APPLICATION (THE APPLICATION) THAT THE FIRMS MADE AVAILABLE TO THEIR REGISTERED REPRESENTATIVES. THE FINDINGS STATED THAT THE FIRM AND ITS AFFILIATE PERMITTED THEIR REGISTERED REPRESENTATIVES TO USE UP TO 10 OR MORE DIFFERENT APPLICATIONS TO CREATE CONSOLIDATED REPORTS, INCLUDING THE APPLICATION. THE APPLICATION WAS THE MOST WIDELY USED CONSOLIDATED REPORTING APPLICATION AT THE FIRMS. THE FINDINGS ALSO STATED THAT WHEN PREPARING APPLICATION REPORTS, THE FIRMS' REPRESENTATIVES WERE PERMITTED TO MANUALLY ENTER INFORMATION REGARDING CUSTOMERS' EXTERNAL ACCOUNTS, ASSETS AND LIABILITIES INTO A CENTRALIZED ASSETS AND LIABILITIES TABLE, WHICH THE FIRMS MAINTAINED. THE APPLICATION WOULD PULL THAT INFORMATION FROM THE TABLE TO POPULATE THE APPLICATION REPORTS, INCLUDING THOSE THAT WERE THEN SENT TO THE FIRMS' CUSTOMERS. THE FIRMS REVIEWED A RANDOM SAMPLING OF ONLY 2 PERCENT OF THE APPLICATION REPORTS. THE FIRM AND ITS AFFILIATE DID NOT, AND HAD NO SYSTEM IN PLACE TO, REVIEW THE CONTENTS OF THE APPLICATION REPORTS, INCLUDING INFORMATION ABOUT CUSTOMERS' HOLDINGS AWAY FROM THE FIRMS. THE FINDINGS ALSO INCLUDED THAT THE FIRMS' SUPERVISORY SYSTEMS AND PROCEDURES WERE INADEQUATE BECAUSE THERE WAS NO MECHANISM ALLOWING THEIR REPRESENTATIVES TO DESIGNATE WHICH APPLICATION REPORTS WERE ACTUALLY PROVIDED TO CUSTOMERS. THE FIRMS COULD NOT DISTINGUISH BETWEEN DRAFT APPLICATION REPORTS AND REPORTS THAT WERE COMPLETED AND SENT TO CUSTOMERS, WHICH SHOULD HAVE BEEN SUBJECTED TO THE FIRMS' SUPERVISORY SYSTEMS DESIGNED TO REVIEW CUSTOMER COMMUNICATIONS. Initiated By: FINRA Date Initiated: 12/05/2016 Docket/Case Number: 2015043740201

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 78 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/05/2016 Sanctions Ordered: Censure Monetary/Fine $1,000,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $1,000,000, JOINTLY AND SEVERALLY. i Disclosure 20 of 167 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 EFFECTED 39 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 RULE. THE FINDINGS STATED THAT THE FIRM FAILED TO DISCLOSE ALL MATERIAL FACTS CONCERNING 39 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, OR THAT THE MUNICIPAL SECURITIES CONTAINED A RESALE RESTRICTION WHICH COULD AFFECT THE LIQUIDITY OF THE CUSTOMER'S POSITION. Initiated By: FINRA Date Initiated: 10/20/2016 Docket/Case Number: 2015046578401

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: 10/20/2016 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 $42,500.00 Other Sanctions Ordered: REQUIRED TO OFFER RESCISSION TO CUSTOMERS Sanction Details: THE FIRM WAS CENSURED, FINED $42,500, AND REQUIRED TO OFFER RESCISSION TO THE CUSTOMERS WHO PURCHASED THE SECURITIES AT EITHER THE ORIGINAL PURCHASE PRICE OR THE CURRENT FAIR MARKET VALUE, WHICHEVER IS HIGHER. THE OFFER OF RESCISSION SHALL REMAIN OPEN WITH THE AFFECTED CUSTOMER FOR A PERIOD OF 60 DAYS. FINES PAID IN FULL ON NOVEMBER 8, 2016. 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 EFFECTED 39 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 RULE. THE FINDINGS STATED THAT THE FIRM FAILED TO DISCLOSE ALL MATERIAL FACTS CONCERNING 39 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, OR THAT THE MUNICIPAL SECURITIES CONTAINED A RESALE RESTRICTION WHICH COULD AFFECT THE LIQUIDITY OF THE CUSTOMER'S POSITION. Initiated By: FINRA Date Initiated: 10/20/2016 Docket/Case Number: 2015046578401

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 80 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/20/2016 Sanctions Ordered: Censure Monetary/Fine $42,500.00 Other Sanctions Ordered: REQUIRED TO OFFER RESCISSION TO CUSTOMERS Sanction Details: THE FIRM WAS CENSURED, FINED $42,500, AND REQUIRED TO OFFER RESCISSION TO THE CUSTOMERS WHO PURCHASED THE SECURITIES AT EITHER THE ORIGINAL PURCHASE PRICE OR THE CURRENT FAIR MARKET VALUE, WHICHEVER IS HIGHER. THE OFFER OF RESCISSION SHALL REMAIN OPEN WITH THE AFFECTED CUSTOMER FOR A PERIOD OF 60 DAYS. FINES PAID IN FULL ON NOVEMBER 8, 2016. Firm Statement N/A i Disclosure 21 of 167 Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK, N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT ITS COMMUNITY BANK GROUP HAD UNSAFE OR UNSOUND PRACTICES IN RISK MANAGEMENT AND OVERSIGHT OF SALES PRACTICES, AND UNSAFE OR UNSOUND SALES PRACTICES BY SELLING UNWANTED DEPOSIT OR CREDIT CARD ACCOUNTS, THE UNAUTHORIZED OPENING OF SUCH ACCOUNTS, THE TRANSFER OF FUNDS TO UNAUTHORIZED ACCOUNTS, AND UNAUTHORIZED CREDIT INQUIRIES TO OPEN THE ACCOUNTS. Initiated By: COMPTROLLER OF THE CURRENCY (OCC) Date Initiated: 09/06/2016 Docket/Case Number: AA-EC-2016-66 AND AA-EC-2016-67

Principal Product Type: Banking Products (Other than CD(s)) Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 81 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief COMPLIANCE AND RISK MANAGEMENT PLAN; PAY REIMBURSEMENT TO Sought: AFFECTED CONSUMERS; CIVIL MONEY PENALTY.

Resolution: Consent Resolution Date: 09/06/2016 Sanctions Ordered: Monetary/Fine $35,000,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: ESTABLISH A COMPLIANCE PLAN; CREATE RISK MANAGEMENT AND AUDIT OVERSIGHT, PROVIDE REIMBURSEMENT PLAN AND ASSESSMENT. Sanction Details: FINE PAID OF $35,000,000.00 i Disclosure 22 of 167 Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK, N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT ITS COMMUNITY BANK GROUP ENGAGED IN UNFAIR AND ABUSIVE PRACTICES BY OPENING DEPOSIT ACCOUNTS, TRANSFERRING FUNDS BETWEEN ACCOUNTS, APPLYING FOR CREDIT CARDS, ISSUING DEBIT CARDS AND ENROLLING CUSTOMERS IN ON-LINE BANKING SERVICES WITHOUT THE CUSTOMERS' CONSENT. Initiated By: CONSUMER FINANCIAL PROTECTION BUREAU (CFPB) Date Initiated: 09/04/2016 Docket/Case Number: 2016-CFPB-0015

Principal Product Type: Banking Products (Other than CD(s)) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CIVIL MONEY PENALTIES OF $100,000,000.00; COMPLIANCE AND REDRESS Sought: PLANS; INDEPENDENT CONSULTANT REVIEW, PAY REDRESS TO AFFECTED CONSUMERS.

Resolution: Consent Resolution Date: 09/04/2016 Sanctions Ordered: Monetary/Fine $100,000,000.00 ©2021 FINRA. All rights reserved. Report aboutDisgorgement/Restitution WELLS FARGO CLEARING SERVICES, LLC 82 Cease and Desist/Injunction www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $100,000,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: DEVELOP COMPLIANCE PLAN AND MONITORING Sanction Details: $100,000,000.00 FINE PAID i Disclosure 23 of 167 Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK, N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT UNDER CERTAIN SCENARIOS AND IN CERTAIN TIMEFRAMES ITS EDUCATION FINANCIAL SERVICES BUSINESS (EFS)ALLOCATED PARTIAL PAYMENTS, AGGREGATED PARTIAL PAYMENTS, AND CHARGED LATE FEES IN WAYS THAT WERE ALLEGED TO BE UNLAWFUL. Initiated By: CONSUMER FINANCIAL PROTECTION BUREAU (CFPB) Date Initiated: 08/20/2016 Docket/Case Number: 2016-CFPB-0013

Principal Product Type: Other Other Product Type(s): STUDENT LOAN SERVICING Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief COMPLIANCE PLAN, REMEDIATION TO BORROWERS, PAY CIVIL MONEY Sought: PENALTIES OF $3,600,000 AND PROVIDE A QUARTERLY/ANNUAL TRACKING REPORT TO CFPB.

Resolution: Consent Resolution Date: 08/20/2016 Sanctions Ordered: Monetary/Fine $3,600,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: DEVELOP COMPLIANCE PLAN AND MONITORING. Sanction Details: $3,600,000.00 FINE PAID i Disclosure 24 of 167

Reporting Source: Firm Current Status: Final Allegations: THE STATE OF VERMONT DEPARTMENT OF FINANCIAL REGULATION ALLEGED THAT WELLS FARGO ADVISORS, LLC FAILED TO REASONABLY SUPERVISE A REGISTERED REPRESENTATIVE WITH REGARD TO THE USE OF INVESTMENTS IN NON-TRADITIONAL ETFS; FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM IN CONNECTION WITH THE SALE OF AND INVESTMENT IN NON-TRADITIONAL ETFS; FAILED TO FOLLOW WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO THE USE OF AND INVESTMENT IN NON-TRADITIONAL ETFS; AND ALLOWED A REGISTERED REPRESENTATIVE TO RECOMMEND UNSUITABLE PRODUCTS TO A CUSTOMER, ALL IN VIOLATION OF 9 VSA SECTION 5412(D)(9). Initiated By: VERMONT DEPARTMENT OF FINANCIAL REGULATION Date Initiated: 06/28/2016 Docket/Case Number: 16-25-S

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

Resolution: Consent Resolution Date: 06/28/2016 Sanctions Ordered: Censure Monetary/Fine $300,000.00 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 $300,000. 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 $300,000. i Disclosure 25 of 167 Reporting Source: Regulator

Current Status: Final Allegations: WELLS FARGO ADVISORS FAILED TO SUPERVISE AN AGENT THAT SOLD OVER $400,000 IN UNREGISTERED SECURITIES TO WELLS FARGO ADVISORS' CLIENTS. Initiated By: VIRGINIA STATE CORPORATION COMMISION Date Initiated: 09/11/2015 Docket/Case Number: SEC-2014-00035 URL for Regulatory Action: HTTP://WWW.SCC.VIRGINIA.GOV/DOCKETSEARCH#/CASEDETAILS/133609 Principal Product Type: Investment Contract(s) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief RESTITUTION Sought:

Resolution: Settled Resolution Date: 09/11/2015 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: Monetary/Fine $150,000.00 Disgorgement/Restitution Other Sanctions Ordered: WELLS FARGO ADVISORS AGREED TO PAY $55,000 TO DEFRAY THE COST OF INVESTIGATION. Sanction Details: MONETARY FINE OF $150,000. WELLS FARGO ADVISORS AGREED TO PAY $55,000 TO DEFRAY THE COST OF INVESTIGATION. Regulator Statement WELLS FARGO ADVISORS EMPLOYED CHRISTOPHER CUNNINGHAM (CRD #2390800) AS AN AGENT FROM 2005 TO 2009. WHILE AT WELLS FARGO ADVISORS, CUNNINGHAM SOLD OVER $400,000 IN UNREGISTERED SECURITIES TO HIS CLIENTS. CUNNINGHAM IS CURRENTLY SERVING 57 MONTHS IN FEDERAL PRISON FOR WIRE FRAUD RELATED TO HIS SCHEME. i Reporting Source: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 85 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: THE DIVISION ALLEGES THAT WFA COMMITTED MULTIPLE VIOLATIONS OF (I) RULE 21 VAC 5-20-260 B BY FAILING TO EXERCISE DILIGENT SUPERVISION OVER SECURITIES ACTIVITIES OF ITS AGENT; (II) RULE 21 VAC 5-20-260 D (2) BY FAILING TO MONITOR AND CONDUCT FREQUENT EXAMINATIONS OF ALL CUSTOMER ACCOUNTS TO DETECT AND PREVENT IRREGULARITIES OR ABUSES; AND (III)RULE 21 VAC 5-20-260 D BY FAILING TO ENFORCE ITS WRITTEN POLICIES AND PROCEDURES. Initiated By: COMMONWEALTH OF VIRGINIA Date Initiated: 09/11/2015 Docket/Case Number: SEC-2014-00035

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: 09/11/2015 Sanctions Ordered: Monetary/Fine $150,000.00 Disgorgement/Restitution Other Sanctions Ordered: WELLS FARGO ADVISORS AGREED TO PAY $55,000 TO DEFRAY THE COST OF INVESTIGATION. Sanction Details: MONETARY FINE OF $150,000. WELLS FARGO ADVISORS AGREED TO PAY $55,000 TO DEFRAY THE COST OF INVESTIGATION. i Disclosure 26 of 167 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 MADE UNSUITABLE RECOMMENDATIONS TO RETAIL CUSTOMERS TO PURCHASE STRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES (STRATS), A COMPLEX STRUCTURED PRODUCT THAT PAID A FLOATING RATE OF PERIODIC INCOME UP TO A MINIMUM OR MAXIMUM RATE, BASED ©2021 FINRA. All rights reserved. Report aboutON THEWELLS STRATS FARGO CLEARING TRUST'S SERVICES, INTEREST LLC IN A CAPITAL SECURITY ISSUED BY A 86 FINANCIAL INSTITUTION AND THE STRATS TRUST'S INTEREST IN AN INTEREST RATE SWAP CONTRACT. THE FIRM SOLD APPROXIMATELY $12 MILLION WORTH OF THE STRATS TO ITS RETAIL CUSTOMERS, IN BOTH PRIMARY AND SECONDARY MARKETS. ALTHOUGH THE FIRM PROVIDED ITS SALES-FORCE TRAINING ON STRUCTURED PRODUCTS, NONE OF THIS TRAINING RELATED SPECIFICALLY TO THE UNIQUE FEATURES AND RISKS OF THE STRATS. ADDITIONALLY, ALTHOUGH THE FIRM'S INTRANET PAGE DEDICATED TO FIXED INCOME PRODUCTS PROVIDED BASIC INFORMATION CONCERNING THE STRATS, IT DID NOT PROVIDE ANY INFORMATION CONCERNING THE RISKS OF INVESTING IN THESE PRODUCTS, AND SPECIFICALLY DID NOT ADDRESS THE RISKS TO CUSTOMER PRINCIPAL IN THE EVENT OF A REDEMPTION OF THE UNDERLYING CAPITAL SECURITY. UNDER THE TERMS OF THE PROSPECTUS FOR THE STRATS, THE AMOUNT PAID TO A CUSTOMER IN THE EVENT OF A TERMINATION WAS THE PROCEEDS OF THE REDEMPTION OF UNDERLYING CAPITAL SECURITY PLUS ACCRUED INTEREST AND LESS THE SWAP TERMINATION FEE. IN CERTAIN CIRCUMSTANCES, THE CUSTOMER WOULD FACE A SUBSTANTIAL RISK OF LOSS OF PRINCIPAL UPON TERMINATION OF THE STRATS DUE TO THE AMOUNT OF THE SWAP TERMINATION FEE. THE FIRM'S REGISTERED REPRESENTATIVES GENERALLY WERE NOT FAMILIAR WITH SUCH RISKS OF INVESTING IN THE STRATS AND WERE CONSEQUENTLY UNABLE TO EXPLAIN SUCH RISKS WHEN RECOMMENDING THE PRODUCT TO THE FIRM'S RETAIL CUSTOMERS. EVENTUALLY, THE FINANCIAL INSTITUTION REDEEMED THE UNDERLYING CAPITAL SECURITY, CAUSING THE STRATS TO BE TERMINATED. THE FINANCIAL INSTITUTION REDEEMED THE UNDERLYING CAPITAL SECURITY AT PAR VALUE PLUS ACCRUED INTEREST. BASED ON THE TERMS OF THE UNDERLYING SWAP AGREEMENT, CUSTOMERS RECEIVED THE PROCEEDS OF THE REDEMPTION AFTER THE SWAP TERMINATION FEE WAS PAID. AS A RESULT, AT THE TIME OF THE STRATS' TERMINATION, MANY CUSTOMERS HOLDING THE STRATS RECEIVED LESS, AND IN SOME CASES SIGNIFICANTLY LESS, THAN THE AMOUNT THEY PAID FOR THE STRATS. THE FIRM FAILED TO EDUCATE ITS REGISTERED REPRESENTATIVES REGARDING THE UNIQUE FEATURES AND RISKS OF THE STRATS. AS A RESULT, THE FIRM'S REGISTERED REPRESENTATIVES DID NOT COMPREHEND THE RISKS TO CUSTOMERS OF INVESTING IN THE STRATS AND THUS LACKED A REASONABLE BASIS FOR RECOMMENDING THESE PRODUCTS TO THE FIRM'S RETAIL CUSTOMERS. THE FINDINGS STATED THAT THE FIRM MADE AVAILABLE TO ITS SALES-FORCE CERTAIN INTERNAL-USE ONLY DOCUMENTS REGARDING THE STRATS. THESE DOCUMENTS DID NOT CONTAIN ADEQUATE DESCRIPTIONS OF THE PRODUCT, NOR DID THEY DISCLOSE THE DEGREE TO WHICH STRATS CUSTOMERS COULD LOSE PRINCIPAL IF THE UNDERLYING CAPITAL SECURITY WAS REDEEMED. ACCORDINGLY, THE FIRM'S INTERNAL-USE ONLY COMMUNICATIONS WERE NOT FAIR AND BALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THE FACTS SURROUNDING THE STRATS OR ITS RISKS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN SUPERVISORY PROCEDURES, INCLUDING TRAINING OF ITS REGISTERED REPRESENTATIVES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA SUITABILITY STANDARDS. THE FIRM'S SUPERVISORY SYSTEM FOR THE SALE OF STRATS WAS NOT REASONABLY DESIGNED BECAUSE IT FAILED TO INCLUDE ADEQUATE TRAINING FOR THE FIRM'S SALES-FORCE REGARDING THE RISKS OF INVESTING IN THE PRODUCT. THE FIRM DID NOT PROVIDE PRODUCT SPECIFIC TRAINING TO ITS REGISTERED REPRESENTATIVES, AND THE INTERNAL-USE ONLY MATERIALS MADE AVAILABLE TO ITS REGISTERED REPRESENTATIVES DID NOT ADEQUATELY INFORM ITS REPRESENTATIVES ABOUT THE RISKS OF INVESTING IN THE STRATS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED www.finra.org/brokercheck TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT MADE User Guidance UNSUITABLE RECOMMENDATIONS TO RETAIL CUSTOMERS TO PURCHASE STRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES (STRATS), A COMPLEX STRUCTURED PRODUCT THAT PAID A FLOATING RATE OF PERIODIC INCOME UP TO A MINIMUM OR MAXIMUM RATE, BASED ON THE STRATS TRUST'S INTEREST IN A CAPITAL SECURITY ISSUED BY A FINANCIAL INSTITUTION AND THE STRATS TRUST'S INTEREST IN AN INTEREST RATE SWAP CONTRACT. THE FIRM SOLD APPROXIMATELY $12 MILLION WORTH OF THE STRATS TO ITS RETAIL CUSTOMERS, IN BOTH PRIMARY AND SECONDARY MARKETS. ALTHOUGH THE FIRM PROVIDED ITS SALES-FORCE TRAINING ON STRUCTURED PRODUCTS, NONE OF THIS TRAINING RELATED SPECIFICALLY TO THE UNIQUE FEATURES AND RISKS OF THE STRATS. ADDITIONALLY, ALTHOUGH THE FIRM'S INTRANET PAGE DEDICATED TO FIXED INCOME PRODUCTS PROVIDED BASIC INFORMATION CONCERNING THE STRATS, IT DID NOT PROVIDE ANY INFORMATION CONCERNING THE RISKS OF INVESTING IN THESE PRODUCTS, AND SPECIFICALLY DID NOT ADDRESS THE RISKS TO CUSTOMER PRINCIPAL IN THE EVENT OF A REDEMPTION OF THE UNDERLYING CAPITAL SECURITY. UNDER THE TERMS OF THE PROSPECTUS FOR THE STRATS, THE AMOUNT PAID TO A CUSTOMER IN THE EVENT OF A TERMINATION WAS THE PROCEEDS OF THE REDEMPTION OF UNDERLYING CAPITAL SECURITY PLUS ACCRUED INTEREST AND LESS THE SWAP TERMINATION FEE. IN CERTAIN CIRCUMSTANCES, THE CUSTOMER WOULD FACE A SUBSTANTIAL RISK OF LOSS OF PRINCIPAL UPON TERMINATION OF THE STRATS DUE TO THE AMOUNT OF THE SWAP TERMINATION FEE. THE FIRM'S REGISTERED REPRESENTATIVES GENERALLY WERE NOT FAMILIAR WITH SUCH RISKS OF INVESTING IN THE STRATS AND WERE CONSEQUENTLY UNABLE TO EXPLAIN SUCH RISKS WHEN RECOMMENDING THE PRODUCT TO THE FIRM'S RETAIL CUSTOMERS. EVENTUALLY, THE FINANCIAL INSTITUTION REDEEMED THE UNDERLYING CAPITAL SECURITY, CAUSING THE STRATS TO BE TERMINATED. THE FINANCIAL INSTITUTION REDEEMED THE UNDERLYING CAPITAL SECURITY AT PAR VALUE PLUS ACCRUED INTEREST. BASED ON THE TERMS OF THE UNDERLYING SWAP AGREEMENT, CUSTOMERS RECEIVED THE PROCEEDS OF THE REDEMPTION AFTER THE SWAP TERMINATION FEE WAS PAID. AS A RESULT, AT THE TIME OF THE STRATS' TERMINATION, MANY CUSTOMERS HOLDING THE STRATS RECEIVED LESS, AND IN SOME CASES SIGNIFICANTLY LESS, THAN THE AMOUNT THEY PAID FOR THE STRATS. THE FIRM FAILED TO EDUCATE ITS REGISTERED REPRESENTATIVES REGARDING THE UNIQUE FEATURES AND RISKS OF THE STRATS. AS A RESULT, THE FIRM'S REGISTERED REPRESENTATIVES DID NOT COMPREHEND THE RISKS TO CUSTOMERS OF INVESTING IN THE STRATS AND THUS LACKED A REASONABLE BASIS FOR RECOMMENDING THESE PRODUCTS TO THE FIRM'S RETAIL CUSTOMERS. THE FINDINGS STATED THAT THE FIRM MADE AVAILABLE TO ITS SALES-FORCE CERTAIN INTERNAL-USE ONLY DOCUMENTS REGARDING THE STRATS. THESE DOCUMENTS DID NOT CONTAIN ADEQUATE DESCRIPTIONS OF THE PRODUCT, NOR DID THEY DISCLOSE THE DEGREE TO WHICH STRATS CUSTOMERS COULD LOSE PRINCIPAL IF THE UNDERLYING CAPITAL ©2021 FINRA. All rights reserved. Report aboutSECURITY WELLS FARGO WAS REDEEMED.CLEARING SERVICES, ACCORDINGLY, LLC THE FIRM'S INTERNAL-USE 87 ONLY COMMUNICATIONS WERE NOT FAIR AND BALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THE FACTS SURROUNDING THE STRATS OR ITS RISKS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN SUPERVISORY PROCEDURES, INCLUDING TRAINING OF ITS REGISTERED REPRESENTATIVES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA SUITABILITY STANDARDS. THE FIRM'S SUPERVISORY SYSTEM FOR THE SALE OF STRATS WAS NOT REASONABLY DESIGNED BECAUSE IT FAILED TO INCLUDE ADEQUATE TRAINING FOR THE FIRM'S SALES-FORCE REGARDING THE RISKS OF INVESTING IN THE PRODUCT. THE FIRM DID NOT PROVIDE PRODUCT SPECIFIC TRAINING TO ITS REGISTERED REPRESENTATIVES, AND THE INTERNAL-USE ONLY MATERIALS MADE AVAILABLE TO ITS REGISTERED REPRESENTATIVES DID NOT ADEQUATELY INFORM ITS REPRESENTATIVES ABOUT THE RISKS OF INVESTING IN THE STRATS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT MADE UNSUITABLE RECOMMENDATIONS TO RETAIL CUSTOMERS TO PURCHASE STRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES (STRATS), A COMPLEX STRUCTURED PRODUCT THAT PAID A FLOATING RATE OF PERIODIC INCOME UP TO A MINIMUM OR MAXIMUM RATE, BASED ON THE STRATS TRUST'S INTEREST IN A CAPITAL SECURITY ISSUED BY A FINANCIAL INSTITUTION AND THE STRATS TRUST'S INTEREST IN AN INTEREST RATE SWAP CONTRACT. THE FIRM SOLD APPROXIMATELY $12 MILLION WORTH OF THE STRATS TO ITS RETAIL CUSTOMERS, IN BOTH PRIMARY AND SECONDARY MARKETS. ALTHOUGH THE FIRM PROVIDED ITS SALES-FORCE TRAINING ON STRUCTURED PRODUCTS, NONE OF THIS TRAINING RELATED SPECIFICALLY TO THE UNIQUE FEATURES AND RISKS OF THE STRATS. ADDITIONALLY, ALTHOUGH THE FIRM'S INTRANET PAGE DEDICATED TO FIXED INCOME PRODUCTS PROVIDED BASIC INFORMATION CONCERNING THE STRATS, IT DID NOT PROVIDE ANY INFORMATION CONCERNING THE RISKS OF INVESTING IN THESE PRODUCTS, AND SPECIFICALLY DID NOT ADDRESS THE RISKS TO CUSTOMER PRINCIPAL IN THE EVENT OF A REDEMPTION OF THE UNDERLYING CAPITAL SECURITY. UNDER THE TERMS OF THE PROSPECTUS FOR THE STRATS, THE AMOUNT PAID TO A CUSTOMER IN THE EVENT OF A TERMINATION WAS THE PROCEEDS OF THE REDEMPTION OF UNDERLYING CAPITAL SECURITY PLUS ACCRUED INTEREST AND LESS THE SWAP TERMINATION FEE. IN CERTAIN CIRCUMSTANCES, THE CUSTOMER WOULD FACE A SUBSTANTIAL RISK OF LOSS OF PRINCIPAL UPON TERMINATION OF THE STRATS DUE TO THE AMOUNT OF THE SWAP TERMINATION FEE. THE FIRM'S REGISTERED REPRESENTATIVES GENERALLY WERE NOT FAMILIAR WITH SUCH RISKS OF INVESTING IN THE STRATS AND WERE CONSEQUENTLY UNABLE TO EXPLAIN SUCH RISKS WHEN RECOMMENDING THE PRODUCT TO THE FIRM'S RETAIL CUSTOMERS. EVENTUALLY, THE FINANCIAL INSTITUTION REDEEMED THE UNDERLYING CAPITAL SECURITY, CAUSING THE STRATS TO BE TERMINATED. THE FINANCIAL INSTITUTION REDEEMED THE UNDERLYING CAPITAL SECURITY AT PAR VALUE PLUS ACCRUED INTEREST. BASED ON THE TERMS OF THE UNDERLYING SWAP AGREEMENT, CUSTOMERS RECEIVED THE PROCEEDS OF THE REDEMPTION AFTER THE SWAP TERMINATION FEE WAS PAID. AS A RESULT, AT THE TIME OF THE STRATS' TERMINATION, MANY CUSTOMERS HOLDING THE STRATS RECEIVED LESS, AND IN SOME CASES SIGNIFICANTLY LESS, THAN THE AMOUNT THEY PAID FOR THE STRATS. THE FIRM FAILED TO EDUCATE ITS REGISTERED REPRESENTATIVES REGARDING THE UNIQUE FEATURES AND RISKS OF THE STRATS. AS A RESULT, THE FIRM'S REGISTERED REPRESENTATIVES DID NOT COMPREHEND THE RISKS TO CUSTOMERS OF INVESTING IN THE STRATS AND THUS LACKED A REASONABLE BASIS FOR RECOMMENDING THESE PRODUCTS TO THE FIRM'S RETAIL CUSTOMERS. THE FINDINGS STATED www.finra.org/brokercheck THAT THE FIRM MADE AVAILABLE TO ITS SALES-FORCE CERTAIN User Guidance INTERNAL-USE ONLY DOCUMENTS REGARDING THE STRATS. THESE DOCUMENTS DID NOT CONTAIN ADEQUATE DESCRIPTIONS OF THE PRODUCT, NOR DID THEY DISCLOSE THE DEGREE TO WHICH STRATS CUSTOMERS COULD LOSE PRINCIPAL IF THE UNDERLYING CAPITAL SECURITY WAS REDEEMED. ACCORDINGLY, THE FIRM'S INTERNAL-USE ONLY COMMUNICATIONS WERE NOT FAIR AND BALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THE FACTS SURROUNDING THE STRATS OR ITS RISKS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN SUPERVISORY PROCEDURES, INCLUDING TRAINING OF ITS REGISTERED REPRESENTATIVES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA SUITABILITY STANDARDS. THE FIRM'S SUPERVISORY SYSTEM FOR THE SALE OF STRATS WAS NOT REASONABLY DESIGNED BECAUSE IT FAILED TO INCLUDE ADEQUATE TRAINING FOR THE FIRM'S SALES-FORCE REGARDING THE RISKS OF INVESTING IN THE PRODUCT. THE FIRM DID NOT PROVIDE PRODUCT SPECIFIC TRAINING TO ITS REGISTERED REPRESENTATIVES, AND THE INTERNAL-USE ONLY MATERIALS MADE AVAILABLE TO ITS REGISTERED REPRESENTATIVES DID NOT ADEQUATELY INFORM ITS REPRESENTATIVES ABOUT THE RISKS OF INVESTING IN THE STRATS. Initiated By: FINRA Date Initiated: 08/03/2015 Docket/Case Number: 2012033568901

Principal Product Type: Other Other Product Type(s): STRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES / INTEREST RATE SWAP CONTRACT Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/03/2015 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 $500,000.00 Disgorgement/Restitution Other Sanctions Ordered: PLUS INTEREST ON THE RESTITUTION

Sanction Details: THE FIRM WAS CENSURED, FINED $500,000, AND ORDERED TO PAY $241,974.34, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.

THE $500,000 FINE PAID IN FULL ON AUGUST 18, 2015. 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 MADE UNSUITABLE RECOMMENDATIONS TO RETAIL CUSTOMERS TO PURCHASE STRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES (STRATS), A COMPLEX STRUCTURED PRODUCT THAT PAID A FLOATING RATE OF PERIODIC INCOME UP TO A MINIMUM OR MAXIMUM RATE, BASED ON THE STRATS TRUST'S INTEREST IN A CAPITAL SECURITY ISSUED BY A FINANCIAL INSTITUTION AND THE STRATS TRUST'S INTEREST IN AN INTEREST RATE SWAP CONTRACT. THE FIRM SOLD APPROXIMATELY $12 MILLION WORTH OF THE STRATS TO ITS RETAIL CUSTOMERS, IN BOTH PRIMARY AND SECONDARY MARKETS. ALTHOUGH THE FIRM PROVIDED ITS SALES-FORCE TRAINING ON STRUCTURED PRODUCTS, NONE OF THIS TRAINING RELATED SPECIFICALLY TO THE UNIQUE FEATURES AND RISKS OF THE STRATS. ADDITIONALLY, ALTHOUGH THE FIRM'S INTRANET PAGE DEDICATED TO FIXED INCOME PRODUCTS PROVIDED BASIC INFORMATION CONCERNING THE STRATS, IT DID NOT PROVIDE ANY INFORMATION CONCERNING THE RISKS OF INVESTING IN THESE PRODUCTS, AND SPECIFICALLY DID NOT ADDRESS THE RISKS TO CUSTOMER PRINCIPAL IN THE EVENT OF A REDEMPTION OF THE UNDERLYING CAPITAL SECURITY. UNDER THE TERMS OF THE PROSPECTUS FOR THE STRATS, THE AMOUNT PAID TO A CUSTOMER IN THE EVENT OF A TERMINATION WAS THE PROCEEDS OF THE REDEMPTION OF UNDERLYING CAPITAL SECURITY PLUS ACCRUED INTEREST AND LESS THE SWAP TERMINATION FEE. IN CERTAIN CIRCUMSTANCES, THE CUSTOMER WOULD FACE A SUBSTANTIAL RISK OF LOSS OF PRINCIPAL UPON TERMINATION OF THE STRATS DUE TO THE AMOUNT OF THE SWAP TERMINATION FEE. THE FIRM'S REGISTERED REPRESENTATIVES GENERALLY WERE NOT FAMILIAR WITH SUCH RISKS OF INVESTING IN THE STRATS AND WERE CONSEQUENTLY UNABLE TO EXPLAIN SUCH RISKS WHEN RECOMMENDING THE PRODUCT TO THE FIRM'S RETAIL CUSTOMERS. EVENTUALLY, THE FINANCIAL INSTITUTION REDEEMED THE UNDERLYING CAPITAL SECURITY, CAUSING THE STRATS TO BE TERMINATED. THE FINANCIAL INSTITUTION REDEEMED THE UNDERLYING CAPITAL SECURITY AT PAR VALUE PLUS ACCRUED INTEREST. BASED ON THE TERMS OF THE[NTC] STRATS, CUSTOMERS RECEIVED THE PROCEEDS OF THE REDEMPTION [NTC] OF THE ©2021 FINRA. All rights reserved. Report aboutUNDERLYING WELLS FARGO CAPITAL CLEARING SECURITY SERVICES, LESSLLC THE SWAP TERMINATION FEE PAID. 89 AS A RESULT, AT THE TIME OF THE STRATS' TERMINATION, MANY CUSTOMERS HOLDING THE STRATS RECEIVED LESS, AND IN SOME CASES SIGNIFICANTLY LESS, THAN THE AMOUNT THEY PAID FOR THE STRATS. NEVERTHELESS, THE FIRM'S REGISTERED REPRESENTATIVES DID NOT COMPREHEND THE RISKS TO CUSTOMERS OF INVESTING IN THE STRATS AND THUS LACKED A REASONABLE BASIS FOR RECOMMENDING THESE PRODUCTS TO THE FIRM'S RETAIL CUSTOMERS. THE FINDINGS STATED THAT THE FIRM MADE AVAILABLE TO ITS SALES-FORCE CERTAIN INTERNAL-USE ONLY DOCUMENTS REGARDING THE STRATS. THESE DOCUMENTS DID NOT CONTAIN ADEQUATE DESCRIPTIONS OF THE PRODUCT, NOR DID THEY DISCLOSE THE DEGREE TO WHICH STRATS CUSTOMERS COULD LOSE PRINCIPAL IF THE UNDERLYING CAPITAL SECURITY WAS REDEEMED. ACCORDINGLY, THE FIRM'S INTERNAL-USE ONLY COMMUNICATIONS WERE NOT FAIR AND BALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THE FACTS SURROUNDING THE STRATS OR ITS RISKS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN SUPERVISORY PROCEDURES, INCLUDING TRAINING OF ITS REGISTERED REPRESENTATIVES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA SUITABILITY STANDARDS. THE FIRM'S SUPERVISORY SYSTEM FOR THE SALE OF STRATS WAS NOT REASONABLY DESIGNED BECAUSE IT FAILED TO INCLUDE ADEQUATE TRAINING FOR THE FIRM'S SALES-FORCE REGARDING THE RISKS OF INVESTING IN THE PRODUCT. THE FIRM DID NOT PROVIDE PRODUCT SPECIFIC TRAINING TO ITS REGISTERED REPRESENTATIVES, AND THE INTERNAL-USE ONLY MATERIALS MADE AVAILABLE TO ITS REGISTERED REPRESENTATIVES DID NOT ADEQUATE INFORM ITS REPRESENTATIVES ABOUT THE RISKS OF INVESTING IN THE STRATS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT MADE UNSUITABLE RECOMMENDATIONS TO RETAIL CUSTOMERS TO PURCHASE STRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES (STRATS), A COMPLEX STRUCTURED PRODUCT THAT PAID A FLOATING RATE OF PERIODIC INCOME UP TO A MINIMUM OR MAXIMUM RATE, BASED ON THE STRATS TRUST'S INTEREST IN A CAPITAL SECURITY ISSUED BY A FINANCIAL INSTITUTION AND THE STRATS TRUST'S INTEREST IN AN INTEREST RATE SWAP CONTRACT. THE FIRM SOLD APPROXIMATELY $12 MILLION WORTH OF THE STRATS TO ITS RETAIL CUSTOMERS, IN BOTH PRIMARY AND SECONDARY MARKETS. ALTHOUGH THE FIRM PROVIDED ITS SALES-FORCE TRAINING ON STRUCTURED PRODUCTS, NONE OF THIS TRAINING RELATED SPECIFICALLY TO THE UNIQUE FEATURES AND RISKS OF THE STRATS. ADDITIONALLY, ALTHOUGH THE FIRM'S INTRANET PAGE DEDICATED TO FIXED INCOME PRODUCTS PROVIDED BASIC INFORMATION CONCERNING THE STRATS, IT DID NOT PROVIDE ANY INFORMATION CONCERNING THE RISKS OF INVESTING IN THESE PRODUCTS, AND SPECIFICALLY DID NOT ADDRESS THE RISKS TO CUSTOMER PRINCIPAL IN THE EVENT OF A REDEMPTION OF THE UNDERLYING CAPITAL SECURITY. UNDER THE TERMS OF THE PROSPECTUS FOR THE STRATS, THE AMOUNT PAID TO A CUSTOMER IN THE EVENT OF A TERMINATION WAS THE PROCEEDS OF THE REDEMPTION OF UNDERLYING CAPITAL SECURITY PLUS ACCRUED INTEREST AND LESS THE SWAP TERMINATION FEE. IN CERTAIN CIRCUMSTANCES, THE CUSTOMER WOULD FACE A SUBSTANTIAL RISK OF LOSS OF PRINCIPAL UPON TERMINATION OF THE STRATS DUE TO THE AMOUNT OF THE SWAP TERMINATION FEE. THE FIRM'S REGISTERED REPRESENTATIVES GENERALLY WERE NOT FAMILIAR WITH SUCH RISKS OF INVESTING IN THE STRATS AND WERE CONSEQUENTLY UNABLE TO EXPLAIN SUCH RISKS WHEN RECOMMENDING THE PRODUCT TO THE FIRM'S RETAIL CUSTOMERS. EVENTUALLY, THE FINANCIAL INSTITUTION REDEEMED THE UNDERLYING CAPITAL SECURITY, CAUSING THE STRATS www.finra.org/brokercheck TO BE TERMINATED. THE FINANCIAL INSTITUTION REDEEMED THE User Guidance UNDERLYING CAPITAL SECURITY AT PAR VALUE PLUS ACCRUED INTEREST. BASED ON THE TERMS OF THE[NTC] STRATS, CUSTOMERS RECEIVED THE PROCEEDS OF THE REDEMPTION [NTC] OF THE UNDERLYING CAPITAL SECURITY LESS THE SWAP TERMINATION FEE PAID. AS A RESULT, AT THE TIME OF THE STRATS' TERMINATION, MANY CUSTOMERS HOLDING THE STRATS RECEIVED LESS, AND IN SOME CASES SIGNIFICANTLY LESS, THAN THE AMOUNT THEY PAID FOR THE STRATS. NEVERTHELESS, THE FIRM'S REGISTERED REPRESENTATIVES DID NOT COMPREHEND THE RISKS TO CUSTOMERS OF INVESTING IN THE STRATS AND THUS LACKED A REASONABLE BASIS FOR RECOMMENDING THESE PRODUCTS TO THE FIRM'S RETAIL CUSTOMERS. THE FINDINGS STATED THAT THE FIRM MADE AVAILABLE TO ITS SALES-FORCE CERTAIN INTERNAL-USE ONLY DOCUMENTS REGARDING THE STRATS. THESE DOCUMENTS DID NOT CONTAIN ADEQUATE DESCRIPTIONS OF THE PRODUCT, NOR DID THEY DISCLOSE THE DEGREE TO WHICH STRATS CUSTOMERS COULD LOSE PRINCIPAL IF THE UNDERLYING CAPITAL SECURITY WAS REDEEMED. ACCORDINGLY, THE FIRM'S INTERNAL-USE ONLY COMMUNICATIONS WERE NOT FAIR AND BALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THE FACTS SURROUNDING THE STRATS OR ITS RISKS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN SUPERVISORY PROCEDURES, INCLUDING TRAINING OF ITS REGISTERED REPRESENTATIVES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA SUITABILITY STANDARDS. THE FIRM'S SUPERVISORY SYSTEM FOR THE SALE OF STRATS WAS NOT REASONABLY DESIGNED BECAUSE IT FAILED TO INCLUDE ADEQUATE TRAINING FOR THE FIRM'S SALES-FORCE REGARDING THE RISKS OF INVESTING IN THE PRODUCT. THE FIRM DID NOT PROVIDE PRODUCT SPECIFIC TRAINING TO ITS REGISTERED REPRESENTATIVES, AND THE INTERNAL-USE ONLY MATERIALS MADE AVAILABLE TO ITS REGISTERED REPRESENTATIVES DID NOT ADEQUATE INFORM ITS REPRESENTATIVES ABOUT THE RISKS OF INVESTING IN THE STRATS. Initiated By: FINRA Date Initiated: 08/03/2015 Docket/Case Number: 2012033568901

Principal Product Type: Other Other Product Type(s): STRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/03/2015

Sanctions Ordered: Censure Monetary/Fine $500,000.00 Disgorgement/Restitution Other Sanctions Ordered: PLUS INTEREST ON THE RESTITUTION Sanction Details: THE FIRM WAS CENSURED, FINED $500,000, AND ORDERED TO PAY $241,974.34, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. i Disclosure 27 of 167 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 DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALES CHARGE. THE FINDINGS STATED THAT THESE CUSTOMERS WERE INSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT ELIGIBLE CUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TO ADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DID NOT PROVIDE SALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES. Initiated By: FINRA Date Initiated: 07/06/2015 Docket/Case Number: 2014042689901

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

Resolution Date: 07/06/2015 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 Disgorgement/Restitution Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM IS CENSURED, ORDERED TO PROVIDE RESTITUTION TO CUSTOMERS, WHICH INCLUDES THE SALES CHARGE PAID, PLUS INTEREST, AND WITH RESPECT TO ANY ELIGIBLE CUSTOMER THAT PURCHASED CLASS B OR C SHARES AND STILL HOLDS SUCH SHARES IN AN ACCOUNT AT THE FIRM, IT SHALL OFFER SUCH CUSTOMER THE OPTION OF CONVERTING SUCH CLASS B OR C SHARES TO CLASS A SHARES. IF AN ELIGIBLE FUND DOES NOT PERMIT CONVERSION OF CLASS B OR C SHARES TO CLASS A SHARES, THE ELIGIBLE CUSTOMER SHALL BE PROVIDED THE OPTION OF REPLACING CLASS B OR C SHARES WITH AN EQUIVALENT VALUE OF CLASS A SHARES OFFERED BY ANOTHER ELIGIBLE FUND. THE FIRM SHALL CAUSE SUCH CONVERSION TO OCCUR AT NO EXPENSE TO THE CUSTOMER. 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 DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALES CHARGE. THE FINDINGS STATED THAT THESE CUSTOMERS WERE INSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT ELIGIBLE CUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TO ADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DID NOT PROVIDE SALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES. Initiated By: FINRA ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 92 www.finra.org/brokercheck User Guidance

Initiated By: FINRA Date Initiated: 07/06/2015 Docket/Case Number: 2014042689901

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/06/2015 Sanctions Ordered: Censure Disgorgement/Restitution Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM IS CENSURED, ORDERED TO PROVIDE RESTITUTION TO CUSTOMERS, WHICH INCLUDES THE SALES CHARGE PAID, PLUS INTEREST, AND WITH RESPECT TO ANY ELIGIBLE CUSTOMER THAT PURCHASED CLASS B OR C SHARES AND STILL HOLDS SUCH SHARES IN AN ACCOUNT AT THE FIRM, IT SHALL OFFER SUCH CUSTOMER THE OPTION OF CONVERTING SUCH CLASS B OR C SHARES TO CLASS A SHARES. IF AN ELIGIBLE FUND DOES NOT PERMIT CONVERSION OF CLASS B OR C SHARES TO CLASS A SHARES, THE ELIGIBLE CUSTOMER SHALL BE PROVIDED THE OPTION OF REPLACING CLASS B OR C SHARES WITH AN EQUIVALENT VALUE OF CLASS A SHARES OFFERED BY ANOTHER ELIGIBLE FUND. THE FIRM SHALL CAUSE SUCH CONVERSION TO OCCUR AT NO EXPENSE TO THE CUSTOMER. i Disclosure 28 of 167 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 ACCEPTED AND HELD CUSTOMER MARKET ORDERS, TRADED FOR ITS OWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIED THE CUSTOMER MARKET ORDERS, AND FAILED TO IMMEDIATELY THEREAFTER EXECUTE THE CUSTOMER MARKET ORDERS. THE FINDINGS STATED THAT THE FIRM FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF BROKERAGE ORDERS AND FAILED TO SHOW THE ©2021 FINRA. All rights reserved. Report aboutCORRECT WELLS FARGO TIME OFCLEARING ENTRY SERVICES, ON THE LLC MEMORANDUM OF BROKERAGE 93 ORDERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORT THE CORRECT TIME OF EXECUTION TO THE OTC REPORTING FACILITY (OTCRF) LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES. THE FINDINGS ALSO INCLUDED 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, CONCERNING OTC ORDER PROTECTION. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE WSPS CONCERNING OTC ORDER PROTECTION. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ACCEPTED AND HELD CUSTOMER MARKET ORDERS, TRADED FOR ITS OWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIED THE CUSTOMER www.finra.org/brokercheck MARKET ORDERS, AND FAILED TO IMMEDIATELY THEREAFTER EXECUTE User Guidance THE CUSTOMER MARKET ORDERS. THE FINDINGS STATED THAT THE FIRM FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF BROKERAGE ORDERS AND FAILED TO SHOW THE CORRECT TIME OF ENTRY ON THE MEMORANDUM OF BROKERAGE ORDERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORT THE CORRECT TIME OF EXECUTION TO THE OTC REPORTING FACILITY (OTCRF) LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES. THE FINDINGS ALSO INCLUDED 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, CONCERNING OTC ORDER PROTECTION. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE WSPS CONCERNING OTC ORDER PROTECTION. Initiated By: FINRA Date Initiated: 05/06/2015 Docket/Case Number: 2012035222801

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: 05/06/2015 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 $35,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $35,000, AND UNDERTAKES TO REVISE ITS WSPS TO ADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC. FINE PAID IN FULL ON 5/28/2015. 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 ACCEPTED AND HELD CUSTOMER MARKET ORDERS, TRADED FOR ITS OWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIED THE CUSTOMER MARKET ORDERS, AND FAILED TO IMMEDIATELY THEREAFTER EXECUTE THE CUSTOMER MARKET ORDERS. THE FINDINGS STATED THAT THE FIRM FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF BROKERAGE ORDERS AND FAILED TO SHOW THE CORRECT TIME OF ENTRY ON THE MEMORANDUM OF BROKERAGE ORDERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORT THE CORRECT TIME OF EXECUTION TO THE OTC REPORTING FACILITY (OTCRF) LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES. THE FINDINGS ALSO INCLUDED 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, CONCERNING OTC ORDER PROTECTION. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE WSPS CONCERNING OTC ORDER PROTECTION. Initiated By: FINRA Date Initiated: 05/06/2015 Docket/Case Number: 2012035222801

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: 05/06/2015 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine WELLS FARGO $35,000.00 CLEARING SERVICES, LLC 95 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $35,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED, FINED $35,000, AND UNDERTAKES TO REVISE ITS WSPS TO ADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC. Firm Statement THE FIRM WAS CENSURED, FINED $35,000, AND UNDERTAKES TO REVISE ITS WSPS TO ADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC. i Disclosure 29 of 167 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 FOR SEVERAL YEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECT OF THE ANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAM REQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSE REQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH AND MAINTAIN A CUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICH IT VERIFIES THE IDENTITY OF EACH CUSTOMER OPENING A NEW ACCOUNT, AND, DURING THE RELEVANT PERIOD, THE FIRM'S CIP WAS DEFICIENT, IN THAT IT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TO IDENTITY VERIFICATION. THE FINDINGS STATED THAT DURING THE RELEVANT PERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSING SYSTEM, THE BETA SYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEW SECURITIES ACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERS PREVIOUSLY ASSIGNED TO ACCOUNTS THAT HAD BEEN CLOSED. WHEN THIS HAPPENED, THE CIP SYSTEM RECOGNIZED THE IDENTIFIERS AND TREATED THE NEW ACCOUNTS AS IF THEY HAD ALREADY GONE THROUGH THE CIP SYSTEM. THUS, EVEN THOUGH THE APPURTENANT CUSTOMER INFORMATION - SUCH AS CUSTOMER NAME, ADDRESS, TAX- IDENTIFICATION NUMBER, AND DATE OF BIRTH - WAS DIFFERENT FROM THE PREVIOUS INSTANCE OF IDENTITY VERIFICATION, THE CIP SYSTEM DID NOT SUBJECT THE CUSTOMERS ASSOCIATED WITH THESE NEW ACCOUNTS TO IDENTITY VERIFICATION. FOR THAT REASON, THE FIRM'S CIP SYSTEM DID NOT VERIFY THE IDENTITIES OF NEW CUSTOMERS WITH RECYCLED IDENTIFIERS. THIS RESULTED IN THE FIRMS' FAILURE TO CONDUCT CUSTOMER-IDENTITY VERIFICATION FOR NEARLY 220,000 ACCOUNTS DURING THE RELEVANT PERIOD. THE FINDINGS ALSO STATED THAT OF THE ACCOUNTS THAT WERE NOT SUBJECTED TO IDENTITY VERIFICATION, APPROXIMATELY 120,000 WERE ALREADY CLOSED WHEN THE PROBLEM CAME TO LIGHT. THESE ACCOUNTS WERE NEVER SUBJECTED TO IDENTITY VERIFICATION. THE ACCOUNTS THAT WERE STILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAW WERE ©2021 FINRA. All rights reserved. Report aboutSUBSEQUENTLY WELLS FARGO CLEARING SENT THROUGH SERVICES, THELLC CIP PROCESS, WITH THE FIRM 96 EVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTS FOR WHICH IDENTITY VERIFICATION COULD NOT BE COMPLETED. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR SEVERAL YEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECT OF THE ANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAM REQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSE REQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH AND MAINTAIN A CUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICH IT VERIFIES THE IDENTITY OF EACH CUSTOMER OPENING A NEW ACCOUNT, AND, DURING THE RELEVANT PERIOD, THE FIRM'S CIP WAS DEFICIENT, IN THAT IT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TO IDENTITY VERIFICATION. THE FINDINGS STATED THAT DURING THE RELEVANT PERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSING SYSTEM, THE BETA SYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEW SECURITIES ACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERS PREVIOUSLY ASSIGNED TO ACCOUNTS THAT HAD BEEN CLOSED. WHEN THIS HAPPENED, THE CIP SYSTEM RECOGNIZED THE IDENTIFIERS AND TREATED THE NEW ACCOUNTS AS IF THEY HAD ALREADY GONE THROUGH THE CIP SYSTEM. THUS, EVEN THOUGH THE APPURTENANT CUSTOMER INFORMATION - SUCH AS CUSTOMER NAME, ADDRESS, TAX- IDENTIFICATION NUMBER, AND DATE OF BIRTH - WAS DIFFERENT FROM THE PREVIOUS INSTANCE OF IDENTITY VERIFICATION, THE CIP SYSTEM DID NOT SUBJECT THE CUSTOMERS ASSOCIATED WITH THESE NEW ACCOUNTS TO IDENTITY VERIFICATION. FOR THAT REASON, THE FIRM'S CIP SYSTEM DID NOT VERIFY THE IDENTITIES OF NEW CUSTOMERS WITH RECYCLED IDENTIFIERS. THIS RESULTED IN THE FIRMS' FAILURE TO CONDUCT CUSTOMER-IDENTITY VERIFICATION FOR NEARLY 220,000 ACCOUNTS DURING THE RELEVANT PERIOD. THE FINDINGS ALSO STATED www.finra.org/brokercheck THAT OF THE ACCOUNTS THAT WERE NOT SUBJECTED TO IDENTITY User Guidance VERIFICATION, APPROXIMATELY 120,000 WERE ALREADY CLOSED WHEN THE PROBLEM CAME TO LIGHT. THESE ACCOUNTS WERE NEVER SUBJECTED TO IDENTITY VERIFICATION. THE ACCOUNTS THAT WERE STILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAW WERE SUBSEQUENTLY SENT THROUGH THE CIP PROCESS, WITH THE FIRM EVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTS FOR WHICH IDENTITY VERIFICATION COULD NOT BE COMPLETED. Initiated By: FINRA Date Initiated: 12/18/2014 Docket/Case Number: 2012034123501

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: 12/18/2014 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 $1,500,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, JOINTLY AND SEVERALLY, $1,500,000.

FINE PAID IN FULL ON JANUARY 12, 2015. Regulator Statement IN DETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDERED THAT THE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGH THE FIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST, INVESTIGATED THEIR CAUSES AND SCOPE, PERFORMED REMEDIATION CIP ON THE APPROXIMATELY 100,000 AFFECTED ACCOUNTS THAT REMAINED OPEN, MADE PROGRAMMING CHANGES TO THE CIP SYSTEM AND TO THE FIRM'S BETA IN AN EFFORT TO PREVENT RECURRENCES, AND REPORTED THE VIOLATIONS TO FINRA IN ACCORDANCE WITH RULE 4530(B).

i Reporting Source: Firm Current Status: Final Allegations: FINRA HAS ALLEGED POTENTIAL VIOLATIONS OF FINRA RULES 3310 AND 2010 AND NASD RULE 2110. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR SEVERAL YEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECT OF THE ANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAM REQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSE REQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH AND MAINTAIN A CUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICH IT VERIFIES THE IDENTITY OF EACH CUSTOMER OPENING A NEW ACCOUNT, AND, DURING THE RELEVANT PERIOD, THE FIRM'S CIP WAS DEFICIENT, IN THAT IT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TO IDENTITY VERIFICATION. THE FINDINGS STATED THAT DURING THE RELEVANT PERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSING SYSTEM, THE BETA SYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEW SECURITIES ACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERS PREVIOUSLY ASSIGNED TO ACCOUNTS THAT HAD BEEN CLOSED. WHEN THIS HAPPENED, THE CIP SYSTEM RECOGNIZED THE IDENTIFIERS AND TREATED THE NEW ACCOUNTS AS IF THEY HAD ALREADY GONE THROUGH THE CIP SYSTEM. THUS, EVEN THOUGH THE APPURTENANT CUSTOMER INFORMATION - SUCH AS CUSTOMER NAME, ADDRESS, TAX-IDENTIFICATION NUMBER, AND DATE OF BIRTH - WAS DIFFERENT FROM THE PREVIOUS INSTANCE OF IDENTITY VERIFICATION, THE CIP SYSTEM DID NOT SUBJECT THE CUSTOMERS ASSOCIATED WITH THESE NEW ACCOUNTS TO IDENTITY VERIFICATION. FOR THAT REASON, THE FIRM'S CIP SYSTEM DID NOT VERIFY THE IDENTITIES OF NEW CUSTOMERS WITH RECYCLED IDENTIFIERS. THIS RESULTED IN THE FIRMS' FAILURE TO CONDUCT CUSTOMER-IDENTITY VERIFICATION FOR NEARLY 220,000 ACCOUNTS DURING THE RELEVANT PERIOD. THE FINDINGS ALSO STATED THAT OF THE ACCOUNTS THAT WERE NOT SUBJECTED TO IDENTITY VERIFICATION, APPROXIMATELY 120,000 WERE ALREADY CLOSED WHEN THE PROBLEM CAME TO LIGHT. THESE ACCOUNTS WERE NEVER SUBJECTED TO IDENTITY VERIFICATION. THE ACCOUNTS THAT WERE STILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAW WERE SUBSEQUENTLY SENT THROUGH THE CIP PROCESS, WITH THE FIRM EVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTS ©2021 FINRA. All rights reserved. Report aboutFOR WELLS WHICH FARGO IDENTITY CLEARING VERIFICATION SERVICES, LLC COULD NOT BE COMPLETED. IN 98 DETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDERED THAT THE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGH THE FIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST, INVESTIGATED THEIR CAUSES AND SCOPE, PERFORMED REMEDIATION CIP ON THE APPROXIMATELY 100,000 AFFECTED ACCOUNTS THAT REMAINED OPEN, MADE PROGRAMMING CHANGES TO THE CIP SYSTEM AND TO THE FIRM'S BETA IN AN EFFORT TO PREVENT RECURRENCES, AND REPORTED THE VIOLATIONS TO FINRA IN ACCORDANCE WITH RULE 4530(B). FINRA HAS ALLEGED POTENTIAL VIOLATIONS OF FINRA RULES 3310 AND 2010 AND NASD RULE 2110. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR SEVERAL YEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECT OF THE ANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAM REQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSE REQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH AND MAINTAIN A CUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICH IT VERIFIES THE IDENTITY OF EACH CUSTOMER OPENING A NEW ACCOUNT, AND, DURING THE RELEVANT PERIOD, THE FIRM'S CIP WAS DEFICIENT, IN THAT IT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TO IDENTITY VERIFICATION. THE FINDINGS STATED THAT DURING THE RELEVANT PERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSING SYSTEM, THE BETA SYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEW SECURITIES ACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERS PREVIOUSLY ASSIGNED TO ACCOUNTS THAT HAD BEEN CLOSED. WHEN THIS HAPPENED, THE CIP SYSTEM RECOGNIZED THE IDENTIFIERS AND TREATED THE NEW ACCOUNTS AS IF THEY HAD ALREADY GONE THROUGH THE CIP SYSTEM. THUS, EVEN THOUGH THE APPURTENANT CUSTOMER INFORMATION - SUCH AS CUSTOMER NAME, ADDRESS, TAX-IDENTIFICATION NUMBER, AND DATE OF BIRTH - WAS DIFFERENT FROM THE PREVIOUS INSTANCE OF IDENTITY VERIFICATION, THE CIP SYSTEM DID NOT SUBJECT THE CUSTOMERS ASSOCIATED WITH THESE NEW ACCOUNTS TO IDENTITY VERIFICATION. FOR THAT REASON, THE FIRM'S CIP SYSTEM DID NOT VERIFY THE IDENTITIES OF NEW CUSTOMERS WITH RECYCLED IDENTIFIERS. THIS RESULTED IN THE FIRMS' FAILURE TO CONDUCT CUSTOMER-IDENTITY VERIFICATION FOR NEARLY 220,000 ACCOUNTS DURING THE RELEVANT PERIOD. THE FINDINGS ALSO STATED THAT OF THE ACCOUNTS THAT WERE NOT SUBJECTED TO IDENTITY VERIFICATION, APPROXIMATELY 120,000 WERE ALREADY CLOSED WHEN THE PROBLEM CAME TO LIGHT. THESE www.finra.org/brokercheck ACCOUNTS WERE NEVER SUBJECTED TO IDENTITY VERIFICATION. THE User Guidance ACCOUNTS THAT WERE STILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAW WERE SUBSEQUENTLY SENT THROUGH THE CIP PROCESS, WITH THE FIRM EVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTS FOR WHICH IDENTITY VERIFICATION COULD NOT BE COMPLETED. IN DETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDERED THAT THE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGH THE FIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST, INVESTIGATED THEIR CAUSES AND SCOPE, PERFORMED REMEDIATION CIP ON THE APPROXIMATELY 100,000 AFFECTED ACCOUNTS THAT REMAINED OPEN, MADE PROGRAMMING CHANGES TO THE CIP SYSTEM AND TO THE FIRM'S BETA IN AN EFFORT TO PREVENT RECURRENCES, AND REPORTED THE VIOLATIONS TO FINRA IN ACCORDANCE WITH RULE 4530(B). Initiated By: FINRA Date Initiated: 12/18/2014 Docket/Case Number: 2012034123501

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: 12/18/2014 Sanctions Ordered: Censure Monetary/Fine $1,500,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED, JOINTLY AND SEVERALLY, $1,500,000. Firm Statement IN DETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDERED THAT THE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGH THE FIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST, INVESTIGATED THEIR CAUSES AND SCOPE, PERFORMED REMEDIATION CIP ON THE APPROXIMATELY 100,000 AFFECTED ACCOUNTS THAT REMAINED OPEN, MADE PROGRAMMING CHANGES TO THE CIP SYSTEM AND TO THE FIRM'S BETA IN AN EFFORT TO PREVENT RECURRENCES, AND REPORTED THE VIOLATIONS TO FINRA IN ACCORDANCE WITH RULE 4530(B). i Disclosure 30 of 167

Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASE 34-73175, IA RELEASE 40-3928 / SEPTEMBER 22, 2014: 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 PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AGAINST WELLS FARGO ADVISORS, LLC ("WELLS FARGO ADVISORS" OR "RESPONDENT"). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. WELLS FARGO ADVISORS ADMITS THE FINDINGS, ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS, ADMITS THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, AND CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE- AND-DESIST PROCEEDINGS. THIS CASE INVOLVES THE FAILURE OF WELLS FARGO ADVISORS TO ADEQUATELY ESTABLISH, MAINTAIN, AND ENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION, SPECIFICALLY, THE MATERIAL NONPUBLIC INFORMATION OBTAINED FROM ITS CUSTOMERS AND ITS ADVISORY CLIENTS. WELLS FARGO ADVISORS' POLICIES AND PROCEDURES TO PREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION WERE NOT REASONABLY DESIGNED TO ADDRESS THE RISK THAT ITS ASSOCIATED PERSONS COULD OBTAIN MATERIAL NONPUBLIC INFORMATION FROM ITS CUSTOMERS AND ADVISORY CLIENTS EVEN THOUGH THE FIRM EXPRESSLY IDENTIFIED THAT RISK IN MULTIPLE INTERNAL DOCUMENTS. THIS RISK MANIFESTED ITSELF IN 2010 WHEN ONE OF THE REGISTERED REPRESENTATIVES OF WELLS FARGO ADVISORS MISAPPROPRIATED INFORMATION FROM ONE OF HIS CUSTOMERS ABOUT A COMPANY'S SECURITIES, TRADED ON THE BASIS OF THAT INFORMATION, AND TIPPED OTHERS INCLUDING SEVERAL OF HIS WELLS FARGO ADVISORS CUSTOMERS. THE MANNER IN WHICH THE POLICIES AND PROCEDURES WERE DESIGNED AFFECTED THE COMPANY SECURITIES REVIEW. MULTIPLE UNITS WITHIN THE FIRM RECEIVED INDICATIONS SUGGESTING THAT THE REGISTERED REPRESENTATIVE WAS MISUSING MATERIAL NONPUBLIC INFORMATION OBTAINED FROM A CUSTOMER TO TRADE IN THE COMPANY'S SECURITIES. BECAUSE OF A LACK OF ASSIGNED RESPONSIBILITY OR COORDINATION, EACH OF THESE UNITS FAILED TO TAKE NEEDED ACTIONS. THE POLICIES AND PROCEDURES DESIGNED CAUSED RESPONDENT NOT TO RECOGNIZE SEVERAL RED FLAGS THAT ITS REPRESENTATIVE WAS ENGAGING IN INSIDER TRADING IN THE COMPANY'S SECURITIES. IN ADDITION THE RESPONDENT DID NOT EFFECTIVELY MAINTAIN AND ©2021 FINRA. All rights reserved. Report aboutENFORCE WELLS FARGO THE POLICIES CLEARING SERVICES,AND PROCEDURES. LLC ADDITIONALLY, ALTHOUGH 100 THE POLICIES AND PROCEDURES REQUIRED "DAILY REVIEW TO IDENTIFY SITUATIONS WHEN PROFIT OR AVOIDANCE OF LOSS COULD MOST LIKELY RESULT FROM TRADING PRIOR TO THE PUBLIC RELEASE OF INFORMATION," FOR A TEN MONTH PERIOD THE RETAIL CONTROL GROUP (RCG), A UNIT IN THE FIRM'S COMPLIANCE DEPARTMENT, FAILED TO PERFORM REVIEWS IN A TIMELY MANNER OF AT LEAST 40 INSTANCES OF POSSIBLE INSIDER TRADING FLAGGED FOR REVIEW. WHEN THE RESPONDENT PRODUCED DOCUMENTS, AS REQUESTED BY THE COMMISSION, RELATING TO REVIEWS OF TRADING BY THE REGISTERED REPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES, IN RESPONSE TO THE COMMISSION'S REQUEST, DOCUMENTS RELATING TO THE RCG REVIEW OF THE SECURITIES TRADING WERE NOT PRODUCED. RESPONDENT UNREASONABLY DELAYED, WITHOUT ANY EXPLANATION, FOR SIX MONTHS PRODUCING DOCUMENTS RELATING TO THE RCG REVIEW OF THE REPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES. WHEN THE DOCUMENTS WERE PRODUCED, THE FIRM FAILED TO PRODUCE AN ACCURATE RECORD OF THE REVIEW AS IT EXISTED AT THE TIME OF THE REQUEST. INSTEAD, IT PRODUCED A DOCUMENT THAT HAD BEEN ALTERED BY AN EMPLOYEE. WHEN QUESTIONS AROSE SURROUNDING THE ALTERED DOCUMENT, THE EMPLOYEE WAS PLACED ON ADMINISTRATIVE LEAVE AND EVENTUALLY TERMINATED. AS A RESULT, RESPONDENT WILLFULLY VIOLATED SECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A- 4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT. SEC ADMIN RELEASE 34-73175, IA RELEASE 40-3928 / SEPTEMBER 22, 2014: 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 PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AGAINST WELLS FARGO ADVISORS, LLC ("WELLS FARGO ADVISORS" OR "RESPONDENT"). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. WELLS FARGO ADVISORS ADMITS THE FINDINGS, ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS, ADMITS THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, AND CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE- AND-DESIST PROCEEDINGS. THIS CASE INVOLVES THE FAILURE OF WELLS FARGO ADVISORS TO ADEQUATELY ESTABLISH, MAINTAIN, AND ENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION, SPECIFICALLY, THE MATERIAL NONPUBLIC INFORMATION OBTAINED FROM ITS CUSTOMERS AND ITS ADVISORY CLIENTS. WELLS FARGO ADVISORS' POLICIES AND PROCEDURES TO PREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION WERE NOT REASONABLY DESIGNED TO ADDRESS THE RISK THAT ITS ASSOCIATED PERSONS COULD OBTAIN MATERIAL NONPUBLIC INFORMATION FROM ITS CUSTOMERS AND ADVISORY CLIENTS EVEN THOUGH THE FIRM EXPRESSLY IDENTIFIED THAT RISK IN MULTIPLE INTERNAL DOCUMENTS. THIS RISK MANIFESTED ITSELF IN 2010 WHEN ONE OF THE REGISTERED REPRESENTATIVES OF WELLS FARGO ADVISORS MISAPPROPRIATED INFORMATION FROM ONE OF HIS CUSTOMERS ABOUT A COMPANY'S SECURITIES, TRADED ON THE BASIS OF THAT INFORMATION, AND TIPPED OTHERS INCLUDING SEVERAL OF HIS WELLS FARGO ADVISORS CUSTOMERS. THE MANNER IN WHICH THE POLICIES AND PROCEDURES WERE DESIGNED AFFECTED THE COMPANY SECURITIES REVIEW. MULTIPLE UNITS WITHIN THE FIRM RECEIVED INDICATIONS SUGGESTING THAT THE REGISTERED REPRESENTATIVE WAS MISUSING MATERIAL NONPUBLIC INFORMATION OBTAINED FROM A CUSTOMER TO TRADE IN THE COMPANY'S SECURITIES. BECAUSE OF A LACK OF ASSIGNED RESPONSIBILITY OR COORDINATION, www.finra.org/brokercheck EACH OF THESE UNITS FAILED TO TAKE NEEDED ACTIONS. THE POLICIES User Guidance AND PROCEDURES DESIGNED CAUSED RESPONDENT NOT TO RECOGNIZE SEVERAL RED FLAGS THAT ITS REPRESENTATIVE WAS ENGAGING IN INSIDER TRADING IN THE COMPANY'S SECURITIES. IN ADDITION THE RESPONDENT DID NOT EFFECTIVELY MAINTAIN AND ENFORCE THE POLICIES AND PROCEDURES. ADDITIONALLY, ALTHOUGH THE POLICIES AND PROCEDURES REQUIRED "DAILY REVIEW TO IDENTIFY SITUATIONS WHEN PROFIT OR AVOIDANCE OF LOSS COULD MOST LIKELY RESULT FROM TRADING PRIOR TO THE PUBLIC RELEASE OF INFORMATION," FOR A TEN MONTH PERIOD THE RETAIL CONTROL GROUP (RCG), A UNIT IN THE FIRM'S COMPLIANCE DEPARTMENT, FAILED TO PERFORM REVIEWS IN A TIMELY MANNER OF AT LEAST 40 INSTANCES OF POSSIBLE INSIDER TRADING FLAGGED FOR REVIEW. WHEN THE RESPONDENT PRODUCED DOCUMENTS, AS REQUESTED BY THE COMMISSION, RELATING TO REVIEWS OF TRADING BY THE REGISTERED REPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES, IN RESPONSE TO THE COMMISSION'S REQUEST, DOCUMENTS RELATING TO THE RCG REVIEW OF THE SECURITIES TRADING WERE NOT PRODUCED. RESPONDENT UNREASONABLY DELAYED, WITHOUT ANY EXPLANATION, FOR SIX MONTHS PRODUCING DOCUMENTS RELATING TO THE RCG REVIEW OF THE REPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES. WHEN THE DOCUMENTS WERE PRODUCED, THE FIRM FAILED TO PRODUCE AN ACCURATE RECORD OF THE REVIEW AS IT EXISTED AT THE TIME OF THE REQUEST. INSTEAD, IT PRODUCED A DOCUMENT THAT HAD BEEN ALTERED BY AN EMPLOYEE. WHEN QUESTIONS AROSE SURROUNDING THE ALTERED DOCUMENT, THE EMPLOYEE WAS PLACED ON ADMINISTRATIVE LEAVE AND EVENTUALLY TERMINATED. AS A RESULT, RESPONDENT WILLFULLY VIOLATED SECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A- 4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/22/2014 Docket/Case Number: 3-16153

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

Resolution: Order Resolution Date: 09/22/2014 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 101 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 $5,000,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKINGS Sanction Details: RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) PROMULGATED THEREUNDER AND SECTIONS 204A AND 204(A) OF THE ADVISERS ACT. RESPONDENT IS CENSURED. RESPONDENT SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $5,000,000. RESPONDENT SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THIS ORDER.

WILLFULLY VIOLATED SECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT. i Reporting Source: Firm Current Status: Final Allegations: SEC ADMIN RELEASE 34-73175, IA RELEASE 40-3928/SEPTEMBER 22, 2014: 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 PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AGAINST WELLS FARGO ADVISORS, LLC ("WELLS FARGO ADVISORS" OR "RESPONDENT"). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. WELLS FARGO ADVISORS ADMITS THE FINDINGS, ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS, ADMITS THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, AND CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE- AND-DESIST PROCEEDINGS. THIS CASE INVOLVES THE FAILURE OF WELLS FARGO ADVISORS TO ADEQUATELY ESTABLISH, MAINTAIN, AND ©2021 FINRA. All rights reserved. Report aboutENFORCE WELLS FARGO POLICIES CLEARING AND SERVICES,PROCEDURES LLC REASONABLY DESIGNED TO 102 PREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION, SPECIFICALLY, THE MATERIAL NONPUBLIC INFORMATION OBTAINED FROM ITS CUSTOMERS AND ITS ADVISORY CLIENTS. WELLS FARGO ADVISORS' POLICIES AND PROCEDURES TO PREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION WERE NOT REASONABLY DESIGNED TO ADDRESS THE RISK THAT ITS ASSOCIATED PERSONS COULD OBTAIN MATERIAL NONPUBLIC INFORMATION FROM ITS CUSTOMERS AND ADVISORY CLIENTS EVEN THOUGH THE FIRM EXPRESSLY IDENTIFIED THAT RISK IN MULTIPLE INTERNAL DOCUMENTS. THIS RISK MANIFESTED ITSELF IN 2010 WHEN ONE OF THE REGISTERED REPRESENTATIVES OF WELLS FARGO ADVISORS MISAPPROPRIATED INFORMATION FROM ONE OF HIS CUSTOMERS ABOUT A COMPANY'S SECURITIES, TRADED ON THE BASIS OF THAT INFORMATION,AND TIPPED OTHERS INCLUDING SEVERAL OF HIS WELLS FARGO ADVISORS CUSTOMERS. THE MANNER IN WHICH THE POLICIES AND PROCEDURES WERE DESIGNED AFFECTED THE COMPANY SECURITIES REVIEW. MULTIPLE UNITS WITHIN THE FIRM RECEIVED INDICATIONS SUGGESTING THAT THE REGISTERED REPRESENTATIVE WAS MISUSING MATERIAL NONPUBLIC INFORMATION OBTAINED FROM A CUSTOMER TO TRADE IN THE COMPANY'S SECURITIES. BECAUSE OF A LACK OF ASSIGNED RESPONSIBILITY OR COORDINATION, EACH OF THESE UNITS FAILED TO TAKE NEEDED ACTIONS. THE POLICIES AND PROCEDURES DESIGNED CAUSED RESPONDENT NOT TO RECOGNIZE SEVERAL RED FLAGS THAT ITS REPRESENTATIVE WAS ENGAGING IN INSIDER TRADING IN THE COMPANY'S SECURITIES. IN ADDITION THE RESPONDENT DID NOT EFFECTIVELY MAINTAIN AND ENFORCE THE POLICIES AND PROCEDURES. ADDITIONALLY, ALTHOUGH THE POLICIES AND PROCEDURES REQUIRED "DAILY REVIEW TO IDENTIFY SITUATIONS WHEN PROFIT OR AVOIDANCE OF LOSS COULD MOST LIKELY RESULT FROM TRADING PRIOR TO THE PUBLIC RELEASE OF INFORMATION," FOR A TEN MONTH PERIOD THE RETAIL CONTROL GROUP (RCG), A UNIT IN THE FIRM'S COMPLIANCE DEPARTMENT, FAILED TO PERFORM REVIEWS IN A TIMELY MANNER OF AT LEAST 40 INSTANCES OF POSSIBLE INSIDER TRADING FLAGGED FOR REVIEW. WHEN THE RESPONDENT PRODUCED DOCUMENTS, AS REQUESTED BY THE COMMISSION,RELATING TO REVIEWS OF TRADING BY THE REGISTERED REPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES, IN RESPONSE TO THE COMMISSION'S REQUEST,DOCUMENTS RELATING TO THE RCG REVIEW OF THE SECURITIES TRADING WERE NOT PRODUCED. RESPONDENT UNREASONABLY DELAYED,WITHOUT ANY EXPLANATION,FOR SIX MONTHS PRODUCING DOCUMENTS RELATING TO THE RCG REVIEW OF THE REPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES. WHEN THE DOCUMENTS WERE PRODUCED, THE FIRM FAILED TO PRODUCE AN ACCURATE RECORD OF THE REVIEW AS IT EXISTED AT THE TIME OF THE REQUEST. INSTEAD, IT PRODUCED A DOCUMENT THAT HAD BEEN ALTERED BY AN EMPLOYEE. WHEN QUESTIONS AROSE SURROUNDING THE ALTERED DOCUMENT, THE EMPLOYEE WAS PLACED ON ADMINISTRATIVE LEAVE AND EVENTUALLY TERMINATED. AS A RESULT, RESPONDENT WILLFULLY VIOLATED SECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A- 4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT. SEC ADMIN RELEASE 34-73175, IA RELEASE 40-3928/SEPTEMBER 22, 2014: 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 PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AGAINST WELLS FARGO ADVISORS, LLC ("WELLS FARGO ADVISORS" OR "RESPONDENT"). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. WELLS FARGO ADVISORS ADMITS THE FINDINGS, ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS, ADMITS THE COMMISSION'S JURISDICTION OVER IT www.finra.org/brokercheck AND THE SUBJECT MATTER OF THESE PROCEEDINGS, AND CONSENTS TO User Guidance THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE- AND-DESIST PROCEEDINGS. THIS CASE INVOLVES THE FAILURE OF WELLS FARGO ADVISORS TO ADEQUATELY ESTABLISH, MAINTAIN, AND ENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION, SPECIFICALLY, THE MATERIAL NONPUBLIC INFORMATION OBTAINED FROM ITS CUSTOMERS AND ITS ADVISORY CLIENTS. WELLS FARGO ADVISORS' POLICIES AND PROCEDURES TO PREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION WERE NOT REASONABLY DESIGNED TO ADDRESS THE RISK THAT ITS ASSOCIATED PERSONS COULD OBTAIN MATERIAL NONPUBLIC INFORMATION FROM ITS CUSTOMERS AND ADVISORY CLIENTS EVEN THOUGH THE FIRM EXPRESSLY IDENTIFIED THAT RISK IN MULTIPLE INTERNAL DOCUMENTS. THIS RISK MANIFESTED ITSELF IN 2010 WHEN ONE OF THE REGISTERED REPRESENTATIVES OF WELLS FARGO ADVISORS MISAPPROPRIATED INFORMATION FROM ONE OF HIS CUSTOMERS ABOUT A COMPANY'S SECURITIES, TRADED ON THE BASIS OF THAT INFORMATION,AND TIPPED OTHERS INCLUDING SEVERAL OF HIS WELLS FARGO ADVISORS CUSTOMERS. THE MANNER IN WHICH THE POLICIES AND PROCEDURES WERE DESIGNED AFFECTED THE COMPANY SECURITIES REVIEW. MULTIPLE UNITS WITHIN THE FIRM RECEIVED INDICATIONS SUGGESTING THAT THE REGISTERED REPRESENTATIVE WAS MISUSING MATERIAL NONPUBLIC INFORMATION OBTAINED FROM A CUSTOMER TO TRADE IN THE COMPANY'S SECURITIES. BECAUSE OF A LACK OF ASSIGNED RESPONSIBILITY OR COORDINATION, EACH OF THESE UNITS FAILED TO TAKE NEEDED ACTIONS. THE POLICIES AND PROCEDURES DESIGNED CAUSED RESPONDENT NOT TO RECOGNIZE SEVERAL RED FLAGS THAT ITS REPRESENTATIVE WAS ENGAGING IN INSIDER TRADING IN THE COMPANY'S SECURITIES. IN ADDITION THE RESPONDENT DID NOT EFFECTIVELY MAINTAIN AND ENFORCE THE POLICIES AND PROCEDURES. ADDITIONALLY, ALTHOUGH THE POLICIES AND PROCEDURES REQUIRED "DAILY REVIEW TO IDENTIFY SITUATIONS WHEN PROFIT OR AVOIDANCE OF LOSS COULD MOST LIKELY RESULT FROM TRADING PRIOR TO THE PUBLIC RELEASE OF INFORMATION," FOR A TEN MONTH PERIOD THE RETAIL CONTROL GROUP (RCG), A UNIT IN THE FIRM'S COMPLIANCE DEPARTMENT, FAILED TO PERFORM REVIEWS IN A TIMELY MANNER OF AT LEAST 40 INSTANCES OF POSSIBLE INSIDER TRADING FLAGGED FOR REVIEW. WHEN THE RESPONDENT PRODUCED DOCUMENTS, AS REQUESTED BY THE COMMISSION,RELATING TO REVIEWS OF TRADING BY THE REGISTERED REPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES, IN RESPONSE TO THE COMMISSION'S REQUEST,DOCUMENTS RELATING TO THE RCG REVIEW OF THE SECURITIES TRADING WERE NOT PRODUCED. RESPONDENT UNREASONABLY DELAYED,WITHOUT ANY EXPLANATION,FOR SIX MONTHS PRODUCING DOCUMENTS RELATING TO THE RCG REVIEW OF THE REPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES. WHEN THE DOCUMENTS WERE PRODUCED, THE FIRM FAILED TO PRODUCE AN ACCURATE RECORD OF THE REVIEW AS IT ©2021 FINRA. All rights reserved. Report aboutEXISTED WELLS AT FARGO THE CLEARING TIME OF SERVICES, THE REQUEST. LLC INSTEAD, IT PRODUCED A 103 DOCUMENT THAT HAD BEEN ALTERED BY AN EMPLOYEE. WHEN QUESTIONS AROSE SURROUNDING THE ALTERED DOCUMENT, THE EMPLOYEE WAS PLACED ON ADMINISTRATIVE LEAVE AND EVENTUALLY TERMINATED. AS A RESULT, RESPONDENT WILLFULLY VIOLATED SECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A- 4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT. SEC ADMIN RELEASE 34-73175, IA RELEASE 40-3928/SEPTEMBER 22, 2014: 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 PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AGAINST WELLS FARGO ADVISORS, LLC ("WELLS FARGO ADVISORS" OR "RESPONDENT"). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. WELLS FARGO ADVISORS ADMITS THE FINDINGS, ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS, ADMITS THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, AND CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE- AND-DESIST PROCEEDINGS. THIS CASE INVOLVES THE FAILURE OF WELLS FARGO ADVISORS TO ADEQUATELY ESTABLISH, MAINTAIN, AND ENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION, SPECIFICALLY, THE MATERIAL NONPUBLIC INFORMATION OBTAINED FROM ITS CUSTOMERS AND ITS ADVISORY CLIENTS. WELLS FARGO ADVISORS' POLICIES AND PROCEDURES TO PREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION WERE NOT REASONABLY DESIGNED TO ADDRESS THE RISK THAT ITS ASSOCIATED PERSONS COULD OBTAIN MATERIAL NONPUBLIC INFORMATION FROM ITS CUSTOMERS AND ADVISORY CLIENTS EVEN THOUGH THE FIRM EXPRESSLY IDENTIFIED THAT RISK IN MULTIPLE INTERNAL DOCUMENTS. THIS RISK MANIFESTED ITSELF IN 2010 WHEN ONE OF THE REGISTERED REPRESENTATIVES OF WELLS FARGO ADVISORS MISAPPROPRIATED INFORMATION FROM ONE OF HIS CUSTOMERS ABOUT A COMPANY'S SECURITIES, TRADED ON THE BASIS OF THAT INFORMATION,AND TIPPED OTHERS INCLUDING SEVERAL OF HIS WELLS FARGO ADVISORS CUSTOMERS. THE MANNER IN WHICH THE POLICIES AND PROCEDURES WERE DESIGNED AFFECTED THE COMPANY SECURITIES REVIEW. MULTIPLE UNITS WITHIN THE FIRM RECEIVED INDICATIONS SUGGESTING THAT THE REGISTERED REPRESENTATIVE WAS MISUSING MATERIAL NONPUBLIC INFORMATION OBTAINED FROM A CUSTOMER TO TRADE IN THE COMPANY'S SECURITIES. BECAUSE OF A LACK OF ASSIGNED RESPONSIBILITY OR COORDINATION, EACH OF THESE UNITS FAILED TO TAKE NEEDED ACTIONS. THE POLICIES AND PROCEDURES DESIGNED CAUSED RESPONDENT NOT TO RECOGNIZE SEVERAL RED FLAGS THAT ITS REPRESENTATIVE WAS ENGAGING IN INSIDER TRADING IN THE COMPANY'S SECURITIES. IN ADDITION THE RESPONDENT DID NOT EFFECTIVELY MAINTAIN AND ENFORCE THE POLICIES AND PROCEDURES. ADDITIONALLY, ALTHOUGH THE POLICIES AND PROCEDURES REQUIRED "DAILY REVIEW TO IDENTIFY SITUATIONS WHEN PROFIT OR AVOIDANCE OF LOSS COULD MOST LIKELY RESULT FROM TRADING PRIOR TO THE PUBLIC RELEASE OF INFORMATION," FOR A TEN MONTH PERIOD THE RETAIL CONTROL GROUP (RCG), A UNIT IN THE FIRM'S COMPLIANCE DEPARTMENT, FAILED TO PERFORM REVIEWS IN A TIMELY MANNER OF AT LEAST 40 INSTANCES OF POSSIBLE INSIDER TRADING FLAGGED FOR REVIEW. WHEN THE RESPONDENT PRODUCED DOCUMENTS, AS REQUESTED BY THE COMMISSION,RELATING TO REVIEWS OF TRADING BY THE REGISTERED REPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES, IN RESPONSE TO THE COMMISSION'S REQUEST,DOCUMENTS RELATING TO THE RCG REVIEW OF THE SECURITIES TRADING WERE NOT PRODUCED. www.finra.org/brokercheck RESPONDENT UNREASONABLY DELAYED,WITHOUT ANY User Guidance EXPLANATION,FOR SIX MONTHS PRODUCING DOCUMENTS RELATING TO THE RCG REVIEW OF THE REPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES. WHEN THE DOCUMENTS WERE PRODUCED, THE FIRM FAILED TO PRODUCE AN ACCURATE RECORD OF THE REVIEW AS IT EXISTED AT THE TIME OF THE REQUEST. INSTEAD, IT PRODUCED A DOCUMENT THAT HAD BEEN ALTERED BY AN EMPLOYEE. WHEN QUESTIONS AROSE SURROUNDING THE ALTERED DOCUMENT, THE EMPLOYEE WAS PLACED ON ADMINISTRATIVE LEAVE AND EVENTUALLY TERMINATED. AS A RESULT, RESPONDENT WILLFULLY VIOLATED SECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A- 4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/22/2014 Docket/Case Number: 3-16153

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

Resolution: Order Resolution Date: 09/22/2014 Sanctions Ordered: Censure Monetary/Fine $5,000,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) PROMULGATED THEREUNDER AND SECTIONS 204A AND 204(A) OF THE ADVISERS ACT. RESPONDENT IS CENSURED. RESPONDENT SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $5,000,000. WILLFULLY VIOLATED SECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT. Firm Statement SEE SANCTION DETAILS IN 12.B. i Disclosure 31 of 167 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, THROUGH A REGISTERED REPRESENTATIVE, DISSEMINATED SALES LITERATURE TO FIRM CUSTOMERS AND POTENTIAL CUSTOMERS THAT FAILED TO COMPLY WITH THE CONTENT STANDARDS OF NASD RULE 2210(D)(1). THE FINDINGS STATED THAT THE FIRM APPROVED THREE ITERATIONS OF THE SALES LITERATURE, WHICH MARKETED THE REGISTERED REPRESENTATIVE'S STOP-LOSS TRADING STRATEGY. THERE WERE NO SIGNIFICANT DIFFERENCES BETWEEN THE THREE VERSIONS OF THE ADVERTISEMENT. THE SALES LITERATURE CONTAINED UNWARRANTED STATEMENTS AND CLAIMS AND FAILED TO PROVIDE A SOUND BASIS FOR EVALUATING ALL OF THE FACTS ABOUT THE TRADING STRATEGY. IT FAILED TO PROVIDE A COMPREHENSIVE DESCRIPTION OF THE STOP-LOSS TRADING STRATEGY BECAUSE IT FAILED TO DESCRIBE THE MECHANICS OF THE STRATEGY AND PROVIDE A BALANCED DISCUSSION OF THE BENEFITS AND SHORTCOMINGS OF THE STRATEGY, AND THE ILLUSTRATION OF THE HYPOTHETICAL INVESTMENT INCLUDED IN THE SALES LITERATURE FAILED TO PROVIDE A COMPREHENSIVE DESCRIPTION OF THE INVESTMENT RETURNS. Initiated By: FINRA Date Initiated: 06/02/2014 Docket/Case Number: 2010023976502

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: 06/02/2014 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: Censure Monetary/Fine $25,000.00 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 105 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: SEE ABOVE Regulator Statement FINE PAID JUNE 12, 2014 i Reporting Source: Firm Current Status: Final Allegations: WELLS FARGO ADVISORS, LLC ("WFA") IS THE SUCCESSOR TO WELLS FARGO INVESTMENTS, LLC ("WFI") (CRD-10582). THE ALLEGATIONS SOLELY INVOLVE WFI'S DISSEMINATION OF SALES LITERATURE THAT FAILED TO CONFORM TO THE CONTENT STANDARDS OF NASD RULE 2210 AND FINRA RULE 2010. Initiated By: FINRA Date Initiated: 06/02/2014 Docket/Case Number: 2010023976502

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/02/2014 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: WELLS FARGO ADVISORS, LLC ("WFA") IS THE SUCCESSOR TO WELLS FARGO INVESTMENTS, LLC ("WFI") (CRD-10582). THE ALLEGATIONS SOLEY INVOLVE WFI'S DISSEMINATION OF SALES LITERATURE THAT FAILED TO CONFORM TO THE CONTENT STANDARDS OF NASD RULE 2210 AND FINRA 2010. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM THROUGH ITS SUCCESSOR CONSENTED TO A CENSURE AND $25,000 MONETARY FINE. THE FIRM SENT PAYMENT TO FINRA ON OR ABOUT JUNE 11, 2014. FINE PAID JUNE 12, 2014

i Disclosure 32 of 167 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 SOLD AGENCY BONDS TO ITS CUSTOMERS AND FAILED TO BUY OR SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WAS ENTITLED TO A PROFIT. Initiated By: FINRA Date Initiated: 07/15/2014 Docket/Case Number: 2012033330501

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/15/2014 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 $10,000.00 Disgorgement/Restitution Other Sanctions Ordered: ORDERED TO PAY RESTITUTION TO FIRM CUSTOMERS IN THE AMOUNT OF $5,032.12, PLUS INTEREST Sanction Details: SEE ABOVE Regulator Statement FINE PAID IN FULL ON JULY 31, 2014.

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 SOLD AGENCY BONDS TO ITS CUSTOMERS AND FAILED TO BUY OR SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WAS ENTITLED TO A PROFIT. Initiated By: FINRA Date Initiated: 07/15/2014 Docket/Case Number: 2012033330501

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/15/2014 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Disgorgement/Restitution Other Sanctions Ordered: ORDERED TO PAY RESTITUTION TO FIRM CUSTOMERS IN THE AMOUNT OF $5,032.12, PLUS INTEREST Sanction Details: SEE ABOVE i Disclosure 33 of 167 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULE 2010, MSRB RULES G-17, G-30(A) - WELLS FARGO ADVISORS, LLC BOUGHT OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT ©2021 FINRA. All rights reserved. Report aboutFROM WELLS CUSTOMERS FARGO CLEARING AND/OR SERVICES, SOLD LLC MUNICIPAL SECURITIES TO 108 CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKUP OR MARKDOWN) 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 IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM SOLD AGENCY BONDS TO ITS CUSTOMERS AND FAILED TO SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED, AND THAT THE FIRM WAS ENTITLED TO A PROFIT. www.finra.org/brokercheck User Guidance

Allegations: FINRA RULE 2010, MSRB RULES G-17, G-30(A) - WELLS FARGO ADVISORS, LLC BOUGHT OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKUP OR MARKDOWN) 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 IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM SOLD AGENCY BONDS TO ITS CUSTOMERS AND FAILED TO SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED, AND THAT THE FIRM WAS ENTITLED TO A PROFIT. Initiated By: FINRA Date Initiated: 12/23/2013 Docket/Case Number: 2009020171701

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/23/2013 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 $20,000.00 Disgorgement/Restitution Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 109 www.finra.org/brokercheck User Guidance

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 $20,000, OF WHICH $10,000 IS FOR MSRB RULE VIOLATIONS, AND ORDERED TO PAY $8,660.93, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. THE FIRM HAS ALREADY PAID FULL OR PARTIAL RESTITUTION FOR SEVERAL OF THE TRANSACTIONS. A REGISTERED FIRM PRINCIPAL 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 AFTER ACCEPTANCE OF THIS AWC. 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 KNOWN TO HAVE LAST RESIDED. FINE PAID IN FULL ON JANUARY 8, 2014. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULE 2010, MSRB RULES G-17, G-30(A) - WELLS FARGO ADVISORS, LLC BOUGHT OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKUP OR MARKDOWN) 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 IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM SOLD AGENCY BONDS TO ITS CUSTOMERS AND FAILED TO SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED, AND THAT THE FIRM WAS ENTITLED TO A PROFIT. Initiated By: FINRA Date Initiated: 12/23/2013 Docket/Case Number: 2009020171701

Principal Product Type: Debt - Municipal Other Product Type(s): AGENCY BONDS ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 110 www.finra.org/brokercheck User Guidance

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/23/2013 Sanctions Ordered: Censure Monetary/Fine $20,000.00 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 $20,000, OF WHICH $10,000 IS FOR MSRB RULE VIOLATIONS, AND ORDERED TO PAY $8,660.93, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. THE FIRM HAS ALREADY PAID FULL OR PARTIAL RESTITUTION FOR SEVERAL OF THE TRANSACTIONS. A REGISTERED FIRM PRINCIPAL 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 AFTER ACCEPTANCE OF THIS AWC. 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 KNOWN TO HAVE LAST RESIDED. FINE PAID IN FULL ON JANUARY 8, 2014. i Disclosure 34 of 167 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULE 2010, NASD INTERPRETATIVE MATERIAL 2110-2 - WELLS FARGO ADVISORS,LLC FAILED TO CONTEMPORANEOUSLY EXECUTE CUSTOMER LIMIT ORDERS IN 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: 11/18/2013 Docket/Case Number: 2011028036801

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/18/2013 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 $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 FIRM HAS ALREADY MADE RESTITUTION TO THE CUSTOMERS WHO RECEIVED INFERIOR PRICES AS A RESULT OF THESE VIOLATIONS. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULE 2010, NASD INTERPRETATIVE MATERIAL 2110-2 - WELLS FARGO ADVISORS,LLC FAILED TO CONTEMPORANEOUSLY EXECUTE CUSTOMER LIMIT ORDERS IN 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: 11/18/2013 Docket/Case Number: 2011028036801

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 112 Sought: www.finra.org/brokercheck User Guidance

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/18/2013 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 35 of 167 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULE 2010, NASD RULES 3010 AND 3012(A)(2)(B)(I): WELLS FARGO'S SUPERVISORY CONTROL SYSTEM FAILED TO INCLUDE A POLICY OR PROCEDURE REQUIRING A REVIEW TO DETECT OR PREVENT MULTIPLE TRANSMITTALS OF FUNDS FROM MULTIPLE CUSTOMERS GOING TO THE SAME THIRD PARTY ACCOUNTS. THE FIRM'S SYSTEM ALSO FAILED TO INCLUDE EXCEPTION REPORTS THAT WOULD HAVE IDENTIFIED MULTIPLE CUSTOMER WIRES GOING TO THE SAME THIRD PARTY ACCOUNT. CONSEQUENTLY, WELLS FARGO FAILED TO DETECT THAT A REGISTERED REPRESENTATIVE HAD INITIATED FUND TRANSFERS, TOTALING APPROXIMATELY $258,000, OUT OF TWO CUSTOMER ACCOUNTS, TO BANK ACCOUNTS THAT SHE OR HER FAMILY MEMBER APPARENTLY CONTROLLED. WELLS FARGO FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ADEQUATELY REVIEW AND MONITOR THE TRANSMITTALS OF FUNDS FROM THE ACCOUNTS OF CUSTOMERS TO THIRD PARTY ACCOUNTS AND OUTSIDE ENTITIES. Initiated By: FINRA Date Initiated: 09/12/2013 Docket/Case Number: 2012031047501

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/12/2013 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: 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 IT IS CENSURED AND FINED $150,000. FINE PAID IN FULL ON SEPTEMBER 27, 2013. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULE 2010, NASD RULES 3010 AND 3012(A)(2)(B)(I): WELLS FARGO'S SUPERVISORY CONTROL SYSTEM FAILED TO INCLUDE A POLICY OR PROCEDURE REQUIRING A REVIEW TO DETECT OR PREVENT MULTIPLE TRANSMITTALS OF FUNDS FROM MULTIPLE CUSTOMERS GOING TO THE SAME THIRD PARTY ACCOUNTS. THE FIRM'S SYSTEM ALSO FAILED TO INCLUDE EXCEPTION REPORTS THAT WOULD HAVE IDENTIFIED MULTIPLE CUSTOMER WIRES GOING TO THE SAME THIRD PARTY ACCOUNT. CONSEQUENTLY, WELLS FARGO FAILED TO DETECT THAT A REGISTERED REPRESENTATIVE HAD INITIATED FUND TRANSFERS, TOTALING APPROXIMATELY $258,000, OUT OF TWO CUSTOMER ACCOUNTS, TO BANK ACCOUNTS THAT SHE OR HER FAMILY MEMBER APPARENTLY CONTROLLED. WELLS FARGO FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ADEQUATELY REVIEW AND MONITOR THE TRANSMITTALS OF FUNDS FROM THE ACCOUNTS OF CUSTOMERS TO THIRD PARTY ACCOUNTS AND OUTSIDE ENTITIES. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 114 www.finra.org/brokercheck User Guidance

Initiated By: FINRA Date Initiated: 09/12/2013 Docket/Case Number: 2012031047501

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: 09/12/2013 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 IT IS CENSURED AND FINED $150,000. WELLS FARGO ADVISORS, LLC FULLY COMPENSATED THE AFFECTED CLIENTS, AND REPORTED THIS MATTER TO REGULATORS. THE FIRM ALSO REPORTED THE MATTER TO LAW ENFORCEMENT AND HAS COOPERATED WITH THEIR EFFORTS TO RESOLVE THIS MATTER." i Disclosure 36 of 167 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULE 2010: IN 25 TRANSACTIONS, THE FIRM PURCHASED AGENCY SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD AGENCY SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER IN THE COURSE OF ITS BUSINESS AT AN AGGREGATE PRICE THAT WAS NOT FAIR AND REASONABLE, AND IN SO DOING FAILED TO OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE. Initiated By: FINRA Date Initiated: 07/02/2013 Docket/Case Number: 2011026083001 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 115 www.finra.org/brokercheck User Guidance

Docket/Case Number: 2011026083001

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/02/2013 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 $35,000.00 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 $35,000 AND ORDERED TO PAY $17,384.81, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. A REGISTERED FIRM PRINCIPAL 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 Reporting Source: Firm Current Status: Final Allegations: WELLS FARGO ADVISORS, LLC IS THE SUCCESSOR OF WELLS FARGO INVESTMENTS. THE ALLEGATIONS RELATE SOLEY TO WELLS FARGO INVESTMENTS, LLC (CRD-10582)AND TRANSACTIONS AFFECTED BY IT, PRIOR TO JANUARY 2011, WHEN IT CEASED DOING BUSINESS. FINRA RULE 2010: IN 25 TRANSACTIONS, THE FIRM PURCHASED AGENCY SECURITIES ©2021 FINRA. All rights reserved. Report aboutFOR WELLS ITS OWN FARGO ACCOUNT CLEARING FROMSERVICES, A CUSTOMER LLC AND/OR SOLD AGENCY 116 SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER IN THE COURSE OF ITS BUSINESS AT AN AGGREGATE PRICE THAT WAS NOT FAIR AND REASONABLE, AND IN SO DOING FAILED TO OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE. www.finra.org/brokercheck WELLS FARGO ADVISORS, LLC IS THE SUCCESSOR OF WELLS FARGO User Guidance INVESTMENTS. THE ALLEGATIONS RELATE SOLEY TO WELLS FARGO INVESTMENTS, LLC (CRD-10582)AND TRANSACTIONS AFFECTED BY IT, PRIOR TO JANUARY 2011, WHEN IT CEASED DOING BUSINESS. FINRA RULE 2010: IN 25 TRANSACTIONS, THE FIRM PURCHASED AGENCY SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD AGENCY SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER IN THE COURSE OF ITS BUSINESS AT AN AGGREGATE PRICE THAT WAS NOT FAIR AND REASONABLE, AND IN SO DOING FAILED TO OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE. Initiated By: FINRA Date Initiated: 07/02/2013 Docket/Case Number: 2011026083001

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/02/2013 Sanctions Ordered: Censure Monetary/Fine $35,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WELLS FARGO ADVISORS, LLC IS THE SUCCESSOR OF WELLS FARGO INVESTMENTS. THE ALLEGATIONS RELATE SOLEY TO WELLS FARGO INVESTMENTS, LLC (CRD-10582)AND TRANSACTIONS AFFECTED BY IT, PRIOR TO JANUARY 2011, WHEN IT CEASED DOING BUSINESS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM THROUGH ITS SUCCESSOR CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, IT IS CENSURED, FINED $35,000 AND ORDERED TO PAY $17,384.81, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. A REGISTERED FIRM PRINCIPAL 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 37 of 167 Reporting Source: Regulator Current Status: Final Allegations: THIS ACTION RELATES TO CONDUCT THAT OCCURRED AT WELLS FARGO INVESTMENTS, LLC (CRD #10582). WELLS FARGO ADVISORS, LLC IS NAMED AS A RESPONDENT SOLELY AS SUCCESSOR IN LIABILITY FOR WELLS FARGO INVESTMENTS, LLC. FINRA RULE 2010, NASD RULES 2110, 2310, 3010: WELLS FARGO INVESTMENTS REGISTERED REPRESENTATIVES MADE RECOMMENDATIONS TO CUSTOMERS TO PURCHASE FLOATING RATE LOAN FUNDS THAT WERE UNSUITABLE FOR THOSE CUSTOMERS IN LIGHT OF THEIR FINANCIAL SITUATIONS AND NEEDS. IN PARTICULAR, WELLS FARGO INVESTMENTS MADE NUMEROUS RECOMMENDATIONS TO CUSTOMERS WHOSE RISK TOLERANCES AND INVESTMENT OBJECTIVES WERE INCONSISTENT WITH THE RISKS AND FEATURES OF FLOATING RATE LOAN FUNDS. THE FLOATING RATE LOAN FUNDS SOLD BY WELLS FARGO INVESTMENTS WERE SUBJECT TO SIGNIFICANT CREDIT AND LIQUIDITY RISKS. ACCORDINGLY, THE FUNDS WERE NOT TYPICALLY SUITABLE FOR INVESTORS WITH AN INVESTMENT OBJECTIVE OF INCOME AND A CONSERVATIVE RISK TOLERANCE OR THOSE CUSTOMERS WHO WERE SEEKING TO PRESERVE PRINCIPAL, PARTICULARLY WHEN THOSE CUSTOMERS' PURCHASES CONSTITUTED A LARGE PERCENTAGE OF THEIR INVESTIBLE ASSETS OR LIQUID NET WORTH. MOREOVER, FLOATING RATE LOAN FUNDS, PARTICULARLY THOSE WITH RESTRICTIVE REDEMPTION POLICIES, WERE NOT TYPICALLY SUITABLE FOR INVESTORS WITH SHORT INVESTMENT TIME HORIZONS. IN SPITE OF THESE FEATURES OF FLOATING RATE FUNDS, WELLS FARGO INVESTMENTS RECOMMENDED FLOATING RATE FUND INVESTMENTS TO HUNDREDS OF CUSTOMERS FOR WHOM THE INVESTMENT WAS UNSUITABLE IN LIGHT OF THE CUSTOMERS' FINANCIAL SITUATIONS, RISK TOLERANCES, AND INVESTMENT OBJECTIVES. BETWEEN 2007 AND EARLY 2009, THE NET ASSET VALUE OF THE TYPICAL FLOATING RATE LOAN FUNDS DECLINED SUBSTANTIALLY. SINCE THAT TIME, THE NET ASSET VALUE OF THE TYPICAL FLOATING RATE LOAN FUND HAS PARTIALLY RECOVERED. HOWEVER, MANY WELLS FARGO INVESTMENTS CUSTOMERS FOR WHOM A FLOATING RATE LOAN FUND WAS UNSUITABLE SOLD THEIR HOLDINGS IN FLOATING RATE LOAN FUNDS AND INCURRED NET LOSSES. WELLS FARGO INVESTMENTS CUSTOMERS SUFFERED LOSSES IN THE TOTAL AMOUNT OF $1,962,000 AS A RESULT OF UNSUITABLE TRANSACTIONS IN FLOATING RATE LOAN FUNDS RECOMMENDED BY THE FIRM. WELLS FARGO INVESTMENTS FAILED TO ESTABLISH AND MAINTAIN A SYSTEM FOR SUPERVISING ITS SALES OF FLOATING RATE LOAN FUNDS THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE SUITABILITY REQUIREMENTS OF NASD AND FINRA RULES. WELLS FARGO ©2021 FINRA. All rights reserved. Report aboutINVESTMENTS WELLS FARGO SOLD CLEARING BILLIONS SERVICES, OF LLCDOLLARS OF FLOATING RATE LOAN 118 FUNDS TO ITS CUSTOMERS. THOSE SALES WERE A SIGNIFICANT PART OF WELLS FARGO INVESTMENTS' MUTUAL FUND BUSINESS. BY AUGUST 2007, FLOATING RATE LOAN FUNDS CONSTITUTED APPROXIMATELY 16 PERCENT OF THE FIRM'S TOTAL MUTUAL FUNDS SALES. DESPITE THIS, WELLS FARGO INVESTMENTS FAILED TO PROVIDE SUFFICIENT GUIDANCE TO REGISTERED REPRESENTATIVES OR SUPERVISORS TO DETERMINE WHETHER FLOATING RATE LOAN FUNDS WERE SUITABLE FOR ITS CLIENTS. WELLS FARGO INVESTMENTS ALSO FAILED TO ADEQUATELY TRAIN ITS REGISTERED PERSONS ABOUT THE CREDIT AND LIQUIDITY RISKS ASSOCIATED WITH FLOATING RATE FUNDS, OR THE CUSTOMERS FOR WHOM SUCH FUNDS WOULD BE SUITABLE. WELLS FARGO INVESTMENTS FAILED TO IMPLEMENT PROCEDURES REASONABLY DESIGNED TO ENSURE THAT ITS SALES OF FLOATING RATE LOAN FUNDS WERE SUITABLE FOR ITS CUSTOMERS EVEN AFTER POTENTIAL CONCERNS WERE RAISED INTERNALLY ABOUT THOSE SALES. THE FIRM'S MUTUAL FUND PRODUCT TEAM CONDUCTED A REVIEW OF FLOATING RATE LOAN FUNDS IN 2007 AND RECOMMENDED THAT WELLS FARGO INVESTMENTS REMIND SELLING REPRESENTATIVES THAT THE FUNDS SHOULD BE PART OF AN OVERALL ASSET ALLOCATION STRATEGY AND NOT SOLD AS A HIGH YIELDING ALTERNATIVE TO MONEY MARKET FUNDS. THE TEAM ALSO PREPARED A PRESENTATION WHICH INCLUDED GUIDANCE REGARDING CUSTOMERS FOR WHOM FLOATING RATE LOAN FUNDS MIGHT BE SUITABLE. HOWEVER, WELLS FARGO INVESTMENTS FAILED TO ADEQUATELY DISTRIBUTE THIS INFORMATION TO REGISTERED REPRESENTATIVES OR TAKE ACTION TO ENSURE THAT THE PRODUCT TEAM'S CONCERNS WERE TAKEN INTO ACCOUNT WHEN FLOATING RATE LOAN FUND PURCHASES WERE RECOMMENDED TO CUSTOMERS. THIS ACTION RELATES TO CONDUCT THAT OCCURRED AT WELLS FARGO INVESTMENTS, LLC (CRD #10582). WELLS FARGO ADVISORS, LLC IS NAMED AS A RESPONDENT SOLELY AS SUCCESSOR IN LIABILITY FOR WELLS FARGO INVESTMENTS, LLC. FINRA RULE 2010, NASD RULES 2110, 2310, 3010: WELLS FARGO INVESTMENTS REGISTERED REPRESENTATIVES MADE RECOMMENDATIONS TO CUSTOMERS TO PURCHASE FLOATING RATE LOAN FUNDS THAT WERE UNSUITABLE FOR THOSE CUSTOMERS IN LIGHT OF THEIR FINANCIAL SITUATIONS AND NEEDS. IN PARTICULAR, WELLS FARGO INVESTMENTS MADE NUMEROUS RECOMMENDATIONS TO CUSTOMERS WHOSE RISK TOLERANCES AND INVESTMENT OBJECTIVES WERE INCONSISTENT WITH THE RISKS AND FEATURES OF FLOATING RATE LOAN FUNDS. THE FLOATING RATE LOAN FUNDS SOLD BY WELLS FARGO INVESTMENTS WERE SUBJECT TO SIGNIFICANT CREDIT AND LIQUIDITY RISKS. ACCORDINGLY, THE FUNDS WERE NOT TYPICALLY SUITABLE FOR INVESTORS WITH AN INVESTMENT OBJECTIVE OF INCOME AND A CONSERVATIVE RISK TOLERANCE OR THOSE CUSTOMERS WHO WERE SEEKING TO PRESERVE PRINCIPAL, PARTICULARLY WHEN THOSE CUSTOMERS' PURCHASES CONSTITUTED A LARGE PERCENTAGE OF THEIR INVESTIBLE ASSETS OR LIQUID NET WORTH. MOREOVER, FLOATING RATE LOAN FUNDS, PARTICULARLY THOSE WITH RESTRICTIVE REDEMPTION POLICIES, WERE NOT TYPICALLY SUITABLE FOR INVESTORS WITH SHORT INVESTMENT TIME HORIZONS. IN SPITE OF THESE FEATURES OF FLOATING RATE FUNDS, WELLS FARGO INVESTMENTS RECOMMENDED FLOATING RATE FUND INVESTMENTS TO HUNDREDS OF CUSTOMERS FOR WHOM THE INVESTMENT WAS UNSUITABLE IN LIGHT OF THE CUSTOMERS' FINANCIAL SITUATIONS, RISK TOLERANCES, AND INVESTMENT OBJECTIVES. BETWEEN 2007 AND EARLY 2009, THE NET ASSET VALUE OF THE TYPICAL FLOATING RATE LOAN FUNDS DECLINED SUBSTANTIALLY. SINCE THAT TIME, THE NET ASSET VALUE OF THE TYPICAL FLOATING RATE LOAN FUND HAS PARTIALLY RECOVERED. HOWEVER, MANY WELLS FARGO INVESTMENTS CUSTOMERS FOR WHOM A FLOATING RATE LOAN FUND WAS UNSUITABLE SOLD THEIR HOLDINGS IN FLOATING RATE LOAN FUNDS AND INCURRED NET LOSSES. WELLS FARGO INVESTMENTS CUSTOMERS SUFFERED LOSSES IN THE TOTAL AMOUNT OF $1,962,000 AS A RESULT OF UNSUITABLE TRANSACTIONS IN www.finra.org/brokercheck FLOATING RATE LOAN FUNDS RECOMMENDED BY THE FIRM. WELLS User Guidance FARGO INVESTMENTS FAILED TO ESTABLISH AND MAINTAIN A SYSTEM FOR SUPERVISING ITS SALES OF FLOATING RATE LOAN FUNDS THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE SUITABILITY REQUIREMENTS OF NASD AND FINRA RULES. WELLS FARGO INVESTMENTS SOLD BILLIONS OF DOLLARS OF FLOATING RATE LOAN FUNDS TO ITS CUSTOMERS. THOSE SALES WERE A SIGNIFICANT PART OF WELLS FARGO INVESTMENTS' MUTUAL FUND BUSINESS. BY AUGUST 2007, FLOATING RATE LOAN FUNDS CONSTITUTED APPROXIMATELY 16 PERCENT OF THE FIRM'S TOTAL MUTUAL FUNDS SALES. DESPITE THIS, WELLS FARGO INVESTMENTS FAILED TO PROVIDE SUFFICIENT GUIDANCE TO REGISTERED REPRESENTATIVES OR SUPERVISORS TO DETERMINE WHETHER FLOATING RATE LOAN FUNDS WERE SUITABLE FOR ITS CLIENTS. WELLS FARGO INVESTMENTS ALSO FAILED TO ADEQUATELY TRAIN ITS REGISTERED PERSONS ABOUT THE CREDIT AND LIQUIDITY RISKS ASSOCIATED WITH FLOATING RATE FUNDS, OR THE CUSTOMERS FOR WHOM SUCH FUNDS WOULD BE SUITABLE. WELLS FARGO INVESTMENTS FAILED TO IMPLEMENT PROCEDURES REASONABLY DESIGNED TO ENSURE THAT ITS SALES OF FLOATING RATE LOAN FUNDS WERE SUITABLE FOR ITS CUSTOMERS EVEN AFTER POTENTIAL CONCERNS WERE RAISED INTERNALLY ABOUT THOSE SALES. THE FIRM'S MUTUAL FUND PRODUCT TEAM CONDUCTED A REVIEW OF FLOATING RATE LOAN FUNDS IN 2007 AND RECOMMENDED THAT WELLS FARGO INVESTMENTS REMIND SELLING REPRESENTATIVES THAT THE FUNDS SHOULD BE PART OF AN OVERALL ASSET ALLOCATION STRATEGY AND NOT SOLD AS A HIGH YIELDING ALTERNATIVE TO MONEY MARKET FUNDS. THE TEAM ALSO PREPARED A PRESENTATION WHICH INCLUDED GUIDANCE REGARDING CUSTOMERS FOR WHOM FLOATING RATE LOAN FUNDS MIGHT BE SUITABLE. HOWEVER, WELLS FARGO INVESTMENTS FAILED TO ADEQUATELY DISTRIBUTE THIS INFORMATION TO REGISTERED REPRESENTATIVES OR TAKE ACTION TO ENSURE THAT THE PRODUCT TEAM'S CONCERNS WERE TAKEN INTO ACCOUNT WHEN FLOATING RATE LOAN FUND PURCHASES WERE RECOMMENDED TO CUSTOMERS. Initiated By: FINRA Date Initiated: 06/04/2013 Docket/Case Number: 2008014350501

Principal Product Type: Other Other Product Type(s): FLOATING RATE LOAN FUNDS Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/04/2013

©2021Does FINRA.the order All rights constitute reserved. a Report aboutNo WELLS FARGO CLEARING SERVICES, LLC 119 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 $1,250,000.00 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 $1,250,000 AND MUST PAY RESTITUTION TO CUSTOMERS IN THE AMOUNT OF $1,981,561.70. 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 AFTER ACCEPTANCE OF THE AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY OF THE CUSTOMERS RECEIVING RESTITUTION AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN 120 DAYS FROM THE DATE THE AWC IS ACCEPTED, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA, 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 WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE STATE AUTHORITY. i Reporting Source: Firm Current Status: Final Allegations: THIS ACTION RELATES TO CONDUCT THAT OCCURRED AT WELLS FARGO INVESTMENTS, LLC (CRD #10582). WELLS FARGO ADVISORS, LLC WAS NOT AFFILIATED WITH WELLS FARGO INVESTMENTS DURING THE RELEVANT PERIOD AND IS NAMED AS A RESPONDENT SOLELY AS SUCCESSOR IN LIABILITY FOR WELLS FARGO INVESTMENTS, LLC. FINRA RULE 2010, NASD RULES 2110, 2310, 3010: BETWEEN JANUARY 1, 2007 AND DECEMBER 31, 2008 WELLS FARGO INVESTMENTS REGISTERED REPRESENTATIVES MADE RECOMMENDATIONS TO CUSTOMERS TO PURCHASE FLOATING RATE LOAN FUNDS THAT WERE UNSUITABLE FOR THOSE CUSTOMERS IN LIGHT OF THEIR FINANCIAL SITUATIONS AND NEEDS. IN PARTICULAR, ©2021 FINRA. All rights reserved. Report aboutWELLS WELLS FARGO FARGO INVESTMENTS CLEARING SERVICES, MADE LLC NUMEROUS RECOMMENDATIONS TO 120 CUSTOMERS WHOSE RISK TOLERANCES AND INVESTMENT OBJECTIVES WERE INCONSISTENT WITH THE RISKS AND FEATURES OF FLOATING RATE LOAN FUNDS. THE FLOATING RATE LOAN FUNDS SOLD BY WELLS FARGO INVESTMENTS WERE SUBJECT TO SIGNIFICANT CREDIT AND LIQUIDITY RISKS. ACCORDINGLY, THE FUNDS WERE NOT TYPICALLY SUITABLE FOR INVESTORS WITH AN INVESTMENT OBJECTIVE OF INCOME AND A CONSERVATIVE RISK TOLERANCE OR THOSE CUSTOMERS WHO WERE SEEKING TO PRESERVE PRINCIPAL, PARTICULARLY WHEN THOSE CUSTOMERS' PURCHASES CONSTITUTED A LARGE PERCENTAGE OF THEIR INVESTIBLE ASSETS OR LIQUID NET WORTH. MOREOVER, FLOATING RATE LOAN FUNDS, PARTICULARLY THOSE WITH RESTRICTIVE REDEMPTION POLICIES, WERE NOT TYPICALLY SUITABLE FOR INVESTORS WITH SHORT INVESTMENT TIME HORIZONS. BETWEEN 2007 AND EARLY 2009, THE NET ASSET VALUE OF THE TYPICAL FLOATING RATE LOAN FUNDS DECLINED SUBSTANTIALLY AND SINCE THAT TIME HAS PARTIALLY RECOVERED. HOWEVER, MANY WELLS FARGO INVESTMENTS CUSTOMERS FOR WHOM A FLOATING RATE LOAN FUND WAS UNSUITABLE SOLD THEIR HOLDINGS IN FLOATING RATE LOAN FUNDS AND INCURRED NET LOSSES. WELLS FARGO INVESTMENTS ALSO FAILED TO ESTABLISH AND MAINTAIN A SYSTEM FOR SUPERVISING ITS SALES OF FLOATING RATE LOAN FUNDS THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE SUITABILITY REQUIREMENTS OF NASD AND FINRA RULES. EVEN AFTER POTENTIAL CONCERNS WERE RAISED INTERNALLY, WELLS FARGO INVESTMENTS FAILED TO PROVIDE SUFFICIENT GUIDANCE OR TRAINING TO REGISTERED REPRESENTATIVES OR SUPERVISORS TO DETERMINE WHETHER FLOATING RATE LOAN FUNDS WERE SUITABLE FOR ITS CLIENTS AND THE CREDIT AND LIQUIDITY RISKS ASSOCIATED WITH FLOATING RATE FUNDS. THIS ACTION RELATES TO CONDUCT THAT OCCURRED AT WELLS FARGO INVESTMENTS, LLC (CRD #10582). WELLS FARGO ADVISORS, LLC WAS NOT AFFILIATED WITH WELLS FARGO INVESTMENTS DURING THE RELEVANT PERIOD AND IS NAMED AS A RESPONDENT SOLELY AS SUCCESSOR IN LIABILITY FOR WELLS FARGO INVESTMENTS, LLC. FINRA RULE 2010, NASD RULES 2110, 2310, 3010: BETWEEN JANUARY 1, 2007 AND DECEMBER 31, www.finra.org/brokercheck 2008 WELLS FARGO INVESTMENTS REGISTERED REPRESENTATIVES User Guidance MADE RECOMMENDATIONS TO CUSTOMERS TO PURCHASE FLOATING RATE LOAN FUNDS THAT WERE UNSUITABLE FOR THOSE CUSTOMERS IN LIGHT OF THEIR FINANCIAL SITUATIONS AND NEEDS. IN PARTICULAR, WELLS FARGO INVESTMENTS MADE NUMEROUS RECOMMENDATIONS TO CUSTOMERS WHOSE RISK TOLERANCES AND INVESTMENT OBJECTIVES WERE INCONSISTENT WITH THE RISKS AND FEATURES OF FLOATING RATE LOAN FUNDS. THE FLOATING RATE LOAN FUNDS SOLD BY WELLS FARGO INVESTMENTS WERE SUBJECT TO SIGNIFICANT CREDIT AND LIQUIDITY RISKS. ACCORDINGLY, THE FUNDS WERE NOT TYPICALLY SUITABLE FOR INVESTORS WITH AN INVESTMENT OBJECTIVE OF INCOME AND A CONSERVATIVE RISK TOLERANCE OR THOSE CUSTOMERS WHO WERE SEEKING TO PRESERVE PRINCIPAL, PARTICULARLY WHEN THOSE CUSTOMERS' PURCHASES CONSTITUTED A LARGE PERCENTAGE OF THEIR INVESTIBLE ASSETS OR LIQUID NET WORTH. MOREOVER, FLOATING RATE LOAN FUNDS, PARTICULARLY THOSE WITH RESTRICTIVE REDEMPTION POLICIES, WERE NOT TYPICALLY SUITABLE FOR INVESTORS WITH SHORT INVESTMENT TIME HORIZONS. BETWEEN 2007 AND EARLY 2009, THE NET ASSET VALUE OF THE TYPICAL FLOATING RATE LOAN FUNDS DECLINED SUBSTANTIALLY AND SINCE THAT TIME HAS PARTIALLY RECOVERED. HOWEVER, MANY WELLS FARGO INVESTMENTS CUSTOMERS FOR WHOM A FLOATING RATE LOAN FUND WAS UNSUITABLE SOLD THEIR HOLDINGS IN FLOATING RATE LOAN FUNDS AND INCURRED NET LOSSES. WELLS FARGO INVESTMENTS ALSO FAILED TO ESTABLISH AND MAINTAIN A SYSTEM FOR SUPERVISING ITS SALES OF FLOATING RATE LOAN FUNDS THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE SUITABILITY REQUIREMENTS OF NASD AND FINRA RULES. EVEN AFTER POTENTIAL CONCERNS WERE RAISED INTERNALLY, WELLS FARGO INVESTMENTS FAILED TO PROVIDE SUFFICIENT GUIDANCE OR TRAINING TO REGISTERED REPRESENTATIVES OR SUPERVISORS TO DETERMINE WHETHER FLOATING RATE LOAN FUNDS WERE SUITABLE FOR ITS CLIENTS AND THE CREDIT AND LIQUIDITY RISKS ASSOCIATED WITH FLOATING RATE FUNDS. Initiated By: FINRA Date Initiated: 06/04/2013 Docket/Case Number: 2008014350501

Principal Product Type: Other Other Product Type(s): FLOATING RATE FUNDS Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief NA Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/04/2013

©2021Sanctions FINRA. Ordered: All rights reserved. Report aboutCensure WELLS FARGO CLEARING SERVICES, LLC 121 Monetary/Fine $1,250,000.00 Disgorgement/Restitution www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $1,250,000.00 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 $1,250,000 AND MUST PAY RESTITUTION TO CUSTOMERS IN THE AMOUNT OF $1,981,561.70. 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 AFTER ACCEPTANCE OF THE AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY OF THE CUSTOMERS RECEIVING RESTITUTION AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN 120 DAYS FROM THE DATE THE AWC IS ACCEPTED, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA, 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 WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE STATE AUTHORITY. i Disclosure 38 of 167 Reporting Source: Regulator Current Status: Final Allegations: FINRA BY-LAWS ARTICLE V, SECTION 2; FINRA RULES 1122, 2010; NASD RULES 2110, 3010, 3070, CAUSED VIOLATIONS OF FINRA RULE 3240(A), NASD RULE 2370(A): WELLS FARGO PERMITTED CERTAIN CUSTOMERS TO BORROW MONEY FROM THE MEMBER FIRM BY WITHDRAWING MORE FUNDS THAN WERE AVAILABLE IN THE CUSTOMERS' ACCOUNTS, THROUGH THE USE OF AMONG OTHER THINGS, ONLINE PAYMENTS, CHECKS, AND DEBIT CARDS. THE REGISTERED REPRESENTATIVES ASSIGNED TO THE ACCOUNTS, WITH THE CONCURRENCE OF THE BRANCH MANAGERS AND THE FIRM'S CREDIT AND MARGIN DEPARTMENT, DETERMINED WHETHER TO ALLOW THESE TYPES OF WITHDRAWALS TO GO THROUGH. IF THE OVERDRAFTS WERE ALLOWED TO OCCUR, THE CUSTOMERS WERE RESPONSIBLE FOR SATISFYING THE OVERDRAFT THROUGH A SAME DAY DEPOSIT OF FUNDS, WIRE TRANSFER, OR COLLATERAL OR SALE OF SECURITIES. ACCORDING TO THE FIRM'S POLICY, IF A CUSTOMER DID NOT SATISFY AN OVERDRAFT ON THE SAME DAY, THE DEBIT WOULD NOT BE HONORED. HOWEVER, DURING THE TIME ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 122 PERIOD AT ISSUE, THE FIRM ALLOWED EXCEPTIONS TO THIS POLICY ON AN OCCASIONAL, THOUGH NOT FREQUENT, BASIS AND PERMITTED OVERDRAFTS IN SITUATIONS WHERE CUSTOMERS DID NOT COVER THE DEBIT ON THE SAME DAY, THEREBY LOANING MONEY TO THOSE CUSTOMERS. IN THOSE INSTANCES, IN ACCORDANCE WITH THE FIRM'S POLICIES AND PROCEDURES, IF THE OVERDRAFT WAS NOT REPAID AFTER A PERIOD OF TIME, THE UNSECURED DEBIT WAS CHARGED AGAINST THE REGISTERED REPRESENTATIVE'S PRODUCTION. ONCE AN OVERDRAFT WAS CHARGED AGAINST A REGISTERED REPRESENTATIVE'S PRODUCTION, THE REGISTERED REPRESENTATIVE COULD REQUEST THAT THE DEBT BE SENT TO COLLECTIONS, THROUGH THE FIRM, FOR RECOVERY FROM THE CUSTOMER. AMOUNTS RECOVERED FROM THE CUSTOMER WERE PAID TO THE REGISTERED REPRESENTATIVE, MINUS ANY COLLECTIONS EXPENSES. BY TRANSFERRING RESPONSIBILITY FOR THE LOAN TO REGISTERED REPRESENTATIVES AND ALLOWING REGISTERED REPRESENTATIVES TO OBTAIN REPAYMENT FROM THE CUSTOMERS, THE FIRM CAUSED REGISTERED REPRESENTATIVES TO LOAN MONEY TO CUSTOMERS. THE FIRM ALSO ALLOWED THE LOANS TO OCCUR WITHOUT ANY SYSTEM OR PROCEDURE IN PLACE TO DETERMINE WHETHER THE LOANS MET THE CONDITIONS OF FINRA RULE 3240(A) AND NASD RULE 2370(A). THEREFORE IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA AND NASD RULES. TWO CUSTOMERS ALLEGED IN WRITING THAT A REGISTERED REPRESENTATIVE HAD MADE JOURNAL TRANSFERS OF FUNDS TO OTHER CUSTOMERS WITHOUT THEIR AUTHORIZATION. THE FIRM SETTLED ONE COMPLAINT FOR $16,500 WHILE THE OTHER WAS RESOLVED WITHOUT A MONETARY SETTLEMENT. THE FIRM NEVER REPORTED EITHER OF THESE COMPLAINTS ON THE REGISTERED REPRESENTATIVE'S FORM U4, AND NEVER DISCLOSED THE SETTLEMENT OF THE SECOND COMPLAINT FOR MORE THAN $15,000. THE CUSTOMER COMPLAINTS ALLEGED MISAPPROPRIATION OF FUNDS WHICH REQUIRES DISCLOSURE UNDER NASD RULE 3070 WITHIN TEN DAYS. ONE COMPLAINT WAS NOT REPORTED UNTIL THREE AND ONE-HALF MONTHS AFTER IT WAS RECEIVED WHILE TO OTHER WAS NEVER REPORTED. FINRA BY-LAWS ARTICLE V, SECTION 2; FINRA RULES 1122, 2010; NASD RULES 2110, 3010, 3070, CAUSED VIOLATIONS OF FINRA RULE 3240(A), NASD RULE 2370(A): WELLS FARGO PERMITTED CERTAIN CUSTOMERS TO BORROW MONEY FROM THE MEMBER FIRM BY WITHDRAWING MORE FUNDS THAN WERE AVAILABLE IN THE CUSTOMERS' ACCOUNTS, THROUGH THE USE OF AMONG OTHER THINGS, ONLINE PAYMENTS, CHECKS, AND DEBIT CARDS. THE REGISTERED REPRESENTATIVES ASSIGNED TO THE ACCOUNTS, WITH THE CONCURRENCE OF THE BRANCH MANAGERS AND THE FIRM'S CREDIT AND MARGIN DEPARTMENT, DETERMINED WHETHER TO ALLOW THESE TYPES OF WITHDRAWALS TO GO THROUGH. IF THE OVERDRAFTS WERE ALLOWED TO OCCUR, THE www.finra.org/brokercheck CUSTOMERS WERE RESPONSIBLE FOR SATISFYING THE OVERDRAFT User Guidance THROUGH A SAME DAY DEPOSIT OF FUNDS, WIRE TRANSFER, OR COLLATERAL OR SALE OF SECURITIES. ACCORDING TO THE FIRM'S POLICY, IF A CUSTOMER DID NOT SATISFY AN OVERDRAFT ON THE SAME DAY, THE DEBIT WOULD NOT BE HONORED. HOWEVER, DURING THE TIME PERIOD AT ISSUE, THE FIRM ALLOWED EXCEPTIONS TO THIS POLICY ON AN OCCASIONAL, THOUGH NOT FREQUENT, BASIS AND PERMITTED OVERDRAFTS IN SITUATIONS WHERE CUSTOMERS DID NOT COVER THE DEBIT ON THE SAME DAY, THEREBY LOANING MONEY TO THOSE CUSTOMERS. IN THOSE INSTANCES, IN ACCORDANCE WITH THE FIRM'S POLICIES AND PROCEDURES, IF THE OVERDRAFT WAS NOT REPAID AFTER A PERIOD OF TIME, THE UNSECURED DEBIT WAS CHARGED AGAINST THE REGISTERED REPRESENTATIVE'S PRODUCTION. ONCE AN OVERDRAFT WAS CHARGED AGAINST A REGISTERED REPRESENTATIVE'S PRODUCTION, THE REGISTERED REPRESENTATIVE COULD REQUEST THAT THE DEBT BE SENT TO COLLECTIONS, THROUGH THE FIRM, FOR RECOVERY FROM THE CUSTOMER. AMOUNTS RECOVERED FROM THE CUSTOMER WERE PAID TO THE REGISTERED REPRESENTATIVE, MINUS ANY COLLECTIONS EXPENSES. BY TRANSFERRING RESPONSIBILITY FOR THE LOAN TO REGISTERED REPRESENTATIVES AND ALLOWING REGISTERED REPRESENTATIVES TO OBTAIN REPAYMENT FROM THE CUSTOMERS, THE FIRM CAUSED REGISTERED REPRESENTATIVES TO LOAN MONEY TO CUSTOMERS. THE FIRM ALSO ALLOWED THE LOANS TO OCCUR WITHOUT ANY SYSTEM OR PROCEDURE IN PLACE TO DETERMINE WHETHER THE LOANS MET THE CONDITIONS OF FINRA RULE 3240(A) AND NASD RULE 2370(A). THEREFORE IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA AND NASD RULES. TWO CUSTOMERS ALLEGED IN WRITING THAT A REGISTERED REPRESENTATIVE HAD MADE JOURNAL TRANSFERS OF FUNDS TO OTHER CUSTOMERS WITHOUT THEIR AUTHORIZATION. THE FIRM SETTLED ONE COMPLAINT FOR $16,500 WHILE THE OTHER WAS RESOLVED WITHOUT A MONETARY SETTLEMENT. THE FIRM NEVER REPORTED EITHER OF THESE COMPLAINTS ON THE REGISTERED REPRESENTATIVE'S FORM U4, AND NEVER DISCLOSED THE SETTLEMENT OF THE SECOND COMPLAINT FOR MORE THAN $15,000. THE CUSTOMER COMPLAINTS ALLEGED MISAPPROPRIATION OF FUNDS WHICH REQUIRES DISCLOSURE UNDER NASD RULE 3070 WITHIN TEN DAYS. ONE COMPLAINT WAS NOT REPORTED UNTIL THREE AND ONE-HALF MONTHS AFTER IT WAS RECEIVED WHILE TO OTHER WAS NEVER REPORTED. Initiated By: FINRA Date Initiated: 04/09/2013 Docket/Case Number: 2010022380001

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/09/2013 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: 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 $50,000. THE FIRM FURTHER UNDERTOOK AND AGREED TO CONDUCT A COMPREHENSIVE REVIEW OF ITS SYSTEMS, POLICIES AND PROCEDURES TO ENSURE THAT THOSE POLICIES AND PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULES AND THE FEDERAL SECURITIES LAWS REGARDING BORROWING MONEY FROM, OR LENDING MONEY TO, CUSTOMERS BY REGISTERED REPRESENTATIVES. WITHIN 120 DAYS OF THE ISSUANCE OF A NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT (I) THE FIRM HAS ENGAGED IN THE COMPREHENSIVE REVIEW; AND (II) AS OF THE DATE OF THE CERTIFICATION, THE FIRM HAS IN PLACE POLICIES AND PROCEDURES TO REASONABLY DESIGNED TO ADDRESS AND CORRECT THE VIOLATIONS RELATING TO SUPERVISION DESCRIBED IN THIS AWC. FINE PAID MAY 29, 2013. i Reporting Source: Firm Current Status: Final Allegations: FINRA BY-LAWS ARTICLE V, SECTION 2; FINRA RULES 1122, 2010; NASD RULES 2110, 3010, 3070, CAUSED VIOLATIONS OF FINRA RULE 3240(A), NASD RULE 2370(A): WELLS FARGO PERMITTED CERTAIN CUSTOMERS TO BORROW MONEY FROM THE MEMBER FIRM BY WITHDRAWING MORE ©2021 FINRA. All rights reserved. Report aboutFUNDS WELLS THAN FARGO WERE CLEARING AVAILABLE SERVICES, IN LLCTHE CUSTOMERS' ACCOUNTS, 124 THROUGH THE USE OF AMONG OTHER THINGS, ONLINE PAYMENTS, CHECKS, AND DEBIT CARDS. THE REGISTERED REPRESENTATIVES ASSIGNED TO THE ACCOUNTS, WITH THE CONCURRENCE OF THE BRANCH MANAGERS AND THE FIRM'S CREDIT AND MARGIN DEPARTMENT, DETERMINED WHETHER TO ALLOW THESE TYPES OF WITHDRAWALS TO GO THROUGH. IF THE OVERDRAFTS WERE ALLOWED TO OCCUR, THE CUSTOMERS WERE RESPONSIBLE FOR SATISFYING THE OVERDRAFT THROUGH A SAME DAY DEPOSIT OF FUNDS, WIRE TRANSFER, OR COLLATERAL OR SALE OF SECURITIES. ACCORDING TO THE FIRM'S POLICY, IF A CUSTOMER DID NOT SATISFY AN OVERDRAFT ON THE SAME DAY, THE DEBIT WOULD NOT BE HONORED. HOWEVER, DURING THE TIME PERIOD AT ISSUE, THE FIRM ALLOWED EXCEPTIONS TO THIS POLICY ON AN OCCASIONAL, THOUGH NOT FREQUENT, BASIS AND PERMITTED OVERDRAFTS IN SITUATIONS WHERE CUSTOMERS DID NOT COVER THE DEBIT ON THE SAME DAY, THEREBY LOANING MONEY TO THOSE CUSTOMERS. IN THOSE INSTANCES, IN ACCORDANCE WITH THE FIRM'S POLICIES AND PROCEDURES, IF THE OVERDRAFT WAS NOT REPAID AFTER A PERIOD OF TIME, THE UNSECURED DEBIT WAS CHARGED AGAINST THE REGISTERED REPRESENTATIVE'S PRODUCTION. ONCE AN OVERDRAFT WAS CHARGED AGAINST A REGISTERED REPRESENTATIVE'S PRODUCTION, THE REGISTERED REPRESENTATIVE COULD REQUEST THAT THE DEBT BE SENT TO COLLECTIONS, THROUGH THE FIRM, FOR RECOVERY FROM THE CUSTOMER. AMOUNTS RECOVERED FROM THE CUSTOMER WERE PAID TO THE REGISTERED REPRESENTATIVE, MINUS ANY COLLECTIONS EXPENSES. BY TRANSFERRING RESPONSIBILITY FOR THE LOAN TO REGISTERED REPRESENTATIVES AND ALLOWING REGISTERED REPRESENTATIVES TO OBTAIN REPAYMENT FROM THE CUSTOMERS, THE FIRM CAUSED REGISTERED REPRESENTATIVES TO LOAN MONEY TO CUSTOMERS. THE FIRM ALSO ALLOWED THE LOANS TO OCCUR WITHOUT ANY SYSTEM OR PROCEDURE IN PLACE TO DETERMINE WHETHER THE LOANS MET THE CONDITIONS OF FINRA RULE 3240(A) AND NASD RULE 2370(A). THEREFORE IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA AND NASD RULES. TWO CUSTOMERS ALLEGED IN WRITING THAT A REGISTERED REPRESENTATIVE HAD MADE JOURNAL TRANSFERS OF FUNDS TO OTHER CUSTOMERS WITHOUT THEIR AUTHORIZATION. THE FIRM SETTLED ONE COMPLAINT FOR $16,500 WHILE THE OTHER WAS RESOLVED WITHOUT A MONETARY SETTLEMENT. THE FIRM NEVER REPORTED EITHER OF THESE COMPLAINTS ON THE REGISTERED REPRESENTATIVE'S FORM U4, AND NEVER DISCLOSED THE SETTLEMENT OF THE SECOND COMPLAINT FOR MORE THAN $15,000. THE CUSTOMER COMPLAINTS ALLEGED MISAPPROPRIATION OF FUNDS WHICH REQUIRES DISCLOSURE UNDER NASD RULE 3070 WITHIN TEN DAYS. ONE COMPLAINT WAS NOT REPORTED UNTIL THREE AND ONE-HALF MONTHS AFTER IT WAS RECEIVED WHILE TO OTHER WAS NEVER REPORTED. www.finra.org/brokercheck FINRA BY-LAWS ARTICLE V, SECTION 2; FINRA RULES 1122, 2010; NASD User Guidance RULES 2110, 3010, 3070, CAUSED VIOLATIONS OF FINRA RULE 3240(A), NASD RULE 2370(A): WELLS FARGO PERMITTED CERTAIN CUSTOMERS TO BORROW MONEY FROM THE MEMBER FIRM BY WITHDRAWING MORE FUNDS THAN WERE AVAILABLE IN THE CUSTOMERS' ACCOUNTS, THROUGH THE USE OF AMONG OTHER THINGS, ONLINE PAYMENTS, CHECKS, AND DEBIT CARDS. THE REGISTERED REPRESENTATIVES ASSIGNED TO THE ACCOUNTS, WITH THE CONCURRENCE OF THE BRANCH MANAGERS AND THE FIRM'S CREDIT AND MARGIN DEPARTMENT, DETERMINED WHETHER TO ALLOW THESE TYPES OF WITHDRAWALS TO GO THROUGH. IF THE OVERDRAFTS WERE ALLOWED TO OCCUR, THE CUSTOMERS WERE RESPONSIBLE FOR SATISFYING THE OVERDRAFT THROUGH A SAME DAY DEPOSIT OF FUNDS, WIRE TRANSFER, OR COLLATERAL OR SALE OF SECURITIES. ACCORDING TO THE FIRM'S POLICY, IF A CUSTOMER DID NOT SATISFY AN OVERDRAFT ON THE SAME DAY, THE DEBIT WOULD NOT BE HONORED. HOWEVER, DURING THE TIME PERIOD AT ISSUE, THE FIRM ALLOWED EXCEPTIONS TO THIS POLICY ON AN OCCASIONAL, THOUGH NOT FREQUENT, BASIS AND PERMITTED OVERDRAFTS IN SITUATIONS WHERE CUSTOMERS DID NOT COVER THE DEBIT ON THE SAME DAY, THEREBY LOANING MONEY TO THOSE CUSTOMERS. IN THOSE INSTANCES, IN ACCORDANCE WITH THE FIRM'S POLICIES AND PROCEDURES, IF THE OVERDRAFT WAS NOT REPAID AFTER A PERIOD OF TIME, THE UNSECURED DEBIT WAS CHARGED AGAINST THE REGISTERED REPRESENTATIVE'S PRODUCTION. ONCE AN OVERDRAFT WAS CHARGED AGAINST A REGISTERED REPRESENTATIVE'S PRODUCTION, THE REGISTERED REPRESENTATIVE COULD REQUEST THAT THE DEBT BE SENT TO COLLECTIONS, THROUGH THE FIRM, FOR RECOVERY FROM THE CUSTOMER. AMOUNTS RECOVERED FROM THE CUSTOMER WERE PAID TO THE REGISTERED REPRESENTATIVE, MINUS ANY COLLECTIONS EXPENSES. BY TRANSFERRING RESPONSIBILITY FOR THE LOAN TO REGISTERED REPRESENTATIVES AND ALLOWING REGISTERED REPRESENTATIVES TO OBTAIN REPAYMENT FROM THE CUSTOMERS, THE FIRM CAUSED REGISTERED REPRESENTATIVES TO LOAN MONEY TO CUSTOMERS. THE FIRM ALSO ALLOWED THE LOANS TO OCCUR WITHOUT ANY SYSTEM OR PROCEDURE IN PLACE TO DETERMINE WHETHER THE LOANS MET THE CONDITIONS OF FINRA RULE 3240(A) AND NASD RULE 2370(A). THEREFORE IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA AND NASD RULES. TWO CUSTOMERS ALLEGED IN WRITING THAT A REGISTERED REPRESENTATIVE HAD MADE JOURNAL TRANSFERS OF FUNDS TO OTHER CUSTOMERS WITHOUT THEIR AUTHORIZATION. THE FIRM SETTLED ONE COMPLAINT FOR $16,500 WHILE THE OTHER WAS RESOLVED WITHOUT A MONETARY SETTLEMENT. THE FIRM NEVER REPORTED EITHER OF THESE COMPLAINTS ON THE REGISTERED REPRESENTATIVE'S FORM U4, AND NEVER DISCLOSED THE SETTLEMENT OF THE SECOND COMPLAINT FOR MORE THAN $15,000. THE CUSTOMER COMPLAINTS ALLEGED MISAPPROPRIATION OF FUNDS WHICH REQUIRES DISCLOSURE UNDER NASD RULE 3070 WITHIN TEN DAYS. ONE COMPLAINT WAS NOT REPORTED UNTIL THREE AND ONE-HALF MONTHS AFTER IT WAS RECEIVED WHILE TO OTHER WAS NEVER REPORTED. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 125 FINRA BY-LAWS ARTICLE V, SECTION 2; FINRA RULES 1122, 2010; NASD RULES 2110, 3010, 3070, CAUSED VIOLATIONS OF FINRA RULE 3240(A), NASD RULE 2370(A): WELLS FARGO PERMITTED CERTAIN CUSTOMERS TO BORROW MONEY FROM THE MEMBER FIRM BY WITHDRAWING MORE FUNDS THAN WERE AVAILABLE IN THE CUSTOMERS' ACCOUNTS, THROUGH THE USE OF AMONG OTHER THINGS, ONLINE PAYMENTS, CHECKS, AND DEBIT CARDS. THE REGISTERED REPRESENTATIVES ASSIGNED TO THE ACCOUNTS, WITH THE CONCURRENCE OF THE BRANCH MANAGERS AND THE FIRM'S CREDIT AND MARGIN DEPARTMENT, DETERMINED WHETHER TO ALLOW THESE TYPES OF WITHDRAWALS TO GO THROUGH. IF THE OVERDRAFTS WERE ALLOWED TO OCCUR, THE CUSTOMERS WERE RESPONSIBLE FOR SATISFYING THE OVERDRAFT THROUGH A SAME DAY DEPOSIT OF FUNDS, WIRE TRANSFER, OR COLLATERAL OR SALE OF SECURITIES. ACCORDING TO THE FIRM'S POLICY, IF A CUSTOMER DID NOT SATISFY AN OVERDRAFT ON THE SAME DAY, THE DEBIT WOULD NOT BE HONORED. HOWEVER, DURING THE TIME PERIOD AT ISSUE, THE FIRM ALLOWED EXCEPTIONS TO THIS POLICY ON AN OCCASIONAL, THOUGH NOT FREQUENT, BASIS AND PERMITTED OVERDRAFTS IN SITUATIONS WHERE CUSTOMERS DID NOT COVER THE DEBIT ON THE SAME DAY, THEREBY LOANING MONEY TO THOSE CUSTOMERS. IN THOSE INSTANCES, IN ACCORDANCE WITH THE FIRM'S POLICIES AND PROCEDURES, IF THE OVERDRAFT WAS NOT REPAID AFTER A PERIOD OF TIME, THE UNSECURED DEBIT WAS CHARGED AGAINST THE REGISTERED REPRESENTATIVE'S PRODUCTION. ONCE AN OVERDRAFT WAS CHARGED AGAINST A REGISTERED REPRESENTATIVE'S PRODUCTION, THE REGISTERED REPRESENTATIVE COULD REQUEST THAT THE DEBT BE SENT TO COLLECTIONS, THROUGH THE FIRM, FOR RECOVERY FROM THE CUSTOMER. AMOUNTS RECOVERED FROM THE CUSTOMER WERE PAID TO THE REGISTERED REPRESENTATIVE, MINUS ANY COLLECTIONS EXPENSES. BY TRANSFERRING RESPONSIBILITY FOR THE LOAN TO REGISTERED REPRESENTATIVES AND ALLOWING REGISTERED REPRESENTATIVES TO OBTAIN REPAYMENT FROM THE CUSTOMERS, THE FIRM CAUSED REGISTERED REPRESENTATIVES TO LOAN MONEY TO CUSTOMERS. THE FIRM ALSO ALLOWED THE LOANS TO OCCUR WITHOUT ANY SYSTEM OR PROCEDURE IN PLACE TO DETERMINE WHETHER THE LOANS MET THE CONDITIONS OF FINRA RULE 3240(A) AND NASD RULE 2370(A). THEREFORE IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA AND NASD RULES. TWO CUSTOMERS ALLEGED IN WRITING THAT A REGISTERED REPRESENTATIVE HAD MADE JOURNAL TRANSFERS OF FUNDS TO OTHER CUSTOMERS WITHOUT THEIR AUTHORIZATION. THE FIRM SETTLED ONE COMPLAINT FOR $16,500 WHILE THE OTHER WAS RESOLVED WITHOUT A MONETARY SETTLEMENT. THE FIRM NEVER REPORTED EITHER OF THESE COMPLAINTS ON THE REGISTERED REPRESENTATIVE'S FORM U4, AND NEVER DISCLOSED THE www.finra.org/brokercheck SETTLEMENT OF THE SECOND COMPLAINT FOR MORE THAN $15,000. THE User Guidance CUSTOMER COMPLAINTS ALLEGED MISAPPROPRIATION OF FUNDS WHICH REQUIRES DISCLOSURE UNDER NASD RULE 3070 WITHIN TEN DAYS. ONE COMPLAINT WAS NOT REPORTED UNTIL THREE AND ONE-HALF MONTHS AFTER IT WAS RECEIVED WHILE TO OTHER WAS NEVER REPORTED. Initiated By: FINRA Date Initiated: 04/09/2013 Docket/Case Number: 2010022380001

Principal Product Type: Other Other Product Type(s): NA 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: 04/09/2013 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE IT IS CENSURED AND FINED $50,000. THE FIRM FURTHER UNDERTOOK AND AGREED TO CONDUCT A COMPREHENSIVE REVIEW OF ITS SYSTEMS, POLICIES AND PROCEDURES TO ENSURE THAT THOSE POLICIES AND PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULES AND THE FEDERAL SECURITIES LAWS REGARDING BORROWING MONEY FROM, OR LENDING MONEY TO, CUSTOMERS BY REGISTERED REPRESENTATIVES. WITHIN 120 DAYS OF THE ISSUANCE OF A NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT (I) THE FIRM HAS ENGAGED IN THE COMPREHENSIVE REVIEW; AND (II) AS OF THE DATE OF THE CERTIFICATION, THE FIRM HAS IN PLACE POLICIES AND PROCEDURES TO REASONABLY DESIGNED TO ADDRESS AND CORRECT THE VIOLATIONS RELATING TO SUPERVISION DESCRIBED IN THIS AWC. i Disclosure 39 of 167 Reporting Source: Firm Current Status: Final Allegations: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ALLEGED THAT DURING THE APPROXIMATE PERIOD OF JANUARY 2007 THROUGH DECEMBER 2010 WELLS FARGO ADVISORS, LLC, AN UNLICENSED ENTITY, ©2021 FINRA. All rights reserved. Report aboutACCEPTED WELLS FARGO INSURANCE CLEARING COMMISSIONS SERVICES, LLC FROM WELLS FARGO ADVISORS 126 INSURANCE AGENCY LLC, IN VIOLATION OF NEW YORK INSURANCE LAW. THE DEPARTMENT FURTHER ALLEGED THAT BOTH WELLS FARGO ADVISORS LLC AND WELLS FARGO ADVISORS FINANCIAL NETWORK LLC PROVIDED MATERIALLY INCOMPLETE INFORMATION IN THEIR RESPECTIVE INSURANCE LICENSE APPLICATIONS SUBMITTED TO THE STATE ON OR ABOUT JANUARY 27, 2012. www.finra.org/brokercheck User Guidance

THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ALLEGED THAT DURING THE APPROXIMATE PERIOD OF JANUARY 2007 THROUGH DECEMBER 2010 WELLS FARGO ADVISORS, LLC, AN UNLICENSED ENTITY, ACCEPTED INSURANCE COMMISSIONS FROM WELLS FARGO ADVISORS INSURANCE AGENCY LLC, IN VIOLATION OF NEW YORK INSURANCE LAW. THE DEPARTMENT FURTHER ALLEGED THAT BOTH WELLS FARGO ADVISORS LLC AND WELLS FARGO ADVISORS FINANCIAL NETWORK LLC PROVIDED MATERIALLY INCOMPLETE INFORMATION IN THEIR RESPECTIVE INSURANCE LICENSE APPLICATIONS SUBMITTED TO THE STATE ON OR ABOUT JANUARY 27, 2012. Initiated By: NEW YORK DEPARTMENT OF FINANCIAL SERVICES Date Initiated: 02/27/2013 Docket/Case Number: 2012-0184-S

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

Resolution: Stipulation and Consent Resolution Date: 02/27/2013 Sanctions Ordered: Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: WELLS FARGO ADVISORS AND AFFILIATES PAID A $50,000 FINE AND AGREED TO TAKE ALL NECESSARY STEPS TO PREVENT THE REOCCURRENCE OF SIMILAR VIOLATIONS. i Disclosure 40 of 167 Reporting Source: Regulator Current Status: Final Allegations: ON DECEMBER 15, 2010, WELLS FARGO, A FEDERALLY COVERED INVESTMENT ADVISER, INFORMED THE OFFICE BY LETTER THAT AN ANOMALY IN ITS AUTOMATED SYSTEMS HAD CAUSED A NUMBER OF INDIVIDUALS TO ENGAGE IN INVESTMENT ADVISORY BUSINESS IN FLORIDA WITHOUT BENEFIT OF INVESTMENT ADVISER REPRESENTATIVE REGISTRATION. IN EARLY 2012, WELLS FARGO ADVISORS, LLC NOTIFIED THE OFFICE THAT IT HAD ADDITIONAL FINANCIAL ADVISORS, INCLUDING SHAPIRO AND BEACH, THAT POTENTIALLY NEEDED INVESTMENT ADVISER REPRESENTATIVE REGISTRATION IN FLORIDA. SHAPIRO AND BEACH ARE ©2021 FINRA. All rights reserved. Report aboutPROPERLY WELLS FARGO REGISTERED CLEARING SERVICES,WITH THE LLC OFFICE TO SELL SECURITIES. ON 127 MARCH 16,2012, THE OFFICE ISSUED A LETTER TO DETERMINE IF SHAPIRO AND BEACH HAD ENGAGED IN INVESTMENT ADVISORY BUSINESS FROM OFFICES IN FLORIDA. IN RESPONSE TO THE OFFICE'S INQUIRY, SHAPIRO INDICATED THAT HE HAD ENGAGED IN BUSINESS FOR THREE MONTHS OUT OF THE YEAR SINCE 2008, AND BEACH INDICATED THAT HE HAD ENGAGED IN BUSINESS FOR TWO TO FOUR MONTHS PER YEAR SINCE 2009, PRIOR TO THEM EACH OBTAINING PROPER REGISTRATION IN FLORIDA. ON DECEMBER 15, 2010, WELLS FARGO, A FEDERALLY COVERED INVESTMENT ADVISER, INFORMED THE OFFICE BY LETTER THAT AN ANOMALY IN ITS AUTOMATED SYSTEMS HAD CAUSED A NUMBER OF INDIVIDUALS TO ENGAGE IN INVESTMENT ADVISORY BUSINESS IN www.finra.org/brokercheck FLORIDA WITHOUT BENEFIT OF INVESTMENT ADVISER REPRESENTATIVE User Guidance REGISTRATION. IN EARLY 2012, WELLS FARGO ADVISORS, LLC NOTIFIED THE OFFICE THAT IT HAD ADDITIONAL FINANCIAL ADVISORS, INCLUDING SHAPIRO AND BEACH, THAT POTENTIALLY NEEDED INVESTMENT ADVISER REPRESENTATIVE REGISTRATION IN FLORIDA. SHAPIRO AND BEACH ARE PROPERLY REGISTERED WITH THE OFFICE TO SELL SECURITIES. ON MARCH 16,2012, THE OFFICE ISSUED A LETTER TO DETERMINE IF SHAPIRO AND BEACH HAD ENGAGED IN INVESTMENT ADVISORY BUSINESS FROM OFFICES IN FLORIDA. IN RESPONSE TO THE OFFICE'S INQUIRY, SHAPIRO INDICATED THAT HE HAD ENGAGED IN BUSINESS FOR THREE MONTHS OUT OF THE YEAR SINCE 2008, AND BEACH INDICATED THAT HE HAD ENGAGED IN BUSINESS FOR TWO TO FOUR MONTHS PER YEAR SINCE 2009, PRIOR TO THEM EACH OBTAINING PROPER REGISTRATION IN FLORIDA. Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION ("OFR") Date Initiated: 03/16/2012 Docket/Case Number: 0672-S-9/12 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: Order Resolution Date: 02/12/2013 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 $30,000.00 Other Sanctions Ordered: Sanction Details: ON 2/12/2013, THE OFFICE OF FINANCIAL REGULATION ("OFFICE") ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF WELLS FARGO ADVISORS, LLC, MARTIN SHAPIRO, AND SAMUEL BEACH JR ("RESPONDENTS"). RESPONDENTS NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THE ENTRY OF FINDINGS BY THE OFFICE. WELLS FARGO ADVISORS, LLC AGREES TO CEASE AND DESIST FROM ANY AND ALL FUTURE VIOLATIONS OF CHAPTER 517, F.S. AND THE ADMINISTRATIVE RULES THEREUNDER AND AGREES TO PAY AN ADMINISTRATIVE FINE OF $30,000.00. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 128 ON 2/12/2013, THE OFFICE OF FINANCIAL REGULATION ("OFFICE") ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF WELLS FARGO ADVISORS, LLC, MARTIN SHAPIRO, AND SAMUEL BEACH JR ("RESPONDENTS"). RESPONDENTS www.finra.org/brokercheck NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THE User Guidance ENTRY OF FINDINGS BY THE OFFICE. WELLS FARGO ADVISORS, LLC AGREES TO CEASE AND DESIST FROM ANY AND ALL FUTURE VIOLATIONS OF CHAPTER 517, F.S. AND THE ADMINISTRATIVE RULES THEREUNDER AND AGREES TO PAY AN ADMINISTRATIVE FINE OF $30,000.00. i Reporting Source: Firm Current Status: Final Allegations: ON DECEMBER 15, 2010, WELLS FARGO, A FEDERALLY COVERED INVESTMENT ADVISER, INFORMED THE OFFICE BY LETTER THAT AN ANOMALY IN ITS AUTOMATED SYSTEMS HAD CAUSED A NUMBER OF INDIVIDUALS TO ENGAGE IN INVESTMENT ADVISORY BUSINESS IN FLORIDA WITHOUT BENEFIT OF INVESTMENT ADVISER REPRESENTATIVE REGISTRATION. IN EARLY 2012, WELLS FARGO ADVISORS, LLC NOTIFIED THE OFFICE THAT IT HAD ADDITIONAL FINANCIAL ADVISORS, INCLUDING TWO OTHER REGISTERED ASSOCIATES, THAT POTENTIALLY NEEDED INVESTMENT ADVISER REPRESENTATIVE REGISTRATION IN FLORIDA. THE REGISTERED ASSOCIATAED ARE PROPERLY REGISTERED WITH THE OFFICE TO SELL SECURITIES. ON MARCH 16,2012, THE OFFICE ISSUED A LETTER TO DETERMINE IF THEY HAD ENGAGED IN INVESTMENT ADVISORY BUSINESS FROM OFFICES IN FLORIDA. IN RESPONSE TO THE OFFICE'S INQUIRY, A REGISTERED ASSOCIATE INDICATED THAT HE HAD ENGAGED IN BUSINESS FOR THREE MONTHS OUT OF THE YEAR SINCE 2008, AND ANOTHER REGISTERED ASSOCIATE INDICATED THAT HE HAD ENGAGED IN BUSINESS FOR TWO TO FOUR MONTHS PER YEAR SINCE 2009, PRIOR TO THEM EACH OBTAINING PROPER REGISTRATION IN FLORIDA. Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION ("OFR") Date Initiated: 02/12/2013 Docket/Case Number: 0672-S-9/12

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: 02/12/2013 Sanctions Ordered: Monetary/Fine $30,000.00 Other Sanctions Ordered: Sanction Details: ON 2/12/2013, THE OFFICE OF FINANCIAL REGULATION ("OFFICE") ©2021 FINRA. All rights reserved. Report aboutENTERED WELLS FARGOA FINAL CLEARING ORDER SERVICES, ADOPTING LLC THE STIPULATION AND CONSENT 129 AGREEMENT IN THE MATTER OF WELLS FARGO ADVISORS, LLC, AND TWO OTHER REGISTERED ASSOCIATES ("RESPONDENTS"). RESPONDENTS NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THE ENTRY OF FINDINGS BY THE OFFICE. WELLS FARGO ADVISORS, LLC AGREES TO CEASE AND DESIST FROM ANY AND ALL FUTURE VIOLATIONS OF CHAPTER 517, F.S. AND THE ADMINISTRATIVE RULES THEREUNDER AND AGREES TO PAY AN ADMINISTRATIVE FINE OF $30,000.00. www.finra.org/brokercheck User Guidance

Sanction Details: ON 2/12/2013, THE OFFICE OF FINANCIAL REGULATION ("OFFICE") ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF WELLS FARGO ADVISORS, LLC, AND TWO OTHER REGISTERED ASSOCIATES ("RESPONDENTS"). RESPONDENTS NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THE ENTRY OF FINDINGS BY THE OFFICE. WELLS FARGO ADVISORS, LLC AGREES TO CEASE AND DESIST FROM ANY AND ALL FUTURE VIOLATIONS OF CHAPTER 517, F.S. AND THE ADMINISTRATIVE RULES THEREUNDER AND AGREES TO PAY AN ADMINISTRATIVE FINE OF $30,000.00. i Disclosure 41 of 167 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULE 2010, NASD RULES 2110, 2310, 3010 - WELLS FARGO ADVISORS, LLC FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD AND FINRA RULES IN CONNECTION WITH THE SALE OF NON-TRADITIONAL EXCHANGE-TRADED FUNDS (ETFS) IN ACCOUNTS WHERE THE FIRM PROVIDED BROKERAGE SERVICES TO CERTAIN RETAIL CUSTOMERS AND THE FIRM FAILED TO PROVIDE ADEQUATE FORMAL TRAINING AND GUIDANCE TO ITS REGISTERED REPRESENTATIVES AND SUPERVISORS REGARDING NON-TRADITIONAL ETFS. THE FIRM ALLOWED ITS REGISTERED REPRESENTATIVES TO RECOMMEND A NON-TRADITIONAL ETF TO CUSTOMERS WITHOUT PERFORMING REASONABLE DILIGENCE TO UNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH IT. CERTAIN FIRM REGISTERED REPRESENTATIVES MADE UNSUITABLE RECOMMENDATION OF NON- TRADITIONAL ETFS TO CERTAIN CUSTOMERS WITH CONSERVATIVE INCOME OR CONSERVATIVE GROWTH & INCOME INVESTMENT OBJECTIVES AND/OR RISK TOLERANCES. Initiated By: FINRA Date Initiated: 05/01/2012 Docket/Case Number: 2009019113901

Principal Product Type: Other Other Product Type(s): NON-TRADITIONAL EXCHANGE TRADED FUNDS Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/01/2012 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 $2,100,000.00 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 $2.1 MILLION AND ORDERED TO PAY $641,489 IN RESTITUTION, JOINTLY AND SEVERALLY. A REGISTERED FIRM PRINCIPAL 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 AFTER ACCEPTANCE OF THE AWC. ANY UNDISTRIBUTED RESTITUTION SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LAST RESIDED. THE FIRM SHALL PROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION TO THE APPROPRIATE STATE AUTHORITY. FINE PAID IN FULL ON MAY 16, 2012. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULE 2010, NASD RULES 2110, 2310, 3010 - WELLS FARGO ADVISORS, LLC FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD AND FINRA RULES IN CONNECTION WITH THE SALE OF NON-TRADITIONAL EXCHANGE-TRADED FUNDS (ETFS) IN ACCOUNTS WHERE THE FIRM PROVIDED BROKERAGE SERVICES TO CERTAIN RETAIL CUSTOMERS AND THE FIRM FAILED TO PROVIDE ADEQUATE FORMAL TRAINING AND GUIDANCE TO ITS REGISTERED REPRESENTATIVES AND SUPERVISORS REGARDING NON-TRADITIONAL ETFS. THE FIRM ALLOWED ITS REGISTERED REPRESENTATIVES TO RECOMMEND A NON-TRADITIONAL ETF TO CUSTOMERS WITHOUT PERFORMING REASONABLE DILIGENCE TO UNDERSTAND THE RISKS AND ©2021 FINRA. All rights reserved. Report aboutFEATURES WELLS FARGO ASSOCIATED CLEARING SERVICES,WITH IT. CERTAINLLC FIRM REGISTERED 131 REPRESENTATIVES MADE UNSUITABLE RECOMMENDATION OF NON- TRADITIONAL ETFS TO CERTAIN CUSTOMERS WITH CONSERVATIVE INCOME OR CONSERVATIVE GROWTH & INCOME INVESTMENT OBJECTIVES AND/OR RISK TOLERANCES. FINRA RULE 2010, NASD RULES 2110, 2310, 3010 - WELLS FARGO ADVISORS, LLC FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD AND FINRA RULES IN CONNECTION WITH THE SALE OF NON-TRADITIONAL EXCHANGE-TRADED FUNDS (ETFS) IN ACCOUNTS WHERE THE FIRM PROVIDED BROKERAGE SERVICES TO CERTAIN RETAIL CUSTOMERS AND THE FIRM FAILED TO PROVIDE www.finra.org/brokercheck ADEQUATE FORMAL TRAINING AND GUIDANCE TO ITS REGISTERED User Guidance REPRESENTATIVES AND SUPERVISORS REGARDING NON-TRADITIONAL ETFS. THE FIRM ALLOWED ITS REGISTERED REPRESENTATIVES TO RECOMMEND A NON-TRADITIONAL ETF TO CUSTOMERS WITHOUT PERFORMING REASONABLE DILIGENCE TO UNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH IT. CERTAIN FIRM REGISTERED REPRESENTATIVES MADE UNSUITABLE RECOMMENDATION OF NON- TRADITIONAL ETFS TO CERTAIN CUSTOMERS WITH CONSERVATIVE INCOME OR CONSERVATIVE GROWTH & INCOME INVESTMENT OBJECTIVES AND/OR RISK TOLERANCES. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) Date Initiated: 05/01/2012 Docket/Case Number: 20090191139

Principal Product Type: Other Other Product Type(s): NON-TRADITIONAL EXCHANGE TRADED FUNDS Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought: RESTITUTION

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/01/2012 Sanctions Ordered: Censure Monetary/Fine $2,100,000.00 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 WITH ITS AFFILIATE WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC IS FINED $2.1 MILLION AND ORDERED TO PAY $641,489 IN RESTITUTION, JOINTLY AND SEVERALLY. A REGISTERED FIRM PRINCIPAL 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 AFTER ACCEPTANCE OF THE AWC. ANY UNDISTRIBUTED RESTITUTION SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LAST RESIDED. THE FIRM SHALL PROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION TO THE APPROPRIATE STATE AUTHORITY. i Disclosure 42 of 167 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 132 www.finra.org/brokercheck User Guidance

Disclosure 42 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010(B)(1): THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATE WRITTEN PROCEDURES RELATED TO THE RESTORATION OR RELEASE OF ACCOUNTS FROM ABANDONED STATUS. THE FIRM'S WRITTEN PROCEDURES REQUIRED THAT EMPLOYEES WISHING TO RESTORE CUSTOMER ACCOUNTS FROM AN ABANDONED STATUS SEND A WRITTEN REQUEST TO ITS ESCHEATMENT GROUP TO RESTORE THE ACCOUNT. THE FIRM'S WRITTEN PROCEDURES FAILED TO IDENTIFY THE FIRM PERSONNEL WHO WERE AUTHORIZED TO SUBMIT REQUESTS TO HAVE ABANDONED ACCOUNTS RESTORED OR RELEASED FROM ABANDONED STATUS. ESCHEATMENT ACCEPTED REQUESTS TO RESTORE ABANDONED ACCOUNTS FROM BRANCH OFFICE PERSONNEL WORKING IN THE BRANCH OFFICE WHERE THE ABANDONED ACCOUNT WAS LAST SERVICED. THE FIRM'S WRITTEN PROCEDURES DID NOT REQUIRE THAT THE REQUESTOR OBTAIN SUPERVISORY APPROVAL BEFORE SUBMITTING REQUESTS TO HAVE ABANDONED ACCOUNTS RESTORED OR RELEASED FROM ABANDONED STATUS, DID NOT REQUIRE THE REQUESTOR TO SUBMIT PROOF TO ESCHEATMENT THAT A CUSTOMER HAD BEEN LOCATED AND DID NOT REQUIRE THE REQUESTOR TO SUBMIT PROOF TO ESCHEATMENT OF THE CUSTOMER'S NEW ADDRESS. THE FIRM'S PROCEDURES ALSO DID NOT REQUIRE THAT ESCHEATMENT NOTIFY BRANCH OFFICE MANAGERS WHEN ACCOUNTS WERE RESTORED TO ACTIVE STATUS. AFTER THE RESTORATION OF AN ABANDONED ACCOUNT, THE REQUESTOR WAS REQUIRED TO SUBMIT A CHANGE OF ADDRESS REQUEST WITH THE CUSTOMER'S NEW ADDRESS TO THE FIRM'S NEW ACCOUNTS GROUP. UPON RECEIPT OF THE ADDRESS CHANGE REQUESTS, THE FIRM CHANGED THE ADDRESS OF RECORD OF THE RESTORED ACCOUNT AND SENT LETTERS CONFIRMING THE CHANGE OF ADDRESS TO BOTH THE CUSTOMER'S NEW AND OLD ADDRESS, ALTHOUGH THE OLD ADDRESS WAS INVARIABLY AN INVALID ADDRESS. THE FIRM'S DEFICIENT PROCEDURES FACILITATED A FIRM OPERATIONS MANAGER'S CONVERSION OF APPROXIMATELY $850,000 IN CUSTOMERS' FUNDS FOR HER PERSONAL USE AND ENABLED THE OPERATIONS MANAGER'S CONDUCT TO ESCAPE DETECTION BY THE FIRM. Initiated By: FINRA Date Initiated: 10/24/2011 Docket/Case Number: 2009020630701

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: 10/24/2011 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 $350,000.00 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 $350,000. i Reporting Source: Firm Current Status: Final Allegations: NASD RULES 2110, 3010(B)(1): THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATE WRITTEN PROCEDURES RELATED TO THE RESTORATION OR RELEASE OF ACCOUNTS FROM ABANDONED STATUS. THE FIRM'S WRITTEN PROCEDURES REQUIRED THAT EMPLOYEES WISHING TO RESTORE CUSTOMER ACCOUNTS FROM AN ABANDONED STATUS SEND A WRITTEN REQUEST TO ITS ESCHEATMENT GROUP TO RESTORE THE ACCOUNT. THE FIRM'S WRITTEN PROCEDURES FAILED TO IDENTIFY THE FIRM PERSONNEL WHO WERE AUTHORIZED TO SUBMIT REQUESTS TO HAVE ABANDONED ACCOUNTS RESTORED OR RELEASED FROM ABANDONED STATUS. ESCHEATMENT ACCEPTED REQUESTS TO RESTORE ABANDONED ACCOUNTS FROM BRANCH OFFICE PERSONNEL WORKING IN THE BRANCH OFFICE WHERE THE ABANDONED ACCOUNT WAS LAST SERVICED. THE FIRM'S WRITTEN PROCEDURES DID NOT REQUIRE THAT THE REQUESTOR OBTAIN SUPERVISORY APPROVAL BEFORE SUBMITTING REQUESTS TO HAVE ABANDONED ACCOUNTS RESTORED OR RELEASED FROM ABANDONED STATUS, DID NOT REQUIRE THE REQUESTOR TO SUBMIT PROOF TO ESCHEATMENT THAT A CUSTOMER HAD BEEN LOCATED AND DID NOT REQUIRE THE REQUESTOR TO SUBMIT PROOF TO ESCHEATMENT OF THE CUSTOMER'S NEW ©2021 FINRA. All rights reserved. Report aboutADDRESS. WELLS FARGO THE FIRM'S CLEARING PROCEDURES SERVICES, LLC ALSO DID NOT REQUIRE THAT 134 ESCHEATMENT NOTIFY BRANCH OFFICE MANAGERS WHEN ACCOUNTS WERE RESTORED TO ACTIVE STATUS. AFTER THE RESTORATION OF AN ABANDONED ACCOUNT, THE REQUESTOR WAS REQUIRED TO SUBMIT A CHANGE OF ADDRESS REQUEST WITH THE CUSTOMER'S NEW ADDRESS TO THE FIRM'S NEW ACCOUNTS GROUP. UPON RECEIPT OF THE ADDRESS CHANGE REQUESTS, THE FIRM CHANGED THE ADDRESS OF RECORD OF THE RESTORED ACCOUNT AND SENT LETTERS CONFIRMING THE CHANGE OF ADDRESS TO BOTH THE CUSTOMER'S NEW AND OLD ADDRESS, ALTHOUGH THE OLD ADDRESS WAS INVARIABLY AN INVALID ADDRESS. THE FIRM'S DEFICIENT PROCEDURES FACILITATED A FIRM OPERATIONS MANAGER'S CONVERSION OF APPROXIMATELY $850,000 IN CUSTOMERS' FUNDS FOR HER PERSONAL USE AND ENABLED THE OPERATIONS MANAGER'S CONDUCT TO ESCAPE DETECTION BY THE FIRM. NASD RULES 2110, 3010(B)(1): THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATE WRITTEN PROCEDURES RELATED TO THE RESTORATION OR RELEASE OF ACCOUNTS FROM ABANDONED STATUS. THE FIRM'S WRITTEN PROCEDURES REQUIRED THAT EMPLOYEES WISHING TO RESTORE CUSTOMER ACCOUNTS FROM AN ABANDONED STATUS SEND A WRITTEN REQUEST TO ITS ESCHEATMENT GROUP TO RESTORE THE ACCOUNT. THE FIRM'S WRITTEN PROCEDURES FAILED TO IDENTIFY THE FIRM PERSONNEL WHO WERE AUTHORIZED TO SUBMIT REQUESTS TO HAVE ABANDONED ACCOUNTS RESTORED OR RELEASED FROM ABANDONED STATUS. ESCHEATMENT ACCEPTED REQUESTS TO RESTORE ABANDONED ACCOUNTS FROM BRANCH OFFICE PERSONNEL WORKING IN THE BRANCH OFFICE WHERE THE ABANDONED ACCOUNT WAS LAST SERVICED. THE FIRM'S WRITTEN PROCEDURES DID NOT REQUIRE THAT THE REQUESTOR OBTAIN SUPERVISORY APPROVAL www.finra.org/brokercheck BEFORE SUBMITTING REQUESTS TO HAVE ABANDONED ACCOUNTS User Guidance RESTORED OR RELEASED FROM ABANDONED STATUS, DID NOT REQUIRE THE REQUESTOR TO SUBMIT PROOF TO ESCHEATMENT THAT A CUSTOMER HAD BEEN LOCATED AND DID NOT REQUIRE THE REQUESTOR TO SUBMIT PROOF TO ESCHEATMENT OF THE CUSTOMER'S NEW ADDRESS. THE FIRM'S PROCEDURES ALSO DID NOT REQUIRE THAT ESCHEATMENT NOTIFY BRANCH OFFICE MANAGERS WHEN ACCOUNTS WERE RESTORED TO ACTIVE STATUS. AFTER THE RESTORATION OF AN ABANDONED ACCOUNT, THE REQUESTOR WAS REQUIRED TO SUBMIT A CHANGE OF ADDRESS REQUEST WITH THE CUSTOMER'S NEW ADDRESS TO THE FIRM'S NEW ACCOUNTS GROUP. UPON RECEIPT OF THE ADDRESS CHANGE REQUESTS, THE FIRM CHANGED THE ADDRESS OF RECORD OF THE RESTORED ACCOUNT AND SENT LETTERS CONFIRMING THE CHANGE OF ADDRESS TO BOTH THE CUSTOMER'S NEW AND OLD ADDRESS, ALTHOUGH THE OLD ADDRESS WAS INVARIABLY AN INVALID ADDRESS. THE FIRM'S DEFICIENT PROCEDURES FACILITATED A FIRM OPERATIONS MANAGER'S CONVERSION OF APPROXIMATELY $850,000 IN CUSTOMERS' FUNDS FOR HER PERSONAL USE AND ENABLED THE OPERATIONS MANAGER'S CONDUCT TO ESCAPE DETECTION BY THE FIRM. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) Date Initiated: 10/24/2011 Docket/Case Number: 20090206307

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE OF $350,000.00 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/24/2011 Sanctions Ordered: Censure Monetary/Fine $350,000.00 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 $350,000. Firm Statement IN APRIL 2011, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") NOTIFIED WELLS FARGO ADVISORS, L.L.C. ("WELLS FARGO") OF ITS INTENT TO RECOMMEND THAT WELLS FARGO BE SUBJECT TO DISCIPLINARY ACTION FOR VIOLATIONS OF NASD RULE 3010(B)(1) AND FINRA RULE 2010 FOR ITS FAILURE, FROM OCTOBER 2005 - MARCH 2007, TO ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES FOR THE RESTORATION OF ACCOUNTS FROM "ABANDONED" TO "ACTIVE" STATUS. ©2021 FINRA. All rights reserved. Report aboutDURING WELLS THAT FARGO TIME, CLEARING A REGISTERED SERVICES, LLC PRINCIPAL OF WACHOVIA SECURITIES, 135 LLC ("WACHOVIA"), N/K/A WELLS FARGO ADVISORS,LLC MISAPPROPRIATED APPROXIMATELY $847,188.87 OF ASSETS FROM ABANDONED CLIENT ACCOUNTS BY FRAUDULENTLY RESTORING "ABANDONED" ACCOUNTS TO "ACTIVE" STATUS AND THEREAFTER FORGING CHECK AND WIRE TRANSFER DOCUMENTATION TO CONVERT "ABANDONED" ASSETS TO HER OWN USE AND BENEFIT. WACHOVIA WAS A REGISTERED BROKER-DEALER AND WHOLLY-OWNED SUBSIDIARY OF WACHOVIA CORPORATION. WACHOVIA SECURITIES, LLC WAS RENAMED WELLS FARGO ADVISORS, L.L.C. AFTER WACHOVIA CORPORATION MERGED WITH WELLS FARGO & COMPANY ON DECEMBER 31, 2008.

AFTER DISCOVERING THE FRAUDULENT ACTIVITY, WACHOVIA RESTORED ALL FUNDS TO EACH AFFECTED ACCOUNT AND IMPLEMENTED ADDITIONAL POLICIES AND PROCEDURES TO STRENGTHEN OVERSIGHT OF THE PROCESS THROUGH WHICH ACCOUNTS ARE RESTORED FROM "ABANDONED" TO "ACTIVE" STATUS. WELLS FARGO HAS FULLY COOPERATED WITH THE FINRA INVESTIGATION. IN APRIL 2011, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") NOTIFIED WELLS FARGO ADVISORS, L.L.C. ("WELLS FARGO") OF www.finra.org/brokercheck ITS INTENT TO RECOMMEND THAT WELLS FARGO BE SUBJECT TO User Guidance DISCIPLINARY ACTION FOR VIOLATIONS OF NASD RULE 3010(B)(1) AND FINRA RULE 2010 FOR ITS FAILURE, FROM OCTOBER 2005 - MARCH 2007, TO ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES FOR THE RESTORATION OF ACCOUNTS FROM "ABANDONED" TO "ACTIVE" STATUS. DURING THAT TIME, A REGISTERED PRINCIPAL OF WACHOVIA SECURITIES, LLC ("WACHOVIA"), N/K/A WELLS FARGO ADVISORS,LLC MISAPPROPRIATED APPROXIMATELY $847,188.87 OF ASSETS FROM ABANDONED CLIENT ACCOUNTS BY FRAUDULENTLY RESTORING "ABANDONED" ACCOUNTS TO "ACTIVE" STATUS AND THEREAFTER FORGING CHECK AND WIRE TRANSFER DOCUMENTATION TO CONVERT "ABANDONED" ASSETS TO HER OWN USE AND BENEFIT. WACHOVIA WAS A REGISTERED BROKER-DEALER AND WHOLLY-OWNED SUBSIDIARY OF WACHOVIA CORPORATION. WACHOVIA SECURITIES, LLC WAS RENAMED WELLS FARGO ADVISORS, L.L.C. AFTER WACHOVIA CORPORATION MERGED WITH WELLS FARGO & COMPANY ON DECEMBER 31, 2008.

AFTER DISCOVERING THE FRAUDULENT ACTIVITY, WACHOVIA RESTORED ALL FUNDS TO EACH AFFECTED ACCOUNT AND IMPLEMENTED ADDITIONAL POLICIES AND PROCEDURES TO STRENGTHEN OVERSIGHT OF THE PROCESS THROUGH WHICH ACCOUNTS ARE RESTORED FROM "ABANDONED" TO "ACTIVE" STATUS. WELLS FARGO HAS FULLY COOPERATED WITH THE FINRA INVESTIGATION. i Disclosure 43 of 167 Reporting Source: Regulator Current Status: Final Allegations: BY THE TERMS, WACHOVIA SECURITIES, LLC (RESPONDENT) DOES NOT ADMIT OR DENY THE ALLEGATIONS OF THE PENNSYLVANIA SECURITIES COMMISSION THAT THE RESPONDENT FAILED TO PROPERLY SUPERVISE ITS REGISTERED REPRESENTATIVE IN VIOLATION OF THE PROVISIONS OF THE PA SECURITIES ACT OF 1972. Initiated By: PENNSYLVANIA CONTACT: COUNSEL DANIEL J. GALLAGHER (717)-783-4226 Date Initiated: 09/20/2011 Docket/Case Number: 2010-03-23 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 WACHOVIA SECURITIES, LLC IS ORDERED TO PAY $150,000.00 TO THE Sought: COMMONWEALTH OF PENNSYLVANIA WITHIN 30 DAYS OF THE DATE OF THIS ORDER, WHICH AMOUNT REPRESENTS AN ADMINISTRATIVE ASSESSMENT. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 136 www.finra.org/brokercheck User Guidance WACHOVIA SECURITIES, LLC IS ORDERED TO PAY $150,000.00 TO THE COMMONWEALTH OF PENNSYLVANIA WITHIN 30 DAYS OF THE DATE OF THIS ORDER, WHICH AMOUNT REPRESENTS AN ADMINISTRATIVE ASSESSMENT.

Resolution: Settled Resolution Date: 09/20/2011 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: Monetary/Fine $150,000.00 Other Sanctions Ordered: Sanction Details: WACHOVIA SECURITIES, LLC IS ORDERED TO PAY $150,000.00 TO THE COMMONWEALTH OF PENNSYLVANIA WITHIN 30 DAYS OF THE DATE OF THIS ORDER, WHICH AMOUNT REPRESENTS AN ADMINISTRATIVE ASSESSMENT. WACHOVIA SECURITIES, LLC IS ORDERED TO PAY $8,557.85 TO THE COMMONWEALTH OF PENNSYLVANIA WITHIN 30 DAYS OF THE DATE OF THIS ORDER, WHICH AMOUNT REPRESENTS LEGAL AND INVESTIGATIVE COSTS. Regulator Statement FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER ISSUED TO WACHOVICA SECURITIES, LLC. i Reporting Source: Firm Current Status: Final Allegations: THE COMMONWEALTH OF PENNSYLVANIA ALLEGED THAT THE FIRM FAILED TO SUPERVISE AN AGENT LOCATED IN MORGANTOWN, WV FROM JUNE 2007 TO OCTOBER 2008. WITHOUT ADMITTING ANY LIABILITY OR WRONGDOING, THE FIRM SETTLED THIS MATTER ON SEPTEMBER 20, 2011 WITH THE CLIENT FOR THE AMOUNT OF $158,557.85. FINRA MATTER # WAS 20100226488. Initiated By: PENNSYLVANIA SECURITIES COMMISSION Date Initiated: 09/20/2011 Docket/Case Number: 2010-03-23

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 137 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief WACHOVIA SECURITIES, LLC IS ORDERED TO PAY $150,000.00 TO THE Sought: COMMONWEALTH OF PENNSYLVANIA WITHIN 30 DAYS OF THE DATE OF THIS ORDER, WHICH AMOUNT REPRESENTS AN ADMINISTRATIVE ASSESSMENT.

Resolution: Settled Resolution Date: 09/20/2011 Sanctions Ordered: Monetary/Fine $150,000.00 Other Sanctions Ordered: WITHIN 30 DAYS OF THE DATE OF THIS ORDER, WACHOVIA SECURITIES, LLC IS ORDERED TO PAY $8,557.85 TO THE COMMONWEALTH OF PENNSYLVANIA FOR LEGAL AND INVESTIGATIVE COSTS. Sanction Details: WACHOVIA SECURITIES, LLC IS ORDERED TO PAY AN ADMINISTRATIVE ASSESSMENT OF $150,000.00 AND LEGAL AND INVESTIGATIVE COSTS OF $8,557.85 TO THE COMMONWEALTH OF PENNSYLVANIA WITHIN 30 DAYS OF THE DATE OF THIS ORDER. . Firm Statement THE COMMONWEALTH OF PENNSYLVANIA ALLEGED THAT THE FIRM FAILED TO SUPERVISE AN AGENT LOCATED IN MORGANTOWN, WV DURING THE TIME PERIOD OF JUNE 2007 TO OCTOBER 2008. WITHOUT ADMITTING ANY LIABILITY OR WRONGDOING, THE FIRM SETTLED THIS MATTER WITH THE CLIENT ON SEPTEMBER 20, 2011 FOR THE AMOUNT OF $158,557.85. FINRA MATTER # 20100226488. i Disclosure 44 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF NEW JERSEY HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF NEW JERSEY OFFICE OF THE ATTORNEY GENERAL BUREAU OF SECURITIES Date Initiated: 09/27/2011 Docket/Case Number: CONSENT ORDER

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

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/27/2011 Sanctions Ordered: Censure Monetary/Fine $3,234,065.06 Disgorgement/Restitution Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE IS DUE TO THE STATE OF NEW JERSEY ON OCTOBER 7, 2011. i Disclosure 45 of 167 Reporting Source: Firm Current Status: Final Allegations: IN AMENDED CONSENT ORDER, DOCKET NO. 2011-0312, IN THE MATTER OF WELLS FARGO ADVISORS, LLC, THE MARYLAND DIVISION OF SECURITIES ALLEGED THAT WELLS FARGO ADVISORS, LLC EMPLOYED EIGHT INVESTMENT ADVISER REPRESENTATIVES WHO PROVIDED INVESTMENT ADVISORY SERVICES TO CLIENTS PRIOR TO BEING REGISTERED WITH THE SECURITIES DIVISION AS INVESTMENT ADVISER REPRESENTATIVES PURSUANT TO SECTION 11-402 OF THE MARYLAND SECURITIES ACT. THE DIVISION ALSO ALLEGED THAT THE FIRM FAILED TO TIMELY AMEND THE FORMS U4 OF TWO OF ITS AGENTS TO REFLECT THE CHANGE IN THEIR EMPLOYMENT ADDRESS PURSUANT TO SECTION 11- 411(D) OF THE MARYLAND SECURITIES ACT AND REGULATION 02.02.02.07 OF THE CODE OF MARYLAND REGULATIONS. THE FIRM WAS ORDERED TO PAY A FINE OF $50,000 TO THE MARYLAND SECURITIES DIVISION, LESS THE $5,000 FINE THE FIRM PAID TO THE DIVISION IN AUGUST 2011 PURSUANT TO THE ORIGINAL CONSENT ORDER ISSUED IN THIS MATTER. THE FIRM WAS ALSO ORDERED TO FOLLOW THE COMPLIANCE POLICIES AND PROCEDURES PROVIDED TO THE DIVISION IN CONNECTION WITH THE MATTER, AND COMPLY FULLY WITH THE MARYLAND SECURITIES ACT AND RULES AND REGULATIONS PROMULGATED THEREUNDER. Initiated By: STATE OF MARYLAND ATTORNEY GENERAL - SECURITIES DIVISION Date Initiated: 03/12/2012 Docket/Case Number: 2011-0312 (AMENDED)

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

Resolution: Consent Resolution Date: 03/12/2012 Sanctions Ordered: Monetary/Fine $50,000.00 Other Sanctions Ordered: FOLLOW THE COMPLIANCE POLICIES AND PROCEDURES THAT THE FIRM DESIGNED TO PREVENT ANY FURTHER UNREGISTERED INVESTMENT ADVISOR REPRESENTATIVE ACTIVITIES AND LATE AMENDMENT FILINGS AND COMPLY FULLY WITH THE MARYLAND SECURITIES ACT AND THE RULES AND REGULATIONS PROMULGATED THEREUNDER. Sanction Details: THE FIRM WAS ORDERED TO PAY A FINE OF $50,000 TO THE MARYLAND SECURITIES DIVISION, LESS THE $5,000 FINE THE FIRM PAID TO THE DIVISION IN AUGUST 2011 PURSUANT TO THE ORIGINAL CONSENT ORDER ISSUED IN THIS MATTER. Firm Statement IN AMENDED CONSENT ORDER, DOCKET NO. 2011-0312, IN THE MATTER OF WELLS FARGO ADVISORS, LLC, THE MARYLAND DIVISION OF SECURITIES ALLEGED THAT WELLS FARGO ADVISORS, LLC EMPLOYED EIGHT INVESTMENT ADVISER REPRESENTATIVES WHO PROVIDED INVESTMENT ADVISORY SERVICES TO CLIENTS PRIOR TO BEING REGISTERED WITH THE SECURITIES DIVISION AS INVESTMENT ADVISER REPRESENTATIVES PURSUANT TO SECTION 11-402 OF THE MARYLAND SECURITIES ACT. THE DIVISION ALSO ALLEGED THAT THE FIRM FAILED TO TIMELY AMEND THE FORMS U4 OF TWO OF ITS AGENTS TO REFLECT THE CHANGE IN THEIR EMPLOYMENT ADDRESS PURSUANT TO SECTION 11- 411(D) OF THE MARYLAND SECURITIES ACT AND REGULATION 02.02.02.07 OF THE CODE OF MARYLAND REGULATIONS. THE FIRM WAS ORDERED TO PAY A FINE OF $50,000 TO THE MARYLAND SECURITIES DIVISION, LESS THE $5,000 FINE THE FIRM PAID TO THE DIVISION IN AUGUST 2011 PURSUANT TO THE ORIGINAL CONSENT ORDER ISSUED IN THIS MATTER. THE FIRM WAS ALSO ORDERED TO FOLLOW THE COMPLIANCE POLICIES AND PROCEDURES PROVIDED TO THE DIVISION IN CONNECTION WITH THE MATTER, AND COMPLY FULLY WITH THE MARYLAND SECURITIES ACT AND RULES AND REGULATIONS PROMULGATED THEREUNDER. i Disclosure 46 of 167

Reporting Source: Regulator Current Status: Final Allegations: N/A Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION Date Initiated: 06/21/2011 Docket/Case Number: 0154-SR-5/11 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief ADMINISTRATIVE FINE Sought:

Resolution: Stipulation and Consent Resolution Date: 06/21/2011 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: Monetary/Fine $65,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: $65,000 ADMINISTRATIVE FINE WAS LEVIED AGAINST WELLS FARGO ADVISORS LLC. THE FINE WAS PAID IN FULL ON 6/21/2011. Regulator Statement ON 6/21/2011 THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF WELLS FARGO ADVISORS, LLC. WELLS FARGO ADVISORS LLC NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENT TO THE ENTRY OF FINDINGS BY THE OFFICE. THE OFFICE FOUND THAT BEGINNING IN OCTOBER 2004, WELLS FARGO ADVISORS LLC, ACTING THROUGH 13 INDIVIDUALS, ENGAGED IN INVESTMENT ADVISORY BUSINESS FROM OFFICES WITHIN THIS STATE WITHOUT THE 13 INDIVIDUALS BEING LAWFULLY REGISTRATION IN THE STATE OF FLORIDA IN VIOLATION OF SECTION 517.12(4), F. S. WELLS FARGO ADVISORS LLC AGREED TO CEASE AND DESIST FROM ALL ©2021 FINRA. All rights reserved. Report aboutPRESENT WELLS FARGOAND FUTURE CLEARING VIOLATIONS SERVICES, LLC OF CHAPTER 517, F.S. AND THE 141 ADMINISTRATIVE RULES THEREUNDER; AND TO PAY AN ADMINISTRATIVE FINE IN THE AMOUNT OF $65,000. ON 6/21/2011 THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF WELLS FARGO ADVISORS, LLC. WELLS FARGO ADVISORS LLC NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENT TO THE ENTRY OF FINDINGS BY THE OFFICE. THE OFFICE FOUND THAT BEGINNING IN OCTOBER 2004, WELLS FARGO www.finra.org/brokercheck ADVISORS LLC, ACTING THROUGH 13 INDIVIDUALS, ENGAGED IN User Guidance INVESTMENT ADVISORY BUSINESS FROM OFFICES WITHIN THIS STATE WITHOUT THE 13 INDIVIDUALS BEING LAWFULLY REGISTRATION IN THE STATE OF FLORIDA IN VIOLATION OF SECTION 517.12(4), F. S. WELLS FARGO ADVISORS LLC AGREED TO CEASE AND DESIST FROM ALL PRESENT AND FUTURE VIOLATIONS OF CHAPTER 517, F.S. AND THE ADMINISTRATIVE RULES THEREUNDER; AND TO PAY AN ADMINISTRATIVE FINE IN THE AMOUNT OF $65,000. i Reporting Source: Firm Current Status: Final Allegations: THE OFFICE FOUND THAT BEGINNING IN OCTOBER 2004, WELLS FARGO ADVISORS LLC, ACTING THROUGH 13 INDIVIDUALS, ENGAGED IN INVESTMENT ADVISORY BUSINESS FROM OFFICES WITHIN THIS STATE WITHOUT THE 13 INDIVIDUALS BEING LAWFULLY REGISTERED IN THE STATE OF FLORIDA AS INVESTMENT ADVISOR REPRESENTATIVES FOR THE FIRM IN VIOLATION OF SECTION 517.12(4), F. S. Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION Date Initiated: 06/21/2011 Docket/Case Number: 0154-SR-5/11

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

Resolution: Stipulation and Consent Resolution Date: 06/21/2011 Sanctions Ordered: Monetary/Fine $65,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: $65,000 ADMINISTRATIVE FINE WAS LEVIED AGAINST WELLS FARGO ADVISORS LLC. THE FINE WAS PAID IN FULL ON 6/21/2011. Firm Statement ON 6/21/2011 THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF WELLS FARGO ADVISORS, LLC. WELLS FARGO ADVISORS LLC NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THE ENTRY OF FINDINGS BY THE OFFICE. THE OFFICE FOUND THAT BEGINNING IN OCTOBER 2004, WELLS FARGO ©2021 FINRA. All rights reserved. Report aboutADVISORS WELLS FARGO LLC, ACTINGCLEARING THROUGH SERVICES, LLC 13 INDIVIDUALS, ENGAGED IN 142 INVESTMENT ADVISORY BUSINESS FROM OFFICES WITHIN THIS STATE WITHOUT THE 13 INDIVIDUALS BEING LAWFULLY REGISTERED IN THE STATE OF FLORIDA IN VIOLATION OF SECTION 517. 12(4), F. S. WELLS FARGO ADVISORS LLC AGREED TO CEASE AND DESIST FROM ALL PRESENT AND FUTURE VIOLATIONS OF CHAPTER 517, F.S. AND THE ADMINISTRATIVE RULES THEREUNDER; AND TO PAY AN ADMINISTRATIVE FINE IN THE AMOUNT OF $65,000. ON 6/21/2011 THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE www.finra.org/brokercheck MATTER OF WELLS FARGO ADVISORS, LLC. User Guidance WELLS FARGO ADVISORS LLC NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THE ENTRY OF FINDINGS BY THE OFFICE. THE OFFICE FOUND THAT BEGINNING IN OCTOBER 2004, WELLS FARGO ADVISORS LLC, ACTING THROUGH 13 INDIVIDUALS, ENGAGED IN INVESTMENT ADVISORY BUSINESS FROM OFFICES WITHIN THIS STATE WITHOUT THE 13 INDIVIDUALS BEING LAWFULLY REGISTERED IN THE STATE OF FLORIDA IN VIOLATION OF SECTION 517. 12(4), F. S. WELLS FARGO ADVISORS LLC AGREED TO CEASE AND DESIST FROM ALL PRESENT AND FUTURE VIOLATIONS OF CHAPTER 517, F.S. AND THE ADMINISTRATIVE RULES THEREUNDER; AND TO PAY AN ADMINISTRATIVE FINE IN THE AMOUNT OF $65,000. i Disclosure 47 of 167 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULES G-14(B)(II), G-15(A)(I) - WELLS FARGO ADVISORS, LLC FAILED TO REPORT THE CORRECT YIELD TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THE CORRECT LOWEST EFFECTED YIELD IN MOST OF THESE TRANSACTIONS IN MUNICIPAL SECURITIES. Initiated By: FINRA Date Initiated: 06/17/2011 Docket/Case Number: 2009020728001

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: 06/17/2011 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 $20,000.00 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 143 www.finra.org/brokercheck User Guidance

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 FOR VIOLATIONS OF MSRB RULES G-14(B)(II) AND G-15(A)(I). i Reporting Source: Firm Current Status: Final Allegations: MSRB RULES G-14(B)(II), G-15(A)(I) - WELLS FARGO ADVISORS, LLC FAILED TO REPORT THE CORRECT YIELD TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THE CORRECT LOWEST EFFECTED YIELD IN MOST OF THESE TRANSACTIONS IN MUNICIPAL SECURITIES. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) Date Initiated: 06/17/2011 Docket/Case Number: 2009020728001

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: 06/17/2011 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 FOR VIOLATIONS OF MSRB RULES G-14(B)(II) AND G-15(A)(I).

i Disclosure 48 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF NEW HAMPSHIRE-DEPARTMENT OF STATE-BUREAU OF SECURITIES REGULATIONS HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF NEW HAMPSHIRE DEPARTMENT OF STATE BUREAU OF SECURITIES REGULATIONS Date Initiated: 05/02/2011 Docket/Case Number: ADMINISTRATIVE CONSENT ORDER: INV- 2009000015

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

Resolution: Consent Resolution Date: 05/02/2011 Sanctions Ordered: Monetary/Fine $289,021.88 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: THE FINE WAS SENT TO THE STATE OF NEW HAMPSHIRE-DEPARTMENT OF STATE-BUREAU OF SECURITIES REGULATIONS ON MAY 9, 2011. i Disclosure 49 of 167 Reporting Source: Regulator Current Status: Final Allegations: FINRA BY-LAWS ARTICLE V, SECTIONS 2(C) AND 3(B), FINRA RULE 2010, NASD RULE 2110: THE FIRM WAS REQUIRED TO PROVIDE EACH OF ITS ©2021 FINRA. All rights reserved. Report aboutCUSTOMERS WELLS FARGO WHO CLEARING PURCHASED SERVICES, A LLCMUTUAL FUND A PHYSICAL COPY OF A 145 PROSPECTUS FOR THAT FUND NO LATER THAN THREE BUSINESS DAYS AFTER THE TRANSACTION, BUT IT FAILED TO DELIVER PROSPECTUS TO ITS CUSTOMERS WITHIN THREE DAYS OF THEIR PURCHASES IN 934,074 MUTUAL FUND TRANSACTIONS ACTING IN CONTRAVENTION OF SECTION 5(B)(2) OF THE SECURITIES ACT OF 1933 AND THEREBY VIOLATED FINRA RULE 2010. SECTION 5(B)(2) OF THE SECURITIES ACT PROHIBITS THE DELIVERY OF CERTAIN SECURITIES UNLESS SUCH DELIVERY IS ACCOMPANIED BY OR PRECEDED BY A PHYSICAL COPY OF A PROSPECTUS THAT MEETS THE REQUIREMENTS OF THE SECURITIES ACT. THE FEDERAL SECURITIES LAWS REQUIRE THE DELIVERY OF A PROSPECTUS TO INVESTORS BECAUSE IT PROVIDES THEM WITH IMPORTANT DISCLOSURE INFORMATION REGARDING THE PRODUCT BEING PURCHASED. THE FIRM SATISFIED ITS PROSPECTUS DELIVERY OBLIGATION BY CONTRACTING WITH A THIRD PARTY SERVICE PROVIDER FOR THE DELIVERY OF PROSPECTUSES. THE FIRM'S PERSONNEL HAD DAILY CONTACT WITH THE SERVICE PROVIDER'S PERSONNEL TO RESOLVE EXCEPTIONS ON THE REPORTS, ALONG WITH OTHER ISSUES RELATING TO DELIVERY OF PROSPECTUSES. THE FIRM DID NOT TIMELY DELIVER, OR DID NOT ENSURE THAT THE SERVICE PROVIDER TIMELY DELIVERED, PROSPECTUSES TO CERTAIN CUSTOMERS WHO PURCHASED MUTUAL FUNDS. IN 934,074 SEPARATE INSTANCES THE FIRM'S CUSTOMERS WHO PURCHASED MUTUAL FUNDS DID NOT RECEIVE A PROSPECTUS WITHIN THREE BUSINESS DAYS OF THE TRANSACTION. THOSE CUSTOMERS RECEIVED THE PROSPECTUSES BETWEEN ONE AND 153 DAYS LATE. OUT OF THE 934,074 SEPARATE INSTANCES IN WHICH DELIVERY WAS UNTIMELY, 47% WERE DELIVERED WITHIN THREE DAYS OF SETTLEMENT DATE, 69% WERE DELIVERED WITHIN SEVEN DAYS OF SETTLEMENT, AND 94% WERE DELIVERED WITHIN 14 DAYS OF SETTLEMENT DATE. THE PRIMARY CAUSE OF THE LATE DELIVERIES WAS THE FAILURE OF CERTAIN MUTUAL FUND COMPANIES TO MAINTAIN ADEQUATE SUPPLIES OF PAPER COPIES OF PROSPECTUSES. AS A RESULT, FOR MANY PURCHASES FROM THESE FUND COMPANIES, NEITHER THE SERVICE PROVIDER NOR THE FIRM COULD OBTAIN A PROSPECTUS TO TIMELY PROVIDE TO THE CUSTOMER. THE FIRM DID NOT TAKE STEPS TO CHANGE THE PRACTICES OF THOSE FUND COMPANIES THAT DID NOT KEEP ADEQUATE STOCKS OF PROSPECTUSES. THE FIRM ALSO DID NOT TAKE REMEDIAL STEPS AVAILABLE TO IT TO ENSURE THAT ITS CUSTOMERS WERE RECEIVING PROSPECTUSES IN A TIMELY FASHION. FOR INSTANCE, THE SERVICE PROVIDER OFFERED A "PRINT ON DEMAND" ("POD") SERVICE AND POD SERVICE ALLOWED THE SERVICE PROVIDER TO OBTAIN ELECTRONIC COPIES OF MUTUAL FUND PROSPECTUSES FROM THOSE MUTUAL FUND COMPANIES THAT OFFERED THEM, AND TO THEN PRINT COPIES OF THE PROSPECTUSES AND SEND THEM TO THE FIRM'S CUSTOMERS. WITH POD, EVEN IF THE MUTUAL FUND COMPANY DID NOT HAVE ADEQUATE SUPPLIES OF PAPER COPIES OF PROSPECTUSES IN STOCK, THE SERVICE PROVIDER COULD PRINT THE ELECTRONICALLY-AVAILABLE PROSPECTUS, AND SEND IT TO THE CUSTOMER. THE FIRM DID NOT USE THIS SERVICE EXTENSIVELY DURING THE RELEVANT PERIOD. THE FIRM HAD NOTICE THAT ITS CUSTOMERS WERE NOT RECEIVING PROSPECTUSES ON A TIMELY BASIS BOTH BEFORE AND DURING THE RELEVANT PERIOD. THE REPORTS PROVIDED BY THE SERVICE PROVIDER IDENTIFIED THE EXTENT OF THE UN- TIMELINESS OF EACH PROSPECTUS THAT HAD NOT YET BEEN DELIVERED. IN ALMOST ALL INSTANCES IN WHICH A FIRM CUSTOMER RECEIVED A PROSPECTUS LATE, THE DAILY REPORTS PROVIDED BY THE SERVICE PROVIDER WOULD HAVE IDENTIFIED THE TRANSACTION ON A DAILY BASIS UNTIL THE PROSPECTUS WAS DELIVERED TO THE CUSTOMER. FURTHER, THE FIRM OPERATIONS PERSONNEL WHO REVIEWED THESE DAILY REPORTS AND UPDATED INFORMATION FOR THE SERVICE PROVIDER WOULD HAVE HAD REGULAR CONTACT WITH THE SERVICE PROVIDER TO RESOLVE ISSUES RELATING TO PROSPECTUSES THAT HAD NOT YET BEEN DELIVERED TO THE FIRM'S CUSTOMERS. (CONTINUE IN THE COMMENT SECTION) www.finra.org/brokercheck User Guidance

Allegations: FINRA BY-LAWS ARTICLE V, SECTIONS 2(C) AND 3(B), FINRA RULE 2010, NASD RULE 2110: THE FIRM WAS REQUIRED TO PROVIDE EACH OF ITS CUSTOMERS WHO PURCHASED A MUTUAL FUND A PHYSICAL COPY OF A PROSPECTUS FOR THAT FUND NO LATER THAN THREE BUSINESS DAYS AFTER THE TRANSACTION, BUT IT FAILED TO DELIVER PROSPECTUS TO ITS CUSTOMERS WITHIN THREE DAYS OF THEIR PURCHASES IN 934,074 MUTUAL FUND TRANSACTIONS ACTING IN CONTRAVENTION OF SECTION 5(B)(2) OF THE SECURITIES ACT OF 1933 AND THEREBY VIOLATED FINRA RULE 2010. SECTION 5(B)(2) OF THE SECURITIES ACT PROHIBITS THE DELIVERY OF CERTAIN SECURITIES UNLESS SUCH DELIVERY IS ACCOMPANIED BY OR PRECEDED BY A PHYSICAL COPY OF A PROSPECTUS THAT MEETS THE REQUIREMENTS OF THE SECURITIES ACT. THE FEDERAL SECURITIES LAWS REQUIRE THE DELIVERY OF A PROSPECTUS TO INVESTORS BECAUSE IT PROVIDES THEM WITH IMPORTANT DISCLOSURE INFORMATION REGARDING THE PRODUCT BEING PURCHASED. THE FIRM SATISFIED ITS PROSPECTUS DELIVERY OBLIGATION BY CONTRACTING WITH A THIRD PARTY SERVICE PROVIDER FOR THE DELIVERY OF PROSPECTUSES. THE FIRM'S PERSONNEL HAD DAILY CONTACT WITH THE SERVICE PROVIDER'S PERSONNEL TO RESOLVE EXCEPTIONS ON THE REPORTS, ALONG WITH OTHER ISSUES RELATING TO DELIVERY OF PROSPECTUSES. THE FIRM DID NOT TIMELY DELIVER, OR DID NOT ENSURE THAT THE SERVICE PROVIDER TIMELY DELIVERED, PROSPECTUSES TO CERTAIN CUSTOMERS WHO PURCHASED MUTUAL FUNDS. IN 934,074 SEPARATE INSTANCES THE FIRM'S CUSTOMERS WHO PURCHASED MUTUAL FUNDS DID NOT RECEIVE A PROSPECTUS WITHIN THREE BUSINESS DAYS OF THE TRANSACTION. THOSE CUSTOMERS RECEIVED THE PROSPECTUSES BETWEEN ONE AND 153 DAYS LATE. OUT OF THE 934,074 SEPARATE INSTANCES IN WHICH DELIVERY WAS UNTIMELY, 47% WERE DELIVERED WITHIN THREE DAYS OF SETTLEMENT DATE, 69% WERE DELIVERED WITHIN SEVEN DAYS OF SETTLEMENT, AND 94% WERE DELIVERED WITHIN 14 DAYS OF SETTLEMENT DATE. THE PRIMARY CAUSE OF THE LATE DELIVERIES WAS THE FAILURE OF CERTAIN MUTUAL FUND COMPANIES TO MAINTAIN ADEQUATE SUPPLIES OF PAPER COPIES OF PROSPECTUSES. AS A RESULT, FOR MANY PURCHASES FROM THESE FUND COMPANIES, NEITHER THE SERVICE PROVIDER NOR THE FIRM COULD OBTAIN A PROSPECTUS TO TIMELY PROVIDE TO THE CUSTOMER. THE FIRM DID NOT TAKE STEPS TO CHANGE THE PRACTICES OF THOSE FUND COMPANIES THAT DID NOT KEEP ADEQUATE STOCKS OF PROSPECTUSES. THE FIRM ALSO DID NOT TAKE REMEDIAL STEPS AVAILABLE TO IT TO ENSURE THAT ITS CUSTOMERS WERE RECEIVING PROSPECTUSES IN A TIMELY FASHION. FOR INSTANCE, THE SERVICE PROVIDER OFFERED A "PRINT ON DEMAND" ("POD") SERVICE AND POD SERVICE ALLOWED THE SERVICE PROVIDER TO OBTAIN ELECTRONIC COPIES OF MUTUAL FUND PROSPECTUSES FROM THOSE MUTUAL FUND COMPANIES THAT OFFERED THEM, AND TO THEN PRINT COPIES OF THE PROSPECTUSES AND SEND THEM TO THE FIRM'S CUSTOMERS. WITH POD, EVEN IF THE MUTUAL FUND ©2021 FINRA. All rights reserved. Report aboutCOMPANY WELLS FARGO DID NOT CLEARING HAVE SERVICES, ADEQUATE LLC SUPPLIES OF PAPER COPIES OF 146 PROSPECTUSES IN STOCK, THE SERVICE PROVIDER COULD PRINT THE ELECTRONICALLY-AVAILABLE PROSPECTUS, AND SEND IT TO THE CUSTOMER. THE FIRM DID NOT USE THIS SERVICE EXTENSIVELY DURING THE RELEVANT PERIOD. THE FIRM HAD NOTICE THAT ITS CUSTOMERS WERE NOT RECEIVING PROSPECTUSES ON A TIMELY BASIS BOTH BEFORE AND DURING THE RELEVANT PERIOD. THE REPORTS PROVIDED BY THE SERVICE PROVIDER IDENTIFIED THE EXTENT OF THE UN- TIMELINESS OF EACH PROSPECTUS THAT HAD NOT YET BEEN DELIVERED. IN ALMOST ALL INSTANCES IN WHICH A FIRM CUSTOMER RECEIVED A PROSPECTUS LATE, THE DAILY REPORTS PROVIDED BY THE SERVICE PROVIDER WOULD HAVE IDENTIFIED THE TRANSACTION ON A DAILY BASIS UNTIL THE PROSPECTUS WAS DELIVERED TO THE CUSTOMER. FURTHER, THE FIRM OPERATIONS PERSONNEL WHO REVIEWED THESE DAILY REPORTS AND UPDATED INFORMATION FOR THE SERVICE PROVIDER WOULD HAVE HAD REGULAR CONTACT WITH THE SERVICE PROVIDER TO RESOLVE ISSUES RELATING TO PROSPECTUSES THAT HAD NOT YET BEEN DELIVERED TO THE FIRM'S CUSTOMERS. (CONTINUE IN THE COMMENT SECTION) FINRA BY-LAWS ARTICLE V, SECTIONS 2(C) AND 3(B), FINRA RULE 2010, NASD RULE 2110: THE FIRM WAS REQUIRED TO PROVIDE EACH OF ITS CUSTOMERS WHO PURCHASED A MUTUAL FUND A PHYSICAL COPY OF A PROSPECTUS FOR THAT FUND NO LATER THAN THREE BUSINESS DAYS AFTER THE TRANSACTION, BUT IT FAILED TO DELIVER PROSPECTUS TO ITS CUSTOMERS WITHIN THREE DAYS OF THEIR PURCHASES IN 934,074 MUTUAL FUND TRANSACTIONS ACTING IN CONTRAVENTION OF SECTION 5(B)(2) OF THE SECURITIES ACT OF 1933 AND THEREBY VIOLATED FINRA RULE 2010. SECTION 5(B)(2) OF THE SECURITIES ACT PROHIBITS THE DELIVERY OF CERTAIN SECURITIES UNLESS SUCH DELIVERY IS ACCOMPANIED BY OR PRECEDED BY A PHYSICAL COPY OF A PROSPECTUS THAT MEETS THE REQUIREMENTS OF THE SECURITIES ACT. THE FEDERAL SECURITIES LAWS REQUIRE THE DELIVERY OF A PROSPECTUS TO INVESTORS BECAUSE IT PROVIDES THEM WITH IMPORTANT DISCLOSURE INFORMATION REGARDING THE PRODUCT BEING PURCHASED. THE FIRM SATISFIED ITS PROSPECTUS DELIVERY OBLIGATION BY CONTRACTING WITH A THIRD PARTY SERVICE PROVIDER FOR THE DELIVERY OF PROSPECTUSES. THE FIRM'S PERSONNEL HAD DAILY CONTACT WITH THE SERVICE PROVIDER'S PERSONNEL TO RESOLVE EXCEPTIONS ON THE REPORTS, ALONG WITH OTHER ISSUES RELATING TO DELIVERY OF PROSPECTUSES. THE FIRM DID NOT TIMELY DELIVER, OR DID NOT ENSURE THAT THE SERVICE PROVIDER TIMELY DELIVERED, PROSPECTUSES TO CERTAIN CUSTOMERS WHO PURCHASED MUTUAL FUNDS. IN 934,074 SEPARATE INSTANCES THE FIRM'S CUSTOMERS WHO PURCHASED MUTUAL FUNDS DID NOT RECEIVE A PROSPECTUS WITHIN THREE BUSINESS DAYS OF THE TRANSACTION. THOSE CUSTOMERS RECEIVED THE PROSPECTUSES BETWEEN ONE AND 153 DAYS LATE. OUT OF THE 934,074 SEPARATE INSTANCES IN WHICH DELIVERY WAS UNTIMELY, 47% WERE DELIVERED WITHIN THREE DAYS OF SETTLEMENT DATE, 69% WERE DELIVERED WITHIN SEVEN DAYS OF SETTLEMENT, AND 94% WERE DELIVERED WITHIN 14 DAYS OF SETTLEMENT DATE. THE PRIMARY CAUSE OF THE LATE DELIVERIES WAS THE FAILURE OF CERTAIN MUTUAL FUND COMPANIES TO MAINTAIN ADEQUATE SUPPLIES OF PAPER COPIES OF PROSPECTUSES. AS A RESULT, FOR MANY PURCHASES FROM THESE FUND COMPANIES, NEITHER THE SERVICE PROVIDER NOR THE FIRM COULD OBTAIN A PROSPECTUS TO TIMELY PROVIDE TO THE CUSTOMER. THE FIRM DID NOT TAKE STEPS TO CHANGE THE PRACTICES OF THOSE FUND COMPANIES THAT DID NOT KEEP ADEQUATE STOCKS OF PROSPECTUSES. THE FIRM ALSO DID NOT TAKE REMEDIAL STEPS AVAILABLE TO IT TO ENSURE THAT ITS CUSTOMERS WERE RECEIVING PROSPECTUSES IN A TIMELY FASHION. FOR INSTANCE, THE SERVICE PROVIDER OFFERED A www.finra.org/brokercheck "PRINT ON DEMAND" ("POD") SERVICE AND POD SERVICE ALLOWED THE User Guidance SERVICE PROVIDER TO OBTAIN ELECTRONIC COPIES OF MUTUAL FUND PROSPECTUSES FROM THOSE MUTUAL FUND COMPANIES THAT OFFERED THEM, AND TO THEN PRINT COPIES OF THE PROSPECTUSES AND SEND THEM TO THE FIRM'S CUSTOMERS. WITH POD, EVEN IF THE MUTUAL FUND COMPANY DID NOT HAVE ADEQUATE SUPPLIES OF PAPER COPIES OF PROSPECTUSES IN STOCK, THE SERVICE PROVIDER COULD PRINT THE ELECTRONICALLY-AVAILABLE PROSPECTUS, AND SEND IT TO THE CUSTOMER. THE FIRM DID NOT USE THIS SERVICE EXTENSIVELY DURING THE RELEVANT PERIOD. THE FIRM HAD NOTICE THAT ITS CUSTOMERS WERE NOT RECEIVING PROSPECTUSES ON A TIMELY BASIS BOTH BEFORE AND DURING THE RELEVANT PERIOD. THE REPORTS PROVIDED BY THE SERVICE PROVIDER IDENTIFIED THE EXTENT OF THE UN- TIMELINESS OF EACH PROSPECTUS THAT HAD NOT YET BEEN DELIVERED. IN ALMOST ALL INSTANCES IN WHICH A FIRM CUSTOMER RECEIVED A PROSPECTUS LATE, THE DAILY REPORTS PROVIDED BY THE SERVICE PROVIDER WOULD HAVE IDENTIFIED THE TRANSACTION ON A DAILY BASIS UNTIL THE PROSPECTUS WAS DELIVERED TO THE CUSTOMER. FURTHER, THE FIRM OPERATIONS PERSONNEL WHO REVIEWED THESE DAILY REPORTS AND UPDATED INFORMATION FOR THE SERVICE PROVIDER WOULD HAVE HAD REGULAR CONTACT WITH THE SERVICE PROVIDER TO RESOLVE ISSUES RELATING TO PROSPECTUSES THAT HAD NOT YET BEEN DELIVERED TO THE FIRM'S CUSTOMERS. (CONTINUE IN THE COMMENT SECTION) Initiated By: FINRA Date Initiated: 05/04/2011 Docket/Case Number: 2010022921801

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/04/2011 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 $1,000,000.00 Other Sanctions Ordered: UNDERTAKINGS ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 147 www.finra.org/brokercheck User Guidance

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 AND FINED $1,000,000. THE FIRM FURTHER UNDERTAKES TO COMPLETE THE FOLLOWING WITHIN 120 DAYS OF NOTICES OF ACCEPTANCE OF THIS AWC: (I) ADOPT AND IMPLEMENT SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND FINRA RULES APPLICABLE TO FILING, AND TIMELY FILING, OF FORMS U4 AND U5, AND (II) PROVIDE A WRITTEN CERTIFICATION BY A DULY AUTHORIZED SENIOR OFFICER OF THE FIRM THAT THE FIRM HAS ADOPTED AND IMPLEMENTED SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND FINRA RULES APPLICABLE TO FILING, AND TIMELY FILING, OF FORMS U4 AND U5. Regulator Statement ALSO, THE SERVICE PROVIDER MET WITH THE FIRM OFFICIALS ON A QUARTERLY BASIS THROUGHOUT THE RELEVANT PERIOD TO PROVIDE STATISTICAL DATA REGARDING AMONG OTHER THINGS, MUTUAL FUND PROSPECTUS DELIVERY. DURING THESE MEETING, THE FIRM RECEIVED STATISTICAL DATA INDICATING THAT THE FIRM'S CUSTOMERS WERE NOT TIMELY RECEIVING PROSPECTUSES IN 4% TO 9% OF THE MUTUAL FUND TRANSACTIONS CONDUCTED BY THE FIRM DURING THIS TIME. THE FIRM ALSO ITSELF CREATED AND ANALYZED DATA INDICATING THAT ITS CUSTOMERS WERE NOT RECEIVING PROSPECTUSES ON A TIMELY BASIS. BOTH PRIOR TO AND THROUGHOUT THE RELEVANT PERIOD THE FIRM'S MANAGEMENT SUPERVISORY GROUP RESPONSIBLE FOR PROSPECTUS DELIVERY CONDUCTED A MONTHLY REVIEW IDENTIFYING STATISTICAL INFORMATION REGARDING PROSPECTUS DELIVERY FOR, AMONG OTHER THINGS, MUTUAL FUNDS. THIS DATA FURTHER SHOWED THAT THE FIRM'S CUSTOMERS WERE NOT TIMELY RECEIVING MUTUAL FUND PROSPECTUSES. BECAUSE OF THE FIRM'S FAILURE TO TIMELY DELIVER PROSPECTUSES TO ITS CUSTOMERS WHO PURCHASED MUTUAL FUNDS, THESE CUSTOMERS WERE NOT PROVIDED WITH IMPORTANT DISCLOSURE INFORMATION AMOUNT THESE PRODUCTS. THE FIRM FILED 147 LATE AMENDMENTS TO FORMS U4, RELATING TO CUSTOMER COMPLAINTS, ARBITRATIONS, CIVIL LITIGATION, REGULATORY MATTERS AND BANKRUPTCIES. THIS REPRESENTED 8.1% OF THE 1,808 FORM U4 AMENDMENTS THE FIRM WAS REQUIRED TO FILE. THE FIRM FILED 40 LATE AMENDMENTS TO FORMS U5, RELATING TO CUSTOMER COMPLAINTS, ARBITRATIONS, AND CIVIL LITIGATION. THIS REPRESENTED 7.6% OF THE 522 FORM U5 AMENDMENTS THE FIRM WAS REQUIRED TO FILE DURING THIS PERIOD. i Reporting Source: Firm

Current Status: Final Allegations: FINRA ALLEGED THAT WFA FAILED TO DELIVER PROSPECTUSES TO ITS CUSTOMERS WITHIN THREE BUSINESS DAYS OF THEIR PURCHASES IN 934,047 MUTUAL FUND TRANSACTIONS BETWEEN JANUARY 1, 2009 AND DECEMBER 31, 2009 (THE "RELEVANT PERIOD").

FINRA ALLEGED THAT WFA FAILED TO TIMELY FILE CERTAIN AMENDMENTS TO UNIFORM APPLICATIONS FOR SECURITIES INDUSTRY OR TRANSFER ("FORMS U4") AND UNIFORM TERMINATION NOTICES FOR SECURITIES INDUSTRY REGISTRATION ("FORMS U5") FROM JULY 1, 2008 TO JUNE 30, 2009. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) Date Initiated: 05/04/2011 Docket/Case Number: 2010022921801

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: UNDERTAKINGS

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/04/2011 Sanctions Ordered: Censure Monetary/Fine $1,000,000.00 Other Sanctions Ordered: WFA FURTHER UNDERTAKES WITHIN 120 DAYS TO: (1) ADOPT AND IMPLEMENT SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHEIVE TIMELY FILING OF FORMS U4 AND FORMS U5. (2) PROVIDE WRITTEN CERTIFICATION BY A DULY AUTHORIZED SENIOR OFFICER OF WFA THAT THE FIRM HAS ADOPTED AND IMPLEMENTED SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHEIVE TIMELY FILING OF FORMS U4 AND FORMS U5. Sanction Details: $1,000,000 FINE TO WFA Firm Statement AWC ACCEPTED ON MAY 4, 2011 i Disclosure 50 of 167 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 149 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: NASD RULES 2110, 2320: IN EIGHT 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. Initiated By: FINRA Date Initiated: 05/02/2011 Docket/Case Number: 2006005324201

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/02/2011 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 $23,000.00 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 $23,000 AND ORDERED TO PAY RESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $15,708.25, PLUS INTEREST AT THE RATE SET FORTH IN SECTION 6621(A) OF THE INTERNAL REVENUE CODE, FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THE DATE THIS AWC IS ACCEPTED BY THE NATIONAL ADJUDICATORY COUNCIL (NAC). A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT ©2021 FINRA. All rights reserved. Report aboutRESTITUTION WELLS FARGO TO CLEARING FINRA NO SERVICES, LATER LLC THAN 120 DAYS AFTER ACCEPTANCE 150 OF THIS AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, OR SUCH ADDITIONAL PERIOD AGREED TO BY THE STAFF, 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. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED, FINED $23,000 AND ORDERED TO PAY RESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $15,708.25, PLUS INTEREST AT THE RATE SET FORTH IN SECTION 6621(A) OF THE INTERNAL www.finra.org/brokercheck REVENUE CODE, FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THE User Guidance DATE THIS AWC IS ACCEPTED BY THE NATIONAL ADJUDICATORY COUNCIL (NAC). A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, OR SUCH ADDITIONAL PERIOD AGREED TO BY THE STAFF, 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. i Reporting Source: Firm Current Status: Final Allegations: NASD RULES 2110, 2320: IN EIGHT 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. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) Date Initiated: 05/02/2011 Docket/Case Number: 2006005324201

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/02/2011 Sanctions Ordered: Censure Monetary/Fine $23,000.00 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 $23,000.00 AND ORDERED TO PAY RESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $15,708.25, PLUS ©2021 FINRA. All rights reserved. Report aboutINTEREST WELLS FARGO AT THE CLEARING RATE SET SERVICES, FORTH LLC IN SECTION 6621(A) OF THE INTERNAL 151 REVENUE CODE, FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THE DATE THIS AWC IS ACCEPTED BY THE NATIONAL ADJUDICATORY COUNCIL (NAC). A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, OR SUCH ADDITIONAL PERIOD AGREED TO BY THE STAFF, 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. 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 IT IS CENSURED, FINED $23,000.00 AND ORDERED TO PAY RESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $15,708.25, PLUS INTEREST AT THE RATE SET FORTH IN SECTION 6621(A) OF THE INTERNAL REVENUE CODE, FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THE DATE THIS AWC IS ACCEPTED BY THE NATIONAL ADJUDICATORY COUNCIL (NAC). A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, OR SUCH ADDITIONAL PERIOD AGREED TO BY THE STAFF, 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. Firm Statement THE FIRM SENT THE $23,000.00 FINE TO FINRA ON 05/13/2011. i Disclosure 51 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 2440, INTERPRETATIVE MATERIAL-2440, MSRB RULES G-17, G-30(A): IN NINE TRANSACTIONS, THE FIRM SOLD (OR BOUGHT) CORPORATE BONDS TO (OR FROM) CUSTOMERS AND FAILED TO SELL (OR BUY) SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WAS ENTITLED TO A PROFIT. IN TEN TRANSACTIONS, THE FIRM SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY 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 TRANSACTIONS 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: 04/28/2011 Docket/Case Number: 2007008011601 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 152 www.finra.org/brokercheck User Guidance

Docket/Case Number: 2007008011601

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/28/2011 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 $58,000.00 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 $58,000 AND ORDERED TO PAY RESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $38,462.01, PLUS INTEREST, AT THE RATE SET FORTH IN SECTION 6221(A) OF THE INTERNAL REVENUE CODE, FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THE DATE THIS AWC IS ACCEPTED BY THE NATIONAL ADJUDICATORY COUNCIL (NAC). 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. IF FOR ANY REASON, THE FIRM CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA, 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 KNOWN TO HAVE LAST RESIDED. i Reporting Source: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 153 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: NASD RULES 2110, 2440, INTERPRETATIVE MATERIAL-2440, MSRB RULES G-17, G-30(A): IN NINE TRANSACTIONS, THE FIRM SOLD (OR BOUGHT) CORPORATE BONDS TO (OR FROM)CUSTOMERS AND FAILED TO SELL (OR BUY) SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WAS ENTITLED TO A PROFIT. IN TEN TRANSACTIONS, THE FIRM SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY 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 TRANSACTIONS 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: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) Date Initiated: 04/28/2011 Docket/Case Number: 2007008011601

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/28/2011 Sanctions Ordered: Censure Monetary/Fine $58,000.00 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; ©2021 FINRA. All rights reserved. Report aboutTHEREFORE WELLS FARGO IT IS CLEARING CENSURED, SERVICES, FINED LLC $58,000 AND ORDERED TO PAY 154 RESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $38,462.01, PLUS INTEREST, AT THE RATE SET FORTH IN SECTION 6221(A) OF THE INTERNAL REVENUE CODE, FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THE DATE THIS AWC IS ACCEPTED BY THE NATIONAL ADJUDICATORY COUNCIL (NAC). 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. IF FOR ANY REASON, THE FIRM CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA, 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 KNOWN TO HAVE LAST RESIDED. www.finra.org/brokercheck User Guidance

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 $58,000 AND ORDERED TO PAY RESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $38,462.01, PLUS INTEREST, AT THE RATE SET FORTH IN SECTION 6221(A) OF THE INTERNAL REVENUE CODE, FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THE DATE THIS AWC IS ACCEPTED BY THE NATIONAL ADJUDICATORY COUNCIL (NAC). 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. IF FOR ANY REASON, THE FIRM CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA, 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 KNOWN TO HAVE LAST RESIDED. Firm Statement THE FIRM SENT THE $58,000.00 FINE TO FINRA ON 05/11/2011. i Disclosure 52 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF OHIO HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF OHIO DIVISION OF SECURITIES Date Initiated: 03/23/2011 Docket/Case Number: ADMINISTRATIVE CONSENT ORDER - DIVISION ORDER NO. 11-015

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

Resolution: Consent Resolution Date: 03/23/2011

©2021Sanctions FINRA. Ordered: All rights reserved. Report aboutMonetary/Fine WELLS FARGO $814,454.59 CLEARING SERVICES, LLC 155 Disgorgement/Restitution Cease and Desist/Injunction www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $814,454.59 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: THE FINE IS DUE TO THE STATE OF OHIO DIVISION OF SECURITIES - SECURITIES INVESTOR EDUCATION AND ENFORCEMENT EXPENSE FUND ON APRIL 2, 2011. i Disclosure 53 of 167 Reporting Source: Firm Current Status: Final Allegations: THE DIVISION ALLEGED THAT A WFA EMPLOYEE HAD ACTED AS AN INVESTMENNT ADVISOR REPRESENTATIVE IN MISSSISSIPPI, WITHOUT BEING PROPERLY REGISTERED AS SUCH IN VIOLATION OF SECTION 75-71-303 (B)(2) MISSSISSIPPI SECURITIES ACT 2000 & SECTION 75-71-403 (2)(D) MISSSISSIPPI SECURITIES ACT 2009. Initiated By: STATE OF MISSISSIPPI, OFFICE OF THE SECRETARY OF STATE, SECURITTIES AND CHARITIES DIVISION (DIVISION) Date Initiated: 03/01/2011 Docket/Case Number: MOU 03/01/2011

Principal Product Type: Other Other Product Type(s): FEE FOR SERVICE - INVESTMENT ADVISING Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Other Resolution Date: 03/01/2011 Sanctions Ordered: Monetary/Fine $25,000.00 Other Sanctions Ordered: OTHER - MEMORANDUM OF AGREEMENT BETWEEN WFA AND THE DIVISION. Sanction Details: WFA PAID THE $25000 FINE TO THE DIVISION ON 02/25/2011. Firm Statement THE DIVISION ALLEGED THAT A WFA EMPLOYEE ACTED AS AN ©2021 FINRA. All rights reserved. Report aboutINVESTMENNT WELLS FARGO ADVISOR CLEARING REPRESENTATIVESERVICES, LLC IN MISSSISSIPPI, WITHOUT 156 BEING PROPERLY REGISTERED AS SUCH, VIOLATING SECTION 75-71-303 (B)(2) MISSSISSIPPI SECURITIES ACT 2000 & SECTION 75-71-403 (2)(D) MISSSISSIPPI SECURITIES ACT 2009. WFA PAID THE $25000 FINE TO THE DIVISION ON 02/25/2011. www.finra.org/brokercheck User Guidance

Firm Statement THE DIVISION ALLEGED THAT A WFA EMPLOYEE ACTED AS AN INVESTMENNT ADVISOR REPRESENTATIVE IN MISSSISSIPPI, WITHOUT BEING PROPERLY REGISTERED AS SUCH, VIOLATING SECTION 75-71-303 (B)(2) MISSSISSIPPI SECURITIES ACT 2000 & SECTION 75-71-403 (2)(D) MISSSISSIPPI SECURITIES ACT 2009. WFA PAID THE $25000 FINE TO THE DIVISION ON 02/25/2011. i Disclosure 54 of 167 Reporting Source: Firm Current Status: Final Allegations: STATE OF DELAWRE DEPARTMENT OF JUSTICE DIVISION OF SECURITIES ALLEGED THAT WACHOVIA SECURITIES, LLC VIOLATED 6 DEL.C. § 7316 (A)(7) OF THE DELAWARE SECURIYTIES ACT BY EXECUTING A TRANSACTION ON BEHALF OF A CUSTOMER WITHOUT PRIOR AUTHORIZATION Initiated By: STATE OF DELAWRE DEPARTMENT OF JUSTICE DIVISION OF SECURITIES Date Initiated: 01/21/2011 Docket/Case Number: CASE NO. 09-03-03

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

Resolution: Settled Resolution Date: 01/21/2011 Sanctions Ordered: Monetary/Fine $1,746.00 Other Sanctions Ordered: WACHOVIA AGREES TO PROVIDE UIT TRAINING TO THE NAPLES, FL BRANCH OFFICE (SPECIFICALLY THE OPTIONS AVAILABLE TO A UIT INVESTOR AT TIME OF MATURITY) AND TO REVIEW POLICIES REGARDING RECORDKEEPING AND CLIENT CONTACT. WACHOVIA WILL PROVIDE TO THE DIVISION A WRITTEN TRAINING AGENDA AND AN ATTENDANCE LIST SIGNED BY EACH ATTENDEE. WACHOVIA AGREES TO REIMBURSE $1746.00 TO THE DIVISION TO COVER COST OF THEIR INVESTIGATION. Sanction Details: BOTH PARTIES WISH TO AMICABLY RESOLVE THIS MATTER WITHOUT THE TIME AND EXPENSE ASSOCIATED WITH CONTINUED LITIGATION. WACHOVIA AGREES TO PERMANENTLY WAIVE ALL RIGHTS TO A HEARING OR APPEAL. WACHOVIA NEITHER ADMITS NOR DENIES THE DIVISION ©2021 FINRA. All rights reserved. Report aboutDETERMINATIONS. WELLS FARGO CLEARING THE DIVISIONSERVICES, AGREESLLC TO CONCLUDE ITS 157 INVESTIGATION AND TAKE NO FURTHER ACTION. www.finra.org/brokercheck User Guidance BOTH PARTIES WISH TO AMICABLY RESOLVE THIS MATTER WITHOUT THE TIME AND EXPENSE ASSOCIATED WITH CONTINUED LITIGATION. WACHOVIA AGREES TO PERMANENTLY WAIVE ALL RIGHTS TO A HEARING OR APPEAL. WACHOVIA NEITHER ADMITS NOR DENIES THE DIVISION DETERMINATIONS. THE DIVISION AGREES TO CONCLUDE ITS INVESTIGATION AND TAKE NO FURTHER ACTION. i Disclosure 55 of 167 Reporting Source: Regulator Current Status: Final Allegations: ON DECEMBER 29, 2010, THE CONNECTICUT BANKING COMMISSIONER ENTERED A CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES, LLC, NOW KNOWN AS WELLS FARGO ADVISORS, LLC, A CONNECTICUT- REGISTERED BROKER-DEALER. THE CONSENT ORDER ALLEGED THAT THE FIRM FAILED TO ESTABLISH, ENFORCE AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM IN OVERSEEING THE ACTIVITIES OF DANIEL CHARLES ALLEGRINI (CRD NO. 2962754), AN EX-BROKER-DEALER AGENT OF THE FIRM. ACCORDING TO THE CONSENT ORDER, ALLEGRINI ISSUED, AND RECOMMENDED TO A CERTAIN WACHOVIA SECURITIES, LLC CLIENT, UNREGISTERED PROMISSORY NOTES THAT WERE NOT SUITABLE FOR THE CLIENT BASED ON THE CLIENT'S FINANCIAL SITUATION AND NEEDS. THE CONSENT ORDER ADDED THAT ALLEGRINI ACTED OUTSIDE THE REGULAR COURSE OR SCOPE OF HIS EMPLOYMENT WITH THE FIRM IN SELLING THE NOTES AND IN RECEIVING COMPENSATION FOR REFERRING BROKERAGE AND BANK CLIENTS TO AN ASSOCIATE FOR THE PURPOSE OF INVESTING IN OTHER INTEREST-PAYING PROMISSORY NOTES. ALLEGRINI ALLEGEDLY DID NOT PROVIDE THE FIRM WITH PRIOR WRITTEN NOTICE OF SUCH ACTIVITIES, NOR WERE THE TRANSACTIONS RECORDED ON THE FIRM'S BOOKS AND RECORDS. Initiated By: CONNECTICUT Date Initiated: 12/29/2010 Docket/Case Number: CO-10-7710-S URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): PROMISSORY NOTES SOLD BY ONE DANIEL CHARLES ALLEGRINI (CRD NO. 2962754) Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent

Resolution Date: 12/29/2010 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 $75,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: THE CONSENT ORDER FINED THE FIRM $75,000 AND DIRECTED IT TO CEASE AND DESIST FROM REGULATORY VIOLATIONS. i Reporting Source: Firm Current Status: Final Allegations: ON DECEMBER 29, 2010, THE CONNECTICUT BANKING COMMISSIONER ENTERED A CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES, LLC, NOW KNOWN AS WELLS FARGO ADVISORS, LLC, A CONNECTICUT- REGISTERED BROKER-DEALER. THE CONSENT ORDER ALLEGED THAT THE FIRM FAILED TO ESTABLISH, ENFORCE AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM IN OVERSEEING THE ACTIVITIES OF AN EX- BROKER-DEALER AGENT OF THE FIRM. ACCORDING TO THE CONSENT ORDER, THE AGENT ISSUED, AND RECOMMENDED TO A CERTAIN WACHOVIA SECURITIES, LLC CLIENT, UNREGISTERED PROMISSORY NOTES THAT WERE NOT SUITABLE FOR THE CLIENT BASED ON THE CLIENT'S FINANCIAL SITUATION AND NEEDS. THE CONSENT ORDER ADDED THAT THE AGENT ACTED OUTSIDE THE REGULAR COURSE OR SCOPE OF HIS EMPLOYMENT WITH THE FIRM IN SELLING THE NOTES AND IN RECEIVING COMPENSATION FOR REFERRING BROKERAGE AND BANK CLIENTS TO AN ASSOCIATE FOR THE PURPOSE OF INVESTING IN OTHER INTEREST-PAYING PROMISSORY NOTES. THE AGENT ALLEGEDLY DID NOT PROVIDE THE FIRM WITH PRIOR WRITTEN NOTICE OF SUCH ACTIVITIES, NOR WERE THE TRANSACTIONS RECORDED ON THE FIRM'S BOOKS AND RECORDS Initiated By: CONNECTICUT Date Initiated: 12/29/2010 Docket/Case Number: CO-10-7710-S

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

Resolution: Consent Resolution Date: 12/29/2010 Sanctions Ordered: Monetary/Fine $75,000.00 Cease and Desist/Injunction Other Sanctions Ordered: THE CONSENT ORDER FINED THE FIRM $75,000 AND DIRECTED IT TO CEASE AND DESIST FROM REGULATORY VIOLATIONS. Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS OR FINDINGS, WACHOVIA SECURITIES, LLC CONSENTED TO THE TERMS OF THIS CONSENT ORDER, PAID APPROXIMATELY $800,000.00 IN RESTITUTION TO THE CLIENT, AND AGREED TO PAY THE $75,000.00 FINE TO THE STATE OF CONNECTICUT. i Disclosure 56 of 167 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULES G-14(B)(II), G-15(A)(I) - WELLS FARGO ADVISORS, LLC FAILED TO REPORT THE CORRECT YIELD TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES AND FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THE CORRECT LOWEST EFFECTED YIELD IN THESE MUNICIPAL SECURITIES TRANSACTIONS. Initiated By: FINRA Date Initiated: 12/20/2010 Docket/Case Number: 2008015589701

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: 12/20/2010 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 $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, THE FIRM IS CENSURED AND FINED $12,500. i Reporting Source: Firm Current Status: Final Allegations: MSRB RULES G-14(B)(II), G-15(A)(I) - WELLS FARGO ADVISORS, LLC FAILED TO REPORT THE CORRECT YIELD TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES AND FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THE CORRECT LOWEST EFFECTED YIELD IN THESE MUNICIPAL SECURITIES TRANSACTIONS. Initiated By: FINRA Date Initiated: 12/20/2010 Docket/Case Number: 20080155897-01

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/20/2010 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine WELLS FARGO $12,500.00 CLEARING SERVICES, LLC 161 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 DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $12,500. A COMPANY CHECK FOR THE FULL AMOUNT, $12,500.00 WAS SENT TO FINRA VIA OVERNIGHT CARRIER ON JANUARY 4, 2011. i Disclosure 57 of 167 Reporting Source: Regulator Current Status: Final Allegations: THE DIVISION ALLEGES THAT ON OR ABOUT JUNE 9, 2009, WFA ENGAGED IN DISHONEST AND UNETHICAL PRACTICES BY FAILING TO PROMPTLY AND REASONABLY FOLLOW INSTRUCTIONS FROM A CLIENT TO TRANSFER THE ASSETS IN HER ACCOUNTS TO ANOTHER FINANCIAL INSTITUTION IN-KIND, IN VIOLATION OF IND. CODE § 23-19-4-12(D)(13) AND 710 IAC 1-17-1(Y) (2001).

THE DIVISION ALLEGES THAT FROM APPROXIMATELY MAY 5, 2009, TO JUNE 11, 2009, WELLS FARGO ADVISORS, LLC ("WFA") ENGAGED IN DISHONEST AND UNETHICAL PRACTICES BY FAILING TO SUPERVISE ITS AGENTS AND EMPLOYEES IN VIOLATION OF IND. CODE § 23-19-4-12(D)(13) AND 710 IAC 1-17-1(V) (2001). Initiated By: INDIANA Date Initiated: 11/18/2010 Docket/Case Number: 10-0271 CA 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 RESTITUTION TO NANCY MOORE IN THE AMOUNT OF $495.84. Sought:

Resolution: Consent Resolution Date: 11/18/2010 Does the order constitute a No ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 162 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: Monetary/Fine $8,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WFA PAID A CIVIL PENALTY TO THE INDIANA SECURITIES DIVISION IN THE AMOUNT OF EIGHT THOUSAND DOLLARS ($8,000) AND ALSO RESTITUTION TO NANCY MOORE FOR FOUR HUNDRED NINETY-FIVE DOLLARS AND EIGHTY-FOUR CENTS ($495.84). i Reporting Source: Firm Current Status: Final Allegations: THE DIVISION ALLEGED THAT O/A JUNE 9,2009, WELLS FARGO ADVISORS, LLC (WFA) ENGAGED IN DISHONEST AND UNETHICAL PRACTICES BY FAILING TO PROMPTLY AND REASONABLY FOLLOW INSTRUCTIONS FROM A CLIENT TO TRANSFER THE ASSETS IN HER ACCOUNTS TO ANOTHER FINANCIAL INSTITUTION IN-KIND, IN VIOLATION OF IND. CODE § 23-19-4- 12(D)(13) AND 710 IAC 1-17-1(Y)(2001). THE DIVISION ALLEGED THAT FROM APPROXIMATELY MAY 5. 2009, TO JUNE 11,2009, WFA ENGAGED IN DISHONEST AND UNETHICAL PRACTICES BY FAILING TO SUPERVISE ITS AGENTS AND EMPLOYEES IN VIOLATION OF IND. CODE § 23-19-4- 12(D)(13) & 710 IAC 1-17-1(V)(2001). Initiated By: INDIANA SECURITIES DIVISION Date Initiated: 11/18/2010 Docket/Case Number: 10-0271 CA

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 RESTITUTION TO NANCY MOORE IN THE AMOUNT OF $495.84 Sought:

Resolution Date: 11/18/2010 Sanctions Ordered: Monetary/Fine $8,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WELLS FARGO ADVISORS, LLC PAID A CIVIL PENALTY TO THE INDIANA SECURITIES DIVISION IN THE AMOUNT OF $8,000.00 AND ALSO PAID RESTITUTION TO NANCY MOORE IN THE AMOUNT OF $495.84. Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS. THE FIRM WAS FINED $8,000.00 AND PAID RESTITUTION TO THE CLIENT IN THE AMOUNT OF $495.84. i Disclosure 58 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF ALASKA HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS Initiated By: STATE OF ALASKA; DEPARTMENT COMMERCE, COMMUNITY, AND ECONOMIC DEVELOPMENT; DIVISION OF BANKING AND SECURITIES Date Initiated: 10/19/2010 Docket/Case Number: ADMINISTRATIVE CONSENT ORDER NO. 10-07-S

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

Resolution: Consent Resolution Date: 10/19/2010 Sanctions Ordered: Monetary/Fine $129,131.10 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR ©2021 FINRA. All rights reserved. Report aboutREDEMPTION WELLS FARGO IN CLEARING THE RELEVANT SERVICES, CLASS. LLC 164 www.finra.org/brokercheck User Guidance

OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: THE FINE IS DUE TO THE STATE OF ALASKA ON OCTOBER 29, 2009. i Disclosure 59 of 167 Reporting Source: Regulator Current Status: Final Allegations: ON JULY 15, 2010, THE CONNECTICUT BANKING COMMISSIONER ENTERED A CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES, LLC (N/K/A WELLS FARGO ADVISORS, LLC), A CONNECTICUT-REGISTERED BROKER- DEALER LOCATED AT ONE NORTH JEFFERSON AVENUE, ST. LOUIS, MISSOURI, AND WACHOVIA CAPITAL MARKETS, LLC (N/K/A WELLS FARGO SECURITIES, LLC), A CONNECTICUT-REGISTERED BROKER-DEALER LOCATED AT 301 SOUTH COLLEGE STREET, CHARLOTTE, NORTH CAROLINA. THE CONSENT ORDER FOLLOWED AN INVESTIGATION BY A MULTISTATE TASK FORCE INTO THE MARKETING AND SALE OF AUCTION RATE SECURITIES (ARS) BY THE FIRMS FROM JANUARY 1, 2006 THROUGH FEBRUARY 14, 2008. THE CONSENT ORDER ALLEGED THAT, IN CONJUNCTION WITH THE MARKETING OF ARS, THE FIRMS FAILED TO SUPERVISE THEIR EMPLOYEES, AND THAT THE FIRM ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS BY MISCHARACTERIZING OR FAILING TO ADEQUATELY EXPLAIN ARS TO CUSTOMERS. Initiated By: CONNECTICUT Date Initiated: 07/15/2010 Docket/Case Number: CO-10-7568-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: 07/15/2010 Does the order constitute a Yes final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 165 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: Monetary/Fine $863,341.30 Cease and Desist/Injunction Other Sanctions Ordered: THE CONSENT ORDER FINED WACHOVIA SECURITIES, LLC (N/K/A WELLS FARGO ADVISORS, LLC) AND WACHOVIA CAPITAL MARKETS, LLC (N/K/A WELLS FARGO SECURITIES, LLC) $863,341.30, AND DIRECTED THEM TO CEASE AND DESIST FROM REGULATORY VIOLATIONS. Sanction Details: SEE RESPONSE TO ITEM 13.B. i Reporting Source: Firm Current Status: Final Allegations: ON JULY 15, 2010, THE CONNECTICUT BANKING COMMISSIONER ENTERED A CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES, LLC (N/K/A WELLS FARGO ADVISORS, LLC), A CONNECTICUT-REGISTERED BROKER DEALER LOCATED AT ONE NORTH JEFFERSON AVENUE, ST. LOUIS, MISSOURI. THE CONSENT ORDER FOLLOWED AN INVESTIGATION BY A MULTISTATE TASK FORCE INTO THE MARKETING AND SALE OF AUCTION RATE SECURITIES (ARS) BY THE FIRM FROM JANUARY 1, 2006 THROUGH FEBRUARY 14, 2008. THE CONSENT ORDER ALLEGED THAT, IN CONJUNCTION WITH THE MARKETING OF ARS, THE FIRM FAILED TO SUPERVISE THEIR EMPLOYEES, AND THAT THE FIRM ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS BY MISCHARACTERIZING OR FAILING TO ADEQUATELY EXPLAIN ARS TO CUSTOMERS. Initiated By: STATE OF CONECTICUT DEPARTMENT OF BANKING Date Initiated: 07/15/2010 Docket/Case Number: CO-10-7568-S

Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES (ARS) Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 166 www.finra.org/brokercheck User Guidance

Resolution: Consent Resolution Date: 07/15/2010 Sanctions Ordered: Monetary/Fine $863,341.30 Cease and Desist/Injunction Other Sanctions Ordered: THE CONSENT ORDER FINED WACHOVIA SECURITIES, LLC (N/K/A WELLS FARGO ADVISORS, LLC)4863,341.30 AND DIRECTED THEM TO CEASE AND DESIST FROM REGULATORY VIOLATIONS. Sanction Details: SEE RESPONSE TO ITEM 12.B. PAYMENT OF THE $863,341.30 FINE WAS SENT TO THE STATE OF CONNECTICUT DEPARTMENT OF BANKING ON 07/20/2010. i Disclosure 60 of 167 Reporting Source: Firm Current Status: Final Allegations: STATE OF HAWAII ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS Date Initiated: 07/14/2010 Docket/Case Number: SEU-2008-069

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

Resolution: Consent Resolution Date: 07/14/2010 Sanctions Ordered: Monetary/Fine $211,619.92 Disgorgement/Restitution Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS.

Sanction Details: PAYMENT OF THE FINE TO THE STATE OF HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS IS DUE BY 07/24/2010. i Disclosure 61 of 167 Reporting Source: Regulator Current Status: Final Allegations: THE DIVISION CONDUCTED AN INVESTIGATION INTO THE ACTIVITIES OF A TEAM OF AGENTS WHO WORKED TOGETHER FOR A.G. EDWARDS (WHICH WAS LATER ACQUIRED BY WACHOVIA SECURITIES, LLC AND LATER BY WELLS FARGO ADVISORS). A LARGE PERCENTAGE OF THE TEAM'S PRODUCTION WAS FROM ANNUITY AND INSURANCE SALES AND THE DIVISION WAS CONCERNED ABOUT THE SUPERVISION OF THE TEAM AND THE SUITABILITY OF THEIR SALES. THE FIRM PLACED THE TEAM ON HEIGHTENED SUPERVISION AND PAID A FINE AND COSTS OF INVESTIGATION TO THE DIVISION. Initiated By: SOUTH DAKOTA Date Initiated: 08/08/2009 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 Sought:

Resolution: Consent Resolution Date: 08/08/2009 Sanctions Ordered: Monetary/Fine $21,000.00 Other Sanctions Ordered: Sanction Details: CONSENT ORDER i Reporting Source: Firm Current Status: Final Allegations: THE STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE & REGULATION ©2021 FINRA. All rights reserved. Report aboutDIVISION WELLS OFFARGO SECURITIES CLEARING SERVICES, CONDUCTED LLC AN INVESTIGATION INTO THE 168 ACTIVITIES OF A TEAM OF AGENTS WHO WORKED TOGETHER FOR A.G. EDWARDS (WHICH WAS LATER ACQUIRED BY WACHOVIA SECURITIES, LLC AND LATER BY WELLS FARGO ADVISORS, LLC.) A LARGE PERCENTAGE OF THE TEAM'S PRODUCTION WAS FROM ANNUITY AND INSURANCE SALES AND THE DIVISION WAS CONCERNED ABOUT THE SUPERVISION OF THE TEAM AND THE SUITABILITY OF THEIR SALES. THE FIRM PLACED THE TEAM ON HEIGHTENED SUPERVISION AND PAID THE DIVISION A $21,000.00 FINE AND $20,000.00 TO COVER THE COSTS OF INVESTIGATION. www.finra.org/brokercheck User Guidance

Allegations: THE STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE & REGULATION DIVISION OF SECURITIES CONDUCTED AN INVESTIGATION INTO THE ACTIVITIES OF A TEAM OF AGENTS WHO WORKED TOGETHER FOR A.G. EDWARDS (WHICH WAS LATER ACQUIRED BY WACHOVIA SECURITIES, LLC AND LATER BY WELLS FARGO ADVISORS, LLC.) A LARGE PERCENTAGE OF THE TEAM'S PRODUCTION WAS FROM ANNUITY AND INSURANCE SALES AND THE DIVISION WAS CONCERNED ABOUT THE SUPERVISION OF THE TEAM AND THE SUITABILITY OF THEIR SALES. THE FIRM PLACED THE TEAM ON HEIGHTENED SUPERVISION AND PAID THE DIVISION A $21,000.00 FINE AND $20,000.00 TO COVER THE COSTS OF INVESTIGATION. Initiated By: STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE & REGULATION DIVISION OF SECURITIES Date Initiated: 08/08/2009 Docket/Case Number: CONSENT ORDER

Principal Product Type: No Product Other Product Type(s): ANNUITY AND INSURANCE SALES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief PAYMENT OF COST OF INVESTIGATION Sought:

Resolution: Consent Resolution Date: 08/08/2009 Sanctions Ordered: Monetary/Fine $21,000.00 Other Sanctions Ordered: $20000.00 COST OF INVESTIGATION AND HEIGHTENED SUPERVISION OF THE SALES TEAM FOR A PERIOD OF ONE YEAR FROM THE DATE OF THE CONSENT ORDER OR AUGUST 8, 2010. Sanction Details: CONSENT ORDER Firm Statement THE STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE & REGULATION DIVISION OF SECURITIES CONDUCTED AN INVESTIGATION INTO THE SALES ACTIVITIES OF A TEAM OF AGENTS WHO WORKED TOGETHER FOR A.G. EDWARDS (WHICH WAS LATER ACQUIRED BY WACHOVIA SECURITIES, LLC AND LATER BY WELLS FARGO ADVISORS, LLC). APPROXIMATELY 44% OF THE GROUP'S PRODUCTION (ABOVE THE FIRM'S AVERAGE FOR THE PERIOD OF JANUARY 1, 2008 TO SEPTEMBER 30, 2008) WAS FROM ANNUITY AND INSURANCE SALES AND THE DIVISION WAS CONCERNED ABOUT THE SUPERVISION OF THE TEAM AND THE SUITABILITY OF THEIR SALES. WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT AND CONCLUSIONS OF LAW CONTAINED IN THE CONSENT ORDER, THE FIRM VOLUNTARILY PLACED THE TEAM ON HEIGHTENED SUPERVISION FOR A ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 169 PERIOD OF ONE YEAR FROM THE DATE OF THE CONSENT ORDER (OR UNTIL AUGUST 8, 2010); PAID THE DIVISION A $21,000.00 FINE; AND PAID $20,000.00 TO COVER THE COSTS OF INVESTIGATION. ALSO THE FIRM NOW USES AN AUTOMATED TOOL (ANNUITYNET) WITH A BUILT IN SCORING SYSTEM THAT ROUTES VARIABLE ANNUITY TRANSACTIONS TO THE APPROPRIATE SUPERVISOR FOR REVIEW. THE STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE & REGULATION DIVISION OF SECURITIES CONDUCTED AN INVESTIGATION INTO THE SALES ACTIVITIES OF A TEAM OF AGENTS WHO WORKED TOGETHER FOR A.G. EDWARDS (WHICH WAS LATER ACQUIRED BY WACHOVIA SECURITIES, LLC AND LATER BY WELLS FARGO ADVISORS, LLC). APPROXIMATELY 44% OF THE GROUP'S PRODUCTION (ABOVE THE FIRM'S AVERAGE FOR THE PERIOD OF JANUARY 1, 2008 TO SEPTEMBER 30, 2008) WAS FROM www.finra.org/brokercheck ANNUITY AND INSURANCE SALES AND THE DIVISION WAS CONCERNED User Guidance ABOUT THE SUPERVISION OF THE TEAM AND THE SUITABILITY OF THEIR SALES. WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT AND CONCLUSIONS OF LAW CONTAINED IN THE CONSENT ORDER, THE FIRM VOLUNTARILY PLACED THE TEAM ON HEIGHTENED SUPERVISION FOR A PERIOD OF ONE YEAR FROM THE DATE OF THE CONSENT ORDER (OR UNTIL AUGUST 8, 2010); PAID THE DIVISION A $21,000.00 FINE; AND PAID $20,000.00 TO COVER THE COSTS OF INVESTIGATION. ALSO THE FIRM NOW USES AN AUTOMATED TOOL (ANNUITYNET) WITH A BUILT IN SCORING SYSTEM THAT ROUTES VARIABLE ANNUITY TRANSACTIONS TO THE APPROPRIATE SUPERVISOR FOR REVIEW. i Disclosure 62 of 167 Reporting Source: Firm Current Status: Final Allegations: STATEOF LOUISIANA HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF LOUISIANA - OFFICE OF FINANCIAL INSTITUTIONS - COMMISSIONER OF SECURITIES Date Initiated: 06/18/2010 Docket/Case Number: OIF-2010-001

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

Resolution: Consent Resolution Date: 06/18/2010 Sanctions Ordered: Monetary/Fine $596,362.56 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: PAYMENT OF THE FINE TO THE STATE OF LOUISIANA - OFFICE OF FINANCIAL INSTITUTIONS - COMMISSIONER OF SECURITIES IS DUE WITHIN TEN DAYS - ON JUNE 28, 2010.

i Disclosure 63 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 2210(C)(1), 2210(C)(2)(A), 2210(D)(1)(A), 2210(D)(1)(B), 2210(D)(2)(B), 2211(D): RESPONDENT WELLS FARGO ADVISORS LLC FAILED TO FILE PIECES OF UNIT INVESTMENT TRUST ("UIT") MARKETING MATERIAL WITH THE NASD DEPARTMENT OF ADVERTISING REGULATION WITHIN 10 DAYS OF FIRST USE OR PUBLICATION. THE FIRM INTERNALLY USED PIECES OF UIT MARKETING MATERIAL THAT FAILED TO COMPLY WITH NASD CONTENT STANDARDS IN THAT THEY FAILED TO PROVIDE A SOUND BASIS FOR EVALUATION AND A COMPLETE PRESENTATION REGARDING THE UITS. THE FIRM ALSO USED A PIECE OF MARKETING MATERIAL THAT COMPARED UITS TO OTHER INVESTMENTS WITHOUT INCLUDING ALL MATERIAL DIFFERENCES BETWEEN THE INVESTMENT OPTIONS. THE FIRM ALSO FAILED TO DISCLOSE RISKS ASSOCIATED WITH UITS AND USED MARKETING MATERIALS THAT INCLUDED PERFORMANCE OF PRIOR, UNAVAILABLE UIT PORTFOLIOS TO PROMOTE UIT PORTFOLIOS THAT WERE CURRENTLY AVAILABLE AND UIT PERFORMANCE DATA THAT WAS MISLEADING. Initiated By: FINRA Date Initiated: 05/11/2010 Docket/Case Number: 2007009356502

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: 05/11/2010 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 ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine WELLS FARGO $25,000.00 CLEARING SERVICES, LLC 171 www.finra.org/brokercheck User Guidance

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, THE FIRM IS CENSURED AND FINED $25,000. i Reporting Source: Firm Current Status: Final Allegations: VIOLATION OF NASD RULES 2110, 2210(C)(1), 2210(C)(2)(A), 2210(D)(1)(A), 2210(D)(1)(B), 2210(D)(2)(B), & 2211 (D): RESPONDENT WELLS FARGO ADVISORS, LLC FAILED TO FILE PIECES OF UNIT INVESTMENT TRUST "UIT" MARKETING MATERIAL WITH THE NASD DEPARTMENT OF ADVERTISING REGULATION. THE FIRM INTERNALLY USED PIECES OF UIT MARKETING MATERIAL THAT FAILED TO COMPLY WITH NASD CONTENT STANDARDS IN THAT THEY FAILED TP PROVIDE A SOUND BASIS FOR EVALUATION AND A COMPLETE PRESENTATION REGARDING THE UITS. THE FIRM ALSO USED A PIECE OF MARKETING MATERIAL THAT COMPARED UITS TO OTHER INVESTMENTS WITHOUT INCLUDING ALL MATERIAL DIFFERENCES BETWEEN THE INVESTMENT OPTIONS. Initiated By: FINRA Date Initiated: 05/11/2010 Docket/Case Number: 2007009356502

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/11/2010 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 THE FINDINGS; ©2021 FINRA. All rights reserved. Report aboutTHEREFORE, WELLS FARGO THE CLEARING FIRM IS SERVICES, CENSURED LLC AND FINED $25,000.00. 172 www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF THE FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $25,000.00. Firm Statement FINRA ALLEGED VIOLATION OF NASD RULES 2110, 2210(C)(1), 2210(C)(2)(A), 2210(D)(1)(A), 2210(D)(1)(B), 2210(D)(2)(B), & 2211(D)IN THAT THE RESPONDENT WELLS FARGO ADVISORS, LLC FAILED TO FILE PIECES OF UNIT INVESTMENT TRUST "UIT" MARKETING MATERIAL WITH THE NASD DEPARTMENT OF ADVERTISING REGULATION. THE FIRM INTERNALLY USED PIECES OF UIT MARKETING MATERIAL THAT FAILED TO COMPLY WITH NASD CONTENT STANDARDS IN THAT THEY FAILED TP PROVIDE A SOUND BASIS FOR EVALUATION AND A COMPLETE PRESENTATION REGARDING THE UITS. THE FIRM ALSO USED A PIECE OF MARKETING MATERIAL THAT COMPARED UITS TO OTHER INVESTMENTS WITHOUT INCLUDING ALL MATERIAL DIFFERENCES BETWEEN THE INVESTMENT OPTIONS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF THE FINDINGS; THEREFORE, THE FIRM WAS CENSURED AND FINED $25,000.00 i Disclosure 64 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF ILLINOIS HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES (ARS) TO CUSTOMERS. Initiated By: OFFICE OF THE SECRETARY OF STATE ILLINOIS SECURITIES DEPARTMENT Date Initiated: 03/29/2010 Docket/Case Number: 08-00202

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

Resolution: Consent Resolution Date: 03/29/2010 Sanctions Ordered: Monetary/Fine $1,691,207.30 Disgorgement/Restitution Cease and Desist/Injunction ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 173 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: THE FINE WAS SENT TO THE STATE OF ILLINOIS ON 04/06/2010. i Disclosure 65 of 167 Reporting Source: Firm Current Status: Final Allegations: STATEOF ARKANSAS HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF ARKANSAS SECURITIES COMMISSIONER Date Initiated: 03/11/2010 Docket/Case Number: S-09-024-09-CO01

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

Resolution: Consent Resolution Date: 03/11/2010 Sanctions Ordered: Monetary/Fine $238,385.75 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: PAYMENT OF THE FINE TO THE STATE OF ARKANSAS IS DUE BY 03/21/2010. i Disclosure 66 of 167 Reporting Source: Firm

Current Status: Final Allegations: THE STATE OF MARYLAND HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF MARYLAND - OFFICE OF THE ATTORNEY GENERAL - SECURITIES DIVISION Date Initiated: 03/11/2010 Docket/Case Number: 2009-0164

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

Resolution: Consent Resolution Date: 03/11/2009 Sanctions Ordered: Monetary/Fine $810,624.05 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: THE FINE IS DUE TO STATE OF MARYLAND - OFFICE OF THE ATTORNEY GENERAL - SECURITIES DIVISION UPON RECEIPT OF THE CONSENT ORDER. i Disclosure 67 of 167 Reporting Source: Firm Current Status: Final Allegations: STATE OF WISCONSIN HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES (ARS) TO CUSTOMERS. Initiated By: STATE OF WISCONSIN DEPARTMENT OF FINANCIAL INSTITUTIONS DIVISION OF SECURITIES

Date Initiated: 01/15/2010 Docket/Case Number: S-09137(EX)

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

Resolution: Decision Resolution Date: 01/15/2010 Sanctions Ordered: Monetary/Fine $457,903.77 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: THE PAYMENT WAS SENT TO THE STATE OF WISCONSIN ON 01/25/2010. i Disclosure 68 of 167 Reporting Source: Firm Current Status: Final Allegations: U.S. VIRGIN ISLANDS HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: U.S. VIRGIN ISLANDS - OFFICE OF THE LIEUTENANT GOVERNOR - DIVISION OF BANKING AND INSURANCE Date Initiated: 01/04/2010 Docket/Case Number: 01-09

Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES (ARS) Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 176 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 01/04/2010 Sanctions Ordered: Monetary/Fine $116,748.21 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: THE PAYMENT WAS SENT TO THE U.S. VIRGIN ISLANDS ON 01/13/2010. i Disclosure 69 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF INDIANA HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF INDIANA OFFICE OF THE SECRETARY OF STATE SECURITIES DIVISION Date Initiated: 05/06/2009 Docket/Case Number: 09-0082 CO

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

Resolution: Consent Resolution Date: 05/06/2009 Sanctions Ordered: Monetary/Fine $509,628.73 Disgorgement/Restitution Cease and Desist/Injunction

©2021Other FINRA. Sanctions All rights Ordered: reserved. Report aboutOFFER WELLS TO FARGO REPURCHASE CLEARING SERVICES, AT PAR ARS LLC THAT ARE SUBJECT TO AUCTIONS 177 THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: THE PAYMENT WAS SENT TO THE STATE OF INDIANA ON 05/12/2009. i Disclosure 70 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF WEST VIRGINIA HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF WEST VIRGINIA SECURITIES COMMISSION Date Initiated: 11/03/2009 Docket/Case Number: 98-44964

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

Resolution: Consent Resolution Date: 11/03/2009 Sanctions Ordered: Monetary/Fine $170,766.82 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: THE FINE IS DUE TO THE STATE OF WEST VIRGINIA - WITHIN TEN DAYS - ON NOVEMBER 13, 2009. i Disclosure 71 of 167 Reporting Source: Firm

Current Status: Final Allegations: THE STATE OF DELAWARE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: THE SECURITIES COMMISIONER OF THE STATE OF DELAWARE Date Initiated: 03/31/2009 Docket/Case Number: 09-2-2

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

Resolution: Consent Resolution Date: 03/31/2009 Sanctions Ordered: Monetary/Fine $309,117.79 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE AT ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: THE PAYMENT WAS SENT TO THE STATE OF DELAWARE ON 04/09/2009. i Disclosure 72 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF MAINE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF MAINE DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION OFFICE OF SECURITIES Date Initiated: 04/14/2009 Docket/Case Number: ADMINISTRATIVE CONSENT ORDER

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

Resolution: Consent Resolution Date: 04/14/2009 Sanctions Ordered: Monetary/Fine $237,916.17 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE AT ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: THE PAYMENT WAS SENT TO THE STATE OF MAINE ON 04/22/2009. i Disclosure 73 of 167 Reporting Source: Regulator Current Status: Final Allegations: THE COMMISSIONER OF THE DEPARTMENT OF INSURANCE, SECURITIES AND BANKING FINDS WACHOVIA SECURITIES FAILED TO SUPERVISE ITS EMPLOYEES AND ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS, AND IN THE SALE OF AUCTION RATE SECURITIES IN THE DISTRICT OF COLUMBIA, IN VIOLATION OF D.C. OFFICIAL CODE §31-5602.07(A)(9)AND(12). Initiated By: DISTRICT OF COLUMBIA Date Initiated: 08/21/2009 Docket/Case Number: SB-09-02 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 ORDER Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 180 www.finra.org/brokercheck User Guidance

Resolution: Consent Resolution Date: 08/21/2009 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 $311,765.11 Cease and Desist/Injunction Other Sanctions Ordered: WACHOVIA WILL CEASE AND DESIST FROM VIOLATING D.C. OFFICIAL CODE §§ 31-5602.07(A)(9) AND 31-5602.07(A)(12) AND WILL COMPLY WITH ALL OF THE LAWS OF THE SECURITIES ACT OF 2000, AND ALL OF THE LAWS OF THE DISTRICT OF COLUMBIA. WITHIN TEN DAYS AFTER THE ENTRY OF THIS ORDER, WACHOVIA SHALL PAY THE SUM OF THREE HUNDRED ELEVEN THOUSAND, SEVEN HUNDRED AND SISTY FIVE DOLLARS AND ELEVEN CENTS ($311,765.11) TO THE DEPARTMENT AS A CIVIL MONETARY PENALTY PURSUANT TO D.C. OFFICIAL CODE §1-204.50 Sanction Details: N/A i Reporting Source: Firm Current Status: Final Allegations: THE DISTRICT OF COLUMBIA HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: DISTRICT OF COLUMBIA DEPARTMENT OF INSURANCE AND BANKING Date Initiated: 09/16/2009 Docket/Case Number: SB-09-02

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

Resolution: Consent

Resolution Date: 09/16/2009 Sanctions Ordered: Monetary/Fine $311,765.11 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: THE FINE IS DUE IN FULL BY SEPTEMBER 26, 2009. i Disclosure 74 of 167 Reporting Source: Regulator Current Status: Final Allegations: THE UTAH DIVISION OF SECURITIES, AS PART OF A MULTI-STATE TASK FORCE CONSISTING OF MEMBER STATES OF THE NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION ("NASAA") INVESTIGATING THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS") TO INVESTORS, ALLEGED THAT WACHOVIA SECURITIES, LLC ("WACHOVIA"): (1) ENGAGED IN DISHONEST AND UNETHICAL PRACTICES IN THE MARKETING AND SALE OF ARS BY MISREPRESENTING TO INVESTORS THAT ARS WERE CASH EQUIVALENTS, COMPLETELY SAFE, AND/OR LIQUID AT ANY TIME; (2) ENGAGED IN DISHONEST AND UNETHICAL PRACTICES BY NOT ADEQUATELY EXPLAINING ISSUES INVOLVING TEMPORARY MAXIMUM WAIVERS ON CERTAIN ARS; AND (3) FAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WHO SOLD ARS. Initiated By: UTAH DIVISION OF SECURITIES Date Initiated: 09/17/2009 Docket/Case Number: SD-09-0043 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 ADMINISTRATIVE FINE AND BUY BACK OF AUCTION RATE SECURITIES Sought: THAT IT SOLD TO ELIGIBLE UTAH INVESTORS.

Resolution: Stipulation and Consent Resolution Date: 09/17/2009

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 $449,851.41 Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO PURCHASE, AT PAR PLUS ACCRUED AND UNPAID DIVIDENDS/INTEREST, ELIGIBLE ARS FROM ALL INVESTORS IN THE RELEVANT CLASS AS OUTLINED IN THE DIVISION'S STIPULATION AND CONSENT ORDER. Sanction Details: PURSUANT TO A STIPULATION AND CONSENT ORDER WITH THE UTAH DIVISION OF SECURITIES, WACHOVIA SECURITIES, LLC ("WACHOVIA") WILL: (1) CEASE AND DESIST FROM VIOLATING THE UTAH UNIFORM SECURITIES ACT ("ACT") AND WILL HEREAFTER COMPLY WITH THE ACT WITH REGARD TO THE MARKETING AND SALE OF ARS TO UTAH INVESTORS; (2) PAY THE SUM OF $247,272.91 AS AN ADMINISTRATIVE FINE TO THE DIVISION; AND (3) OFFER TO PURCHASE, AT PAR PLUS ACCRUED AND UNPAID DIVIDENDS/INTEREST, ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS FROM ALL INVESTORS WHO PURCHASED ARS FROM WACHOVIA ON OR BEFORE 13 FEBRUARY 2008 INTO ACCOUNTS MAINTAINED AT WACHOVIA. Regulator Statement A PDF COPY OF THE DIVISION'S STIPULATION AND CONSENT ORDER CAN BE VIEWED ONLINE AT HTTP://SECURITIES.UTAH.GOV/DOCKETS/09004301.PDF i Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: DIVISION OF SECURITIES UTAH DEPARTMENT OF COMMERCE Date Initiated: 09/17/2009 Docket/Case Number: SD-09-0043

Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES

©2021Principal FINRA. Sanction(s)/Relief All rights reserved. Report aboutCivil WELLSand Administrative FARGO CLEARING Penalt(ies) SERVICES, /Fine(s) LLC 183 Sought: 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: 09/17/2009 Sanctions Ordered: Monetary/Fine $247,272.91 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE IS DUE IN FULL BY 09/27/2009 i Disclosure 75 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER. Initiated By: STATE OF NEW MEXICO REGULATION AND LICENSING DEPARTMENT SECURITIES DIVISION Date Initiated: 08/18/2009 Docket/Case Number: 09-09-007040

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: 08/18/2009 Sanctions Ordered: Monetary/Fine $221,609.71 ©2021 FINRA. All rights reserved. Report aboutDisgorgement/Restitution WELLS FARGO CLEARING SERVICES, LLC 184 Cease and Desist/Injunction www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $221,609.71 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: THE FINE WAS SENT ON AUGUST 18, 2009. i Disclosure 76 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER. Initiated By: COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION Date Initiated: 08/12/2009 Docket/Case Number: SEC-20900044 ARS

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: 08/12/2009 Sanctions Ordered: Monetary/Fine $1,220,592.50 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: PAYMENT WAS MADE ON AUGUST 25, 2009. i Disclosure 77 of 167

Reporting Source: Regulator Current Status: Final Allegations: IF THE FACTS ARE AS FOUND IN THE FINDINGS OF FACT IN THE MISSOURI ORDER, THEN THE ACTS AND CONDUCT SET FORTH IN THE MISSOURI ORDER, IN PARTICULAR THE AUCTION RATE SECURITIES SALES IN PA, WOULD CONSTITUTE DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS BY RESPONDENT, AND WOULD CONSTITUTE FAILURE TO REASONABLY SUPERVISE AGENTS OR EMPLOYEES. Initiated By: PENNSYLVANIA CONTACT: CAROLYN MENDELSON (412)-565-5083 Date Initiated: 08/11/2009 Docket/Case Number: 2008-04-16 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 WACHOVIA SECURITIES, LLC D/B/A WELLS FARGO ADVISORS, LLC Sought: (RESPONDENT) IS REQUIRED TO OFFER AND TO COMPLETE A BUYBACK OF AUCTION RATE SECURITIES THAT IT SOLD TO ELIGIBLE PA INVESTORS.

Resolution: Settled Resolution Date: 08/11/2009 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 $2,527,771.09 Other Sanctions Ordered: Sanction Details: RESPONDENT SHALL PAY WITHIN TEN DAYS AFTER ENTRY OF THIS ORDER $2,527,771.09 TO THE COMMONWEALTH OF PA, WHICH AMOUNT REPRESENTS AN ADMINISTRATIVE ASSESSMENT. Regulator Statement FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER ISSUED TO WACHOVIA SECURITIES, LLC D/B/A WELLS FARGO ADVISORS, LLC AND ANOTHER NAMED RESPONDENT.

i Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER. Initiated By: PENNSYLVANIA SECURITIES COMMISSION Date Initiated: 08/11/2009 Docket/Case Number: 2008-04-16

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: 08/11/2009 Sanctions Ordered: Monetary/Fine $2,527,771.09 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: PAYMENT WAS MADE AUGUST 19, 2009. i Disclosure 78 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER. Initiated By: IOWA INSURANCE DIVISION Date Initiated: 07/30/2009

Docket/Case Number: 64477

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: 07/30/2009 Sanctions Ordered: Monetary/Fine $191,289.03 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: PAYMENT WAS MADE ON AUGUST 5, 2009. i Disclosure 79 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010(A), 3010(B): THE FIRM, FROM AUGUST 2001, THROUGH OCTOBER 2004, SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE TO DETECT ABUSIVE SALES PRACTICES REGARDING VARIABLE ANNUITIES THEREBY ALLOWING TWO REPRESENTATIVES TO ENGAGE IN ABUSIVE SALES PRACTICES REGARDING VARIABLE ANNUITIES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES PLACED RESPONSIBILITY WITH THE BRANCH OFFICE MANAGER FOR THE REVIEW OF ANNUITY TRANSACTIONS, BOTH INITIAL PURCHASES AND EXCHANGES, AND THE WRITTEN SUPERVISORY PROCEDURES DID NOT DESCRIBE ADEQUATELY THE REQUIRED DOCUMENTATION AND/OR INFORMATION THE BRANCH OFFICE MANAGER (OR HIS DESIGNEE) SHOULD REVIEW DURING A SUITABILITY ANALYSIS OR HOW TO EVIDENCE APPROVAL, AND AS A RESULT OF INADEQUATE PROCEDURES IN THIS AREA, THERE WERE INCONSISTENT AND INADEQUATE SUITABILITY REVIEWS CONDUCTED AT THE FIRM OF TRANSACTIONS EXECUTED BY THE REPRESENTATIVES. THE WRITTEN SUPERVISORY PROCEDURES RELIED SUBSTANTIALLY ON A DIALOGUE BETWEEN THE BRANCH OFFICE MANAGER AND THE FINANCIAL ADVISOR ©2021 FINRA. All rights reserved. Report aboutREGARDING WELLS FARGO A SUITABILITY CLEARING SERVICES, ANALYSIS LLC AND THE PROCEDURES DID NOT 188 REQUIRE THE BRANCH OFFICE MANAGER TO VERIFY REPRESENTATIONS MADE BY THE FINANCIAL ADVISOR, AS A RESULT NO STEPS WERE TAKEN TO DETECT THE REPEATED FALSEHOODS BY THE REPRESENTATIVES THAT THE ANNUITY TRANSACTIONS REPRESENTED AN INVESTMENT OF NEW FUNDS AND DID NOT REPRESENT EXCHANGES OR REPLACEMENTS, FURTHERMORE TO THE EXTENT THAT THE BRANCH OFFICE MANAGER REVIEWED INFORMATION ON THE FIRM'S COMPUTER REGARDING THE SOURCE OF FUNDS, THE FIRM'S SYSTEM DID NOT REFLECT THAT INSURANCE COMPANIES WERE THE SOURCE OF DEPOSITS THAT THE REPRESENTATIVES ASSERTED WERE NEW FUNDS. THE FIRM DID NOT HAVE ANY EXCEPTION REPORTS APPROPRIATE FOR MONITORING VARIABLE ANNUITY SALES PRACTICES, THUS WHEN THE REPRESENTATIVES WERE ENGAGING IN UNAUTHORIZED ANNUITY SWITCHES, THE FIRM GENERATED MONTHLY ACTIVE ACCOUNT REPORTS BASED ON ESTABLISHED CRITERIA LARGELY RELATED TO EQUITIES, WHICH DID NOT SUCCESSFULLY IDENTIFY ANNUITY SALES PRACTICE VIOLATIONS. THE FIRM DID NOT HAVE EXCEPTION REPORTS TO IDENTIFY VARIABLE ANNUITY RELATED CONCERNS, FAILED TO VERIFY THAT THE CUSTOMER'S INFORMATION ON THE ANNUITY APPLICATION MATCHED THAT ON THE BROKERAGE ACCOUNT, DID NOT HAVE ADEQUATE CONTROLS TO MONITOR ANNUITY WITHDRAWALS, AND DID NOT HAVE AN ADEQUATE PROCEDURE TO REMOVE ANNUITIES FROM CUSTOMER ACCOUNTS WHEN THEY WERE SURRENDERED BUT INSTEAD RELIED UPON A DISCLAIMER ON EACH CUSTOMER'S ACCOUNT STATEMENTS. THE FIRM'S PROCEDURE BY WHICH CUSTOMERS' ACCOUNT STATEMENTS WERE UPDATED RELIED UPON THE FINANCIAL ADVISOR ADVISING THE BRANCH'S OPERATIONS DEPARTMENT THAT AN ANNUITY HAD BEEN CLOSED AND, AT THE TIME, THE OPERATIONS AREA WOULD THEN SEND THE SURRENDER INFORMATION TO THE FIRM'S ANNUITY DEPARTMENT, WHICH WOULD REMOVE THE POSITION FROM THE CLIENT'S STATEMENT, THUS THE REPRESENTATIVES FAILED TO SO ADVISE THE BRANCH'S OPERATIONS DEPARTMENT, AND WERE ABLE TO USE THIS WEAKNESS IN THE FIRM'S PROCEDURE TO CONCEAL THEIR UNAUTHORIZED PARTIAL WITHDRAWALS. THE FIRM DID NOT HAVE AN ADEQUATE PROCEDURE TO REJECT ANNUITY TRANSACTIONS IF THE ANNUITY BUY TICKET WAS NOT COMPLETE AND THE ANNUITY BUY TICKETS FOR MANY OF THE SUBJECT TRANSACTIONS, HOWEVER, WERE PROCESSED WITHOUT FULL AND COMPLETE INFORMATION. NASD RULES 2110, 3010(A), 3010(B): THE FIRM, FROM AUGUST 2001, THROUGH OCTOBER 2004, SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE TO DETECT ABUSIVE SALES PRACTICES REGARDING VARIABLE ANNUITIES THEREBY ALLOWING TWO REPRESENTATIVES TO ENGAGE IN ABUSIVE SALES PRACTICES REGARDING VARIABLE ANNUITIES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES PLACED RESPONSIBILITY WITH THE BRANCH OFFICE MANAGER FOR THE REVIEW OF ANNUITY TRANSACTIONS, BOTH INITIAL PURCHASES AND EXCHANGES, AND THE WRITTEN SUPERVISORY PROCEDURES DID NOT DESCRIBE ADEQUATELY THE REQUIRED DOCUMENTATION AND/OR INFORMATION THE BRANCH OFFICE MANAGER (OR HIS DESIGNEE) SHOULD REVIEW DURING A SUITABILITY ANALYSIS OR HOW TO EVIDENCE APPROVAL, AND AS A RESULT OF INADEQUATE PROCEDURES IN THIS AREA, THERE WERE INCONSISTENT AND www.finra.org/brokercheck INADEQUATE SUITABILITY REVIEWS CONDUCTED AT THE FIRM OF User Guidance TRANSACTIONS EXECUTED BY THE REPRESENTATIVES. THE WRITTEN SUPERVISORY PROCEDURES RELIED SUBSTANTIALLY ON A DIALOGUE BETWEEN THE BRANCH OFFICE MANAGER AND THE FINANCIAL ADVISOR REGARDING A SUITABILITY ANALYSIS AND THE PROCEDURES DID NOT REQUIRE THE BRANCH OFFICE MANAGER TO VERIFY REPRESENTATIONS MADE BY THE FINANCIAL ADVISOR, AS A RESULT NO STEPS WERE TAKEN TO DETECT THE REPEATED FALSEHOODS BY THE REPRESENTATIVES THAT THE ANNUITY TRANSACTIONS REPRESENTED AN INVESTMENT OF NEW FUNDS AND DID NOT REPRESENT EXCHANGES OR REPLACEMENTS, FURTHERMORE TO THE EXTENT THAT THE BRANCH OFFICE MANAGER REVIEWED INFORMATION ON THE FIRM'S COMPUTER REGARDING THE SOURCE OF FUNDS, THE FIRM'S SYSTEM DID NOT REFLECT THAT INSURANCE COMPANIES WERE THE SOURCE OF DEPOSITS THAT THE REPRESENTATIVES ASSERTED WERE NEW FUNDS. THE FIRM DID NOT HAVE ANY EXCEPTION REPORTS APPROPRIATE FOR MONITORING VARIABLE ANNUITY SALES PRACTICES, THUS WHEN THE REPRESENTATIVES WERE ENGAGING IN UNAUTHORIZED ANNUITY SWITCHES, THE FIRM GENERATED MONTHLY ACTIVE ACCOUNT REPORTS BASED ON ESTABLISHED CRITERIA LARGELY RELATED TO EQUITIES, WHICH DID NOT SUCCESSFULLY IDENTIFY ANNUITY SALES PRACTICE VIOLATIONS. THE FIRM DID NOT HAVE EXCEPTION REPORTS TO IDENTIFY VARIABLE ANNUITY RELATED CONCERNS, FAILED TO VERIFY THAT THE CUSTOMER'S INFORMATION ON THE ANNUITY APPLICATION MATCHED THAT ON THE BROKERAGE ACCOUNT, DID NOT HAVE ADEQUATE CONTROLS TO MONITOR ANNUITY WITHDRAWALS, AND DID NOT HAVE AN ADEQUATE PROCEDURE TO REMOVE ANNUITIES FROM CUSTOMER ACCOUNTS WHEN THEY WERE SURRENDERED BUT INSTEAD RELIED UPON A DISCLAIMER ON EACH CUSTOMER'S ACCOUNT STATEMENTS. THE FIRM'S PROCEDURE BY WHICH CUSTOMERS' ACCOUNT STATEMENTS WERE UPDATED RELIED UPON THE FINANCIAL ADVISOR ADVISING THE BRANCH'S OPERATIONS DEPARTMENT THAT AN ANNUITY HAD BEEN CLOSED AND, AT THE TIME, THE OPERATIONS AREA WOULD THEN SEND THE SURRENDER INFORMATION TO THE FIRM'S ANNUITY DEPARTMENT, WHICH WOULD REMOVE THE POSITION FROM THE CLIENT'S STATEMENT, THUS THE REPRESENTATIVES FAILED TO SO ADVISE THE BRANCH'S OPERATIONS DEPARTMENT, AND WERE ABLE TO USE THIS WEAKNESS IN THE FIRM'S PROCEDURE TO CONCEAL THEIR UNAUTHORIZED PARTIAL WITHDRAWALS. THE FIRM DID NOT HAVE AN ADEQUATE PROCEDURE TO REJECT ANNUITY TRANSACTIONS IF THE ANNUITY BUY TICKET WAS NOT COMPLETE AND THE ANNUITY BUY TICKETS FOR MANY OF THE SUBJECT TRANSACTIONS, HOWEVER, WERE PROCESSED WITHOUT FULL AND COMPLETE INFORMATION. Initiated By: FINRA Date Initiated: 08/28/2009 Docket/Case Number: 2005002169202

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/28/2009 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 $350,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED $350,000.

AN UNDERTAKING TO CERTIFY TO FINRA WITHIN 90 DAYS THAT FIRM HAS REVIEWED ITS PROCEDURES REGARDING VARIABLE ANNUITIES AND HAS SYSTEMS AND PROCEDURES IN PLACE THAT ARE REASONABLY DESIGNED TO DETECT ABUSIVE SALES PRACTICES. i Reporting Source: Firm Current Status: Final Allegations: NASD RULES 2110, 3010(A), 3010(B): THE FIRM, FROM AUGUST 2001, THROUGH OCTOBER 2004, SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE TO DETECT ABUSIVE SALES PRACTICES REGARDING VARIABLE ANNUITIES THEREBY ALLOWING TWO REPRESENTATIVES TO ENGAGE IN ABUSIVE SALES PRACTICES REGARDING VARIABLE ANNUITIES. Initiated By: FINRA Date Initiated: 08/28/2009 Docket/Case Number: 2005002169202

Principal Product Type: Annuity(ies) - Variable Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/28/2009 Sanctions Ordered: Censure Monetary/Fine $350,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED $350,000. AN UNDERTAKING TO CERTIFY TO FINRA WITHIN 90 DAYS THAT FIRM HAS REVIEWED ITS PROCEDURES REGARDING VARIABLE ANNUITIES AND HAS SYSTEMS AND PROCEDURES IN PLACE THAT ARE REASONABLY DESIGNED TO DETECT ABUSIVE SALES PRACTICES. i Disclosure 80 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF WYOMING SECRETARY OF STATE SECURITIES DIVISION Date Initiated: 06/23/2009 Docket/Case Number: 09-05

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: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 191 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 06/23/2009 Sanctions Ordered: Monetary/Fine $176,314.77 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: THE FINE WAS PAID ON JUNE 29, 2009. i Disclosure 81 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF OREGON DIVISION OF FINANCE AND CORPORATE SECURITIES Date Initiated: 06/29/2009 Docket/Case Number: S-09-0022

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: 06/29/2009 Sanctions Ordered: Monetary/Fine $397,234.57 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE ©2021 FINRA. All rights reserved. Report aboutNOT WELLS SUCCESSFUL FARGO CLEARING AND ARE SERVICES, NOT SUBJECT LLC TO CURRENT CALLS OR 192 REDEMPTION IN THE RELEVANT CLASS. www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: THE FINE IS PAYABLE WITHIN 10 DAYS IF THE ORDER. i Disclosure 82 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF IDAHO Date Initiated: 06/22/2009 Docket/Case Number: 2009-7-08

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: 06/22/2009 Sanctions Ordered: Monetary/Fine $191,049.02 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: THE FINE WAS PAID ON JUNE 29, 2009. i Disclosure 83 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO ©2021 FINRA. All rights reserved. Report aboutCUSTOMERS. WELLS FARGO CLEARING SERVICES, LLC 193 www.finra.org/brokercheck User Guidance

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF KANSAS Date Initiated: 06/09/2009 Docket/Case Number: 09 E 012

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: 06/09/2009 Sanctions Ordered: Monetary/Fine $633,090.35 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON JUNE 16, 2009. i Disclosure 84 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF NEBRASKA Date Initiated: 06/04/2009 Docket/Case Number: N/A

Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) ©2021Sought: FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 194 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: 06/04/2009 Sanctions Ordered: Monetary/Fine $298,818.42 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: THE FINE WAS PAID ON JUNE 12TH, 2009 i Disclosure 85 of 167 Reporting Source: Regulator Current Status: Final Allegations: THE TN SECURITIES DIVISION, AS PART OF A MULTI-STATE TASK FORCE CONSISTING OF MEMBER STATES OF THE NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION ("NASAA") INVESTIGATING THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS") TO INVESTORS, ALLEGED THAT DURING THE PERIOD OF JANUARY 2006 THROUGH FEBRUARY 2008 WACHOVIA SECURITIES, LLC, ("WACHOVIA") MISREPRESENTED THE SALE OF ARS TO INVESTORS AS CONSERVATIVE, LIQUID, CASH-EQUIVALENT INVESTMENTS AND THAT WACHOVIA FAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TO THE SALE OF ARS. Initiated By: TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE, SECURITIES DIVISION Date Initiated: 05/22/2009 Docket/Case Number: 09-003 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): AUTION RATE SECURITIES Principal Sanction(s)/Relief Cease and Desist Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 195 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief RESTITUTION; CIVIL PENALTY Sought:

Resolution: Settled Resolution Date: 05/22/2009 Sanctions Ordered: Monetary/Fine $449,851.41 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKINGS Sanction Details: PURSUANT TO A CONSENT ORDER IN WHICH WACHOVIA NEITHER ADMITTED NOR DENIED THE FINDINGS OF FACT AND CONCLUSIONS OF LAW, THE COMMISSIONER OF THE TN DEPARTMENT OF COMMERCE AND INSURANCE ORDERED WACHOVIA TO CEASE AND DESIST FROM VIOLATING THE TN SECURITIES ACT OF 1980; AND ORDERED WACHOVIA TO MAKE CERTAIN UNDERTAKINGS, INCLUDING OFFERING TO REPURCHASE FROM CERTAIN INVESTORS ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND THAT ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS; AND ORDERED WACHOVIA TO MAKE A PAYMENT OF $449,851.41 TO THE TN DEPARTMENT OF COMMERCE AND INSURANCE. i Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: TENNESSEE SECURITIES DIVISION Date Initiated: 05/22/2009 Docket/Case Number: 09-003 SI 2008-010

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 05/22/2009 Sanctions Ordered: Monetary/Fine $449,851.41 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE IS DUE BY 06/01/2009 i Disclosure 86 of 167 Reporting Source: Regulator Current Status: Final Allegations: THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITED WACHOVIA SECURITIES LLC AND WACHOVIA CAPITAL MARKETS LLC 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: 05/26/2009 Docket/Case Number: CO-2009-0011 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 ORDER Sought:

Resolution: Consent Resolution Date: 05/26/2009 Does the order constitute a No ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 197 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: Monetary/Fine $683,141.24 Other Sanctions Ordered: $350,000 TO STATE OF ALABAMA; $250,000 TO ALABAMA SECURITIES COMMISSION; $73,141.24 TO INVESTOR PROTECTION TRUST; $10,000 TO ALABAMA DISTRICT ATTORNEY'S ASSOCIATION. RECEIVED 06/10/2009 Sanction Details: $350,000 TO STATE OF ALABAMA; $250,000 TO ALABAMA SECURITIES COMMISSION; $73,141.24 TO INVESTOR PROTECTION TRUST; $10,000 TO ALABAMA DISTRICT ATTORNEY'S ASSOCIATION. RECEIVED 06/10/2009 Regulator Statement THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITED WACHOVIA SECURITIES LLC AND WACHOVIA CAPITAL MARKETS LLC 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: THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITED WACHOVIA SECURITIES, LLC WITH ENGAGING IN UNETHICAL AND DISHONEST PRACTICES AND FAILURE TO PROPERLY SUPERVISE ITS AGENTS. THIS ACTION STEMMED FROM THE FIRMS INAPPROPIATE MARKETING OF AUCTION RATE SECURITIES (ARS) TO CUSTOMERS WITHOUT ADEQUATELY DISCLOSING RISKS OF ILLIQUIDITY Initiated By: ALABAMA SECURITIES COMMISSION Date Initiated: 05/26/2009 Docket/Case Number: CO-2009-0011

Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Other Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 198 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief CONSENT ORDER Sought:

Resolution: Consent Resolution Date: 05/26/2009 Sanctions Ordered: Monetary/Fine $683,141.24 Other Sanctions Ordered: $350.000 TO STATE OF ALABAMA; $250,000 TO ALABAMA SECURITIES COMMISSION; $73,141.24 TO INVESTOR PROTECTION TRUST; $10,000 TO ALABAMA DISTRICT ATTORNEY'S ASSOCIATION. RECEIVED 06/10/2009 Sanction Details: $350.000 TO STATE OF ALABAMA; $250,000 TO ALABAMA SECURITIES COMMISSION; $73,141.24 TO INVESTOR PROTECTION TRUST; $10,000 TO ALABAMA DISTRICT ATTORNEY'S ASSOCIATION. RECEIVED 06/10/2009 THE FIRM SENT THE $683,141.24 TOTAL FINE, AS STIPULATED, TO THE STATE OF ALABAMA ON 06/04/2009. Firm Statement THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITED WACHOVIA SECURITIES, LLC WITH ENGAGING IN UNETHICAL AND DISHONEST PRACTICES AND FAILURE TO PROPERLY SUPERVISE ITS AGENTS. THIS ACTION STEMMED FROM THE FIRMS INAPPROPIATE MARKETING OF AUCTION RATE SECURITIES (ARS) TO CUSTOMERS WITHOUT ADEQUATELY DISCLOSING RISKS OF ILLIQUIDITY i Disclosure 87 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: MINNESOTA DEPARTMENT OF COMMERCE Date Initiated: 05/11/2009 Docket/Case Number: FILE 11200

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: 05/11/2009 Sanctions Ordered: Monetary/Fine $387,790.88 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON 05/18/2009 i Disclosure 88 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: COMMONWEALTH OF KENTUCKY Date Initiated: 05/14/2009 Docket/Case Number: NO. 2009-AH-032

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: 05/14/2009 Sanctions Ordered: Monetary/Fine $315,300.14 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON 05/19/2009

i Disclosure 89 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: STATE OF RHODE ISLAND Date Initiated: 04/22/2009 Docket/Case Number: 09-110

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: 04/22/2009 Sanctions Ordered: Monetary/Fine $131,565.93 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON 05/01/2009 i Disclosure 90 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110 AND 3010: RESPONDENT WACHOVIA SECURITIES, LLC FAILED TO DELIVER PROSPECTUSES AND PRODUCT DESCRIPTIONS TO CERTAIN CUSTOMERS WHO PURCHASED INVESTMENT PRODUCTS, AS REQUIRED UNDER FEDERAL SECURITIES LAWS AND NASD RULES. WACHOVIA SECURITIES FAILED TO HAVE ADEQUATE SUPERVISORY SYSTEMS AND APPROPRIATE WRITTEN SUPERVISORY PROCEDURES IN ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 201 PLACE TO ENSURE THAT OFFERING DOCUMENTS WERE BEING SENT TO CUSTOMERS IN CONNECTION WITH SECURITIES TRANSACTIONS. WACHOVIA SECURITIES ALSO FAILED TO ADEQUATELY SUPERVISE THE SUBMISSION OF INFORMATION TO FINRA STAFF AND ENSURE THAT ITS SUBMISSIONS WERE ACCURATE, COMPLETE AND TIMELY SUBMITTED. NASD RULES 2110 AND 3010: RESPONDENT WACHOVIA SECURITIES, LLC www.finra.org/brokercheck FAILED TO DELIVER PROSPECTUSES AND PRODUCT DESCRIPTIONS TO User Guidance CERTAIN CUSTOMERS WHO PURCHASED INVESTMENT PRODUCTS, AS REQUIRED UNDER FEDERAL SECURITIES LAWS AND NASD RULES. WACHOVIA SECURITIES FAILED TO HAVE ADEQUATE SUPERVISORY SYSTEMS AND APPROPRIATE WRITTEN SUPERVISORY PROCEDURES IN PLACE TO ENSURE THAT OFFERING DOCUMENTS WERE BEING SENT TO CUSTOMERS IN CONNECTION WITH SECURITIES TRANSACTIONS. WACHOVIA SECURITIES ALSO FAILED TO ADEQUATELY SUPERVISE THE SUBMISSION OF INFORMATION TO FINRA STAFF AND ENSURE THAT ITS SUBMISSIONS WERE ACCURATE, COMPLETE AND TIMELY SUBMITTED. Initiated By: FINRA Date Initiated: 05/01/2009 Docket/Case Number: 2007010181101

Principal Product Type: Debt - Corporate Other Product Type(s): AFTERMARKET EQUITY NON-SYNDICATE IPOS, COLLATERAL MORTGAGE OBLIGATIONS (CMOS), AUCTION MARKET PREFERRED SECURITIES, PREFERRED STOCKS, MUTUAL FUNDS, ALTERNATIVE INVESTMENT SECURITIES, EQUITY IPO TRANSACTIONS AND EXCHANGE TRADED FUNDS (ETFS) Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/01/2009 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 $1,400,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WACHOVIA SECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $1,400,000. IN ADDITION, WACHOVIA SECURITIES UNDERTAKES TO COMPLETE THE FOLLOWING WITHIN 120 DAYS OF NOTICE OF ACCEPTANCE OF THE AWC: 1) ADOPT AND IMPLEMENT SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND NASD/FINRA RULES APPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS, ©2021 FINRA. All rights reserved. Report aboutINCLUDING WELLS FARGO SYSTEMS CLEARING AND SERVICES, PROCEDURES LLC TO PROVIDE ADEQUATE 202 OVERSIGHT IF THIRD PARTY VENDORS ARE UTILIZED; AND 2) PROVIDE A WRITTEN CERTIFICATE BY A DULY AUTHORIZED SENIOR OFFICER OF WACHOVIA SECURITIES LLC THAT THE FIRM HAS ADOPTED AND IMPLEMENTED SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND NASD/FINRA RULES APPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS. WITHOUT ADMITTING OR DENYING THE FINDINGS, WACHOVIA SECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $1,400,000. IN ADDITION, WACHOVIA SECURITIES UNDERTAKES TO www.finra.org/brokercheck COMPLETE THE FOLLOWING WITHIN 120 DAYS OF NOTICE OF User Guidance ACCEPTANCE OF THE AWC: 1) ADOPT AND IMPLEMENT SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND NASD/FINRA RULES APPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS, INCLUDING SYSTEMS AND PROCEDURES TO PROVIDE ADEQUATE OVERSIGHT IF THIRD PARTY VENDORS ARE UTILIZED; AND 2) PROVIDE A WRITTEN CERTIFICATE BY A DULY AUTHORIZED SENIOR OFFICER OF WACHOVIA SECURITIES LLC THAT THE FIRM HAS ADOPTED AND IMPLEMENTED SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND NASD/FINRA RULES APPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS. i Reporting Source: Firm Current Status: Final Allegations: NASD RULES 2110 AND 3010: RESPONDENT WACHOVIA SECURITIES, LLC FAILED TO DELIVER PROSPECTUSES AND PRODUCT DESCRIPTIONS TO CERTAIN CUSTOMERS WHO PURCHASED INVESTMENT PRODUCTS, AS REQUIRED UNDER FEDERAL SECURITIES LAWS AND NASD RULES. WACHOVIA SECURITIES FAILED TO HAVE ADEQUATE SUPERVISORY SYSTEMS AND APPROPRIATE WRITTEN SUPERVISORY PROCEDURES IN PLACE TO ENSURE THAT OFFERING DOCUMENTS WERE BEING SENT TO CUSTOMERS IN CONNECTION WITH SECURITIES TRANSACTIONS. WACHOVIA SECURITIES ALSO FAILED TO ADEQUATELY SUPERVISE THE SUBMISSION OF INFORMATION TO FINRA STAFF AND ENSURE THAT ITS SUBMISSIONS WERE ACCURATE, COMPLETE AND TIMELY SUBMITTED. Initiated By: FINRA Date Initiated: 05/01/2009 Docket/Case Number: 2007010181101

Sanctions Ordered: Censure Monetary/Fine $1,400,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WACHOVIA SECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $1,400,000. IN ADDITION, WACHOVIA SECURITIES UNDERTAKES TO COMPLETE THE FOLLOWING WITHIN 120 DAYS OF NOTICE OF ACCEPTANCE OF THE AWC: 1) ADOPT AND IMPLEMENT SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND NASD/FINRA RULES APPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS, INCLUDING SYSTEMS AND PROCEDURES TO PROVIDE ADEQUATE OVERSIGHT IF THIRD PARTY VENDORS ARE UTILIZED; AND 2) PROVIDE A WRITTEN CERTIFICATE BY A DULY AUTHORIZED SENIOR OFFICER OF WACHOVIA SECURITIES LLC THAT THE FIRM HAS ADOPTED AND IMPLEMENTED SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND NASD/FINRA RULES APPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS. i Disclosure 91 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: STATE OF COLORADO SECURITIES COMMISSIONER Date Initiated: 04/20/2009 Docket/Case Number: 09-L-11

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: 04/20/2009 Sanctions Ordered: Monetary/Fine $664,614.09 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE IS DUE BY 04/30/2009 i Disclosure 92 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION Date Initiated: 04/17/2009 Docket/Case Number: 0420-S-2/09

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: 04/17/2009 Sanctions Ordered: Monetary/Fine $5,673,320.82 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE IS DUE BY 04/27/2009 i ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 205 www.finra.org/brokercheck User Guidance

Disclosure 93 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: STATE COMMISSIONER OF SOUTH CAROLINA Date Initiated: 04/13/2009 Docket/Case Number: 08018

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: 04/13/2009 Sanctions Ordered: Monetary/Fine $772,958.03 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE IS DUE IN FULL BY 12/31/2009 i Disclosure 94 of 167 Reporting Source: Regulator Current Status: Final Allegations: THE STATE ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS AND FAILED TO SUPERVISE AGENTS WHO SOLD THE SECURITIES Initiated By: OKLAHOMA DEPARTMENT OF SECURITIES Date Initiated: 04/03/2009 Docket/Case Number: 09-087 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 206 www.finra.org/brokercheck User Guidance

Docket/Case Number: 09-087 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 CIVIL PENALTY AND RESCISSION Sought:

Resolution: Consent Resolution Date: 04/03/2009 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 $478,286.84 Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE AUCTION RATE SECURITIES THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: WACHOVIA HAS PAID THE FINE i Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: STATE OF OKLAHOMA DEPARTMENT OF SECURITIES Date Initiated: 04/03/2009 Docket/Case Number: 09-087

Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 207 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: 04/03/2009 Sanctions Ordered: Monetary/Fine $478,286.84 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON 04/10/2009 i Disclosure 95 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: STATE OF NORTH DAKOTA SECURITIES DEPARTMENT Date Initiated: 04/01/2009 Docket/Case Number:

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: 04/01/2009 Sanctions Ordered: Monetary/Fine $121,409.18 Disgorgement/Restitution Cease and Desist/Injunction ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 208 www.finra.org/brokercheck User Guidance

Monetary/Fine $121,409.18 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON 04/03/2009 i Disclosure 96 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: STATE OF MICHIGAN OFFICE OF FINANCIAL AND INSURANCE REGULATION Date Initiated: 03/27/2009 Docket/Case Number:

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: 03/27/2009 Sanctions Ordered: Monetary/Fine $653,981.26 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON 04/07/2009 i Disclosure 97 of 167 Reporting Source: Firm

Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: STATE OF ARIZONA - ARIZONA CORPORATION COMMISSION Date Initiated: 03/24/2009 Docket/Case Number: S-20655A-09-0071

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: 03/24/2009 Sanctions Ordered: Monetary/Fine $642,280.13 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON 04/01/2009 i Disclosure 98 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: STATE OF VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION Date Initiated: 03/18/2009 Docket/Case Number: 09-039-S

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: 03/18/2009 Sanctions Ordered: Monetary/Fine $166,923.26 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON 03/25/2009 i Disclosure 99 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: TEXAS STATE SECURITIES BOARD Date Initiated: 03/16/2009 Docket/Case Number: IC09-CDO-06

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: 03/16/2009

©2021Sanctions FINRA. Ordered: All rights reserved. Report aboutMonetary/Fine WELLS FARGO $3,982,274.57 CLEARING SERVICES, LLC 211 Disgorgement/Restitution Cease and Desist/Injunction www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $3,982,274.57 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON 03/18/2009 i Disclosure 100 of 167 Reporting Source: Regulator Current Status: Final Allegations: ON MARCH 24, 2009, THE SECURITIES DIVISION ENTERED INTO A CONSENT ORDER WITH WACHOVIA SECURITIES, LLC AND WACHOVIA CAPITAL MARKETS, LLC (COLLECTIVELY "RESPONDENTS"), IN ORDER TO SETTLE THE ALLEGATIONS THAT RESPONDENTS HAD ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND FAILED TO REASONABLY SUPERVISE THEIR SALESPERSONS IN THE SALE OF ARS. RESPONDENTS NEITHER ADMITTED NOR DENIED THE ALLEGATIONS, BUT AGREED TO CEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OF WASHINGTON. RESPONDENTS AGREED TO OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO UNSUCCESSFUL AUCTIONS AND THAT ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS, FROM INVESTORS WHO PURCHASED ARS FROM RESPONDENTS ON OR BEFORE FEBRUARY 13, 2008, INTO ACCOUNTS MAINTAINED WITH RESPONDENTS. RESPONDENTS AGREED TO PAY $491,556.71 AS A CIVIL MONETARY PENALTY. RESPONDENTS EACH WAIVED THEIR RIGHT TO A HEARING AND TO JUDICIAL REVIEW OF THIS MATTER. Initiated By: WASHINGTON Date Initiated: 03/24/2009 Docket/Case Number: S-08-229-09-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: 03/24/2009 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 $491,556.71 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: IT IS HEREBY ORDERED: 1. THIS ORDER CONCLUDES THE INVESTIGATION BY THE SECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENT OF FINANCIAL INSTITUTIONS AND ANY OTHER ACTION THAT THE SECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENT OF FINANCIAL INSTITUTIONS COULD COMMENCE UNDER APPLICABLE WASHINGTON STATE LAW ON BEHALF OF THE STATE OF WASHINGTON AS IT RELATES TO WACHOVIA, AND ITS MARKETING AND SALE OF AUCTION RATE SECURITIES TO INVESTORS. 2.THIS ORDER IS ENTERED INTO SOLELY FOR THE PURPOSE OF RESOLVING THE REFERENCED MULTI-STATE INVESTIGATION, AND IS NOT INTENDED TO BE USED FOR ANY OTHER PURPOSE. 3. WACHOVIA SHALL CEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OF WASHINGTON AND SHALL COMPLY WITH THE SECURITIES ACT OF WASHINGTON. 4. WITHIN TEN DAYS AFTER THE ENTRY OF THIS ORDER, WACHOVIA SHALL PAY THE SUM OF $491,556.71 TO THE STATE OF WASHINGTON AS A CIVIL MONETARY PENALTY PURSUANT TO RCW 21.20.110, TO BE DEPOSITED IN THE SECURITIES PROSECUTION FUND, PURSUANT TO RCW 21.20.395, WHICH AMOUNT CONSTITUTES THE STATE OF WASHINGTON'S PROPORTIONATE SHARE OF THE STATE SETTLEMENT AMOUNT OF 50 MILLION DOLLARS ($50,000,000.00). 5. IN THE EVENT ANOTHER STATE SECURITIES REGULATOR DETERMINES NOT TO ACCEPT WACHOVIA'S STATE SETTLEMENT OFFER, THE TOTAL AMOUNT OF THE STATE OF WASHINGTON'S PAYMENT SHALL NOT BE AFFECTED, AND SHALL REMAIN AT $491,556.71. 6. WACHOVIA SECURITIES AND WACHOVIA CAPITAL MARKETS, RESPECTIVELY, AS AGENTS FOR ONE OR MORE AFFILIATED COMPANIES AND NOT AS PRINCIPAL, SHALL OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. FOR PURPOSES OF THIS ORDER THE RELEVANT CLASS SHALL BE DEFINED AS ALL INVESTORS ©2021 FINRA. All rights reserved. Report aboutWHO WELLS PURCHASED FARGO CLEARING ARS FROM SERVICES, EITHER LLC WACHOVIA SECURITIES OR 213 WACHOVIA CAPITAL MARKETS, RESPECTIVELY, ON OR BEFORE FEBRUARY 13, 2008 INTO ACCOUNTS MAINTAINED AT WACHOVIA SECURITIES OR WACHOVIA CAPITAL MARKETS, RESPECTIVELY. IT IS HEREBY ORDERED: 1. THIS ORDER CONCLUDES THE INVESTIGATION BY THE SECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENT OF FINANCIAL INSTITUTIONS AND ANY OTHER ACTION THAT THE SECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENT OF FINANCIAL INSTITUTIONS COULD COMMENCE UNDER APPLICABLE WASHINGTON STATE LAW ON BEHALF OF THE STATE OF WASHINGTON AS IT RELATES TO WACHOVIA, AND ITS MARKETING AND SALE OF AUCTION RATE SECURITIES TO INVESTORS. 2.THIS ORDER IS ENTERED INTO SOLELY FOR THE PURPOSE OF RESOLVING THE REFERENCED MULTI-STATE INVESTIGATION, AND IS NOT INTENDED TO BE USED FOR ANY OTHER PURPOSE. 3. WACHOVIA SHALL CEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OF WASHINGTON AND SHALL COMPLY WITH THE SECURITIES ACT OF WASHINGTON. 4. WITHIN TEN DAYS AFTER THE ENTRY OF THIS ORDER, WACHOVIA SHALL PAY THE SUM OF $491,556.71 TO THE STATE OF WASHINGTON AS A CIVIL MONETARY PENALTY PURSUANT TO RCW 21.20.110, TO BE DEPOSITED IN THE SECURITIES PROSECUTION FUND, PURSUANT TO RCW 21.20.395, WHICH AMOUNT CONSTITUTES THE STATE OF WASHINGTON'S PROPORTIONATE SHARE OF THE STATE SETTLEMENT AMOUNT OF 50 MILLION DOLLARS ($50,000,000.00). 5. IN THE EVENT ANOTHER STATE SECURITIES REGULATOR DETERMINES NOT TO ACCEPT WACHOVIA'S STATE SETTLEMENT OFFER, THE TOTAL AMOUNT OF THE STATE OF WASHINGTON'S PAYMENT SHALL NOT BE AFFECTED, AND SHALL REMAIN AT $491,556.71. 6. WACHOVIA SECURITIES AND WACHOVIA CAPITAL MARKETS, RESPECTIVELY, AS AGENTS FOR ONE OR MORE AFFILIATED COMPANIES www.finra.org/brokercheck AND NOT AS PRINCIPAL, SHALL OFFER TO PURCHASE AT PAR ARS THAT User Guidance ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. FOR PURPOSES OF THIS ORDER THE RELEVANT CLASS SHALL BE DEFINED AS ALL INVESTORS WHO PURCHASED ARS FROM EITHER WACHOVIA SECURITIES OR WACHOVIA CAPITAL MARKETS, RESPECTIVELY, ON OR BEFORE FEBRUARY 13, 2008 INTO ACCOUNTS MAINTAINED AT WACHOVIA SECURITIES OR WACHOVIA CAPITAL MARKETS, RESPECTIVELY. Regulator Statement BRIDGETT FISHER 360-902-8783 i Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMER Initiated By: STATE OF WASHINGTON FINANCIAL INSTITUTIONS SECURITIES DIVISION Date Initiated: 03/24/2009 Docket/Case Number: S08-229-09-CO01

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: 03/24/2009 Sanctions Ordered: Monetary/Fine $491,556.71 Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON 03/27/2009 i Disclosure 101 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES ©2021 FINRA. All rights reserved. Report aboutMISREPRESENTED WELLS FARGO CLEARING THE SALE SERVICES, OF AUCTION LLC RATE SECURITIES TO 214 CUSTOMERS www.finra.org/brokercheck User Guidance

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS Initiated By: STATE OF CALIFORNIA - DEPARTMENT OF CORPORATIONS Date Initiated: 03/09/2009 Docket/Case Number:

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: 03/09/2009 Sanctions Ordered: Monetary/Fine $5,507,824.50 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO ACUTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON 03/13/2009 i Disclosure 102 of 167 Reporting Source: Firm Current Status: Final Allegations: ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: OFFICE OF THE COMMISSIONER OF FINANCIAL INSTITUTIONS COMMONWEALTH OF PUERTO RICO Date Initiated: 03/05/2009 Docket/Case Number: C09-V-001

Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES

©2021Principal FINRA. Sanction(s)/Relief All rights reserved. Report aboutCivil WELLSand Administrative FARGO CLEARING Penalt(ies) SERVICES, /Fine(s) LLC 215 Sought: 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: 03/05/2009 Sanctions Ordered: Monetary/Fine $103,739.22 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: FINE WAS PAID ON 3/11/2009. i Disclosure 103 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: OFFICE OF THE MISSISSIPPI SECRETARY OF STATE Date Initiated: 03/03/2009 Docket/Case Number: S-09-0086

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: 03/03/2009 Sanctions Ordered: Monetary/Fine $317,667.55 Disgorgement/Restitution ©2021 FINRA. All rights reserved. Report aboutCease WELLS and FARGODesist/Injunction CLEARING SERVICES, LLC 216 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $317,667.55 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: FINE WAS PAID ON 3/6/2009. i Disclosure 104 of 167 Reporting Source: Regulator Current Status: Final Allegations: SECTION 17(A) OF THE SEC EXCHANGE ACT, RULES 17A-3 AND 17-4 THEREUNDER, NASD RULES 2110, 3010(A), 3010(B)(1), 3012, 3012(B), 3110 - WACHOVIA SECURITIES, LLC FAILED TO SEND CUSTOMERS CONFIRMATION OF CHANGES IN INVESTMENT OBJECTIVES, AND THUS FAILED TO KEEP RECORDS OF SUCH MAILINGS. THE FIRM ERRONEOUSLY PROGRAMMED ITS COMPUTER SYSTEMS SO THE SYSTEM DID NOT GENERATE A MAILING TO THE CUSTOMER IF THE REQUIRED MAILING DATE FELL ON A WEEKEND OR HOLIDAY WHILE NOTIFYING THE SYSTEM THAT A LETTER HAD BEEN SENT. THE ERRORS WENT UNDETECTED BECAUSE THE FIRM FAILED TO ASSIGN SUPERVISORY REVIEW AND ADEQUATE TESTING OVER ITS AUTOMATED MAILING SYSTEM AND FAILED TO IMPLEMENT INTERNAL CONTROLS TO DETECT AND PREVENT ERRORS. THE FIRM FAILED TO SEND REQUIRED NOTIFICATIONS OF CHANGE IN INVESTMENT OBJECTIVES TO CUSTOMERS AFFECTED BY A MERGER WITH ANOTHER FIRM AND TO KEEP RECORDS REFLECTING THE MAILINGS. THE FIRM SENT DEFECTIVE INVESTMENT OBJECTIVE CHANGE CONFIRMATIONS TO CUSTOMERS AS A RESULT OF PROGRAMMING ERRORS. THE FIRM FAILED TO CONFIRM WITH CUSTOMERS AND TO KEEP RECORDS OF CONFIRMATIONS AND CHANGES OF ADDRESS BY THE CUSTOMERS AND FAILED TO SEND CHANGE OF ADDRESS NOTIFICATIONS TO CUSTOMERS. THIS ERROR WENT UNDETECTED BECAUSE IT FAILED TO IMPLEMENT ADEQUATE SUPERVISORY REVIEW AND TESTING, AS WELL AS IMPLEMENT INTERNAL CONTROLS OVER ITS AUTOMATED MAILING SYSTEM. THE FIRM HAD AN ERROR IN ITS OPERATIONAL PROCEDURES UTILIZED BY EMPLOYEES WHO WERE CONDUCTING MANUAL REVIEWS OF CERTAIN TRANSACTIONS, RESULTING IN ITS FAILURE TO SEND REQUIRED NOTIFICATIONS TO CUSTOMERS WHEN ASSETS WERE TRANSFERRED TO A THIRD-PARTY OR AN OUTSIDE ENTITY. THE FIRM FAILED TO SEND ASSET NOTIFICATIONS TO CUSTOMERS RELATED TO THE PAYMENT OF FEES TO OUTSIDE MONEY MANAGERS. THE FIRM FAILED TO SEND COMPLETE CUSTOMER PROFILE INFORMATION VERIFICATION FORMS TO CUSTOMERS. [CONTINUED IN COMMENTS] ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 217 SECTION 17(A) OF THE SEC EXCHANGE ACT, RULES 17A-3 AND 17-4 THEREUNDER, NASD RULES 2110, 3010(A), 3010(B)(1), 3012, 3012(B), 3110 - WACHOVIA SECURITIES, LLC FAILED TO SEND CUSTOMERS CONFIRMATION OF CHANGES IN INVESTMENT OBJECTIVES, AND THUS FAILED TO KEEP RECORDS OF SUCH MAILINGS. THE FIRM ERRONEOUSLY PROGRAMMED ITS COMPUTER SYSTEMS SO THE SYSTEM DID NOT GENERATE A MAILING TO THE CUSTOMER IF THE REQUIRED MAILING DATE FELL ON A WEEKEND OR HOLIDAY WHILE NOTIFYING THE SYSTEM THAT A LETTER HAD BEEN SENT. THE ERRORS WENT UNDETECTED BECAUSE THE FIRM FAILED TO ASSIGN SUPERVISORY REVIEW AND ADEQUATE TESTING OVER ITS AUTOMATED MAILING SYSTEM AND FAILED TO IMPLEMENT INTERNAL CONTROLS TO DETECT AND PREVENT ERRORS. THE FIRM FAILED TO SEND REQUIRED NOTIFICATIONS OF CHANGE IN INVESTMENT OBJECTIVES TO CUSTOMERS AFFECTED BY A MERGER WITH ANOTHER FIRM AND TO KEEP RECORDS REFLECTING THE MAILINGS. THE FIRM SENT DEFECTIVE INVESTMENT OBJECTIVE CHANGE CONFIRMATIONS TO CUSTOMERS AS A RESULT OF PROGRAMMING ERRORS. THE FIRM FAILED TO CONFIRM WITH CUSTOMERS AND TO KEEP RECORDS OF CONFIRMATIONS AND CHANGES OF ADDRESS BY THE CUSTOMERS AND FAILED TO SEND CHANGE OF ADDRESS NOTIFICATIONS TO CUSTOMERS. THIS ERROR WENT UNDETECTED BECAUSE IT FAILED TO IMPLEMENT ADEQUATE SUPERVISORY REVIEW AND TESTING, AS WELL AS IMPLEMENT INTERNAL CONTROLS OVER ITS AUTOMATED MAILING SYSTEM. THE FIRM HAD AN ERROR IN ITS OPERATIONAL PROCEDURES UTILIZED BY EMPLOYEES WHO WERE CONDUCTING MANUAL REVIEWS OF CERTAIN TRANSACTIONS, RESULTING IN ITS FAILURE TO SEND REQUIRED NOTIFICATIONS TO CUSTOMERS WHEN ASSETS WERE TRANSFERRED TO www.finra.org/brokercheck A THIRD-PARTY OR AN OUTSIDE ENTITY. THE FIRM FAILED TO SEND ASSET User Guidance NOTIFICATIONS TO CUSTOMERS RELATED TO THE PAYMENT OF FEES TO OUTSIDE MONEY MANAGERS. THE FIRM FAILED TO SEND COMPLETE CUSTOMER PROFILE INFORMATION VERIFICATION FORMS TO CUSTOMERS. [CONTINUED IN COMMENTS] Initiated By: FINRA Date Initiated: 02/23/2009 Docket/Case Number: 2007009470901

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/23/2009 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 $1,100,000.00 Other Sanctions Ordered: UNDERTAKINGS: RETAIN, WITHIN 60 DAYS OF NOTICE OF ACCEPTANCE OF THIS AWC, AN INDEPENDENT CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF THE FIRM'S POLICES, PROCEDURES, TESTING AND SYSTEMS ADOPTED IN RESPONSE TO THE ACTIVITY DESCRIBED, TO ENSURE THAT ITS PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULES AND FEDERAL SECURITIES LAWS. AFTER CONCLUSION OF THE REVIEW, THE CONSULTANT SHALL SUBMIT A WRITTEN REPORT TO THE FIRM AND FINRA ADDRESSING THE FIRM'S POLICIES, SYSTEMS, PROCEDURES AND TRAINING. WITHIN 90 DAYS AFTER RECEIPT OF THE WRITTEN REPORT, THE FIRM SHALL ADOPT AND IMPLEMENT THE CONSULTANT'S RECOMMENDATIONS OR PROPOSE ALTERNATIVE PROCEDURES IN WRITING TO THE CONSULTANT AND FINRA. THE CONSULTANT WILL REVIEW AND EVALUATE THE PROPOSED ALTERNATIVES WITHIN 30 DAYS AND PROVIDE A DECISION. THE FIRM WILL ABIDE BY THE CONSULTANT'S DETERMINATIONS AND, WITHIN 30 DAYS, THE FIRM SHALL PROVIDE FINRA WITH A WRITTEN IMPLEMENTATION REPORT SETTING FORTH THE DETAILS OF ITS IMPLEMENTATION OF THE CONSULTANT'S RECOMMENDATIONS. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED ©2021 FINRA. All rights reserved. Report aboutTO THE WELLS DESCRIBED FARGO CLEARING SANCTIONS SERVICES, AND LLC TO THE ENTRY OF FINDINGS; 218 THEREFORE, THE FIRM IS CENSURED, FINED $1,100,000, JOINTLY AND SEVERALLY, AND REQUIRED TO COMPLY WITH UNDERTAKINGS. www.finra.org/brokercheck User Guidance

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 $1,100,000, JOINTLY AND SEVERALLY, AND REQUIRED TO COMPLY WITH UNDERTAKINGS. Regulator Statement THE FORM DISPLAYED "F" AS A NET WORTH CODE, BUT NO CORRESPONDING DOLLAR RANGE APPEARED IN THE FINANCIAL CODE LEGEND AND CUSTOMERS WERE UNABLE TO VERIFY THEIR NET WORTH AMOUNT RECORDED BY THE FIRM. THE FIRM HAD AN INADEQUATE SYSTEM OF SUPERVISION WITH RESPECT TO VARIOUS REQUIRED MAILINGS BECAUSE THE SUPERVISORY SYSTEMS ESTABLISHED WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULES AND FEDERAL SECURITIES LAWS. i Reporting Source: Firm Current Status: Final Allegations: FINRA HAS ALLEGED THAT WACHOVIA SECURITIES, LLC AND FIRST CLEARING, LLC FAILED TO ACCURATELY MAKE CERTAIN CUSTOMER MAILINGS. Initiated By: FINRA Date Initiated: 02/23/2009 Docket/Case Number: 2007009470901

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: 02/23/2009 Sanctions Ordered: Censure Monetary/Fine $1,100,000.00 Other Sanctions Ordered: AN OUTSIDE CONSULTANT SHALL CONDUCT A REVIEW OF THE FIRM'S POLICIES, PROCEDURES, TESTING AND SYSTEMS ADOPTED IN RESPONSE TO THE ACTIVITY DESCRIBED IN THE AWC. Sanction Details: WACHOVIA SECURITIES, LLC AND FIRST CLEARING, LLC JOINTLY CONSENTED TO A FINE OF $1,100,000.00. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 219 www.finra.org/brokercheck User Guidance

WACHOVIA SECURITIES, LLC AND FIRST CLEARING, LLC JOINTLY CONSENTED TO A FINE OF $1,100,000.00. i Disclosure 105 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF GEORGIA COMMISSIONER OF SECURITIES Date Initiated: 02/24/2009 Docket/Case Number: ENSC-1465

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: 02/24/2009 Sanctions Ordered: Monetary/Fine $1,076,276.28 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: FINE IS DUE BY 03/06/2009 i Disclosure 106 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE ©2021 FINRA. All rights reserved. Report aboutSECURITIES WELLS FARGO DIVISION CLEARING SERVICES, LLC 220 www.finra.org/brokercheck User Guidance

Initiated By: STATE OF NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE SECURITIES DIVISION Date Initiated: 02/24/2009 Docket/Case Number: 09SEC029

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: 02/24/2009 Sanctions Ordered: Monetary/Fine $1,700,203.25 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: PAYMENT OF FINE IS DUE BY 03/06/2009 i Disclosure 107 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: MONTANA SECURITIES DEPARTMENT Date Initiated: 02/17/2009 Docket/Case Number: CASE NO. SEC-2009-5

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

Resolution: Consent Resolution Date: 02/17/2009 Sanctions Ordered: Monetary/Fine $148,811.54 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE WAS FINE PAID ON FEBRUARY 19, 2009 i Disclosure 108 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF NEVADA OFFICE OF THE SECRETARY OF STATE SECURITIES DIVISION Date Initiated: 02/17/2009 Docket/Case Number: FILE NO. I09-038

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: 02/17/2009 Sanctions Ordered: Monetary/Fine $839,326.74 Disgorgement/Restitution ©2021 FINRA. All rights reserved. Report aboutCease WELLS and FARGODesist/Injunction CLEARING SERVICES, LLC 222 www.finra.org/brokercheck User Guidance

Monetary/Fine $839,326.74 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON FEBRUARY 24, 2009 i Disclosure 109 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE AND REGULATION DIVISION OF SECURITIES Date Initiated: 02/19/2009 Docket/Case Number: ADMINISTRATIVE CONSENT ORDER

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: 02/19/2009 Sanctions Ordered: Monetary/Fine $155,069.08 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: THE FINE WAS PAID ON FEBRUARY 25, 2009 i Disclosure 110 of 167 Reporting Source: Firm ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 223 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS Initiated By: ATTORNEY GENERAL OF THE STATE OF NEW YORK INVESTOR PROTECTION BUREAU Date Initiated: 02/04/2009 Docket/Case Number: ASSURANCE NO. 08-179

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: 02/04/2009 Sanctions Ordered: Monetary/Fine $50,000,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS Sanction Details: PAYMENT IS DUE TO STATE OF NEW YORK BY MARCH 31, 2009 i Disclosure 111 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: COMMON WEALTH OF MASSACHUSETTS SECURITIES DIVISION Date Initiated: 02/19/2009 Docket/Case Number: E-2008-0053

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: 02/19/2009 Sanctions Ordered: Monetary/Fine $782,321.56 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANT CLASS. Sanction Details: THE FINE WAS PAID ON FEBRUARY 24, 2009 i Disclosure 112 of 167 Reporting Source: Firm Current Status: Final Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TO CUSTOMERS. Initiated By: OFFICE OF THE SECRETARY OF STATE STATE OF MISSOURI Date Initiated: 12/08/2008 Docket/Case Number: AP-08-28

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: 12/08/2008 Sanctions Ordered: Monetary/Fine $2,841,550.88 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS. Sanction Details: IN ADDITION TO TO THE FINE PAID ON 12/16/2008 IN THE AMOUNT OF $2,841,550.88. WACHOVIA SHALL PAY $265,000 AS COST FOR THE INVESTIGATION. $15,000 SHALL BE PAID TO NASAA. i Disclosure 113 of 167 Reporting Source: Regulator Current Status: Final Allegations: IN CONNECTION WITH RESPONDENT'S (AND RESPONDENT'S PREDECESSOR'S) EMPLOYMENT OF BROKER MILLIET K. LANHAM, RESPONDENT FAILED TO REASONABLY SUPERVISE WITHIN THE MEANING OF SECTION 11-412(A)(10) OF THE SECURITIES ACT. Initiated By: MARYLAND Date Initiated: 01/01/2006 Docket/Case Number: 2008-0268 URL for Regulatory Action: Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief FINE Sought: COMPLIANCE UNDERTAKINGS

Resolution: Stipulation and Consent Resolution Date: 12/08/2008 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 226 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 $50,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: RESTITUTION TO ONE CUSTOMER IN AMOUNT OF $109,673. SUPERVISING BROKER MUST TAKE CERTAIN CONTINUING EDUCATION COURSES DEALING WITH SUPERVISION WITHIN SIX MONTHS OF EXECUTION OF ORDER. COMPLIANCE ENHANCEMENTS AND UNDERTAKINGS TO BE PERFORMED. Sanction Details: FINE = $50,000 PAID UPON ISSUANCE OF ORDER. NO PORTION OF PENALTY WAS WAIVED. Regulator Statement CONSENT ORDER REFERRED TO FORMER BROKER'S HANDLING OF CERTAIN CUSTOMER ACCOUNTS. SOME CUSTOMERS WERE INVOLVED IN PRIVATE SETTLEMENT OF CLAIMS. ONE CUSTOMER, B.L., RECEIVED RESTITUTION PURSUANT TO THE TERMS OF THE CONSENT ORDER IN CONNECTION WITH BROKER'S HANDLING OF HER ACCOUNT. i Reporting Source: Firm Current Status: Final Allegations: IN CONNECTION WITH RESPONDENT'S (AND RESPONDENT'S PREDECESSOR'S) EMPLOYMENT OF BROKER MILLIET K. LANHAM, RESPONDENT FAILED TO REASONABLY SUPERVISE WITHIN THE MEANING OF SECTION 11-412(A)(10) OF THE SECURITIES ACT. Initiated By: STATE OF MARYLAND Date Initiated: 01/01/2006 Docket/Case Number: 2008-0268

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

Resolution: Stipulation and Consent Resolution Date: 12/08/2008 Sanctions Ordered: Monetary/Fine $50,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: RESTITUTION TO ONE CUSTOMER IN AMOUNT OF $109,673. SUPERVISING BROKER MUST TAKE CERTAIN CONTINUING EDUCATION COURSES DEALING WITH SUPERVISION WITHIN SIX MONTHS OF EXECUTION OF ORDER. COMPLIANCE ENHANCEMENTS AND UNDERTAKINGS TO BE PERFORMED. Sanction Details: FINE = $50,000 PAID UPON ISSUANCE OF ORDER. NO PORTION OF PENALTY WAS WAIVED. Firm Statement CONSENT ORDER REFERRED TO FORMER BROKER'S HANDLING OF CERTAIN CUSTOMER ACCOUNTS. SOME CUSTOMERS WERE INVOLVED IN PRIVATE SETTLEMENT OF CLAIMS. ONE CUSTOMER, B.L., RECEIVED RESTITUTION PURSUANT TO THE TERMS OF THE CONSENT ORDER IN CONNECTION WITH BROKER'S HANDLING OF HER ACCOUNT. i Disclosure 114 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 1021, 1022(A)(1), 1022(A)(5), 2110, 3010: RESPONDENT MEMBER FIRM PERMITTED INDIVIDUAL TO FUNCTION AS A PRINCIPAL WITHOUT BEING PROPERLY LICENSED AS A GENERAL SECURITIES PRINCIPAL ("GP") AND PERMITTED AN INDIVIDUAL TO SUPERVISE ITS EQUITY RESEARCH ANALYSTS WITHOUT BEING PROPERLY LICENSED AS A RESEARCH PRINCIPAL ("RP"). THE FIRM ALSO FAILED TO ENSURE THAT A GP OR RP MANAGE AND SUPERVISE THE FIRM'S ADVISORY SERVICES GROUP BY FAILING TO ENSURE THAT INDIVIDUAL BE PROPERLY LICENSED. Initiated By: FINRA Date Initiated: 10/30/2008 Docket/Case Number: 2007010115401

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: 10/30/2008 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $75,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBER FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $75,000. i Reporting Source: Firm Current Status: Final Allegations: NASD RULES 1021, 1022(A)(1), 1022(A)(5), 2110, 3010: RESPONDENT MEMBER FIRM PERMITTED INDIVIDUAL TO FUNCTION AS A PRINCIPAL WITHOUT BEING PROPERLY LICENSED AS A GENERAL SECURITIES PRINCIPAL ("GP") AND PERMITTED AN INDIVIDUAL TO SUPERVISE ITS EQUITY RESEARCH ANALYSTS WITHOUT BEING PROPERLY LICENSED AS A RESEARCH PRINCIPAL ("RP"). THE FIRM ALSO FAILED TO ENSURE THAT A GP OR RP MANAGE AND SUPERVISE THE FIRM'S ADVISORY SERVICES GROUP BY FAILING TO ENSURE THAT INDIVIDUAL BE PROPERLY LICENSED. Initiated By: FINRA Date Initiated: 10/30/2008 Docket/Case Number: 2007010115401

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 WELLS FARGO CLEARING SERVICES, LLC 229 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/30/2008 Sanctions Ordered: Censure Monetary/Fine $75,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBER FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $75,000. i Disclosure 115 of 167 Reporting Source: Regulator Current Status: Final Allegations: AG EDWARDS PERMITTED AN UNREGISTERED PERSON TO USE BRANCH OFFICE FACILITIES TO FACILITATE THE REFERAL AND TRANSFER OF CLIENT FROM PREVIOUS BROKER-DEALER TO AG EDWARDS THROUGH HIS FORMER PARTNER NOW AN AG EDWARDS AGENT. AG EDWARDS DID NOT SUPERVISE NOR EMPLOY THE INDIVIDUAL IN ANY CAPACITY AND PERMITTED THE UNREGISTERED PERSON TO TRANSACT SECURITIES THROUGH HIS FORMER PARTNER. Initiated By: NEW JERSEY BUREAU OF SECURITIES Date Initiated: 03/28/2007 Docket/Case Number: 2007-010 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: 10/06/2008 Does the order constitute a No final order based on ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 230 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 $400,000.00 Disgorgement/Restitution Other Sanctions Ordered: WACHOVIA WILL OFFER NO LESS THAN $120,000, RESTITUTION TO COMPENSATE FOR THE LOSSES OF CERTAIN CUSTOMERS. Sanction Details: AG EDWARDS ALLOWED AN UNREGISTERED PERSON TO MAINTAIN A PRESENCE IN A NEW JERSEY BRANCH OFFICE AND PROVIDE INVESTMENT ADVISE TO CLIENTS. AG EDWARDS FAILED TO PREVENT UNSUITABLE TRADING STRATEGIES FROM BEING RECOMMENDED TO AG EDWARDS CLIENTS A FAILED TO REASONABLY SUPERVISE AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DEFECT AND PREVENT SUCH CONDUCT. i Reporting Source: Firm Current Status: Final Allegations: AG EDWARDS PERMITTED AN UNREGISTERED PERSON TO USE BRANCH OFFICE FACILITIES TO FACILITATE THE REFERAL AND TRANSFER OF CLIENT FROM PREVIOUS BROKER-DEALER TO AG EDWARDS THROUGH HIS FORMER PARTNER A FORMER AG EDWARDS AGENT. AG EDWARDS DID NOT SUPERVISE NOR EMPLOY THE INDIVIDUAL IN ANY CAPACITY AND PERMITTED THE UNREGISTERED PERSON TO TRANSACT SECURITIES THROUGH HIS FORMER PARTNER Initiated By: NEW JERSEY BUREAU OF SECURITIES Date Initiated: 03/28/2007 Docket/Case Number: 2007-010

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: 10/06/2008 Sanctions Ordered: Monetary/Fine $400,000.00 Disgorgement/Restitution Other Sanctions Ordered: WACHOVIA WILL OFFER NO LESS THAN $120,000, RESTITUTION TO COMPENSATE FOR THE LOSSES OF CERTAIN CUSTOMERS. Sanction Details: AG EDWARDS ALLOWED AN UNREGISTERED PERSON TO MAINTAIN A PRESENCE IN A NEW JERSEY BRANCH OFFICE AND PROVIDE INVESTMENT ADVISE TO CLIENTS. AG EDWARDS FAILED TO PREVENT UNSUITABLE TRADING STRATEGIES FROM BEING RECOMMENDED TO AG EDWARDS CLIENTS, FAILED TO REASONABLY SUPERVISE AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DEFECT PREVENT SUCH CONDUCT. i Disclosure 116 of 167 Reporting Source: Firm Current Status: Final Allegations: ON AUGUST 11, 2008, WACHOVIA SECURITIES RECEIVED AN ORDER TO SHOW CAUSE FROM THE STATE OF SOUTH DAKOTA DATED AUGUST 7, 2008, COMMENCING DISCIPLINARY PROCEEDINGS AGAINST THE FIRM BASED ON THE STATE'S INVESTIGATION OF TWO SEPARATE CUSTOMER SALES PRACTICE COMPLAINTS. Initiated By: STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE & REGULATION DIVISION OF SECURITIES Date Initiated: 08/07/2008 Docket/Case Number: N/A

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief ORDER TO SHOW CAUSE Sought:

Resolution: Consent Resolution Date: 08/08/2009 Sanctions Ordered: Monetary/Fine $21,000.00 Other Sanctions Ordered: THE FIRM AGREED TO PAY THE STATE $20,000 FOR THE COSTS OF THE ©2021 FINRA. All rights reserved. Report aboutINVESTIGATION. WELLS FARGO CLEARING SERVICES, LLC 232 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: THE FIRM AGREED TO PAY THE STATE $20,000 FOR THE COSTS OF THE INVESTIGATION. Sanction Details: THE FIRM AGREED TO THE FOLLOWING ADDITIONAL CONDITIONS: (1) WELLS FARGO ADVISORS ("WFA") TO PROVIDE ANNUITY WORKSHEETS IN LIEU OF BROKER NOTES FOR THE THREE FAS UNDER REVIEW AND TO PLACE FAS ON HEIGHTENED SUPERVISION FOR ONE YEAR; (2) WFA TO PROVIDE THE STATE WITH QUARTERLY HEIGHTENED SUPERVISION CHECKLIST; (3) WFA TO PERMIT UNANNOUNCED REVIEWS OF WFA SOUTH DAKOTA OFFICES AND TO PERMIT RANDOM CLIENT CONTACTS; (4) WFA TO PROVIDE THE STATE WITH DATE TIME & LOCATION OF FA SEMINARS; (5) FA JOSEPH WOOD TO COMPLETE ADDITIONAL TRAINING WITHIN 90 DAYS OF CONSENT ORDER ENTRY. Firm Statement BY LETTER DATED 9/1/2010 WFA NOTIFIED THE STATE THAT IT HAD COMPLETED ALL OF ITS OBLIGATIONS UNDER THE CONSENT ORDER. i Disclosure 117 of 167 Reporting Source: Firm Current Status: Final Allegations: THE FIRM THROUGH A REGISTERED REPRESENTATIVE AND OTHERS ALLOWED THE CLIENT'S WIFE TO EFFECT THE WITHDRAWALS FROM A CUSTOMER'S ACCOUNT WITHOUT THE REQUIRED DOCUMENTS AS REQUIRED BY A.G. EDWARDS WRITTEN PROCEDURES. Initiated By: TEXAS STATE SECURITIES BOARD Date Initiated: 07/14/2008 Docket/Case Number: IC08-CAF-05

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

Resolution: Order Resolution Date: 07/14/2008 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: WITHIN 30 DAYS EDWARDS WILL MAKE A GOOD FAITH AND BINDING SETTLEMENT OFFER OF AT LEAST $10,000.00 AND PROVIDE THE DIVISION ©2021 FINRA. All rights reserved. Report aboutWITH WELLS A COPY FARGO OF CLEARING THE OFFER. SERVICES, LLC 233 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: WITHIN 30 DAYS EDWARDS WILL MAKE A GOOD FAITH AND BINDING SETTLEMENT OFFER OF AT LEAST $10,000.00 AND PROVIDE THE DIVISION WITH A COPY OF THE OFFER. Sanction Details: REPRIMAND AND $5000 FINE. i Disclosure 118 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 2310, 3010: WACHOVIA SECURITIES DID NOT ADEQUATELY CONSIDER, ON A CONSISTENT BASIS, PERTINENT ELEMENTS, SUCH AS BREAKPOINTS, FEES AND EXPENSES, WHEN MAKING RECOMMENDATIONS TO CUSTOMERS TO PURCHASE CLASS B OR CLASS C SHARES IN MUTUAL FUNDS INSTEAD OF CLASS A SHARES. WACHOVIA SECURITIES RECOMMENDED AND SOLD CLASS B AND/OR CLASS C SHARES TO CUSTOMERS WHO, DEPENDING UPON AMONG OTHER THINGS, THE AMOUNT OF THE INVESTMENT AND THE CUSTOMER'S CONTEMPLATED HOLDING PERIOD, WOULD HAVE BENEFITED HAD THEY PURCHASED CLASS A SHARES INSTEAD. AS A RESULT, WACHOVIA RECEIVED GREATER COMMISSIONS TOTALING $3.86 MILLION MORE THAT IT WOULD HAVE RECEIVED HAD IT SOLD CLASS A SHARES IN THE SAME MUTUAL FUNDS. WACHOVIA FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATE SUPERVISORY AND COMPLIANCE POLICIES AND PROCEDURES THAT WERE REASONABLY DESIGNED TO IDENTIFY PURCHASES OF CLASS B AND/OR CLASS C SHARES BY CUSTOMERS FOR WHOM CLASS A SHARES WOULD HAVE BEEN MORE ECONOMICALLY BENEFICIAL, NOR WERE THE FIRM'S PROCEDURES SUFFICIENT ENOUGH TO ENSURE THAT REGISTERED REPRESENTATIVES MADE ADEQUATE DISCLOSURES TO CUSTOMERS ABOUT THE VARIOUS CLASSES OF MUTUAL FUNDS. WACHOVIA FAILED TO ENSURE THAT ELIGIBLE INVESTORS RECEIVED THE BENEFIT OF AVAILABLE NET ASSET VALUE (NAV) TRANSFER PROGRAMS, RESULTING IN CUSTOMERS INCURRING FRONT-END SALES CHARGES THEY SHOULD NOT HAVE PAID, OR PURCHASED OTHER SHARE CLASSES THAT UNNECESSARILY SUBJECTED THEM TO HIGHER FEES AND THE POTENTIAL OF CONTINGENT DEFERRED SALES CHARGES. WACHOVIA FAILED TO EXERCISE REASONABLE DUE DILIGENCE TO IDENTIFY ESSENTIAL TERMS AND CONDITIONS OF THE NAV TRANSFER PROGRAMS OF CERTAIN MUTUAL FUNDS, AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCE SYSTEMS AND PROCEDURES TO ENSURE THAT ITS CUSTOMERS RECEIVED THE BENEFIT OF NAV PRICING WHEN THEY QUALIFIED. [CONTINUED IN COMMENTS] Initiated By: FINRA Date Initiated: 02/12/2009 Docket/Case Number: E9A2005013001 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 234 www.finra.org/brokercheck User Guidance

Docket/Case Number: E9A2005013001

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/12/2009 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 $4,410,000.00 Other Sanctions Ordered: UNDERTAKINGS: WACHOVIA WILL UNDERTAKE TO PROVIDE REMEDIATION TO CUSTOMERS WHO PURCHASED CLASS B AND/OR CLASS C SHARES OF MUTUAL FUNDS WHEN THE PURCHASE OF CLASS A SHARES WOULD HAVE BEEN MORE BENEFICIAL, EXCLUDING CUSTOMERS WHO SETTLED, CANCELLED THEIR PURCHASES, WERE NOT SUBJECT TO HIGHER CHARGES OR FEES THAN CLASS A SHARES, WERE NOT ELIGIBLE FOR BREAKPOINTS, OR WHERE THERE WAS NO DISCERNABLE MATERIAL BENEFIT IN PURCHASING CLASS A SHARES OVER CLASS B AND/OR CLASS C SHARES. WITHIN 120 DAYS, WACHOVIA WILL PROVIDE CURRENT CLASS B AND CLASS C SHARE OWNERS THE OPTION TO CONVERT TO CLASS A SHARE OWNERSHIP. WACHOVIA WILL ALSO PROVIDE REMEDIATION TO CUSTOMERS WHO PURCHASED SHARES OF MUTUAL FUNDS AND QUALIFIED FOR, BUT DID NOT RECEIVE, THE BENEFIT OF A NAV TRANSFER PROGRAM, INCLUDING REFUND OF INITIAL SALES CHARGE PLUS INTEREST AND VARIOUS FEES AND EXPENSES. THE REMEDIATION PLAN INCLUDES QUALIFYING CLASS B AND/OR CLASS C SHARES THAT ALSO QUALIFY FOR NAV PURCHASES. WITHIN 60 DAYS OF ACCEPTANCE OF THE AWC, WACHOVIA WILL PROVIDE FINRA WITH A SAMPLE LETTERS TO CUSTOMERS: 1) WISHING TO CONVERT CLASS B AND CLASS C SHARES INTO CLASS A SHARES THE OFFER, AN EXPLANATION OF THE ADVANTAGES AND DISADVANTAGES, AND ADVICE TO CONSULT A TAX ADVISOR; AND 2) WHO DID NOT RECEIVE THE BENEFITS OF THE NAV TRANSFER PROGRAM DETAILING REMEDIATION PAYMENTS. ALSO, WITHIN 60 SAYS, WACHOVIA WILL TRAIN STAFF TO FIELD CUSTOMER INQUIRES, ©2021 FINRA. All rights reserved. Report aboutRETAIN WELLS A FARGOTHIRD-PARTY CLEARING EXAMINER SERVICES, LLC TO EXAMINE THE FIRM'S 235 PERFORMANCE OF ITS OBLIGATIONS UNDER THE TERMS OF THE AWC, BEAR THE EXAMINER'S COSTS AND COOPERATE WITH THE EXAMINER. WACHOVIA SHALL COMPLETE THE REMEDIATION PROCESS WITHIN 270 DAYS OF THE AWC AND WITHIN 330 DAYS OF THE EFFECTIVE DATE OF THE AWC FILED A DETAILED REPORT WITH FINRA REGARDING THE RESULTS OF THE REMEDIATION PLAN. THE THIRD PARTY EXAMINER SHALL FILE A FINAL REPORT NO LATER THAN 420 DAYS AFTER THE EFFECTIVE DATE OF THE AWC. UNDERTAKINGS: WACHOVIA WILL UNDERTAKE TO PROVIDE REMEDIATION TO CUSTOMERS WHO PURCHASED CLASS B AND/OR CLASS C SHARES OF MUTUAL FUNDS WHEN THE PURCHASE OF CLASS A SHARES WOULD HAVE BEEN MORE BENEFICIAL, EXCLUDING CUSTOMERS WHO SETTLED, CANCELLED THEIR PURCHASES, WERE NOT SUBJECT TO HIGHER CHARGES OR FEES THAN CLASS A SHARES, WERE NOT ELIGIBLE FOR BREAKPOINTS, OR WHERE THERE WAS NO DISCERNABLE MATERIAL BENEFIT IN PURCHASING CLASS A SHARES OVER CLASS B AND/OR CLASS C SHARES. WITHIN 120 DAYS, WACHOVIA WILL PROVIDE CURRENT CLASS B AND CLASS C SHARE OWNERS THE OPTION TO CONVERT TO CLASS A SHARE OWNERSHIP. WACHOVIA WILL ALSO PROVIDE REMEDIATION TO CUSTOMERS WHO PURCHASED SHARES OF MUTUAL FUNDS AND QUALIFIED FOR, BUT DID NOT RECEIVE, THE BENEFIT OF A NAV TRANSFER PROGRAM, INCLUDING REFUND OF INITIAL SALES CHARGE PLUS INTEREST AND VARIOUS FEES AND EXPENSES. THE REMEDIATION PLAN INCLUDES QUALIFYING CLASS B AND/OR CLASS C SHARES THAT ALSO QUALIFY FOR NAV PURCHASES. WITHIN 60 DAYS OF ACCEPTANCE OF THE AWC, WACHOVIA WILL PROVIDE FINRA WITH A SAMPLE LETTERS TO CUSTOMERS: 1) WISHING TO CONVERT CLASS B AND CLASS C SHARES www.finra.org/brokercheck INTO CLASS A SHARES THE OFFER, AN EXPLANATION OF THE User Guidance ADVANTAGES AND DISADVANTAGES, AND ADVICE TO CONSULT A TAX ADVISOR; AND 2) WHO DID NOT RECEIVE THE BENEFITS OF THE NAV TRANSFER PROGRAM DETAILING REMEDIATION PAYMENTS. ALSO, WITHIN 60 SAYS, WACHOVIA WILL TRAIN STAFF TO FIELD CUSTOMER INQUIRES, RETAIN A THIRD-PARTY EXAMINER TO EXAMINE THE FIRM'S PERFORMANCE OF ITS OBLIGATIONS UNDER THE TERMS OF THE AWC, BEAR THE EXAMINER'S COSTS AND COOPERATE WITH THE EXAMINER. WACHOVIA SHALL COMPLETE THE REMEDIATION PROCESS WITHIN 270 DAYS OF THE AWC AND WITHIN 330 DAYS OF THE EFFECTIVE DATE OF THE AWC FILED A DETAILED REPORT WITH FINRA REGARDING THE RESULTS OF THE REMEDIATION PLAN. THE THIRD PARTY EXAMINER SHALL FILE A FINAL REPORT NO LATER THAN 420 DAYS AFTER THE EFFECTIVE DATE OF THE AWC. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WACHOVIA SECURITIES CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $4,410,000 AND REQUIRED TO UNDERTAKE A REMEDIATION PLAN. Regulator Statement [CONTINUED] WACHOVIA FAILED TO APPLY CORRECTLY ROLLOVER AND BREAKPOINT DISCOUNTS IN CONNECTION WITH UNIT INVESTMENT TRUSTS (UIT) PURCHASES BY CUSTOMERS, RESULTING IN ADDITIONAL AND EXCESSIVE SALES CHARGES TOTALING $1.976 MILLION AND $735,000 RESPECTIVELY. WACHOVIA HAD NOTICE THAT THE PROPER APPLICATION OF ROLLOVER AND BREAKPOINT DISCOUNTS TO ELIGIBLE UIT PURCHASES BY CUSTOMERS CONSTITUTED A COMPLIANCE MATTER THAT NECESSITATED ITS PROMPT AND DILIGENT ATTENTION, BUT DID NOT PROMPTLY UNDERTAKE OR PERFORM ANY REVIEW, TESTING OR ANALYSIS TO DETERMINE IF THE FIRM WAS PROPERLY IDENTIFYING AND APPLYING ROLLOVER AND BREAKPOINT DISCOUNTS IN CONNECTION WITH THE SALES OF UITS, THEREBY FAILING TO PROVIDE ALL CUSTOMERS THE BENEFIT OF SALES CHARGE DISCOUNTS. WACHOVIA FAILED TO ESTABLISH, MAINTAIN AND IMPLEMENT A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES THAT WERE REASONABLY DESIGNED TO ENSURE THAT SALES CHARGE DISCOUNTS WERE CORRECTLY APPLIED AND PROVIDE SUBSTANTIVE GUIDELINES, INSTRUCTIONS, POLICIES AND PROCEDURES OR STEPS THAT REPRESENTATIVES AND/OR MANAGERS WERE OBLIGATED TO TAKE OR PERFORM IN EFFECTING UIT PURCHASES FOR CUSTOMERS TO DETERMINE IF THE PURCHASE QUALIFIED FOR A DISCOUNT AND/OR TO ENSURE CUSTOMERS RECEIVED THE BENEFIT OF ANY APPLICABLE SALES CHARGE DISCOUNT. i Reporting Source: Firm Current Status: Final Allegations: ALLEGATIONS THAT THE FIRM (1) MADE RECOMMENDATIONS THROUGH ITS REGISTERED REPRESENTATIVES TO CUSTOMERS TO PURCHASE CLASS B AND CLASS C MUTUAL FUND SHARES WHERE AN EQUAL ©2021 FINRA. All rights reserved. Report aboutINVESTMENT WELLS FARGO IN CLEARINGCLASS A SERVICES,SHARES LLCWOULD HAVE BEEN MORE 236 ADVANTAGEOUS FOR CERTAIN CLIENTS IN VIOLATION OF NASD RULE 2310, (2) DID NOT PROVIDE CERTAIN ELIGIBLE CUSTOMERS WITH THE BENEFIT OF NAV TRANSFER PROGRAMS IN CONNECTION WITH MUTUAL FUND PURCHASES AND SALES DISCOUNTS IN CONNECTION WITH PURCHASES OF UNIT INVESTMENT TRUSTS ("UIT") AND (3) FAILED TO ESTABLISH, MAINTAIN AND ENFORCE SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED (A) TO PROVIDE CONSIDERATION, ON A CONSISTENT BASIS, OF THE BENEFITS OF VARIOUS MUTUAL FUND CLASSES AS THEY APPLIED TO INDIVIDUAL CUSTOMERS, (B) TO IDENTIFY OPPORTUNITIES FOR INVESTORS TO PURCHASE MUTUAL FUNDS AT NAV AND (C) TO ENSURE THAT SALES CHARGE DISCOUNTS WERE APPLIED TO ELIGIBLE UIT PURCHASES BY CUSTOMERS IN VIOLATION OF NASD RULES 2110 AND 3010. www.finra.org/brokercheck User Guidance

ALLEGATIONS THAT THE FIRM (1) MADE RECOMMENDATIONS THROUGH ITS REGISTERED REPRESENTATIVES TO CUSTOMERS TO PURCHASE CLASS B AND CLASS C MUTUAL FUND SHARES WHERE AN EQUAL INVESTMENT IN CLASS A SHARES WOULD HAVE BEEN MORE ADVANTAGEOUS FOR CERTAIN CLIENTS IN VIOLATION OF NASD RULE 2310, (2) DID NOT PROVIDE CERTAIN ELIGIBLE CUSTOMERS WITH THE BENEFIT OF NAV TRANSFER PROGRAMS IN CONNECTION WITH MUTUAL FUND PURCHASES AND SALES DISCOUNTS IN CONNECTION WITH PURCHASES OF UNIT INVESTMENT TRUSTS ("UIT") AND (3) FAILED TO ESTABLISH, MAINTAIN AND ENFORCE SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED (A) TO PROVIDE CONSIDERATION, ON A CONSISTENT BASIS, OF THE BENEFITS OF VARIOUS MUTUAL FUND CLASSES AS THEY APPLIED TO INDIVIDUAL CUSTOMERS, (B) TO IDENTIFY OPPORTUNITIES FOR INVESTORS TO PURCHASE MUTUAL FUNDS AT NAV AND (C) TO ENSURE THAT SALES CHARGE DISCOUNTS WERE APPLIED TO ELIGIBLE UIT PURCHASES BY CUSTOMERS IN VIOLATION OF NASD RULES 2110 AND 3010. Initiated By: FINRA Date Initiated: 02/12/2009 Docket/Case Number: E9A2005013001

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: 02/12/2009 Sanctions Ordered: Censure Monetary/Fine $4,410,000.00 Other Sanctions Ordered: UNDERTAKINGS THAT INCLUDE REMEDIATION TO CERTAIN CUSTOMERS WHO DURING THE PERIOD (A) FROM JANUARY 1, 2002 THROUGH DECEMBER 31, 2004, PURCHASED SHARES OF MUTUAL FUNDS AND QUALIFIED FOR, BUT DID NOT RECEIVE, THE BENEFIT OF AN NAV TRANSFER PROGRAM AND (B) FROM JANUARY 1, 2003 THROUGH THE NOTICE OF ACCEPTANCE OF THIS AWC, PURCHASED CLASS B AND CLASS C MUTUAL FUND SHARES. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AS OUTLINE ABOVE. IN DETERMINING APPROPRIATE SANCTIONS, FINRA CONSIDERED THE FIRM'S PROACTIVE REMEDIAL ACTIONS TAKEN UPON DURING ITS DISCOVERY OF -AND BEFORE FINRA'S ©2021 FINRA. All rights reserved. Report aboutINQUIRY WELLS INTO FARGO - CERTAINCLEARING SERVICES,VIOLATIVE LLC CONDUCT. AFTER IDENTIFYING 237 FAILURES TO PROVIDE CERTAIN CUSTOMERS WITH NAV PRICING AND UIT SALES DISCOUNTS, THE FIRM ACTED PROMPTLY AND IN GOOD FAITH TO REPAY CUSTOMERS APPROXIMATELY $5.4 MILLION AND CORRECT ITS SYSTEMS AND PROCEDURES. www.finra.org/brokercheck WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED User Guidance TO THE SANCTIONS AS OUTLINE ABOVE. IN DETERMINING APPROPRIATE SANCTIONS, FINRA CONSIDERED THE FIRM'S PROACTIVE REMEDIAL ACTIONS TAKEN UPON DURING ITS DISCOVERY OF -AND BEFORE FINRA'S INQUIRY INTO - CERTAIN VIOLATIVE CONDUCT. AFTER IDENTIFYING FAILURES TO PROVIDE CERTAIN CUSTOMERS WITH NAV PRICING AND UIT SALES DISCOUNTS, THE FIRM ACTED PROMPTLY AND IN GOOD FAITH TO REPAY CUSTOMERS APPROXIMATELY $5.4 MILLION AND CORRECT ITS SYSTEMS AND PROCEDURES. i Disclosure 119 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULE 6230 - WACHOVIA SECURITIES, LLC FAILED TO REPORT TO TRACE THE CORRECT REPORTING MARKET PARTICIPANT IDENTIFIER (MPID) FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. Initiated By: FINRA Date Initiated: 02/26/2008 Docket/Case Number: 20050001452-03

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/26/2008 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: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM HAS ENTERED INTO AN ACCEPTANCE, WAIVER AND CONSENT WITH FINRA CONCERNING CERTAIN FINDINGS REGARDING COMPLIANCE WITH TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) RULES DURING THE PERIOD JULY 1, 2004 THROUGH SEPTEMBER 30, 2004. THESE FINDINGS INVOLVED FAILING TO REPORT THE CORRECT MPID IN TRACE-ELIGIBLE SECURITIES. THE FIRM HAS CONSENTED TO A FINE OF $7,500. Initiated By: FINRA Date Initiated: 02/26/2008 Docket/Case Number: 20050001452-03

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/26/2008 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 SANCTION AND TO THE ENTRY OF FINDINGS; THE FIRM WAS FINED $7,500. i Disclosure 120 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 6230, 6230(A) - WACHOVIA SECURITIES FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES EXECUTED ON A BUSINESS DAY DURING TRACE SYSTEM HOURS WITHIN 15 MINUTES OF ©2021 FINRA. All rights reserved. Report aboutTHE WELLS TIME FARGOOF EXECUTION; CLEARING SERVICES, AND REPORTED LLC TO TRACE TRANSACTIONS IN 239 TRACE-ELIGIBLE SECURITIES THAT IT WAS NOT REQUIRED TO REPORT. www.finra.org/brokercheck User Guidance NASD RULES 6230, 6230(A) - WACHOVIA SECURITIES FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES EXECUTED ON A BUSINESS DAY DURING TRACE SYSTEM HOURS WITHIN 15 MINUTES OF THE TIME OF EXECUTION; AND REPORTED TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS NOT REQUIRED TO REPORT. Initiated By: FINRA Date Initiated: 01/25/2008 Docket/Case Number: 20050032155-01

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/25/2008 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: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM HAS ENTERED INTO AN ACCEPTANCE, WAIVER AND CONSENT WITH FINRA CONCERNING CERTAIN FINDINGS REGARDING COMPLIANCE WITH TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) RULES DURING THE PERIOD JULY 1, 2005 THROUGH SEPTEMBER 30, 2005. THESE FINDINGS INVOLVED FAILING TO REPORT 1,434 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF TIME OF EXECUTION, AND OVER- REPORTING 4,008 TRANSACTIONS THAT WAS NOT REQUIRED TO BE ©2021 FINRA. All rights reserved. Report aboutREPORTED. WELLS FARGO THE CLEARING FIRM HAS SERVICES, CONSENTED LLC TO A FINE OF $5,000. 240 WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM HAS ENTERED INTO AN ACCEPTANCE, WAIVER AND CONSENT WITH FINRA CONCERNING CERTAIN FINDINGS REGARDING COMPLIANCE WITH TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) RULES DURING THE www.finra.org/brokercheck PERIOD JULY 1, 2005 THROUGH SEPTEMBER 30, 2005. THESE FINDINGS User Guidance INVOLVED FAILING TO REPORT 1,434 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF TIME OF EXECUTION, AND OVER- REPORTING 4,008 TRANSACTIONS THAT WAS NOT REQUIRED TO BE REPORTED. THE FIRM HAS CONSENTED TO A FINE OF $5,000. Initiated By: FINRA Date Initiated: 01/25/2008 Docket/Case Number: 20050032155-01

Principal Product Type: Other Other Product Type(s): TRACE-ELIGIBLE 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: 01/25/2008 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; THE FIRM WAS FINED $5,000. i Disclosure 121 of 167 Reporting Source: Regulator Current Status: Final Allegations: ORDER OF DISMISSAL PURSUANT TO SETTLEMENT AGREEMENT. WACHOVIA SECURITIES, LLC PAID A $50,000 MONETARY AMOUNT AND AGREED TO TAKE CERTAIN REMEDIAL MEASURES. THE MATTER WAS SETTLED WITHOUT ANY SANCTIONS AGAINST MS. WIEGAND. Initiated By: ILLINOIS Date Initiated: 01/04/2008 Docket/Case Number: 0600669 URL for Regulatory Action: Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 241 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief NOTICE OF HEARING Sought: 1) REVOCATION OR SUSPENSION OF SALESPERSON AND/OR DEALER REGISTRATION

2) ORDER OF PROHIBITION AGAINST OFFER AND SALE OF SECURITIES

3) $10,000 FINE PER VIOLATION

Resolution: Order Resolution Date: 06/18/2009 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 $50,000.00 Other Sanctions Ordered: UNDER TOOK CHANGES TO TRAINING AND COMPLIANCE RELATED TO PROHIBITED TRANSACTIONS UNDER ERISA Sanction Details: ORDER OF DISMISSAL Regulator Statement SECOND NOTICE OF HEARING WAS ISSUED JANUARY 4, 2008. THE HEARING IS SCHEDULED FOR APRIL 15, 2008. ORDER OF DISMISSAL WAS ISSUED JUNE 18, 2009. CONTACT (217) 785-4947 i Reporting Source: Firm Current Status: Final Allegations: FAILURE TO SUPERVISE DECEPTIVE OR FRAUDULENT SECURITIES TRANSACTIONS. **AMENDED NOTICE OF HEARING SECURITIES FRAUD. ALLEGATIONS ADDED 1/4/2008 - AMENDED NOTICE OF HEARING SECURITIES FRAUD 1) SUZANNE WIEGAND ENGAGED IN FRAUDULENT AND/OR DECEPTIVE SECURITIES TRANSACTIONS BY ACTING AS THE SALESPERSON OR INVESTMENT ADVISOR REP FOR SEVERAL PENSION FUND ACCOUNTS FOR WHICH HER FATHER WAS THE TRUSTEE AND WHO DIRECTED TRANSACTIONS TO HER ACCOUNT FOR PURPOSES OF GENERALING COMMISSION 2) A.G. EDWARDS (NOT KNOW AS WACHOVIA SECURITIES, LLC) KNEW OR SHOULD HAVE KNOWN OF THE ABOVE ACTIVITIES AND FAILED TO TAKE REASONABLE SUPERVISORY STEPS TO ©2021 FINRA. All rights reserved. Report aboutPREVENT WELLS FARGOOR STOP CLEARING THE ILLEGALSERVICES, ACTIVITIES LLC 242 FAILURE TO SUPERVISE DECEPTIVE OR FRAUDULENT SECURITIES TRANSACTIONS. **AMENDED NOTICE OF HEARING SECURITIES FRAUD. ALLEGATIONS ADDED 1/4/2008 - AMENDED NOTICE OF HEARING SECURITIES FRAUD 1) SUZANNE WIEGAND ENGAGED IN FRAUDULENT AND/OR DECEPTIVE SECURITIES TRANSACTIONS BY ACTING AS THE SALESPERSON OR INVESTMENT ADVISOR REP FOR SEVERAL PENSION www.finra.org/brokercheck FUND ACCOUNTS FOR WHICH HER FATHER WAS THE TRUSTEE AND WHO User Guidance DIRECTED TRANSACTIONS TO HER ACCOUNT FOR PURPOSES OF GENERALING COMMISSION 2) A.G. EDWARDS (NOT KNOW AS WACHOVIA SECURITIES, LLC) KNEW OR SHOULD HAVE KNOWN OF THE ABOVE ACTIVITIES AND FAILED TO TAKE REASONABLE SUPERVISORY STEPS TO PREVENT OR STOP THE ILLEGAL ACTIVITIES Initiated By: STATE OF ILLINOIS Date Initiated: 05/18/2007 Docket/Case Number: 0600669

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

Resolution: Order Resolution Date: 06/18/2009 Sanctions Ordered: Monetary/Fine $50,000.00 Other Sanctions Ordered: UNDER TOOK CHANGES TO TRAINING AND COMPLIANCE RELATED TO PROHIBITED TRANSACTIONS UNDER ERISA. Sanction Details: ORDER OF DISMISSAL. Firm Statement NOTICE OF HEARING WAS ISSUED MAY 18, 2007. AMENDED NOTICE OF HEARING WAS ISSUED OCTOBER 10, 2007. SECOND AMENDED NOTICE OF HEARING WAS ISSUED JANUARY 4, 2008. THE HEARING IS SCHEDULED FOR APRIL 15, 2008. CONTACT (217) 785-4947 i Disclosure 122 of 167 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASES 34-56462, IA RELEASE 40-2648, IC RELEASE 40- 27973, SEPTEMBER 19, 2007: THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION (THE COMMISSION) DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT ADMINISTRATIVE AND CEASE-AND- DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B)(4), 17A(C)(3) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT), AND SECTIONS 9(B) AND 9(F) OF THE INVESTMENT COMPANY ACT OF 1940 (INVESTMENT COMPANY ACT) AGAINST WACHOVIA SECURITIES, LLC (WACHOVIA). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THE ©2021 FINRA. All rights reserved. Report aboutRESPONDENT WELLS FARGO SUBMITTED CLEARING SERVICES, AN OFFER LLC OF SETTLEMENT (THE OFFER) THAT 243 THE COMMISSION HAS DETERMINED TO ACCEPT. THE ORDER IS INSTITUTED AS TO WACHOVIA SECURITIES PURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT AND SECTIONS 9(B) AND 9(F) OF THE INVESTMENT COMPANY ACT. THIS PROCEEDING CONCERNS VARIOUS VIOLATIONS OF THE FEDERAL SECURITIES LAWS COMMITTED IN CONNECTION WITH THE CREATING AND/OR IMPLEMENTING TWO MARKET TIMING AGREEMENTS (AND THE ROLE OF WACHOVIA SECURITIES IN CREATING AND/OR IMPLEMENTING ONE OF THOSE TWO AGREEMENTS) THAT PERMITTED, IN EACH CASE, A REGISTERED REPRESENTATIVE TO MAKE, ON BEHALF OF CERTAIN OF HIS CUSTOMERS, FREQUENT TRADES IN CERTAIN FUNDS IN EXCESS OF THE EXCHANGE LIMITS SET FORTH IN THE FUNDS' PROSPECTUSES. SEC ADMIN RELEASES 34-56462, IA RELEASE 40-2648, IC RELEASE 40- 27973, SEPTEMBER 19, 2007: THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION (THE COMMISSION) DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT ADMINISTRATIVE AND CEASE-AND- DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B)(4), 17A(C)(3) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), SECTIONS 203(E) AND 203(K) OF THE www.finra.org/brokercheck INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT), AND SECTIONS 9(B) User Guidance AND 9(F) OF THE INVESTMENT COMPANY ACT OF 1940 (INVESTMENT COMPANY ACT) AGAINST WACHOVIA SECURITIES, LLC (WACHOVIA). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THE RESPONDENT SUBMITTED AN OFFER OF SETTLEMENT (THE OFFER) THAT THE COMMISSION HAS DETERMINED TO ACCEPT. THE ORDER IS INSTITUTED AS TO WACHOVIA SECURITIES PURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT AND SECTIONS 9(B) AND 9(F) OF THE INVESTMENT COMPANY ACT. THIS PROCEEDING CONCERNS VARIOUS VIOLATIONS OF THE FEDERAL SECURITIES LAWS COMMITTED IN CONNECTION WITH THE CREATING AND/OR IMPLEMENTING TWO MARKET TIMING AGREEMENTS (AND THE ROLE OF WACHOVIA SECURITIES IN CREATING AND/OR IMPLEMENTING ONE OF THOSE TWO AGREEMENTS) THAT PERMITTED, IN EACH CASE, A REGISTERED REPRESENTATIVE TO MAKE, ON BEHALF OF CERTAIN OF HIS CUSTOMERS, FREQUENT TRADES IN CERTAIN FUNDS IN EXCESS OF THE EXCHANGE LIMITS SET FORTH IN THE FUNDS' PROSPECTUSES. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/19/2007 Docket/Case Number: SEC FILE 3-12805

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: 09/19/2007 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $500,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION OR IN WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT THOSE FINDINGS PERTAINING TO THE ©2021 FINRA. All rights reserved. Report aboutJURISDICTION WELLS FARGO OF CLEARING THE COMMISSION SERVICES, LLC OVER RESPONDENT AND THE 244 SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTIONS 15(B)(4), 17A(C)(3) AND 21C OF THE EXCHANGE ACT, SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, AND SECTIONS 9(B) AND 9(F) OF THE INVESTMENT COMPANY ACT, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. WACHOVIA SECURITIES WAS AFFILIATED WITH THE SMALL COMPANY GROWTH FUND, WILLFULLY VIOLATED SECTION 17(D) OF THE INVESTMENT COMPANY ACT AND RULE 17D-1 THEREUNDER. WACHOVIA SECURITIES FORMED A JOINT ARRANGEMENT WITH AN AFFILIATED FUND. AS A RESULT, WACHOVIA SECURITIES WILLFULLY VIOLATED SECTION 17(D) AND RULE 17D-1 THEREUNDER. IT IS HEREBY ORDERED PURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT, WACHOVIA SECURITIES IS HEREBY CENSURED. PURSUANT TO SECTION 9(F) OF THE INVESTMENT COMPANY ACT, WACHOVIA SECURITIES SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(D) OF THE INVESTMENT COMPANY ACT AND RULE 17D-1 THEREUNDER. WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, WACHOVIA SECURITIES SHALL PAY DISGORGEMENT IN THE AMOUNT OF $1 AND, PURSUANT TO SECTIONS 9(B) AND 9(D) OF THE INVESTMENT COMPANY ACT, A CIVIL PENALTY IN THE AMOUNT OF $500,000.THERE SHALL BE, PURSUANT TO SECTION 308(A) OF THE SARBANES-OXLEY ACT OF 2002, A FAIR FUND ESTABLISHED FOR THE FUNDS. www.finra.org/brokercheck User Guidance SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION OR IN WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT THOSE FINDINGS PERTAINING TO THE JURISDICTION OF THE COMMISSION OVER RESPONDENT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTIONS 15(B)(4), 17A(C)(3) AND 21C OF THE EXCHANGE ACT, SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, AND SECTIONS 9(B) AND 9(F) OF THE INVESTMENT COMPANY ACT, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. WACHOVIA SECURITIES WAS AFFILIATED WITH THE SMALL COMPANY GROWTH FUND, WILLFULLY VIOLATED SECTION 17(D) OF THE INVESTMENT COMPANY ACT AND RULE 17D-1 THEREUNDER. WACHOVIA SECURITIES FORMED A JOINT ARRANGEMENT WITH AN AFFILIATED FUND. AS A RESULT, WACHOVIA SECURITIES WILLFULLY VIOLATED SECTION 17(D) AND RULE 17D-1 THEREUNDER. IT IS HEREBY ORDERED PURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT, WACHOVIA SECURITIES IS HEREBY CENSURED. PURSUANT TO SECTION 9(F) OF THE INVESTMENT COMPANY ACT, WACHOVIA SECURITIES SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(D) OF THE INVESTMENT COMPANY ACT AND RULE 17D-1 THEREUNDER. WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, WACHOVIA SECURITIES SHALL PAY DISGORGEMENT IN THE AMOUNT OF $1 AND, PURSUANT TO SECTIONS 9(B) AND 9(D) OF THE INVESTMENT COMPANY ACT, A CIVIL PENALTY IN THE AMOUNT OF $500,000.THERE SHALL BE, PURSUANT TO SECTION 308(A) OF THE SARBANES-OXLEY ACT OF 2002, A FAIR FUND ESTABLISHED FOR THE FUNDS. i Reporting Source: Firm Current Status: Final Allegations: THE FIRM AND AFFILIATES WERE ALLEGED TO HAVE ENTERED INTO AN AGREEMENT TO ALLOW A REGISTERED REPRESENTATIVE TO MARKET TIME IN A SPECIFIC EVERGREEN FUND IN EXCESS OF TRADING LIMITS SET FORTH IN THE FUNDS' PROSPECTUS. Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/19/2007 Docket/Case Number: ADMIN PROCEEDING FILE NO. 3-12805

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 245 www.finra.org/brokercheck User Guidance

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

Resolution: Decision & Order of Offer of Settlement Resolution Date: 09/19/2007 Sanctions Ordered: Censure Monetary/Fine $500,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN AGREEMENT TO PAY DISGORGEMENT OF $1 AND CIVIL PENALTY OF $500,000, CENSURED, AND CEASE AND DESIST ANY FURTHER VIOLATIONS OF SECTION 17(D) OF THE INVESTMENT COMPANY ACT AND RULE 17D-1. i Disclosure 123 of 167 Reporting Source: Regulator Current Status: Final Allegations: WACHOVIA THROUGH ITS AGENT ROSS O. HAUGEN CONDUCTED COVERED CALL WRITING WHILE EXPOSING CLIENTS TO HIGH CONCENTRATIONS OF CERTAIN SECURITIES THAT WERE NOT SUITABLE TO CLIENTS INVESTMENT OBJECTIVES AND RISK TEMPERAMENTS. WACHOVIA DID PROPERLY SUPERVISE ITS AGENT, HAUGEN. Initiated By: NORTH DAKOTA SECURITIES DEPARTMENT Date Initiated: 06/19/2007 Docket/Case Number: 06-556 URL for Regulatory Action: Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief RESTITUTION Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 06/19/2007 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 246 www.finra.org/brokercheck User Guidance

Resolution Date: 06/19/2007 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $75,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: IMMEDIATE PAYMENT OF THE $75,000 PENALTY. WACHOVIA SHALL CONTACT SEVERAL IDENTIFIED CLIENTS TO AND RESOLVE THE SALES PRACTICE ISSUES THROUGH NORMAL RESOLUTION PROCESS. WACHOVIA SHALL PROPERLY SUPERVISE THE ACTIVITIES OF ITS AGENTS IN ND. i Reporting Source: Firm Current Status: Final Allegations: THE NORTH DAKOTA SECURITIES COMMISSIONER ALLEGED THAT, FROM DECEMBER 2001 TO JULY 2002, TWO PREDECESSORS TO WACHOVIA SECURITIES, LLC (WSLLC) HAD FAILED TO SUPERVISE A FORMER REGISTERED REPRESENTATIVE IN CONNECTION WITH ALLEGEDLY UNSUITABLE TRADING IN OTC STOCKS AND OPTIONS IN THE ACCOUNTS OF SEVERAL CUSTOMERS. Initiated By: NORTH DAKOTA SECURITIES COMMISSIONER Date Initiated: 06/19/2007 Docket/Case Number: 06-556

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 UNDERTAKING Sought:

Resolution: Consent Resolution Date: 06/19/2007 Sanctions Ordered: Monetary/Fine $75,000.00 Disgorgement/Restitution ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 247 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $75,000.00 Disgorgement/Restitution Other Sanctions Ordered: UNDERTAKING Sanction Details: $75,000 PAID BY WSLLC. UNDERTAKING IS DESCRIBED IN RESPONSE TO QUESTION 13. Firm Statement WSLLC AGREED TO CORRESPOND WITH CERTAIN FORMER CLIENTS AND TO ADDRESS ANY COMPLAINTS THROUGH ITS NORMAL DISPUTE RESOLUTION PROCESS. i Disclosure 124 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 2210(D) AND 3010(A) AND (B): WACHOVIA SECURITIES, LLC (THE FIRM) OFFERED ITS CUSTOMERS A FEE-BASED BROKERAGE ACCOUNT PROGRAM (THE PROGRAM) SINCE 1999. BETWEEN JANUARY 1, 2001 AND DECEMBER 31, 2004 (THE REVIEW PERIOD), THE FIRM FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO REVIEW AND MONITOR THE FEE-BASED PROGRAM. WHILE THE FIRM INFORMED ITS BROKERS THAT THIS PROGRAM WAS NOT APPROPRIATE FOR CUSTOMERS WHO MADE A LIMITED NUMBER OF TRADES, BUY-AND-HOLD CUSTOMERS, AND CUSTOMERS WITH SMALLER ACCOUNTS (ASSETS BELOW $50,000), THE FIRM'S SYSTEM AND PROCEDURES NEVERTHELESS WERE NOT REASONABLY DESIGNED TO DETERMINE WHETHER THE PROGRAM WAS APPROPRIATE FOR ITS CUSTOMERS. AS A RESULT OF THE FIRM'S SUPERVISORY DEFICIENCIES DURING THE REVIEW PERIOD, THE FIRM ALLOWED APPROXIMATELY 1,200 CUSTOMERS TO CONTINUE IN FEE- BASED ACCOUNTS WITHOUT ADEQUATELY REASSESSING WHETHER FEE- BASED ACCOUNTS REMAINED APPROPRIATE FOR THOSE CUSTOMERS. THESE CUSTOMERS EITHER CONDUCTED NO TRADES IN THEIR PROGRAM ACCOUNTS FOR AT LEAST TWO CONSECUTIVE YEARS OR HAD PROGRAM ACCOUNTS WHERE THE TOTAL VALUE OF THE ASSETS IN THE ACCOUNTS AVERAGED BELOW $25,000 FOR AT LEAST ONE FULL YEAR. DURING THE REVIEW PERIOD, APPROXIMATELY 594 CUSTOMERS CONDUCTED NO TRADES IN THE PROGRAM ACCOUNTS FOR AT LEAST TWO CONSECUTIVE YEARS AND PAID THE FIRM APPROXIMATELY $1.9 MILLION IN FEES DURING THE TIME WHEN THEIR ACCOUNTS WERE INACTIVE. IN ADDITION, APPROXIMATELY 620 CUSTOMERS HELD ASSETS BELOW $50,000 AND AVERAGED LESS THAN $25,000 FOR AT LEAST ONE FULL YEAR DURING THE REVIEW PERIOD. DURING THE TIME THAT THESE CUSTOMERS' ELIGIBLE ASSETS AVERAGED BELOW $25,000 FOR AT LEAST ONE FULL YEAR, THEY PAID A TOTAL OF APPROXIMATELY $1 MILLION IN PROGRAM FEES. (ALLEGATIONS CONTINUED IN COMMENTS SECTION) ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 248 NASD RULES 2110, 2210(D) AND 3010(A) AND (B): WACHOVIA SECURITIES, LLC (THE FIRM) OFFERED ITS CUSTOMERS A FEE-BASED BROKERAGE ACCOUNT PROGRAM (THE PROGRAM) SINCE 1999. BETWEEN JANUARY 1, 2001 AND DECEMBER 31, 2004 (THE REVIEW PERIOD), THE FIRM FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO REVIEW AND MONITOR THE FEE-BASED PROGRAM. WHILE THE FIRM INFORMED ITS BROKERS THAT THIS PROGRAM WAS NOT APPROPRIATE FOR CUSTOMERS WHO MADE A LIMITED NUMBER OF TRADES, BUY-AND-HOLD CUSTOMERS, AND CUSTOMERS WITH SMALLER ACCOUNTS (ASSETS BELOW $50,000), THE FIRM'S SYSTEM AND PROCEDURES NEVERTHELESS WERE NOT REASONABLY DESIGNED TO DETERMINE WHETHER THE PROGRAM WAS APPROPRIATE FOR ITS CUSTOMERS. AS A RESULT OF THE FIRM'S SUPERVISORY DEFICIENCIES DURING THE REVIEW PERIOD, THE FIRM ALLOWED APPROXIMATELY 1,200 CUSTOMERS TO CONTINUE IN FEE- BASED ACCOUNTS WITHOUT ADEQUATELY REASSESSING WHETHER FEE- BASED ACCOUNTS REMAINED APPROPRIATE FOR THOSE CUSTOMERS. THESE CUSTOMERS EITHER CONDUCTED NO TRADES IN THEIR PROGRAM ACCOUNTS FOR AT LEAST TWO CONSECUTIVE YEARS OR HAD PROGRAM ACCOUNTS WHERE THE TOTAL VALUE OF THE ASSETS IN THE ACCOUNTS AVERAGED BELOW $25,000 FOR AT LEAST ONE FULL YEAR. DURING THE REVIEW PERIOD, APPROXIMATELY 594 CUSTOMERS CONDUCTED NO TRADES IN THE PROGRAM ACCOUNTS FOR AT LEAST TWO CONSECUTIVE YEARS AND PAID THE FIRM APPROXIMATELY $1.9 MILLION IN FEES DURING THE TIME WHEN THEIR ACCOUNTS WERE INACTIVE. IN ADDITION, APPROXIMATELY 620 CUSTOMERS HELD ASSETS BELOW $50,000 AND www.finra.org/brokercheck AVERAGED LESS THAN $25,000 FOR AT LEAST ONE FULL YEAR DURING User Guidance THE REVIEW PERIOD. DURING THE TIME THAT THESE CUSTOMERS' ELIGIBLE ASSETS AVERAGED BELOW $25,000 FOR AT LEAST ONE FULL YEAR, THEY PAID A TOTAL OF APPROXIMATELY $1 MILLION IN PROGRAM FEES. (ALLEGATIONS CONTINUED IN COMMENTS SECTION) Initiated By: NASD Date Initiated: 06/21/2007 Docket/Case Number: EAF0400840001

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: 06/21/2007 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $2,000,000.00 Disgorgement/Restitution 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 $2 MILLION AND AGREES TO COMPLETE UNDERTAKINGS IN ORDER TO IDENTIFY AND PAY RESTITUTION TO CUSTOMERS WHO WERE INAPPROPRIATELY ALLOWED TO CONTINUE IN THE FEE-BASED PROGRAM WHEN THEIR ACCOUNTS WERE NOT APPROPRIATE FOR THEM AND/OR INAPPROPRIATELY CHARGED FEES ON A-SHARES FOR WHICH THEY HAD ALREADY PAID A SALES LOAD. THE FIRM MUST ALSO RETAIN AN OUTSIDE CONSULTANT TO EXAMINE AND REPORT TO NASD THE FIRM'S PERFORMANCE OF ITS OBLIGATIONS UNDER THE TERMS OF THIS AWC INCLUDING THE FIRM'S METHODOLOGY AND PROCESS USED, THE IDENTIFICATION OF CUSTOMERS AND CALCULATION OF RESTITUTION AMOUNTS AND INTEREST. Regulator Statement (ALLEGATIONS CONTINUED) IN ADDITION, THE FIRM EXEMPTED HIGH PRODUCING BROKERS FROM SOME OF THE FIRM'S REVIEW AND APPROVAL PROCESSES. CONSEQUENTLY, THESE BROKERS WERE ABLE ©2021 FINRA. All rights reserved. Report aboutTO OPEN WELLS ACCOUNTSFARGO CLEARING FOR SERVICES, CERTAIN LLC CUSTOMERS FOR WHOM FEE-BASED 249 ACCOUNTS MAY NOT HAVE BEEN APPROPRIATE, INCLUDING INACTIVE ACCOUNTS AND CUSTOMERS WHOSE ASSETS WERE BELOW THE FIRM'S STATED $50,000 MINIMUM. THE FIRM ALSO FAILED TO REASONABLY ENFORCE ITS WRITTEN PROCEDURES DESIGNED TO PROTECT PROGRAM CUSTOMERS FROM BEING ASSESSED DOUBLE FEES ON THE PURCHASE OF CLASS A SHARES OF MUTUAL FUNDS THAT CARRIED AN UP-FRONT SALES CHARGE; THAT IS PAYING A SALES LOAD, THEN THE ASSET BASED FEE ON TOP OF THE LOAD. THE FIRM MADE AN INACCURATE MATERIAL STATEMENT IN ITS COMMUNICATION WITH THE PUBLIC IN THAT IT PROVIDED ITS BROKERS WITH A PIECE OF SALES LITERATURE RELATING TO THE PROGRAM THAT BROKERS COULD USE WITH THEIR CUSTOMERS. THE SALES LITERATURE REFERRED TO THE PROGRAM AS A MONITORED BROKERAGE ACCOUNT," BUT INACCURATELY STATED IN FOOTNOTE THAT THE PROGRAM WAS A "FEE-BASED, INVESTMENT ADVISORY SERVICE PROVIDED BY THE FIRM. www.finra.org/brokercheck User Guidance (ALLEGATIONS CONTINUED) IN ADDITION, THE FIRM EXEMPTED HIGH PRODUCING BROKERS FROM SOME OF THE FIRM'S REVIEW AND APPROVAL PROCESSES. CONSEQUENTLY, THESE BROKERS WERE ABLE TO OPEN ACCOUNTS FOR CERTAIN CUSTOMERS FOR WHOM FEE-BASED ACCOUNTS MAY NOT HAVE BEEN APPROPRIATE, INCLUDING INACTIVE ACCOUNTS AND CUSTOMERS WHOSE ASSETS WERE BELOW THE FIRM'S STATED $50,000 MINIMUM. THE FIRM ALSO FAILED TO REASONABLY ENFORCE ITS WRITTEN PROCEDURES DESIGNED TO PROTECT PROGRAM CUSTOMERS FROM BEING ASSESSED DOUBLE FEES ON THE PURCHASE OF CLASS A SHARES OF MUTUAL FUNDS THAT CARRIED AN UP-FRONT SALES CHARGE; THAT IS PAYING A SALES LOAD, THEN THE ASSET BASED FEE ON TOP OF THE LOAD. THE FIRM MADE AN INACCURATE MATERIAL STATEMENT IN ITS COMMUNICATION WITH THE PUBLIC IN THAT IT PROVIDED ITS BROKERS WITH A PIECE OF SALES LITERATURE RELATING TO THE PROGRAM THAT BROKERS COULD USE WITH THEIR CUSTOMERS. THE SALES LITERATURE REFERRED TO THE PROGRAM AS A MONITORED BROKERAGE ACCOUNT," BUT INACCURATELY STATED IN FOOTNOTE THAT THE PROGRAM WAS A "FEE-BASED, INVESTMENT ADVISORY SERVICE PROVIDED BY THE FIRM. i Reporting Source: Firm Current Status: Final Allegations: FOR THE PERIOD JANUARY 1, 2001 THROUGH DECEMBER 31, 2004, WACHOVIA SECURITIES, LLC CONSENTED TO, WITHOUT ADMITTING OR DENYING THE FINDINGS, VIOLATIONS OF NASD RULES 3010, 2110 AND 2210(D) FOR FAILURE TO SUPERVISOR IN CONNECTION WITH ITS FEE IN LIEU OF COMMISSION ACCOUNTS (PILOT PLUS ACCOUNTS) BASED ON LOW ACTIVITY, OPENING ACCOUNTS BELOW STATED MINIMUMS AND DISTRIBUTING A PIECE OF SALES LITERATURE THAT INACCURATELY STATED THAT PILOT PLUS WAS A FEE BASED ADVISORY ACCOUNT. Initiated By: NASD Date Initiated: 12/13/2004 Docket/Case Number: AWC# EAF0400840001

Principal Product Type: Other Other Product Type(s): FEE OF LIEW OF COMMISSION ACCOUNTS Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE AND REMEDIATION TO CLIENTS Sought:

Resolution Date: 06/21/2007 Sanctions Ordered: Censure Monetary/Fine $2,000,000.00 Disgorgement/Restitution Other Sanctions Ordered: REMEDIATION ON THE FOLLOWING TERMS:

1. REMEDIATE TO CLIENTS WHOSE PILOT PLUS ACCOUNTS WERE INACTIVE FOR TWO CONSECUTIVE YEARS OR MORE, ALL PILOT PLUS FEES CHARGED AFTER THE FIRST YEAR OF INACTIVITY; 2. REMEDIATE TO CLIENTS WITH PILOT PLUS ACCOUNTS WITH ASSETS LESS THAN THE REQUIRED $50,000 MINIMUM, THE DIFFERENCE BETWEEN THE $1,000 MINIMUM ANNUAL FEE AND A FEE EQUAL TO 2% OF THE ASSETS WITH AVERAGE BALANCES, FOR FOUR CONSECUTIVE QUARTERS, BELOW $25,000 3. REMEDIATE TO CLIENTS WHO PURCHASED LOADED CLASS A MUTUAL FUNDS AND TRANSFERRED THOSE ASSETS INTO A PILOT PLUS ACCOUNT WITHIN 13 MONTHS OF THE PURCHASE, THE FEES CHARGED ON THAT ASSET THROUGH THE END OF THE THIRTEENTH MONTH; 4. PAY CLIENTS INTEREST AT THE PROSCRIBED IRS RATE FROM THE DATE OF THE REQUIRED REMEDIATION THROUGH THE DATE OF ACCEPTANCE OF THE AWC; 5. RETAIN AND OUTSIDE CONSULTANT TO VERIFY THAT ALL OF THE APPROPRIATE CLIENTS WERE IDENIFIED AND THE REMEDIATION WAS DONE ACCORDANCE WITH THE TERMS OF THE AWC. Sanction Details: REMEDIATION ON THE FOLLOWING TERMS:

1. REMEDIATE TO CLIENTS WHOSE PILOT PLUS ACCOUNTS WERE INACTIVE FOR TWO CONSECUTIVE YEARS OR MORE, ALL PILOT PLUS FEES CHARGED AFTER THE FIRST YEAR OF INACTIVITY; 2. REMEDIATE TO CLIENTS WITH PILOT PLUS ACCOUNTS WITH ASSETS LESS THAN THE REQUIRED $50,000 MINIMUM, THE DIFFERENCE BETWEEN THE $1,000 MINIMUM ANNUAL FEE AND A FEE EQUAL TO 2% OF THE ASSETS WITH AVERAGE BALANCES, FOR FOUR CONSECUTIVE QUARTERS, BELOW $25,000 3. REMEDIATE TO CLIENTS WHO PURCHASED LOADED CLASS A MUTUAL FUNDS AND TRANSFERRED THOSE ASSETS INTO A PILOT PLUS ACCOUNT WITHIN 13 MONTHS OF THE PURCHASE, THE FEES CHARGED ON THAT ASSET THROUGH THE END OF THE THIRTEENTH MONTH; 4. PAY CLIENTS INTEREST AT THE PROSCRIBED IRS RATE FROM THE DATE OF THE REQUIRED REMEDIATION THROUGH THE DATE OF ACCEPTANCE OF THE AWC; 5. RETAIN AND OUTSIDE CONSULTANT TO VERIFY THAT ALL OF THE APPROPRIATE CLIENTS WERE IDENIFIED AND THE REMEDIATION WAS DONE ACCORDANCE WITH THE TERMS OF THE AWC. Firm Statement WITHIN 180 DAYS OF THE ACCEPTANCE OF THE AWC, IDENTIFY ALL ©2021 FINRA. All rights reserved. Report aboutCUSTOMERS WELLS FARGO ENTITLED CLEARING TO SERVICES, REMEDIATION LLC AND, WITHIN 195 DAYS OF 251 ACCEPTANCE, REPORT TO THE NASD. WITHIN 315 DAYS OF THE ACCEPTANCE OF THE ORDER, REMEDIATE TO CLIENTS WITH INTEREST. www.finra.org/brokercheck User Guidance

Firm Statement WITHIN 180 DAYS OF THE ACCEPTANCE OF THE AWC, IDENTIFY ALL CUSTOMERS ENTITLED TO REMEDIATION AND, WITHIN 195 DAYS OF ACCEPTANCE, REPORT TO THE NASD. WITHIN 315 DAYS OF THE ACCEPTANCE OF THE ORDER, REMEDIATE TO CLIENTS WITH INTEREST. i Disclosure 125 of 167 Reporting Source: Regulator Current Status: Final Allegations: **5/30/07** STIPULATION AND CONSENT TO PENALTY FILED BY NYSE REGULATION, INC. DIVISION OF ENFORCEMENT AND PENDING. CONSENTED TO FINDINGS: A. FINDINGS BY A HEARING PANEL OR A HEARING OFFICER ACTING ALONE THAT, FROM MARCH 2001 THROUGH JUNE 2005, THE FIRM VIOLATED NYSE RULE 345A, IN THAT IT PERMITTED REGISTERED REPRESENTATIVES WITH INACTIVE REGISTRATIONS TO PERFORM DUTIES AND FUNCTIONS WHICH REQUIRED REGISTRATION. B. FINDINGS BY THE HEARING PANEL OR A HEARING OFFICER ACTING ALONE THAT, FROM MARCH 2001 THROUGH JUNE 2005, THE FIRM VIOLATED NYSE RULE 342, IN THAT IT FAILED TO PROVIDE FOR, ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY PROCEDURES AND CONTROLS, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF ITS BUSINESS ACTIVITIES RELATING TO COMPLIANCE WITH CONTINUING EDUCATION TRAINING REQUIREMENTS BY FIRM REGISTERED REPRESENTATIVES. C. THE IMPOSITION OF A CENSURE AND A FINE OF $90,000. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 05/30/2007 Docket/Case Number: HBD# 07-90

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

Resolution: Decision Resolution Date: 07/17/2007 Sanctions Ordered: Censure Monetary/Fine $90,000.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 252 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: **6/18/07** 07-90 ISSUED BY THE HEARING BOARD DECISION: 1. VIOLATED NYSE RULE 345A BY PERMITTING REGISTERED REPRESENTATIVES WITH INACTIVE REGISTRATIONS TO PERFORM DUTIES AND FUNCTIONS WHICH REQUIRED REGISTRATION; AND 2. VIOLATED NYSE RULE 342 BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY PROCEDURES AND CONTROLS, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF BUSINESS ACTIVITIES RELATING TO COMPLIANCE WITH CONTINUING EDUCATION TRAINING REQUIREMENTS BY REGISTERED REPRESENTATIVES. THE HEARING BOARD IMPOSED A PENALTY OF A CENSURE AND $90,000 FINE. Regulator Statement **7/17/07** THE DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESS ON JULY 13, 2007. CONTACT: PEGGY GERMINO 212-656-8450. i Reporting Source: Firm Current Status: Final Allegations: ON JUNE 18 2007, AN NYSE HEARING OFFICER ACCEPTED "THE STIPULATION OF FACTS AND CONSENT TO PENALTY" ENTERED INTO BETWEEN NYSE REGULATION AND WACHOVIA SECURITIES LLC , WHEREIN WACHOVIA SECURITIES, LLC, WITHOUT ADMITTING OR DENYING GUILT, CONSENTED TO: (I) A FINDING THAT IT VIOLATED NYSE RULE 345A BY PERMITTING REGISTERED REPRESENTATIVES WITH INACTIVE REGISTRATIONS DUE TO CONTINUING EDUCATION REQUIREMENTS TO PERFORM DUTIES AND FUNCTIONS WHICH REQUIRED REGISTRATION AND VIOLATED NYSE RULE 342 BY FAILING TO PROVIDE FOR , ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY PROCEDURES AND CONTROLS, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF BUSINESS ACTIVITIES RELATING TO COMPLIANCE WITH CONTINUING EDUCATION TRAINING REQUIREMENTS BY REGISTERED REPRESENTATIVES; AND, (II) THE PENALTY OF A CENSURE AND A $90,000. FINE.

IF NO REVIEW IS REQUESTED BY A MEMBER OF THE NYSE ENTITIES IDENTIFIED IN NYSE RULE 476(G), THE DECISION WILL BECOME FINAL AT THE CLOSE OF BUSINESS ON JULY 13, 2007. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 05/30/2007 Docket/Case Number: HBD# 07-90

Principal Product Type: No Product Other Product Type(s):

Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $90,000. Sought:

Resolution: Stipulation and Consent Resolution Date: 06/18/2007 Sanctions Ordered: Censure Monetary/Fine $90,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING GUILT, CONSENTED TO THE PENALTY OF A CENSURE AND A $90,000. FINE. i Disclosure 126 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 2830(L)(4) - WACHOVIA SECURITIES, LLC RECEIVED $33,856.35 IN SPECIAL CASH COMPENSATION FOR THE SALE OF SHARES OF PARTICULAR MUTUAL FUNDS DURING AN IRA PROMOTION THAT WAS NOT AVAILABLE TO ALL WHO DISTRIBUTED THE MUTUAL FUNDS AND THE DETAILS OF THE ARANGEMENT WERE NOT PROPERLY DISCLOSED IN THE PROSPECTUS OR STATEMENTS OF ADDITIONAL INFORMATION FOR THE MUTUAL FUNDS. Initiated By: NASD Date Initiated: 02/26/2007 Docket/Case Number: E8A2003062017

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/26/2007 Does the order constitute a No ©2021final orderFINRA. basedAll rights on reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 254 violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

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: 02/26/2007 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Other Sanctions Ordered:

©2021Sanction FINRA. Details: All rights reserved. Report aboutWITHOUT WELLS FARGOADMITTING CLEARING OR SERVICES,DENYING LLC THE ALLEGATIONS, THE FIRM 255 CONSENTED TO THE CENSURE AND FINE OF $25,000. www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE CENSURE AND FINE OF $25,000. i Disclosure 127 of 167 Reporting Source: Regulator Current Status: Final Allegations: **2/14/07**STIPULATION AND CONSENT TO PENALTY FILED BY NYSE REGULATION DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDINGS (WITHOUT ADMITTING OR DENYING GUILT):1.VIOLATED EXCHANGE ACT RULE 15C3-1(C)(2) IN THAT IT INCORRECTLY CALCULATED ITS REQUIRED NET CAPITAL COMPUTATION BY MISCLASSIFYING ASSETS;2.VIOLATED EXCHANGE ACT RULE 17A-5 IN THAT IT FILED AN INACCURATE FINANCIAL AND OPERATIONAL COMBINED UNIFORM SINGLE REPORT ("FOCUS REPORT") WITH THE NYSE;3.VIOLATED EXCHANGE ACT RULE 15C3-3 IN THAT IT IMPROPERLY COMPUTED ITS CUSTOMER RESERVE FORMULA REQUIREMENTS;4.VIOLATED EXCHANGE ACT RULE 17A-3 AND NYSE RULE 440 IN THAT IT FAILED TO MAINTAIN BOOKS AND RECORDS REGARDING ITS ACCOUNTS NECESSARY FOR COMPUTATION OF ITS NET CAPITAL AND CUSTOMER RESERVE FORMULA REQUIREMENTS; 5.VIOLATED NYSE RULE 440.20 IN THAT IT DID NOT MAINTAIN PROPER RECORDS IDENTIFYING SUSPENSE ACCOUNTS AND DID NOT HAVE PROCEDURES IN PLACE FOR SUPERVISORY REVIEW OF SUSPENSE ACCOUNTS; AND 6.VIOLATED NYSE RULES 342(A) AND (B) IN THAT IT FAILED TO PROVIDE FOR APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND TO ESTABLISH A SYSTEM OF FOLLOW- UP AND REVIEW TO PREVENT THE FOREGOING VIOLATIONS. STIPULATED SANCTION:CENSURE AND $100,000 FINE. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 02/12/2007 Docket/Case Number: HBD# 07-34

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

Resolution Date: 04/17/2007 Sanctions Ordered: Censure Monetary/Fine $100,000.00 Other Sanctions Ordered: Sanction Details: **3/12/07** DECISION 07-34 ISSUED BY THE HEARING BOARD DECISION: VIOLATED EXCHANGE ACT RULE15C3-1(C)(2) IN THAT IT INCORRECTLY CALCULATED ITS REQUIRED NET CAPITAL COMPUTATION BY MISCLASSIFYING ASSETS; VIOLATED EXCHANGE ACT RULE 17A-5 IN THAT IT FILED AN INACCURATE FOCUS REPORT WITH THE NYSE; VIOLATED EXCHANGE ACT RULE 15C3-3 IN THAT IT IMPROPERLY COMPUTING CUSTOMER RESERVE FORMULA REQUIREMENTS; VIOLATED EXCHANGE ACT RULE 17A-3 AND NYSE RULE 440 IN THAT IT FAILED TO MAINTAIN BOOKS AND RECORDS REGARDING ACCOUNTS NECESSARY FOR COMPUTATION OF ITS NET CAPITAL AND CUSTOMER RESERVE FORMULA REQUIREMENTS;VIOLATED NYSE RULE 440.20 IN THAT IT DID NOT MAINTAIN PROPER RECORDS IDENTIFYING SUSPENSE ACCOUNTS AND DID NOT HAVE PROCEDURES IN PLACE FOR SUPERVISORY REVIEW OF SUSPENSE ACCOUNTS; VIOLATED NYSE RULES 342(A) AND (B)IN THAT IT FAILED TO PROVIDE FOR APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND TO ESTABLISH A SYSTEM OF FOLLOW- UP AND REVIEW TO PREVENT THE FOREGOING VIOLATIONS - CONSENTED TO A CENSURE AND $100,000 FINE. Regulator Statement **4/17/07** THE DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESS ON APRIL 6, 2007. CONTACT: PEGGY GERMINO 212-656-8450. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING GUILT, THE FIRM HAS ENTERED INTO A STIPULATION OF FACT AND CONSENT TO PENALTY WITH THE NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT CONCERNING CERTAIN FINDINGS MADE DURING THE FIRM'S 2004 FINANCIAL AND OPERATIONAL EXAM. THESE FINDINGS INVOLVED OVERSTATING EXCESS NET CAPITAL AS OF SEPTEMBER 30, 2004 AND OVERSTATING EXCESS CUSTOMER DEBITS IN ITS CUSTOMER RESERVE FORMULA AS OF SEPTEMBER 30, 2004. ADDITIONAL FINDINGS INCLUDED FAILING TO ADEQUATELY SUPERVISE IN CONNECTION WITH THE FOREGOING AND INADEQUATE INTERNAL CONTROLS IN CONNECTION WITH THE CALCULATION AND DOCUMENTATION OF ITS NET CAPITAL AND CUSTOMER RESERVE REQUIREMENTS. THE FIRM HAS CONSENTED TO A CENSURE AND $100,000 FINE. Initiated By: NEW YORK STOCK EXCHANGE, INC., DIVISION OF ENFORCEMENT Date Initiated: 02/12/2007 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 257 www.finra.org/brokercheck User Guidance

Date Initiated: 02/12/2007 Docket/Case Number: HBD# 07-034

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

Resolution: Stipulation and Consent Resolution Date: 04/06/2007 Sanctions Ordered: Censure Monetary/Fine $100,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND FINE OF $100,000. i Disclosure 128 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010 - WACHOVIA SECURITIES, LLC FAILED TO ESTABLISH AND MAINTAIN A SYSTEM TO SUPERVISE THE ACTIVITIES OF A REGISTERED REPRESENTATIVE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES; ALTHOUGH THE FIRM HAD PROCEDURES REQUIRING SUPERVISORY REVIEW OF INCOMING/OUTGOING MAIL AND PROHIBITED THE RECEIPT OF PERSONAL MAIL AT THE BRANCH OFFICE, THE FIRM FAILED TO REVIEW CORRESPONDENCE; FAILED TO FOLLOW UP ON "RED FLAGS" INDICATING POSSIBLE MISCONDUCT BY THE REPRESENTATIVE REGARDING A FICTITIOUS ENTITY OPERATING AS A PONZI SCHEME; FAILED TO VERIFY THE REPRESENTATIVE'S EXPLANATION OF AN OUTSIDE BUSINESS ACTIVITY; FAILED TO CONTACT CUSTOMERS REGARDING FUND RECEIVED FROM THE REPRESENTATIVE, DID NOT REVIEW BANK STATEMENTS THAT WOULD HAVE REVEALED ADDITIONAL PERIODIC PAYMENTS TO CUSTOMERS, DID NOT ASK THE REPRESENTATIVE FOR THE NAME OF A CONTACT WITHIN THE OUTSIDE BUSINESS ENTITY TO VERIFY FINANCIAL ARRANGEMENTS AND DID NOT REVIEW THE REPRESENTATIVE'S CUSTOMER ACCOUNTS TO SEE IF THE CUSTOMERS HAD WRITTEN CHECKS TO THE ENTITY. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 258 NASD RULES 2110, 3010 - WACHOVIA SECURITIES, LLC FAILED TO ESTABLISH AND MAINTAIN A SYSTEM TO SUPERVISE THE ACTIVITIES OF A REGISTERED REPRESENTATIVE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES; ALTHOUGH THE FIRM HAD PROCEDURES REQUIRING SUPERVISORY REVIEW OF INCOMING/OUTGOING MAIL AND PROHIBITED THE RECEIPT OF PERSONAL MAIL AT THE BRANCH OFFICE, THE FIRM FAILED TO REVIEW CORRESPONDENCE; FAILED TO FOLLOW UP ON "RED FLAGS" INDICATING POSSIBLE MISCONDUCT BY THE REPRESENTATIVE REGARDING A FICTITIOUS ENTITY OPERATING AS A PONZI SCHEME; FAILED TO VERIFY THE REPRESENTATIVE'S EXPLANATION OF AN OUTSIDE BUSINESS ACTIVITY; FAILED TO CONTACT CUSTOMERS REGARDING FUND RECEIVED FROM THE REPRESENTATIVE, DID NOT REVIEW BANK STATEMENTS THAT WOULD HAVE REVEALED ADDITIONAL PERIODIC www.finra.org/brokercheck PAYMENTS TO CUSTOMERS, DID NOT ASK THE REPRESENTATIVE FOR THE User Guidance NAME OF A CONTACT WITHIN THE OUTSIDE BUSINESS ENTITY TO VERIFY FINANCIAL ARRANGEMENTS AND DID NOT REVIEW THE REPRESENTATIVE'S CUSTOMER ACCOUNTS TO SEE IF THE CUSTOMERS HAD WRITTEN CHECKS TO THE ENTITY. Initiated By: NASD Date Initiated: 12/20/2006 Docket/Case Number: 2005001720503

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: 12/20/2006 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $50,000. i Reporting Source: Firm Current Status: Final Allegations: DUE TO THE MISCONDUCT OF A REGISTERED REPRESENTATIVE, THE FIRM WAS ALLEGED TO HAVE VIOLATED NASD CONDUCT RULES 2110 AND 3010 IN REGARDS TO THE SUPERVISION OF CERTAIN ACTIVITIES OF THIS REGISTERED REPRESENTATIVE. Initiated By: NASD, DEPARTMENT OF ENFORCEMENT Date Initiated: 12/18/2006 Docket/Case Number: AWC NO. 2005001720503

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/18/2006 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO A CENSURE AND FINE OF $50,000. i Disclosure 129 of 167 Reporting Source: Regulator Current Status: Final Allegations: **8/25/06** STIPULATION AND CONSENT TO PENALTY FILED BY NYSE REGULATION, INC. DIVISION OF ENFORCEMENT AND PENDING. CONSENTED TO FINDING: A FINDING BY THE HEARING PANEL THAT WACHOVIA VIOLATED NYSE RULE 342(A) AND (B) BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLS FOR CERTAIN ACTIVITIES AT ITS BANK-AFFILIATE WHICH AFFECT COMMAND ASSET PROGRAM ACCOUNTS, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF ITS BUSINESS ACTIVITIES RELATING TO CHANGES OF CUSTOMER ADDRESS. THE IMPOSITION BY THE EXCHANGE OF THE PENALTY OF A CENSURE AND A FINE OF $300,000. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 08/25/2006 Docket/Case Number: HDB# 06-172

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 260 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 10/09/2006 Sanctions Ordered: Censure Monetary/Fine $300,000.00 Other Sanctions Ordered: Sanction Details: **9/13/06** DECISION 06-172 ISSUED BY NYSE HEARING BOARD. DECISION: VIOLATED NYSE RULES 342(A) AND (B) BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLS FOR CERTAIN ACTIVITIES AT ITS BANK-AFFILIATE WHICH AFFECT COMMAND ASSET PROGRAM ACCOUNTS, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF ITS BUSINESS ACTIVITIES RELATING TO CHANGES OF CUSTOMER ADDRESS. CONSENT TO CENSURE AND $300,000 FINE. Regulator Statement **10/9/06** THE DECISION BECAME FINAL CLOSE OF BUSINESS ON OCTOBER 9, 2006. CONTACT: PEGGY GERMINO 212-656-8450. i Reporting Source: Firm Current Status: Final Allegations: IN NYSE HEARING BOARD DECISION 06-172 THE HEARING OFFICER APPROVED THE STIPULATION AND CONSENT TO PENALTY WHEREIN WACHOVIA SECURITIES, WITHOUT ADMITTING OR DENYING GUILT CONSENTED TO FINDING: A FINDING BY THE HEARING PANEL THAT WACHOVIA VIOLATED NYSE RULE 342(A) AND (B) BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLS FOR CERTAIN ACTIVITIES AT ITS BANK AFFILIATE WHICH AFFECT COMMAND ASSET PROGRAM ACCOUNTS, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF ITS BUSINESS ACTIVITIES RELATING TO CHANGES OF CUSTOMER ADDRESS. Initiated By: NEW YORK STOCK EXCHANGE, DIVISION OF ENFORCEMENT Date Initiated: 08/25/2006 Docket/Case Number: HDB# 06-172

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 261 www.finra.org/brokercheck User Guidance

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

Resolution: Stipulation and Consent Resolution Date: 10/09/2006 Sanctions Ordered: Censure Monetary/Fine $300,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTED TO A CENSURE AND FINE OF $300,000. i Disclosure 130 of 167 Reporting Source: Firm Current Status: Final Allegations: ALLEGED TO HAVE VIOLATED SECTION 36B-6(B) AND SECTION 36B-6(C) OF THE CONNECTICUT UNIFORM SECURITIES ACT WHERE CERTAIN FINACIAL ADVISORS AND A SALES ASSISTANT WERE NOT REGISTERED AS INVESTMENT ADVISORY AGENTS. Initiated By: STATE OF CONNECTICUT Date Initiated: 01/23/2004 Docket/Case Number: ST-03-6927-S

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

Resolution: Stipulation and Consent Resolution Date: 01/23/2004 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ©2021 FINRA. All rights reserved. Report aboutCONSENTED WELLS FARGO TO CLEARING A FINE OF SERVICES, $2500. LLC 262 www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE OF $2500. i Disclosure 131 of 167 Reporting Source: Regulator Current Status: Final Allegations: **7/6/06** STIPULATION AND CONSENT TO PENALTY FILED BY NYSE REGULATION DIVISION OF ENFORCEMENT AND PENDING AGAINST WACHOVIA CAPITAL MARKETS, LLC; WACHOVIA SECURITIES, LLC; AND FIRST CLEARING, LLC ("WACHOVIA RESPONDENTS") CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT, CONSENTED TO FINDINGS: THAT THE WACHOVIA RESPONDENTS VIOLATED SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-4 THEREUNDER AND NYSE RULE 440 IN THAT THE WACHOVIA RESPONDENTS FAILED TO PRESERVE ELECTRONIC RECORDS RELATING TO THE BUSINESS OF THE WACHOVIA RESPONDENTS FOR AT LEAST THREE YEARS, THE FIRST TWO YEARS IN AN EASILY ACCESSIBLE LOCATION. THAT THE WACHOVIA RESPONDENTS VIOLATED NYSE RULES 342 AND 342.17 IN THAT THE WACHOVIA RESPONDENTS FAILED TO REASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF THEIR EMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO ASSURE COMPLIANCE WITH NYSE RULES AND FEDERAL SECURITIES LAWS RELATING TO RETENTION AND/OR REVIEW OF ELECTRONIC COMMUNICATIONS. CONSENTED TO SANCTION: THE IMPOSITION BY THE EXCHANGE OF THE PENALTY OF A CENSURE, A REGULATORY UNDERTAKING, AND A FINE OF $2,250,000 (TWO MILLION AND TWO HUNDRED AND FIFTY THOUSAND DOLLARS, TO BE PAYABLE AS FOLLOWS: BY ONE PAYMENT TO NYSE REGULATION, INC. IN THE AMOUNT OF $600,000 (SIX HUNDRED THOUSAND DOLLARS), DUE AND PAYABLE WHEN THE DECISION IN THIS MATTER BECOMES FINAL; AND BY ANOTHER PAYMENT IN THE AMOUNT OF $1,650,000 (ONE MILLION AND SIX HUNDRED AND FIFTY THOUSAND DOLLARS), COLLECTION OF WHICH THE NYSE WILL WAIVE IN RECOGNITION OF AND CONDITIONAL UPON THE PAYMENT BY WACHOVIA CAPITAL MARKETS OF $1,650,000 (ONE MILLION AND SIX HUNDRED AND FIFTY THOUSAND DOLLARS) PURSUANT TO THE TERMS OF THE SETTLEMENT OF A REGULATORY ACTION, CONCLUDED UNDER THE AUSPICES OF THE NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION, RELATING TO WACHOVIA CAPITAL MARKETS' VIOLATION OF THE DUTY TO RETAIN E-MAIL COMMUNICATIONS. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 07/06/2006 Docket/Case Number: HBD# 06-151 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 263 www.finra.org/brokercheck User Guidance

Docket/Case Number: HBD# 06-151

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

Resolution: Decision Resolution Date: 09/01/2006 Sanctions Ordered: Censure Monetary/Fine $2,250,000.00 Other Sanctions Ordered: Sanction Details: **8/1/06** DECISION 06-151 ISSUED BY NYSE HEARING BOARD VIOLATIONS FOUND: VIOLATED SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-4 THEREUNDER AND NYSE RULE 440 BY FAILING TO PRESERVE ELECTRONIC RECORDS RELATING TO ITS BUSINESS FOR AT LEAST THREE YEARS, THE FIRST TWO YEARS IN AN EASILY ACCESSIBLE LOCATION; VIOLATED EXCHANGE RULES 342 AND 342.17 BY FAILING TO REASONABLY SUPERVISE AND CONTROL ACTIVITIES OF ITS EMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO ASSURE COMPLIANCE WITH NYSE RULES AND FEDERAL SECURITIES LAWS RELATING TO RETENTION AND/OR REVIEW OF ELECTRONIC COMMUNICATIONS. SANCTION: THE HEARING PANEL IMPOSED THE SANCTION, CONSENTED TO BY THE RESPONDENT, OF A CENSURE, A FINE OF $2,250,000, SUBJECT TO CERTAIN CONDITIONS SET FORTH IN THE DECISION, AND A REGULATORY UNDERTAKING. Regulator Statement **9/1/06** THE DECISION IS NOW FINAL AND IS EFFECTIVE IMMEDIATELY. CONTACT: PEGGY GERMINO 212-656-8450. i Reporting Source: Firm Current Status: Final Allegations: THE FIRM, ALONG WITH FIRST CLEARING, LLC ("FC) AND WACHOVIA CAPITAL MARKETS, LLC ("WCM"), IS ALLEGED TO HAVE VIOLATED SECTION 17(A) OF THE SECURITIES EXCHANGE ACT AND RULE 17A-4 THEREUNDER, ALONG WITH NYSE RULES 440, 342 AND 342.17, BY FAILING TO PRESERVE ELECTRONIC RECORDS RELATING TO THE BUSINESS OF THE FIRM FOR AT LEAST THREE YEARS AND BY FAILING TO REASONABLY SUPERVISE THE ©2021 FINRA. All rights reserved. Report aboutRETENTION WELLS FARGO AND/OR CLEARING REVIEW SERVICES, OF ELECTRONIC LLC COMMUNICATIONS. 264 THE FIRM, ALONG WITH FIRST CLEARING, LLC ("FC) AND WACHOVIA www.finra.org/brokercheck CAPITAL MARKETS, LLC ("WCM"), IS ALLEGED TO HAVE VIOLATED SECTION User Guidance 17(A) OF THE SECURITIES EXCHANGE ACT AND RULE 17A-4 THEREUNDER, ALONG WITH NYSE RULES 440, 342 AND 342.17, BY FAILING TO PRESERVE ELECTRONIC RECORDS RELATING TO THE BUSINESS OF THE FIRM FOR AT LEAST THREE YEARS AND BY FAILING TO REASONABLY SUPERVISE THE RETENTION AND/OR REVIEW OF ELECTRONIC COMMUNICATIONS. Initiated By: NEW YORK STOCK EXCHANGE, INC., DIVISION OF ENFORCEMENT Date Initiated: 07/06/2006 Docket/Case Number: HBD#06-151

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

Resolution: Stipulation and Consent Resolution Date: 08/26/2006 Sanctions Ordered: Censure Monetary/Fine $2,250,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE STIPULATION OF FACTS AND CONSENT TO PENALTY, THE FIRM, ALONG WITH FC AND WCM, CONSENTED TO THE CENSURE, THE FINE, AND AN UNDERTAKING TO ENSURE COMPLIANCE WITH THE RULES AND REGULATIONS ON THE RETENTION AND REVIEW OF ELECTRONIC COMMUNICATIONS THROUGH ENGAGEMENT OF AN INDEPENDENT CONSULTANT. WITH REGARD TO THE FINE, $1,650,000 OF THE $2,250,000 IS WAIVED, CONDITIONAL UPON WCM PAYING THAT AMOUNT PURSUANT TO WCM'S SETTLEMENT OF A REGULATORY ACTION BY STATE SECURITIES REGULATORS RELATING, IN PART, TO EMAIL RETENTION. THE BALANCE OF THE FINE WILL BE PAID BY THE THREE FIRMS ON OR BEFORE 10/16/06. i Disclosure 132 of 167 Reporting Source: Firm Current Status: Final Allegations: THE FIRM WAS ALLEGED TO HAVE VIOLATED EXCHANGE RULE 123C, IN FAILING TO ADHERE TO THE ORDER ENTRY AND CANCELLATION PROCEDURES FOR MARKET-ON-CLOSE (MOC) AND LIMIT-ON-CLOSE (LOC) ORDERS. Initiated By: NEW YORK STOCK EXCHANGE, INC. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 265 www.finra.org/brokercheck User Guidance

Initiated By: NEW YORK STOCK EXCHANGE, INC. Date Initiated: 01/18/2006 Docket/Case Number:

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

Resolution: Other Resolution Date: 01/18/2006 Sanctions Ordered: Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO PAYMENT OF THE TOTAL FINE OF $7500, PAID ON 2/8/2006. i Disclosure 133 of 167 Reporting Source: Firm Current Status: Final Allegations: FAILURE TO DEVELOP WRITTEN SUPERVISORY PROCEDURES. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/02/1990 Docket/Case Number: NEW-779-AWC

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/02/1990 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine WELLS FARGO $2,500.00 CLEARING SERVICES, LLC 266 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: CENSURED AND FINED $2500, JOINTLY AND SEVERALLY. Firm Statement ON NOVEMBER 2, 1990 THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. NEW-779-AWC (DISTRICT NO. 5) SUBMITTED BY RESPONDENTS SOUTHTRUST SECURITIES, INC. (CRD#17922 - MERGED INTO WACHOVIA SECURITIES, LLC),JOSEPH C. MARFOGLIO, CHARLES J. SMITH AND JAMES D HOOKS WAS ACCEPTED; THEREFORE THEY ARE CENSURED AND FINED $2500 JOINTLY AND SEVERALLY - (ARTICLE III, SECTIONS 1, 21, 27 AND 33, APPENDIX 3 OF THE RULES OF FAIR PRACTICE AND MSRB RULE G-3 IN THAT RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS MARFOGLIO AND SMITH, FAILED TO MAKE THE REQUIRED DEPOSIT IN ITS SPECIAL RESERVE BANK ACCOUNT; FAILED TO PROPERLY CONDUCT A QUARTERLY SECURITY EXAMINATION, COUNT AND VERIFICATION; FAILED TO PREPARE AND KEEP CURRENT AN ACCURATE SECURITIES POSITION RECORD; FAILED TO PREPARE AN ACCURATE COMPUTATION OF NET CAPITAL; RESPONDENT MEMBER, ACTING THROUGH RESPONDENT MARFOGLIO, FILED TO DEVELOP AND IMPLEMENT WRITTEN SUPERVISORY PROCEDURES; AND RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS MARFOGLIO AND HOOKS, FAILED TO PROPERLY REGISTERE AN INDIVIDUAL AS A MUNICIPAL SECURITIES PRINCIPAL. ***$2,500 J&S PAID ON 11/20/90, INVOICE #90-05- 1262*** i Disclosure 134 of 167 Reporting Source: Firm Current Status: Final Allegations: THE FIRM WAS ALLEGED TO HAVE VIOLATED SECURITIES LAWS BY FAILING TO ADEQUATELY SUPERVISE ITS AGENTS IN THE STATE OF MISSOURI. Initiated By: MISSOURI SECURITIES DIVISION Date Initiated: 06/13/2005 Docket/Case Number: CASE NO. AP-05-20

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief PAYMENT OF $300,000 TO THE MISSOURI INVESTOR EDUCATION AND ©2021Sought: FINRA. All rights reserved. Report aboutPROTECTION WELLS FARGO FUND. CLEARING SERVICES, LLC 267 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief PAYMENT OF $300,000 TO THE MISSOURI INVESTOR EDUCATION AND Sought: PROTECTION FUND.

Resolution: Consent Resolution Date: 06/13/2005 Sanctions Ordered: Monetary/Fine $300,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE ORDER TO CEASE AND DESIST AND PAYMENT OF $300,000 TO THE MISSOURI INVESTOR EDUCATION AND PROTECTION FUND. IN ADDITION FOR A PERIOD OF TWO YEARS: (1) UPON REQUEST PROVIDE THE STATE OF MISSOURI BRANCH OFFICE REVIEWS BY REGULATORS, INCLUDING THE SEC, NYSE AND THE NASD, (2) PROMPTLY REPORT TO THE STATE OF MISSOURI THE NAME AND CRD NUMBER OF EACH MISSOURI-BASED AGENT IDENTIFIED BY THE SYSTEM WARRANTING HEIGHTENED SUPERVISION, (3) PROMPTLY REPORT ALL MATERIAL CHANGES IN COMPLIANCE SUPERVISORS WITH DIRECT OVERSIGHT OF MISSOURI-BASED AGENTS AND BRANCH OFFICES. i Disclosure 135 of 167 Reporting Source: Firm Current Status: Final Allegations: DURING AUGUST 5, 1999 THROUGH JULY 31, 2000, A REGISTERED REPRESENTATIVE OF THE FIRM HAD TRANSACTED BUSINESS WITH MAINE CLIENTS AND WAS NOT LICENSED OR EXEMPT. THE FIRM WAS ALLEGED TO HAVE VIOLATED THE REVISED MAINE SECURITIES ACT BY EMPLOYING THIS REGISTERED REPRESENTATIVE WHO WAS NOT LICENSED OR EXEMPT IN THE STATE AND FAILING TO REASONABLY SUPERVISE ONE OF ITS REGISTERED REPRESENTATIVES. Initiated By: STATE OF MAINE, OFFICE OF SECURITIES Date Initiated: 04/25/2005 Docket/Case Number: 05-026-CAG

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief ADMINISTRATIVE FINE OF $27,000 Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 268 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief ADMINISTRATIVE FINE OF $27,000 Sought:

Resolution: Consent Resolution Date: 04/25/2005 Sanctions Ordered: Censure Monetary/Fine $27,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO THE CENSURE AND PAYMENT OF $27,000. i Disclosure 136 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULES 2110, 2210(D)(1)(A), 2210(D)(1)(B), 2210(C)(1), 3010(A)(1), 3010(B)(1), IM-2210-2 - WACHOVIA SECURITIES, LLC ACTING THROUGH A REGISTERED REPRESENTATIVE, CREATED AND DISTRIBUTED WRITTEN COMMUNICATIONS THAT FAILED TO DISCLOSE ADEQUATELY MATERIAL FACTS REGARDING INVESTMENT PRODUCTS AND STRATEGIES, OR MADE EXAGGERATED, UNWARRANTED OR MISLEADING STATEMENTS OR CLAIMS REGARDING THOSE PRODUCTS, OR BOTH. THE FIRM ACTING PRIMARILY THROUGH A BRANCH MANAGER, FAILED TO SUPERVISE REASONABLY A REGISTERED REPRESENTATIVES WRITTEN COMMUNICATIONS ACTIVITIES IN CONNECTION WITH CORRESPONDENCES AND SALES LITERATURE. IN ADDITION, WACHOVIA FAILED TO FILE THE REGISTERED REPRESENTATIVE'S SALES LITERATURE WITH NASD. THE FIRM ALSO FAILED TO ESTABLISH AND MAINTAIN PROCEDURES THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD'S REQUIREMENT FOR FILING SALES LITERATURE WITHIN 10 DAYS OF FIRST USE. THE FIRM ACTING PRIMARILY THROUGH AN INDIVIDUAL, REVIEWED AND APPROVED A REGISTERED REPRESENTATIVE'S WRITTEN COMMUNICATIONS THAT WERE DEFICIENT BECAUSE THEY FAILED TO DISCLOSE ADEQUATELY MATERIAL FACTS REGARDING PRODUCTS OR INVESTMENT STRATEGIES RECOMMENDED. BY APPROVING THESE WRITTEN COMMUNICATIONS, WACHOVIA FAILED TO REASONABLY SUPERVISE THE REGISTERED REPRESENTATIVE. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES INCORRECTLY DEFINED "SALES LITERATURE" WHICH IS REQUIRED TO BE FILED WITH NASD WITHIN 10 DAYS OF FIRST USE. THE FIRM'S MANAGERIAL PERSONNEL USED THE WRITTEN SUPERVISORY PROCEDURES TO DETERMINE WHETHER A WRITTEN COMMUNICATION SHOULD BE FORWARDED TO NASD. BY INCORRECTLY DEFINING "SALES LITERATURE," WACHOVIA'S ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 269 WRITTEN SUPERVISORY PROCEDURES IMPROPERLY INSTRUCTED THE FIRM'S MANAGERIAL PERSONNEL ON WHEN WRITTEN COMMUNICATION QUALIFIED AS SALES LITERATURE THAT NEEDED TO BE FILED WITH NASD. NASD CONDUCT RULES 2110, 2210(D)(1)(A), 2210(D)(1)(B), 2210(C)(1), 3010(A)(1), 3010(B)(1), IM-2210-2 - WACHOVIA SECURITIES, LLC ACTING THROUGH A REGISTERED REPRESENTATIVE, CREATED AND DISTRIBUTED WRITTEN COMMUNICATIONS THAT FAILED TO DISCLOSE ADEQUATELY MATERIAL FACTS REGARDING INVESTMENT PRODUCTS AND STRATEGIES, OR MADE EXAGGERATED, UNWARRANTED OR MISLEADING STATEMENTS OR CLAIMS REGARDING THOSE PRODUCTS, OR BOTH. THE FIRM ACTING PRIMARILY THROUGH A BRANCH MANAGER, FAILED TO SUPERVISE REASONABLY A REGISTERED REPRESENTATIVES WRITTEN COMMUNICATIONS ACTIVITIES IN CONNECTION WITH CORRESPONDENCES AND SALES LITERATURE. IN ADDITION, WACHOVIA FAILED TO FILE THE REGISTERED REPRESENTATIVE'S SALES LITERATURE WITH NASD. THE FIRM ALSO FAILED TO ESTABLISH AND MAINTAIN PROCEDURES THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD'S REQUIREMENT FOR FILING SALES LITERATURE WITHIN 10 DAYS OF FIRST USE. THE FIRM ACTING PRIMARILY THROUGH AN INDIVIDUAL, REVIEWED AND APPROVED A REGISTERED REPRESENTATIVE'S WRITTEN COMMUNICATIONS THAT WERE DEFICIENT BECAUSE THEY FAILED TO DISCLOSE ADEQUATELY MATERIAL FACTS REGARDING PRODUCTS OR INVESTMENT STRATEGIES RECOMMENDED. BY APPROVING THESE WRITTEN COMMUNICATIONS, WACHOVIA FAILED TO REASONABLY SUPERVISE THE REGISTERED REPRESENTATIVE. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES INCORRECTLY DEFINED www.finra.org/brokercheck "SALES LITERATURE" WHICH IS REQUIRED TO BE FILED WITH NASD User Guidance WITHIN 10 DAYS OF FIRST USE. THE FIRM'S MANAGERIAL PERSONNEL USED THE WRITTEN SUPERVISORY PROCEDURES TO DETERMINE WHETHER A WRITTEN COMMUNICATION SHOULD BE FORWARDED TO NASD. BY INCORRECTLY DEFINING "SALES LITERATURE," WACHOVIA'S WRITTEN SUPERVISORY PROCEDURES IMPROPERLY INSTRUCTED THE FIRM'S MANAGERIAL PERSONNEL ON WHEN WRITTEN COMMUNICATION QUALIFIED AS SALES LITERATURE THAT NEEDED TO BE FILED WITH NASD. Initiated By: NASD Date Initiated: 04/13/2005 Docket/Case Number: CE2050007

Principal Product Type: Annuity(ies) - Variable Other Product Type(s): FUNDS Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/13/2005 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 $25,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIA SECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS THEREFORE, THE FIRM IS CENSURED AND FINED $25,000. i Reporting Source: Firm Current Status: Final Allegations: DURING THE PERIOD OF MAY 25, 2001 THROUGH APRIL 12, 2002, WACHOVIA WAS ALLEGED TO HAVE VIOLATED CONDUCT RULES 2110 AND 2210(C)(1)IN FAILING TO FILE SALES LITERATURE WITH THE NASD, ALLEGED TO HAVE VIOLATED RULE 2110 AND 3010(A)(1) IN FAILING TO RESONABLY SUPERVISE THE WRITTEN COMMUNICATION OF A REGISTERED REPRESENTATIVE, AND ALLEGED TO HAVE VIOLATED RULE ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 270 2110 AND 3010(B)(1)IN FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN PROCEDURES ON COMMUNICATIONS TO THE PUBLIC. DURING THE PERIOD OF MAY 25, 2001 THROUGH APRIL 12, 2002, www.finra.org/brokercheck WACHOVIA WAS ALLEGED TO HAVE VIOLATED CONDUCT RULES 2110 AND User Guidance 2210(C)(1)IN FAILING TO FILE SALES LITERATURE WITH THE NASD, ALLEGED TO HAVE VIOLATED RULE 2110 AND 3010(A)(1) IN FAILING TO RESONABLY SUPERVISE THE WRITTEN COMMUNICATION OF A REGISTERED REPRESENTATIVE, AND ALLEGED TO HAVE VIOLATED RULE 2110 AND 3010(B)(1)IN FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN PROCEDURES ON COMMUNICATIONS TO THE PUBLIC. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/13/2005 Docket/Case Number: AWC CE2050007

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $25,000 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/13/2005 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIA CONSENTED TO A CENSURE AND FINE OF $25,000. THE FINE WAS PAID ON APRIL 29, 2005. i Disclosure 137 of 167 Reporting Source: Regulator Current Status: Final Allegations: AGENT MISAPPROPRIATES CLIENT FUNDS AND WACHOVIA'S FAILURE TO SUPERVISE ITS AGENTS AND TO ENFORCE WRITTEN PROCEDURES Initiated By: CALIFORNIA DEPARTMENT OF CORPORATIONS. Date Initiated: 11/10/2004 Docket/Case Number: URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Other ©2021Sought: FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 271 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief ADMINISTRATIVE ACTION INIATED ON 11/10/04. Sought:

Resolution: Stipulation and Consent Resolution Date: 11/10/2004 Sanctions Ordered: Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: NO PART OF PENALTIES WAIVED. Regulator Statement WACHOVIA STIPULATED TO THE ISSUANCE OF AN ADMINISTRATIVE CONSENT ORDER BY THE CALIFORNIA CORPORATIONS COMMISSIONER PER WHICH WACHOVIA WAS ORDERED TO DISCONTINUE THE FOLLOWING VIOLATIONS: CALIFORNIA CORPORATIONS CODE SECTIONS 25210(B) & (A), AND 25218, AND CALIFORNIA CODE OF REGULATIONS, TITLE 10, SECTIONS 260.218 AND 260.218(A) & (C)(2) AND (3). WACHOVIA ALSO AGREED TO MAKE CERTAIN REVISIONS OF ITS AGENT HIRING POLICIES AND PROCEDURES, AND ITS CLIENT TRANSACTION CONFIRMATION PROCEDURES, AND TO PAY THE COMMISSIONER A CIVIL PENALTY IN THE AMOUNT OF $250,000, WHICH AMOUNT WAS TIMELY PAID IN FULL. THE ADMINISTRATIVE ACTION WAS THE RESULT OF A STIPULATION WHEREBY THE COMMISSIONER AGREED TO DISMISS A CIVIL COMPLAINT IT HAD FILED AGAINST WACHOVIA, JAMES A. MEHALL AND TODD MICHAEL LONG ON 9/30/03, REGARDING LONG'S UNAUTHORIZED DISBURSEMENT OF CLIENT FUNDS AND WACHOVIA'S ALLEGED FAILURE TO SUPERVISE LONG'S ACTIVITIES. i Reporting Source: Firm Current Status: Final Allegations: THE FIRM WAS ALLEGED TO HAVE VIOLATED CORPORATIONS CODE SECTION 25210(B), 25218, CODE OF REGULATIONS SECTION 260.210(A), 260.218, 260.218.4(A), 260.218.4(C)IN THE EMPLOYING OF AN AGENT WITHOUT INVESTIGATING THE EXPERIENCE AND BACKGROUND OF THE INDIVIDUAL, FAILING TO ENFORCE WRITTEN PROCEDURES AND FAILING TO SUPERVISE THE AGENT. Initiated By: STATE OF CALIFORNIA, DEPARTMENT OF CORPORATIONS Date Initiated: 09/30/2003 Docket/Case Number:

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: 11/12/2004 Sanctions Ordered: Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO A PENALTY OF $250,000 PAID ON DECEMBER 20, 2004. THE FIRM ALSO REVISED AND ADOPTED ENHANCED HIRING POLICIES AND REVISED AND ADOPTED ENHANCED POLICIES AND PROCEDURES SURROUNDING WIRE TRANSFERS AND JOURNALING OF MONIES OR SECURITIES. i Disclosure 138 of 167 Reporting Source: Regulator Current Status: Final Allegations: ARTICLE V, SECTIONS 2(C) AND 3(B) OF NASD'S BY-LAWS, NASD RULES 2110, 3010 - WACHOVIA SECURITIES, LLC FILED AT LEAST 610 LATE AMENDMENTS TO FORMS U4 AND U5, REPRESENTING APPROXIMATELY 32% OF THE REQUIRED AMENDMENTS RELATING TO REPORTABLE CUSTOMER COMPLAINTS, TERMINATIONS, REGULATORY ACTIONS, AND CRIMINAL DISCLOSURES. THE 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: CAF040089

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 $650,000.00 Other Sanctions Ordered: PROHIBITION; UNDERTAKINGS Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIA SECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED $650,000 WHICH SHALL BE PAID WITHIN 10 DAYS OF NOTICE OF ACCEPTANCE OF THIS AWC. THE FIRM IS ALSO PROHIBITED FROM REGISTERING ANY ASSOCIATED PERSONS, IN A NON-SUPERVISORY SALES CAPACITY FOR FIVE CONSECUTIVE BUSINESS DAYS. PROMPTLY FOLLOWING NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM'S INTERNAL AUDIT DEPT. OR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE V REPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALL CONDUCT AN AUDIT FOR THE PERIOD JANUARY 1, 2004 THROUGH SEPTEMBER 30, 2004 TO ASSESS THE EFFECTIVENESS OF ITS SYSTEM AND PROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5 AMENDMENTS AND SHALL PREPARE A WRITTEN REPORT 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. 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. NO LATER THAN 60 DAYS AFTER THE DATE OF THE 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. 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. NO LATER THAN SIX MONTHS AFTER NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS ©2021 FINRA. All rights reserved. Report aboutREVIEWED WELLS FARGO ITS SYSTEM CLEARING AND SERVICES, PROCEDURES LLC FOR COMPLYING WITH ITS 274 ARTICLE V REPORTING OBLIGATIONS AND HAS ESTABLISHED A SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REPORTING REQUIREMENTS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIA SECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED $650,000 WHICH SHALL BE PAID WITHIN 10 DAYS OF NOTICE OF ACCEPTANCE OF THIS AWC. THE FIRM IS ALSO PROHIBITED FROM REGISTERING ANY ASSOCIATED PERSONS, IN A NON-SUPERVISORY SALES CAPACITY FOR FIVE CONSECUTIVE BUSINESS DAYS. PROMPTLY FOLLOWING NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM'S INTERNAL AUDIT DEPT. OR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE V REPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALL CONDUCT AN AUDIT FOR THE PERIOD JANUARY 1, 2004 THROUGH SEPTEMBER 30, 2004 TO ASSESS THE EFFECTIVENESS OF ITS SYSTEM AND PROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5 AMENDMENTS AND SHALL PREPARE A WRITTEN REPORT 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. 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. NO LATER THAN 60 DAYS AFTER THE DATE OF THE 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. NO LATER THAN 60 DAYS AFTER THE LAST DAY OF THE NEXT FOUR QUARTERS, AN www.finra.org/brokercheck OFFICER SHALL CERTIFY IN WRITING TO NASD THAT AN AUDIT WAS User Guidance CONDUCTED, THE CURRENT AUDIT REPORT WAS REVIEWED, AND RECOMMENDATIONS IMPLEMENTED, OR BEGUN TO BE IMPLEMENTED. 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. Regulator Statement THE FIRM CANNOT REGISTER ANY ASSOCIATED PERSONS, IN A NON- SUPERVISORY SALES CAPACITY EFFECTIVE JANUARY 24, 2005 TO CLOSE OF BUSINESS JANUARY 28, 2005. i Reporting Source: Firm Current Status: Final Allegations: THE FIRM WAS ALLEGED TO HAVE FAILED TO FILE FORM U4 AND U5 AMENDMENTS IN A TIMELY MANNER FROM JANUARY, 2002 TO MARCH, 2004. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/30/2004 Docket/Case Number: AWC NO. CAF040089

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: 11/30/2004 Sanctions Ordered: Censure Monetary/Fine $650,000.00 Other Sanctions Ordered: THE FIRM IS PROHIBITED IN REGISTERING ANY ASSOCIATED PERSON, IN A NONSUPERVISORY SALES CAPACITY, FOR 5 CONSECUTIVE BUSINESS DAYS. Sanction Details: THE FIRM WAS FINED IN THE TOTAL AMOUNT OF $650,000 WHICH WAS PAID ON NOVEMBER 16, 2004. THE FIRM IS PROHIBITED IN REGISTERING ANY ASSOCIATED PERSON, IN A NONSUPERVISORY SALES CAPACITY, FOR 5 CONSECUTIVE BUSINESS DAYS BEGINNING ON JANUARY 24, 2005 AND ENDING ON JANUARY 28, 2005. THE FIRM'S INTERNAL AUDIT DEPARTMENT IS REQUIRED TO AUDIT U4 AND U5 AMENDMENTS FILED BETWEEN ©2021 FINRA. All rights reserved. Report aboutJANUARY WELLS FARGO1, 2004 CLEARING AND SEPTEMBER SERVICES, LLC 30, 2004 SUMMARIZING THEIR 275 FINDINGS AND RECOMMENDATIONS WITH AN OFFICER. FURTHER, AN OFFICER SHALL CERTIFY THE FIRM HAS REVIEWED ITS SYSTEM AND PROCEDURES AND HAVE ESTABLISHED A SYSTEM AND PROCEDURES TO COMPLY WITH ARTICLE V REPORTING OBLIGATIONS. THE FIRM WAS FINED IN THE TOTAL AMOUNT OF $650,000 WHICH WAS PAID ON NOVEMBER 16, 2004. THE FIRM IS PROHIBITED IN REGISTERING www.finra.org/brokercheck ANY ASSOCIATED PERSON, IN A NONSUPERVISORY SALES CAPACITY, FOR User Guidance 5 CONSECUTIVE BUSINESS DAYS BEGINNING ON JANUARY 24, 2005 AND ENDING ON JANUARY 28, 2005. THE FIRM'S INTERNAL AUDIT DEPARTMENT IS REQUIRED TO AUDIT U4 AND U5 AMENDMENTS FILED BETWEEN JANUARY 1, 2004 AND SEPTEMBER 30, 2004 SUMMARIZING THEIR FINDINGS AND RECOMMENDATIONS WITH AN OFFICER. FURTHER, AN OFFICER SHALL CERTIFY THE FIRM HAS REVIEWED ITS SYSTEM AND PROCEDURES AND HAVE ESTABLISHED A SYSTEM AND PROCEDURES TO COMPLY WITH ARTICLE V REPORTING OBLIGATIONS. i Disclosure 139 of 167 Reporting Source: Firm Current Status: Final Allegations: N/A Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/13/1998 Docket/Case Number: C0970033

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/13/1998 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: RESULTED IN A MONETARY FINE OF $250.00. Firm Statement ON JANUARY 13, 1998 DISTRICT NO. 5 NOTIFIED RESPONDENT, SOUTHTRUST SECURITIES,INC. (CRD 17322-MERGED INTO WACHOVIA SECURITIES, LLC), THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C05970033 WAS ACCEPTED; THEREFORE THE FIRM WAS FINED $250 - MSRB RULE G-36 RESPONDENT MEMBER FAILED TO FILE TO THE MSRB A FORM G-36 IN A TIMELY MANNER AND FILED INACCURATE FORMS G-36 TO THE MSRB ***$250.00 PAID ON 2/9/98, INVOICE NO. 98-05- 129*** i Disclosure 140 of 167

Reporting Source: Firm Current Status: Final Allegations: SOUTHTRUST SECURITIES, INC. (CRD# 17922 - MERGED INTO WACHOVIA SECURITIES, LLC) FAILED TO EFFECT RENEWAL OF 7 EXISTING REGISTERED OFFICES WITH THE STATE OF FLORIDA. Initiated By: STATE OF FLORIDA, DEPARTMENT OF BANKING AND FINANCE Date Initiated: 05/11/2000 Docket/Case Number: 2970-S-6/00

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: Stipulation and Consent Resolution Date: 07/20/2000 Sanctions Ordered: Monetary/Fine $5,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: PAID FINE ON 7/10/2000. Firm Statement FINAL ORDER WAS ACCEPTED ON 7/20/2000 BY THE STATE OF FLORIDA; ALL SUBJECT OFFICES WERE PROMPTLY APPROVED BY THE STATE. i Disclosure 141 of 167 Reporting Source: Firm Current Status: Final Allegations: VIOLATED APPLICABLE BOOKS AND RECORDS REQUIREMENTS IN CONNECTION WITH CERTAIN PRIMARY DISTRIBUTIONS OF DEBT SECURITIES OF ONE OR MORE OF THE FOLLOWING GOVERNMENT SPONSORED ENTITIES: FHLB, FFCBFC FNMA, FHLMC, AND STUDENT LOAN MARKETING ASSOCIATION. SPEDIFICALLY VIOLATED RULES 17(A), 17(A)(3), AND 17(A)(4) OF THE SECURITIES EXCHANGE ACT OF 1934. Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION Date Initiated: 01/16/1992 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 277 www.finra.org/brokercheck User Guidance

Date Initiated: 01/16/1992 Docket/Case Number: NONE

Principal Product Type: Debt - Government Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CIVIL AND ADMINISTRATIVE PENALTY/FINE Sought:

Resolution: Settled Resolution Date: 01/16/1992 Sanctions Ordered: Monetary/Fine $10,000.00 Other Sanctions Ordered: SOUTHTRUST SECURITIES, INC. (CRD# 17922 - MERGED INTO WACHOVIA SECURITIES, LLC) WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATION OR FUTURE VIOLATION OF SAID RULES, AND SSI WAS REQUIRED TO DEVELOP,IMPLEMENT, AND MAINTAIN POLICIES AND PROCEDURES TO ENSURE FUTURE COMPLIANCE. Sanction Details: SOUTHTRUST SECURITIES, INC. (CRD# 17922 - MERGED INTO WACHOVIA SECURITIES, LLC) WAS ORDERED TO PAY A $10,000 CIVIL MONETARY PENALTY, PAID IN FULL ON 01/16/1992. Firm Statement SEC INSTITUTED PROCEEDINGS AGAINST SOUTHTRUST SECURITIES, INC. (CRD# 17922 - MERGED INTO WACHOVIA SECURITIES, LLC) AND AT LEAST 97 OTHER FIRMS, EACH OF WHICH WAS A BROKER AND/OR DEALER. i Disclosure 142 of 167 Reporting Source: Firm Current Status: Final Allegations: THE FIRM INADVERTENTLY FAILED TO RENEW SALES REPRESENTATIVE, LARRY M MALLES, LICENSE BY DECEMBER 31, 2003 WHICH RESULTED IN MR MALLES TRANSACTING BUSINESS UNLICENSED FROM JANUARY 6, 2004 THROUGH JANUARY 8, 2004. Initiated By: STATE OF MAINE, OFFICE OF SECURITIES Date Initiated: 09/16/2004 Docket/Case Number: 04-063-CAG

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

Resolution: Consent Resolution Date: 09/16/2004 Sanctions Ordered: Monetary/Fine $1,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING VIOLATION OF THE REVISED MAINE SECURITIES ACT, THE FIRM AGREED TO A PENALTY OF $1500 AND WOULD COMPLY WITH ALL LICENSING AND OTHER LEGAL REQUIREMENTS FOR PERSONS ACTING IN A SECURITIES SALES REPRESENTATIVE CAPACITY. i Disclosure 143 of 167 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULES G-17, G-30(A) - WACHOVIA SECURITIES, LLC RECEIVED REQUESTS FROM PUBLIC CUSTOMERS TO LIQUIDATE EIGHT DIFFERENT MUNICIPAL SECURITY POSITIONS AND CONTACTED A BROKER'S BROKER AND OBTAINED BIDS FOR THE CUSTOMERS' SECURITIES. BASED ON THE BIDS PROVIDED BY THE BROKER'S BROKER, WACHOVIA PURCHASED THE SECURITIES FROM THE CUSTOMERS FOR ITS OWN ACCOUNT AND SOLD THE SECURITIES TO THE BROKER'S BROKER AT A NOMINAL GAIN. IN ALL EIGHT INSTANCES, THE PRICES PAID TO THE CUSTOMERS AND RECEIVED BY THE FIRM WERE BELOW THE FAIR MARKET VALUE FOR THE SECURITY IN AMOUNTS RANGING FROM 10.94% TO 63.45%. BY RELYING SOLELY ON THE BIDS PROVIDED BY THE BROKER'S BROKER TO DETERMINE THE FAIR MARKET VALUE OF THE SECURITY, WACHOVIA FAILED TO ENSURE THAT THE TRANSACTIONS WERE EXECUTED AT AGGREGATE PRICES THAT WERE FAIR AND REASONABLE. Initiated By: NASD Date Initiated: 06/28/2004 Docket/Case Number: C05040043

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: 06/28/2004 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $20,000.00 Disgorgement/Restitution Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIA SECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM WAS CENSURED, FINED $20,000, AND REQUIRED TO PAY $19,486.25, PLUS INTEREST, IN RESTITUTION TO THE CUSTOMER. SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION SHALL BE PROVIDED TO NASD NO LATER THAN 90 DAYS AFTER ACCEPTANCE OF THE AWC. THE FIRM SHALL ALSO PROVIDE NASD, WITHIN 90 DAYS OF ACCEPTANCE OF THIS AWC, 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: THE FIRM WAS ALLEGED TO HAVE FAILED TO EXECUTE EIGHT MUNICIPAL SECURITY POSITIONS AT PRICES THAT WERE FAIR AND REASONABLE, DURING THE PERIOD FROM ON OR ABOUT AUGUST 22, 2002 THROUGH DECEMBER 10, 2002 IN VIOLATION OF MSRB RULES G-17 AND G-30(A). Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/28/2004 Docket/Case Number: C05040043 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 280 www.finra.org/brokercheck User Guidance

Docket/Case Number: C05040043

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 RESTITUTION OF $19,486.25 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/28/2004 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Disgorgement/Restitution Other Sanctions Ordered: CUSTOMER RESTITUTION OF $19,486.25 AND WITHIN 90 DAYS OF ACCEPTANCE OF AWC THE FIRM SHALL PROVIDE THE NASD WITH A COPY OF ITS UPDATED WRITTEN SUPERVISORY PROCEDURES AS IT RELATES TO DETERMINING FAIR MARKET VALUE OF MUNICIPAL SECURITIES. Sanction Details: THE FIRM WAS CENSURED, FINED $20,000 AND PAYMENT OF RESTITUTION TO CLIENTS OF $19,486.25. WITHIN 90 DAYS OF ACCEPTANCE OF AWC THE FIRM SHALL PROVIDE THE NASD WITH A COPY OF ITS UPDATED WRITTEN SUPERVISORY PROCEDURES AS IT RELATES TO DETERMINING FAIR MARKET VALUE OF MUNICIPAL SECURITIES. i Disclosure 144 of 167 Reporting Source: Regulator Current Status: Final Allegations: **05/26/2004** STIPULATION AND CONSENT TO PENALTY FILED BY THE DIVISION OF ENFORCEMENT AND PENDING. A. CONSENTED TO FINDINGS THAT THE FIRM: 1. VIOLATED EXCHANGE RULE 345A AND 345(A) BY: A) PERMITTING EMPLOYEES TO ACT IN A REGISTERED CAPACITY AND GENERATE COMMISSIONS WHILE THEIR REGISTRATION STATUS WAS INACTIVE; AND B) PERMITTING A RETAIL COMPLIANCE MANAGER TO SUPERVISE TEN OR MORE INDIVIDUALS WHO ACTED IN A COMPLIANCE CAPACITY EVEN THOUGH THE MANAGER DID NOT POSSESS THE REQUIRED QUALIFICATION. 2. VIOLATED EXCHANGE RULE 345 AND 351 BY: A) FAILING TO REPORT AND/OR PROMPTLY AND ACCURATELY REPORT, CUSTOMER COMPLAINTS AS REQUIRED; AND B) FAILING TO FILE AND/OR PROMPTLY FILE, FORMS U-5 AND A FORM RE-3 WITH THE EXCHANGE. 3. VIOLATED EXCHANGE RULE 440 AND SEC RULES 240.17A-3 AND 17A-4 BY ©2021 FINRA. All rights reserved. Report aboutFAILING WELLS TO FARGO MAINTAIN CLEARING SERVICES, ACCURATE LLC BOOKS AND RECORDS IN 281 CONNECTION WITH THE REPORTING OF CUSTOMERS’ COMPLAINTS AND FILING OF FORMS U-5 AND A FORM RE-3. 4. VIOLATED EXCHANGE RULE 405 BY FAILING TO ENSURE THAT CUSTOMERS RECEIVED MUTUAL FUND SWITCH LETTERS DISCLOSING SPECIFIC FEES INCURRED BY CUSTOMERS. 5. VIOLATED EXCHANGE RULES 342 AND 472 IN THAT THE FIRM FAILED TO REASONABLY SUPERVISE AND CONTROL AND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND ESTABLISH A SYSTEM OF FOLLOW–UP AND REVIEW WITH RESPECT TO: A) ASSURING COMPLIANCE WITH EXCHANGE RULES REGARDING CONTINUING EDUCATION AND REGISTRATION REQUIREMENTS; **CONTINUED IN #14** **05/26/2004** STIPULATION AND CONSENT TO PENALTY FILED BY THE DIVISION OF ENFORCEMENT AND PENDING. A. CONSENTED TO FINDINGS THAT THE FIRM: 1. VIOLATED EXCHANGE RULE 345A AND 345(A) BY: A) PERMITTING EMPLOYEES TO ACT IN A REGISTERED CAPACITY AND GENERATE COMMISSIONS WHILE THEIR REGISTRATION STATUS WAS INACTIVE; AND B) PERMITTING A RETAIL COMPLIANCE MANAGER TO SUPERVISE TEN OR MORE INDIVIDUALS WHO ACTED IN A COMPLIANCE CAPACITY EVEN THOUGH THE MANAGER DID NOT POSSESS THE REQUIRED QUALIFICATION. 2. VIOLATED EXCHANGE RULE 345 AND 351 BY: www.finra.org/brokercheck A) FAILING TO REPORT AND/OR PROMPTLY AND ACCURATELY REPORT, User Guidance CUSTOMER COMPLAINTS AS REQUIRED; AND B) FAILING TO FILE AND/OR PROMPTLY FILE, FORMS U-5 AND A FORM RE-3 WITH THE EXCHANGE. 3. VIOLATED EXCHANGE RULE 440 AND SEC RULES 240.17A-3 AND 17A-4 BY FAILING TO MAINTAIN ACCURATE BOOKS AND RECORDS IN CONNECTION WITH THE REPORTING OF CUSTOMERS’ COMPLAINTS AND FILING OF FORMS U-5 AND A FORM RE-3. 4. VIOLATED EXCHANGE RULE 405 BY FAILING TO ENSURE THAT CUSTOMERS RECEIVED MUTUAL FUND SWITCH LETTERS DISCLOSING SPECIFIC FEES INCURRED BY CUSTOMERS. 5. VIOLATED EXCHANGE RULES 342 AND 472 IN THAT THE FIRM FAILED TO REASONABLY SUPERVISE AND CONTROL AND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND ESTABLISH A SYSTEM OF FOLLOW–UP AND REVIEW WITH RESPECT TO: A) ASSURING COMPLIANCE WITH EXCHANGE RULES REGARDING CONTINUING EDUCATION AND REGISTRATION REQUIREMENTS; **CONTINUED IN #14** Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 05/26/2004 Docket/Case Number: HPD# 04-115

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

Resolution: Decision Resolution Date: 08/13/2004 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: **07/08/2004** #04-115 ISSUED BY THE NYSE HEARING PANEL DECISION: VIOLATED EXCHANGE RULE 345A AND 345(A) BY PERMITTING EMPLOYEES TO ACT IN A REGISTERED CAPACITY WHILE REGISTRATION STATUS WAS INACTIVE AND BY PERMITTING A MANAGER TO SUPERVISE INDIVIDUALS IN A COMPLIANCE CAPACITY WITHOUT THE REQUIRED QUALIFICATION; VIOLATED EXCHANGE RULES 345 AND 351 AND 440 AND SEC RULES 240.17A-3 AND 17A-4 BY FAILING TO PROMPTLY AND ACCURATELY REPORT CUSTOMER COMPLAINTS AND FAILING TO PROMPTLY FILE FORMS U-5 AND A FORM RE-3; VIOLATED EXCHANGE RULE 405 BY FAILING TO ENSURE THAT CUSTOMERS RECEIVED MUTUAL FUND SWITCH LETTERS DISCLOSING SPECIFIC FEES; VIOLATED EXCHANGE RULES 342 AND 472 BY FAILING TO REASONABLY SUPERVISE WITH RESPECT TO CONTINUING EDUCATION AND REGISTRATION ©2021 FINRA. All rights reserved. Report aboutREQUIREMENTS, WELLS FARGO CLEARING PROMPT SERVICES, REPORTING LLC OF CUSTOMER COMPLAINTS AND 282 FILING OF FORMS U-5 AND A FORM RE-3, ASSURING APPROPRIATE REVIEW OF CERTAIN DISCRETIONARY ACCOUNTS, MONITORING CUSTOMER ACCOUNTS TO ENSURE THAT CUSTOMERS RECEIVED BETTER EXECUTION PRICES THAN REGISTERED REPRESENTATIVES; AND ENSURING THAT RESEARCH REPORTS CONTAINED CLEAR, POSITIVE LANGUAGE IN SECURITIES IN WHICH THE FIRM WAS MAKING A MARKET – CONSENT TO CENSURE AND $250,000 FINE **07/08/2004** #04-115 ISSUED BY THE NYSE HEARING PANEL DECISION: VIOLATED EXCHANGE RULE 345A AND 345(A) BY PERMITTING EMPLOYEES TO ACT IN A REGISTERED CAPACITY WHILE REGISTRATION STATUS WAS INACTIVE AND BY PERMITTING A MANAGER TO SUPERVISE INDIVIDUALS IN A COMPLIANCE CAPACITY WITHOUT THE REQUIRED QUALIFICATION; VIOLATED EXCHANGE RULES 345 AND 351 AND 440 AND SEC RULES 240.17A-3 AND 17A-4 BY FAILING TO PROMPTLY AND ACCURATELY REPORT CUSTOMER COMPLAINTS AND FAILING TO www.finra.org/brokercheck PROMPTLY FILE FORMS U-5 AND A FORM RE-3; VIOLATED EXCHANGE User Guidance RULE 405 BY FAILING TO ENSURE THAT CUSTOMERS RECEIVED MUTUAL FUND SWITCH LETTERS DISCLOSING SPECIFIC FEES; VIOLATED EXCHANGE RULES 342 AND 472 BY FAILING TO REASONABLY SUPERVISE WITH RESPECT TO CONTINUING EDUCATION AND REGISTRATION REQUIREMENTS, PROMPT REPORTING OF CUSTOMER COMPLAINTS AND FILING OF FORMS U-5 AND A FORM RE-3, ASSURING APPROPRIATE REVIEW OF CERTAIN DISCRETIONARY ACCOUNTS, MONITORING CUSTOMER ACCOUNTS TO ENSURE THAT CUSTOMERS RECEIVED BETTER EXECUTION PRICES THAN REGISTERED REPRESENTATIVES; AND ENSURING THAT RESEARCH REPORTS CONTAINED CLEAR, POSITIVE LANGUAGE IN SECURITIES IN WHICH THE FIRM WAS MAKING A MARKET – CONSENT TO CENSURE AND $250,000 FINE Regulator Statement B) ASSURING COMPLIANCE WITH EXCHANGE RULES TO PROMPTLY AND ACCURATELY REPORT CUSTOMER COMPLAINTS AND FILE FORMS U-5 AND A FORM RE-3; ASSURING THAT CERTAIN DISCRETIONARY ACCOUNTS WERE RECEIVING THE APPROPRIATE SUPERVISORY REVIEW; D) MONITORING CUSTOMER ACCOUNTS TO ENSURE THAT CUSTOMERS RECEIVED BETTER EXECUTION PRICES THAN REGISTERED REPRESENTATIVES; AND E) ENSURING THAT RESEARCH REPORTS CONTAINED CLEAR, POSITIVE LANGUAGE IN SECURITIES IN WHICH THE FIRM WAS MAKING A MARKET. B. THE IMPOSITION BY THE EXCHANGE OF THE PENALTY OF: 1. A CENSURE; AND 2. A FINE OF $250,000. **8/13/04**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT: MICHELE VAN TASSEL (212) 656-5340. i Reporting Source: Firm Current Status: Final Allegations: AS A RESULT OF ITS EXAM OF FIRST UNION IN 2000 AND 2001, THE NYSE FOUND REGISTRATION ISSUES, CUSTOMER COMPLAINT REPORTING DEFICIENCIES, REVIEW OF DISCRETIONARY ACCOUNTS SHORTCOMINGS, INSUFFICENT DISCLOSURE IN MUTUAL FUND SWITCH LETTERS AND LACK OF CLEAR LANGUAGE IN RESEARCH REPORTS. Initiated By: NEW YORK STOCK EXCHANGE, INC. Date Initiated: 07/08/2004 Docket/Case Number: HPD# 04-115

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 OF $250,000 Sought:

Resolution: Consent Resolution Date: 08/13/2004 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING THE ALLEGATIONS, THE FIRM AGREED TO THE ENTRY OF A CONSENT ORDER, THE TERMS OF WHICH WERE A CENSURE AND A FINE OF $250,000. PAYMENT OF THE FINE WAS MADE ON AUGUST 25, 2004. i Disclosure 145 of 167 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE NOS. 33-8380 AND 34-49229, DATED FEBRUARY 12, 2004: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION" OR "SEC") 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") AND SECTIONS 15(B)(4) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST WACHOVIA SECURITIES, LLC, F/K/A WACHOVIA SECURITIES, INC. ("RESPONDENT"). Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 02/12/2004 Docket/Case Number: 3-11410

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CENSURE; FINE; AND DISGORGEMENT, PLUS PREJUDGMENT INTEREST. Sought:

Resolution: Order Resolution Date: 02/12/2004 Does the order constitute a No final order based on violations of any laws or ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 284 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 $2,422,232.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: IT IS ORDERED: A. PURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT, THAT RESPONDENT IS CENSURED; B. PURSUANT TO SECTION 8A OF THE SECURITIES ACT AND SECTION 21C OF THE EXCHANGE ACT, THAT RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT, AND RULE 10B-10 UNDER THE EXCHANGE ACT; C. WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, RESPONDENT SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $2,422,232 TO THE UNITED STATES TREASURY; D. RESPONDENT SHALL PAY DISGORGEMENT AND PREJUDGMENT INTEREST; AND E. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THIS ORDER, UNLESS OTHERWISE EXTENDED BY THE COMMISSION FOR GOOD CAUSE SHOWN, RESPONDENT'S CHIEF EXECUTIVE OFFICER SHALL CERTIFY IN WRITING TO THE COMMISSION THAT RESPONDENT HAS IMPLEMENTED PROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, THAT CAN REASONABLY BE EXPECTED TO PREVENT AND DETECT FAILURES BY RESPONDENT TO PROVIDE APPROPRIATE BREAKPOINT DISCOUNTS FOR WHICH CUSTOMERS ARE ELIGIBLE ON PURCHASES OF FRONT-END LOAD MUTUAL FUNDS, BASED ON INFORMATION REASONABLY ASCERTAINABLE BY RESPONDENT. Regulator Statement RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION, AND CONSENTED TO THE ENTRY OF THIS ORDER. THE SEC FINDS THAT: DURING 2001 AND 2002 (THE "RELEVANT PERIOD"), RESPONDENT SOLD SHARES ISSUED BY MUTUAL FUNDS WITHOUT PROVIDING CERTAIN CUSTOMERS WITH THE REDUCTIONS IN FRONT-END LOADS, OR SALES CHARGES, ALSO KNOWN AS "BREAKPOINT" DISCOUNTS, DESCRIBED IN THE PROSPECTUSES OF THE FUNDS. ACCORDING TO DATA SUBMITTED TO NASD BY RESPONDENT, RESPONDENT IS ESTIMATED TO HAVE FAILED TO GIVE CERTAIN CUSTOMERS BREAKPOINT DISCOUNTS TOTALING APPROXIMATELY $4,844,465 DURING THE RELEVANT PERIOD. BY FAILING TO DISCLOSE TO CERTAIN CUSTOMERS THAT THEY WERE NOT RECEIVING THE BENEFIT OF ©2021 FINRA. All rights reserved. Report aboutAPPLICABLE WELLS FARGO BREAKPOINT CLEARING SERVICES, DISCOUNTS, LLC RESPONDENT WILLFULLY 285 VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. FURTHER, BECAUSE RESPONDENT DID NOT CHARGE THESE CUSTOMERS THE CORRECT SALES LOADS AS SET FORTH IN THE MUTUAL FUNDS' PROSPECTUSES, AND ALSO DID NOT DISCLOSE IN CONFIRMATIONS THE REMUNERATION RESPONDENT RECEIVED FROM THE SALES LOADS CHARGED TO THESE CUSTOMERS, RESPONDENT WILLFULLY VIOLATED RULE 10B-10 UNDER THE EXCHANGE ACT. RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION, AND CONSENTED TO THE ENTRY OF THIS ORDER. THE SEC FINDS THAT: DURING 2001 AND 2002 (THE "RELEVANT PERIOD"), RESPONDENT SOLD SHARES ISSUED BY MUTUAL FUNDS WITHOUT PROVIDING CERTAIN CUSTOMERS WITH THE REDUCTIONS IN FRONT-END LOADS, OR SALES CHARGES, ALSO KNOWN AS "BREAKPOINT" DISCOUNTS, DESCRIBED IN THE PROSPECTUSES OF THE FUNDS. www.finra.org/brokercheck ACCORDING TO DATA SUBMITTED TO NASD BY RESPONDENT, User Guidance RESPONDENT IS ESTIMATED TO HAVE FAILED TO GIVE CERTAIN CUSTOMERS BREAKPOINT DISCOUNTS TOTALING APPROXIMATELY $4,844,465 DURING THE RELEVANT PERIOD. BY FAILING TO DISCLOSE TO CERTAIN CUSTOMERS THAT THEY WERE NOT RECEIVING THE BENEFIT OF APPLICABLE BREAKPOINT DISCOUNTS, RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. FURTHER, BECAUSE RESPONDENT DID NOT CHARGE THESE CUSTOMERS THE CORRECT SALES LOADS AS SET FORTH IN THE MUTUAL FUNDS' PROSPECTUSES, AND ALSO DID NOT DISCLOSE IN CONFIRMATIONS THE REMUNERATION RESPONDENT RECEIVED FROM THE SALES LOADS CHARGED TO THESE CUSTOMERS, RESPONDENT WILLFULLY VIOLATED RULE 10B-10 UNDER THE EXCHANGE ACT. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM WAS ALLEGED TO HAVE VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT IN FAILING TO NOTIFY CUSTOMERS OF APPROPRIATE BREAKPOINT DISCOUNTS AND VIOLATED RULE 10B-10 UNDER THE EXCHANGE ACT IN FAILING TO DISCLOSE THE REMUNERATION THE FIRM RECEIVED FROM FRONT END SALES LOADS. Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 02/12/2004 Docket/Case Number: 3-11410

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CENSURE, MONETARY FINE AND DISGORGEMENT, PLUS PREJUDGMENT Sought: INTEREST

Resolution: Decision & Order of Offer of Settlement Resolution Date: 02/12/2004 Sanctions Ordered: Censure Monetary/Fine $2,422,232.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: THE TOTAL AMOUNT OF THE FINE WAS $4,844,465. $2,422,232 PAID TO THE NASD ON 2/19/04 AND $2,422,232 PAID TO THE SEC ON 2/19/04.

©2021Firm StatementFINRA. All rights reserved. Report aboutTHE WELLS FIRM FARGOAGREED CLEARING TO AN SERVICES, OFFER OF LLC SETTLEMENT WITHOUT ADMITTING 286 OR DENYING THE ALLEGATIONS. IN ADDITION TO THE CENSURE, CEASE AND DESIST ORDER, MONETARY FINE, THE FIRM HAS AGREED TO CERTAIN UNDERTAKINGS SET FORTH UNDER NASD AWC#CAF040008: (1) A TRADE BY TRADE REVIEW OF ALL FRONT END LOADED FUND SALES ABOVE $2500 FROM JANUARY 1, 1999 THROUGH NOVEMBER 3, 2003 TO ENSURE THAT CUSTOMERS RECEIVE THE APPROPRIATE SALES DISCOUNTS AND PROVIDE REFUNDS WHERE APPLICABLE, AND (2) WITHIN 6 MONTHS OF THE DATE OF THE AWC, THE FIRM WILL CERTIFY TO THE REGULATORS THAT A SYSTEM IS IN PLACE REASONABLY DESIGNED TO MAKE CERTAIN CUSTOMERS GET APPROPRIATE BREAKPOINT DISCOUNTS. www.finra.org/brokercheck User Guidance

Firm Statement THE FIRM AGREED TO AN OFFER OF SETTLEMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. IN ADDITION TO THE CENSURE, CEASE AND DESIST ORDER, MONETARY FINE, THE FIRM HAS AGREED TO CERTAIN UNDERTAKINGS SET FORTH UNDER NASD AWC#CAF040008: (1) A TRADE BY TRADE REVIEW OF ALL FRONT END LOADED FUND SALES ABOVE $2500 FROM JANUARY 1, 1999 THROUGH NOVEMBER 3, 2003 TO ENSURE THAT CUSTOMERS RECEIVE THE APPROPRIATE SALES DISCOUNTS AND PROVIDE REFUNDS WHERE APPLICABLE, AND (2) WITHIN 6 MONTHS OF THE DATE OF THE AWC, THE FIRM WILL CERTIFY TO THE REGULATORS THAT A SYSTEM IS IN PLACE REASONABLY DESIGNED TO MAKE CERTAIN CUSTOMERS GET APPROPRIATE BREAKPOINT DISCOUNTS. i Disclosure 146 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULE 2110 - RESPONDENT MEMBER SOLD SHARES ISSUED BY MUTUAL FUNDS WITHOUT PROVIDING CERTAIN CUSTOMERS WITH BREAKPOINT DISCOUNTS DESCRIBED IN THE PROSPECTUSES OF THE FUNDS; FAILED TO GIVE ITS CUSTOMERS BREAKPOINT DISCOUNTS IN 28.77% OF ELIGIBLE MUTUAL FUND TRANSACTIONS IN 2001 AND 2002 THAT RESULTED IN MISSED BREAKPOINTS THAT WOULD HAVE REDUCED CUSTOMERS' CHARGES BY AT LEAST $4.8 MILLION ON THEIR PURCHASES OF MUTUAL FUND SHARES WITH FRONT-END LOADS DURING THE RELEVANT PERIOD. Initiated By: NASD Date Initiated: 02/12/2004 Docket/Case Number: CAF040008

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/12/2004 Does the order constitute a No final order based on ©2021violations FINRA. of All any rights laws reserved. or Report about WELLS FARGO CLEARING SERVICES, LLC 287 regulations that prohibit fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

Initiated By: NASD Date Initiated: 02/12/2004 Docket/Case Number: CAF040008

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE AND UNDERTAKINGS Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/12/2004 Sanctions Ordered: Censure Monetary/Fine $2,422,232.00 Other Sanctions Ordered: UNDERTAKINGS Sanction Details: THE TOTAL AMOUNT OF THE FINE WAS $4,844,465. $2,422,232 PAID TO THE NASD ON 2/19/04 AND $2,422,232 PAID TO THE SEC ON 2/19/04. Firm Statement THE FIRM AGREED TO THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. IN ADDITION TO THE CENSURE AND MONETARY FINE, THE FIRM HAS AGREED TO CERTAIN UNDERTAKINGS: (1) A TRADE BY TRADE REVIEW OF ALL FRONT END LOADED FUND SALES ABOVE $2500 FROM JANUARY 1, 1999 THROUGH NOVEMBER 3, 2003 TO ENSURE THAT CUSTOMERS RECEIVE THE APPROPRIATE SALES DISCOUNTS AND PROVIDE REFUNDS WHERE APPLICABLE AND (2) WITHIN 6 MONTHS OF THE DATE OF THE AWC, THE FIRM WILL CERTIFY TO THE REGULATORS THAT A SYSTEM IS IN PLACE REASONABLY DESIGNED TO MAKE CERTAIN CUSTOMERS GET APPROPRIATE BREAKPOINT DISCOUNTS. i Disclosure 147 of 167 Reporting Source: Regulator Current Status: Final Allegations: LATE FILED AUDITED FINANCIALS FOR YEAR ENDING 2000. Initiated By: NEW HAMPSHIRE BUREAU OF SECURITIES REGULATION Date Initiated: 02/10/2003

Docket/Case Number: INV03-010 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): N/A Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Consent Resolution Date: 06/16/2003 Sanctions Ordered: Monetary/Fine $500.00 Other Sanctions Ordered: N/A Sanction Details: RESPONDENT FINED $500. Regulator Statement WACHOVIA SECURITIES INC, CRD#431 FILED ITS YEAR END AUDITED FINANCIALS LATE. WACHOVIA MERGED INTO FIRST UNION SECURITIES INC ON 6/15/2002 AND THEN CHANGED ITS NAME TO WACHOVIA SECURITIES INC. CRD#19616. THIS ACTION WAS COMMENCED AGAINST THE NEW WACHOVIA ALTHOUGH THE VIOLATION WAS COMMITTED BY THE LEGACY WACHOVIA. i Reporting Source: Firm Current Status: Final Allegations: FAILURE OF PREDECESSOR FIRM WACHOVIA SECURITIES, INC. (BD 431) TO FILE ANNUAL AUDITED STATEMENTS WITHIN TIMELY MANNER AND TO PAY PENALTY OF $500 FOR LATE FILING. Initiated By: STATE OF NEW HAMPSHIRE Date Initiated: 03/19/2003 Docket/Case Number: INV03-010

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: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 290 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 06/09/2003 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: ADMINISTRATIVE FINE OF $500.00 AND PENALTY FEE OF $500.00 PAID TO STATE 04/07/2003. Firm Statement THE RESPONDENT WACHOVIA SECURITIES, INC. (BD 19616)VOLUNTARILY CONSENTED TO THE ENTRY OF THE ORDER AND TO PAY THE PENALTY INCURRED BY THE FORMER WACHOVIA SECURITIES, INC. (BD431), WHICH MERGED WITH FIRST UNION SECURITIES, INC. ON 6/15/2002 TO BECOME WACHOVIA SECURITIES, INC. (BD19616). i Disclosure 148 of 167 Reporting Source: Regulator Current Status: Final Allegations: SEC RULE 11AC1-4 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TO DISPLAY IMMEDIATELY THE CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER IN SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH ITS BID OR OFFER IN EACH SUCH SECURITY. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/30/2002 Docket/Case Number: CMS020202

Principal Product Type: Other Other Product Type(s): UNKNOWN TYPE OF SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 291 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/30/2002 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $10,000. i Reporting Source: Firm Current Status: Final Allegations: SEC RULE 11AC1-4 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TO DISPLAY IMMEDIATELY THE CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER IN SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH ITS BID OR OFFER IN EACH SUCH SECURITY. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/30/2002 Docket/Case Number: CMS020202

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: 10/30/2002 Sanctions Ordered: Censure Monetary/Fine $10,000.00

Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $10,000. i Disclosure 149 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULE 2110 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT TO FIXED INCOME PRICING SYSTEM ("FIPS") TRANSACTIONS IN FIPS SECURITIES WITHIN FIVE MINUTES AFTER EXECUTION. SUCH CONDUCT CONSTITUTES A PATTERN OR PRACTICE OF THE LATE REPORTING AND IS CONSIDERED CONDUCT INCONSISTENT WITH HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPALS OF TRADE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/24/2002 Docket/Case Number: CMS020193

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: 10/24/2002 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: A FINE OF $5,000. i Reporting Source: Firm Current Status: Final Allegations: NASD RULE 2110 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIA SECURITIES, INC. CONSENTED TO THE ENTRY OF FINDINGS ©2021 FINRA. All rights reserved. Report aboutTHAT WELLS IT FAILED FARGO TOCLEARING REPORT SERVICES, TO THE LLC FIXED INCOME PRICING SYSTEM 293 ("FIPS")46 TRANSACTIONS IN FIPS SECURITIES WITHIN FIVE MINUTES AFTER EXECUTION DURING THE PERIOD FROM JANUARY 1, 2001 THROUGH JUNE 28,2001, WHICH CONSTITUTES A PATTERN OR PRACTICE OF REPORTING IN VIOLATION OF RULE 2110. THE FIRM PAID A FINE OF $5,000. www.finra.org/brokercheck User Guidance

NASD RULE 2110 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIA SECURITIES, INC. CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT TO THE FIXED INCOME PRICING SYSTEM ("FIPS")46 TRANSACTIONS IN FIPS SECURITIES WITHIN FIVE MINUTES AFTER EXECUTION DURING THE PERIOD FROM JANUARY 1, 2001 THROUGH JUNE 28,2001, WHICH CONSTITUTES A PATTERN OR PRACTICE OF REPORTING IN VIOLATION OF RULE 2110. THE FIRM PAID A FINE OF $5,000. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/24/2002 Docket/Case Number: CMS020193

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: 10/24/2002 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: A FINE OF $5000.00 i Disclosure 150 of 167 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 8210 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TO TIMELY COMPLETE AND RETURN TO THE NASD A BRANCH OFFICE INFORMATION QUESTIONNAIRE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/07/2002 Docket/Case Number: C07020006

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: 02/07/2002 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: CENSURED AND FINED $5,000 i Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGES THAT ON OR ABOUT APRIL 3, 2000 NASD REGULATION STAFF REQUESTED PURSUANT TO NASD PROCEDURAL RULE 8210 THAT FIRST UNION COMPLETE AND RETURN A BRANCH OFFICE INFORMATION QUESTIONNAIRE BY APRIL 18, 2000. FIRST UNION REQUESTED AND RECIEVED AN EXTENSION OF THE RESPONSE DEADLINE UNTIL MAY 12, 2000. AFTER FURTHER COMMUNICATION WITH FIRST UNION, NASD REGULATION STAFF DID NOT RECEIVE THE REQUESTED INFORMATION UNTIL MARCH 2001. THE NASD ALLEGES THAT SUCH CONDUCT VIOLATES NASD PROCEDURAL RULE 8210 AND NASD CONDUCT RULE 2110. Initiated By: NASD REGULATION, INC. Date Initiated: 04/03/2000 Docket/Case Number: C07020006-AWC

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $5,000 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/07/2002 Sanctions Ordered: Monetary/Fine $5,000.00 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 295 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: N/A Sanction Details: N/A Firm Statement WITHOUT ADMITTING OR DENYING GUILT, FIRST UNION SECURITIES COSENTED TO THE NASD'S FINDINGS THAT ON OR ABOUT APRIL 3, 2000 NASD REGULATION STAFF REQUESTED PURSUANT TO NASD PROCEDURAL RULE 8210 THAT FIRST UNION COMPLETE AND RETURN A BRANCH OFFICE INFORMATION QUESTIONNAIRE BY APRIL 18, 2000. THAT FIRST UNION REQUESTED AND RECIEVED AN EXTENSION OF THE RESPONSE DEADLINE UNTIL MAY 12, 2000. THAT AFTER FURTHER COMMUNICATION WITH FIRST UNION, NASD REGULATION STAFF DID NOT RECEIVE THE REQUESTED INFORMATION UNTIL MARCH 2001. THAT THE NASD ALLEGES THAT SUCH CONDUCT VIOLATES NASD PROCEDURAL RULE 8210 AND NASD CONDUCT RULE 2110. i Disclosure 151 of 167 Reporting Source: Regulator Current Status: Final Allegations: **11/05/2001** STIPULATION AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT, FIRST UNION SECURITIES, INC. CONSENTED TO A FINDING BY THE HEARING PANEL THAT THE FIRM: EXCHANGE RULE 440 AND SEC REGULATIONS ?240.17A-3 AND 17A-4 BY FAILING TO MAKE AND PRESERVE REQUIRED RECORDS RELATING TO ACCOUNT DESIGNATION AND EXECUTION OF CUSTOMER ORDERS. EXCHANGE RULE 410 BY FAILING TO MAKE AND PRESERVE REQUIRED RECORDS REGARDING THE TIMELY ALLOCATION OF ORDERS TO CUSTOMER ACCOUNTS. EXCHANGE RULE 351 BY FAILING TO PROMPTLY REPORT CERTAIN CUSTOMER COMPLAINTS AND/OR SETTLEMENTS TO THE EXCHANGE AS REQUIRED. EXCHANGE RULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE AND CONTROL AND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND ESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEW WITH RESPECT TO: ASSURING COMPLIANCE WITH EXCHANGE RULES AND FEDERAL SECURITIES LAWS REQUIRING THE MAKING AND PRESERVATION OF TIMELY RECORDS RELATING TO THE ACCOUNT DESIGNATION AND EXECUTION OF CUSTOMER ORDERS; ASSURING THAT TRADE CORRECTIONS EFFECTED BY BRANCH OFFICE MANAGERS ARE PROPERLY REVIEWED; AND ASSURING COMPLIANCE WITH EXCHANGE RULES TO PROMPTLY AND ACCURATELY REPORT CUSTOMER COMPLAINTS AND/OR SETTLEMENTS TO THE EXCHANGE. STIPULATED SANCTION: THE IMPOSITION BY THE EXCHANGE OF THE ©2021 FINRA. All rights reserved. Report aboutPENALTY WELLS OF:FARGO A CENSURE;CLEARING SERVICES, AND, A LLCFINE OF $145,000. 296 **11/05/2001** STIPULATION AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT, FIRST UNION SECURITIES, INC. CONSENTED TO A FINDING BY THE HEARING PANEL THAT THE FIRM: EXCHANGE RULE 440 AND SEC REGULATIONS ?240.17A-3 AND 17A-4 BY FAILING TO MAKE AND PRESERVE REQUIRED RECORDS RELATING TO ACCOUNT DESIGNATION AND EXECUTION OF CUSTOMER ORDERS. EXCHANGE RULE 410 BY FAILING TO MAKE AND PRESERVE REQUIRED RECORDS REGARDING THE TIMELY ALLOCATION OF ORDERS TO CUSTOMER ACCOUNTS. EXCHANGE RULE 351 BY FAILING TO PROMPTLY REPORT CERTAIN CUSTOMER COMPLAINTS AND/OR SETTLEMENTS TO THE EXCHANGE AS REQUIRED. EXCHANGE RULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE AND CONTROL AND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND ESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEW WITH RESPECT TO: ASSURING COMPLIANCE WITH EXCHANGE RULES AND FEDERAL SECURITIES LAWS REQUIRING THE MAKING AND PRESERVATION OF TIMELY RECORDS RELATING TO THE ACCOUNT DESIGNATION AND EXECUTION OF CUSTOMER ORDERS; www.finra.org/brokercheck ASSURING THAT TRADE CORRECTIONS EFFECTED BY BRANCH OFFICE User Guidance MANAGERS ARE PROPERLY REVIEWED; AND ASSURING COMPLIANCE WITH EXCHANGE RULES TO PROMPTLY AND ACCURATELY REPORT CUSTOMER COMPLAINTS AND/OR SETTLEMENTS TO THE EXCHANGE. STIPULATED SANCTION: THE IMPOSITION BY THE EXCHANGE OF THE PENALTY OF: A CENSURE; AND, A FINE OF $145,000. Initiated By: NYSE DIVISION OF ENFORCEMENT Date Initiated: 11/05/2001 Docket/Case Number: HPD#01-232

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

Resolution: Decision Resolution Date: 01/28/2002 Sanctions Ordered: Censure Monetary/Fine $145,000.00 Other Sanctions Ordered: Sanction Details: **12/26/2001** DECISION 01-232 ISSUED BY NYSE HEARING PANEL DECISION: VIOLATED RULE 440 AND SEC REGULATIONS 240.17A-3 AND A-4 BY FAILING TO MAKE AND PRESERVE REQUIRED RECORDS, VIOLATED RULE 410 BY FAILING TO MAKE AND PRESERVE REQUIRED RECORDS; VIOLATED RULE 351 BY FAILING TO PROMPTLY REPORT CERTAIN CUSTOMER COMPLAINTS; AND VIOLATED RULE 342 BY FAILING TO REASONABLY SUPERVISE AND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL -- CONSENT TO CENSURE AND $145,000 FINE. Regulator Statement **01/28/2002** THE DECISION IS FINAL AND IS EFFECTIVE IMMEDIATELY. CONTACT: PEGGY GERMINO (212) 656-8450. i Reporting Source: Firm Current Status: Final Allegations: 1. ALLEGATIONS OF FAILURE TO SUPERVISE TO ENSURE THAT CUSTOMER ORDERS WERE PROPERLY ALLOCATED TO CUSTOMER ACCOUNTS PRIOR TO OR SIMULTANEOUSLY WITH ORDER EXECUTION BY EVEREN SECURITIES (NOW KNOWN AS FIRST UNION SECURITIES) DURING 1997. 2. DURING 1999 & 2000, EVEREN SECURITIES ALLEGEDLY FAILED TO REPORT ALL CUSTOMER COMPLAINTS, CUSTOMER SETTLEMENTS AND VIOLATIVE ©2021 FINRA. All rights reserved. Report aboutCONDUCT WELLS FARGO IN A TIMELY CLEARING MANNER. SERVICES, LLC 297 1. ALLEGATIONS OF FAILURE TO SUPERVISE TO ENSURE THAT CUSTOMER ORDERS WERE PROPERLY ALLOCATED TO CUSTOMER ACCOUNTS PRIOR www.finra.org/brokercheck TO OR SIMULTANEOUSLY WITH ORDER EXECUTION BY EVEREN User Guidance SECURITIES (NOW KNOWN AS FIRST UNION SECURITIES) DURING 1997. 2. DURING 1999 & 2000, EVEREN SECURITIES ALLEGEDLY FAILED TO REPORT ALL CUSTOMER COMPLAINTS, CUSTOMER SETTLEMENTS AND VIOLATIVE CONDUCT IN A TIMELY MANNER. Initiated By: NEW YORK STOCK EXCHANGE, INC. Date Initiated: 04/01/2000 Docket/Case Number: 01-232

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $145,000 Sought:

Resolution: Consent Resolution Date: 01/28/2002 Sanctions Ordered: Monetary/Fine $145,000.00 Other Sanctions Ordered: N/A Sanction Details: N/A Firm Statement WITHOUT ADMITTING OR DENYING ANY GUILT, EVEREN SECURITIES (NOW KNOWN AS FIRST UNION SECURITIES) CONSENTED TO THE NYSE'S FINDINGS THAT 1. VIOLATED EXCHANGE RULE 440 AND SEC REGULATIONS 240.71A-3 AND 17A-4 BY FAILING IT TO MAKE AND PERSERVE REQUIRED RECORDS RELATING TO ACCOUNT DESIGNATION AND EXECUTION OF CUSTOMER ORDERS, 2. EXCHANGE RULE 410 BY FAILING TO MAKE AND PERSERVE REQUIRED RECORDS REGARDING THE TIMELY ALLOCATION OF ORDERS TO CUSTOMER ACCOUNTS, 3. EXCHANGE RULE 351 BY FAILING TO PROMPTLY REPORT CERTAIN CUSTOMER COMPLAINTS AND/OR SETTLEMENTS TO THE EXCHANGE AS REQUIRED, 4. EXCHANGE RULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE AND CONTROL AND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND ESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEW WITH RESPECT TO (A)ASSURING COMPLIANCE WITH EXCHANGE RULES AND FEDERAL SECURITIES LAWS REQUIRING THE MAKING AND PRESERVATION OF TIMELY RECORDS RELATING TO THE ACCOUNT DESIGNATION AND EXECUTION OF CUSTOMER ORDERS, (B) ASSURING THAT TRADE CORRECTIONS EFFECTED BY BRANCH OFFICE MANAGERS ARE PROPERLY REVIEWED, AND (C) ASSURING COMPLIANCE WITH EXCHANGE RULES TO PROMPTLY AND ACCURATLEY REPORT CUSTOMER COMPLAINTS AND/OR SETTLEMENTS TO THE EXCHANGE. i Disclosure 152 of 167 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 298 www.finra.org/brokercheck User Guidance

Disclosure 152 of 167 Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT FUSI'S PREDECESSORS, BUTCHER & SINGER AND WHEAT FIRST SECURITIES, INC. VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT AND NASD RULE 2001 CONCERNING SALES OF PORTFOLIOS OF US TREASURY SECURITIES FOR DEFEASANCE ESCROW AT EXCESSIVE, UNDISCLOSED MARKUPS TO MUNICIPALITIES IN CONNECTION WITH ADVANCE REFUNDINGS. FURTHER, THE NASD ALLEGED THAT THE FIRM KNEW OR SHOULD HAVE KNOWN THAT THE MARKUPS WERE NOT REASONABLY RELATED TO THE PREVAILING WHOLESALE MARKET PRICES AND THEREBY JEOPARDIZED THE TAX- EXEMPT STATUS OF THE BONDS AND DIVERTED THE FUNDS FROM THE US TREASURY. Initiated By: NASD REGULATION, INC. Date Initiated: 04/05/2000 Docket/Case Number: C05000014

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/05/2000 Sanctions Ordered: Censure Other Sanctions Ordered: UNDERTAKING Sanction Details: FUSI, WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS, CONSENTED TO THE FINDINGS OF THE NASD AND UNDERTAKES TO MAKE PAYMENTS TOTALING $1,460,110.32 RELATED TO THE SALE OF SECURITIES TO CERTAIN MUNICIPAL ISSUERS IN CONNECTION WITH ADVANCE REFUNDINGS, PAY $6,752,152.49 TO THE US TREASURY AND $478,500 TO THE NASDR UNDER AN AGREEMENT SIMULTANEOUSLY ENTERED INTO AMONG FUSI, THE INTERNAL REVENUE SERVICE AND THE US ATTORNEY FOR THE SOUTHERN DISTRICT OF NEW YORK. i Disclosure 153 of 167 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 299 www.finra.org/brokercheck User Guidance

Disclosure 153 of 167 Reporting Source: Regulator Current Status: Final Allegations: THE SEC ALLEGED THAT FIRST UNION SECURITIES, INC. ("FIRST UNION SECURITIES" OR "DEFENDANT"), A REGISTERED BROKER-DEALER, VIOLATED THE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH THE PURCHASE AND SALE OF UNITED STATES TREASURY NOTES AND BONDS ISSUED THROUGH THE NONCOMPETITIVE AUCTION PROCESS ("NONCOMPETITIVE SECURITIES") FROM 1995 THROUGH 1998. FIRST UNION SECURITIES' BOOKS AND RECORDS FAILED TO REFLECT CERTAIN TERMS OF CUSTOMER ORDERS, WHICH WERE PRE-AUCTION AGREEMENTS BETWEEN FIRST UNION SECURITIES AND ITS NONCOMPETITIVE BIDDING CUSTOMERS, TO SELL THE SECURITIES THOSE CUSTOMERS WOULD BE AWARDED THROUGH THE AUCTION. THOSE PRE-AUCTION AGREEMENTS VIOLATED A TREASURY DEPARTMENT PROHIBITION OF SUCH AGREEMENTS. FIRST UNION SECURITIES RECEIVED APPROXIMATELY $225,000 IN MARKDOWNS FROM ITS CUSTOMERS ON THE NONCOMPETITIVE SECURITIES TRANSACTIONS. FIRST UNION SECURITIES' FAILURE TO RECORD ON ITS BOOKS AND RECORDS THESE PRE-AUCTION AGREEMENTS WITH ITS CUSTOMERS CONSTITUTED A VIOLATION OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 PROMULGATED THEREUNDER. THE ORDER TICKETS RELATING TO THE CUSTOMERS' PURCHASE OF THE TREASURY SECURITIES SHOULD HAVE RECORDED THE PRE-AUCTION AGREEMENTS BETWEEN FIRST UNION SECURITIES AND ITS CUSTOMERS TO SELL THE CUSTOMERS' NONCOMPETITIVE TREASURY SECURITIES AS SOON AS POSSIBLE AFTER THE AUCTIONS. THE PRE-AUCTION AGREEMENTS CONSTITUTED A TERM OR CONDITION OF THE CUSTOMERS' ORDERS TO PURCHASE THE TREASURY SECURITIES AT AUCTION, SINCE THOSE ORDERS WOULD NOT HAVE BEEN PLACED WITHOUT THE ACCOMPANYING AGREEMENTS TO SELL BEING IN PLACE.

Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 10/24/2000 Docket/Case Number: REL. 34-43478; FILE #3-10352

Principal Product Type: Other Other Product Type(s): U.S. TREASURY NOTES AND BONDS Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief DISGORGEMENT, PLUS INTEREST; AND A CIVIL MONEY PENALTY. Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 300 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief DISGORGEMENT, PLUS INTEREST; AND A CIVIL MONEY PENALTY. Sought:

Resolution: Order Resolution Date: 10/24/2000 Sanctions Ordered: Monetary/Fine $100,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: IT IS HEREBY ORDERED: (1) THAT FIRST UNION SECURITIES CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATION, AND FROM COMMITTING OR CAUSING ANY FUTURE VIOLATION, OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER; AND (2) THAT FIRST UNION SECURITIES, WITHIN 30 DAYS OF THE DATE OF THIS ORDER, SHALL PAY THE AMOUNT OF $308,931.00 REPRESENTING DISGORGEMENT AND INTEREST THEREON TO THE UNITED STATES TREASURY; AND (3) THAT FIRST UNION SECURITIES, WITHIN 30 DAYS OF THE DATE OF THIS ORDER, SHALL PAY THE AMOUNT OF $100,000, REPRESENTING A CIVIL MONEY PENALTY, TO THE UNITED STATES TREASURY. Regulator Statement +11/10/2000+ SEC NEWS DIGEST, ISSUE NO. 2000-204, DATED 10/24/2000, ENFORCEMENT PROCEEDINGS, AND ADMINISTRATIVE PROCEEDING RELEASE NO. 34-43478, DATED 10/24/2000, DISCLOSES: THE SEC INSTITUTED PUBLIC ADMINISTRATIVE PROCEEDINGS PURSUANT TO SECTIONS 15(B)(4) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST DEFENDANT FIRST UNION SECURITIES. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, DEFENDANT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS DEFENDANT CONSENTED TO THE ISSUANCE OF THIS CEASE AND DESIST ORDER. THE SEC ALLEGED THAT DEFENDANT VIOLATED THE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH THE PURCHASE AND SALE OF UNITED STATES TREASURY NOTES AND BONDS ISSUED THROUGH THE NONCOMPETITIVE AUCTION PROCESS FROM 1995 THROUGH 1998. THE SEC FOUND THAT DEFENDANT WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER. IT IS HEREBY ORDERED THAT DEFENDANT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATION, AND FROM COMMITTING OR CAUSING ANY FUTURE VIOLATION OF THE SECURITIES LAWS. THE SEC ALSO ORDERED THAT DEFENDANT SHALL PAY THE DISGORGEMENT, PLUS INTEREST AND A CIVIL MONEY PENALTY. (REL. 34-43478; FILE #3-10352) i ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 301 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: FIRST UNION SECURITIES, WITHOUT ADMITTING OR DENYING THE COMMISSION'S FINDINGS, CONSENTED TO A COMMISSION ORDER FINDING THAT THE FIRM VIOLATED THE BROKER-DEALER RECORDKEEPING PROVISIONS OF SECTION 17A AND RULE 17A-3 THEREUNDER. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 10/24/2000 Docket/Case Number: REL. 34-43478, FILE NO. 3-10352

Principal Product Type: Other Other Product Type(s): TREASURY SECURITIES Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief FIRST UNION SECURITIES, WITHOUT ADMITTING OR DENYING ANY Sought: WRONGDOING, WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING FUTURE VIOLATIONS OF THE BROKER-DEALER RECORDKEEPING PROVISIONS OF THE FEDERAL SECUIRITIES LAWS. FIRST UNION WAS ORDERED TO A CIVIL PENALTY, DISGORGEMENT AND PREJUDGEMENT INTEREST.

Resolution: Consent Resolution Date: 10/24/2000 Sanctions Ordered: Monetary/Fine $100,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: ORDERED TO PAY CIVIL PENALTIES OF $100,000, DISGORGEMENT AND PREJUDGEMENT INTEREST OF $308,931. Firm Statement FIRST UNION SECURITIES, WITHOUT ADMITTING OR DENYING ANY WRONGDOING, WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING FUTURE VIOLATIONS OF THE BROKER-DEALER RECORDKEEPING PROVISIONS OF THE FEDERAL SECUIRITIES LAWS. THE COMMISSION ORDER FINDS THAT FUSI FAILED TO PROPERLY RECORD CERTAIN TERMS OF CUSTOMER ORDERS MADE IN CONNECTION WITH THE PURCHASE AND SALE OF U.S. TREASURY SECURITIES ISSUED THROUGH THE NONCOMPETATIVE AUCTION PROCESS FROM 1995 THROUGH 1998.

i Disclosure 154 of 167 Reporting Source: Regulator Current Status: Final Allegations: 11-02-00, SECTIONS 17(A)(2), 17(A)(3) OF THE SECURITIES ACT, NASD RULE 2110 - RESPONDENT MEMBER SOLD PORTFOLIOS OF U.S. TREASURY SECURITIES FOR DEFEASANCE ESCROW AT EXCESSIVE, UNDISCLOSED MARKUPS TO MUNICIPALITIES IN CONNECTION WITH ADVANCE REFUNDINGS. THE FIRM SOLD A PORTFOLIO OF $20,608,015.60 IN U.S. TREASURY SECURITIES TO A MUNICIPALITY. THE FIRM'S MARKUP AND CARRY ON THAT PORTFOLIO WAS .55 PERCENT OF THE PREVAILING INTERDEALER MARKET PRICES OF THE TREASURY SECURITIES SOLD TO THE MUNICIPALITY. AT THE TIME, DEALERS GENERALLY CHARGED MATERIALLY LOWER MARKUPS ON ESCROW SECURITIES WHEN THE PRICES WERE DETERMINED THROUGH COMPETITION OR BONA FIDE ARM'S LENGTH NEGOTIATION. THE FIRM EFFECTED DEFEASANCE ESCROW TRANSACTIONS WITH MUNICIPALITIES AT PRICES NOT REASONABLY RELATED TO THE CURRENT WHOLESALE MARKET PRICES FOR THE SECURITIES UNDER THE PARTICULAR FACTS AND CIRCUMSTANCES, INCLUDING THE PERTINENT TX REGULATIONS;THE FIRM KNEW OR SHOULD HAVE KNOWN THAT THE PRICES IT CHARGED WERE NOT REASONABLY RELATED TO THE PREVAILING WHOLESALE MARKET PRICES. THE EXCESSIVE MARKUPS ALSO JEOPARDIZED THE TAX- EXEMPT STATUS OF THOSE MUNICIPALITIES' REFUNDING BONDS AND DIVERTED MONEY FROM THE U.S. TREASURY TO THE FIRM WHEN THE TRANSACTION WAS IN POSITIVE ARBITRAGE OR REDUCED THE SAVINGS AVAILABLE TO THE MUNICIPALITIES FROM THE REFUNDINGS WHEN THE TRANSACTION WAS IN NEGATIVE ARBITRAGE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/30/2000 Docket/Case Number: C05000058

Principal Product Type: Other Other Product Type(s): U.S. TREASURY SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution Date: 10/30/2000 Sanctions Ordered: Censure Other Sanctions Ordered: UNDERTAKING Sanction Details: CENSURED,UNDERTAKE TO MAKE PAYMENTS TOTALING $309,775.92 RELATED TO THE SALE OF DEFEASANCE ESCROW SECURITIES TO CERTAIN MUNICIPAL ISSUERS IN CONNECTION WITH ADVANCE REFUNDINGS IN NEGATIVE ARBITRAGE SITUATIONS, PAY $11,802,522.08 TO THE U.S. TREASURY AND $625,000 TO THE NASDR UNDER AN AGREEMENT SIMULTANEOUSLY ENTERED WITH FIRST UNION SECURITIES, INC., THE INTERNAL REVENUE SERVICE AND THE U.S. ATTORNEY FOR THE SOUTHERN DISTRICT OF NEW YORK. AT THE TIME PAYMENTS ARE MADE TO THE MUNICIPALITIES AND THE U.S. TREASURY, COPIES OF THE PAYMENTS AND ANY ACCOMPANYING COVER LETTERS SHALL BE SENT TO THE DISTRICT NO. 5 DIRECTOR. i Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT AND NASD RULE 2110 CONCERNING SALES OF PORTFOLIOS OF US TREASURY SECURITIES FOR DEFEASANCE ESCROW AT EXCESSIVE, UNDISCLOSED MARKUPS TO MUNICIPALITIES IN CONNECTION WITH ADVANCE REFUNDINGS. FURTHER, THE NASD ALLEGED THAT THE FIRM KNEW, OR SHOULD HAVE KNOWN, THAT THE MARKUPS WERE NOT REASONABLY RELATED TO THE PREVAILING WHOLESALE MARKET PRICES AND THEREBY JEOPARDIZED THE TAX- EXEMPT STATUS OF THE BONDS AND DIVERTED FUNDS FROM THE US TREASURY. Initiated By: NASD Date Initiated: 10/30/2000 Docket/Case Number: C05000058

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/30/2000 Sanctions Ordered: Censure Other Sanctions Ordered: UNDERTAKING Sanction Details: FIRST UNION SECURITIES, WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS, CONSENTED TO THE FINDINGS OF THE NASD AND UNDERTAKES TO MAKE PAYMENTS TOTALING $309,775.92 RELATED TO THE SALE OF SECURITIES TO CERTAIN MUNICIPAL ISSUERS IN CONNECTION WITH ADVANCE REFUNDINGS, PAY $11,802,522.08 TO THE US TREASURY AND $625,000 TO THE NASD UNDER AN AGREEMENT SIMULTANEOUSLY ENTERED INTO AMONG FIRST UNION SECURIRITIES, THE INTERNAL REVENUE SERVICE AND THE US ATTORNEY FOR THE SOUTHERN DISTRICT OF NEW YORK. i Disclosure 155 of 167 Reporting Source: Regulator Current Status: Final Allegations: 07/20/00GS: NASD RULES 2110 AND 3010 - RESPONDENT EFFECTED OR CAUSED TO BE EFFECTED FOR THE ACCOUNT OF PUBLIC CUSTOMERS THE PURCHASE OF SECURITIES IN INITIAL PUBLIC OFFERINGS AT THE INITIAL PUBLIC OFFERING PRICES WHEN TRADING IN THE SECURITIES TRADED AT A PREMIUM OVER THE PUBLIC OFFERING PRICES, IN VIOLATION OF THE NASD'S FREE-RIDING AND WITHHOLDING INTERPRETATION; AND, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE NASD'S FREE-RIDING AND WITHHOLDING INTERPRETATION. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 07/10/2000 Docket/Case Number: C8A000039

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/10/2000 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: 11-07-00, $7,500 PAID 8/09/00, INVOICE 00-8A-455 i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATION OF NASD CONDUCT RULE 2110 AND 3010(B). Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/10/2000 Docket/Case Number: C8A000039

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/10/2000 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM CONSENTED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS AND CONSENTED TO CENSURE AND A FINE OF $7500. i Disclosure 156 of 167 Reporting Source: Regulator Current Status: Final Allegations: 06-16-00, SEC RULES 17A-3,17A-4, MSRB RULES G-8, G-9, AND G-27 - ©2021 FINRA. All rights reserved. Report aboutRESPONDENT WELLS FARGO MEMBER CLEARING FAILED SERVICES, TO LLC RECORD FINDER'S FEES PAID TO A 306 NOW DEFUNCTED FIRM AND ITS BOOKS AND RECORDS FAILED TO REFLECT PAYMENTS ON NUMEROUS MUNICIPAL SECURITIES TRANSACTIONS AND OVERSTATED THE AMOUNT OWED; AND ITS BOOKS AND RECORDS FAILED TO RECORD PAYMENTS MADE THROUGH A THIRD PARTY www.finra.org/brokercheck User Guidance

Allegations: 06-16-00, SEC RULES 17A-3,17A-4, MSRB RULES G-8, G-9, AND G-27 - RESPONDENT MEMBER FAILED TO RECORD FINDER'S FEES PAID TO A NOW DEFUNCTED FIRM AND ITS BOOKS AND RECORDS FAILED TO REFLECT PAYMENTS ON NUMEROUS MUNICIPAL SECURITIES TRANSACTIONS AND OVERSTATED THE AMOUNT OWED; AND ITS BOOKS AND RECORDS FAILED TO RECORD PAYMENTS MADE THROUGH A THIRD PARTY Initiated By: NATIONAL ASSOCIATION OFSECURITIES DEALERS, INC. Date Initiated: 06/13/2000 Docket/Case Number: CAF000022

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/13/2000 Sanctions Ordered: Censure Monetary/Fine $350,000.00 Other Sanctions Ordered: Sanction Details: CENSURED AND FINED $350,000 i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGED THAT FIRST UNION SECURITIES, INC. (F/K/A WHEAT FIRST SECURITIES, INC.) VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULES 17A-3 AND 17A-4 THEREUNDER AND MSRB RULES G-8, G-9 AND G- 27. FIRST UNION'S BOOKS AND RECORDS FAILED TO ACCURATELY REFLECT FINDERS FEES PAID FOR MUNICIPAL SECURITIES TRANSACTIONS OVER AN EIGHTEEN MONTH PERIOD FROM LATE 1991 THROUGH APRIL, 1993. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/13/2000 Docket/Case Number: CAF000022 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 307 www.finra.org/brokercheck User Guidance

Docket/Case Number: CAF000022

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $350,000 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/13/2000 Sanctions Ordered: Censure Monetary/Fine $350,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FIRST UNION SECURITIES, INC. CONSENTED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WHICH INCLUDED A CONSENT TO CENSURE AND A FINE OF $350,000. i Disclosure 157 of 167 Reporting Source: Firm Current Status: Final Allegations: VIOLATIONS OF CFR PART 404 PROMULGATED PURSUANT TO SECTION 15C WITH THE PRIMARY DISTRIBUTION OF CERTAIN UNSECURED DEBT SECURITIES ISSUED BY GOVERNMENTAL SPONSORED ENTERPRISES. Initiated By: U S SECURITIES & EXCHANGE COMMISSION Date Initiated: 01/01/1992 Docket/Case Number: N/A

Principal Product Type: Other Other Product Type(s): UNSECURED DEBT SECURITIES Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled

Resolution Date: 01/01/1992 Sanctions Ordered: Monetary/Fine $100,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CEASE AND DESIST, $100,000 FINE. i Disclosure 158 of 167 Reporting Source: Firm Current Status: Final Allegations: EVEREN SECURITIES, INC. (NAME CHANGED TO FIRST UNION SECURITIES, INC.)VIOLATIONS OF SECTION 201 OF THE RHODE ISLAND UNIFORM SECURITIES ACT OF 1990, SECTION 7-11-101 ET SEQ. Initiated By: STATE OF RHODE ISLAND, DIVISION OF SECURITIES Date Initiated: 03/16/1995 Docket/Case Number: 95-015

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

Resolution: Other Resolution Date: 03/16/1995 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: FINED $2000.00 i Disclosure 159 of 167 Reporting Source: Firm Current Status: Final Allegations: EVEREN SECURITIES, INC. (NAME CHANGED TO FIRST UNION SECURITIES, INC.)ALLEGED THAT THE FIRM VIOLATED HAWAII UNIFORM SECURITIES ©2021 FINRA. All rights reserved. Report aboutACT WELLS PURSUANT FARGO CLEARINGTO SECTION SERVICES, 485-15(10) LLC IN THAT IT FAILED TO PREVENT 309 AND DETECT WHETHER OR NOT ITS REPS WERE PROPERLY REGISTERED AND/OR WERE TRANSACTING SECURITIES BUSINESS IN HAWAII WITHOUT THE APPROPRIATE REGISTRATION. www.finra.org/brokercheck User Guidance

EVEREN SECURITIES, INC. (NAME CHANGED TO FIRST UNION SECURITIES, INC.)ALLEGED THAT THE FIRM VIOLATED HAWAII UNIFORM SECURITIES ACT PURSUANT TO SECTION 485-15(10) IN THAT IT FAILED TO PREVENT AND DETECT WHETHER OR NOT ITS REPS WERE PROPERLY REGISTERED AND/OR WERE TRANSACTING SECURITIES BUSINESS IN HAWAII WITHOUT THE APPROPRIATE REGISTRATION. Initiated By: STATE OF HAWAII, DEPT OF COMMERCE AND CONSUMER AFFAIRS Date Initiated: 08/26/1998 Docket/Case Number: SEU-96-071

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

Resolution: Settled Resolution Date: 09/29/1998 Sanctions Ordered: Monetary/Fine $6,000.00 Other Sanctions Ordered: Sanction Details: UNDERTAKING TO MODIFY ITS SECURITIES COMPLIANCE PROCEDURES FOR REGISTRATION OF ITS REPS i Disclosure 160 of 167 Reporting Source: Regulator Current Status: Final Allegations: 09/24/1999JJM -- RESPONDENT MEMBER FAILED TO REPORT TRANSACTIONS IN AN FIPS ELIGIBLE SECURITY TO FIPS WITHIN FIVE MINUTES OF EXECUTION. [NASD RULE 6420(A)] Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/30/1999 Docket/Case Number: CMS990023

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Other Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 310 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief $2,500.00 FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/30/1999 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: $2,500.00 FINE Regulator Statement NONE i Reporting Source: Firm Current Status: Final Allegations: EVEREN SECURITIES, INC. (NAME CHANGED TO FIRST UNION SECURITIES, INC.)VIOLATIONS OF THE ASSOCIATIONS FIXED INCOME PRICING SYSTEM (FIPS) ALLEGING LATE REPORTING OF TRANSACTIONS IN HIGH YIELD CORPORATE DEBT SECURITIES DURING THE PERIOD NOVEMBER 1996 THROUGH FEBRUARY 1997. Initiated By: NASD REGULATION, INC Date Initiated: 03/30/1999 Docket/Case Number: CMS9090023AWC

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

Resolution: Settled Resolution Date: 03/30/1999 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: FINE OF $2500 i Disclosure 161 of 167 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 311 www.finra.org/brokercheck User Guidance

Disclosure 161 of 167 Reporting Source: Regulator Current Status: Final Allegations: **06/01/1999** STIPULATION AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT AND PENDING. CONSENTED TO FINDINGS: A. A FINDING BY THE HEARING PANEL THAT IT: 1. VIOLATED EXCHANGE RULE 440 AND SECTION 17(A) OF THE SEA OF 1934 AND SEC REGULATIONS 240.17A-3 AND 17A-4 BY FAILING TO MAKE AND PRESERVE REQUIRED RECORDS RELATING TO RECEIPT AND EXECUTION OF CUSTOMERS ORDERS. 2. VIOLATED EXCHANGE RULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF TIS EMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, TO ASSURE COMPLIANCE WITH SEC AND EXCHANGE RULES FOR MAKING AND PRESERVING TIMELY ORDER RECORDS SHOWING ALLOCATION OF TRADES TO CUSTOMER ACCOUNTS. B. THE IMPOSITION BY THE EXCHANGE OF A PENALTY OF A CENSURE AND A FINE OF 120,000. Initiated By: NYSE DIVISION OF ENFORCEMENT Date Initiated: 06/01/1999 Docket/Case Number: HPD# 99-91

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

Resolution: Decision Resolution Date: 08/27/1999 Sanctions Ordered: Censure Monetary/Fine Other Sanctions Ordered: Sanction Details: **07/14/1999** DECISION #99-91 ISSUED BY NYSE HEARING PANEL. DECISION: 1. VIOLATED EXCHANGE RULE 440 AND SECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND SEC REGULATIONS 240.17A-3 AND 17A-4 BY FAILING TO MAKE AND PRESERVE REQUIRED RECORDS RELATING TO RECEIPT AND EXECUTION OF CUSTOMER ORDERS. 2 VIOLATED EXCHANGE RULE 342 IN THAT IF FAILED TO REASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF ITS ©2021 FINRA. All rights reserved. Report aboutEMPLOYEES, WELLS FARGO INCLUDING CLEARING SERVICES,A SEPARATE LLC SYSTEM OF FOLLOW-UP AND 312 REVIEW, TO ASSURE COMPLIANCE WITH SEC AND EXCHANGE RULES FOR MAKING AND PRESERVING TIMELY ORDER RECORDS SHOWING ALLOCATION OF TRADES TO CUSTOMER ACCOUNTS. CONSENT TO CENSURE AND $120,000. **07/14/1999** DECISION #99-91 ISSUED BY NYSE HEARING PANEL. DECISION: 1. VIOLATED EXCHANGE RULE 440 AND SECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND www.finra.org/brokercheck SEC REGULATIONS 240.17A-3 AND 17A-4 BY FAILING TO MAKE AND User Guidance PRESERVE REQUIRED RECORDS RELATING TO RECEIPT AND EXECUTION OF CUSTOMER ORDERS. 2 VIOLATED EXCHANGE RULE 342 IN THAT IF FAILED TO REASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF ITS EMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, TO ASSURE COMPLIANCE WITH SEC AND EXCHANGE RULES FOR MAKING AND PRESERVING TIMELY ORDER RECORDS SHOWING ALLOCATION OF TRADES TO CUSTOMER ACCOUNTS. CONSENT TO CENSURE AND $120,000. Regulator Statement **08/27/1999** THE DECISION IS NOW FINAL AND IS EFFECTIVE IMMEDIATELY. CONTACT: PEGGY GERMINO (212) 656-8450 i Reporting Source: Firm Current Status: Final Allegations: EVEREN SECURITIES, INC. (CHANGED ITS NAME TO FIRST UNION SECURITIES, INC.) 1. VIOLATED EXCHANGE RULE 440 AND SEC REGS 240.17A-3 AND A-4; 2. VIOLATED RULE 342. Initiated By: NEW YORK STOCK EXCHANGE, INC Date Initiated: 06/01/1999 Docket/Case Number: HPD#99-91

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

Resolution: Stipulation and Consent Resolution Date: 07/14/1999 Sanctions Ordered: Censure Monetary/Fine $120,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF $120,000.00 i Disclosure 162 of 167 Reporting Source: Regulator

Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/25/1999 Docket/Case Number: CMS990024

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/25/1999 Sanctions Ordered: Censure Monetary/Fine $13,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS990024 AWC.

ON FEBRUARY 25, 1999, EVEREN SECURITIES, INC. (EVRN) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED WAS ACCEPTED BY NASD REGULATION, INC.'S DISCIPLINARY AFFAIRS AND THE NATIONAL ADJUDICATORY COUNCIL. THE AWC ALLEGES THAT THE FOLLOWING ACTIVITY OCCURRED:

EVRN FAILED TO PRESERVE FOR A PERIOD OF NOT LESS THAN THREE YEARS MEMORANDA OF 25 BROKERAGE ORDERS THAT SHOWED THE TIME RECEIPT OF THE ORDER. THIS CONDUCT CONSTITUTES A VIOLATION OF ©2021 FINRA. All rights reserved. Report aboutSEC WELLS RULE FARGO 17a-4 CLEARINGAND NASD SERVICES, CONDUCT LLC RULE 3110. 314

EVRN FAILED TO CONTEMPORANEOUSLY EXECUTE NINE CUSTOMER LIMIT ORDERS AFTER IT TRADED EACH SUCH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT A PRICE THAT WOULD SATISFY EACH SUCH CUSTOMER LIMIT ORDER. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD CONDUCT RULES 2110 AND IM-2110-2.

EVRN FAILED TO DISPLAY IMMEDIATELY 25 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 MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SECURITY. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF SEC RULE 11Ac1-4.

EVRN FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET FOR TEN SECURITIES TRANSACTIONS AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO THE CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD CONDUCT RULES 2110 AND 2320. www.finra.org/brokercheck User Guidance EVRN FAILED TO PRESERVE FOR A PERIOD OF NOT LESS THAN THREE YEARS MEMORANDA OF 25 BROKERAGE ORDERS THAT SHOWED THE TIME RECEIPT OF THE ORDER. THIS CONDUCT CONSTITUTES A VIOLATION OF SEC RULE 17a-4 AND NASD CONDUCT RULE 3110.

EVRN WAS CENSURED AND FINED $13,000. EVRN ALSO AGREED TO PROVIDE RESTITUTION AND INTEREST TO EACH CUSTOMER WHOSE ORDERS WERE TREATED IN A MANNER INCONSISTENT WITH THE DUTY OF BEST EXECUTION. SUCH RE*See FAQ #1* i Reporting Source: Firm Current Status: Final Allegations: ALLEGED TO HAVE VIOLATED NASD CONDUCT RULES 2110 AND 2320 WITH RESPECT TO THE FIRM'S FAILURE TO ASCERTAIN THE BEST INTERDEALER MARKET IN EXECUTING CUSTOMER TRANSACTIONS. SEC RULE 17A-4 AND NASD CONDUCT RULE 3110 WITH RESPECT TO RECORDKEEPING REGULATIONS. NASD CONDUCT RULES 2110 AND IM-2110-2 WITH RESPECT TO EXECUTION OF CUSTOMER LIMIT ORDERS AND SEC RULE 11AC1-4 WITH RESPECT TO THE FIRM'S FAILURE TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS. Initiated By: NASD REGULATION, INC. Date Initiated: 02/25/1999 Docket/Case Number: CMS990024AWC

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

Resolution: Settled Resolution Date: 03/02/1999 Sanctions Ordered: Censure Monetary/Fine $13,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM AGREED TO A CENSURE AND A $13,000 FINE (COMPOSED OF A $1,000 FINE FOR RECORDKEEPING VIOLATIONS AND FINE OF $7,500 FOR BEST EXECUTION VIOLATIONS, A FINE OF $2,500 FOR THE LIMIT ORDER PROTECTION INTERPRETATION VIOLATIONS, AND A FINE OF $2,000 FOR THE LIMIT ORDER DISPLAY RULE VIOLATIONS.) i Disclosure 163 of 167 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/30/1998 Docket/Case Number: CMS980025 AWC

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/30/1998 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine WELLS FARGO $18,500.00 CLEARING SERVICES, LLC 316 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $18,500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS980025 AWC.

ON MARCH 30, 1998, EVEREN SECURITIES, INC. (EVRN) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED WAS ACCEPTED BY NASD REGULATION, INC.'S DEPARTMENT OF ENFORCEMENT AND THE NATIONAL ADJUDICATORY COUNCIL. THE AWC ALLEGES THAT THE FOLLOWING ACTIVITY OCCURRED:

EVRN FAILED TO DESIGNATE AS LATE TO ACT TWO TRANSACTIONS IN NASDAQ NATIONAL MARKET SECURITIES; AND FAILED TO REPORT ONE TRANSACTION IN A NASDAQ NATIONAL MARKET SECURITY THAT IT WAS REQUIRED TO REPORT. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD MARKETPLACE RULE 4632.

EVRN FAILED TO REPORT TO ACT THE CONTRA SIDE EXECUTING BROKER IN 35 TRANSACTIONS IN ELIGIBLE SECURITIES IN SEPARATE AND

DISTINCT VIOLATIONS OF NASD MARKETPLACE RULE 6130(d). EVRN FAILED TO REPORT ONE TRANSACTION IN AN OTC EQUITY SECURITY THAT IT WAS REQUIRED TO REPORT, IN VIOLATION OF NASD CONDUCT RULE 6620; AND FAILED TO REPORT ONE TRANSACTION IN A LISTED SECURITY THAT IT WAS REQUIRED TO REPORT, IN VIOLATION OF NASD CONDUCT RULE 6420.

EVRN FAILED TO CONTEMPORANEOOUSLY EXECUTE SEVEN CUSTOMER LIMIT ORDERS AFTER IT TRADED FOR ITS MARKET MAKING ACCOUNT AT A PRICE THAT WOULD SATISFY EACH CUSTOMER LIMIT ORDER. THIS CONSTITUTES VIOLATIONS OF NASD CONDUCT RULE 2110 AND IM-2110-2.

EVRN FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS, REGULATIONS AND RULES REGARDING TRADE REPORTING, RECORD KEEPING, REGISTRATION AND LIMIT ORDERS. THIS CONSTITUTES A VIOLATION OF NASD CONDUCT ©2021 FINRA. All rights reserved. Report aboutRULES WELLS 2110 FARGO AND CLEARING 3010. SERVICES, LLC 317 EVRN WAS CENSURED AND FINED $18,500.

**$18,500.00 PAID ON 5/11/98, INVOICE # 98-MS-378** LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS980025 AWC.

EVRN FAILED TO REPORT TO ACT THE CONTRA SIDE EXECUTING BROKER IN 35 TRANSACTIONS IN ELIGIBLE SECURITIES IN SEPARATE AND

EVRN FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS, REGULATIONS www.finra.org/brokercheck AND User Guidance RULES REGARDING TRADE REPORTING, RECORD KEEPING, REGISTRATION AND LIMIT ORDERS. THIS CONSTITUTES A VIOLATION OF NASD CONDUCT RULES 2110 AND 3010.

EVRN WAS CENSURED AND FINED $18,500.

**$18,500.00 PAID ON 5/11/98, INVOICE # 98-MS-378** i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF RULES SET FORTH UNDER NASD CONDUCT RULES 2110 AND 3010 AND VIOLATIONS OF NASD MARKETPLACE RULE 4632(A). Initiated By: NASD REGULATION, INC. Date Initiated: 04/07/1998 Docket/Case Number: CMS980025

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

Resolution: Settled Resolution Date: 04/23/1998 Sanctions Ordered: Censure Monetary/Fine $18,500.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF $18,500 (COMPOSED OF $5000 FINE FOR THE TRADE REPORTING VIOLATION, $3500 FOR THE LIMIT ORDER VIOLATIONS AND $10,000 FINE FOR THE SUPERVISION VIOLATION). i Disclosure 164 of 167 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 318 www.finra.org/brokercheck User Guidance

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/29/1998 Docket/Case Number: C8A980037

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/29/1998 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON MAY 29, 1998, DISTRICT NO. 8 NOTIFIED RESPONDENT EVEREN SECURITIES, INC. THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C8A980037 WAS ACCEPTED; THEREFORE, THE FIRM IS CENSURED AND FINED $3,000 - MSRB RULE G-8 AND G-36 - RESPONDENT MEMBER FAILED TO FILE COPIES OF THE FINAL OFFICIAL STATEMENT AND COPIES OF A COMPLETED FORM G-36(OS) WITH THE MSRB ON A TIMELY BASIS; FAILED TO ACCURATELY RECORD THE DATE OF FINAL AGREEMENTS TO PURCHASE, OFFER OR SELL MUNICIPAL SECURITIES AS A PRIMARY OFFERING OF SECURITIES; AND, FAILED TO MAINTAIN A RECORD OF THE DATE THAT THE COPIES OF THE FINAL OFFICIAL STATEMENT AND COMPLETED FORM G-36(0S) WERE SENT TO THE MSRB FOR FINAL AGREEMENTS TO PURCHASE, OFFER OR SELL MUNICIPAL SECURITIES AS AN UNDERWRITER IN A PRIMARY OFFERING OF MUNICIPAL SECURITIES).

**$3,000.00 PAID ON 6/22/98, INVOICE # 98-8A-517** i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF MSRB RULE G36. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 319 www.finra.org/brokercheck User Guidance

Allegations: ALLEGED VIOLATIONS OF MSRB RULE G36. Initiated By: NASD REGULATION, INC. Date Initiated: 03/30/1998 Docket/Case Number: C8A980037

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

Resolution: Settled Resolution Date: 05/29/1998 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF $3,000. Firm Statement 3/23/2000 - CORRECTED DOCKET NO. AND DATE SETTLED DUE TO DATA ENTRY ERROR. i Disclosure 165 of 167 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/23/1997 Docket/Case Number: CMS960098

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 320 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/23/1997 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement LETTER OF ACCEPTANCE, WAIVER & CONSENT NO. CMS960098 AWC. ON APRIL 23, 1997, EVEREN SECURITIES, INC. (EVRN) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED WAS ACCEPTED BY THE MARKET REGULATION AND THE NATIONAL BUSINESS CONDUCT COMMITTEES. THE AWC ALLEGES THAT EVRN VIOLATED MARKETPLACE RULES 6240(a)(4), 6240(a)(2)(A), 6240(a)(1) AND 6240(b)(1) AND CONDUCT RULE 2110 IN THAT: EVRN INACCURATELY REPORTED UNIT PRICES, EXECUTION TIMES AND ISSUE SYMBOLS FOR SIX TRANSACTIONS IN MANDATORY FIPS BONDS; FAILED TO DEMONSTRATE THAT 35 TRANSACTIONS IN FIPS BONDS WERE REPORTED IN A TIMELY MANNER; AND, FAILED TO REPORT 23 TRANSACTIONS IN FIPS BONDS. EVRN WAS FINED $2,500.

***$2,500.00 PAID ON 5/22/97, INVOICE #97-MS-398*** i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATION OF RULES SET FORTH UNDER PART IV(A)4, (A)2(A), AND PART IV(A) AND PART IV(B) OF FIPS RULES AND ARTICLE III, SECTION 1 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 12/22/1995 Docket/Case Number: CMS960098AWC

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 WELLS FARGO CLEARING SERVICES, LLC 321 www.finra.org/brokercheck User Guidance

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

Resolution: Settled Resolution Date: 05/13/1997 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: Sanction Details: FINE OF $2,500 AND AN UNDERTAKING TO SUBMIT REVISED WRITTEN SUPERVISORY PROCEDURES CONCERNING FIPS IN A FORM NOT UNACCEPTABLE TO THE STAFF. i Disclosure 166 of 167 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 12/01/1995 Docket/Case Number: CMS950180

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/10/1996 Sanctions Ordered: Monetary/Fine $1,500.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS950180 AWC

©2021 FINRA. All rights reserved. Report aboutLETTER WELLS OF FARGO ACCEPTANCE, CLEARING SERVICES, WAIVER LLC AND CONSENT (AWC) FILED ON 322 DECEMBER 1, 1995 AGAINST EVEREN SECURITIES INC. f/k/a KEMPER SECURITIES INC. (KEMP) ALLEGING VIOLATIONS OF SECTION c)2(E) OF THE RULES OF PRACTICE AND PROCEDURE FOR SOES AND ARTICLE III, SECTION 1 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE IN THAT ON 8 OCCASIONS, KEMP ENTERED ORDERS ON AN AGENCY BASIS INTO SOES FOR SECURITIES FOR WHICH KEMP WAS A REGISTERED MARKET MAKER.

ON APRIL 10, 1996 EVEREN SECURITIES WAS NOTIFIED THAT THE AWC WAS ACCEPTED BY THE MARKET SURVEILLANCE AND THE NATIONAL BUSINESS CONDUCT COMMITTEES. KEMP WAS FINED $1,500. THE AWC BECAME FINAL ON APRIL 10, 1996.

***$1,500.00 PAID ON 5/02/96, INVOICE #96-MS-311*** www.finra.org/brokercheck User Guidance

MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS950180 AWC

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED ON DECEMBER 1, 1995 AGAINST EVEREN SECURITIES INC. f/k/a KEMPER SECURITIES INC. (KEMP) ALLEGING VIOLATIONS OF SECTION c)2(E) OF THE RULES OF PRACTICE AND PROCEDURE FOR SOES AND ARTICLE III, SECTION 1 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE IN THAT ON 8 OCCASIONS, KEMP ENTERED ORDERS ON AN AGENCY BASIS INTO SOES FOR SECURITIES FOR WHICH KEMP WAS A REGISTERED MARKET MAKER.

***$1,500.00 PAID ON 5/02/96, INVOICE #96-MS-311*** i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATION OF RULES SET FORTH UNDER PART V, SECTION 2(D) OF SCHEDULE TO THE ASSOCIATION'S BY-LAWS CONCERNING QUOTATIONS ENTERED IN THE NASDAQ SYSTEM THAT EXCEEDED THE PARAMETERS FOR THE MAXIMUM ALLOWABLE SPREAD. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/05/1995 Docket/Case Number: CMS950180

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

Resolution: Settled Resolution Date: 04/25/1996 Sanctions Ordered: Censure Monetary/Fine $8,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF $8,000. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 323 www.finra.org/brokercheck User Guidance

Sanction Details: CENSURE AND FINE OF $8,000. i Disclosure 167 of 167 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/15/1995 Docket/Case Number: CMS950122 AWC

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/10/1996 Sanctions Ordered: Censure Monetary/Fine $8,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS950122 AWC

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED ON NOVEMBER 15, 1995 AGAINST EVEREN SECURITIES INC. f/k/a KEMPER SECURITIES INC. (KEMP) ALLEGING VIOLATIONS OF PART V, SECTION 2(d) OF SCHEDULE D TO THE ASSOCIATION'S BY-LAWS IN THAT KEMP ENTERED QUOTATIONS INTO THE NASDAQ SYSTEM THAT EXCEEDED THE PARAMETERS FOR THE MAXIMUM ALLOWABLE SPREAD.

ON APRIL 10, 1996 EVEREN SECURITIES INC. WAS NOTIFIED THAT THE AWC WAS ACCEPTED BY THE MARKET SURVEILLANCE AND THE NATIONAL BUSINESS CONDUCT COMMITTEES. AS SANCTIONS, KEMP WAS CENSURED AND FINED $8,000.

***$8,000.00 PAID ON 5/02/96, INVOICE #96-MS-308*** MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS950122 AWC

ON APRIL 10, 1996 EVEREN SECURITIES INC. WAS NOTIFIED THAT THE www.finra.org/brokercheck AWC WAS ACCEPTED BY THE MARKET SURVEILLANCE AND THE NATIONAL User Guidance BUSINESS CONDUCT COMMITTEES. AS SANCTIONS, KEMP WAS CENSURED AND FINED $8,000.

THE AWC BECAME FINAL ON APRIL 10, 1996.

***$8,000.00 PAID ON 5/02/96, INVOICE #96-MS-308*** i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATION OF RULES SET FORTH UNDER PART V, SECTION 2(D) OF SCHEDULE TO THE ASSOCIATION'S BY-LAWS CONCERNING QUOTATIONS ENTERED IN THE NASDAQ SYSTEM THAT EXCEEDED THE PARAMETERS FOR THE MAXIMUM ALLOWABLE SPREAD. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/15/1995 Docket/Case Number: CMS950122

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

Resolution: Settled Resolution Date: 04/25/1996 Sanctions Ordered: Censure Monetary/Fine $8,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF $8000.

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 20885, FEBRUARY 5, 2009: SECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934 - THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED A SETTLEMENT WITH WACHOVIA SECURITIES, LLC THAT WILL PROVIDE MORE THAN $7 BILLION IN LIQUIDITY TO THOUSANDS OF CUSTOMERS WHO INVESTED IN AUCTION RATE SECURITIES (ARS) BEFORE THE MARKET FOR THOSE SECURITIES COLLAPSED. THE SETTLEMENT RESOLVES THE SEC'S CHARGES THAT WACHOVIA MISLED INVESTORS REGARDING THE LIQUIDITY RISKS ASSOCIATED WITH ARS THAT IT UNDERWROTE, MARKETED AND SOLD. THE SEC'S COMPLAINT ALLEGES THAT WACHOVIA AND ANOTHER FIRM, WHOSE BROKER-DEALER OPERATIONS WERE CONSOLIDATED INTO WACHOVIA MISREPRESENTED TO CUSTOMERS THAT ARS WERE SAFE, HIGHLY LIQUID INVESTMENTS THAT WERE COMPARABLE TO CASH OR MONEY MARKET INSTRUMENTS. ACCORDING TO THE SEC'S COMPLAINT, WACHOVIA REINFORCED THE PERCEPTION OF LIQUIDITY BY ROUTINELY PURCHASING ARS FROM THE OTHER FIRM'S CUSTOMERS BETWEEN AUCTIONS, WITHOUT TELLING CUSTOMERS THAT WACHOVIA'S WILLINGNESS TO DO SO DEPENDED UPON THE CONTINUED SUCCESS OF THE AUCTIONS. THE SEC'S COMPLAINT ALLEGES THAT WACHOVIA BECAME AWARE OF MOUNTING EVIDENCE THAT PUT THE FIRM ON NOTICE THAT THE RISK OF AUCTION FAILURES HAD MATERIALLY INCREASED. WACHOVIA, NEVERTHELESS, CONTINUED TO MARKET ARS TO ITS CUSTOMERS AS HIGHLY LIQUID INVESTMENTS. WACHOVIA FOLLOWED THE LEAD OF OTHER BROKER-DEALERS AND DECIDED TO STOP SUPPORTING AUCTIONS. WITHOUT BROKER-DEALER SUPPORT, ARS AUCTIONS FAILED AND THOUSANDS OF WACHOVIA'S CUSTOMERS WERE LEFT HOLDING BILLIONS OF DOLLARS IN ILLIQUID ARS, WITHOUT ANY PRACTICAL MEANS OF REDEEMING, SELLING OR DERIVING VALUE FROM THEM. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Court Details: UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS, SECURITIES AND EXCHANGE COMMISSION V. WACHOVIA SECURITIES, LLC, CIVIL CASE NO. 09 CV 743 (N.D. ILL.) Date Court Action Filed: 02/05/2009

Principal Product Type: Other Other Product Types: AUCTION RATE SECURITIES Relief Sought: Injunction Other Relief Sought: PERMANENT INJUNCTION, FINANCIAL PENALTIES Resolution: Judgment Rendered Resolution Date: 02/17/2009 Sanctions Ordered or Relief Cease and Desist/Injunction Granted: Other Sanctions: UNDERTAKINGS: THE SETTLEMENT, WHICH IS SUBJECT TO COURT APPROVAL, PROVIDES, AMONG OTHER THINGS, THAT: WACHOVIA WILL OFFER TO BUY BACK ARS FROM ALL INVESTORS WHO PURCHASED ARS FROM WACHOVIA INTO ACCOUNTS MAINTAINED AT WACHOVIA ON OR BEFORE FEB. 13, 2008. WACHOVIA'S BUYBACK HAS TWO PHASES. IN THE FIRST PHASE, WHICH ENDED ON NOV. 28, 2008, WACHOVIA OFFERED TO PURCHASE ARS HELD BY NATURAL PERSONS, NOT-FOR-PROFIT AND RELIGIOUS ORGANIZATIONS AND FOR OTHER ACCOUNTS WITH ACCOUNT VALUES OR HOUSEHOLD VALUES UP TO $10 MILLION. AS OF NOV. 28, IT PURCHASED OVER $6.2 BILLION OF ELIGIBLE ARS FROM CUSTOMERS. SECOND, BEGINNING NO LATER THAT JUNE 10 AND ENDING NO LATER THAN JUNE 30, 2009, WACHOVIA WILL OFFER TO PURCHASE ARS HELD BY ALL OTHER INVESTORS. WACHOVIA WILL PAY CUSTOMERS WHO SOLD THEIR ARS BELOW PAR BETWEEN FEB. 13, 2008, AND NOV. 10, 2008, THE DIFFERENCE BETWEEN PAR AND THE SALE PRICE OF THE ARS, PLUS REASONABLE INTEREST. WACHOVIA WILL COMPENSATE CUSTOMERS WHO TOOK OUT LOANS FROM WACHOVIA AFTER FEB. 13, 2008, BECAUSE OF LIQUIDITY CONCERNS BY REIMBURSING CUSTOMERS FOR NO LESS THAN THE NEGATIVE CARRY ASSOCIATED WITH ANY SUCH LOANS. WACHOVIA WILL OFFER TO LEND ITS CUSTOMERS THE FULL PAR VALUE OF THEIR ARS, PENDING THE CONTEMPLATED BUYBACK, WITH INTEREST RATES SET SO THAT CUSTOMERS WILL HAVE NO NEGATIVE CARRY ON THEIR LOANS. FURTHER, IF ELIGIBLE CUSTOMERS INCURRED CONSEQUENTIAL DAMAGES BECAUSE OF THE ILLIQUIDITY OF THEIR ARS, THEY MAY PARTICIPATE IN SPECIAL FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) ARBITRATIONS. Sanction Details: SEC JUDGMENT CIVIL CASE 09-CV-743, FEBRUARY 17, 2009: THE SECURITIES AND EXCHANGE COMMISSION HAVING FILED A COMPLAINT AND DEFENDANT WACHOVIA SECURITIES, LLC HAVING ENTERED A GENERAL APPEARANCE; CONSENTED TO THE COURT'S JURISDICTION OVER DEFENDANT AND THE SUBJECT MATTER OF THIS ACTION; CONSENTED TO ENTRY OF THIS JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT (EXCEPT AS TO JURISDICTION); WAIVED FINDINGS OF FACT AND CONCLUSIONS OF LAW; ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 327 AND WAIVED ANY RIGHT TO APPEAL FROM THIS JUDGMENT: IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT DEFENDANT AND DEFENDANT'S AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS, AND ALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM WHO RECEIVE ACTUAL NOTICE OF THIS JUDGMENT BY PERSONAL SERVICE OR OTHERWISE ARE PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING, DIRECTLY OR INDIRECTLY, SECTION 15(C)(1) OF THE SECURITIES EXCHANGE ACT OF 1934; THE COURT SHALL DETERMINE WHETHER IT IS APPROPRIATE TO ORDER A CIVIL PENALTY AND, IF SO, THE AMOUNT OF THE CIVIL PENALTY; THE CONSENT IS INCORPORATED HEREIN WITH THE SAME FORCE AND EFFECT AS IF FULLY SET FORTH HEREIN, AND THAT DEFENDANT SHALL COMPLY WITH ALL OF THE UNDERTAKINGS AND AGREEMENTS SET FORTH THEREIN; THIS COURT SHALL RETAIN JURISDICTION OF THIS MATTER FOR THE PURPOSES OF ENFORCING THE TERMS OF THIS JUDGMENT.WITHOUT ADMITTING OR DENYING THE SEC'S ALLEGATIONS, WACHOVIA AGREED TO BE PERMANENTLY ENJOINED FROM VIOLATIONS OF SECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934, THE BROKER-DEALER FRAUD PROVISION, AND TO COMPLY WITH A NUMBER OF UNDERTAKINGS. AFTER WACHOVIA HAS COMPLETED ITS OBLIGATIONS UNDER THE SETTLEMENT AGREEMENT, THE SEC WILL DECIDE WHETHER TO SEEK A FINANCIAL PENALTY. SEC JUDGMENT CIVIL CASE 09-CV-743, FEBRUARY 17, 2009: THE SECURITIES AND EXCHANGE COMMISSION HAVING FILED A COMPLAINT AND DEFENDANT WACHOVIA SECURITIES, LLC HAVING ENTERED A www.finra.org/brokercheck GENERAL APPEARANCE; CONSENTED TO THE COURT'S JURISDICTION User Guidance OVER DEFENDANT AND THE SUBJECT MATTER OF THIS ACTION; CONSENTED TO ENTRY OF THIS JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT (EXCEPT AS TO JURISDICTION); WAIVED FINDINGS OF FACT AND CONCLUSIONS OF LAW; AND WAIVED ANY RIGHT TO APPEAL FROM THIS JUDGMENT: IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT DEFENDANT AND DEFENDANT'S AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS, AND ALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM WHO RECEIVE ACTUAL NOTICE OF THIS JUDGMENT BY PERSONAL SERVICE OR OTHERWISE ARE PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING, DIRECTLY OR INDIRECTLY, SECTION 15(C)(1) OF THE SECURITIES EXCHANGE ACT OF 1934; THE COURT SHALL DETERMINE WHETHER IT IS APPROPRIATE TO ORDER A CIVIL PENALTY AND, IF SO, THE AMOUNT OF THE CIVIL PENALTY; THE CONSENT IS INCORPORATED HEREIN WITH THE SAME FORCE AND EFFECT AS IF FULLY SET FORTH HEREIN, AND THAT DEFENDANT SHALL COMPLY WITH ALL OF THE UNDERTAKINGS AND AGREEMENTS SET FORTH THEREIN; THIS COURT SHALL RETAIN JURISDICTION OF THIS MATTER FOR THE PURPOSES OF ENFORCING THE TERMS OF THIS JUDGMENT.WITHOUT ADMITTING OR DENYING THE SEC'S ALLEGATIONS, WACHOVIA AGREED TO BE PERMANENTLY ENJOINED FROM VIOLATIONS OF SECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934, THE BROKER-DEALER FRAUD PROVISION, AND TO COMPLY WITH A NUMBER OF UNDERTAKINGS. AFTER WACHOVIA HAS COMPLETED ITS OBLIGATIONS UNDER THE SETTLEMENT AGREEMENT, THE SEC WILL DECIDE WHETHER TO SEEK A FINANCIAL PENALTY. Regulator Statement SEC LITIGATION RELEASE 21585, JUNE 30, 2010: THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT WACHOVIA SECURITIES LLC THAT SETTLED THE COMMISSION'S AUCTION RATE SECURITIES (ARS) CHARGES AGAINST IT HAS SATISFIED ITS OBLIGATIONS UNDER THE SETTLEMENT. WACHOVIA WAS REQUIRED TO OFFER TO PURCHASE ARS AT PAR FROM INDIVIDUAL, CHARITABLE, AND SMALL BUSINESS CUSTOMERS. WACHOVIA ALSO AGREED TO OFFER TO PURCHASE ARS FROM ALL OF ITS INSTITUTIONAL CUSTOMERS AS WELL. NEARLY 100% OF THESE CUSTOMERS HAVE ACCEPTED THE OFFER. WACHOVIA PURCHASED ARS FROM ITS ELIGIBLE CUSTOMERS IN THE AMOUNT OF $7.45 BILLION. WACHOVIA 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 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 328 PURSUED. SEC LITIGATION RELEASE 21585, JUNE 30, 2010: THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT WACHOVIA SECURITIES LLC THAT SETTLED THE COMMISSION'S AUCTION RATE SECURITIES (ARS) CHARGES AGAINST IT HAS SATISFIED ITS OBLIGATIONS UNDER THE SETTLEMENT. WACHOVIA WAS REQUIRED TO OFFER TO PURCHASE ARS AT PAR FROM INDIVIDUAL, CHARITABLE, AND SMALL BUSINESS CUSTOMERS. WACHOVIA ALSO AGREED TO OFFER TO PURCHASE ARS FROM ALL OF ITS INSTITUTIONAL CUSTOMERS AS WELL. NEARLY 100% OF THESE CUSTOMERS HAVE ACCEPTED THE OFFER. WACHOVIA PURCHASED ARS FROM ITS ELIGIBLE CUSTOMERS IN THE AMOUNT OF $7.45 BILLION. WACHOVIA 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 www.finra.org/brokercheck OBLIGATIONS. TO ENSURE COMPLIANCE WITH THE TERMS, THE User Guidance 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 20885, FEBRUARY 5, 2009: SECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934 - THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED A SETTLEMENT WITH WACHOVIA SECURITIES, LLC THAT WILL PROVIDE MORE THAN $7 BILLION IN LIQUIDITY TO THOUSANDS OF CUSTOMERS WHO INVESTED IN AUCTION RATE SECURITIES (ARS) BEFORE THE MARKET FOR THOSE SECURITIES COLLAPSED. THE SETTLEMENT RESOLVES THE SEC'S CHARGES THAT WACHOVIA MISLED INVESTORS REGARDING THE LIQUIDITY RISKS ASSOCIATED WITH ARS THAT IT UNDERWROTE, MARKETED AND SOLD. THE SEC'S COMPLAINT ALLEGES THAT WACHOVIA AND ANOTHER FIRM, WHOSE BROKER-DEALER OPERATIONS WERE CONSOLIDATED INTO WACHOVIA MISREPRESENTED TO CUSTOMERS THAT ARS WERE SAFE, HIGHLY LIQUID INVESTMENTS THAT WERE COMPARABLE TO CASH OR MONEY MARKET INSTRUMENTS. ACCORDING TO THE SEC'S COMPLAINT, WACHOVIA REINFORCED THE PERCEPTION OF LIQUIDITY BY ROUTINELY PURCHASING ARS FROM THE OTHER FIRM'S CUSTOMERS BETWEEN AUCTIONS, WITHOUT TELLING CUSTOMERS THAT WACHOVIA'S WILLINGNESS TO DO SO DEPENDED UPON THE CONTINUED SUCCESS OF THE AUCTIONS. THE SEC'S COMPLAINT ALLEGES THAT WACHOVIA BECAME AWARE OF MOUNTING EVIDENCE THAT PUT THE FIRM ON NOTICE THAT THE RISK OF AUCTION FAILURES HAD MATERIALLY INCREASED. WACHOVIA, NEVERTHELESS, CONTINUED TO MARKET ARS TO ITS CUSTOMERS AS HIGHLY LIQUID INVESTMENTS. WACHOVIA FOLLOWED THE LEAD OF OTHER BROKER-DEALERS AND DECIDED TO STOP SUPPORTING AUCTIONS. WITHOUT BROKER-DEALER SUPPORT, ARS AUCTIONS FAILED AND THOUSANDS OF WACHOVIA'S CUSTOMERS WERE LEFT HOLDING BILLIONS OF DOLLARS IN ILLIQUID ARS, WITHOUT ANY PRACTICAL MEANS OF REDEEMING, SELLING OR DERIVING VALUE FROM THEM. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Court Details: UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS, SECURITIES AND EXCHANGE COMMISSION V. WACHOVIA SECURITIES, LLC, CIVIL CASE NO. 09 CV 743 (N.D. ILL.) Date Court Action Filed: 02/05/2009 Principal Product Type: Other Other Product Types: AUCTION RATE SECURITIES (ARS) ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 329 www.finra.org/brokercheck User Guidance

Other Product Types: AUCTION RATE SECURITIES (ARS) Relief Sought: Injunction Other Relief Sought: PERMANENT INJUNCTION, FINANCIAL PENALTIES Resolution: Judgment Rendered Resolution Date: 02/17/2009 Sanctions Ordered or Relief Cease and Desist/Injunction Granted: Other Sanctions: UNDERTAKINGS: THE SETTLEMENT, WHICH IS SUBJECT TO COURT APPROVAL, PROVIDES, AMONG OTHER THINGS, THAT: WACHOVIA WILL OFFER TO BUY BACK ARS FROM ALL INVESTORS WHO PURCHASED ARS FROM WACHOVIA INTO ACCOUNTS MAINTAINED AT WACHOVIA ON OR BEFORE FEB. 13, 2008. WACHOVIA'S BUYBACK HAS TWO PHASES. IN THE FIRST PHASE, WHICH ENDED ON NOV. 28, 2008, WACHOVIA OFFERED TO PURCHASE ARS HELD BY NATURAL PERSONS, NOT-FOR-PROFIT AND RELIGIOUS ORGANIZATIONS AND FOR OTHER ACCOUNTS WITH ACCOUNT VALUES OR HOUSEHOLD VALUES UP TO $10 MILLION. AS OF NOV. 28, IT PURCHASED OVER $6.2 BILLION OF ELIGIBLE ARS FROM CUSTOMERS. SECOND, BEGINNING NO LATER THAT JUNE 10 AND ENDING NO LATER THAN JUNE 30, 2009, WACHOVIA WILL OFFER TO PURCHASE ARS HELD BY ALL OTHER INVESTORS. WACHOVIA WILL PAY CUSTOMERS WHO SOLD THEIR ARS BELOW PAR BETWEEN FEB. 13, 2008, AND NOV. 10, 2008, THE DIFFERENCE BETWEEN PAR AND THE SALE PRICE OF THE ARS, PLUS REASONABLE INTEREST. WACHOVIA WILL COMPENSATE CUSTOMERS WHO TOOK OUT LOANS FROM WACHOVIA AFTER FEB. 13, 2008, BECAUSE OF LIQUIDITY CONCERNS BY REIMBURSING CUSTOMERS FOR NO LESS THAN THE NEGATIVE CARRY ASSOCIATED WITH ANY SUCH LOANS. WACHOVIA WILL OFFER TO LEND ITS CUSTOMERS THE FULL PAR VALUE OF THEIR ARS, PENDING THE CONTEMPLATED BUYBACK, WITH INTEREST RATES SET SO THAT CUSTOMERS WILL HAVE NO NEGATIVE CARRY ON THEIR LOANS. FURTHER, IF ELIGIBLE CUSTOMERS INCURRED CONSEQUENTIAL DAMAGES BECAUSE OF THE ILLIQUIDITY OF THEIR ARS, THEY MAY PARTICIPATE IN SPECIAL FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) ARBITRATIONS. Sanction Details: SEC JUDGMENT CIVIL CASE 09-CV-743, FEBRUARY 17, 2009: THE SECURITIES AND EXCHANGE COMMISSION HAVING FILED A COMPLAINT AND DEFENDANT WACHOVIA SECURITIES, LLC HAVING ENTERED A GENERAL APPEARANCE; CONSENTED TO THE COURT'S JURISDICTION OVER DEFENDANT AND THE SUBJECT MATTER OF THIS ACTION; CONSENTED TO ENTRY OF THIS JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT (EXCEPT AS TO JURISDICTION); WAIVED FINDINGS OF FACT AND CONCLUSIONS OF LAW; AND WAIVED ANY RIGHT TO APPEAL FROM THIS JUDGMENT: IT IS HEREBY ©2021 FINRA. All rights reserved. Report aboutORDERED, WELLS FARGO ADJUDGED, CLEARING AND SERVICES, DECREED LLC THAT DEFENDANT AND 330 DEFENDANT'S AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS, AND ALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM WHO RECEIVE ACTUAL NOTICE OF THIS JUDGMENT BY PERSONAL SERVICE OR OTHERWISE ARE PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING, DIRECTLY OR INDIRECTLY, SECTION 15(C)(1) OF THE SECURITIES EXCHANGE ACT OF 1934; THE COURT SHALL DETERMINE WHETHER IT IS APPROPRIATE TO ORDER A CIVIL PENALTY AND, IF SO, THE AMOUNT OF THE CIVIL PENALTY; THE CONSENT IS INCORPORATED HEREIN WITH THE SAME FORCE AND EFFECT AS IF FULLY SET FORTH HEREIN, AND THAT DEFENDANT SHALL COMPLY WITH ALL OF THE UNDERTAKINGS AND AGREEMENTS SET FORTH THEREIN; THIS COURT SHALL RETAIN JURISDICTION OF THIS MATTER FOR THE PURPOSES OF ENFORCING THE TERMS OF THIS JUDGMENT.WITHOUT ADMITTING OR DENYING THE SEC'S ALLEGATIONS, WACHOVIA AGREED TO BE PERMANENTLY ENJOINED FROM VIOLATIONS OF SECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934, THE BROKER-DEALER FRAUD PROVISION, AND TO COMPLY WITH A NUMBER OF UNDERTAKINGS. AFTER WACHOVIA HAS COMPLETED ITS OBLIGATIONS UNDER THE SETTLEMENT AGREEMENT, THE SEC WILL DECIDE WHETHER TO SEEK A FINANCIAL PENALTY. SEC JUDGMENT CIVIL CASE 09-CV-743, FEBRUARY 17, 2009: THE SECURITIES AND EXCHANGE COMMISSION HAVING FILED A COMPLAINT AND DEFENDANT WACHOVIA SECURITIES, LLC HAVING ENTERED A GENERAL APPEARANCE; CONSENTED TO THE COURT'S JURISDICTION www.finra.org/brokercheck OVER DEFENDANT AND THE SUBJECT MATTER OF THIS ACTION; User Guidance CONSENTED TO ENTRY OF THIS JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT (EXCEPT AS TO JURISDICTION); WAIVED FINDINGS OF FACT AND CONCLUSIONS OF LAW; AND WAIVED ANY RIGHT TO APPEAL FROM THIS JUDGMENT: IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT DEFENDANT AND DEFENDANT'S AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS, AND ALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM WHO RECEIVE ACTUAL NOTICE OF THIS JUDGMENT BY PERSONAL SERVICE OR OTHERWISE ARE PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING, DIRECTLY OR INDIRECTLY, SECTION 15(C)(1) OF THE SECURITIES EXCHANGE ACT OF 1934; THE COURT SHALL DETERMINE WHETHER IT IS APPROPRIATE TO ORDER A CIVIL PENALTY AND, IF SO, THE AMOUNT OF THE CIVIL PENALTY; THE CONSENT IS INCORPORATED HEREIN WITH THE SAME FORCE AND EFFECT AS IF FULLY SET FORTH HEREIN, AND THAT DEFENDANT SHALL COMPLY WITH ALL OF THE UNDERTAKINGS AND AGREEMENTS SET FORTH THEREIN; THIS COURT SHALL RETAIN JURISDICTION OF THIS MATTER FOR THE PURPOSES OF ENFORCING THE TERMS OF THIS JUDGMENT.WITHOUT ADMITTING OR DENYING THE SEC'S ALLEGATIONS, WACHOVIA AGREED TO BE PERMANENTLY ENJOINED FROM VIOLATIONS OF SECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934, THE BROKER-DEALER FRAUD PROVISION, AND TO COMPLY WITH A NUMBER OF UNDERTAKINGS. AFTER WACHOVIA HAS COMPLETED ITS OBLIGATIONS UNDER THE SETTLEMENT AGREEMENT, THE SEC WILL DECIDE WHETHER TO SEEK A FINANCIAL PENALTY. Firm Statement SEC LITIGATION RELEASE 21585, JUNE 30, 2010: THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT WACHOVIA SECURITIES LLC THAT SETTLED THE COMMISSION'S AUCTION RATE SECURITIES (ARS) CHARGES AGAINST IT HAS SATISFIED ITS OBLIGATIONS UNDER THE SETTLEMENT. WACHOVIA WAS REQUIRED TO OFFER TO PURCHASE ARS AT PAR FROM INDIVIDUAL, CHARITABLE, AND SMALL BUSINESS CUSTOMERS. WACHOVIA ALSO AGREED TO OFFER TO PURCHASE ARS FROM ALL OF ITS INSTITUTIONAL CUSTOMERS AS WELL. NEARLY 100% OF THESE CUSTOMERS HAVE ACCEPTED THE OFFER. WACHOVIA PURCHASED ARS FROM ITS ELIGIBLE CUSTOMERS IN THE AMOUNT OF $7.45 BILLION. WACHOVIA 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. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 331 SEC LITIGATION RELEASE 21585, JUNE 30, 2010: THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT WACHOVIA SECURITIES LLC THAT SETTLED THE COMMISSION'S AUCTION RATE SECURITIES (ARS) CHARGES AGAINST IT HAS SATISFIED ITS OBLIGATIONS UNDER THE SETTLEMENT. WACHOVIA WAS REQUIRED TO OFFER TO PURCHASE ARS AT PAR FROM INDIVIDUAL, CHARITABLE, AND SMALL BUSINESS CUSTOMERS. WACHOVIA ALSO AGREED TO OFFER TO PURCHASE ARS FROM ALL OF ITS INSTITUTIONAL CUSTOMERS AS WELL. NEARLY 100% OF THESE CUSTOMERS HAVE ACCEPTED THE OFFER. WACHOVIA PURCHASED ARS FROM ITS ELIGIBLE CUSTOMERS IN THE AMOUNT OF $7.45 BILLION. WACHOVIA 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 www.finra.org/brokercheck SETTLEMENT PROVIDED FOR A POTENTIAL DEFERRED PENALTY IF THE User Guidance 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: Regulator Current Status: Final Allegations: AGENT MISAPPORPRIATED CLIENT FUNDS AND WACHOVIA FAILED TO SUPERVISE ITS AGENTS AND TO ENFORCE WRITTEN PROCEDURES. Initiated By: STATE OF CALIFORNIA - DEPARTMENT OF CORPORATIONS Court Details: ORANGE COUNTY SUPERIOR COURT - SANTA ANA - CALIFORNIA CASE NO. 03CC00433. Date Court Action Filed: 09/30/2003 Date Notice/Process Served: 09/30/2003 Principal Product Type: Other Other Product Types: EQUITY - LISTED (COMMON PREFERRED STOCK). Relief Sought: Other Other Relief Sought: CIV - CIVIL COMPLAINT FILED. Resolution: Dismissed Resolution Date: 01/10/2005 Sanctions Ordered or Relief Granted: Other Sanctions: Sanction Details: Regulator Statement LONG MISAPPROPRIATED FUNDS FROM 16 CLIENT ACCOUNTS WITH INVESTOR LOSSES TOTALING CLOSE TO 2 MILLION. THE BD FAILED TO SUPERVISE ITS AGENTS AND FAILED TO ENFORCE WRITTEN PROCEDURES.

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, A CONSENT ORDER WAS AGREED TO BY THE FIRM. i Reporting Source: Firm Current Status: Final Allegations: THE CALIFORNIA CORPORATIONS COMMISSIONER ALLEGES A FORMER BRANCH MANAGER FAILED TO SUPERVISE A FORMER REGISTERED ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 332 REPRESENTATIVE WHO MISAPPROPRIATED MONEY FROM HIS CLIENTS, ALL OF WHOM HAVE BEEN REIMBURSED BY THE FIRM. www.finra.org/brokercheck User Guidance

Allegations: THE CALIFORNIA CORPORATIONS COMMISSIONER ALLEGES A FORMER BRANCH MANAGER FAILED TO SUPERVISE A FORMER REGISTERED REPRESENTATIVE WHO MISAPPROPRIATED MONEY FROM HIS CLIENTS, ALL OF WHOM HAVE BEEN REIMBURSED BY THE FIRM. Initiated By: STATE OF CALIFORNIA , DEPARTMENT OF CORPORATIONS Court Details: ORANGE COUNTY SUPERIOR COURT; SANTA ANA; CALIFORNIA CASE NO. 03CC00433 Date Court Action Filed: 09/30/2003 Date Notice/Process Served: 11/12/2004 Principal Product Type: No Product Other Product Types: MISAPPROPRIATION OF FUNDS Relief Sought: Other Other Relief Sought: CIV - CIVIL COMPLAINT FILED Resolution: Dismissed Resolution Date: 01/10/2005 Sanctions Ordered or Relief Granted: Other Sanctions: Sanction Details: Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, A CONSENT ORDER WAS AGREED TO BY THE FIRM.

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 296 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: 04/03/2000 Case Number: 00-00937 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $115,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/04/2001 Sum of All Relief Awarded: $90,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 2 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 04/12/2000 Case Number: 00-01242 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 334 www.finra.org/brokercheck User Guidance

Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $300,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/01/2001 Sum of All Relief Awarded: $23,076.00 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 296 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: 05/11/2000 Case Number: 00-01331 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $784,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/09/2002 Sum of All Relief Awarded: $21,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 4 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/10/2000 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 335 www.finra.org/brokercheck User Guidance

Case Initiated: 04/10/2000 Case Number: 00-01428 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/20/2002 Sum of All Relief Awarded: $101,300.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 5 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 05/22/2000 Case Number: 00-01980 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $34,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/22/2002 Sum of All Relief Awarded: $8,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 6 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH ©2021 FINRA. All rights reserved. Report aboutOF CONTRACT; WELLS FARGO ACCOUNTCLEARING SERVICES, RELATED-NEGLIGENCE; LLC ACCOUNT RELATED- 336 OTHER www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED- OTHER Arbitration Forum: NASD Case Initiated: 07/05/2000 Case Number: 00-02369 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $589,496.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/09/2002 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 7 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 08/25/2000 Case Number: 00-03566 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $18,816.48 Disposition: AWARD AGAINST PARTY Disposition Date: 07/16/2001 Sum of All Relief Awarded: $8,816.48 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 296 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 337 www.finra.org/brokercheck User Guidance

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: 10/27/2000 Case Number: 00-04266 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,075.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/18/2001 Sum of All Relief Awarded: $575.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/11/2000 Case Number: 00-04341 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $30,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/16/2001 Sum of All Relief Awarded: $29,306.00 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 296 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 338 www.finra.org/brokercheck User Guidance

Disclosure 10 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/12/2000 Case Number: 00-04456 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $285,043.29 Disposition: AWARD AGAINST PARTY Disposition Date: 09/18/2002 Sum of All Relief Awarded: $72,380.54 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 11 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/30/2000 Case Number: 00-05242 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $31,800.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/19/2002 Sum of All Relief Awarded: $6,300.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 12 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-EXECUTIONS-LIMIT V MRKT ORDR Arbitration Forum: NASD Case Initiated: 01/29/2001 Case Number: 00-05490 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/23/2002 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 13 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE- EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 03/05/2001 Case Number: 01-00878 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $375,104.00 Disposition: AWARD AGAINST PARTY

Disposition Date: 09/11/2002 Sum of All Relief Awarded: $52,375.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 14 of 296 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: 04/04/2001 Case Number: 01-01630 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $3,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/14/2003 Sum of All Relief Awarded: $368,428.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 15 of 296 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: 05/08/2001 Case Number: 01-02319 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF ©2021 FINRA. All rights reserved. Report aboutSECURITIES WELLS FARGO CLEARING SERVICES, LLC 341 www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $63,178.50 Disposition: AWARD AGAINST PARTY Disposition Date: 06/11/2002 Sum of All Relief Awarded: $306,292.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 16 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 09/04/2001 Case Number: 01-03235 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $117,493.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/23/2002 Sum of All Relief Awarded: $108,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 17 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 342 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 07/03/2001 Case Number: 01-03307 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $300,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/05/2003 Sum of All Relief Awarded: $53,615.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 18 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- BREACH OF CONTRACT; ACCOUNT RELATED-MARGIN CALLS; DO NOT USE- EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 08/23/2001 Case Number: 01-03451 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS; OPTIONS Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/30/2002 Sum of All Relief Awarded: $35,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 19 of 296 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 07/06/2001 Case Number: 01-03469 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $410,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/22/2003 Sum of All Relief Awarded: $60,300.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 20 of 296 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: NASD Case Initiated: 08/15/2001 Case Number: 01-03781 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $501,125.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/24/2002 Sum of All Relief Awarded: $86,546.84 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 07/24/2001 Case Number: 01-03824 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: Disposition: AWARD AGAINST PARTY Disposition Date: 06/20/2003 Sum of All Relief Awarded: 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- TRANSFER Arbitration Forum: NASD Case Initiated: 09/17/2001 Case Number: 01-04580 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $58,234.35 Disposition: AWARD AGAINST PARTY Disposition Date: 05/17/2002 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 345 www.finra.org/brokercheck User Guidance

Disposition Date: 05/17/2002 Sum of All Relief Awarded: $17,460.15 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 23 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED- TRANSFER Arbitration Forum: NASD Case Initiated: 09/07/2001 Case Number: 01-04743 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: 07/02/2002 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 24 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/27/2001 Case Number: 01-04907 Disputed Product Type: ANNUITIES; COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES

Sum of All Relief Requested: $33,086.34 Disposition: AWARD AGAINST PARTY Disposition Date: 09/23/2002 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 25 of 296 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: 10/17/2001 Case Number: 01-05146 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: 09/13/2002 Sum of All Relief Awarded: $17,585.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE- NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/14/2001

Case Number: 01-05629 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $733,157.20 Disposition: AWARD AGAINST PARTY Disposition Date: 07/03/2003 Sum of All Relief Awarded: $92,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 27 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-MARGIN CALLS Arbitration Forum: NASD Case Initiated: 11/14/2001 Case Number: 01-06003 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $391,323.06 Disposition: AWARD AGAINST PARTY Disposition Date: 05/13/2003 Sum of All Relief Awarded: $77,550.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 28 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ©2021 FINRA. All rights reserved. Report aboutACTIVITY-SUITABILITY WELLS FARGO CLEARING SERVICES, LLC 348 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 01/02/2002 Case Number: 01-06890 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $1,400,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/14/2003 Sum of All Relief Awarded: $612,674.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/18/2002 Case Number: 02-00424 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $19,589.50 Disposition: AWARD AGAINST PARTY Disposition Date: 10/31/2002 Sum of All Relief Awarded: $15,699.86 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 30 of 296 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 349 www.finra.org/brokercheck User Guidance

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 03/28/2002 Case Number: 02-01681 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $5,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/26/2003 Sum of All Relief Awarded: $65,765.12 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 31 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 04/22/2002 Case Number: 02-02172 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $11,900,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/11/2003 Sum of All Relief Awarded: $318,288.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 350 www.finra.org/brokercheck User Guidance

i Disclosure 32 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE- NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/10/2002 Case Number: 02-02491 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $188,535.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/11/2003 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 33 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/03/2002 Case Number: 02-04961 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $120,905.60 Disposition: AWARD AGAINST PARTY Disposition Date: 10/23/2003 Sum of All Relief Awarded: $50,608.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 34 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-EXCHANGES; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 10/17/2002 Case Number: 02-05151 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $19,355.37 Disposition: AWARD AGAINST PARTY Disposition Date: 10/11/2004 Sum of All Relief Awarded: $2,125.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 35 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/21/2002 Case Number: 02-05447 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $25,278.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/01/2003 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 352 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $3,385.00 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 296 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: 10/23/2002 Case Number: 02-06220 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $601,746.51 Disposition: AWARD AGAINST PARTY Disposition Date: 07/20/2004 Sum of All Relief Awarded: $300,907.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 37 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE; TRADING DISPUTES-MANIPULATION Arbitration Forum: NASD Case Initiated: 11/05/2002 Case Number: 02-06253 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $7,505.02

Disposition: AWARD AGAINST PARTY Disposition Date: 03/12/2003 Sum of All Relief Awarded: $1,765.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 11/07/2002 Case Number: 02-06567 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: 03/03/2004 Sum of All Relief Awarded: $335,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 39 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED- ERRORS-CHARGES; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 11/22/2002 Case Number: 02-06786 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 354 www.finra.org/brokercheck User Guidance

Case Number: 02-06786 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; MUTUAL FUNDS; OPTIONS Sum of All Relief Requested: $7,309,475.77 Disposition: AWARD AGAINST PARTY Disposition Date: 09/15/2004 Sum of All Relief Awarded: $420,494.94 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 11/29/2002 Case Number: 02-06799 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; MUNICIPAL BONDS; MUTUAL FUNDS Sum of All Relief Requested: $768,315.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/02/2004 Sum of All Relief Awarded: $98,375.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 41 of 296 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 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 355 www.finra.org/brokercheck User Guidance

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 12/09/2002 Case Number: 02-07178 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $10,575,140.76 Disposition: AWARD AGAINST PARTY Disposition Date: 07/08/2004 Sum of All Relief Awarded: $2,692,591.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 42 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 12/27/2002 Case Number: 02-07610 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $342,264.50 Disposition: AWARD AGAINST PARTY Disposition Date: 03/22/2004 Sum of All Relief Awarded: $57,475.05 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 43 of 296 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/08/2003 Case Number: 02-07847 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $521,295.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/23/2004 Sum of All Relief Awarded: $343,116.10 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 44 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS Arbitration Forum: NASD Case Initiated: 02/19/2003 Case Number: 03-00704 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $101,099,408.39 Disposition: AWARD AGAINST PARTY Disposition Date: 11/18/2004 Sum of All Relief Awarded: $566,932.12 There may be a non-monetary award associated with this arbitration.

Please select the Case Number above to view more detailed information. i Disclosure 45 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 02/05/2003 Case Number: 03-00738 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $150,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/18/2003 Sum of All Relief Awarded: $36,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 46 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/11/2003 Case Number: 03-00824 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $93,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/15/2004 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 358 www.finra.org/brokercheck User Guidance

Disposition Date: 03/15/2004 Sum of All Relief Awarded: $28,776.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 03/24/2003 Case Number: 03-01817 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $364,930.75 Disposition: AWARD AGAINST PARTY Disposition Date: 03/11/2004 Sum of All Relief Awarded: $106,997.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: NASD Case Initiated: 05/02/2003 Case Number: 03-01897 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 359 www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $130,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/09/2006 Sum of All Relief Awarded: $70,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 49 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 04/01/2003 Case Number: 03-02046 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $999,990.69 Disposition: AWARD AGAINST PARTY Disposition Date: 09/12/2006 Sum of All Relief Awarded: $300,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 50 of 296 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 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 360 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 05/05/2003 Case Number: 03-02298 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $155,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/10/2004 Sum of All Relief Awarded: $6,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 51 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 04/14/2003 Case Number: 03-02491 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS; OPTIONS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $875,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/26/2004 Sum of All Relief Awarded: $360,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 52 of 296 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 05/14/2003 Case Number: 03-03132 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $448,018.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/29/2004 Sum of All Relief Awarded: $27,700.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 53 of 296 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: 07/10/2003 Case Number: 03-04949 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $221,230.78 Disposition: AWARD AGAINST PARTY Disposition Date: 08/06/2004 Sum of All Relief Awarded: $93,399.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 54 of 296 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: 09/17/2003 Case Number: 03-05072 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $40,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/03/2004 Sum of All Relief Awarded: $31,959.93 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 55 of 296 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: 07/24/2003 Case Number: 03-05384 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $312,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/27/2004 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 363 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $61,371.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 56 of 296 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: 08/13/2003 Case Number: 03-05692 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $205,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/22/2004 Sum of All Relief Awarded: $141,800.02 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 57 of 296 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: 08/08/2003 Case Number: 03-05764 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $21,748.07 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 364 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $21,748.07 Disposition: AWARD AGAINST PARTY Disposition Date: 02/09/2004 Sum of All Relief Awarded: $13,295.35 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 296 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: 09/17/2003 Case Number: 03-06298 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $21,336.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/11/2004 Sum of All Relief Awarded: $21,336.00 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 296 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: 09/16/2003

Case Number: 03-06583 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $750,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/10/2004 Sum of All Relief Awarded: $122,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 60 of 296 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: 10/08/2003 Case Number: 03-07234 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $140,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/07/2005 Sum of All Relief Awarded: $30,300.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 61 of 296 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: 12/03/2003 Case Number: 03-08306 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $1,983,248.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/02/2005 Sum of All Relief Awarded: $140,224.71 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 62 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 12/04/2003 Case Number: 03-08495 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $681,310.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/01/2004 Sum of All Relief Awarded: $295,875.94 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 296 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 02/06/2004 Case Number: 04-00705 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS Sum of All Relief Requested: $3,685,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/15/2005 Sum of All Relief Awarded: $590,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 64 of 296 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: 04/30/2004 Case Number: 04-01727 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $3,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/01/2006 Sum of All Relief Awarded: $794,088.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 03/26/2004 Case Number: 04-01979 Disputed Product Type: ANNUITIES; COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $250,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/29/2005 Sum of All Relief Awarded: $135,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 66 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/05/2004 Case Number: 04-02277 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 05/26/2005 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 369 www.finra.org/brokercheck User Guidance

Disposition Date: 05/26/2005 Sum of All Relief Awarded: $86,864.00 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 296 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: 04/22/2004 Case Number: 04-02907 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $313,390.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/28/2005 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 68 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 05/18/2004 Case Number: 04-03070 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF ©2021 FINRA. All rights reserved. Report aboutSECURITIES WELLS FARGO CLEARING SERVICES, LLC 370 www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $949,604.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/08/2005 Sum of All Relief Awarded: $185,000.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 06/22/2004 Case Number: 04-03314 Disputed Product Type: CERTIFICATE OF DEPOSIT; COMMON STOCK; OTHER TYPES OF SECURITIES; PREFERRED STOCK Sum of All Relief Requested: $11,700,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/03/2006 Sum of All Relief Awarded: $35,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 70 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

Arbitration Forum: NASD Case Initiated: 05/14/2004 Case Number: 04-03410 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $241,646.67 Disposition: AWARD AGAINST PARTY Disposition Date: 12/27/2005 Sum of All Relief Awarded: $12,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 71 of 296 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: 06/21/2004 Case Number: 04-03813 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $25,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/02/2005 Sum of All Relief Awarded: $23,024.32 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 72 of 296 Reporting Source: Regulator Type of Event: ARBITRATION ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 372 www.finra.org/brokercheck User Guidance

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: 06/23/2004 Case Number: 04-04336 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $3,600,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/10/2005 Sum of All Relief Awarded: $369,850.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 73 of 296 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: 08/03/2004 Case Number: 04-05459 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; GOVERNMENT SECURITIES; MUTUAL FUNDS Sum of All Relief Requested: $869,060.59 Disposition: AWARD AGAINST PARTY Disposition Date: 06/29/2006 Sum of All Relief Awarded: $28,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 74 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 10/08/2004 Case Number: 04-07044 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/18/2006 Sum of All Relief Awarded: $240,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 75 of 296 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: 12/02/2004 Case Number: 04-08079 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $2,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/13/2006 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 374 www.finra.org/brokercheck User Guidance

Disposition Date: 04/13/2006 Sum of All Relief Awarded: $1,701,930.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/29/2004 Case Number: 04-08117 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $425,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/12/2008 Sum of All Relief Awarded: $421,031.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/01/2004 Case Number: 04-08161 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF ©2021 FINRA. All rights reserved. Report aboutSEC WELLS INVOLVE FARGO CLEARING SERVICES, LLC 375 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: $110,643.78 Disposition: AWARD AGAINST PARTY Disposition Date: 08/16/2005 Sum of All Relief Awarded: $14,654.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 05/20/2005 Case Number: 04-08571 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 04/24/2006 Sum of All Relief Awarded: $243,250.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 79 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 02/04/2005 Case Number: 04-08618 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $90,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/13/2006 Sum of All Relief Awarded: $41,900.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 80 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED- TRANSFER Arbitration Forum: NASD Case Initiated: 01/06/2005 Case Number: 05-00019 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $80,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/22/2005 Sum of All Relief Awarded: $72,342.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 81 of 296 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 03/10/2005 Case Number: 05-01222 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS Sum of All Relief Requested: $30,525.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/16/2005 Sum of All Relief Awarded: $26,775.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 03/22/2005 Case Number: 05-01452 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $2,500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/09/2006 Sum of All Relief Awarded: $9,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 83 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/31/2005 Case Number: 05-01616 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $32,199.47 Disposition: AWARD AGAINST PARTY Disposition Date: 12/19/2005 Sum of All Relief Awarded: $16,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 84 of 296 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: 04/25/2005 Case Number: 05-02096 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $624,771.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/03/2007 Sum of All Relief Awarded: $295,822.01 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 379 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $295,822.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 85 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- OMISSION OF FACTS; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 06/10/2005 Case Number: 05-02573 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $999,999.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/30/2005 Sum of All Relief Awarded: $431,042.00 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 296 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: 08/11/2005 Case Number: 05-03586 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES

Sum of All Relief Requested: $12,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/23/2006 Sum of All Relief Awarded: $2,021,200.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 87 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/07/2005 Case Number: 05-05190 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $2,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/21/2006 Sum of All Relief Awarded: $1,877.21 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 88 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/13/2005

Case Number: 05-05339 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $450,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/08/2007 Sum of All Relief Awarded: $40,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 89 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 10/20/2005 Case Number: 05-05346 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $80,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/11/2006 Sum of All Relief Awarded: $30,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 90 of 296 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: 11/09/2005 Case Number: 05-05673 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/19/2006 Sum of All Relief Awarded: $12,833.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 91 of 296 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: 12/02/2005 Case Number: 05-06026 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $25,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/04/2006 Sum of All Relief Awarded: $10,619.98 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 92 of 296 Reporting Source: Regulator Type of Event: ARBITRATION ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 383 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT RELATED-MARGIN CALLS; DO NOT USE-EXECUTIONS- INCORRECT QUANTITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/15/2006 Case Number: 05-06078 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $99,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/23/2007 Sum of All Relief Awarded: $11,099.00 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 296 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: 01/23/2006 Case Number: 06-00085 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/05/2008 Sum of All Relief Awarded: $775,012.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/17/2006 Case Number: 06-00170 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $288,954.88 Disposition: AWARD AGAINST PARTY Disposition Date: 01/19/2007 Sum of All Relief Awarded: $25,712.09 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 95 of 296 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: 04/28/2006 Case Number: 06-02094 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $11,550,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/10/2007 Sum of All Relief Awarded: $343,000.01

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 96 of 296 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: 06/05/2006 Case Number: 06-02660 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $11,602,637.06 Disposition: AWARD AGAINST PARTY Disposition Date: 08/01/2007 Sum of All Relief Awarded: $10,513.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-DIVIDENDS; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 07/12/2006 Case Number: 06-03014 Disputed Product Type: ANNUITIES; COMMON STOCK; MUNICIPAL BONDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $499,000.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 386 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 05/19/2008 Sum of All Relief Awarded: $98,709.35 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/19/2006 Case Number: 06-03324 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $25,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/30/2007 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 99 of 296 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: 11/09/2006 Case Number: 06-04869

©2021Disputed FINRA. Product All rights Type:reserved. Report aboutDO NOTWELLS USE-NO FARGO CLEARING OTHER TYPESERVICES, OF SECLLC INVOLVE; UNKNOWN TYPE OF 387 SECURITIES www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $400,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/08/2007 Sum of All Relief Awarded: $293,659.25 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 100 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 02/14/2007 Case Number: 07-00417 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $32,851.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/12/2007 Sum of All Relief Awarded: $13,713.36 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 296 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: 04/05/2007 Case Number: 07-00666 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; HEDGE FUND Sum of All Relief Requested: $120,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/02/2012 Sum of All Relief Awarded: $852,000.02 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 102 of 296 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: NASD Case Initiated: 04/05/2007 Case Number: 07-00905 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 08/05/2008 Sum of All Relief Awarded: $163,848.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION

©2021Allegations: FINRA. All rights reserved. Report aboutACCOUNT WELLS FARGO ACTIVITY-BRCH CLEARING SERVICES, OF FIDUCIARY LLC DT; ACCOUNT ACTIVITY- 389 MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 06/12/2007 Case Number: 07-01557 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 03/19/2009 Sum of All Relief Awarded: $162,135.89 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 104 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 09/14/2007 Case Number: 07-01706 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $410,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/13/2010 Sum of All Relief Awarded: $18,384.41 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 105 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: FINRA Case Initiated: 07/31/2007 Case Number: 07-01716 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 11/12/2010 Sum of All Relief Awarded: $2,079,300.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 106 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/16/2007 Case Number: 07-01729 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $6,354,498.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/30/2008 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 391 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $5,297,001.72 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 107 of 296 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: FINRA Case Initiated: 11/07/2007 Case Number: 07-03105 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $15,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/26/2008 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 108 of 296 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: 11/26/2007 Case Number: 07-03227 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FUTURES (OTHER THAN COMMODITIES) Sum of All Relief Requested: $1,300,000.00 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 392 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $1,300,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/12/2008 Sum of All Relief Awarded: $525,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 109 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-OTHER; DO NOT USE-EXECUTIONS- FAILURE TO EXECUTE Arbitration Forum: FINRA Case Initiated: 04/03/2008 Case Number: 08-00956 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $98,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/13/2009 Sum of All Relief Awarded: $89,338.37 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 110 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; TRADING DISPUTES-TRANSFERS Arbitration Forum: FINRA Case Initiated: 04/07/2008 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 393 www.finra.org/brokercheck User Guidance

Case Initiated: 04/07/2008 Case Number: 08-01002 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $25,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/20/2009 Sum of All Relief Awarded: $32,182.86 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 111 of 296 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: FINRA Case Initiated: 07/30/2008 Case Number: 08-02454 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 07/21/2009 Sum of All Relief Awarded: $143,000.00 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 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; UNKNOWN TYPE OF CONTROVERSIES ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 394 www.finra.org/brokercheck User Guidance ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: FINRA Case Initiated: 10/07/2008 Case Number: 08-03219 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $440,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/27/2010 Sum of All Relief Awarded: $391,375.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 113 of 296 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: FINRA Case Initiated: 10/31/2008 Case Number: 08-03999 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $482,338.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/19/2009 Sum of All Relief Awarded: $60,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 114 of 296 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 12/09/2008 Case Number: 08-04027 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $8,400,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/29/2010 Sum of All Relief Awarded: $82,837.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 115 of 296 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: 12/09/2008 Case Number: 08-04559 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $376,691.07 Disposition: AWARD AGAINST PARTY Disposition Date: 12/23/2009 Sum of All Relief Awarded: $123,324.22 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 116 of 296 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: FINRA Case Initiated: 12/18/2008 Case Number: 08-04797 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/09/2009 Sum of All Relief Awarded: $3,995.94 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 117 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: FINRA Case Initiated: 01/05/2009 Case Number: 08-05005 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/17/2010 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 397 www.finra.org/brokercheck User Guidance

Disposition Date: 03/17/2010 Sum of All Relief Awarded: $14,376.85 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 118 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 01/22/2009 Case Number: 09-00314 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; STOCK INDEX FUTURES Sum of All Relief Requested: $61,842.33 Disposition: AWARD AGAINST PARTY Disposition Date: 04/29/2010 Sum of All Relief Awarded: $17,533.75 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 119 of 296 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: FINRA Case Initiated: 04/17/2009 Case Number: 09-00958 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES

Sum of All Relief Requested: $9,118.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/11/2009 Sum of All Relief Awarded: $9,443.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 120 of 296 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: 04/06/2009 Case Number: 09-01766 Disputed Product Type: MUTUAL FUNDS Sum of All Relief Requested: $66,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/08/2010 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 121 of 296 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; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 399 www.finra.org/brokercheck User Guidance

Arbitration Forum: FINRA Case Initiated: 04/13/2009 Case Number: 09-01827 Disputed Product Type: Sum of All Relief Requested: $95,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/18/2010 Sum of All Relief Awarded: $26,225.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 122 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: FINRA Case Initiated: 04/16/2009 Case Number: 09-01981 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $155,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/05/2010 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 123 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report aboutSUITABILITY; WELLS FARGO ACCOUNT CLEARING RELATED-BREACH SERVICES, LLC OF CONTRACT 400 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: FINRA Case Initiated: 04/29/2009 Case Number: 09-02283 Disputed Product Type: ANNUITIES; MUTUAL FUNDS Sum of All Relief Requested: $7,127.70 Disposition: AWARD AGAINST PARTY Disposition Date: 02/11/2010 Sum of All Relief Awarded: $1,106.25 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 124 of 296 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: 05/08/2009 Case Number: 09-02513 Disputed Product Type: VARIABLE ANNUITIES Sum of All Relief Requested: $75,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/21/2009 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 125 of 296 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 401 www.finra.org/brokercheck User Guidance

Disclosure 125 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 05/07/2009 Case Number: 09-02527 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $19,995.87 Disposition: AWARD AGAINST PARTY Disposition Date: 10/14/2009 Sum of All Relief Awarded: $9,412.52 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 126 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; TRADING DISPUTES-OTHER Arbitration Forum: FINRA Case Initiated: 07/10/2009 Case Number: 09-02748 Disputed Product Type: FANNIE MAE; PREFERRED STOCK Sum of All Relief Requested: $1,937,806.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/23/2010 Sum of All Relief Awarded: $25,000.00 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 402 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $25,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 127 of 296 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 ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 06/02/2009 Case Number: 09-03013 Disputed Product Type: COMMON STOCK; FANNIE MAE; FREDDIE MACS; PREFERRED STOCK; VARIABLE ANNUITIES Sum of All Relief Requested: $1,440,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/19/2010 Sum of All Relief Awarded: $276,844.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 128 of 296 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: 06/12/2009 Case Number: 09-03471 Disputed Product Type: UNKNOWN TYPE OF SECURITIES ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 403 www.finra.org/brokercheck User Guidance

Disputed Product Type: UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $46,489.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/14/2011 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 129 of 296 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-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 06/12/2009 Case Number: 09-03489 Disputed Product Type: Sum of All Relief Requested: $226,865.86 Disposition: AWARD AGAINST PARTY Disposition Date: 07/12/2010 Sum of All Relief Awarded: $90,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 130 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 404 www.finra.org/brokercheck User Guidance

Arbitration Forum: FINRA Case Initiated: 06/18/2009 Case Number: 09-03593 Disputed Product Type: COMMON STOCK; FANNIE MAE; MUTUAL FUNDS; PREFERRED STOCK Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/21/2011 Sum of All Relief Awarded: $10,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 131 of 296 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: 07/15/2009 Case Number: 09-03773 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $1,248,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/31/2010 Sum of All Relief Awarded: $91,128.70 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 132 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURE ©2021 FINRA. All rights reserved. Report aboutTO SUPERVISE; WELLS FARGO CLEARINGDO NOT USE-EXECUTIONS-FAILURESERVICES, LLC TO EXECUTE 405 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: FINRA Case Initiated: 06/30/2009 Case Number: 09-03803 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $66,945.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/22/2011 Sum of All Relief Awarded: $34,304.95 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 133 of 296 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: 07/15/2009 Case Number: 09-04136 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $74,518.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/14/2010 Sum of All Relief Awarded: $49,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 134 of 296 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 406 www.finra.org/brokercheck User Guidance

Disclosure 134 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 08/05/2009 Case Number: 09-04471 Disputed Product Type: MUNICIPAL BOND FUNDS Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 12/20/2010 Sum of All Relief Awarded: $210,891.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 135 of 296 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; DO NOT USE-EXECUTIONS-OTHER Arbitration Forum: FINRA Case Initiated: 08/18/2009 Case Number: 09-04773 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $1,467,091.06 Disposition: AWARD AGAINST PARTY Disposition Date: 01/04/2011 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 407 www.finra.org/brokercheck User Guidance

Disposition Date: 01/04/2011 Sum of All Relief Awarded: $208,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 136 of 296 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; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 08/21/2009 Case Number: 09-04887 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $130,085.96 Disposition: AWARD AGAINST PARTY Disposition Date: 07/23/2010 Sum of All Relief Awarded: $39,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 137 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED- ERRORS-CHARGES; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-TRANSFER Arbitration Forum: FINRA Case Initiated: 10/01/2009 Case Number: 09-05158 Disputed Product Type: MUNICIPAL BOND FUNDS; MUNICIPAL BONDS; MUTUAL FUNDS ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 408 www.finra.org/brokercheck User Guidance

Disputed Product Type: MUNICIPAL BOND FUNDS; MUNICIPAL BONDS; MUTUAL FUNDS Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 12/14/2010 Sum of All Relief Awarded: $53,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 138 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 09/30/2009 Case Number: 09-05301 Disputed Product Type: COMMON STOCK; OPTIONS Sum of All Relief Requested: $474,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/05/2011 Sum of All Relief Awarded: $260,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 139 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 409 www.finra.org/brokercheck User Guidance

Arbitration Forum: FINRA Case Initiated: 09/24/2009 Case Number: 09-05435 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; MUTUAL FUNDS Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/16/2010 Sum of All Relief Awarded: $100,300.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 140 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 10/06/2009 Case Number: 09-05626 Disputed Product Type: PRIVATE EQUITIES Sum of All Relief Requested: $130,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/02/2012 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 141 of 296 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 10/07/2009 Case Number: 09-05655 Disputed Product Type: Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 04/16/2010 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 142 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 12/16/2009 Case Number: 09-06534 Disputed Product Type: VARIABLE ANNUITIES Sum of All Relief Requested: $29,145.22 Disposition: AWARD AGAINST PARTY Disposition Date: 11/04/2010 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 143 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-TRANSFER; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; TRADING DISPUTES-TRANSFERS Arbitration Forum: FINRA Case Initiated: 01/07/2010 Case Number: 09-06730 Disputed Product Type: EXCHANGE-TRADED FUNDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $22,088.72 Disposition: AWARD AGAINST PARTY Disposition Date: 08/04/2010 Sum of All Relief Awarded: $20,368.44 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 144 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 12/31/2009 Case Number: 09-07137 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $809,677.92 Disposition: AWARD AGAINST PARTY Disposition Date: 03/24/2011 Sum of All Relief Awarded: $292,952.71

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 145 of 296 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: FINRA Case Initiated: 01/06/2010 Case Number: 09-07145 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $600,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/14/2011 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 146 of 296 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-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED- OTHER Arbitration Forum: FINRA Case Initiated: 02/22/2010 Case Number: 10-00742 Disputed Product Type: OTHER TYPES OF SECURITIES; STRUCTURED PRODUCTS Sum of All Relief Requested: $36,414.30

Disposition: AWARD AGAINST PARTY Disposition Date: 07/30/2010 Sum of All Relief Awarded: $57,165.10 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 147 of 296 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; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 03/12/2010 Case Number: 10-01040 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $425,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/25/2011 Sum of All Relief Awarded: $153,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 148 of 296 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: FINRA Case Initiated: 03/12/2010 Case Number: 10-01051 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 414 www.finra.org/brokercheck User Guidance

Case Number: 10-01051 Disputed Product Type: MUNICIPAL BOND FUNDS; MUTUAL FUNDS Sum of All Relief Requested: $375,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/07/2011 Sum of All Relief Awarded: $217,928.40 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 149 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED- NEGLIGENCE; ACCOUNT RELATED-TRANSFER; TRADING DISPUTES-SELL OUTS Arbitration Forum: FINRA Case Initiated: 04/22/2010 Case Number: 10-01102 Disputed Product Type: Sum of All Relief Requested: $750,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/16/2012 Sum of All Relief Awarded: $37,645.87 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 150 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 415 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 03/26/2010 Case Number: 10-01194 Disputed Product Type: MUTUAL FUNDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $4,100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/26/2013 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 151 of 296 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-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 03/17/2010 Case Number: 10-01209 Disputed Product Type: OTHER TYPES OF SECURITIES; PREFERRED STOCK Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 08/03/2011 Sum of All Relief Awarded: $60,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 152 of 296 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 ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 05/27/2010 Case Number: 10-01775 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 07/20/2012 Sum of All Relief Awarded: $227,750.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 153 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: FINRA Case Initiated: 04/30/2010 Case Number: 10-01950 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $5,642.15 Disposition: AWARD AGAINST PARTY Disposition Date: 09/24/2010 Sum of All Relief Awarded: $5,804.65 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 154 of 296 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- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 06/14/2010 Case Number: 10-01997 Disputed Product Type: Sum of All Relief Requested: $48,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/29/2011 Sum of All Relief Awarded: $43,579.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 155 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE; ACCOUNT RELATED-OTHER; ACCOUNT RELATED-TRANSFER Arbitration Forum: FINRA Case Initiated: 05/14/2010 Case Number: 10-02160 Disputed Product Type: CERTIFICATE OF DEPOSIT; COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $180,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/05/2011 Sum of All Relief Awarded: $78,343.24 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 418 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $78,343.24 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 156 of 296 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-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 07/06/2010 Case Number: 10-03013 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $25,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/22/2010 Sum of All Relief Awarded: $31,673.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 157 of 296 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: 08/26/2010 Case Number: 10-03052 Disputed Product Type: Sum of All Relief Requested: $190,000.00 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 419 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $190,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/30/2012 Sum of All Relief Awarded: $99,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 158 of 296 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-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 07/16/2010 Case Number: 10-03084 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS; VARIABLE ANNUITIES Sum of All Relief Requested: $540,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/11/2011 Sum of All Relief Awarded: $55,860.71 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 159 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: FINRA Case Initiated: 07/22/2010

Case Number: 10-03151 Disputed Product Type: AUCTION RATE SECURITIES Sum of All Relief Requested: $925,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/07/2011 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 160 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 08/30/2010 Case Number: 10-03357 Disputed Product Type: FANNIE MAE; PREFERRED STOCK Sum of All Relief Requested: $23,467.51 Disposition: AWARD AGAINST PARTY Disposition Date: 03/07/2011 Sum of All Relief Awarded: $23,892.51 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 161 of 296 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; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED- OTHER

Arbitration Forum: FINRA Case Initiated: 08/04/2010 Case Number: 10-03416 Disputed Product Type: COMMON STOCK; GOVERNMENT SECURITIES; OPTIONS Sum of All Relief Requested: $5,400,000.02 Disposition: AWARD AGAINST PARTY Disposition Date: 02/14/2012 Sum of All Relief Awarded: $370,882.54 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 162 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 08/18/2010 Case Number: 10-03554 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $6,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/03/2013 Sum of All Relief Awarded: $2,752,049.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 163 of 296 Reporting Source: Regulator Type of Event: ARBITRATION ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 422 www.finra.org/brokercheck User Guidance

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 09/28/2010 Case Number: 10-04159 Disputed Product Type: Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/12/2011 Sum of All Relief Awarded: $3,536.82 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 164 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 09/30/2010 Case Number: 10-04321 Disputed Product Type: ANNUITIES; MUTUAL FUNDS; OTHER TYPES OF SECURITIES; PRIVATE EQUITIES Sum of All Relief Requested: $652,204.30 Disposition: AWARD AGAINST PARTY Disposition Date: 12/03/2013 Sum of All Relief Awarded: $297,516.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 165 of 296 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-FAILURE TO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 12/07/2010 Case Number: 10-04904 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $811,867.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/21/2011 Sum of All Relief Awarded: $375.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 166 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-DIVIDENDS; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 11/23/2010 Case Number: 10-05212 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $780,000.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 424 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 12/08/2011 Sum of All Relief Awarded: $214,100.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 167 of 296 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: 11/24/2010 Case Number: 10-05215 Disputed Product Type: FANNIE MAE; FREDDIE MACS; PREFERRED STOCK Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/05/2012 Sum of All Relief Awarded: $62,515.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 168 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 12/01/2010 Case Number: 10-05260 Disputed Product Type: PREFERRED STOCK ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 425 www.finra.org/brokercheck User Guidance

Disputed Product Type: PREFERRED STOCK Sum of All Relief Requested: $34,411.80 Disposition: AWARD AGAINST PARTY Disposition Date: 02/16/2012 Sum of All Relief Awarded: $5,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 169 of 296 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: 01/11/2011 Case Number: 10-05826 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $154,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/01/2011 Sum of All Relief Awarded: $130,300.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 170 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

Arbitration Forum: FINRA Case Initiated: 01/13/2011 Case Number: 11-00052 Disputed Product Type: PREFERRED STOCK Sum of All Relief Requested: $425,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/05/2012 Sum of All Relief Awarded: $90,297.79 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 171 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 01/21/2011 Case Number: 11-00185 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $300,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/17/2012 Sum of All Relief Awarded: $61,894.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 172 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 427 MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 02/05/2011 Case Number: 11-00416 Disputed Product Type: UNIT INVESTMENT TRUST Sum of All Relief Requested: $128,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/17/2012 Sum of All Relief Awarded: $49,759.58 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 173 of 296 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; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 02/11/2011 Case Number: 11-00482 Disputed Product Type: MUTUAL FUNDS Sum of All Relief Requested: $987,015.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/13/2012 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 174 of 296 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 428 www.finra.org/brokercheck User Guidance

Disclosure 174 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED- FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 03/17/2011 Case Number: 11-00484 Disputed Product Type: ANNUITIES; MUNICIPAL BOND FUNDS; MUTUAL FUNDS Sum of All Relief Requested: $10,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/10/2012 Sum of All Relief Awarded: $97,250.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 175 of 296 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 Arbitration Forum: FINRA Case Initiated: 02/18/2011 Case Number: 11-00556 Disputed Product Type: COMMON STOCK; MUNICIPAL BONDS Sum of All Relief Requested: $1,904,290.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/09/2013 Sum of All Relief Awarded: $1,333,933.02 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 429 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $1,333,933.02 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 176 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER Arbitration Forum: FINRA Case Initiated: 04/14/2011 Case Number: 11-01076 Disputed Product Type: CORPORATE BONDS Sum of All Relief Requested: $23,993.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/15/2011 Sum of All Relief Awarded: $20,819.30 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 177 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 05/12/2011 Case Number: 11-01830 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS; STRUCTURED PRODUCTS Sum of All Relief Requested: $100,000.00

Disposition: AWARD AGAINST PARTY Disposition Date: 02/27/2012 Sum of All Relief Awarded: $21,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 178 of 296 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: 08/23/2011 Case Number: 11-03046 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/14/2012 Sum of All Relief Awarded: $70,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 179 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 12/01/2011 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 431 www.finra.org/brokercheck User Guidance

Case Initiated: 12/01/2011 Case Number: 11-04241 Disputed Product Type: AUCTION RATE SECURITIES Sum of All Relief Requested: $80,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/24/2013 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 180 of 296 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: 12/15/2011 Case Number: 11-04556 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 03/08/2013 Sum of All Relief Awarded: $70,930.20 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 181 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report aboutMANIPULATION; WELLS FARGO CLEARINGACCOUNT SERVICES, ACTIVITY-MISREPRESENTATION; LLC ACCOUNT 432 ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-ERRORS- CHARGES; ACCOUNT RELATED-EXCHANGES; DO NOT USE-EXECUTIONS- FAILURE TO EXECUTE www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-ERRORS- CHARGES; ACCOUNT RELATED-EXCHANGES; DO NOT USE-EXECUTIONS- FAILURE TO EXECUTE Arbitration Forum: FINRA Case Initiated: 12/30/2011 Case Number: 11-04763 Disputed Product Type: VARIABLE ANNUITIES Sum of All Relief Requested: $737,733.14 Disposition: AWARD AGAINST PARTY Disposition Date: 01/15/2013 Sum of All Relief Awarded: $306,127.34 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 182 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: FINRA Case Initiated: 01/27/2012 Case Number: 11-04797 Disputed Product Type: Sum of All Relief Requested: $16,960.66 Disposition: AWARD AGAINST PARTY Disposition Date: 10/16/2012 Sum of All Relief Awarded: $8,692.84 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 183 of 296

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: FINRA Case Initiated: 03/02/2012 Case Number: 12-00515 Disputed Product Type: ANNUITIES Sum of All Relief Requested: $71,775.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/27/2012 Sum of All Relief Awarded: $15,786.45 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 184 of 296 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; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 04/04/2012 Case Number: 12-00793 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $18,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/30/2013 Sum of All Relief Awarded: $1,802,508.08

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 185 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 03/26/2012 Case Number: 12-00996 Disputed Product Type: COMMON STOCK; FANNIE MAE; GOVERNMENT SECURITIES; PREFERRED STOCK Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/06/2013 Sum of All Relief Awarded: $48,399.70 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 186 of 296 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: 07/11/2012 Case Number: 12-02349 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: Unspecified Damages ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 435 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 11/26/2013 Sum of All Relief Awarded: $1,307,920.80 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 187 of 296 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-ERRORS-CHARGES Arbitration Forum: FINRA Case Initiated: 10/09/2012 Case Number: 12-03473 Disputed Product Type: EXCHANGE-TRADED FUNDS Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/22/2014 Sum of All Relief Awarded: $35,952.94 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 188 of 296 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 ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 436 www.finra.org/brokercheck User Guidance

Case Initiated: 12/26/2012 Case Number: 12-03924 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/02/2015 Sum of All Relief Awarded: $60,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 189 of 296 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 ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; TRADING DISPUTES-SELL OUTS Arbitration Forum: FINRA Case Initiated: 01/28/2013 Case Number: 13-00033 Disputed Product Type: MUTUAL FUNDS; OTHER TYPES OF SECURITIES; PREFERRED STOCK Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 12/16/2013 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 190 of 296 Reporting Source: Regulator Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 01/09/2013 Case Number: 13-00034 Disputed Product Type: VARIABLE ANNUITIES Sum of All Relief Requested: $420,150.21 Disposition: AWARD AGAINST PARTY Disposition Date: 11/06/2013 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 191 of 296 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: 03/21/2013 Case Number: 13-00333 Disputed Product Type: VARIABLE ANNUITIES Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 11/06/2014 Sum of All Relief Awarded: $144,808.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

i Disclosure 192 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE- EXECUTIONS-EXECUTION PRICE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-EXECUTIONS-INCORRECT QUANTITY; DO NOT USE-EXECUTIONS-OTHER; OTHER-UNDERWRITING; TRADING DISPUTES- OTHER Arbitration Forum: FINRA Case Initiated: 03/15/2013 Case Number: 13-00469 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $4,914.32 Disposition: AWARD AGAINST PARTY Disposition Date: 10/29/2013 Sum of All Relief Awarded: $3,289.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 193 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 04/16/2013 Case Number: 13-00779 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $500,000.00 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 439 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/30/2014 Sum of All Relief Awarded: $144,125.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 194 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: FINRA Case Initiated: 06/07/2013 Case Number: 13-01405 Disputed Product Type: Sum of All Relief Requested: $4,999.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/11/2014 Sum of All Relief Awarded: $2,881.92 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 195 of 296 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-FAILURE TO SUPERVISE Arbitration Forum: FINRA Case Initiated: 07/08/2013 Case Number: 13-01756 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 440 www.finra.org/brokercheck User Guidance

Case Number: 13-01756 Disputed Product Type: CERTIFICATE OF DEPOSIT Sum of All Relief Requested: $193,327.68 Disposition: AWARD AGAINST PARTY Disposition Date: 03/28/2014 Sum of All Relief Awarded: $61,725.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 196 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 08/19/2013 Case Number: 13-02375 Disputed Product Type: ANNUITIES; VARIABLE ANNUITIES Sum of All Relief Requested: $49,292.36 Disposition: AWARD AGAINST PARTY Disposition Date: 02/19/2014 Sum of All Relief Awarded: $34,982.02 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 197 of 296 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 ©2021 FINRA. All rights reserved. Report aboutRELATED-NEGLIGENCE WELLS FARGO CLEARING SERVICES, LLC 441 www.finra.org/brokercheck User Guidance 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: 08/30/2013 Case Number: 13-02508 Disputed Product Type: MUTUAL FUNDS Sum of All Relief Requested: $60,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/09/2015 Sum of All Relief Awarded: $60,545.10 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 198 of 296 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; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: FINRA Case Initiated: 10/11/2013 Case Number: 13-02910 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $11,923.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/25/2014 Sum of All Relief Awarded: $2,225.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 199 of 296

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; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 10/17/2013 Case Number: 13-03009 Disputed Product Type: PREFERRED STOCK Sum of All Relief Requested: $49,999.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/01/2014 Sum of All Relief Awarded: $49,999.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 200 of 296 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-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 11/21/2013 Case Number: 13-03327 Disputed Product Type: COLLATERALIZED DEBT OBLIGATIONS; COLLATERALIZED MORTGAGE OBLIGATIONS; COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/15/2015 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 443 www.finra.org/brokercheck User Guidance

Disposition Date: 12/15/2015 Sum of All Relief Awarded: $10,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 201 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: FINRA Case Initiated: 01/29/2014 Case Number: 14-00189 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $87,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/10/2015 Sum of All Relief Awarded: $94,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 202 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 03/27/2014 Case Number: 14-00455 Disputed Product Type: Sum of All Relief Requested: $24,000.00 Disposition: AWARD AGAINST PARTY

Disposition Date: 12/05/2014 Sum of All Relief Awarded: $866.14 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 203 of 296 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; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 05/21/2014 Case Number: 14-01404 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $300,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/19/2015 Sum of All Relief Awarded: $50,300.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 204 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; TRADING DISPUTES- OTHER Arbitration Forum: FINRA ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 445 www.finra.org/brokercheck User Guidance

Arbitration Forum: FINRA Case Initiated: 06/06/2014 Case Number: 14-01741 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $473,603.60 Disposition: AWARD AGAINST PARTY Disposition Date: 01/07/2016 Sum of All Relief Awarded: $346,881.41 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 205 of 296 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; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: FINRA Case Initiated: 10/21/2014 Case Number: 14-02593 Disputed Product Type: VARIABLE ANNUITIES Sum of All Relief Requested: $95,930.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/16/2015 Sum of All Relief Awarded: $3,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 206 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report aboutMISREPRESENTATION; WELLS FARGO CLEARING ACCOUNT SERVICES, ACTIVITY-OTHER;LLC ACCOUNT ACTIVITY- 446 SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 09/03/2014 Case Number: 14-02644 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 05/09/2016 Sum of All Relief Awarded: $113,607.87 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 207 of 296 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: 10/17/2014 Case Number: 14-02849 Disputed Product Type: MUTUAL FUNDS Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/31/2016 Sum of All Relief Awarded: $66,225.00 There may be a non-monetary award associated with this arbitration. ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 447 www.finra.org/brokercheck User Guidance

Please select the Case Number above to view more detailed information. i Disclosure 208 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED- OTHER; DO NOT USE-EXECUTIONS-EXECUTION PRICE; DO NOT USE- EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-EXECUTIONS-OTHER; TRADING DISPUTES-OTHER Arbitration Forum: FINRA Case Initiated: 10/21/2014 Case Number: 14-02953 Disputed Product Type: MUTUAL FUNDS Sum of All Relief Requested: $300,000.02 Disposition: AWARD AGAINST PARTY Disposition Date: 07/18/2016 Sum of All Relief Awarded: $363,514.24 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 209 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED- OTHER Arbitration Forum: FINRA Case Initiated: 01/13/2015 Case Number: 15-00074

Disputed Product Type: COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $342,077.89 Disposition: AWARD AGAINST PARTY Disposition Date: 06/16/2016 Sum of All Relief Awarded: $423,770.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 210 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 02/10/2015 Case Number: 15-00235 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 10/24/2016 Sum of All Relief Awarded: $5,987.76 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 211 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: Arbitration Forum: FINRA

Case Initiated: 07/20/2015 Case Number: 15-01676 Disputed Product Type: Sum of All Relief Requested: $275,000.01 Disposition: AWARD AGAINST PARTY Disposition Date: 09/12/2016 Sum of All Relief Awarded: $262,354.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 212 of 296 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-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT ACTIVITY- VIOLATE OF BLUE SKY LWS; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 08/28/2015 Case Number: 15-01842 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $100,000.01 Disposition: AWARD AGAINST PARTY Disposition Date: 08/02/2016 Sum of All Relief Awarded: $98,750.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 213 of 296 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 450 www.finra.org/brokercheck User Guidance

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 11/03/2015 Case Number: 15-02810 Disputed Product Type: Sum of All Relief Requested: $5,340,000.06 Disposition: AWARD AGAINST PARTY Disposition Date: 10/09/2018 Sum of All Relief Awarded: $860,000.08 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 214 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: Arbitration Forum: FINRA Case Initiated: 02/10/2016 Case Number: 16-00213 Disputed Product Type: Sum of All Relief Requested: $10,600.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/23/2016 Sum of All Relief Awarded: $212.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 215 of 296 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 451 www.finra.org/brokercheck User Guidance

Disclosure 215 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 05/04/2016 Case Number: 16-01066 Disputed Product Type: MUNICIPAL BONDS Sum of All Relief Requested: $8,025,000.02 Disposition: AWARD AGAINST PARTY Disposition Date: 07/19/2018 Sum of All Relief Awarded: $8,677,937.64 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 216 of 296 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 Arbitration Forum: FINRA Case Initiated: 05/03/2016 Case Number: 16-01123 Disputed Product Type: COMMON STOCK; LIMITED PARTNERSHIPS; MUTUAL FUNDS; REAL ESTATE INVESTMENT TRUST; STRUCTURED PRODUCTS Sum of All Relief Requested: $1,000,000.00 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 452 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $1,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/09/2017 Sum of All Relief Awarded: $357,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 217 of 296 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; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 07/20/2016 Case Number: 16-01810 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $150,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/26/2018 Sum of All Relief Awarded: $76,257.03 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 218 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 453 www.finra.org/brokercheck ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD; User Guidance ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 11/07/2016 Case Number: 16-02832 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $300,000.01 Disposition: AWARD AGAINST PARTY Disposition Date: 10/30/2018 Sum of All Relief Awarded: $360,800.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 219 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 01/24/2017 Case Number: 16-03388 Disputed Product Type: OTHER TYPES OF SECURITIES Sum of All Relief Requested: $155,699.49 Disposition: AWARD AGAINST PARTY Disposition Date: 09/25/2018 Sum of All Relief Awarded: $75,383.76 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 220 of 296 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 454 www.finra.org/brokercheck User Guidance

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 03/22/2017 Case Number: 17-00704 Disputed Product Type: Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/08/2017 Sum of All Relief Awarded: $50,600.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 221 of 296 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; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 06/07/2017 Case Number: 17-01426 Disputed Product Type: LIMITED PARTNERSHIPS Sum of All Relief Requested: $650,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/19/2019 Sum of All Relief Awarded: $936,600.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 222 of 296 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 455 www.finra.org/brokercheck User Guidance

Disclosure 222 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-VIOLATE OF BLUE SKY LWS; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-OTHER Arbitration Forum: FINRA Case Initiated: 06/21/2017 Case Number: 17-01621 Disputed Product Type: COMMON STOCK; OTHER TYPES OF SECURITIES; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/16/2018 Sum of All Relief Awarded: $70,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 223 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 07/07/2017 Case Number: 17-01786 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $125,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/26/2019 Sum of All Relief Awarded: $167,002.05

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 224 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: FINRA Case Initiated: 06/22/2018 Case Number: 18-02123 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $32,550.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/14/2019 Sum of All Relief Awarded: $4,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 225 of 296 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: FINRA Case Initiated: 09/19/2018 Case Number: 18-03250 Disputed Product Type: Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/08/2019 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 457 www.finra.org/brokercheck User Guidance

Disposition Date: 03/08/2019 Sum of All Relief Awarded: $50,600.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 226 of 296 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-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 09/28/2018 Case Number: 18-03398 Disputed Product Type: 401(K); COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $375,364.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/24/2020 Sum of All Relief Awarded: $54,532.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 227 of 296 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- UNAUTHORIZED TRADING; ACCOUNT ACTIVITY-VIOLATE OF BLUE SKY LWS; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 11/19/2018 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 458 www.finra.org/brokercheck User Guidance

Case Initiated: 11/19/2018 Case Number: 18-03891 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; EXCHANGE-TRADED FUNDS Sum of All Relief Requested: $40,851.40 Disposition: AWARD AGAINST PARTY Disposition Date: 08/19/2019 Sum of All Relief Awarded: $41,451.40 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 228 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 04/15/2019 Case Number: 19-01011 Disputed Product Type: COMMON STOCK; EXCHANGE-TRADED FUNDS; OPTIONS Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/30/2019 Sum of All Relief Awarded: $4,617.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 229 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ©2021 FINRA. All rights reserved. Report aboutRELATED-BREACH WELLS FARGO CLEARING OF CONTRACT; SERVICES, LLC ACCOUNT RELATED-FAILURE TO 459 SUPERVISE; ACCOUNT RELATED-NEGLIGENCE www.finra.org/brokercheck User Guidance ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 09/13/2019 Case Number: 19-02695 Disputed Product Type: 401(K); COMMON STOCK; EXCHANGE-TRADED FUNDS; MUNICIPAL BOND FUNDS; MUNICIPAL BONDS; MUTUAL FUNDS; OTHER TYPES OF SECURITIES; PREFERRED STOCK Sum of All Relief Requested: $65,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/11/2021 Sum of All Relief Awarded: $43,225.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 230 of 296 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: 01/01/1989 Case Number: 89-01661 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/11/1989 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 231 of 296 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 460 www.finra.org/brokercheck User Guidance

Disclosure 231 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-TRANSFER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/01/1990 Case Number: 90-00374 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $7,261.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/06/1990 Sum of All Relief Awarded: $2,547.25 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 232 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY- SUITABILITY Arbitration Forum: NASD Case Initiated: 05/15/1991 Case Number: 91-01469 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS Sum of All Relief Requested: $139,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/01/1992 Sum of All Relief Awarded: $31,833.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 233 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 08/09/1991 Case Number: 91-01908 Disputed Product Type: COMMON STOCK; CORPORATE BONDS; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $90,383.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/23/1992 Sum of All Relief Awarded: $20,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 234 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 01/21/1992 Case Number: 91-03839 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $45,906.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/21/1992 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 462 www.finra.org/brokercheck User Guidance

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 235 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/18/1992 Case Number: 92-01018 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS Sum of All Relief Requested: $9,800.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/29/1992 Sum of All Relief Awarded: $6,600.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 236 of 296 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: 04/28/1992 Case Number: 92-01252 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY

Disposition Date: 10/12/1992 Sum of All Relief Awarded: $20,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 237 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 05/06/1993 Case Number: 92-03851 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $30,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/16/1994 Sum of All Relief Awarded: $6,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 238 of 296 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: 04/22/1993 Case Number: 92-04217 Disputed Product Type: GINNIE MAES; GOVERNMENT SECURITIES; LIMITED PARTNERSHIPS; MUTUAL FUNDS

Sum of All Relief Requested: $45,240.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/28/1993 Sum of All Relief Awarded: $15,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 239 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 03/25/1993 Case Number: 93-00889 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $110,404.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/28/1994 Sum of All Relief Awarded: $110,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 240 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 04/29/1993 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 465 www.finra.org/brokercheck User Guidance

Case Initiated: 04/29/1993 Case Number: 93-00971 Disputed Product Type: ANNUITIES; COMMON STOCK; CORPORATE BONDS; MUNICIPAL BOND FUNDS Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/20/1994 Sum of All Relief Awarded: $98,159.63 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 241 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 05/10/1993 Case Number: 93-01849 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS; OPTIONS Sum of All Relief Requested: $680,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/09/1994 Sum of All Relief Awarded: $134,053.16 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 242 of 296 Reporting Source: Regulator Type of Event: ARBITRATION

©2021Allegations: FINRA. All rights reserved. Report aboutACCOUNT WELLS FARGO ACTIVITY-MISREPRESENTATION; CLEARING SERVICES, LLC ACCOUNT ACTIVITY- 466 SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/04/1994 Case Number: 93-04411 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: 11/30/1994 Sum of All Relief Awarded: $13,211.40 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 243 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 03/02/1994 Case Number: 94-00149 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $7,911.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/16/1995 Sum of All Relief Awarded: $810.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 244 of 296

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 04/14/1994 Case Number: 94-00197 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/31/1995 Sum of All Relief Awarded: $305,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 245 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/05/1994 Case Number: 94-01485 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $10,600.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/27/1995 Sum of All Relief Awarded: $10,600.00 There may be a non-monetary award associated with this arbitration.

Please select the Case Number above to view more detailed information. i Disclosure 246 of 296 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: 08/10/1994 Case Number: 94-02471 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/29/1996 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 247 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 07/19/1994 Case Number: 94-02529 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $425,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/10/1996 Sum of All Relief Awarded: $13,164.00 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 469 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $13,164.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 248 of 296 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: 08/17/1994 Case Number: 94-02866 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/21/1995 Sum of All Relief Awarded: $4,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 249 of 296 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: 09/15/1994 Case Number: 94-03482 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $106,689.75

Disposition: AWARD AGAINST PARTY Disposition Date: 06/28/1995 Sum of All Relief Awarded: $70,968.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 250 of 296 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: 11/09/1994 Case Number: 94-03639 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $425,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/02/1996 Sum of All Relief Awarded: $23,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 251 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/08/1994 Case Number: 94-03991

Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $23,375.85 Disposition: AWARD AGAINST PARTY Disposition Date: 12/07/1995 Sum of All Relief Awarded: $30,109.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 252 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/15/1994 Case Number: 94-04168 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $73,920.34 Disposition: AWARD AGAINST PARTY Disposition Date: 02/23/1996 Sum of All Relief Awarded: $22,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 253 of 296 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: 12/07/1994 Case Number: 94-04341 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS; MUTUAL FUNDS Sum of All Relief Requested: $8,397,312.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/16/1996 Sum of All Relief Awarded: $580,050.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 254 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/22/1994 Case Number: 94-04806 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,320.80 Disposition: AWARD AGAINST PARTY Disposition Date: 06/23/1995 Sum of All Relief Awarded: $1,182.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 255 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ©2021 FINRA. All rights reserved. Report aboutACCOUNT WELLS FARGO RELATED-NEGLIGENCE CLEARING SERVICES, LLC 473 www.finra.org/brokercheck User Guidance

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/11/1995 Case Number: 94-05052 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 10/13/1995 Sum of All Relief Awarded: $109,992.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 256 of 296 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: 12/14/1994 Case Number: 94-05072 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,030,911.72 Disposition: AWARD AGAINST PARTY Disposition Date: 07/15/1996 Sum of All Relief Awarded: $23,931.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 257 of 296 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 474 www.finra.org/brokercheck User Guidance

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: 02/10/1995 Case Number: 95-00161 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FANNIE MAE Sum of All Relief Requested: $3,005,642.14 Disposition: AWARD AGAINST PARTY Disposition Date: 08/01/1996 Sum of All Relief Awarded: $77,250.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 258 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/02/1995 Case Number: 95-00354 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $4,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/25/1995 Sum of All Relief Awarded: $2,714.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 259 of 296

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/29/1995 Case Number: 95-00571 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $40,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/22/1996 Sum of All Relief Awarded: $12,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 260 of 296 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: 02/21/1995 Case Number: 95-00735 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $272,841.56 Disposition: AWARD AGAINST PARTY Disposition Date: 05/04/1998 Sum of All Relief Awarded: $91,912.00

There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 261 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/07/1995 Case Number: 95-00874 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $2,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/20/1996 Sum of All Relief Awarded: $400,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 262 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/16/1995 Case Number: 95-01190 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/25/1995 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 477 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $662.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 263 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/16/1995 Case Number: 95-03876 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $3,852.25 Disposition: AWARD AGAINST PARTY Disposition Date: 02/14/1996 Sum of All Relief Awarded: $3,915.02 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 264 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/12/1995 Case Number: 95-04229 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $7,014.86 Disposition: AWARD AGAINST PARTY Disposition Date: 03/28/1996 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 478 www.finra.org/brokercheck User Guidance

Disposition Date: 03/28/1996 Sum of All Relief Awarded: $2,949.06 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 265 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 10/18/1995 Case Number: 95-04646 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $180,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/18/1997 Sum of All Relief Awarded: $77,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 266 of 296 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: 01/24/1996 Case Number: 96-00060 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS

Sum of All Relief Requested: $512,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/09/1997 Sum of All Relief Awarded: $287,130.75 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 267 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/29/1996 Case Number: 96-00347 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $402,490.80 Disposition: AWARD AGAINST PARTY Disposition Date: 05/06/1997 Sum of All Relief Awarded: $259,322.08 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 268 of 296 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: 02/09/1996

Case Number: 96-00589 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $121,462.50 Disposition: AWARD AGAINST PARTY Disposition Date: 09/09/1996 Sum of All Relief Awarded: $143,809.41 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 269 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/21/1996 Case Number: 96-00877 Disputed Product Type: 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: 03/31/1997 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 270 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE- EXECUTIONS-OTHER

Arbitration Forum: NASD Case Initiated: 03/08/1996 Case Number: 96-00885 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $53,500.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/28/1997 Sum of All Relief Awarded: $7,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 271 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE- EXECUTIONS-FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 04/11/1996 Case Number: 96-01455 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $45,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/09/1998 Sum of All Relief Awarded: $10,520.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 272 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report aboutMISREPRESENTATION; WELLS FARGO CLEARING ACCOUNT SERVICES, ACTIVITY-SUITABILITY;LLC ACCOUNT 482 RELATED-FAILURE TO SUPERVISE www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 03/21/1997 Case Number: 97-00915 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $772,105.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/03/1999 Sum of All Relief Awarded: $3,700.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 273 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 05/01/1997 Case Number: 97-02147 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $236,318.67 Disposition: AWARD AGAINST PARTY Disposition Date: 10/14/1997 Sum of All Relief Awarded: $76,721.69 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 274 of 296 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 483 www.finra.org/brokercheck User Guidance

Disclosure 274 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 07/31/1997 Case Number: 97-02255 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $2,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/08/1999 Sum of All Relief Awarded: $203,101.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 275 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED- FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 06/12/1997 Case Number: 97-02831 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $208,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/06/1998 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 276 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/16/1997 Case Number: 97-04296 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $27,012.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/15/1998 Sum of All Relief Awarded: $7,400.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 277 of 296 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: 10/02/1997 Case Number: 97-04300 Disputed Product Type: ANNUITIES; COMMON STOCK; GOVERNMENT SECURITIES; PREFERRED STOCK Sum of All Relief Requested: $311,607.53 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 485 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 03/29/1999 Sum of All Relief Awarded: $75,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 278 of 296 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: NASD Case Initiated: 04/15/1998 Case Number: 98-01192 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $169,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/19/1999 Sum of All Relief Awarded: $114,850.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 279 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 04/13/1998 Case Number: 98-01226 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 486 www.finra.org/brokercheck User Guidance

Case Number: 98-01226 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $5,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/22/1999 Sum of All Relief Awarded: $200,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 280 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 04/13/1998 Case Number: 98-01226 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $5,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/22/1999 Sum of All Relief Awarded: $200,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 281 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EMPLOYMENT-DISCRIMINATION AGE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; EMPLOYMENT-BREACH OF CONTRACT; ©2021 FINRA. All rights reserved. Report aboutEMPLOYMENT-COMPENSATION WELLS FARGO CLEARING SERVICES, LLC 487 www.finra.org/brokercheck User Guidance

Allegations: DO NOT USE-EMPLOYMENT-DISCRIMINATION AGE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; EMPLOYMENT-BREACH OF CONTRACT; EMPLOYMENT-COMPENSATION Arbitration Forum: NASD Case Initiated: 09/09/1998 Case Number: 98-03100 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,150,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/10/1999 Sum of All Relief Awarded: $117,610.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 282 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 12/11/1998 Case Number: 98-03452 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $1,100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/23/2001 Sum of All Relief Awarded: $65,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 283 of 296

Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 12/15/1998 Case Number: 98-04080 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $166,496.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/26/2000 Sum of All Relief Awarded: $54,969.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 284 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/30/1998 Case Number: 98-04168 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $5,538.63 Disposition: AWARD AGAINST PARTY Disposition Date: 07/16/1999 Sum of All Relief Awarded: $5,538.63 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 WELLS FARGO CLEARING SERVICES, LLC 489 www.finra.org/brokercheck User Guidance

i Disclosure 285 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED; UNKNOWN TYPE OF CONTROVERSIES Arbitration Forum: NASD Case Initiated: 03/10/1999 Case Number: 98-04822 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $84,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/09/2000 Sum of All Relief Awarded: $0.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 286 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 03/24/1999 Case Number: 99-00292 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $16,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/20/2002 ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 490 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $408,646.31 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 287 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 02/25/1999 Case Number: 99-00579 Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/04/2000 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 288 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED- BREACH OF CONTRACT Arbitration Forum: NASD Case Initiated: 05/21/1999 Case Number: 99-02222 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS; OPTIONS Sum of All Relief Requested: $650,000.00

Disposition: AWARD AGAINST PARTY Disposition Date: 09/07/2000 Sum of All Relief Awarded: $31,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 289 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/11/1999 Case Number: 99-02526 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $148,061.41 Disposition: AWARD AGAINST PARTY Disposition Date: 07/16/2001 Sum of All Relief Awarded: $21,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 290 of 296 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: 08/26/1999 Case Number: 99-03288

©2021Disputed FINRA. Product All rights Type:reserved. Report aboutCORPORATE WELLS FARGO BONDS; CLEARING DO SERVICES,NOT USE-NO LLC OTHER TYPE OF SEC INVOLVE 492 www.finra.org/brokercheck User Guidance

Disputed Product Type: CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $59,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/25/2000 Sum of All Relief Awarded: $30,210.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 291 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/12/1999 Case Number: 99-03729 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $537,501.66 Disposition: AWARD AGAINST PARTY Disposition Date: 12/21/2000 Sum of All Relief Awarded: $221,954.03 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 292 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 493 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 09/22/1999 Case Number: 99-03778 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $1,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/03/2001 Sum of All Relief Awarded: $10,041.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 293 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/14/1999 Case Number: 99-04019 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $98,325.16 Disposition: AWARD AGAINST PARTY Disposition Date: 04/24/2002 Sum of All Relief Awarded: $40,990.18 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 294 of 296 Reporting Source: Regulator Type of Event: ARBITRATION ©2021 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC 494 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 11/15/1999 Case Number: 99-04914 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $54,870.65 Disposition: AWARD AGAINST PARTY Disposition Date: 11/30/2000 Sum of All Relief Awarded: $9,220.43 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 295 of 296 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 01/18/2000 Case Number: 99-04915 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS; WARRANTS/RIGHTS Sum of All Relief Requested: $2,817,745.86 Disposition: AWARD AGAINST PARTY Disposition Date: 10/23/2001 Sum of All Relief Awarded: $376,334.82 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i

Disclosure 296 of 296 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: 01/31/2000 Case Number: 99-05550 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $6,319.05 Disposition: AWARD AGAINST PARTY Disposition Date: 10/24/2000 Sum of All Relief Awarded: $5,221.33 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

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