J.P. Morgan Securities Inc. Crd# 18718

BrokerCheck Report J.P. MORGAN SECURITIES INC. CRD# 18718

Section Title Page(s) Report Summary 1

Registration and Withdrawal 2

Firm Profile 3 - 10

Firm History 11

Firm Operations 12 - 77

Disclosure Events 78

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©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 1 www.finra.org/brokercheck User Guidance Registration Withdrawal Information This section provides information relating to the date the brokerage firm ceased doing business and the firm's financial obligations to customers or other brokerage firms.

This firm terminated or 10/01/2008 withdrew registration on:

Does this brokerage firm owe No any money or securities to any customer or brokerage firm?

This firm is classified as a corporation. This firm was formed in Delaware on 09/10/1986. 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.

J.P. MORGAN SECURITIES INC. Doing business as J.P. MORGAN SECURITIES INC. CRD# 18718 SEC# 8-36950

Main Office Location 270/277 PARK AVENUE NEW YORK, NY 10017-2014

Mailing Address 570 WASHINGTON BOULEVARD 12TH FLOOR JERSEY CITY, NJ 07310

Business Telephone Number 212-270-6000

Other Names of this Firm

Name Where is it used CHASE H&Q AK, AR, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VA, VT, WA, WI, WV, WY JPMORGAN AK, AR, AZ, CA, CO, CT, DC, DE, FL, GA, ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. HI, IA, ID, IL, IN, KS, 3 KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VA, VT, WA, WI, WV, WY www.finra.org/brokercheckJPMORGAN AK, AR, AZ, CA, CO, User Guidance CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VA, VT, WA, WI, WV, WY JPMORGAN & CO. AK, AR, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VA, VT, WA, WI, WV, WY JPMORGAN H&Q AK, AR, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VA, VT, WA, WI, WV, WY

©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 4 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): JPMORGAN SECURITIES HOLDINGS LLC Is this a domestic or foreign Domestic Entity entity or an individual?

Position DIRECTLY OWNS 100% OF J.P. MORGAN SECURITIES INC. Position Start Date 12/2001 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): BLACK, STEVEN DAVIS 801694 Is this a domestic or foreign Individual entity or an individual?

Position CEO, CHAIRPERSON, DIRECTOR, MANAGING DIRECTOR Position Start Date 06/2008 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): BLESER, PHILIP FRANCIS 4506044 Is this a domestic or foreign Individual entity or an individual?

Position DIRECTOR Position Start Date 06/2008 Percentage of Ownership Less than 5% ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 5 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): BRAUNSTEIN, DOUGLAS LEE 1542814 Is this a domestic or foreign Individual entity or an individual?

Position DIRECTOR AND MANAGING DIRECTOR Position Start Date 07/2005 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): COLLINS, JAMES MICHAEL 2725065 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF FINANCIAL OFFICER AND SR. MANAGING DIRECTOR Position Start Date 06/2008 Percentage of Ownership Less than 5% Does this owner direct the No management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): ERDOES, MARY ELIZABETH

Direct Owners and Executive Officers (continued) 2502095 Is this a domestic or foreign Individual entity or an individual?

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

Is this a public reporting No company?

Legal Name & CRD# (if any): FITZGERALD, LISA JOAN 1542376 Is this a domestic or foreign Individual entity or an individual?

Position TREASURER AND MANAGING DIRECTOR Position Start Date 06/2008 Percentage of Ownership Less than 5% Does this owner direct the No management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): GENOVA, DIANE M 5558897 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF LEGAL OFFICER AND MANAGING DIRECTOR Position Start Date 06/2008 Percentage of Ownership Less than 5% Does this owner direct the No management or policies of the©2021 firm? FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 7 www.finra.org/brokercheck User Guidance Firm Profile

Direct Owners and Executive Officers (continued) Does this owner direct the No management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): HERNANDEZ, CARLOS M 2647255 Is this a domestic or foreign Individual entity or an individual?

Position PRESIDENT, DIRECTOR, MANAGING DIRECTOR Position Start Date 04/2006 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): HORAN, ANTHONY JAMES 1970798 Is this a domestic or foreign Individual entity or an individual?

Position SECRETARY AND SR. VICE PRESIDENT Position Start Date 06/2008 Percentage of Ownership Less than 5% Does this owner direct the No management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): JOHNSON, GREGORY JUDE 2611617

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

Position CHIEF COMPLIANCE OFFICER, DIRECTOR OF COMPLIANCE, MANAGING DIRECTOR Position Start Date 04/2006 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): SULLIVAN, MARGARET MARY 1940830 Is this a domestic or foreign Individual entity or an individual?

Position DIRECTOR, CHIEF OPERATIONS OFFICER, EXECUTIVE DIRECTOR Position Start Date 10/2004 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 J.P. MORGAN SECURITIES INC. 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): JPMORGAN CHASE & CO. Is this a domestic or foreign Domestic Entity entity or an individual?

Company through which JPMORGAN SECURITIES HOLDINGS LLC (OWNS 100% OF J.P. MORGAN indirect ownership is SECURITIES INC.) established Relationship to Direct Owner ULTIMATE PARENT COMPANY OWNS 100% OF JPMORGAN SECURITIES HOLDINGS LLC Relationship Established 05/2001 Percentage of Ownership 75% or more Does this owner direct the Yes management or policies of the firm? Is this a public reporting Yes company?

©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 10 www.finra.org/brokercheck User Guidance Firm History This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

This firm was previously: HAMBRECHT & QUIST LLC Date of Succession: 02/01/2000 Predecessor CRD#: 940 Predecessor SEC#: 8-29123 Description AGREEMENT OF MERGER - ASSUMPTION OF ALL ASSETS AND LIABILITIES.

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 no longer registered. The firm's registration was from 04/23/1987 to 06/10/2009.

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 16 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) U S. government securities dealer U S. government securities broker Municipal securities dealer Municipal securities broker Put and call broker or dealer or option writer Investment advisory services Trading securities for own account Private placements of securities Broker or dealer selling interests in mortgages or other receivables Other - BROKER AND DEALER IN BANKERS ACCEPTANCES, CERTIFICATES OF DEPOSIT, AND OTHER MONEY MARKET INSTRUMENTS.

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: LOAN PARTICIPATIONS, CREDIT DERIVATIVES, STRUCTURED CREDIT PRODUCTS, BANK LOAN SYNDICATION.

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: PERSHING TRADING COMPANY, L.P. CRD #: 36671 Business Address: ONE PERSHING PLAZA JERSEY CITY, NJ 07399-0002 Effective Date: 08/07/1989 Description: FULLY DISCLOSED CLEARING AGREEMENT.

Name: NATIONAL FINANCIAL SERVICES CORPORATION CRD #: 13041 Business Address: 260 FRANKLIN STREET, L17C BOSTON, MA 02109 Effective Date: 11/09/1989 Description: FULLY DISCLOSED CLEARING AGREEMENT.

This firm does have books or records maintained by a third party. Name: GOLDMAN, SACHS & CO. CRD #: 361 Business Address: 85 BROAD STREET NEW YORK, NY 10004 Effective Date: 02/04/1998 Description: PRIME BROKER AGREEMENT.

This firm does have accounts, funds, or securities maintained by a third party. Name: GOLDMAN, SACHS & CO. CRD #: 361 Business Address: 85 BROAD STREET NEW YORK, NY 10004 Effective Date: 02/04/1998 Description: PRIME BROKER AGREEMENT.

This firm does have customer accounts, funds, or securities maintained by a third party. Name: GOLDMAN, SACHS & CO. CRD #: 361 Business Address: 85 BROAD STREET NEW YORK, NY 10004 Effective Date: 02/04/1998 Description: PRIME BROKER AGREEMENT.

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. BEAR STEARNS PRIVATE EQUITY OPPORTUNITY FUND II, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS FOF ASSET MANAGEMENT LLC is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS HEALTH INNOVENTURES, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE ©2021 FINRA. All rights reserved. Report aboutNEW J.P. YORK, MORGAN NY SECURITIES 10179 INC. 16 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS EQUITY FINANCE CAYMAN, LTD. is under common control with the firm. Business Address: C/O MAPLES & CALDER PO BOX 309, UGLAND HOUSE GEORGE TOWN, GRAND CAYMAN, CAYMAN ISLANDS Effective Date: 04/08/2008 Foreign Entity: Yes Country: CAYMAN ISLANDS Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

NORTH CREEK PARTNERS LLC is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 17 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

LYNX CAPITAL VENTURES GP LIMITED is under common control with the firm. Business Address: ONE CANADA SQUARE LONDON E14 5AD, ENGLAND Effective Date: 04/08/2008 Foreign Entity: Yes Country: UNITED KINGDOM Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

LYNX CAPITAL VENTURES LP is under common control with the firm. Business Address: 45 OLD BOND STREET 4TH FLOOR LONDON W1, ENGLAND Effective Date: 04/08/2008 Foreign Entity: Yes Country: UNITED KINGDOM Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BSCGP INC. is under common control with the firm. Business Address: 245 PARK AVENUE NEW YORK, NY 10167-0024 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: No ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 18 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

MIGDAL CAPITAL MARKETS (1965) LTD. is under common control with the firm. Business Address: 28 ACHAD HA'AM STREET TEL-AVIV, ISRAEL Effective Date: 04/08/2008 Foreign Entity: Yes Country: ISRAEL Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS ASSET MANAGEMENT LIMITED is under common control with the firm. Business Address: ONE CANADA SQUARE LONDON E 14, 5AD, ENGLAND Effective Date: 04/08/2008 Foreign Entity: Yes Country: UNITED KINGDOM Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS ALTERNATIVE ASSETS INTERNATIONAL LIMITED is under common control with the firm. Business Address: C/O MAPLES & CALDER PO BOX 309 GEORGE TOWN, GRAND CAYMAN, CAYMAN ISLANDS Effective Date: 04/08/2008

Organization Affiliates (continued)

Foreign Entity: Yes Country: CAYMAN ISLANDS Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS ALTERNATIVE ASSETS INC. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS VENTURES MANAGEMENT LLC is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS PRIVATE OPPORTUNITY VENTURES MANAGEMENT LLC is under common control with the firm.

Organization Affiliates (continued)

Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS MERCHANT GP II, LLC is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS MERCHANT CAPITAL II, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 21 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS UK HOLDINGS LIMITED is under common control with the firm. Business Address: ONE CANADA SQUARE LONDON E14 5AD, ENGLAND Effective Date: 04/08/2008 Foreign Entity: Yes Country: UNITED KINGDOM Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS TRADING RISK MANAGEMENT INC. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

THE BSC EMPLOYEE FUND IV, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities:©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 22 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

THE BSC EMPLOYEE FUND III, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS N.Y., INC. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS MERCHANT MANAGER II, LLC is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No

Organization Affiliates (continued)

Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS MERCHANT BANKING INVESTORS II, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS MERCHANT BANKING PARTNERS II, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS MB-PSERS II, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179

Organization Affiliates (continued)

Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

LYNX NEW MEDIA VENTURES GP A LIMITED is under common control with the firm. Business Address: 45 OLD BOND STREET, 4TH FLOOR LONDON W1, ENGLAND Effective Date: 04/08/2008 Foreign Entity: Yes Country: UNITED KINGDOM Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

LYNX NEW MEDIA VENTURES LP is under common control with the firm. Business Address: 45 OLD BOND STREET, 4TH FLOOR LONDON W1, ENGLAND Effective Date: 04/08/2008 Foreign Entity: Yes Country: UNITED KINGDOM Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

Organization Affiliates (continued)

BEAR STEARNS IRELAND LIMITED is under common control with the firm. Business Address: BLOCK 8, HARCOURT CENTRE CHARLOTTE WAY, DUBLIN 2, IRELAND Effective Date: 04/08/2008 Foreign Entity: Yes Country: IRELAND Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS HEALTH INNOVENTURES OFFSHORE, L.P. is under common control with the firm. Business Address: C/O MAPLES & CALDER PO BOX 309, UGLAND HOUSE, SOUTH CHURCH STREET GEORGE TOWN, GRAND CAYMAN, CAYMAN ISLANDS Effective Date: 04/08/2008 Foreign Entity: Yes Country: CAYMAN ISLANDS Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS HEALTH INNOVENTURES MANAGEMENT LLC is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities:©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 26 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS HEALTH INNOVENTURES EMPLOYEE FUND, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS GLOBAL EQUITY ARBITRAGE FUND OFFSHORE LTD. is under common control with the firm. Business Address: C/O CITCO FUND SERVICES (CAYMAN ISLANDS) LIMITED PO BOX 31106 SMB WEST BAY ROAD, GRAND CAYMAN, CAYMAN ISLANDS Effective Date: 04/08/2008 Foreign Entity: Yes Country: CAYMAN ISLANDS Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

CONSTELLATION VENTURE CAPITAL OFFSHORE II, L.P. is under common control with the firm. Business Address: C/O MAPLES & CALDER PO BOX 309 GEORGE TOWN, GRAND CAYMAN, CAYMAN ISLANDS

Organization Affiliates (continued)

Effective Date: 04/08/2008 Foreign Entity: Yes Country: CAYMAN ISLANDS Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS FINANCIAL PRODUCTS INC. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

CONSTELLATION VENTURES MANAGEMENT II, LLC is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

Organization Affiliates (continued)

BSTJ, INC. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

THE BSC EMPLOYEE FUND II, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS VENTURE PARTNERS, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 29 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS PRINCIPAL PROTECTED FUNDING, LTD. is under common control with the firm. Business Address: C/O MAPLES & CALDER, UGLAND HOUSE PO BOX 309 GEORGE TOWN, GRAND CAYMAN, CAYMAN ISLANDS Effective Date: 04/08/2008 Foreign Entity: Yes Country: CAYMAN ISLANDS Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS PRIVATE OPPORTUNITY VENTURES, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS GLOBAL EQUITY ARBITRAGE FUND, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country:

Organization Affiliates (continued)

Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

CONSTELLATION VENTURE CAPITAL II, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS SINGAPORE PTE. LIMITED is under common control with the firm. Business Address: 30 RAFFLES PLACE #21-00 CALTEX HOUSE, SINGAPORE 048622 Effective Date: 04/08/2008 Foreign Entity: Yes Country: SINGAPORE Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS (JAPAN), LTD. is under common control with the firm. Business Address: SHIROYAMA HILLS 3-1 TORANOMON 4-CHOME MINATO-KU, TOKYO, JAPAN Effective Date: 04/08/2008 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 31 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS ASIA LIMITED is under common control with the firm. Business Address: CITBANK TOWER, CITIBANK PLAZA 26TH FLOOR, 3 GARDEN ROAD HONG KONG, HONG KONG Effective Date: 04/08/2008 Foreign Entity: Yes Country: HONG KONG Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS HONG KONG LIMITED is under common control with the firm. Business Address: CITIBANK TOWER, CITIBANK PLAZA 26TH FLOOR, 3 GARDEN ROAD HONG KONG, HONG KONG Effective Date: 04/08/2008 Foreign Entity: Yes Country: HONG KONG Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 32 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

NEW CASTLE MILLENNIUM II, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

NEW CASTLE MILLENNIUM, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

NEW CASTLE PARTNERS, LLC is under common control with the firm. Business Address: C/O MAPLES & CALDER, UGLAND HOUSE PO BOX 309 GEORGE TOWN, GRAND CAYMAN, CAYMAN ISLANDS Effective Date: 04/08/2008 Foreign Entity: Yes Country: CAYMAN ISLANDS Securities Activities: Yes Investment Advisory No Activities:©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 33 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

NEW CASTLE MARKET NEUTRAL OFFSHORE LIMITED is under common control with the firm. Business Address: REID HOUSE, 31 CHURCH STREET HAMILTON HM 12, BERMUDA Effective Date: 04/08/2008 Foreign Entity: Yes Country: BERMUDA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

NEW CASTLE MARKET NEUTRAL FUND, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

NEW CASTLE HOLDING, INC. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No

Organization Affiliates (continued)

Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR, STEARNS INTERNATIONAL LIMITED is under common control with the firm. Business Address: ONE CANADA SQUARE LONDON E14 5AD, ENGLAND Effective Date: 04/08/2008 Foreign Entity: Yes Country: UNITED KINGDOM Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS INTERNATIONAL TRADING LIMITED is under common control with the firm. Business Address: ONE CANADA SQUARE LONDON E14 5AD, ENGLAND Effective Date: 04/08/2008 Foreign Entity: Yes Country: UNITED KINGDOM Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS INVESTMENT PRODUCTS INC. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179

Organization Affiliates (continued)

Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

CONSTELLATION VENTURE CAPITAL OFFSHORE, L.P. is under common control with the firm. Business Address: C/O MAPLES & CALDER, UGLAND HOUSE PO BOX 309 GEORGE TOWN, GRAND CAYMAN, CAYMAN ISLANDS Effective Date: 04/08/2008 Foreign Entity: Yes Country: CAYMAN ISLANDS Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

CONSTELLATION VENTURE CAPITAL, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

Organization Affiliates (continued)

CONSTELLATION VENTURES MANAGEMENT LLC is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS CAPITAL MARKETS INC. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS ASSET MANAGEMENT (IRELAND) LIMITED is under common control with the firm. Business Address: BLOCK 8 HARCOURT CENTRE CHARLOTTE WAY, DUBLIN 2, IRELAND Effective Date: 04/08/2008 Foreign Entity: Yes Country: IRELAND Securities Activities: Yes Investment Advisory No Activities: ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 37 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS BANK PLC is under common control with the firm. Business Address: BLOCK 8 HARCOURT CENTRE CHARLOTTE WAY, DUBLIN 2, IRELAND Effective Date: 04/08/2008 Foreign Entity: Yes Country: IRELAND Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BS FUND AMERICA 1933-C GP CAPITAL INC. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

THE BSC EMPLOYEE FUND L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 38 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

THE BEAR STEARNS FUNDS is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS PRIVATE EQUITY OPPORTUNITY FUND, L.P. is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS FOF II ASSET MANAGEMENT LLC is under common control with the firm. Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008

Organization Affiliates (continued)

Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS ASSET MANAGEMENT (LUXEMBOURG) S.A. is under common control with the firm. Business Address: 39 ALLEE SCHEFFER L-2250 LUXEMBOURG, LUXEMBOURG Effective Date: 04/08/2008 Foreign Entity: Yes Country: LUXEMBOURG Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR WAGNER SPECIALISTS LLC is under common control with the firm. CRD #: 32691 Business Address: 40 WALL STREET, 42ND FLOOR NEW YORK, NY 10005 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

Organization Affiliates (continued)

BEAR, STEARNS SECURITIES CORP. is under common control with the firm. CRD #: 28432 Business Address: ONE METROTECH CENTER NORTH BROOKLYN, NY 11201-3859 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR, STEARNS & CO. INC. is under common control with the firm. CRD #: 79 Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

BEAR STEARNS ASSET MANAGEMENT INC is under common control with the firm. CRD #: 113359 Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 41 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

CAMILLA ASSET MANAGEMENT, LP is under common control with the firm. CRD #: 114927 Business Address: C/O BEAR, STEARNS & CO. INC. 300 CRESCENT COURT, SUITE 200 DALLAS, TX 75201 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

MADISON VANDERBILT MANAGEMENT LLC is under common control with the firm. CRD #: 121839 Business Address: 383 MADISON AVENUE NEW YORK, NY 10179 Effective Date: 04/08/2008 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JP MORGAN CHASE & CO.

Organization Affiliates (continued)

IXE SECURITIES, INC. is under common control with the firm. CRD #: 19920 Business Address: 140 EAST 45TH STREET 2ND FLOOR NEW YORK, NY 10017 Effective Date: 09/07/2007 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT - JPMORGAN CHASE & CO.

JPMORGAN SECURITIES JAPAN CO. LTD. is under common control with the firm. Business Address: TOKYO BUILDING 7-3 MARUNOUCHI 2 CHOME CHIYODA-KU TOKYO, JAPAN 100 6432 Effective Date: 04/10/2002 Foreign Entity: Yes Country: JAPAN Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT - JPMORGAN CHASE & CO.

JPMCB NY BRANCH (GLAS) - MUMBAI is under common control with the firm. Business Address: 9/F, MAFATLAL CENTRE NARIMAN POINT MUMBAI, INDIA 400021 Effective Date: 08/09/1994 Foreign Entity: Yes Country: INDIA

Organization Affiliates (continued)

Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN SECURITIES (MALAYSIA) SDN. BHD is under common control with the firm. Business Address: 22/F, WISMA CYCLECARRI 288 JALAN RAJA LAUT 53050 KUALA LUMPUR, MALAYSIA Effective Date: 04/03/1974 Foreign Entity: Yes Country: MALAYSIA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

CAZENOVE AG is under common control with the firm. Business Address: BOERSENSTRASSE 2-4 D-60313 FRANKFURT AM MAIN D-60313 FRANKFURT, GERMANY Effective Date: 11/29/2001 Foreign Entity: Yes Country: GERMANY Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN ASSET MANAGEMENT (IRELAND) LIMITED is under common control with the firm. Business Address: CRAMPTON AVE/SHERBOURNE ROAD CO. NO. 359401, BALLSBRIDGE ©2021 FINRA. All rights reserved. Report aboutDUBLIN, J.P. MORGAN REPUBLIC SECURITIES OF IRELAND INC. 44 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)CRAMPTON AVE/SHERBOURNE ROAD CO. NO. 359401, BALLSBRIDGE DUBLIN, REPUBLIC OF IRELAND Effective Date: 07/18/2002 Foreign Entity: Yes Country: REPUBLIC OF IRELAND Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN TRUST COMPANY (BAHAMAS) LIMITED is under common control with the firm. Business Address: P.O. BOX N-4899 NASSAU, BAHAMAS Effective Date: 12/02/1983 Foreign Entity: Yes Country: BAHAMAS Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN TRUST COMPANY OF DELAWARE is under common control with the firm. Business Address: 500 STANTON CHRISTIANA ROAD NEWARK, DE 19713 Effective Date: 01/25/1994 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

Organization Affiliates (continued) Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN TRUST BANK LIMITED is under common control with the firm. Business Address: AKASAKA PARK BUILDING 2-20 AKASAKA 5-CHOME MINATO-KU TOKYO, JAPAN Effective Date: 10/16/1985 Foreign Entity: Yes Country: JAPAN Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN MARKETS AUSTRALIA PTY LIMITED is under common control with the firm. Business Address: LEVEL 32, GROSVENOR PLACE 225 GEORGE STREET SYDNEY, NSW, AUSTRALIA 2000 Effective Date: 07/29/1957 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN INVESTMENT MANAGEMENT LIMITED is under common control with the firm. Business Address: 125 LONDON WALL LONDON, UNITED KINGDOM Effective Date: 04/28/2000 Foreign Entity: Yes Country: UNITED KINGDOM

Organization Affiliates (continued)

Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN GESTION SOCIEDAD GESTORA DE INSTITUCIONES DE INVERSION COLECTIVA S.A. is under common control with the firm. Business Address: JOSE ORTEGA Y GASSET, 29 2ND FLOOR MADRID, SPAIN 28006 Effective Date: 02/05/1987 Foreign Entity: Yes Country: SPAIN Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN CAZENOVE LIMITED is under common control with the firm. Business Address: 20 MOORGATE LONDON LONDON, UNITED KINGDOM Effective Date: 02/02/2001 Foreign Entity: Yes Country: UNITED KINGDOM Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JF TAIWAN LIMITED is under common control with the firm. Business Address: 22ND FLOOR, #285, 287, 289, 291 & 293 WEN HWA ROAD 24TH FLOOR, #285, 287 & 289 WEN HWA RD, SECTION 2 ©2021 FINRA. All rights reserved. Report aboutPAN J.P.CHIAO MORGAN CITY, SECURITIES TAIPEI, TAIWAN INC. 47 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)22ND FLOOR, #285, 287, 289, 291 & 293 WEN HWA ROAD 24TH FLOOR, #285, 287 & 289 WEN HWA RD, SECTION 2 PAN CHIAO CITY, TAIPEI, TAIWAN Effective Date: 08/28/1985 Foreign Entity: Yes Country: TAIWAN Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JF MANAGEMENT GP LIMITED is under common control with the firm. Business Address: P.O. BOX 309 GRAND CAYMAN CAYMAN ISLANDS GEORGETOWN, CAYMAN ISLANDS, BWI Effective Date: 02/27/1996 Foreign Entity: Yes Country: CAYMAN ISLANDS, BWI Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JF INDIA MANAGEMENT LIMITED is under common control with the firm. Business Address: PALM GROVE HOUSE P.O. BOX 438 ROAD TOWN TORTOLA, BRITISH VIRGIN ISLANDS Effective Date: 07/18/1989 Foreign Entity: Yes Country: BRITISH VIRGIN ISLANDS Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 48 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JF CAPITAL PARTNERS LTD is under common control with the firm. Business Address: LEVEL 23, 600 BOURKE STREET MELBOURNE, VICTORIA, AUSTRALIA 3000 Effective Date: 12/02/1998 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

H&Q LONDON VENTURES MANAGEMENT INC. is under common control with the firm. Business Address: 560 MISSION STREET SAN FRANCISCO, CA 94105 Effective Date: 08/05/1996 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

CHINA INTERNATIONAL FUND MANAGEMENT CO. LTD. is under common control with the firm. Business Address: 20TH FLOOR, AURORA BUILDING 99 FU CHENG ROAD SHANGHAI, CHINA 200120 Effective Date: 05/12/2004 Foreign Entity: Yes Country: CHINA Securities Activities: No ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 49 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

CAZENOVE & CO. (SINGAPORE) PTE LIMITED is under common control with the firm. Business Address: 9 RAFFLES PLACE #52-01 REPUBLIC PLAZA SINGAPORE, SINGAPORE 048619 Effective Date: 02/07/1990 Foreign Entity: Yes Country: SINGAPORE Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

CAZENOVE ASIA LIMITED is under common control with the firm. Business Address: 5001, ONE EXCHANGE SQUARE, 8 CONNAUGHT PLACE CENTRAL HONG KONG HONG KONG, HONG KONG Effective Date: 11/17/1981 Foreign Entity: Yes Country: HONG KONG Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

BANCO J.P. MORGAN S.A. INSTITUCION DE BANCA MULTIPLE J.P. MORGAN GROUPO FINANCIERO is under common control with the firm. Business Address: PASEO DE LA PALMAS NO 405, 16TH FLOOR LOMAS DE CHAPULTEPEC 11000 MEXICO D.F. ©2021 FINRA. All rights reserved. Report aboutMEXICO J.P. MORGAN CITY, MEXICO SECURITIES INC. 50 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)PASEO DE LA PALMAS NO 405, 16TH FLOOR LOMAS DE CHAPULTEPEC 11000 MEXICO D.F. MEXICO CITY, MEXICO Effective Date: 12/05/1994 Foreign Entity: Yes Country: MEXICO Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN SOLUTIONS LLC is under common control with the firm. Business Address: 277 PARK AVENUE NEW YORK, NY 10172 Effective Date: 12/05/2005 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

HIGHBRIDGE CAPITAL MANAGEMENT, LLC is under common control with the firm. CRD #: 134776 Business Address: 9 WEST 57TH STREET 26TH FLOOR NEW YORK, NY 10019 Effective Date: 12/13/2004 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities:

Description:©2021 FINRA. All rights reserved. Report aboutHIGHBRIDGE J.P. MORGAN CAPITAL SECURITIES MANAGEMENT, INC. LLC (HCM,LLC) IS THE TRADING 51 MANAGER OF HIGHBRIDGE CAPITAL CORPORATION. AS OF 12/13/2004, HCM,LLC IS MAJORITY OWNED BY J.P. MORGAN FLEMING ASSET MANAGEMENT HOLDINGS, INC., A WHOLLY-OWNED SUBSIDIARY OF JPMORGAN CHASE & CO. AND MINORITY OWNED BY DUBIN & SWIECA ASSET MANAGEMENT, LLC ("DSAM,LLC"). DSAM,LLC IS A WHOLLY OWNED SUBSIDIARY OF DUBIN & SWIECA ASSET MANAGEMENT, INC. DSAM,LLC IS WHOLLY OWNED BY MSSRS. DUBIN & SWIECA. www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Description: HIGHBRIDGE CAPITAL MANAGEMENT, LLC (HCM,LLC) IS THE TRADING MANAGER OF HIGHBRIDGE CAPITAL CORPORATION. AS OF 12/13/2004, HCM,LLC IS MAJORITY OWNED BY J.P. MORGAN FLEMING ASSET MANAGEMENT HOLDINGS, INC., A WHOLLY-OWNED SUBSIDIARY OF JPMORGAN CHASE & CO. AND MINORITY OWNED BY DUBIN & SWIECA ASSET MANAGEMENT, LLC ("DSAM,LLC"). DSAM,LLC IS A WHOLLY OWNED SUBSIDIARY OF DUBIN & SWIECA ASSET MANAGEMENT, INC. DSAM,LLC IS WHOLLY OWNED BY MSSRS. DUBIN & SWIECA.

J.P. MORGAN SECURITIES LTD. is under common control with the firm. Business Address: 125 LONDON WALL LONDON, ENGLAND EC2Y 5AJ Effective Date: 01/02/2001 Foreign Entity: Yes Country: ENGLAND Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN INVESTMENT ADVISORS INC. is under common control with the firm. Business Address: 1111 POLARIS PARKWAY COLUMBUS, OH 43240 Effective Date: 07/01/2004 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

SECURITY CAPITAL RESEARCH & MANAGEMENT INCORPORATED is under common control with the firm. CRD #: 106201 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 52 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) CRD #: 106201 Business Address: 10 SOUTH DEARBORN STREET SUITE 1400 CHICAGO, IL 60603 Effective Date: 07/01/2004 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN DISTRIBUTION SERVICES, INC. is under common control with the firm. CRD #: 104234 Business Address: 245 PARK AVENUE NEW YORK, NY 10167 Effective Date: 07/01/2004 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN CORRETORA DE CAMBIO E VALORES MOBILIARIOS S.A. is under common control with the firm. Business Address: AVENIDA BRIGADEIRO FARIA LIMA 3729 14TH FLOOR - PARTE ITAIM BIBI SAO PAULO, BRAZIL 00000 Effective Date: 03/27/1989 Foreign Entity: Yes Country: BRAZIL Securities Activities: Yes ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 53 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN SOCIEDAD DE VALORES S.A. is under common control with the firm. Business Address: JOSE ORTEGA Y GASSET, 29 2ND FLOOR MADRID, SPAIN 28006 Effective Date: 07/19/1989 Foreign Entity: Yes Country: SPAIN Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN ASSET MANAGEMENT SOCIETA DI GESTIONE DEL RISPARMIO SPA is under common control with the firm. Business Address: VIA CATENA 4 MILAN, ITLAY 20121 Effective Date: 03/05/2005 Foreign Entity: Yes Country: ITLAY Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN FUTURES INC. is under common control with the firm. Business Address: 270 PARK AVENUE NEW YORK, NY 10017 Effective Date: 05/31/1989 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 54 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Effective Date: 05/31/1989 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN LATIN AMERICA MANAGEMENT COMPANY LLC is under common control with the firm. Business Address: 1221 AVENUE OF THE AMERICAS NEW YORK, NY 10020 Effective Date: 02/18/2000 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN PRIVATE INVESTMENTS INC. is under common control with the firm. Business Address: 345 PARK AVENUE NEW YORK, NY 10154-1002 Effective Date: 11/25/1991 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

Organization Affiliates (continued)

JFAM SECURITIES TAIWAN LIMITED is under common control with the firm. Business Address: B1-1, 17F NO. 71 SECTION 2 TUN HWA SOUTH ROAD TAIPEI, TAIWAN 00000 Effective Date: 05/01/2005 Foreign Entity: Yes Country: TAIWAN Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN PARTNERS, LLC is under common control with the firm. Business Address: 1221 AVENUE OF THE AMERICAS NEW YORK, NY 10020 Effective Date: 10/11/2000 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

SIXTY WALL STREET INVESTMENT CORPORATION is under common control with the firm. Business Address: 1221 AVENUE OF THE AMERICAS 39TH FLOOR NEW YORK, NY 10020 Effective Date: 04/03/2002 Foreign Entity: No Country: Securities Activities: No

Organization Affiliates (continued)

Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

SIXTY WALL STREET MANAGEMENT COMPANY LLC is under common control with the firm. Business Address: 1221 AVENUE OF THE AMERICAS 39TH FLOOR NEW YORK, NY 10020 Effective Date: 04/03/2002 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN ASSET MANAGEMENT (EUROPE) S.A.R.L. is under common control with the firm. Business Address: EUROPEAN BANK & BUSINESS CENTER 6 ROUTE DE TREVES R.C.S 27 900 SENNINGERBERG, LUXEMBOURG 00000 Effective Date: 05/03/2005 Foreign Entity: Yes Country: LUXEMBORG Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN INSTITUTIONAL INVESTMENTS INC. is under common control with the firm. CRD #: 102920 Business Address: 522 PARK AVENUE NEW YORK, NY 10036 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 57 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)522 PARK AVENUE NEW YORK, NY 10036 Effective Date: 10/30/2002 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: REGISTERED BD; UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN SECURITIES INDIA PRIVATE LIMITED is under common control with the firm. Business Address: 9TH FL. MAFATLAL CENTRE NARIMAN POINT MUMBAI BOMBAY, INDIA 400021 Effective Date: 01/02/2001 Foreign Entity: Yes Country: INDIA Securities Activities: Yes Investment Advisory No Activities: Description: PRIMARY DEALER - TRADING IN FIXED INCOME SECURITIES; UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN & CIE S.A. is under common control with the firm. Business Address: 14 PLACE VENDOME PARIS, FRANCE 00000 Effective Date: 01/02/2001 Foreign Entity: Yes Country: FRANCE Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

Organization Affiliates (continued) Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN (SUISSE) S.A is under common control with the firm. Business Address: 8, RUE DE LA CONFEDERATION P.O. BOX 5160 GENEVA, SWITZERLAND 1211 Effective Date: 01/02/2001 Foreign Entity: Yes Country: SWITZERLAND Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN INVESTMENT MANAGEMENT INC. is under common control with the firm. Business Address: 245 PARK AVENUE NEW YORK, NY 10167 Effective Date: 01/02/2001 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: INVESTMENT ADVISORY/ASSET MANAGEMENT AFFILIATE; UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN SECURITIES ASIA PRIVATE LIMITED is under common control with the firm. Business Address: 168 ROBINSON ROAD, 17TH FLOOR CAPITAL TOWER SINGAPORE, SINGAPORE 068912 Effective Date: 03/30/1973 Foreign Entity: Yes Country: SINGAPORE

Organization Affiliates (continued)

Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN SECURITIES CANADA is under common control with the firm. Business Address: ROYAL BANK PLAZA, SOUTH TOWER SUITE 1800 TORONTO, ONTARIO, CANADA M5X 1A4 Effective Date: 01/02/2001 Foreign Entity: Yes Country: CANADA Securities Activities: Yes Investment Advisory No Activities: Description: SECURITIES DEALER REGISTERED WITH THE OSE AND A MEMBER OF THE IDA OF CANADA; UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN SECURITIES SOUTH AFRICA (PROPRIETARY) LIMITED is under common control with the firm. Business Address: 1 FRICKER ROAD, ILLOVO JOHANNESBURG, SOUTH AFRICA 00000 Effective Date: 01/02/2001 Foreign Entity: Yes Country: SOUTH AFRICA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN SECURITIES NEW ZEALAND LIMITED is under common control with the firm. Business Address: C/O BELL GULLY LEVEL 21, HP TOWER 171 FEATHERSTON STREET ©2021 FINRA. All rights reserved. Report aboutWELLINGTON, J.P. MORGAN NEW SECURITIES ZEALAND INC. 00000 60 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)C/O BELL GULLY LEVEL 21, HP TOWER 171 FEATHERSTON STREET WELLINGTON, NEW ZEALAND 00000 Effective Date: 04/06/2001 Foreign Entity: Yes Country: NEW ZEALAND Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

ORD MINNETT FINANCIAL PLANNING PTY LIMITED is under common control with the firm. Business Address: LEVEL 8, NATIONAL AUSTRALIA BANK HOUSE 255 GEORGE STREET SYDNEY, AUSTRALIA NSW 2000 Effective Date: 09/01/2000 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

ORD MINNETT LIMITED is under common control with the firm. Business Address: LEVEL 8, NATIONAL AUSTRALIA BANK HOUSE 255 GEORGE STREET SYDNEY, AUSTRALIA NSW 2000 Effective Date: 09/01/2000 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & ©2021 FINRA. All rights reserved. Report aboutCO. J.P. MORGAN SECURITIES INC. 61 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN SECURITIES AUSTRALIA LIMITED is under common control with the firm. Business Address: LEVEL 32, GROSVENOR PLACE 225 GEORGE STREET SYDNEY, AUSTRALIA NSW 2000 Effective Date: 04/03/2002 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

PT J.P. MORGAN SECURITIES INDONESIA is under common control with the firm. Business Address: PLAZA CHASE PODIUM, 2ND FLOOR JL. JEND. SUDIRMAN KAV. 21 JAKARTA, INDONESIA 12920 Effective Date: 08/01/2000 Foreign Entity: Yes Country: INDONESIA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JF APEX SECURITIES BERHAD is under common control with the firm. Business Address: 6/F, MENARA APEX OFF JALAN SEMENYIH BUKIT MEWAH 43000 KAJANG SELANGOR, MALAYSIA 00000 Effective Date: 08/01/2000 Foreign Entity: Yes ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 62 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Foreign Entity: Yes Country: MALAYSIA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN SECURITIES (THAILAND) LIMITED is under common control with the firm. Business Address: 3/F BUBHAJIT BUILDING 20 NORTH SATHORN ROAD - SILOM BANGRAK BANGKOK, THAILAND 99999 Effective Date: 04/03/2002 Foreign Entity: Yes Country: THAILAND Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN SECURITIES (TAIWAN) LIMITED is under common control with the firm. Business Address: 3/F, XIN YI TRADING CENTER, NO. 106 SETION 5, HSIN YI ROAD TAIPEI, TAIWAN 110 Effective Date: 05/15/2002 Foreign Entity: Yes Country: TAIWAN Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

FLEMING (FCP) AKTIEN STEATEGIE WELT MANAGEMENT COMPANY SARL is under common control with the firm. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 63 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) FLEMING (FCP) AKTIEN STEATEGIE WELT MANAGEMENT COMPANY SARL is under common control with the firm. Business Address: EUROPEAN BANK & BUSINESS CENTRE 6 ROUTE DE TREVES SENNINGERBERG, LUXEMBOURG 00000 Effective Date: 08/01/2000 Foreign Entity: Yes Country: LUXEMBOURG Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN SECURITIES (FAR EAST) LIMITED is under common control with the firm. Business Address: 22ND FLOOR CHATER HOUSE 8 CONNAUGHT ROAD, CENTRAL HONG KONG HONG KONG, HONG KONG 99999 Effective Date: 03/25/2002 Foreign Entity: Yes Country: HONG KONG Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN PAKISTAN BROKING (PRIVATE) LIMITED is under common control with the firm. Business Address: 2ND FLOOR, BAHRIA COMPLEX II M.T. KHAN ROAD KARACHI, PAKISTAN 74000 Effective Date: 12/19/2003 Foreign Entity: Yes Country: PAKISTAN Securities Activities: Yes ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 64 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN FUTURES (KOREA) LIMITED is under common control with the firm. Business Address: 4/F, JPMORGAN PLAZA 34-35 JEONG-DONG JUNG-GU SEOUL 100-120, SOUTH KOREA 00000 Effective Date: 08/01/2000 Foreign Entity: Yes Country: SOUTH KOREA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN SECURITIES PHILIPPINES, INC. is under common control with the firm. Business Address: 31ST FLOOR, PHILAM LIFE TOWER 8767 PASEO DE ROXAS MAKATI CITY, PHILIPPINES 00000 Effective Date: 04/03/2002 Foreign Entity: Yes Country: PHILIPPINES Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN BROKING (HONG KONG) LIMITED is under common control with the firm. Business Address: 22ND FLOOR CHATER HOUSE 8 CONNAUGHT ROAD, CENTRAL HONG KONG HONG KONG, HONG KONG

Organization Affiliates (continued)

Effective Date: 03/25/2002 Foreign Entity: Yes Country: HONG KONG Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN EQUITIES LIMITED is under common control with the firm. Business Address: 1 FRICKER ROAD ILLOVO 2196 JOHANNESBURG, SOUTH AFRICA 00000 Effective Date: 04/03/2002 Foreign Entity: Yes Country: SOUTH AFRICA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JF ASSET MANAGEMENT (TAIWAN) LIMITED is under common control with the firm. Business Address: 17/F, NO. 65, 67 & 69 TUN HWA SOUTH ROAD SECTION 2 TAIPEI, TAIWAN 00000 Effective Date: 04/03/2002 Foreign Entity: Yes Country: TAIWAN Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 66 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JF ASSET MANAGEMENT (SINGAPORE) LIMITED is under common control with the firm. Business Address: 168 ROBINSON ROAD 17TH FLOOR CAPITAL TOWER SINGAPORE 068912, SINGAPORE 00000 Effective Date: 04/03/2002 Foreign Entity: Yes Country: SINGAPORE Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN SECURITIES SINGAPORE PRIVATE LIMITED is under common control with the firm. Business Address: 17TH FLOOR CAPITAL TOWER 168 ROBINSON ROAD SINGAPORE, SINGAPORE 068912 Effective Date: 09/16/2002 Foreign Entity: Yes Country: SINGAPORE Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN ASSET MANAGEMENT ADVISORY COMPANY S.A R.L. is under common control with the firm. Business Address: EUROPEAN BANK & BUSINESS CENTER 6 ROUTE DE TREVES SENNINGERBERG, LUXEMBOURG 00000 Effective Date: 05/03/2005 Foreign Entity: Yes Country: LUXEMBOURG ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 67 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Country: LUXEMBOURG Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

FLEMING (FCP) FUND SERIES MANAGEMENT COMPANY SARL is under common control with the firm. Business Address: EUROPEAN BANK & BUSINESS CENTRE 6 ROUTE DE TREVES SENNINGERBERG, LUXEMBOURG 00000 Effective Date: 08/01/2000 Foreign Entity: Yes Country: LUXEMBOURG Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JF ASSET MANAGEMENT LIMITED is under common control with the firm. Business Address: 21ST FLOOR CHATER HOUSE 8 CONNAUGHT ROAD, CENTRAL HONG KONG HONG KONG, HONG KONG Effective Date: 08/01/2000 Foreign Entity: Yes Country: HONG KONG Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN ASSET MANAGEMENT (JAPAN) LIMITED is under common control with the firm. Business Address: TOKYO BUILDING 7-3 MARUNOUCHI ©2021 FINRA. All rights reserved. Report about2-CHOME J.P. MORGAN CHIYODA-KU SECURITIES INC. 68 TOKYO, JAPAN 107-6432 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Business Address: TOKYO BUILDING 7-3 MARUNOUCHI 2-CHOME CHIYODA-KU TOKYO, JAPAN 107-6432 Effective Date: 04/03/2002 Foreign Entity: Yes Country: JAPAN Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JF FUNDS LIMITED is under common control with the firm. Business Address: 21ST FLOOR CHATER HOUSE 8 CONNAUGHT ROAD, CENTRAL HONG KONG HONG KONG, HONG KONG 00000 Effective Date: 04/03/2002 Foreign Entity: Yes Country: HONG KONG Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JF INTERNATIONAL MANAGEMENT INC. is under common control with the firm. Business Address: CHATER HOUSE, 8 CONNAUGHT ROAD CENTRAL 21ST FLOOR HONG KONG, CHINA Effective Date: 08/01/2000 Foreign Entity: Yes Country: CHINA Securities Activities: No Investment Advisory Yes Activities:©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 69 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN ASSET MANAGEMENT FRANCE SAS is under common control with the firm. Business Address: WASHINGTON PLAZA 40 RUE WASHINGTON, B.P. 252-08 75364 PARIS CEDEX 08, FRANCE 00000 Effective Date: 04/03/2002 Foreign Entity: Yes Country: FRANCE Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN PRIVATE FUND MANAGEMENT LIMITED is under common control with the firm. Business Address: 10 ALDERMANBURY LONDON, ENGLAND EC2V 7RF Effective Date: 11/20/2003 Foreign Entity: Yes Country: ENGLAND Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN STRUCTURED FUND MANAGEMENT SAS is under common control with the firm. Business Address: 14, PLACE VENDOME PARIS, FRANCE 00000 Effective Date: 03/21/2003 Foreign Entity: Yes

Organization Affiliates (continued)

Country: FRANCE Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN ASSET MANAGEMENT (UK) LIMITED is under common control with the firm. Business Address: 125 LONDON WALL CO. NO. 01161446 LONDON, ENGLAND 00000 Effective Date: 05/03/2005 Foreign Entity: Yes Country: ENGLAND Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN ASSET MANAGEMENT (CANADA) INC. is under common control with the firm. Business Address: 999 WEST HASTINGS STREET SUITE 600, BRITISH COLUMBIA VANCOUVER, CANADA 00000 Effective Date: 02/23/2005 Foreign Entity: Yes Country: CANADA Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JF ASSET MANAGEMENT INTERNATIONAL LIMITED is under common control with the firm. Business Address: PALM GROVE HOUSE P.O. BOX 438, ROAD TOWN ©2021 FINRA. All rights reserved. Report aboutTORTOLA, J.P. MORGAN BRITISH SECURITIES VIRGIN INC. ISLANDS 00000 71 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Business Address: PALM GROVE HOUSE P.O. BOX 438, ROAD TOWN TORTOLA, BRITISH VIRGIN ISLANDS 00000 Effective Date: 04/03/2002 Foreign Entity: Yes Country: BRITISH VIRGIN ISLANDS Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

ORD MINNETT MANAGEMENT LIMITED is under common control with the firm. Business Address: LEVEL 8, BAB HOUSE 255 GEORGE STREET SYDNEY, AUSTRALIA NSW 2000 Effective Date: 08/01/2000 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN TRUST COMPANY (CAYMAN) LIMITED is under common control with the firm. Business Address: P.O. BOX 1748GT 27 HOSPITAL ROAD GEORGE, BAHAMAS 00000 Effective Date: 03/01/2003 Foreign Entity: Yes Country: CAYMAN ISLANDS Securities Activities: No Investment Advisory Yes Activities: ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 72 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN CHASE S.A. SOCIEDAD DE BOLSA is under common control with the firm. Business Address: CORRIENTES 415 - PISO 2 C1043AAE CIUDAD AUTONOMA DE BUENOS AIRES BUENOS AIRES, ARGENTINA 00000 Effective Date: 12/10/2004 Foreign Entity: Yes Country: ARGENTINA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN BANK INTERNATIONAL LLC is under common control with the firm. Business Address: 2 PAVELETSKAY SQUARE BUILDING 1 MOSCOW, RUSSIA 115054 Effective Date: 10/26/1993 Foreign Entity: Yes Country: RUSSIA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN AUSTRALIA LIMITED is under common control with the firm. Business Address: LEVEL 32, GROSVENOR PLACE 225 GEORGE STREET SYDNEY, NSW, 2000, AUSTRALIA 00000 Effective Date: 01/29/1985 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 73 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Effective Date: 01/29/1985 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN S.A. DISTRIBUIDORA DE TITULOS E VALORES MOBILIARIOS is under common control with the firm. Business Address: AVENIDA BRIGADEIRO FARIA LIMA 3729 14FL-PARTE, ITAIM BIBI SAO PAULO, BRAZIL 00000 Effective Date: 04/30/2002 Foreign Entity: Yes Country: BRAZIL Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN (SEA) LIMITED is under common control with the firm. Business Address: 168 ROBINSON ROAD, 17TH FLOOR CAPITAL TOWER SINGAPORE, SINAGPORE 068912 Effective Date: 01/22/1985 Foreign Entity: Yes Country: SINGAPORE Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 74 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

J.P. MORGAN TRUST COMPANY, NATIONAL ASSOCIATION is under common control with the firm. Business Address: 1999 AVENUE OF THE STARS LOS ANGELES, CA 90067 Effective Date: 11/17/1997 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

J.P. MORGAN SECURITIES (ASIA PACIFIC) LIMITED is under common control with the firm. Business Address: 22ND FLOOR, CHATER HOUSE 8 CONNAUGHT ROAD, CENTRAL HONG KONG HONG KONG, CHINA 00000 Effective Date: 03/30/1973 Foreign Entity: Yes Country: HONG KONG Securities Activities: Yes Investment Advisory No Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

BANCO J.P. MORGAN S.A. is under common control with the firm. Business Address: AVENIDA BRIGADEIRO FARIA LIMA, 3729 14TH FLOOR SAO PAULO, BRAZIL 00000 Effective Date: 08/19/1925 Foreign Entity: Yes Country: BRAZIL Securities Activities: Yes ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 75 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN CHASE BANK, NATIONAL ASSOCIATION is under common control with the firm. Business Address: 270 PARK AVENUE NEW YORK, NY 10017 Effective Date: 11/13/2004 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

CHASE INVESTMENT SERVICES CORP. is under common control with the firm. CRD #: 25574 Business Address: 300 S. RIVERSIDE PLAZA 420 W. VAN BUREN STREET CHICAGO, IL 60606 Effective Date: 09/27/1989 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

JPMORGAN ALTERNATIVE ASSET MANAGEMENT is under common control with the firm. CRD #: 20989 Business Address: 245 PARK AVENUE ©2021 FINRA. All rights reserved. Report about8TH J.P.FLOOR MORGAN SECURITIES INC. 76 NEW YORK, NY 10167 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Business Address: 245 PARK AVENUE 8TH FLOOR NEW YORK, NY 10167 Effective Date: 11/24/2003 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: UNDER COMMON CONTROL OF ULTIMATE PARENT, JPMORGAN CHASE & CO.

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

JPMORGAN CHASE & CO. is a Bank Holding Company and controls the firm. Business Address: 270 PARK AVENUE NEW YORK, NY 10017 Effective Date: 09/10/1986 Description: PARENT HOLDING COMPANY

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 1 102 0 Civil Event 0 3 0 Arbitration N/A 2 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 102 Reporting Source: Regulator Current Status: Final Allegations: DURING THE PERIOD OF JANUARY 1, 2004 THROUGH DECEMBER 31, 2011, ©2021 FINRA. All rights reserved. Report aboutTHE J.P. DIVISION MORGAN ALLEGED: SECURITIES (1) INC. J.P. MORGAN SECURITIES, LLC ("JPMS") FAILED 79 TO ESTABLISH AN ADEQUATE SUPERVISORY SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS, IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-260B, (2) JPMS FILED TO ENSURE ITS SALES ASSISTANTS WERE REGISTERED IN ACCORDANCE WITH JPMS'S WRITTEN PROCEDURES AND FAILED TO ENFORCE ITS ESTABLISHED WRITTEN PROCEDURES IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-260 D, (3) JPMS ACCEPTED ORDERS IN VIRGINIA THROUGH SALES ASSISTANTS WHO WERE NOT PROPERLY REGISTERED IN VIRGINIA VIOLATING § 13.1-504 A OF THE ACT, AND (4) JPMS FAILED, IN CERTAIN INSTANCES, TO RECORD THE IDENTITY OF THE PERSON ACCEPTING CLIENT ORDERS ENTERED UNTIL JUNE 2011 IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-240. www.finra.org/brokercheck User Guidance

Allegations: DURING THE PERIOD OF JANUARY 1, 2004 THROUGH DECEMBER 31, 2011, THE DIVISION ALLEGED: (1) J.P. MORGAN SECURITIES, LLC ("JPMS") FAILED TO ESTABLISH AN ADEQUATE SUPERVISORY SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS, IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-260B, (2) JPMS FILED TO ENSURE ITS SALES ASSISTANTS WERE REGISTERED IN ACCORDANCE WITH JPMS'S WRITTEN PROCEDURES AND FAILED TO ENFORCE ITS ESTABLISHED WRITTEN PROCEDURES IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-260 D, (3) JPMS ACCEPTED ORDERS IN VIRGINIA THROUGH SALES ASSISTANTS WHO WERE NOT PROPERLY REGISTERED IN VIRGINIA VIOLATING § 13.1-504 A OF THE ACT, AND (4) JPMS FAILED, IN CERTAIN INSTANCES, TO RECORD THE IDENTITY OF THE PERSON ACCEPTING CLIENT ORDERS ENTERED UNTIL JUNE 2011 IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-240. Initiated By: VIRGINIA - VIRGINIA STATE CORPORATION COMMISSION - DIVISION OF SECURITIES & RETAIL FRANCHISING Date Initiated: 07/16/2014 Docket/Case Number: SEC-2014-00027 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Settled Resolution Date: 07/16/2014 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $45,000.00 Other Sanctions Ordered: COST OF INVESTIGATION: $3,900.00 Sanction Details: SEE ABOVE $48,900.00 PAID ON 6/25/2014 Regulator Statement THIS MATTER WAS INITIATED AS A PART OF A MULTI-STATE TASK FORCE INVESTIGATION COORDINATED BY NASAA. DURING THE PERIOD OF ©2021 FINRA. All rights reserved. Report aboutJANUARY J.P. MORGAN 1, 2004 SECURITIES THROUGH INC. DECEMBER 31, 2011, THE DIVISION ALLEGED: 80 (1) J.P. MORGAN SECURITIES, LLC ("JPMS") FAILED TO ESTABLISH AN ADEQUATE SUPERVISORY SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS, IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-260B, (2) JPMS FILED TO ENSURE ITS SALES ASSISTANTS WERE REGISTERED IN ACCORDANCE WITH JPMS'S WRITTEN PROCEDURES AND FAILED TO ENFORCE ITS ESTABLISHED WRITTEN PROCEDURES IN VIOLATION OF COMMISSION RULE 21 VAC 5-20- 260 D, (3) JPMS ACCEPTED ORDERS IN VIRGINIA THROUGH SALES ASSISTANTS WHO WERE NOT PROPERLY REGISTERED IN VIRGINIA VIOLATING § 13.1-504 A OF THE ACT, AND (4) JPMS FAILED, IN CERTAIN INSTANCES, TO RECORD THE IDENTITY OF THE PERSON ACCEPTING CLIENT ORDERS ENTERED UNTIL JUNE 2011 IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-240. THE FINE AMOUNT OF $45,000 WAS THE AMOUNT DUE TO VIRGINIA IN AN AGREED UPON SETTLEMENT WITH ALL 50 STATES, THE DISTRICT OF COLUMBIA, PUERTO RICO, AND THE US VIRGIN ISLANDS. JPMS IMPLEMENTED A NUMBER OF ENHANCEMENTS IN ITS LEGACY PRIVATE CLIENT SERVICES DIVISION SINCE THIS INVESTIGATION BEGAN, INCLUDING IMPLEMENTING A NEW TRADING SYSTEM WITH ADDITIONAL BLOCKING MECHANISMS AND THE ABILITY TO CONFIRM THE REGISTRATION STATUS OF ORDER ACCEPTORS. JPMS FURTHER ENHANCED ITS REGISTRATION, COMPLIANCE TRAINING, AND WRITTEN COMPLIANCE POLICIES. JPMS ALSO UPDATED ITS ENTRY SYSTEM TO RECORD THE IDENTITY OF THE ORDER ACCEPTOR IN THE ELECTRONIC ORDER SYSTEM. CONTACT MARC BANTEL AT 804-225-4419 FOR FURTHER INFORMATION. www.finra.org/brokercheck User Guidance

Regulator Statement THIS MATTER WAS INITIATED AS A PART OF A MULTI-STATE TASK FORCE INVESTIGATION COORDINATED BY NASAA. DURING THE PERIOD OF JANUARY 1, 2004 THROUGH DECEMBER 31, 2011, THE DIVISION ALLEGED: (1) J.P. MORGAN SECURITIES, LLC ("JPMS") FAILED TO ESTABLISH AN ADEQUATE SUPERVISORY SYSTEM TO MONITOR THE REGISTRATION STATUS OF PERSONS ACCEPTING CLIENT ORDERS, IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-260B, (2) JPMS FILED TO ENSURE ITS SALES ASSISTANTS WERE REGISTERED IN ACCORDANCE WITH JPMS'S WRITTEN PROCEDURES AND FAILED TO ENFORCE ITS ESTABLISHED WRITTEN PROCEDURES IN VIOLATION OF COMMISSION RULE 21 VAC 5-20- 260 D, (3) JPMS ACCEPTED ORDERS IN VIRGINIA THROUGH SALES ASSISTANTS WHO WERE NOT PROPERLY REGISTERED IN VIRGINIA VIOLATING § 13.1-504 A OF THE ACT, AND (4) JPMS FAILED, IN CERTAIN INSTANCES, TO RECORD THE IDENTITY OF THE PERSON ACCEPTING CLIENT ORDERS ENTERED UNTIL JUNE 2011 IN VIOLATION OF COMMISSION RULE 21 VAC 5-20-240. THE FINE AMOUNT OF $45,000 WAS THE AMOUNT DUE TO VIRGINIA IN AN AGREED UPON SETTLEMENT WITH ALL 50 STATES, THE DISTRICT OF COLUMBIA, PUERTO RICO, AND THE US VIRGIN ISLANDS. JPMS IMPLEMENTED A NUMBER OF ENHANCEMENTS IN ITS LEGACY PRIVATE CLIENT SERVICES DIVISION SINCE THIS INVESTIGATION BEGAN, INCLUDING IMPLEMENTING A NEW TRADING SYSTEM WITH ADDITIONAL BLOCKING MECHANISMS AND THE ABILITY TO CONFIRM THE REGISTRATION STATUS OF ORDER ACCEPTORS. JPMS FURTHER ENHANCED ITS REGISTRATION, COMPLIANCE TRAINING, AND WRITTEN COMPLIANCE POLICIES. JPMS ALSO UPDATED ITS ENTRY SYSTEM TO RECORD THE IDENTITY OF THE ORDER ACCEPTOR IN THE ELECTRONIC ORDER SYSTEM. CONTACT MARC BANTEL AT 804-225-4419 FOR FURTHER INFORMATION. i Disclosure 2 of 102 Reporting Source: Regulator Current Status: Final Allegations: ON JANUARY 13, 2010, THE SECURITIES DIVISION ENTERED INTO A CONSENT ORDER WITH JPMORGAN CHASE & CO. ("RESPONDENT"), IN ORDER TO SETTLE THE ALLEGATIONS THAT RESPONDENT ENGAGED IN UNETHICAL PRACTICES IN THE SALE OF AUCTION RATE SECURITIES ("ARS"), AND FAILED TO SUPERVISE REASONABLY ITS SALESPERSONS IN THE MARKETING AND SALE OF ARS. RESPONDENT NEITHER ADMITTED NOR DENIED THE ALLEGATIONS, BUT AGREED TO CEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OF WASHINGTON. RESPONDENT AGREED TO OFFER TO PURCHASE AT PAR ARS THAT SINCE FEBRUARY 12, 2008 HAVE NOT BEEN AUCTIONING FROM INDIVIDUAL INVESTORS WHO PURCHASED THOSE ARS FROM RESPONDENT PRIOR TO FEBRUARY 12, 2008. RESPONDENT AGREED TO PAY $224,424.14 AS A CIVIL MONETARY PENALTY. RESPONDENT WAIVED ITS RIGHT TO A HEARING AND TO ©2021 FINRA. All rights reserved. Report aboutJUDICIAL J.P. MORGAN REVIEW SECURITIES OF THIS INC. MATTER. 81 ON JANUARY 13, 2010, THE SECURITIES DIVISION ENTERED INTO A CONSENT ORDER WITH JPMORGAN CHASE & CO. ("RESPONDENT"), IN ORDER TO SETTLE THE ALLEGATIONS THAT RESPONDENT ENGAGED IN UNETHICAL PRACTICES IN THE SALE OF AUCTION RATE SECURITIES ("ARS"), AND FAILED TO SUPERVISE REASONABLY ITS SALESPERSONS IN THE MARKETING AND SALE OF ARS. RESPONDENT NEITHER ADMITTED NOR DENIED THE ALLEGATIONS, BUT AGREED TO CEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OF WASHINGTON. RESPONDENT www.finra.org/brokercheck AGREED TO OFFER TO PURCHASE AT PAR ARS THAT SINCE FEBRUARY 12, User Guidance 2008 HAVE NOT BEEN AUCTIONING FROM INDIVIDUAL INVESTORS WHO PURCHASED THOSE ARS FROM RESPONDENT PRIOR TO FEBRUARY 12, 2008. RESPONDENT AGREED TO PAY $224,424.14 AS A CIVIL MONETARY PENALTY. RESPONDENT WAIVED ITS RIGHT TO A HEARING AND TO JUDICIAL REVIEW OF THIS MATTER. Initiated By: WASHINGTON Date Initiated: 01/13/2010 Docket/Case Number: S-09-196-09CO01 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 TO IMPOSE FINES. Sought:

Resolution: Order Resolution Date: 01/13/2010 Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $224,424.14 Cease and Desist/Injunction Other Sanctions Ordered: JPMORGAN SHALL CEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OF WASHINGTON AND SHALL COMPLY WITH THE SECURITIES ACT OF WASHINGTON. WITHIN TEN DAYS AFTER THE ENTRY OF THIS CONSENT ORDER, JPMORGAN SHALL PAY THE SUM OF $224,424.14 TO THE STATE OF WASHINGTON AS A CIVIL MONETARY PENALTY PURSUANT TO RCW 21.20.110 AND RCW 21.20.395, TO BE DEPOSITED IN THE SECURITIES PROSECUTION FUND, RCW 43.320.115, WHICH AMOUNT CONSTITUTES THE STATE OF WASHINGTON'S PROPORTIONATE SHARE OF THE STATE SETTLEMENT AMOUNT OF $25 MILLION DOLLARS ($25,000,000.00). Sanction Details: $224,424.14 Regulator Statement BRIDGETT FISHER - 360-902-8783 i Disclosure 3 of 102 Reporting Source: Regulator

Current Status: Final Allegations: SEC RULES 10B-10, 200(G) OF REGULATION SHO, NASD RULES 2110, 2320, 3010, 4632, 4632(D), 6130(B), 6130(D), 6230(C)(6), 6620(A), 6955(A), MSRB RULES G-14, G-15(A)(I)(A)(5), G-27 - J.P. MORGAN SECURITIES INC. EXECUTED NUMEROUS SHORT SALE TRANSACTIONS AND FAILED TO REPORT THEM TO THE AUTOMATED CONFIRMATION TRANSACTION SERVICE (ACT) WITH A SHORT SALE MODIFIER DUE TO A TECHNOLOGY ISSUE THAT INACCURATELY TREATED PRINCIPAL SHORT SALES AS LONG SALES. THE FIRM SUBMITTED TO OATS NEW ORDER REPORTS AND RELATED SUBSEQUENT REPORTS WHERE THE TIMESTAMP FOR THE RELATED SUBSEQUENT REPORT OCCURRED PRIOR TO THE RECEIPT OF THE ORDER SO THAT THE OATS SYSTEM WAS UNABLE TO CREATE AN ACCURATE TIME-SEQUENCED RECORD FROM THE RECEIPT OF THE ORDER THROUGH ITS RESOLUTION. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. THE FIRM FAILED TO TIMELY REPORT REPORTABLE ORDER EVENTS (ROES) TO OATS. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTC REPORTING FACILITY LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE TO THE OTC REPORTING FACILITY SOME OF THE LAST SALE REPORTS AS LATE. THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY; FAILED TO REPORT TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES IT WAS REQUIRED TO REPORT OR IMPROPERLY REPORTED TRANSACTIONS THAT IT SHOULD NOT HAVE. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING FACILITY (TRF) THE CORRECT SYMBOL INDICATING WHETHER TRANSACTIONS WERE A BUY, SELL, SELL SHORT, SELL SHORT EXEMPT OR CROSS FOR TRANSACTIONS IN REPORTABLE SECURITIES; FAILED TO REPORT TO THE TRF THE CORRECT SYMBOL INDICATING WHETHER IT EXECUTED TRANSACTIONS IN REPORTABLE SECURITIES IN A PRINCIPAL OR AGENCY CAPACITY; [CONTINUED IN COMMENTS] Initiated By: FINRA Date Initiated: 04/24/2008 Docket/Case Number: 2004100001101

Principal Product Type: Equity - OTC Other Product Type(s): TRACE-ELIGIBLE SECURITIES, MUNICIPAL SECURITIES, REPORTABLE SECURITIES, DESIGNATED SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 83 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/24/2008 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 $185,000.00 Disgorgement/Restitution Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $185,000; ORDERED TO PAY $299, PLUS INTEREST, IN RESTITUTION TO INVESTORS AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING SHORT SALE, TRACE TRADE, TRADE AND RISKLESS PRINCIPAL TRADE REPORTING, AND BEST EXECUTION FOR TRANSACTIONS EXECUTED BY ITS PROGRAM TRADING DESK WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. Regulator Statement FAILED TO REPORT THE CORRECT TIME OF EXECUTION TO THE OTC REPORTING FACILITY IN ONE LATE LAST SALE REPORT OF A TRANSACTION IN AN OTC EQUITY SECURITY; FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY IN TRANSACTIONS; FAILED TO SUBMIT REQUIRED ROUTE REPORTS TO OATS AND INACCURATELY SUBMITTED EXECUTION REPORTS AND A CANCEL REPORT. THE FIRM EXECUTED SELL ORDERS AND IMPROPERLY MARKED THE ORDERS AS SHORT EXEMPT; FAILED TO SUBMIT TO THE TRF, FOR THE OFFSETTING, "RISKLESS" PORTION OF "RISKLESS" PRINCIPAL TRANSACTIONS IN DESIGNATED SECURITIES, EITHER A CLEARING-ONLY REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL" OR A NON-TAPE, NON-CLEARING REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL;" INCORRECTLY REPORTED TO THE TRF PRINCIPAL TRANSACTIONS WHEN EACH WAS PARTIALLY A PRINCIPAL TRANSACTION AND PARTIALLY A RISKLESS PRINCIPAL TRANSACTION AND FAILED TO SUBMIT FOR THE OFFSETTING, "RISKLESS" PORTION EITHER A CLEARING-ONLY REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL," OR A NON-TAPE, NON- CLEARING REPORT WITH A "RISKLESS PRINCIPAL" CAPACITY INDICATOR; ©2021 FINRA. All rights reserved. Report aboutFAILED J.P. MORGANTO REPORT SECURITIES THE CORRECTINC. NUMBER OF SHARES TO THE TRF OF 84 DESIGNATED SECURITIES TRANSACTIONS IN LAST SALE REPORTS; INCORRECTLY REPORTED TO THE TRF THE 2ND LEG OF A "RISKLESS" PRINCIPAL TRANSACTION(S) IN DESIGNATED SECURITIES BECAUSE IT INCORRECTLY DESIGNATED THE CAPACITY AS "PRINCIPAL;" FAILED TO PROVIDE WRITTEN CONFIRMATION OF TRANSACTIONS DISCLOSING THE CORRECT YIELD TO ITS CUSTOMERS;FAILED TO ACCEPT OR DECLINE IN THE TRF OR OTC REPORTING FACILITY TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION IT HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE OEID. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD AND MSRB RULES CONCERNING SHORT SALE, TRACE TRADE, TRADE AND RISKLESS PRINCIPAL TRADE REPORTING, AND BEST EXECUTION. FAILED TO REPORT THE CORRECT TIME OF EXECUTION TO THE OTC REPORTING FACILITY IN ONE LATE LAST SALE REPORT OF A TRANSACTION IN AN OTC EQUITY SECURITY; FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY IN TRANSACTIONS; FAILED TO SUBMIT REQUIRED ROUTE REPORTS TO OATS AND INACCURATELY SUBMITTED EXECUTION REPORTS AND A CANCEL REPORT. THE FIRM EXECUTED SELL ORDERS AND IMPROPERLY MARKED THE ORDERS AS SHORT EXEMPT; FAILED TO SUBMIT TO THE TRF, FOR THE OFFSETTING, "RISKLESS" PORTION OF "RISKLESS" PRINCIPAL TRANSACTIONS IN DESIGNATED SECURITIES, EITHER A CLEARING-ONLY REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL" OR A NON-TAPE, NON-CLEARING REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL;" INCORRECTLY REPORTED TO THE TRF PRINCIPAL TRANSACTIONS WHEN EACH WAS www.finra.org/brokercheck PARTIALLY A PRINCIPAL TRANSACTION AND PARTIALLY A RISKLESS User Guidance PRINCIPAL TRANSACTION AND FAILED TO SUBMIT FOR THE OFFSETTING, "RISKLESS" PORTION EITHER A CLEARING-ONLY REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL," OR A NON-TAPE, NON- CLEARING REPORT WITH A "RISKLESS PRINCIPAL" CAPACITY INDICATOR; FAILED TO REPORT THE CORRECT NUMBER OF SHARES TO THE TRF OF DESIGNATED SECURITIES TRANSACTIONS IN LAST SALE REPORTS; INCORRECTLY REPORTED TO THE TRF THE 2ND LEG OF A "RISKLESS" PRINCIPAL TRANSACTION(S) IN DESIGNATED SECURITIES BECAUSE IT INCORRECTLY DESIGNATED THE CAPACITY AS "PRINCIPAL;" FAILED TO PROVIDE WRITTEN CONFIRMATION OF TRANSACTIONS DISCLOSING THE CORRECT YIELD TO ITS CUSTOMERS;FAILED TO ACCEPT OR DECLINE IN THE TRF OR OTC REPORTING FACILITY TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION IT HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE OEID. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD AND MSRB RULES CONCERNING SHORT SALE, TRACE TRADE, TRADE AND RISKLESS PRINCIPAL TRADE REPORTING, AND BEST EXECUTION. i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGES THAT JPMSI VIOLATED SEC RULES 10B-10, 200(G) OF REGULATION SHO, NASD RULES 2110, 2320, 3010, 4632, 4632(D), 6130(B), 6130(D), 6230(C)(6), 6620(A), 6955(A), MSRB RULES G-14, G-15(A)(I)(A)(5), G- 27 IN THAT THE FIRM (1) EXECUTED NUMEROUS SHORT SALE TRANSACTIONS AND FAILED TO REPORT THEM TO ACT WITH A SHORT SALE MODIFIER; (2) SUBMITTED TO OATS NEW ORDER REPORTS AND RELATED SUBSEQUENT REPORTS THAT WERE OUT OF SEQUENCE; (3) FAILED TO TIMELY REPORT ROES TO OATS; (4) FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES; (5) FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTC REPORTING FACILITY LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE TO THE OTC REPORTING FACILITY SOME OF THE LAST SALE REPORTS AS LATE; (6) FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY; (7) FAILED TO REPORT TO THE RTRS REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES IT WAS REQUIRED TO REPORT AND/OR IMPROPERLY REPORTED TRANSACTIONS THAT IT SHOULD NOT HAVE; (8) FAILED TO REPORT TO TRF THE CORRECT SYMBOL INDICATING WHETHER TRANSACTIONS WERE A BUY, SELL, SELL SHORT, SELL SHORT EXEMPT OR CROSS; FAILED TO REPORT TO TRF THE CORRECT SYMBOL INDICATING WHETHER IT EXECUTED IN A PRINCIPAL OR AGENCY CAPACITY; FAILED TO REPORT CORRECT TIME OF EXECUTION TO THE OTC REPORTING FACILITY; FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY; FAILED TO SUBMIT REQUIRED ROUTE REPORTS TO OATS AND INACCURATELY ©2021 FINRA. All rights reserved. Report aboutSUBMITTED J.P. MORGAN EXECUTION/CANCEL SECURITIES INC. REPORTS; EXECUTED SELL ORDERS 85 AND IMPROPERLY MARKED THE ORDERS AS SHORT EXEMPT; FAILED TO SUBMIT TO THE TRF, FOR THE OFFSETTING, "RISKLESS" PORTION OF "RISKLESS" PRINCIPAL TRANSACTIONS, EITHER A CLEARING-ONLY REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL" OR A NON-TAPE, NON-CLEARING REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL;" [CONTINUED BELOW] FINRA ALLEGES THAT JPMSI VIOLATED SEC RULES 10B-10, 200(G) OF REGULATION SHO, NASD RULES 2110, 2320, 3010, 4632, 4632(D), 6130(B), 6130(D), 6230(C)(6), 6620(A), 6955(A), MSRB RULES G-14, G-15(A)(I)(A)(5), G- 27 IN THAT THE FIRM (1) EXECUTED NUMEROUS SHORT SALE TRANSACTIONS AND FAILED TO REPORT THEM TO ACT WITH A SHORT SALE MODIFIER; (2) SUBMITTED TO OATS NEW ORDER REPORTS AND RELATED SUBSEQUENT REPORTS THAT WERE OUT OF SEQUENCE; (3) FAILED TO TIMELY REPORT ROES TO OATS; (4) FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES; (5) FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTC REPORTING FACILITY LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE TO THE OTC REPORTING FACILITY SOME OF THE LAST SALE REPORTS AS LATE; (6) FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY; (7) FAILED TO REPORT TO THE RTRS REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES IT WAS REQUIRED TO REPORT AND/OR IMPROPERLY REPORTED TRANSACTIONS THAT IT SHOULD NOT HAVE; (8) FAILED TO REPORT TO TRF THE CORRECT SYMBOL INDICATING WHETHER TRANSACTIONS WERE A BUY, SELL, SELL SHORT, SELL SHORT EXEMPT OR CROSS; FAILED TO REPORT TO TRF THE CORRECT SYMBOL www.finra.org/brokercheck INDICATING WHETHER IT EXECUTED IN A PRINCIPAL OR AGENCY User Guidance CAPACITY; FAILED TO REPORT CORRECT TIME OF EXECUTION TO THE OTC REPORTING FACILITY; FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITS CORRECT CAPACITY; FAILED TO SUBMIT REQUIRED ROUTE REPORTS TO OATS AND INACCURATELY SUBMITTED EXECUTION/CANCEL REPORTS; EXECUTED SELL ORDERS AND IMPROPERLY MARKED THE ORDERS AS SHORT EXEMPT; FAILED TO SUBMIT TO THE TRF, FOR THE OFFSETTING, "RISKLESS" PORTION OF "RISKLESS" PRINCIPAL TRANSACTIONS, EITHER A CLEARING-ONLY REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL" OR A NON-TAPE, NON-CLEARING REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL;" [CONTINUED BELOW] Initiated By: FINRA. Date Initiated: 04/23/2008 Docket/Case Number: 20041000011-01

Principal Product Type: Equity - OTC Other Product Type(s): TRACE-ELIGIBLE SECURITIES, MUNICIPAL SECURITIES, CORPORATE SECURITIES, EQUITY SECURITIES. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief 185,000 FINE CENSURE, UNDERTAKINGS, $299.00, PLUS INTEREST, IN Sought: RESTITUTION

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/24/2008 Sanctions Ordered: Censure Monetary/Fine $185,000.00 Disgorgement/Restitution Other Sanctions Ordered: UNDERTAKING. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND FINDINGS; THE FIRM WAS CENSURED, FINED $185,000; ORDERED TO PAY $299.00, PLUS INTEREST, IN RESTITUTION TO INVESTORS WITHIN 120 DAYS OF ACCEPTANCE OF THE AWC BY THE NAC, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING SHORT SALE, TRACE TRADE, MSRB TRADE, AND RISKLESS PRINCIPAL TRADE REPORTING AND BEST EXECUTION, WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THE AWC BY THE NAC. Firm Statement INCORRECTLY REPORTED TO THE TRF PRINCIPAL TRANSACTIONS WHEN EACH WAS PARTIALLY A PRINCIPAL TRANSACTION AND PARTIALLY A RISKLESS PRINCIPAL TRANSACTION; FAILED TO REPORT THE CORRECT NUMBER OF SHARES TO THE TRF IN LAST SALE REPORTS; INCORRECTLY REPORTED TO THE TRF THE 2ND LEG OF A "RISKLESS" PRINCIPAL TRANSACTION(S); (9) FAILED TO PROVIDE WRITTEN CONFIRMATION OF TRANSACTIONS DISCLOSING THE CORRECT YIELD TO ITS CUSTOMERS; ©2021 FINRA. All rights reserved. Report about(10) J.P.FAILED MORGAN TO SECURITIESACCEPT OR INC. DECLINE IN THE TRF OR OTC REPORTING 86 FACILITY TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION IT HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE OEID.

THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD AND MSRB RULES CONCERNING SHORT SALE, TRACE TRADE, MSRB TRADE, AND, RISKLESS PRINCIPAL TRADE REPORTING AND BEST EXECUTION IN THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR: (1) THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; (2) A STATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THE IDENTIFIED PERSON(S); (3) A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED INCORRECTLY REPORTED TO THE TRF PRINCIPAL TRANSACTIONS WHEN EACH WAS PARTIALLY A PRINCIPAL TRANSACTION AND PARTIALLY A www.finra.org/brokercheck RISKLESS PRINCIPAL TRANSACTION; FAILED TO REPORT THE CORRECT User Guidance NUMBER OF SHARES TO THE TRF IN LAST SALE REPORTS; INCORRECTLY REPORTED TO THE TRF THE 2ND LEG OF A "RISKLESS" PRINCIPAL TRANSACTION(S); (9) FAILED TO PROVIDE WRITTEN CONFIRMATION OF TRANSACTIONS DISCLOSING THE CORRECT YIELD TO ITS CUSTOMERS; (10) FAILED TO ACCEPT OR DECLINE IN THE TRF OR OTC REPORTING FACILITY TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION IT HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE OEID.

THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD AND MSRB RULES CONCERNING SHORT SALE, TRACE TRADE, MSRB TRADE, AND, RISKLESS PRINCIPAL TRADE REPORTING AND BEST EXECUTION IN THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR: (1) THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE APPLICABLE RULES; (2) A STATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THE IDENTIFIED PERSON(S); (3) A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED i Disclosure 4 of 102 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010, 3310 - JP MORGAN SECURITIES, INC. ADVERTISED ITS TRADING VOLUME FOR SECURITIES IN PRIVATE SERVICE PROVIDERS AND ITS AGGREGATE TRADE VOLUME (BUY AND SELL) FOR SOME EQUITY SECURITIES ADVERTISED IN THE PROVIDERS SUBSTANTIALLY EXCEEDED ITS EXECUTED TRADE VOLUME FOR THE SECURITIES AND THE FIRM DID NOT DETERMINE WHETHER THE TRADE VOLUME THAT IT ADVERTISED IN THESE SERVICES ACCURATELY REFLECTED ITS EXECUTED TRADE VOLUME. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING NASD RULE 3310. THE FIRM DID NOT SUPERVISE THE TRADE VOLUME THAT IT ADVERTISED IN THESE SYSTEMS. Initiated By: FINRA Date Initiated: 04/04/2008 Docket/Case Number: 2006006754101

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: 04/04/2008 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 $150,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $150,000 AND REQUIRED TO REVISE ITS WRITTEN SUEPRVISORY PROCEDURES REGARDING NASD RULE 3310 WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. i Reporting Source: Firm Current Status: Final Allegations: NASD RULES 2110, 3010, 3310 - JP MORGAN SECURITIES INC.'S AGGREGATE TRADE VOLUME (BUY AND SELL) FOR THREE EQUITY SECURITIES ADVERTISED IN AUTEX, BLOOMBERG AND REUTERS FOR AUGUST 2006 SUBSTANTIALLY EXCEEDED THE FIRM'S EXECUTED TRADE VOLUME FOR THE SAME THREE SECURITIES. THE FIRM ALSO DID NOT DETERMINE WHETHER THE TRADE VOLUME THAT IT ADVERTISED IN THESE SERVICES ACCURATELY REFLECTED ITS EXECUTED TRADE VOLUME. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING NASD RULE 3310. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR: (1) THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE ADVERTISED TRADE VOLUME ON THESE SUBSCRIBER SERVICES AND THE APPLICABLE RULES; (2) A STATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY ©2021 FINRA. All rights reserved. Report aboutTHE J.P. IDENTIFIED MORGAN SECURITIES PERSON(S); INC. (3) A STATEMENT AS TO HOW OFTEN SUCH 88 PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED. THE FIRM ALSO DID NOT SUPERVISE THE TRADE VOLUME THAT IT ADVERTISED IN THESE SYSTEMS. NASD RULES 2110, 3010, 3310 - JP MORGAN SECURITIES INC.'S AGGREGATE TRADE VOLUME (BUY AND SELL) FOR THREE EQUITY SECURITIES ADVERTISED IN AUTEX, BLOOMBERG AND REUTERS FOR AUGUST 2006 SUBSTANTIALLY EXCEEDED THE FIRM'S EXECUTED TRADE VOLUME FOR THE SAME THREE SECURITIES. THE FIRM ALSO DID NOT DETERMINE WHETHER THE TRADE VOLUME THAT IT ADVERTISED IN THESE SERVICES ACCURATELY REFLECTED ITS EXECUTED TRADE VOLUME. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING NASD RULE 3310. SPECIFICALLY, THE FIRM'S SUPERVISORY www.finra.org/brokercheck SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES User Guidance PROVIDING FOR: (1) THE IDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISION WITH RESPECT TO THE ADVERTISED TRADE VOLUME ON THESE SUBSCRIBER SERVICES AND THE APPLICABLE RULES; (2) A STATEMENT OF THE SUPERVISORY STEP(S) TO BE TAKEN BY THE IDENTIFIED PERSON(S); (3) A STATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCH STEP(S); AND (4) A STATEMENT AS TO HOW THE COMPLETION OF THE STEP(S) INCLUDED IN THE WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED. THE FIRM ALSO DID NOT SUPERVISE THE TRADE VOLUME THAT IT ADVERTISED IN THESE SYSTEMS. Initiated By: FINRA. Date Initiated: 04/02/2008 Docket/Case Number: 20060067541-01

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINED $150,000. UNDERTAKING TO REVISE THE FIRM'S WRITTEN Sought: SUPERVISORY PROCEDURES.

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/02/2008 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: UNDERTAKING. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $150,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING NASD RULE 3310 WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. i Disclosure 5 of 102 Reporting Source: Regulator Current Status: Final Allegations: MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULES G-27 AND G-38: THIS MATTER INVOLVES VIOLATIONS OF MSRB RULE G-38, BY J.P. MORGAN SECURITIES, INC. ("JP MORGAN" OR THE "FIRM") FROM JANUARY 1, 2002 THROUGH JUNE 30, 2004. DURING THAT PERIOD RULE G-38 REQUIRED THAT FIRMS DISCLOSE AMONG OTHER THINGS, MUNICIPAL SECURITIES BUSINESS OBTAINED OR RETAINED BY CONSULTANTS AS ©2021 FINRA. All rights reserved. Report aboutWELL J.P. AS MORGAN PAYMENTS SECURITIES MADE INC. TO CONSULTANTS CONNECTED TO 89 PARTICULAR SECURITIES BUSINESS. HOWEVER, THE FIRM FAILED TO DISCLOSE IN QUARTERLY FORM G-37/38 REPORTS FILED WITH THE MSRB THAT NUMEROUS CONSULTANTS HAD OBTAINED OR RETAINED PARTICULAR MUNICIPAL SECURITIES BUSINESS FOR THE FIRM AND THAT JP MORGAN HAD MADE PAYMENTS TO CONSULTANTS CONNECTED WITH PARTICULAR MUNICIPAL SECURITIES BUSINESS. DURING THAT SAME TIME PERIOD, THE FIRM ALSO FAILED TO ADOPT, MAINTAIN AND ENFORCE PROCEDURES REASONABLE DESIGNED TO ENSURE COMPLIANCE WITH THE REPORTING REQUIREMENTS OF RULE G-38, IN VIOLATION OF MSRB RULE G-27. AS DISCLOSED IN ITS QUARTERLY FORMS G-37/G-38, OVER THE COURSE OF THE TWO-AND-A-HALF YEAR PERIOD FROM JANUARY 1, 2002 THROUGH JUNE 30, 2004, THE FIRM PAID A TOTAL OF APPROXIMATELY $7.15 MILLION, CONSISTING OF APPROXIMATELY $6.8 MILLION IN CONSULTING FEES, INCLUDING APPROXIMATELY $2.5 MILLION IN BONUSES, AND APPROXIMATELY $365,000 IN EXPENSES, TO APPROXIMATELY 40 CONSULTANTS RETAINED IN CONNECTION WITH ITS MUNICIPAL SECURITIES BUSINESS. IN QUARTERLY FORMS G-37/G-38 FILED WITH THE MSRB FOR THAT SAME PERIOD, HOWEVER, THE FIRM INACCURATELY REPORTED THAT THESE CONSULTANTS HAD NOT OBTAINED OR RETAINED ANY MUNICIPAL SECURITIES BUSINESS FOR THE FIRM. JP MORGAN ALSO FAILED TO REPORT THAT ANY OF THE PAYMENTS MADE TO EACH OF THE APPROXIMATELY 40 CONSULTANTS WERE CONNECTED WITH PARTICULAR MUNICIPAL SECURITIES BUSINESS AWARDED TO THE FIRM. IN FACT, AT LEAST 70 MUNICIPAL SECURITIES OFFERINGS UNDERWRITTEN BY THE FIRM DURING THIS PERIOD WERE OBTAINED BY A LEAST 16 DIFFERENT FIRM CONSULTANTS. (CONTINUED IN COMMENTS) MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULES G-27 AND www.finra.org/brokercheck G-38: THIS MATTER INVOLVES VIOLATIONS OF MSRB RULE G-38, BY J.P. User Guidance MORGAN SECURITIES, INC. ("JP MORGAN" OR THE "FIRM") FROM JANUARY 1, 2002 THROUGH JUNE 30, 2004. DURING THAT PERIOD RULE G-38 REQUIRED THAT FIRMS DISCLOSE AMONG OTHER THINGS, MUNICIPAL SECURITIES BUSINESS OBTAINED OR RETAINED BY CONSULTANTS AS WELL AS PAYMENTS MADE TO CONSULTANTS CONNECTED TO PARTICULAR SECURITIES BUSINESS. HOWEVER, THE FIRM FAILED TO DISCLOSE IN QUARTERLY FORM G-37/38 REPORTS FILED WITH THE MSRB THAT NUMEROUS CONSULTANTS HAD OBTAINED OR RETAINED PARTICULAR MUNICIPAL SECURITIES BUSINESS FOR THE FIRM AND THAT JP MORGAN HAD MADE PAYMENTS TO CONSULTANTS CONNECTED WITH PARTICULAR MUNICIPAL SECURITIES BUSINESS. DURING THAT SAME TIME PERIOD, THE FIRM ALSO FAILED TO ADOPT, MAINTAIN AND ENFORCE PROCEDURES REASONABLE DESIGNED TO ENSURE COMPLIANCE WITH THE REPORTING REQUIREMENTS OF RULE G-38, IN VIOLATION OF MSRB RULE G-27. AS DISCLOSED IN ITS QUARTERLY FORMS G-37/G-38, OVER THE COURSE OF THE TWO-AND-A-HALF YEAR PERIOD FROM JANUARY 1, 2002 THROUGH JUNE 30, 2004, THE FIRM PAID A TOTAL OF APPROXIMATELY $7.15 MILLION, CONSISTING OF APPROXIMATELY $6.8 MILLION IN CONSULTING FEES, INCLUDING APPROXIMATELY $2.5 MILLION IN BONUSES, AND APPROXIMATELY $365,000 IN EXPENSES, TO APPROXIMATELY 40 CONSULTANTS RETAINED IN CONNECTION WITH ITS MUNICIPAL SECURITIES BUSINESS. IN QUARTERLY FORMS G-37/G-38 FILED WITH THE MSRB FOR THAT SAME PERIOD, HOWEVER, THE FIRM INACCURATELY REPORTED THAT THESE CONSULTANTS HAD NOT OBTAINED OR RETAINED ANY MUNICIPAL SECURITIES BUSINESS FOR THE FIRM. JP MORGAN ALSO FAILED TO REPORT THAT ANY OF THE PAYMENTS MADE TO EACH OF THE APPROXIMATELY 40 CONSULTANTS WERE CONNECTED WITH PARTICULAR MUNICIPAL SECURITIES BUSINESS AWARDED TO THE FIRM. IN FACT, AT LEAST 70 MUNICIPAL SECURITIES OFFERINGS UNDERWRITTEN BY THE FIRM DURING THIS PERIOD WERE OBTAINED BY A LEAST 16 DIFFERENT FIRM CONSULTANTS. (CONTINUED IN COMMENTS) Initiated By: FINRA Date Initiated: 12/12/2007 Docket/Case Number: 2005001306301

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: 12/12/2007

©2021Does FINRA.the order All rights constitute reserved. a Report aboutNo J.P. MORGAN SECURITIES INC. 90 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 $500,000.00 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 FINE $500,000. IN ADDITION, WITHIN 60 DAYS, AN OFFICER OF THE FIRM MUST CERTIFY TO FINRA THAT THE FIRM HAS REVIEWED ITS PROCEDURES REGARDING COMPLIANCE WITH MSRB RULE G-38 IN ITS CURRENT FORM AND HAS ESTABLISHED SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS PROHIBITIONS AND REPORTING REQUIREMENTS. THE FIRM ALSO MUST PROVIDE FINRA WITH A DETAILED DESCRIPTION OF THE REVIEW CONDUCTED, ITS SYSTEMS AND PROCEDURES, AND ANY CHANGES TO ITS SYSTEMS AND PROCEDURES INCLUDING A COPY OF ANY APPLICABLE WRITTEN PROCEDURES. Regulator Statement (FINDINGS CONTINUED) IN ADDITION, DURING THE SAME PERIOD, THE FIRM MADE AT LEAST SIX PAYMENTS TOTALING $775,000 TO FOUR OF THE FIRM'S CONSULTANTS THAT WERE CONNECTED TO PARTICULAR MUNICIPAL SECURITIES BUSINESS. BY FAILING TO REPORT THIS INFORMATION ON MSRB FOR G-37/G-38, THE FIRM VIOLATED MSRB RULE G-38. IN ADDITION, J.P. MORGAN FAILED TO FILE ITS QUARTERLY FORM G- 37/G-38 REPORTS IN THE CORRECT FORMAT UNTIL JUNE 30, 2003. INSTEAD, THE FIRM FILED THE REPORTS ON AN OUT-OF-DATE VERSION OF THE FORM THAT DID NOT REFLECT THE APPLICABLE REPORTING REQUIREMENTS FOR RULE G-38. IN FACT, EVEN WHEN J.P. MORGAN BEGAN TO FILE ITS QUARTERLY REPORTS ON THE CORRECT FORM, IT FAILED TO ADOPT PROCEDURES, OR TO UPDATE ITS CURRENT WRITTEN PROCEDURES, TO REFLECT THE ACTUAL DISCLOSURE REQUIREMENTS OF THE RULE. IN ADDITION, THE FIRM'S WRITTEN PROCEDURES CONTAINED NO STANDARDS FOR REVIEW OF THE QUARTERLY FORM G- 37/G-38 FILINGS PRIOR TO THEIR SUBMISSION TO THE MSRB, AND THE FIRM HAD NO PROCEDURES DESIGNED TO ENSURE THAT FORMS G-37/G- 38 WERE FILED WITH THE CONSULTANT AND PAYMENT INFORMATION DESCRIBED ABOVE REQUIRED BY RULE G-38. JP MORGAN THUS FAILED TO ADOPT, MAINTAIN AND ENFORCE PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH RULE G-38. IN FACT, THERE WAS NO OVERALL SUPERVISION OF THE RULE G-38 REPORTING PROCESS, AND NO INDIVIDUAL AT THE FIRM WAS RESPONSIBLE FOR THE ©2021 FINRA. All rights reserved. Report aboutOVERSIGHT J.P. MORGAN OR SECURITIES SUPERVISION INC. OF THE COMPLETION OF THE QUARTERLY 91 REPORTS TO ENSURE THAT THE INFORMATION DISCLOSED WAS ACCURATE AND COMPLETE. (FINDINGS CONTINUED) IN ADDITION, DURING THE SAME PERIOD, THE FIRM MADE AT LEAST SIX PAYMENTS TOTALING $775,000 TO FOUR OF THE FIRM'S CONSULTANTS THAT WERE CONNECTED TO PARTICULAR MUNICIPAL SECURITIES BUSINESS. BY FAILING TO REPORT THIS INFORMATION ON MSRB FOR G-37/G-38, THE FIRM VIOLATED MSRB RULE G-38. IN ADDITION, J.P. MORGAN FAILED TO FILE ITS QUARTERLY FORM G- 37/G-38 REPORTS IN THE CORRECT FORMAT UNTIL JUNE 30, 2003. INSTEAD, THE FIRM FILED THE REPORTS ON AN OUT-OF-DATE VERSION OF THE FORM THAT DID NOT REFLECT THE APPLICABLE REPORTING REQUIREMENTS FOR RULE G-38. IN FACT, EVEN WHEN J.P. MORGAN BEGAN TO FILE ITS QUARTERLY REPORTS ON THE CORRECT FORM, IT FAILED TO ADOPT PROCEDURES, OR TO UPDATE ITS CURRENT WRITTEN PROCEDURES, TO REFLECT THE ACTUAL DISCLOSURE REQUIREMENTS OF THE RULE. IN ADDITION, THE FIRM'S WRITTEN PROCEDURES CONTAINED NO STANDARDS FOR REVIEW OF THE QUARTERLY FORM G- 37/G-38 FILINGS PRIOR TO THEIR SUBMISSION TO THE MSRB, AND THE FIRM HAD NO PROCEDURES DESIGNED TO ENSURE THAT FORMS G-37/G- 38 WERE FILED WITH THE CONSULTANT AND PAYMENT INFORMATION www.finra.org/brokercheck DESCRIBED ABOVE REQUIRED BY RULE G-38. JP MORGAN THUS FAILED User Guidance TO ADOPT, MAINTAIN AND ENFORCE PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH RULE G-38. IN FACT, THERE WAS NO OVERALL SUPERVISION OF THE RULE G-38 REPORTING PROCESS, AND NO INDIVIDUAL AT THE FIRM WAS RESPONSIBLE FOR THE OVERSIGHT OR SUPERVISION OF THE COMPLETION OF THE QUARTERLY REPORTS TO ENSURE THAT THE INFORMATION DISCLOSED WAS ACCURATE AND COMPLETE. i Reporting Source: Firm Current Status: Final Allegations: THE ALLEGATIONS RELATED TO THIS REGULATORY ACTION INVOLVE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULES G-38 AND G-27, DURING THE PERIOD FROM JANUARY 1, 2002 THROUGH JUNE 30, 2004. AS STATED IN THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") LETTER OF ACCEPTANCE, WAIVER AND CONSENT DATED DECEMBER 12, 2007, FINRA MADE THE FOLLOWING ALLEGATIONS AND FINDINGS AND J.P. MORGAN SECURITIES INC. ("JPMORGAN") ACCEPTED AND CONSENTED TO THESE ALLEGATIONS AND FINDINGS WITHOUT ADMITTING OR DENYING THEM: (1) JPMORGAN VIOLATED MSRB RULE G- 38 BY INACCURATELY REPORTING THAT NO MUNICIPAL SECURITIES BUSINESS HAD BEEN OBTAINED OR RETAINED BY ITS CONSULTANTS AND BY INACCURATELY REPORTING THAT IT HAD MADE NO PAYMENTS TO ITS CONSULTANTS CONNECTED WITH PARTICULAR MUNICIPAL SECURITIES BUSINESS, (2) JPMORGAN VIOLATED MSRB RULE G-38 BY FAILING TO FILE RULE G-38 QUARTERLY REPORTS ON THE REQUIRED FORM G-37/G-38, AND (3) JPMORGAN VIOLATED MSRB RULE G-27 BY FAILING TO ADOPT, MAINTAIN AND ENFORCE PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE REPORTING REQUIREMENTS OF MSRB RULE G-38. Initiated By: FINRA. Date Initiated: 12/12/2007 Docket/Case Number: 2005001306301

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/12/2007 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine J.P. MORGAN $500,000.00 SECURITIES INC. 92 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $500,000.00 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 $500,000. IN ADDITION, WITHIN 60 DAYS, AN OFFICER OF THE FIRM MUST CERTIFY TO FINRA THAT THE FIRM HAS REVIEWED ITS PROCEDURES REGARDING COMPLIANCE WITH MSRB RULE G-38 IN ITS CURRENT FORM AND HAS ESTABLISHED SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS PROHIBITIONS AND REPORTING REQUIREMENTS. THE FIRM ALSO MUST PROVIDE FINRA WITH A DETAILED DESCRIPTION OF THE REVIEW CONDUCTED, ITS SYSTEMS AND PROCEDURES, AND ANY CHANGES TO ITS SYSTEMS AND PROCEDURES INCLUDING A COPY OF ANY APPLICABLE WRITTEN PROCEDURES. Firm Statement THE SUBJECT EVENTS OF THIS REGULATORY ACTION ALL OCCURRED BEFORE JULY 1, 2004. AT THE TIME OF THESE EVENTS, A DIFFERENT VERSION OF THE RELEVANT MSRB RULE (MSRB RULE G-38) WAS IN EFFECT. THE NEW VERSION OF THAT RULE WAS ADOPTED IN AUGUST 2005 (AND REMAINS IN EFFECT AS THE CURRENT RULE) TO BAR THE USE OF CONSULTANTS ALTOGETHER AND END THE REGULATORY FILINGS THAT WERE AT ISSUE IN THIS ACTION. JPMORGAN SUPPORTED THE ADOPTION OF THE CURRENT RULE BARRING CONSULTANTS BEFORE IT WAS ADOPTED AND TERMINATED ALL USE OF CONSULTANTS BEFORE THAT RULE WAS IN FORCE. AS FINRA NOTED IN THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT DATED DECEMBER 12, 2007, JPMORGAN DID IN FACT DISCLOSE IN ITS MSRB FILINGS THE IDENTITIES OF THE APPROXIMATELY 40 CONSULTANTS IT USED TO COMMUNICATE WITH MUNICIPAL SECURITIES ISSUERS AND THE TOTAL AMOUNTS IT PAID TO THESE CONSULTANTS. i Disclosure 6 of 102 Reporting Source: Regulator Current Status: Final Allegations: **6/29/07**STIPULATION AND CONSENT TO PENALTY FILED BY NYSE REGULATION'S DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYING GUILT, J.P. MORGAN SECURITIES INC. CONSENTS TO FINDINGS THAT IT VIOLATED: 1. NYSE RULE 401(A) BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM FAILED TO ENSURE THE DELIVERY OF PROSPECTUSES IN CONNECTION WITH CERTAIN SALES OF REGISTERED SECURITIES IN VIOLATION OF SECTION 5(B)(2) OF THE ©2021 FINRA. All rights reserved. Report aboutSECURITIES J.P. MORGAN ACT SECURITIES OF 1933;2. INC. NYSE RULE 1100(B) BY FAILING TO DELIVER 93 PRODUCT DESCRIPTIONS TO CUSTOMERS THAT PURCHASED EXCHANGE TRADED FUNDS; AND 3. NYSE RULE 342 BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITS OPERATIONAL AND TECHNOLOGICAL ACTIVITIES RELATING TO THE DELIVERY OF PRODUCT DESCRIPTIONS AND PROSPECTUSES.STIPULATED SANCTION: THE IMPOSITION BY THE NYSE OF:1. CENSURE;2. A FINE IN THE AMOUNT OF $375,000; AND 3. AN UNDERTAKING TO PROVIDE ENFORCEMENT WITH A WRITTEN CERTIFICATION THAT ITS CURRENT POLICIES AND PROCEDURES, INCLUDING WRITTEN SUPERVISORY AND OPERATIONAL POLICIES AND PROCEDURES, REGARDING THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS ARE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND NYSE RULES APPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS. THE FIRM WILL PROVIDE ENFORCEMENT WITH THIS WRITTEN CERTIFICATION WITHIN 90 DAYS FROM THE DATE THAT A HEARING PANEL DECISION IN THIS MATTER BECOMES FINAL. **6/29/07**STIPULATION AND CONSENT TO PENALTY FILED BY NYSE REGULATION'S DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYING GUILT, J.P. MORGAN www.finra.org/brokercheck SECURITIES INC. CONSENTS TO FINDINGS THAT IT VIOLATED: User Guidance 1. NYSE RULE 401(A) BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM FAILED TO ENSURE THE DELIVERY OF PROSPECTUSES IN CONNECTION WITH CERTAIN SALES OF REGISTERED SECURITIES IN VIOLATION OF SECTION 5(B)(2) OF THE SECURITIES ACT OF 1933;2. NYSE RULE 1100(B) BY FAILING TO DELIVER PRODUCT DESCRIPTIONS TO CUSTOMERS THAT PURCHASED EXCHANGE TRADED FUNDS; AND 3. NYSE RULE 342 BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITS OPERATIONAL AND TECHNOLOGICAL ACTIVITIES RELATING TO THE DELIVERY OF PRODUCT DESCRIPTIONS AND PROSPECTUSES.STIPULATED SANCTION: THE IMPOSITION BY THE NYSE OF:1. CENSURE;2. A FINE IN THE AMOUNT OF $375,000; AND 3. AN UNDERTAKING TO PROVIDE ENFORCEMENT WITH A WRITTEN CERTIFICATION THAT ITS CURRENT POLICIES AND PROCEDURES, INCLUDING WRITTEN SUPERVISORY AND OPERATIONAL POLICIES AND PROCEDURES, REGARDING THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS ARE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND NYSE RULES APPLICABLE TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS. THE FIRM WILL PROVIDE ENFORCEMENT WITH THIS WRITTEN CERTIFICATION WITHIN 90 DAYS FROM THE DATE THAT A HEARING PANEL DECISION IN THIS MATTER BECOMES FINAL. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 06/29/2007 Docket/Case Number: HPD 07-128

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

Resolution: Decision Resolution Date: 10/04/2007 Sanctions Ordered: Censure Monetary/Fine $375,000.00 Other Sanctions Ordered: CONSENT TO CENSURE, $375,000 FINE AND UNDERTAKING. Sanction Details: **9/7/07**DECISION 07-128 ISSUED BY NYSE HEARING BOARD DECISION: J.P. MORGAN SECURITIES INC. CONSENTED TO FINDINGS THAT IT VIOLATED: 1. NYSE RULE 401(A) BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM FAILED TO ©2021 FINRA. All rights reserved. Report aboutENSURE J.P. MORGAN THE DELIVERY SECURITIES OF INC. PROSPECTUSES IN CONNECTION WITH 94 CERTAIN SALES OF REGISTERED SECURITIES IN VIOLATION OF SECTION 5(B)(2) OF THE SECURITIES ACT OF 1933; 2. NYSE RULE 1100(B) BY FAILING TO DELIVER PRODUCT DESCRIPTIONS TO CUSTOMERS THAT PURCHASED EXCHANGE TRADED FUNDS; AND 3. NYSE RULE 342 BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITS OPERATIONAL AND TECHNOLOGICAL ACTIVITIES RELATING TO THE DELIVERY OF PRODUCT DESCRIPTIONS AND PROSPECTUSES. SANCTION: CENSURE, A $375,000 FINE AND AN UNDERTAKING www.finra.org/brokercheck User Guidance **9/7/07**DECISION 07-128 ISSUED BY NYSE HEARING BOARD DECISION: J.P. MORGAN SECURITIES INC. CONSENTED TO FINDINGS THAT IT VIOLATED: 1. NYSE RULE 401(A) BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM FAILED TO ENSURE THE DELIVERY OF PROSPECTUSES IN CONNECTION WITH CERTAIN SALES OF REGISTERED SECURITIES IN VIOLATION OF SECTION 5(B)(2) OF THE SECURITIES ACT OF 1933; 2. NYSE RULE 1100(B) BY FAILING TO DELIVER PRODUCT DESCRIPTIONS TO CUSTOMERS THAT PURCHASED EXCHANGE TRADED FUNDS; AND 3. NYSE RULE 342 BY FAILING TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITS OPERATIONAL AND TECHNOLOGICAL ACTIVITIES RELATING TO THE DELIVERY OF PRODUCT DESCRIPTIONS AND PROSPECTUSES. SANCTION: CENSURE, A $375,000 FINE AND AN UNDERTAKING Regulator Statement **10/4/07** THE DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESS ON OCTOBER 2, 2007 AND THE FINE BECAME PAYABLE ON THAT SAME DATE. CONTACT: PEGGY GERMINO 212-656-8450. i Reporting Source: Firm Current Status: Final Allegations: THE NEW YORK STOCK EXCHANGE ("NYSE") ALLEGED, AND J.P. MORGAN SECURITIES, INC. ("JPMSI") NEITHER ADMITTED NOR DENIED, THAT JPMSI VIOLATED NYSE RULES 401(A) AND 1100(B) BY FAILING TO FURNISH CUSTOMERS WITH PROSPECTUSES AND PRODUCT DESCRIPTIONS IN CONNECTION WITH PURCHASES OF CERTAIN EQUITY SECURITIES AND EXCHANGE-TRADED FUNDS. ADDITIONALLY, THE NYSE ALLEGED, AND JPMSI NEITHER ADMITTED NOR DENIED, THAT JPMSI VIOLATED NYSE RULE 342 BY FAILING TO HAVE APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL RELATING TO THE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS. Initiated By: NEW YORK STOCK EXCHANGE, LLC Date Initiated: 09/07/2007 Docket/Case Number: HEARING BOARD DECISION 07-128

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): EXCHANGE-TRADED FUNDS Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE, UNDERTAKING Sought:

Resolution Date: 10/02/2007 Sanctions Ordered: Censure Monetary/Fine $375,000.00 Other Sanctions Ordered: AN UNDERTAKING TO PROVIDE THE NYSE WITH A WRITTEN CERTIFICATION THAT THE FIRM'S POLICIES AND PROCEDURES ARE REASONABLY DESIGNED TO ENSURE THE APPROPRIATE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS. Sanction Details: FINE EXPECTED TO BE PAID BY NOVEMBER 16, 2007, AND UNDERTAKING EXPECTED TO BE SATISFIED BY DECEMBER 31, 2007. i Disclosure 7 of 102 Reporting Source: Regulator Current Status: Final Allegations: **4/13/07**STIPULATION AND CONSENT TO PENALTY SENT BY DIVISION OF ENFORCEMENT TO NYSE HEARING BOARD AND PENDING. CONSENTED TO FINDINGS (WITHOUT ADMITTING OR DENYING GUILT): (1) VIOLATED SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") SECTION 15(C) AND EXCHANGE ACT RULE 15C3-1 THEREUNDER BY FAILING TO APPLY NET CAPITAL CHARGES ON AGED, UNPAIRED SUSPENSE ACCOUNT ITEMS, RESULTING IN A NET CAPITAL DEFICIENCY; (2) VIOLATED SECTION 15(C) OF THE EXCHANGE ACT AND EXCHANGE ACT RULE 15C3-3 THEREUNDER, BY IMPROPERLY COMPUTING ITS CUSTOMER RESERVE REQUIREMENT, IN THAT IT FAILED TO INCLUDE AGED, INTERNALLY UNPAIRED SUSPENSE ITEMS, RESULTING IN A RESERVE ACCOUNT DEFICIENCY; (3) VIOLATED EXCHANGE ACT RULE 17A-3 AND NYSE RULE 440, IN THAT, FOLLOWING A SYSTEM CONVERSION, CERTAIN OF THE FIRM'S BOOKS AND RECORDS WERE INACCURATE; AND (4) VIOLATED NYSE RULE 416, IN THAT THE FIRM SUBMITTED AN INACCURATE KEY OPERATIONAL INDICATOR REPORT TO THE NYSE.STIPULATION SANCTION: CENSURE AND A FINE IN THE AMOUNT OF $150,000. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 04/13/2007 Docket/Case Number: HPD#07-67

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 96 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Decision Resolution Date: 06/04/2007 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: Sanction Details: **5/3/07**DECISION ISSUE BY NYSE HEARING BOARD

DECISION: VIOLATED (1) SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") SECTION 15(C) AND EXCHANGE ACT RULE 15C3-1 THEREUNDER BY FAILING TO APPLY NET CAPITAL CHARGES ON AGED, UNPAIRED SUSPENSE ACCOUNT ITEMS, RESULTING IN A NET CAPITAL DEFICIENCY; (2) SECTION 15(C) OF THE EXCHANGE ACT AND EXCHANGE ACT RULE 15C3-3 THEREUNDER, BY IMPROPERLY COMPUTING ITS CUSTOMER RESERVE REQUIREMENT, IN THAT IT FAILED TO INCLUDE AGED, INTERNALLY UNPAIRED SUSPENSE ITEMS, RESULTING IN A RESERVE ACCOUNT DEFICIENCY; (3) EXCHANGE ACT RULE 17A-3 AND NYSE RULE 440, IN THAT, FOLLOWING A SYSTEM CONVERSION, CERTAIN OF THE FIRM'S BOOKS AND RECORDS WERE INACCURATE; AND (4) NYSE RULE 416, IN THAT THE FIRM SUBMITTED AN INACCURATE KEY OPERATIONAL INDICATOR REPORT TO THE NYSE - CONSENT TO CENSURE AND A FINE OF $150,000. Regulator Statement **6/4/07**DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESS ON MAY 28, 2007. CONTACT: PEGGY GERMINO 212-656-8450 i Reporting Source: Firm Current Status: Final Allegations: THE NYSE ALLEGED THAT WHEN THE FIRM CONVERTED ITS FIXED INCOME PROCESSING SYSTEM IN MARCH 2004, IT EXPERIENCED DIFFICULTIES RECONCILING CERTAIN ACCOUNTS, AND THEN INCORRECTLY TREATED SOME RECONCILIATION DIFFERENCES WHEN CALCULATING ITS NET CAPITAL AND CUSTOMER SERVICE ACCOUNT REQUIREMENT. AS A RESULT, THE FIRM EXPERIENCED A NET CAPITAL DEFICIENCY, VIOLATING EXCHANGE ACT SECTION 15(C)(3) AND RULE 15C3-1 THEREUNDER; EXPERIENCED A RESERVE ACCOUNT DEFICIENCY, VIOLATING EXCHANGE ACT SECTION 15(C)(3) AND RULE 15C3-3 THEREUNDER; FAILED TO MAINTAIN ACCURATE BOOKS AND RECORDS, VIOLATING EXCHANGE ACT RULE 17A-3 AND NYSE RULE 440; AND ©2021 FINRA. All rights reserved. Report aboutIMPROPERLY J.P. MORGAN NETTED SECURITIES CERTAIN INC. ITEMS IN PREPARING ITS KEOP REPORT, 97 VIOLATING NYSE RULE 416. THE NYSE ALLEGED THAT WHEN THE FIRM CONVERTED ITS FIXED INCOME PROCESSING SYSTEM IN MARCH 2004, IT EXPERIENCED DIFFICULTIES RECONCILING CERTAIN ACCOUNTS, AND THEN INCORRECTLY TREATED SOME RECONCILIATION DIFFERENCES WHEN CALCULATING ITS NET CAPITAL AND CUSTOMER SERVICE ACCOUNT REQUIREMENT. AS A RESULT, THE FIRM EXPERIENCED A NET CAPITAL www.finra.org/brokercheck DEFICIENCY, VIOLATING EXCHANGE ACT SECTION 15(C)(3) AND RULE User Guidance 15C3-1 THEREUNDER; EXPERIENCED A RESERVE ACCOUNT DEFICIENCY, VIOLATING EXCHANGE ACT SECTION 15(C)(3) AND RULE 15C3-3 THEREUNDER; FAILED TO MAINTAIN ACCURATE BOOKS AND RECORDS, VIOLATING EXCHANGE ACT RULE 17A-3 AND NYSE RULE 440; AND IMPROPERLY NETTED CERTAIN ITEMS IN PREPARING ITS KEOP REPORT, VIOLATING NYSE RULE 416. Initiated By: NEW YORK STOCK EXCHANGE, LLC Date Initiated: 04/13/2007 Docket/Case Number: HPD#07-67

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: 06/04/2007 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: Sanction Details: THE NYSE IMPOSED A CENSURE AND A FINE OF $150,000. THE FINE WAS PAID ON MAY 25, 2007. Firm Statement ON APRIL 13, 2007, THE FIRM ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY WITHOUT ADMITTING OR DENYING ANY OF THE NYSE'S ALLEGATIONS OR FINDINGS DESCRIBED ABOVE. THE NYSE IMPOSED A CENSURE AND FINE OF $150,000. i Disclosure 8 of 102 Reporting Source: Firm Current Status: Final Allegations: PRIOR TO MERGING WITH JPMSI, BOSC FROM 11/10/03 TO 11/18/05 FAILED TO TIMELY FILE FORM U5 UNIFORM TERMINATION NOTICES FOR SECURITIES INDUSTRY REGISTRATION FOR 269 INDIVIDUALS WHOSE REGISTRATIONS WERE TERMINATED, IN VIOLATION OF ART. V, SEC. 3 OF NASD BY-LAWS AND NASD CONDUCT RULE 2110. JPMSI WAS NOT ITSELF A PARTY TO THE INVESTIGATION OR SETTLEMENT. Initiated By: NASD (AGAINST BANC ONE SECURITIES CORP., WHICH MERGED INTO J.P. MORGAN SECURITIES INC. ("JPMSI") ON OR ABOUT JULY 1, 2006.

Date Initiated: 08/29/2006 Docket/Case Number: NASD -- E8A2005001601

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/31/2006 Sanctions Ordered: Censure Monetary/Fine $142,000.00 Other Sanctions Ordered: Sanction Details: THE NASD IMPOSED $142,000 IN FINES AGAINST BOSC FOR ITS LATE FORM U5 FILINGS PRIOR TO ITS MERGER WITH JPMSI. BOSC WAS RESPONSIBLE FOR PAYMENT OF THE FINES IN FULL. NO PORTION OF THE PENALTY WAS WAIVED, WHICH BOSC AGREED TO PAY VIA A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") ACCEPTED BY THE NASD ON OR ABOUT OCTOBER 31, 2006. i Disclosure 9 of 102 Reporting Source: Regulator Current Status: Final Allegations: SEC RULE 605, NASD RULES 2110, 4632(C)(6), 4642(C)(6), 5430(A)(10), 6620(A) - J.P. MORGAN SECURITIES, INC. FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES THAT THE FIRM WAS REQUIRED TO REPORT TO ACT; FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE THROUGH ACT SUCH LAST SALE REPORTS AS LATE; FAILED TO REPORT THE CORRECT TIME OF EXECUTION THROUGH THE NASDAQ MARKET CENTER IN LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET CENTER SECURITIES AND NASDAQ SMALLCAP SECURITIES FOR WHICH THE FIRM HAS RECORDING AND REPORTING OBLIGATIONS; TRANSMITTED THROUGH NASDAQ MARKET CENTER OR TRACS LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ SECURITIES AND FAILED TO DESIGNATE THORUGH NASDAQ MARKET CENTER OR ©2021 FINRA. All rights reserved. Report aboutTRACS J.P. MORGANSUCH LAST SECURITIES SALE INC.REPORTS AS REFLECTING A PRICE DIFFERENT 99 FROM THE CURRENT MARKET WHEN THE EXECUTION WAS BASED ON A PRIOR REFERENCE POINT IN TIME; THE FIRM INCORRECTLY DESIGNATED THESE TRANSACTIONS AS".T." THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH THE NASDAQ MARKET CENTER OR TRACS LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ SECURITIES THAT THE FIRM WAS REQUIRED TO REPORT TO THE NASDAQ MARKET CENTER OR TRACS; AND THE FIRM MADE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON AND THE REPORT CONTAINED INCORRECT INFORMATION AS TO THE AMOUNT OF TOTAL CANCELED SHARES. SEC RULE 605, NASD RULES 2110, 4632(C)(6), 4642(C)(6), 5430(A)(10), 6620(A) - J.P. MORGAN SECURITIES, INC. FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES THAT THE FIRM WAS REQUIRED TO REPORT TO ACT; FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE THROUGH ACT SUCH LAST SALE REPORTS AS LATE; FAILED TO REPORT THE CORRECT TIME OF EXECUTION THROUGH THE NASDAQ MARKET CENTER IN LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ www.finra.org/brokercheck NATIONAL MARKET CENTER SECURITIES AND NASDAQ SMALLCAP User Guidance SECURITIES FOR WHICH THE FIRM HAS RECORDING AND REPORTING OBLIGATIONS; TRANSMITTED THROUGH NASDAQ MARKET CENTER OR TRACS LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ SECURITIES AND FAILED TO DESIGNATE THORUGH NASDAQ MARKET CENTER OR TRACS SUCH LAST SALE REPORTS AS REFLECTING A PRICE DIFFERENT FROM THE CURRENT MARKET WHEN THE EXECUTION WAS BASED ON A PRIOR REFERENCE POINT IN TIME; THE FIRM INCORRECTLY DESIGNATED THESE TRANSACTIONS AS".T." THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH THE NASDAQ MARKET CENTER OR TRACS LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ SECURITIES THAT THE FIRM WAS REQUIRED TO REPORT TO THE NASDAQ MARKET CENTER OR TRACS; AND THE FIRM MADE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON AND THE REPORT CONTAINED INCORRECT INFORMATION AS TO THE AMOUNT OF TOTAL CANCELED SHARES. Initiated By: NASD Date Initiated: 08/10/2006 Docket/Case Number: 2005000113701

Principal Product Type: Equity - OTC Other Product Type(s): NASDAQ NATIONAL MARKET SECURITIES, SMALLCAP SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/10/2006 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $45,000.00 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 $45,000. i Reporting Source: ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 100 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: THE ALLEGATIONS RELATED TO NASD'S FINDINGS THAT DURING THE PERIOD OF MAY 1, 2004 THROUGH AUGUST 31, 2004, THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT 78 LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES, IN VIOLATION OF NASD RULE 2110. NASD ALSO FOUND THAT JPMSI FAILED TO DESIGNATE 14 LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AS LATE, IN VIOLATION OF NASD RULE 6620(A). NASD ALSO FOUND THAT DURING THE PERIOD OF SEPTEMBER 1, 2004 THROUGH DECEMBER 31, 2004, THE FIRM FAILED TO REPORT THE CORRECT TIME OF EXECUTION THROUGH THE NASDAQ MARKET CENTER IN 861 LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET AND 8 LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ SMALLCAP SECURITIES, IN VIOLATION OF NASD RULE 4632(C)(6) AND 4642(C)(6). NASD FOUND THAT JPMSI FAILED TO DESIGNATE 869 LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ SECURITIES AS REFLECTING A PRICE DIFFERENT FROM THE CURRENT MARKET WHEN THE EXECUTION WAS BASED ON A PRIOR REFERENCE POINT IN TIME, AND INCORRECTLY DESIGNATED SUCH REPORTS AS ".T," IN VIOLATION OF NASD RULE 5430(A)(10). NASD FOUND THAT THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH THE NASDAQ MARKET CENTER OR TRACS LAST SALE REPORTS OF 1,082 TRANSACTIONS IN NASDAQ SECURITIES, IN VIOLATION OF NASD RULE 2110. NASD FOUND THAT THE FIRM MADE AVAILABLE A REPORT ON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVED FOR EXECUTION FROM ANY PERSON, WHICH REPORT INCLUDED, FOR ONE MARCH 2005, INCORRECT INFORMATION AS TO THE AMOUNT OF TOTAL CANCELED SHARES, IN VIOLATION OF SEC RULE 605. Initiated By: NASD Date Initiated: 08/10/2006 Docket/Case Number: 20050001137-01

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief $45,000 FINE Sought:

Resolution Date: 08/10/2006 Sanctions Ordered: Censure Monetary/Fine $45,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND $45,000 FINE. Firm Statement THE FIRM ACCEPTED AND CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS, AND SOLELY FOR THE PURPOSES OF THIS PROCEEDING AND ANY OTHER PROCEEDING BROUGHT BY OR ON BEHALF OF NASD, OR TO WHICH NASD IS A PARTY, PRIOR TO A HEARING AND WITHOUT AN ADJUDICATION OF ANY ISSUE OF LAW OR FACT, TO THE ENTRY OF THE FINDINGS DESCRIBED ABOVE AND CONSENTED TO THE IMPOSITION OF THE $45,000 FINE AND A CENSURE. i Disclosure 10 of 102 Reporting Source: Regulator Current Status: Final Allegations: **6/23/06**EVENT: STIPULATION AND CONSENT TO PENALTY FILED BY THE DIVISION OF ENFORCEMENT AND PENDING. CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT, J. P. MORGAN SECURITIES INC. CONSENTS TO FINDINGS BY A HEARING PANEL OR HEARING OFFICER ACTING ALONE THAT IT: 1. VIOLATED RULE 10A-1 OF THE EXCHANGE ACT AND NYSE RULES 440B(A), 440B.13, 440B.20 AND 410A BY ERRONEOUSLY EXECUTING SELL ORDERS ON A MINUS TICK FOR SECURITIES IN WHICH THE FIRM HELD A SHORT POSITION, BY FAILING TO ACCURATELY MARK SELL ORDERS AS EITHER LONG, SHORT OR SHORT EXEMPT, BY ERRONEOUSLY MISMARKING SELL ORDERS AS SHORT EXEMPT, AND BY SUBMITTING INACCURATE TRADING INFORMATION THAT CAUSED CERTAIN SHORT SALES TO BE REPORTED AS LONG AND CERTAIN LONG SALES TO BE REPORTED AS SHORT. 2. VIOLATED RULE 200(F) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT UTILIZED INDEPENDENT TRADING UNIT AGGREGATION TO DETERMINE ITS NET POSITION WHEN IT DID NOT HAVE AN ADEQUATE WRITTEN PLAN OF ORGANIZATION. 3. VIOLATED RULE 200(G) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT FAILED TO ENSURE THAT ALL SELL ORDERS WERE PROPERLY MARKED AS "LONG" "SHORT" OR "SHORT EXEMPT." 4. VIOLATED RULE 203(A) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT EFFECTED CUSTOMER AND/OR PROPRIETARY SALES PURSUANT TO ORDERS MARKED LONG WHEN IT DID NOT KNOW OR HAVE REASONABLE GROUNDS TO BELIEVE: A. THAT IT WOULD BE ABLE TO DELIVER THE SECURITY ON THE DATE THE DELIVERY WAS DUE; AND B. THAT ITS CUSTOMERS WERE NOT MISREPRESENTING SHORT SALES AS ©2021 FINRA. All rights reserved. Report aboutLONG J.P. SALES. MORGAN 5. SECURITIES VIOLATED INC. RULE 203(B)(1) OF REGULATION SHO UNDER 102 THE EXCHANGE ACT IN THAT IT EFFECTED SHORT SALE ORDERS WITHOUT HAVING REASONABLE GROUNDS TO BELIEVE THAT THE SECURITIES COULD BE BORROWED SO THAT THEY COULD BE DELIVERED ON THE DATES DELIVERY WAS DUE. **CONTINUED IN 13C** **6/23/06**EVENT: STIPULATION AND CONSENT TO PENALTY FILED BY THE DIVISION OF ENFORCEMENT AND PENDING. CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT, J. P. MORGAN SECURITIES INC. CONSENTS TO FINDINGS BY A HEARING PANEL OR HEARING OFFICER ACTING ALONE THAT IT: 1. VIOLATED RULE 10A-1 OF THE EXCHANGE ACT AND NYSE RULES 440B(A), 440B.13, 440B.20 AND 410A BY ERRONEOUSLY EXECUTING SELL ORDERS ON A MINUS TICK FOR SECURITIES IN WHICH THE FIRM HELD A SHORT POSITION, BY FAILING TO ACCURATELY MARK SELL ORDERS AS EITHER LONG, SHORT OR SHORT EXEMPT, BY ERRONEOUSLY MISMARKING SELL ORDERS AS SHORT EXEMPT, AND BY SUBMITTING INACCURATE TRADING INFORMATION THAT CAUSED CERTAIN SHORT SALES TO BE REPORTED AS LONG AND CERTAIN LONG SALES TO BE REPORTED AS SHORT. 2. VIOLATED RULE 200(F) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT UTILIZED INDEPENDENT TRADING UNIT AGGREGATION TO DETERMINE ITS NET POSITION WHEN IT DID NOT HAVE AN ADEQUATE WRITTEN PLAN OF ORGANIZATION. 3. VIOLATED RULE 200(G) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT FAILED TO ENSURE THAT ALL SELL ORDERS WERE PROPERLY MARKED AS "LONG" "SHORT" OR "SHORT EXEMPT." 4. VIOLATED RULE 203(A) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT EFFECTED CUSTOMER AND/OR PROPRIETARY SALES www.finra.org/brokercheck PURSUANT TO ORDERS MARKED LONG WHEN IT DID NOT KNOW OR HAVE User Guidance REASONABLE GROUNDS TO BELIEVE: A. THAT IT WOULD BE ABLE TO DELIVER THE SECURITY ON THE DATE THE DELIVERY WAS DUE; AND B. THAT ITS CUSTOMERS WERE NOT MISREPRESENTING SHORT SALES AS LONG SALES. 5. VIOLATED RULE 203(B)(1) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT EFFECTED SHORT SALE ORDERS WITHOUT HAVING REASONABLE GROUNDS TO BELIEVE THAT THE SECURITIES COULD BE BORROWED SO THAT THEY COULD BE DELIVERED ON THE DATES DELIVERY WAS DUE. **CONTINUED IN 13C** Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 06/23/2006 Docket/Case Number: HPD# 06-139

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

Resolution: Decision Resolution Date: 08/29/2006 Sanctions Ordered: Censure Monetary/Fine $400,000.00 Other Sanctions Ordered: Sanction Details: **7/21/06** NYSE HEARING BOARD DECISION 06-139 ISSUED DECISION:VIOLATED NYSE RULE 10A-1 OF SECURITIES EXCHANGE ACT OF 1934 AND NYSE RULES 440B(A), 440B.13, 440B.20 AND 410A (A) BY ERRONEOUSLY EXECUTING SELL ORDERS ON MINUS TICK FOR SECURITIES IN WHICH A SHORT POSITION WAS HELD, (B) BY FAILING TO ACCURATELY MARK SELL ORDERS AS EITHER LONG, SHORT, OR SHORT EXEMPT, (C) BY ERRONEOUSLY MISMARKING SELL ORDERS AS SHORT EXEMPT, AND (D) BY SUBMITTING INACCURATE TRADING INFORMATION THAT CAUSED CERTAIN SHORT SALES TO BE REPORTED AS LONG AND CERTAIN LONG SALES TO BE REPORTED AS SHORT; VIOLATED RULE 200(F) OF REGULATION SHO UNDER SECURITIES EXCHANGE ACT OF 1934 BY UTILIZING INDEPENDENT TRADING UNIT AGGREGATION TO DETERMINE NET POSITION WHEN IT DID NOT HAVE ADEQUATE WRITTEN PLAN OF ORGANIZATION; VIOLATED RULE 200(G) OF REGULATION SHO BY FAILING TO ENSURE THAT ALL SELL ORDERS WERE PROPERLY MARKED AS "LONG," "SHORT," OR "SHORT EXEMPT," VIOLATED RULE 203(A) OF REGULATION SHO BY EFFECTING CUSTOMER AND/OR PROPRIETARY SALES PURSUANT TO ORDERS MARKED LONG WHEN IT DID NOT KNOW OR HAVE REASONABLE GROUNDS TO BELIEVE (A) THAT IT WOULD BE ©2021 FINRA. All rights reserved. Report aboutABLE J.P. TO MORGAN DELIVER SECURITIES SECURITY INC. ON DATE DELIVERY WAS DUE, AND (B) THAT 103 ITS CUSTOMERS WERE NOT MISREPRESENTING SHORT SALES AS LONG SALES; VIOLATED RULE 203(B)(1) OF REGULATION SHO BY EFFECTING SHORT SALE ORDERS WITHOUT HAVING REASONABLE GROUNDS TO BELIEVE THAT SECURITIES COULD BE BORROWED SO THAT THEY COULD BE DELIVERED ON DATES DELIVERY WAS DUE; VIOLATED SECTION 17(A) OF SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3 THEREUNDER AND NYSE RULES 123 AND 440 IN THAT FIRM'S BOOKS AND RECORDS DID NOT ACCURATELY CAPTURE TRADING DATA RESULTING FROM SHORT SALE ORDERS AND THE FIRM FAILED TO REPORT TRADES TO NYSE IN TIMELY FASHION AND RETAIN RECORDS OF ERROR TRANSACTIONS;**CONTINUED AT #14** **7/21/06** NYSE HEARING BOARD DECISION 06-139 ISSUED DECISION:VIOLATED NYSE RULE 10A-1 OF SECURITIES EXCHANGE ACT OF 1934 AND NYSE RULES 440B(A), 440B.13, 440B.20 AND 410A (A) BY ERRONEOUSLY EXECUTING SELL ORDERS ON MINUS TICK FOR SECURITIES IN WHICH A SHORT POSITION WAS HELD, (B) BY FAILING TO ACCURATELY MARK SELL ORDERS AS EITHER LONG, SHORT, OR SHORT EXEMPT, (C) BY ERRONEOUSLY MISMARKING SELL ORDERS AS SHORT EXEMPT, AND (D) BY SUBMITTING INACCURATE TRADING INFORMATION THAT CAUSED CERTAIN SHORT SALES TO BE REPORTED AS LONG AND CERTAIN LONG SALES TO BE REPORTED AS SHORT; VIOLATED RULE 200(F) OF REGULATION SHO UNDER SECURITIES EXCHANGE ACT OF 1934 BY UTILIZING INDEPENDENT TRADING UNIT AGGREGATION TO DETERMINE NET POSITION WHEN IT DID NOT HAVE ADEQUATE WRITTEN PLAN OF ORGANIZATION; VIOLATED RULE 200(G) OF REGULATION SHO BY FAILING www.finra.org/brokercheck TO ENSURE THAT ALL SELL ORDERS WERE PROPERLY MARKED AS User Guidance "LONG," "SHORT," OR "SHORT EXEMPT," VIOLATED RULE 203(A) OF REGULATION SHO BY EFFECTING CUSTOMER AND/OR PROPRIETARY SALES PURSUANT TO ORDERS MARKED LONG WHEN IT DID NOT KNOW OR HAVE REASONABLE GROUNDS TO BELIEVE (A) THAT IT WOULD BE ABLE TO DELIVER SECURITY ON DATE DELIVERY WAS DUE, AND (B) THAT ITS CUSTOMERS WERE NOT MISREPRESENTING SHORT SALES AS LONG SALES; VIOLATED RULE 203(B)(1) OF REGULATION SHO BY EFFECTING SHORT SALE ORDERS WITHOUT HAVING REASONABLE GROUNDS TO BELIEVE THAT SECURITIES COULD BE BORROWED SO THAT THEY COULD BE DELIVERED ON DATES DELIVERY WAS DUE; VIOLATED SECTION 17(A) OF SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3 THEREUNDER AND NYSE RULES 123 AND 440 IN THAT FIRM'S BOOKS AND RECORDS DID NOT ACCURATELY CAPTURE TRADING DATA RESULTING FROM SHORT SALE ORDERS AND THE FIRM FAILED TO REPORT TRADES TO NYSE IN TIMELY FASHION AND RETAIN RECORDS OF ERROR TRANSACTIONS;**CONTINUED AT #14** Regulator Statement **8/29/06** DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY. CONTACT: PEGGY GERMINO 212-656-8450 i Reporting Source: Firm Current Status: Final Allegations: EVENT: STIPULATION AND CONSENT TO PENALTY FILED BY THE DIVISION OF ENFORCEMENT ON 6/23/2006 AND ACCEPTED BY HEARING PANEL ON 7/21/2006. CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT, J. P. MORGAN SECURITIES INC. CONSENTS TO FINDINGS BY A HEARING PANEL OR HEARING OFFICER ACTING ALONE THAT IT: 1. VIOLATED RULE 10A-1 OF THE EXCHANGE ACT AND NYSE RULES 440B(A), 440B.13, 440B.20 AND 410A BY ERRONEOUSLY EXECUTING SELL ORDERS ON A MINUS TICK FOR SECURITIES IN WHICH THE FIRM HELD A SHORT POSITION, BY FAILING TO ACCURATELY MARK SELL ORDERS AS EITHER LONG, SHORT OR SHORT EXEMPT, BY ERRONEOUSLY MISMARKING SELL ORDERS AS SHORT EXEMPT, AND BY SUBMITTING INACCURATE TRADING INFORMATION THAT CAUSED CERTAIN SHORT SALES TO BE REPORTED AS LONG AND CERTAIN LONG SALES TO BE REPORTED AS SHORT. 2. VIOLATED RULE 200(F) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT UTILIZED INDEPENDENT TRADING UNIT AGGREGATION TO DETERMINE ITS NET POSITION WHEN IT DID NOT HAVE AN ADEQUATE WRITTEN PLAN OF ORGANIZATION. 3. VIOLATED RULE 200(G) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT FAILED TO ENSURE THAT ALL SELL ORDERS WERE PROPERLY MARKED AS "LONG" "SHORT" OR "SHORT EXEMPT." 4. VIOLATED RULE 203(A) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT EFFECTED CUSTOMER AND/OR PROPRIETARY SALES PURSUANT TO ORDERS MARKED LONG WHEN IT DID NOT KNOW OR HAVE REASONABLE GROUNDS TO BELIEVE: A. THAT IT WOULD BE ABLE TO DELIVER THE SECURITY ON THE DATE THE DELIVERY WAS DUE; AND B. THAT ITS ©2021 FINRA. All rights reserved. Report aboutCUSTOMERS J.P. MORGAN WERE SECURITIES NOT MISREPRESENTINGINC. SHORT SALES AS LONG 104 SALES. 5. VIOLATED RULE 203(B)(1) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT EFFECTED SHORT SALE ORDERS WITHOUT HAVING REASONABLE GROUNDS TO BELIEVE THAT THE SECURITIES COULD BE BORROWED SO THAT THEY COULD BE DELIVERED ON THE DATES DELIVERY WAS DUE. **CONTINUED IN 13C** EVENT: STIPULATION AND CONSENT TO PENALTY FILED BY THE DIVISION OF ENFORCEMENT ON 6/23/2006 AND ACCEPTED BY HEARING PANEL ON 7/21/2006. CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT, J. P. MORGAN SECURITIES INC. CONSENTS TO FINDINGS BY A HEARING PANEL OR HEARING OFFICER ACTING ALONE THAT IT: 1. VIOLATED RULE 10A-1 OF THE EXCHANGE ACT AND NYSE RULES 440B(A), 440B.13, 440B.20 AND 410A BY ERRONEOUSLY EXECUTING SELL ORDERS ON A MINUS TICK FOR SECURITIES IN WHICH THE FIRM HELD A SHORT POSITION, BY FAILING TO ACCURATELY MARK SELL ORDERS AS EITHER LONG, SHORT OR SHORT EXEMPT, BY ERRONEOUSLY MISMARKING SELL ORDERS AS SHORT EXEMPT, AND BY SUBMITTING INACCURATE TRADING INFORMATION THAT CAUSED CERTAIN SHORT SALES TO BE REPORTED AS LONG AND CERTAIN LONG SALES TO BE REPORTED AS SHORT. 2. VIOLATED RULE 200(F) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT UTILIZED INDEPENDENT TRADING UNIT AGGREGATION TO DETERMINE ITS NET POSITION WHEN IT DID NOT HAVE AN ADEQUATE WRITTEN PLAN OF ORGANIZATION. 3. VIOLATED RULE 200(G) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT FAILED TO ENSURE THAT ALL SELL ORDERS WERE PROPERLY MARKED AS "LONG" "SHORT" OR "SHORT EXEMPT." 4. VIOLATED RULE 203(A) OF www.finra.org/brokercheck REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT EFFECTED User Guidance CUSTOMER AND/OR PROPRIETARY SALES PURSUANT TO ORDERS MARKED LONG WHEN IT DID NOT KNOW OR HAVE REASONABLE GROUNDS TO BELIEVE: A. THAT IT WOULD BE ABLE TO DELIVER THE SECURITY ON THE DATE THE DELIVERY WAS DUE; AND B. THAT ITS CUSTOMERS WERE NOT MISREPRESENTING SHORT SALES AS LONG SALES. 5. VIOLATED RULE 203(B)(1) OF REGULATION SHO UNDER THE EXCHANGE ACT IN THAT IT EFFECTED SHORT SALE ORDERS WITHOUT HAVING REASONABLE GROUNDS TO BELIEVE THAT THE SECURITIES COULD BE BORROWED SO THAT THEY COULD BE DELIVERED ON THE DATES DELIVERY WAS DUE. **CONTINUED IN 13C** Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 06/23/2006 Docket/Case Number: 06-139

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

Resolution: Stipulation and Consent Resolution Date: 07/21/2006 Sanctions Ordered: Censure Monetary/Fine $400,000.00 Other Sanctions Ordered: Sanction Details: **CONTINUED FROM 7** 6. VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER AND NYSE RULES 123 AND 440 IN THAT THE FIRM'S BOOKS AND RECORDS WERE INADEQUATE BECAUSE THEY DID NOT ACCURATELY CAPTURE TRADING DATA RESULTING FROM SHORT SALE ORDERS, AND BECAUSE THE FIRM FAILED TO REPORT TRADES TO THE NYSE IN A TIMELY FASHION AND RETAIN RECORDS OF ERROR TRANSACTIONS. 7. VIOLATED NYSE RULE 123C BY FAILING TO COMPLY WITH REQUIREMENTS GOVERNING THE ENTRY AND CANCELLATION OF MARKET-ON-CLOSE AND LIMIT-ON-CLOSE ORDERS. 8. VIOLATED NYSE RULE 476(A)(11) BY FAILING TO TIMELY AND ACCURATELY FILE DAILY PROGRAM TRADING REPORTS. 9. VIOLATED NYSE RULE 342 IN THAT IT FAILED TO ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES FOR SUPERVISION AND CONTROL INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW FOR COMPLIANCE WITH REGULATION SHO, RULE 10A-1 UNDER THE EXCHANGE ACT, NYSE RULES 440B ET SEQ. AND NYSE RULES RELATING TO THE ENTRY AND CANCELLATION OF MARKET- ON-CLOSE AND LIMIT-ON-CLOSE ORDERS. STIPULATED SANCTION: THE IMPOSITION BY THE NYSE OF A CENSURE AND A FINE IN THE AMOUNT OF ©2021 FINRA. All rights reserved. Report about$400,000. J.P. MORGAN SECURITIES INC. 105 **CONTINUED FROM 7** 6. VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER AND NYSE RULES 123 AND 440 IN THAT THE FIRM'S BOOKS AND RECORDS WERE INADEQUATE BECAUSE THEY DID NOT ACCURATELY CAPTURE TRADING DATA RESULTING FROM SHORT SALE ORDERS, AND BECAUSE THE FIRM FAILED TO REPORT TRADES TO THE NYSE IN A TIMELY FASHION AND RETAIN RECORDS OF ERROR TRANSACTIONS. 7. VIOLATED NYSE RULE 123C BY FAILING TO COMPLY WITH REQUIREMENTS GOVERNING THE ENTRY AND CANCELLATION OF MARKET-ON-CLOSE AND LIMIT-ON-CLOSE ORDERS. 8. VIOLATED NYSE RULE 476(A)(11) BY FAILING TO TIMELY AND ACCURATELY FILE DAILY PROGRAM TRADING REPORTS. 9. VIOLATED NYSE RULE 342 IN THAT IT FAILED TO ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES FOR SUPERVISION AND CONTROL INCLUDING A SEPARATE SYSTEM OF www.finra.org/brokercheck FOLLOW-UP AND REVIEW FOR COMPLIANCE WITH REGULATION SHO, User Guidance RULE 10A-1 UNDER THE EXCHANGE ACT, NYSE RULES 440B ET SEQ. AND NYSE RULES RELATING TO THE ENTRY AND CANCELLATION OF MARKET- ON-CLOSE AND LIMIT-ON-CLOSE ORDERS. STIPULATED SANCTION: THE IMPOSITION BY THE NYSE OF A CENSURE AND A FINE IN THE AMOUNT OF $400,000. i Disclosure 11 of 102 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 33-8684, 34-53888, DATED MAY 31, 2006, THE SECURITIES AND EXCHANGE COMMISSION COMPLAINT ALLEGES THAT RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. AS PART OF ITS BROKER-DEALER BUSINESS RESPONDENT UNDERWRITE, AND MANAGE AUCTIONS FOR, AUCTION RATE SECURITIES. FROM AT LEAST JANUARY 1, 2003 THROUGH JUNE 30, 2004, IN CONNECTION WITH CERTAIN AUCTIONS, RESPONDENT ENGAGED IN ONE OR MORE OF THE FOLLOWING PRACTICES VIOLATIONS: COMPLETION OF OPEN OR MARKET BIDS, INTERVENTION IN AUCTIONS, BIDS TO PREVENT FAILED AUCTIONS, BIDS TO A SET A "MARKET" RATE, BIDS TO PREVENT ALL-HOLD AUCTIONS, PRIORITIZATION OF BIDS, SUBMISSION OR REVISION OF BIDS AFTER DEADLINES, ALLOCATION OF SECURITIES, PARTIAL ORDERS, EXPRESS OR TACTIC UNDERSTANDING TO PROVIDE HIGHER RETURNS, AND PRICE TALK. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 05/31/2006 Docket/Case Number: 3-12310

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): MUNICIPAL BONDS, CORPORATE BONDS Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CENSURE, CIVIL MONEY PENALTY Sought:

Resolution: Order Resolution Date: 05/31/2006 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 106 www.finra.org/brokercheck User Guidance

Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $1,500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THIS ORDER, RESPONDENT SHALL PROVIDE ALL OF ITS CUSTOMERS WHO HOLD AUCTION RATE SECURITIES ("HOLDERS") AND THE ISSUERS OF SUCH SECURITIES ("ISSUERS") WITH A WRITTEN DESCRIPTION OF THE RESPONDENT'S MATERIAL AUCTION PRACTICES AND PROCEDURES.

FURTHERMORE, COMMENCING NOT LATER THAN 3 MONTHS AFTER THE ENTRY OF THIS ORDER, RESPONDENT SHALL AT ALL TIMES MAKE A DESCRIPTION OF ITS THEN-CURRENT MATERIAL AUCTION PRACTICES AND PROCEDURES AVAILABLE TO (1) ALL CUSTOMERS AND BROKER- DEALERS WHO ARE PARTICIPATING THROUGH SUCH RESPONDENT IN AN AUCTION OF AUCTION RATE SECURITIES ON THE PORTION OF ITS WEBSITE THAT IS ACCESSIBLE TO SUCH CUSTOMERS AND BROKER- DEALERS AND IS RELATED TO SUCH AUCTION AND (2) THE GENERAL PUBLIC ON ANOTHER PORTION OF ITS WEBSITE ACCESSIBLE TO THE GENERAL PUBLIC. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THIS ORDER, UNLESS OTHERWISE EXTENDED BY THE STAFF OF THE COMMISSION FOR GOOD CAUSE SHOWN, RESPONDENT'S CHIEF EXECUTIVE OFFICER OR GENERAL COUNSEL SHALL CERTIFY IN WRITING TO THE STAFF OF THE COMMISSION THAT RESPONDENT HAS IMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TO PREVENT AND DETECT FAILURES BY RESPONDENT TO CONDUCT THE AUCTION PROCESS IN ACCORDANCE WITH THE AUCTION PROCEDURES DISCLOSED IN THE DISCLOSURE DOCUMENTS AND ANY SUPPLEMENTAL DISCLOSURES AND THAT THE RESPONDENT IS IN COMPLIANCE WITH SECTION IV.E. OF THIS ORDER. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT CONSENTED TO THE ENTRY OF THIS ORDER; ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIES ACT AND SECTION 15(B) OF THE EXCHANGE ACT, IS ORDERED THAT RESPONDENT IS CENSURED, SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT; AND SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY OF $1,500,000 TO THE UNITED STATES TREASURY.

i Reporting Source: Firm Current Status: Final Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 33-8684, 34-53888, DATED MAY 31, 2006, THE SECURITIES AND EXCHANGE COMMISSION COMPLAINT ALLEGES THAT RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. AS PART OF ITS BROKER-DEALER BUSINESS RESPONDENT UNDERWRITE, AND MANAGE AUCTIONS FOR, AUCTION RATE SECURITIES. FROM AT LEAST JANUARY 1, 2003 THROUGH JUNE 30, 2004, IN CONNECTION WITH CERTAIN AUCTIONS, RESPONDENT ENGAGED IN ONE OR MORE OF THE FOLLOWING PRACTICES VIOLATIONS: COMPLETION OF OPEN OR MARKET BIDS, INTERVENTION IN AUCTIONS, BIDS TO PREVENT FAILED AUCTIONS, BIDS TO A SET A "MARKET" RATE, BIDS TO PREVENT ALL-HOLD AUCTIONS, PRIORITIZATION OF BIDS, SUBMISSION OR REVISION OF BIDS AFTER DEADLINES, ALLOCATION OF SECURITIES, PARTIAL ORDERS, EXPRESS OR TACTIC UNDERSTANDING TO PROVIDE HIGHER RETURNS, AND PRICE TALK. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 05/31/2006 Docket/Case Number: 3-12310

Principal Product Type: Other Other Product Type(s): MUNICIPAL SECURITIES: ASSED-BACKED SECURITIES Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CENSURE, CIVIL MONEY PENALTY Sought:

Resolution: Order Resolution Date: 05/31/2006 Sanctions Ordered: Censure Monetary/Fine $1,500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THIS ORDER, RESPONDENT SHALL PROVIDE ALL OF ITS CUSTOMERS WHO HOLD AUCTION RATE SECURITIES ("HOLDERS") AND THE ISSUERS OF SUCH SECURITIES ("ISSUERS") WITH A WRITTEN DESCRIPTION OF THE RESPONDENT'S MATERIAL AUCTION PRACTICES AND PROCEDURES. FURTHERMORE, COMMENCING NOT LATER THAN 3 MONTHS AFTER THE ENTRY OF THIS ORDER, RESPONDENT SHALL AT ALL TIMES MAKE A ©2021 FINRA. All rights reserved. Report aboutDESCRIPTION J.P. MORGAN OF SECURITIES ITS THEN-CURRENT INC. MATERIAL AUCTION PRACTICES 108 AND PROCEDURES AVAILABLE TO (1) ALL CUSTOMERS AND BROKER- DEALERS WHO ARE PARTICIPATING THROUGH SUCH RESPONDENT IN AN AUCTION OF AUCTION RATE SECURITIES ON THE PORTION OF ITS WEBSITE THAT IS ACCESSIBLE TO SUCH CUSTOMERS AND BROKER- DEALERS AND IS RELATED TO SUCH AUCTION AND (2) THE GENERAL PUBLIC ON ANOTHER PORTION OF ITS WEBSITE ACCESSIBLE TO THE GENERAL PUBLIC. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THIS ORDER, UNLESS OTHERWISE EXTENDED BY THE STAFF OF THE COMMISSION FOR GOOD CAUSE SHOWN, RESPONDENT'S CHIEF EXECUTIVE OFFICER OR GENERAL COUNSEL SHALL CERTIFY IN WRITING TO THE STAFF OF THE COMMISSION THAT RESPONDENT HAS IMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TO PREVENT AND DETECT FAILURES BY RESPONDENT TO CONDUCT THE AUCTION PROCESS IN ACCORDANCE WITH THE AUCTION PROCEDURES DISCLOSED IN THE DISCLOSURE DOCUMENTS AND ANY SUPPLEMENTAL DISCLOSURES AND THAT THE RESPONDENT IS IN COMPLIANCE WITH SECTION IV.E. OF THIS ORDER. NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THIS ORDER, RESPONDENT SHALL PROVIDE ALL OF ITS CUSTOMERS WHO HOLD www.finra.org/brokercheck AUCTION RATE SECURITIES ("HOLDERS") AND THE ISSUERS OF SUCH User Guidance SECURITIES ("ISSUERS") WITH A WRITTEN DESCRIPTION OF THE RESPONDENT'S MATERIAL AUCTION PRACTICES AND PROCEDURES. FURTHERMORE, COMMENCING NOT LATER THAN 3 MONTHS AFTER THE ENTRY OF THIS ORDER, RESPONDENT SHALL AT ALL TIMES MAKE A DESCRIPTION OF ITS THEN-CURRENT MATERIAL AUCTION PRACTICES AND PROCEDURES AVAILABLE TO (1) ALL CUSTOMERS AND BROKER- DEALERS WHO ARE PARTICIPATING THROUGH SUCH RESPONDENT IN AN AUCTION OF AUCTION RATE SECURITIES ON THE PORTION OF ITS WEBSITE THAT IS ACCESSIBLE TO SUCH CUSTOMERS AND BROKER- DEALERS AND IS RELATED TO SUCH AUCTION AND (2) THE GENERAL PUBLIC ON ANOTHER PORTION OF ITS WEBSITE ACCESSIBLE TO THE GENERAL PUBLIC. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THIS ORDER, UNLESS OTHERWISE EXTENDED BY THE STAFF OF THE COMMISSION FOR GOOD CAUSE SHOWN, RESPONDENT'S CHIEF EXECUTIVE OFFICER OR GENERAL COUNSEL SHALL CERTIFY IN WRITING TO THE STAFF OF THE COMMISSION THAT RESPONDENT HAS IMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TO PREVENT AND DETECT FAILURES BY RESPONDENT TO CONDUCT THE AUCTION PROCESS IN ACCORDANCE WITH THE AUCTION PROCEDURES DISCLOSED IN THE DISCLOSURE DOCUMENTS AND ANY SUPPLEMENTAL DISCLOSURES AND THAT THE RESPONDENT IS IN COMPLIANCE WITH SECTION IV.E. OF THIS ORDER. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT CONSENTED TO THE ENTRY OF THIS ORDER; ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIES ACT AND SECTION 15(B) OF THE EXCHANGE ACT, IS ORDERED THAT RESPONDENT IS CENSURED, SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT; AND SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY OF $1,500,000 TO THE UNITED STATES TREASURY. i Disclosure 12 of 102 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010, 4632, 4632(A)(9), 6130(D), 6420, 6420(A), 6420(C)(4), 6620 - RESPONDENT MEMBER TRASMITTED THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET (NNM) SECURITIES AND FAILED TO DESIGNATE THROUGH ACT SUCH LAST SALE REPORTS AS REFLECTING A PRICE DIFFERENT FROM THE CURRENT MARKET WHEN THE EXECUTION WAS BASED ON A PRIOR REFERENCE POINT IN TIME. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT THROUGH ACT THE CORRECT SYMBOL INDICATING WHETHER THE TRANSACTION WAS A BUY, SELL OR CROSS IN LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE SECURITIES. NASD FOUND THAT THE FIRM FAILED, WHITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE ©2021 FINRA. All rights reserved. Report aboutSECURITIES J.P. MORGAN AND SECURITIES FAILED INC.TO DESIGNATE TRHOUGH ACT SUCH LAST SALE 109 REPORTS AS LATE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER IT EXECUTED TRANSACTIONS IN ELIGIBLE SECURITIES IN A PRINCIPAL OR AGENCY CAPACITY. IN ADDITION, THE FINDINGS STATED THAT THE FIRM REPORTED THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET SECURITIES, ELIGIBLE SECURITIES AND IN OTC EQUITY SECURITIES IT WAS NOT REQUIRED TO REPORT. NASD ALSO FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD CONCERNING ACT REPORTING AND TRADE REPORTING. NASD RULES 2110, 3010, 4632, 4632(A)(9), 6130(D), 6420, 6420(A), 6420(C)(4), 6620 - RESPONDENT MEMBER TRASMITTED THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET (NNM) SECURITIES AND FAILED TO DESIGNATE THROUGH ACT SUCH LAST SALE REPORTS AS REFLECTING A PRICE DIFFERENT FROM THE CURRENT MARKET WHEN THE EXECUTION WAS BASED ON A PRIOR REFERENCE POINT IN TIME. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT www.finra.org/brokercheck THROUGH ACT THE CORRECT SYMBOL INDICATING WHETHER THE User Guidance TRANSACTION WAS A BUY, SELL OR CROSS IN LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE SECURITIES. NASD FOUND THAT THE FIRM FAILED, WHITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE SECURITIES AND FAILED TO DESIGNATE TRHOUGH ACT SUCH LAST SALE REPORTS AS LATE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER IT EXECUTED TRANSACTIONS IN ELIGIBLE SECURITIES IN A PRINCIPAL OR AGENCY CAPACITY. IN ADDITION, THE FINDINGS STATED THAT THE FIRM REPORTED THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET SECURITIES, ELIGIBLE SECURITIES AND IN OTC EQUITY SECURITIES IT WAS NOT REQUIRED TO REPORT. NASD ALSO FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD CONCERNING ACT REPORTING AND TRADE REPORTING. Initiated By: NASD Date Initiated: 01/09/2006 Docket/Case Number: 2004200015901

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: 01/09/2006 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 $115,000.00 Other Sanctions Ordered: UNDERTAKING: REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD CONCERNING THE AUTOMATED AUTOMATED CONFIRMATION TRANSACTION SERVICE (ACT) REPORTING AND TRADE REPORTING. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN ©2021 FINRA. All rights reserved. Report aboutSECURITIES J.P. MORGAN INC., SECURITIES CONSENTED INC. TO THE DESCRIBED SANCTIONS AND TO 110 THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED $115,000. www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN SECURITIES INC., CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED $115,000. i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGES THAT JPMSI VIOLATED NASD RULES 2110, 3010, 4632, 4632(A)(9), 6130(D), 6420, 6420(A), 6420(C)(4), 6620. NASD ALLEGES THAT JPMSI TRASMITTED THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET (NNM) SECURITIES AND FAILED TO DESIGNATE THROUGH ACT SUCH LAST SALE REPORTS AS REFLECTING A PRICE DIFFERENT FROM THE CURRENT MARKET WHEN THE EXECUTION WAS BASED ON A PRIOR REFERENCE POINT IN TIME. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT THROUGH ACT THE CORRECT SYMBOL INDICATING WHETHER THE TRANSACTION WAS A BUY, SELL OR CROSS IN LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE SECURITIES. NASD FOUND THAT THE FIRM FAILED, WHITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE SECURITIES AND FAILED TO DESIGNATE THROUGH ACT SUCH LAST SALE REPORTS AS LATE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER IT EXECUTED TRANSACTIONS IN ELIGIBLE SECURITIES IN A PRINCIPAL OR AGENCY CAPACITY. IN ADDITION, THE FINDINGS STATED THAT THE FIRM REPORTED THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET SECURITIES, ELIGIBLE SECURITIES AND IN OTC EQUITY SECURITIES IT WAS NOT REQUIRED TO REPORT. NASD ALSO FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD CONCERNING ACT REPORTING AND TRADE REPORTING. Initiated By: NASD Date Initiated: 01/09/2006 Docket/Case Number: 20042000159-01

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE ©2021Sought: FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 111 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/09/2006 Sanctions Ordered: Censure Monetary/Fine $115,000.00 Other Sanctions Ordered: UNDERTAKING: JPMSI IS REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD CONCERNING THE AUTOMATED CONFIRMATION TRANSACTION SERVICE (ACT) REPORTING AND TRADE REPORTING. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN SECURITIES INC., CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED $115,000. i Disclosure 13 of 102 Reporting Source: Regulator Current Status: Final Allegations: MEMBER FIRM VIOLATED PCXE RULE 7.23(A)(1) WHEN IT FAILED TO MAINTAIN CONTINUOUS TWO-SIDED Q ORDERS FOR ISSUES IN WHICH IT IS REGISTERED AS A MARKET MAKER. Initiated By: PACIFIC STOCK EXCHANGE Date Initiated: 08/01/2004 Docket/Case Number: 05-25

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: Decision & Order of Offer of Settlement Resolution Date: 09/08/2005 Does the order constitute a No final order based on ©2021violations FINRA. of All any rights laws reserved. or Report about J.P. MORGAN SECURITIES INC. 112 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 $6,000.00 Other Sanctions Ordered: Sanction Details: $6,000.00 FINE LEVIED AGAINST J.P. MORGAN SECURITIES WAS PAID ON MAY 19, 2005. i Reporting Source: Firm Current Status: Final Allegations: PACIFIC EXCHANGE, INC. ALLEGES THAT J.P. MORGAN SECURITIES INC. ("JPMSI") VIOLATED RULE 7.23(A)(1) IN THAT JPMSI FAILED ON NUMEROUS OCCASIONS TO MAINTAIN CONTINUOUS, TWO-SIDED Q ORDERS IN NUMEROUS SECURITIES IN WHICH JPMSI WAS REGISTERED TO TRADE AS A MARKET MAKER. Initiated By: PACIFIC EXCHANGE, INC. Date Initiated: 05/18/2005 Docket/Case Number: #05-25; #33742,33760,33802,33839,33892

Resolution: Settled Resolution Date: 06/14/2005 Sanctions Ordered: Monetary/Fine $6,000.00 Other Sanctions Ordered: Sanction Details: JPMSI CONSENTED TO A FINE OF $6,000. i Disclosure 14 of 102 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 113 www.finra.org/brokercheck User Guidance

Disclosure 14 of 102 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULES G-27, G-36 - RESPONDENT MEMBER FAILED TO TIMELY SUBMIT OFFICIAL STATEMENTS AND/OR OTHER DOCUMENTS TO THE MSRB. THE FINDINGS STATED THAT THE FIRM FAILED TO ADEQUATELY MONITOR ITS UNDERWRITING FILINGS WITH THE MSRB TO ENSURE THAT ITS FILINGS WERE TIMELY AND THEREFORE IN COMPLIANCE WITH MSRB RULE G-36. Initiated By: NASD Date Initiated: 08/05/2005 Docket/Case Number: E102003026501

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: 08/05/2005 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 $100,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN SECURITIES, INC., CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED $100,000. i Reporting Source: Firm

Current Status: Final Allegations: FAILURE TO COMPLY WITH MUNICIPAL SECURITIES RULE BOARD ("MSRB") RULE G-36 IN CONNECTION WITH THE SUBMISSION OF OFFERING STATEMENTS TO THE MSRB ON OFFERINGS WHERE J.P. MORGAN ACTED AS UNDERWRITER, AND FAILURE TO ADEQUATELY MONITOR ITS UNDERWRITING FILINGS IN COMPLIANCE WITH MSRB RULE G-27. J.P. MORGAN ACCEPTED AND CONSENTED TO THESE FINDINGS WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS. Initiated By: NASD Date Initiated: 08/05/2005 Docket/Case Number: AWC# E102003026501

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $100,000.00 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/05/2005 Sanctions Ordered: Censure Monetary/Fine $100,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING LIABILITY, J.P. MORGAN ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT. i Disclosure 15 of 102 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULE G-14 AND G-27- RESPONDENT FIRM FAILED TO TIMELY REPORT ITS MUNICIPAL SECURITIES CUSTOMER AND INTER-DEALER TRANSACTIONS TO THE MSRB. THE FIRM FAILED TO MONITOR ITS TRADE REPORTING TO ENSURE COMPLIANCE WITH MSRB RULE G-14. Initiated By: NASD Date Initiated: 06/28/2005

Docket/Case Number: C10050038

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/28/2005 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $160,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $160,000 i Reporting Source: Firm Current Status: Final Allegations: FAILURE TO COMPLY WITH MSRB RULES G-14 AND G-27 BY FAILING TO TIMELY REPORT CERTAIN MUNICIPAL SECURITIES TRANSACTIONS TO THE MUNICIPAL SECURITIES RULEMAKING BOARD DURING THE PERIOD OF JANUARY 1, 2003 THROUGH OCTOBER 31, 2004. Initiated By: NASD Date Initiated: 06/28/2005 Docket/Case Number: C10050038

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 116 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $160,000.00 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/28/2005 Sanctions Ordered: Censure Monetary/Fine $160,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING LIABILITY, J.P. MORGAN ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT. i Disclosure 16 of 102 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULES 3010(A) AND (B), 2110, 2710 - J.P. MORGAN SECURITIES INC. ("J.P. MORGAN" OR THE "FIRM") VIOLATED NASD CONDUCT RULE 2110 BY FAILING TO TAKE REASONABLE STEPS TO ENSURE THAT ITS REPRESENTATIONS TO NASD, SPECIFICALLY THAT SHARES HELD BY AN AFFILIATED ENTITY WOULD NOT BE SOLD FOR SPECIFIC TIME PERIODS FROM THE EFFECTIVE DATE OF THE IPO, WOULD BE ADHERED TO. THE FIRM'S SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES CONTAINED INADEQUATE PROCEDURES FOR MONITORING RESTRICTIONS ON SALES OF SECURITIES HELD BY INDIVIDUALS ASSOCIATED WITH THE FIRM WHICH COULD NOT BE SOLD FOR SPECIFIC TIME PERIODS OF TIME PURSUANT TO NASD CONDUCT RULE 2710. J.P. MORGAN'S SUPERVISORY SYSTEM ALSO CONTAINED INADEQUATE POLICIES OR PROCEDURES FOR MONITORING RESTRICTIONS ON SALES OF SECURITIES, WHICH AN AFFILIATE HAD REPRESENTED TO NASD, WOULD NOT BE SOLD FOR SPECIFIC TIME PERIODS IN CONNECTION WITH OBTAINING APPROVAL OF THE TERMS OF AN OFFERING. Initiated By: NASD Date Initiated: 04/18/2005 Docket/Case Number: CE2050008

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 117 www.finra.org/brokercheck User Guidance

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/18/2005 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN SECURITIES INC., CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS THEREFORE, THE FIRM IS CENSURED AND FINED $150,000. i Reporting Source: Firm Current Status: Final Allegations: VIOLATION OF NASD CONDUCT RULES 2110 AND 2710(C)(7)(A)(I); VIOLATION OF NASD CONDUCT RULES 3010(A) AND (B) AND 2110. Initiated By: NASD Date Initiated: 04/18/2005 Docket/Case Number: CE2050008 - AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief A FINE OF $150,000. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/18/2005 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 118 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: Sanction Details: A CENSURE; AND A FINE OF $150,000 (PAID ON MAY 2, 2005). i Disclosure 17 of 102 Reporting Source: Regulator Current Status: Final Allegations: **12/20/2004**STIPULATION AND CONSENT TO PENALTY FILED BY NYSE DIVISION OF ENFORCEMENT CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYING GUILT, J.P. MORGAN SECURITIES, INC. CONSENTED TO FINDINGS BY THE HEARING PANEL THAT THE FIRM: (1)VIOLATED EXCHANGE RULE 440, SECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND RULE 17A-4 BY FAILING TO PRESERVE FOR A PERIOD OF THREE YEARS, THE FIRST TWO OF WHICH IN AN ACCESSIBLE PLACE, ELECTRONIC COMMUNICATIONS RELATING TO ITS BUSINESS; AND (2)VIOLATED EXCHANGE RULE 342 BY FAILING TO REASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF ITS EMPLOYEES AND BY FAILING TO ESTABLISH AN ADEQUATE SYSTEM OF FOLLOW-UP AND REVIEW TO ENSURE COMPLIANCE WITH EXCHANGE RULES AND FEDERAL SECURITIES LAWS RELATING TO THE RETENTION OF ELECTRONIC COMMUNICATIONS.STIPULATED SANCTION:THE IMPOSITION BY THE EXCHANGE OF:1.)A CENSURE;2.)A TOTAL PAYMENT OF $2,100,000; AND 3.)AN UNDERTAKING. Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT Date Initiated: 12/20/2004 Docket/Case Number: HPD#: 05-001

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

Resolution: Decision Resolution Date: 02/09/2005 Sanctions Ordered: Censure Monetary/Fine $2,100,000.00 Other Sanctions Ordered: CONSENT TO CENSURE, A TOTAL FINE IN THE AMOUNT OF $2,100,000 AND ©2021 FINRA. All rights reserved. Report aboutAN UNDERTAKING. J.P. MORGAN SECURITIES INC. 119 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: CONSENT TO CENSURE, A TOTAL FINE IN THE AMOUNT OF $2,100,000 AND AN UNDERTAKING. Sanction Details: **1/5/05**DECISION 05-1 ISSUED BY NYSE HEARING PANEL DECISION:VIOLATED EXCHANGE RULE 440, SECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND RULE 17A-4 BY FAILING TO PRESERVE FOR A PERIOD OF THREE YEARS, THE FIRST TWO OF WHICH IN AN ACCESSIBLE PLACE, ELECTRONIC COMMUNICATIONS RELATING TO ITS BUSINESS; VIOLATED EXCHANGE RULE 342 BY FAILING TO REASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF ITS EMPLOYEES AND BY FAILING TO ESTABLISH AN ADEQUATE SYSTEM OF FOLLOW-UP AND REVIEW TO ENSURE COMPLIANCE WITH EXCHANGE RULES AND FEDERAL SECURITIES LAWS RELATING TO THE RETENTION OF ELECTRONIC COMMUNICATIONS -- CONSENT TO CENSURE, A TOTAL FINE IN THE AMOUNT OF $2,100,000 AND AN UNDERTAKING. Regulator Statement **2/9/05**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY. CONTACT:MICHELE VAN TASSEL 212-656-5340 i Reporting Source: Firm Current Status: Final Allegations: THE NYSE ALLEGES THAT JPMSI VIOLATED THE RECORD-KEEPING REQUIREMENTS OF THE SECURITIES EXCHANGE ACT OF 1934, RULE 17A-4 THEREUNDER, AND EXCHANGE RULE 440 DURING THE PERIOD JULY 1, 1999 TO JUNE 30, 2002 BY FAILING TO PRESERVE FOR THREE YEARS, AND/OR TO PRESERVE IN AN ACCESSIBLE PLACE FOR TWO YEARS, ELECTRONIC MAIL COMMUNICATIONS (INCLUDING INTER-OFFICE MEMORANDA AND COMMUNICATIONS) RECEIVED AND SENT BY ITS EMPLOYEES THAT RELATED TO ITS BUSINESS AS A MEMBER OF AN EXCHANGE, BROKER, OR DEALER. THE NYSE ALSO ALLEGES THAT JPMSI LACKED ADEQUATE SYSTEMS OR PROCEDURES FOR THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS IN VIOLATION OF EXCHANGE RULE 342. Initiated By: NEW YORK STOCK EXCHANGE, INC. ("NYSE") Date Initiated: 12/16/2004 Docket/Case Number: EXCHANGE HEARING PANEL DECISION 05-1

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE, UNDERTAKING ©2021Sought: FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 120 www.finra.org/brokercheck User Guidance

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

Resolution: Stipulation and Consent Resolution Date: 02/09/2005 Sanctions Ordered: Censure Monetary/Fine $2,100,000.00 Other Sanctions Ordered: JPMSI SHALL COMPLETE AN APPROPRIATE UNDERTAKING TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE WITH EXCHANGE RULES AND FEDERAL SECURITIES LAWS. Sanction Details: CENSURE AND FINE OF $700,000.00 LEVIED AGAINST JPMSI, WHICH WAS PAID TO NYSE ON FEBRUARY 24, 2005. THE TOTAL FINE THAT JPMSI PAID WAS $2,100,000.00 ($700,000.00 PAID TO NASD; $700,000.00 PAID TO NYSE& $700,000.00 PAID TO THE TREASURY). Firm Statement THE PROCEEDING SETTLED AS FOLLOWS: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, JPMSI CONSENTED TO FINDINGS BY THE EXCHANGE HEARING PANEL. i Disclosure 18 of 102 Reporting Source: Firm Current Status: Final Allegations: THE SEC ALLEGES THAT JPMSI VIOLATED THE RECORD-KEEPING REQUIREMENTS OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-4 THEREUNDER DURING THE PERIOD JULY 1, 1999 TO JUNE 30, 2002 BY FAILING TO PRESERVE FOR THREE YEARS, AND/OR TO PRESERVE IN AN ACCESSIBLE PLACE FOR TWO YEARS, ELECTRONIC MAIL COMMUNICATIONS (INCLUDING INTER-OFFICE MEMORANDA AND COMMUNICATIONS) RECEIVED AND SENT BY ITS EMPLOYEES THAT RELATED TO ITS BUSINESS AS A MEMBER OF AN EXCHANGE, BROKER, OR DEALER. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 12/16/2004 Docket/Case Number: NO. 3-11828

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 121 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief FINE, UNDERTAKING Sought:

Resolution: Settled Resolution Date: 02/14/2005 Sanctions Ordered: Monetary/Fine $700,000.00 Cease and Desist/Injunction Other Sanctions Ordered: JPMSI SHALL COMPLETE AN APPROPRIATE UNDERTAKING TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE WITH FEDERAL SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE NYSE AND NASD. Sanction Details: CEASE AND DESIST ORDER AND CIVIL MONETARY PENALTY OF $700,000 LEVIED AGAINST JPMSI, WHICH WAS PAID ON FEBRUARY 16, 2005. Firm Statement THE PROCEEDING SETTLED AS FOLLOWS: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, JPMSI SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE SEC ACCEPTED ON FEBRUARY 14, 2005. i Disclosure 19 of 102 Reporting Source: Regulator Current Status: Final Allegations: SECURITIES AND EXCHANGE ACT OF 1934 SECTION 17(A); NASD RULES 3110 AND 3010 - RESPONDENT FIRM FAILED TO KEEP ELECTRONIC COMMUNICATIONS FOR THREE YEARS AND/OR FAILED TO PRESERVE ELECTRONIC MAIL COMMUNICATIONS FOR THE FIRST TWO YEARS IN AN ACCESSIBLE PLACE. THE RESPONDENT ALSO HAD INADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES THAT WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE. Initiated By: NASD Date Initiated: 02/14/2005 Docket/Case Number: CAF040117

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 J.P. MORGAN SECURITIES INC. 122 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/14/2005 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 $700,000.00 Other Sanctions Ordered: RESPONDENT FIRM SHALL COMPLETE AN APPROPRITAE UNDERTAKING TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE WITH NASD RULES AND THE FEDERAL SECURITIES LAWS. WITHIN 90 DAYS OF THE EXECUTION OF THE AWC, RESPONDENT UNDERTAKES AND AGREES TO INFORM NASD IN WRITING THAT IT HAS COMPLETED ITS REVIEW AND THAT IT HAS SYSTEMS AND PROCEDURES IN PLACE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THOSE LAWS, REGULATIONS AND RULES CONCERNING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $700,000. i Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGES THAT JPMSI VIOLATED THE RECORD-KEEPING REQUIREMENTS OF THE SECURITIES EXCHANGE ACT OF 1934, RULE 17A-4 THEREUNDER, AND NASD RULE 3110 DURING THE PERIOD JULY 1, 1999 TO JUNE 30, 2002 BY FAILING TO PRESERVE FOR THREE YEARS, AND/OR TO PRESERVE IN AN ACCESSIBLE PLACE FOR TWO YEARS, ELECTRONIC MAIL COMMUNICATIONS (INCLUDING INTER-OFFICE MEMORANDA AND COMMUNICATIONS) RECEIVED AND SENT BY ITS EMPLOYEES THAT RELATED TO ITS BUSINESS AS A MEMBER OF AN EXCHANGE, BROKER, OR DEALER. THE NASD ALSO ALLEGES THAT JPMSI LACKED ADEQUATE SYSTEMS OR PROCEDURES FOR THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS, IN VIOLATION OF NASD RULE 3010. Initiated By: NASD, INC. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 123 www.finra.org/brokercheck User Guidance

Initiated By: NASD, INC. Date Initiated: 12/16/2004 Docket/Case Number: CAF040117

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/14/2005 Sanctions Ordered: Censure Monetary/Fine $700,000.00 Other Sanctions Ordered: JPMSI SHALL COMPLETE AN APPROPRIATE UNDERTAKING TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE WITH NASD RULES AND FEDERAL SECURITIES LAWS. Sanction Details: CENSURE AND FINE OF $700,000 LEVIED AGAINST JPMSI, WHICH WAS PAID ON FEBRUARY 24, 2005. Firm Statement THE PROCEEDING SETTLED AS FOLLOWS: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, JPMSI ACCEPTED AND CONSENTED TO THE NASD AWC, AND NASD ACCEPTED THE AWC ON DECEMBER 23, 2004. i Disclosure 20 of 102 Reporting Source: Regulator Current Status: Final Allegations: RESEARCH ANALYST/INVESTMENT BANKING CONFLICT OF INTEREST Initiated By: UTAH DIVISION OF SECURITIES Date Initiated: 09/04/2003 Docket/Case Number: SD-03-0030 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 124 www.finra.org/brokercheck User Guidance

Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief PAY $250,000 TO SECURITIES INVESTOR EDUCATION AND TRAINING FUND Sought: AS A CIVIL MONETARY PENALTY

Resolution: Consent Resolution Date: 09/04/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: ORDERED TO CEASE & DESIST AND PAY A CIVIL MONETARY PENALTY OF $250,000.00 TO THE SECURITIES INVESTOR EDUCATION AND TRAINING FUND Regulator Statement FOR MORE INFORMATION, PLEASE VISIT THE DIVISION'S WEB SITE AT: HTTP://WWW.SECURITIES.STATE.UT.US/ACTIONSEVENTS.ASP? DOCKET+NUMBER=SD%2D03%2D0030 i Reporting Source: Firm Current Status: Final Allegations: THE STATE OF UTAH ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN ©2021 FINRA. All rights reserved. Report aboutOFFERING J.P. MORGAN DOCUMENTS SECURITIES ORINC. ELSEWHERE THE FACT OF SUCH PAYMENTS. 125 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF UTAH ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE www.finra.org/brokercheck INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE User Guidance RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF UTAH; DIVISION OF SECURITIES OF THE DEPARTMENT OF COMMERCE Date Initiated: 06/09/2003 Docket/Case Number: SD-03-0030

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

Resolution: Settled Resolution Date: 09/04/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON AUGUST 27, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 4, 2003. i Disclosure 21 of 102 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULE 2110 - RESPONDENT MEMBER FAILED WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH ACT 127 LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE SECURITIES. Initiated By: NASD Date Initiated: 03/26/2004 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 126 www.finra.org/brokercheck User Guidance

Docket/Case Number: CMS040044

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/26/2004 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 $15,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN SECURITIES INC. CONSENTED TO THE FINDING OF THE ALLEGATIONS AND TO THE FOLLOWING SANCTIONS: CENSURE AND FINE $15,000.00. i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGES THAT JPMORGAN SECURITIES INC. ("JPHQ") FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGH THE AUTOMATED CONFIRMATION TRANSACTION SERVICE ("ACT") 127 LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE SECURITIES. THESE TRANSACTIONS CONSTITUTE 3.3 PERCENT OF THE TRANSACTIONS REVIEWED THAT JPHQ WAS REQUIRED TO REPORT TO ACT IN ELIGIBLE SECURITIES DURING THE REVIEW PERIOD (JANAUARY 2, 2002 THROUGH APRIL 30, 2002.

THIS CONDUCT CONSTITUTES A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CICUMSTANCES IN VIOLATION OF NASD CONDUCT RULE 2110. Initiated By: NASD, DEPARTMENT OF MARKET REGULATION ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 127 www.finra.org/brokercheck User Guidance

Initiated By: NASD, DEPARTMENT OF MARKET REGULATION Date Initiated: 04/30/2002 Docket/Case Number: CMS040044 AWC

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/26/2004 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: JPHQ CONSENTS TO A CENSURE AND A FINE OF $15,000. Firm Statement JPHQ ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, TO THE ENTRY OF THE FINDINGS BY NASD. i Disclosure 22 of 102 Reporting Source: Regulator Current Status: Final Allegations: VIOLATIONS OF THE VERMONT SECURITIES ACT IN THAT (A) FIRM FAILED TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING WHICH CONDUCT IS A DISHONEST AND UNETHICAL PRACTICE UNDER SECTION 4221A(A)(8) OF THE ACT; AND (B) FIRM FAILED TO REASONABLY SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING AS REQUIRED BY SECTION 4221A(A)(11). Initiated By: VERMONT Date Initiated: 07/01/2002 Docket/Case Number: 03-066-S URL for Regulatory Action:

Resolution: Order Resolution Date: 10/08/2003 Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: GLOBAL SETTLEMENT RESULTING FROM INVESTIGATION OF ANALYSTS TASK FORCE. FIRM ADMITS THE JURISDICTION OF THE COMMISSIONER, NEITHER ADMITS NOR DENIES THE FINDINGS OF FACT AND CONCLUSIONS OF LAW CONTAINED IN THIS ORDER, AND CONSENTS TO THE ENTRY OF THIS ORDER BY THE COMMISSIONER. i Reporting Source: Firm Current Status: Final Allegations: THE STATE OF VERMONT ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE ©2021 FINRA. All rights reserved. Report aboutSUBJECT J.P. MORGAN TO CONFLICTS SECURITIES INC.OF INTEREST BETWEEN SUPPORTING THE 129 INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF VERMONT ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING www.finra.org/brokercheck AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH User Guidance DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF VERMONT; DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION; SECURITIES DIVISION Date Initiated: 05/09/2003 Docket/Case Number: DOCKET NO. 03-066-S

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

Resolution: Settled Resolution Date: 10/08/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 2, 2003. Firm Statement SETTLED BY A ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 8, 2003. i Disclosure 23 of 102 Reporting Source: Firm Current Status: Final

©2021Allegations: FINRA. All rights reserved. Report aboutTHE J.P. STATE MORGAN OF SECURITIESSOUTH CAROLINA INC. ALLEGES THAT DURING THE PERIOD OF 130 JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. www.finra.org/brokercheck User Guidance

Allegations: THE STATE OF SOUTH CAROLINA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF SOUTH CAROLINA, SECURITIES DIVISION, OFFICE OF THE ATTORNEY GENERAL Date Initiated: 02/13/2004 Docket/Case Number: FILE NO. 03084

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

Resolution: Settled Resolution Date: 06/29/2004 Sanctions Ordered: Monetary/Fine $309,130.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN ©2021 FINRA. All rights reserved. Report aboutBUSINESS J.P. MORGAN PRACTICES. SECURITIES INC. 131 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $309,130.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON JUNE 22, 2004. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON JUNE 29, 2004. i Disclosure 24 of 102 Reporting Source: Regulator Current Status: Final Allegations: THIS ACTION IS IN CONNECTION WITH THE GLOBAL ANALYST SETTLEMENT WHICH INCORPORATED THE FINAL JUDGMENT OF THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, CIVIL ACTION NO. 3 CIV. 2939 (WHP) ENTERED OCTOBER 31, 2003. Initiated By: PA SECURITIES COMMISSION CONTACT: G. PHILIP RUTLEDGE (717) 787-8059 Date Initiated: 12/19/2003 Docket/Case Number: 2003-04-45 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): SECURITIES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief RESPONDENT J.P. MORGAN SECURITIES, INC., PAID A $946,269.00 Sought: ADMINISTRATIVE ASSESSMENT.

Resolution: Settled Resolution Date: 12/19/2003 Sanctions Ordered: Monetary/Fine $946,269.00 Other Sanctions Ordered: Sanction Details: RESPONDENT J.P. MORGAN SECURITIES INC. PAID A $946,269.00 ADMINISTRATIVE ASSESSMENT. i Reporting Source: Firm

Current Status: Final Allegations: THE COMMONWEALTH OF PENNSYLVANIA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: COMMONWEALTH OF PENNSYLVANIA; PENNSYLVANIA SECURITIES COMMISSION. Date Initiated: 05/23/2003 Docket/Case Number: 2003-04-45

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

Resolution: Settled Resolution Date: 12/19/2003 Sanctions Ordered: Monetary/Fine $946,269.00 ©2021 FINRA. All rights reserved. Report aboutCease J.P. and MORGAN Desist/Injunction SECURITIES INC. 133 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $946,269.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $946,269.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON DECEMBER 18, 2003. Firm Statement SETTLED BY AN ORDER THAT WAS ISSUED AND ENTERED ON DECEMBER 19, 2003. i Disclosure 25 of 102 Reporting Source: Regulator Current Status: Final Appealed To and Date Appeal N/A Filed: Allegations: FAILED TO ESTABLISH AND ENFORCE WRITTEN SUPERVISORY PROCEDURES TO ENSURE ANALYSTS WERE NOT UNDULY INFLUENCED, CREATED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS (CONFLICT OF INTEREST), MADE PAYMENTS TO OTHER BDS FOR RESEARCH AND FAILING TO DISCLOSE SAID PAYMENTS. Initiated By: IOWA Date Initiated: 04/15/2002 Docket/Case Number: C04-12-430 URL for Regulatory Action: Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): N/A Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Consent Resolution Date: 01/30/2004 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or ©2021deceptive FINRA. conduct? All rights reserved. Report about J.P. MORGAN SECURITIES INC. 134 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 $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: RESPONDENT NEITHER ADMITS NOR DENIES THE FINDINGS OF FACT AND CONCLUSIONS OF LAW CONTAINED IN THE ORDER.ON Sanction Details: ONE OF SEVERAL SETTLEMENTS WITH "ANALYST TASK FORCE." SEVERAL UNDERTAKINGS AS WELL. Regulator Statement N/A i Reporting Source: Firm Current Status: Final Allegations: THE STATE OF IOWA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST.

Initiated By: STATE OF IOWA Date Initiated: 12/30/2003 Docket/Case Number: C04-12-430

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

Resolution: Settled Resolution Date: 01/30/2004 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON JANUARY 27, 2004. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON JANUARY 30, 2004. i Disclosure 26 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF ILLINOIS ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE ©2021 FINRA. All rights reserved. Report aboutSUBJECT J.P. MORGAN TO CONFLICTS SECURITIES INC.OF INTEREST BETWEEN SUPPORTING THE 136 INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF ILLINOIS ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING www.finra.org/brokercheck AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH User Guidance DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF ILLINOIS; SECRETARY OF STATE; SECURITIES DEPARTMENT Date Initiated: 12/02/2003 Docket/Case Number: CASE NO. 0300912

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

Resolution: Settled Resolution Date: 04/08/2004 Sanctions Ordered: Monetary/Fine $956,921.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $956,921.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON APRIL 8, 2004. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON APRIL 8, 2004. i Disclosure 27 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF NEW MEXICO ALLEGES THAT DURING THE PERIOD OF JULY ©2021 FINRA. All rights reserved. Report about1, 1999 J.P. MORGANTO JUNE SECURITIES 30, 2001 J.P.INC. MORGAN SECURITIES INC: 1. ENGAGED IN 137 ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. www.finra.org/brokercheck User Guidance

Allegations: THE STATE OF NEW MEXICO ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF NEW MEXICO, SECURITIES DIVISION Date Initiated: 10/20/2003 Docket/Case Number: 03-03-030-050 (CO)

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

Resolution: Settled Resolution Date: 12/19/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES.

©2021Sanction FINRA. Details: All rights reserved. Report aboutFINE J.P. OF MORGAN $250,000.00, SECURITIES ALL INC.OF WHICH WAS LEVIED AGAINST JPMSI AND PAID 138 BY JPMSI ON DECEMBER 18, 2003. www.finra.org/brokercheck User Guidance

Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON DECEMBER 18, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON DECEMBER 19, 2003. i Disclosure 28 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF MARYLAND ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF MARYLAND; DIVISION OF SECURITIES Date Initiated: 09/05/2003 Docket/Case Number: FILE NO. 2002-0888

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 J.P. MORGAN SECURITIES INC. 139 www.finra.org/brokercheck User Guidance

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

Resolution: Settled Resolution Date: 11/21/2003 Sanctions Ordered: Monetary/Fine $408,100.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $408,100.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 7, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON NOVEMBER 21, 2003. i Disclosure 29 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF WISCONSIN ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 140 AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF WISCONSIN ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT www.finra.org/brokercheck INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW User Guidance THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF WISCONSIN; DEPARTMENT OF FINANCIAL INSTITUTIONS; DIVISION OF SECURITIES Date Initiated: 08/19/2003 Docket/Case Number: FILE NO. S-03104(EX)

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

Resolution: Settled Resolution Date: 10/09/2003 Sanctions Ordered: Monetary/Fine $413,277.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $413,277.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 7, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 9, 2003. i Disclosure 30 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF LOUISIANA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ©2021 FINRA. All rights reserved. Report aboutACTIVITIES, J.P. MORGAN AND SECURITIES USED THIS INC. PARTICIPATION AS A FACTOR IN EVALUATING 141 AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF LOUISIANA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER www.finra.org/brokercheck RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST User Guidance FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF LOUISIANA; OFFICE OF FINANCIAL INSTITUTIONS Date Initiated: 08/20/2003 Docket/Case Number: NO DOCKET NUMBER PROVIDED BY STATE

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

Resolution: Settled Resolution Date: 05/26/2004 Sanctions Ordered: Monetary/Fine $344,339.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $344,339.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON APRIL 15, 2004. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON MAY 26, 2004. i Disclosure 31 of 102 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 142 www.finra.org/brokercheck User Guidance

Disclosure 31 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF NEVADA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF NEVADA; OFFICE OF THE SECRETARY OF STATE; SECURITIES DIVISION Date Initiated: 08/13/2003 Docket/Case Number: FILE NO. I03-184

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

Resolution: Settled

Resolution Date: 10/08/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 7, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 8, 2003. i Disclosure 32 of 102 Reporting Source: Regulator Current Status: Final Allegations: RESPONDENT ENGAGED IN UNETHICAL AND DISHONEST PRACTICES IN CONNECTION WITH THE OFFER OR SALE OF SECURITIES. RESPONDENT ALSO FAILED REASONABLY TO SUPERVISE THEIR EMPLOYEES. ALL ALLEGATIONS RELATED TO PRACTICES OF THE RESEARCH AND INVESTMENT BANKING SECTIONS OF THE RESPONDENTS FIRM. Initiated By: OREGON DIVISION OF FINANCE AND CORPORATE SECURITIES Date Initiated: 07/23/2003 Docket/Case Number: S-03-0038 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): STOCK Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST Sought:

Resolution: Consent Resolution Date: 09/18/2003 Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 144 www.finra.org/brokercheck User Guidance

Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $263,622.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: NO PORTION OF PENALTY SUSPENDED Regulator Statement RESEARCH ANALYSTS AT THE FIRM WERE SUBJECTED TO PRESSURES FROM TEH INVESTMENT BANKING SECTION OF THE FIRM TO RATE STOCKS FAVORABLY SO AS TO GAIN THE INVESTMENT BANKING BUSINESS OF THE FIRMS ISSUING THE STOCKS. i Reporting Source: Firm Current Status: Final Allegations: THE STATE OF OREGON ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 145 THE STATE OF OREGON ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN www.finra.org/brokercheck OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. User Guidance 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF OREGON; DEPARTMENT OF CONSUMER AND BUSINESS SERVICES; DIVISION OF FINANCE AND CORPORATE SECURITIES Date Initiated: 07/24/2003 Docket/Case Number: S-03-0038

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 & DESIST Sought:

Resolution: Settled Resolution Date: 09/18/2003 Sanctions Ordered: Monetary/Fine $263,622.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $263,622.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 9, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE ORDER, ORDER IMPOSING MONETARY OBLIGATIONS AND CONSENT TO ENTRY OF ORDER THAT WERE FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 18, 2003. i Disclosure 33 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF CALIFORNIA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH ©2021 FINRA. All rights reserved. Report aboutDEPARTMENT J.P. MORGAN COORDINATEDSECURITIES INC. THE DECISION TO INITIATE AND MAINTAIN 146 RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF CALIFORNIA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE www.finra.org/brokercheck CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED User Guidance ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF CALIFORNIA; BUSINESS, TRANSPORTATION AND HOUSING AGENCY; DEPARTMENT OF CORPORATIONS Date Initiated: 08/07/2003 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 CEASE AND DESIST Sought:

Resolution: Settled Resolution Date: 12/15/2003 Sanctions Ordered: Monetary/Fine $2,609,851.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $2,609,851.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 14, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON DECEMBER 15, 2003. i Disclosure 34 of 102

Reporting Source: Firm Current Status: Final Allegations: THE STATE OF OHIO ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF OHIO; DEPARTMENT OF COMMERCE; DIVISION OF SECURITIES Date Initiated: 08/01/2003 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 CEASE AND DESIST Sought:

Resolution: Settled Resolution Date: 11/03/2003 Sanctions Ordered: Monetary/Fine $874,773.00 ©2021 FINRA. All rights reserved. Report aboutCease J.P. and MORGAN Desist/Injunction SECURITIES INC. 148 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $874,773.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $874,773.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 31, 2003. Firm Statement SETTLED BY A SETTLEMENT AGREEMENT THAT WAS FULLY EXECUTED AND EFFECTIVE ON NOVEMBER 3, 2003. i Disclosure 35 of 102 Reporting Source: Firm Current Status: Final Allegations: THE COMMONWEALTH OF MASSACHUSETTS ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: THE COMMONWEALTH OF MASSACHUSETTS; OFFICE OF THE SECRETARY OF THE COMMONWEALTH; SECURITIES DIVISION Date Initiated: 07/29/2003 Docket/Case Number: NO. E-2003-42 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 149 www.finra.org/brokercheck User Guidance

Docket/Case Number: NO. E-2003-42

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

Resolution: Settled Resolution Date: 10/08/2003 Sanctions Ordered: Monetary/Fine $489,205.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $489,205.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 8, 2003. Firm Statement SETTLED BY A ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 8, 2003. i Disclosure 36 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF DELAWARE ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT ©2021 FINRA. All rights reserved. Report aboutINVOLVED J.P. MORGAN IN AN SECURITIES UNDERWRITING INC. TRANSACTION WHEN THE FIRM KNEW 150 THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF DELAWARE ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT www.finra.org/brokercheck BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY User Guidance INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF DELAWARE; SECURITIES COMMISSIONER Date Initiated: 08/01/2003 Docket/Case Number: C.A. NO. 03-6-9

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

Resolution: Settled Resolution Date: 09/11/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON AUGUST 28, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 11, 2003. i Disclosure 37 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF NORTH CAROLINA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT ©2021 FINRA. All rights reserved. Report aboutOVER J.P. RESEARCH MORGAN SECURITIES ANALYSTS INC. AND THEREBY CREATED CONFLICTS OF 151 INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. www.finra.org/brokercheck THE STATE OF NORTH CAROLINA ALLEGES THAT DURING THE PERIOD OF User Guidance JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF NORTH CAROLINA; DEPARTMENT OF THE SECRETARY OF STATE; SECURITIES DIVISION Date Initiated: 07/16/2003 Docket/Case Number: FILE NO.: 03-014-IG

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

Resolution: Settled Resolution Date: 12/23/2003 Sanctions Ordered: Monetary/Fine $620,209.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $620,209.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON DECEMBER 12, 2003. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 152 www.finra.org/brokercheck User Guidance

Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON DECEMBER 23, 2003. i Disclosure 38 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF NEW HAMPSHIRE ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: THE STATE OF NEW HAMPSHIRE; DEPARTMENT OF STATE; BUREAU OF SECURITIES REGULATION Date Initiated: 07/16/2003 Docket/Case Number: NO DOCKET/CASE NUMBER GIVEN BY THE STATE

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 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 153 Sought: www.finra.org/brokercheck User Guidance

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

Resolution: Settled Resolution Date: 01/29/2004 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON JANUARY 27, 2004. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON JANUARY 29, 2004. i Disclosure 39 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF MINNESOTA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF ©2021 FINRA. All rights reserved. Report aboutINTEREST. J.P. MORGAN SECURITIES INC. 154 THE STATE OF MINNESOTA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH www.finra.org/brokercheck COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN User Guidance OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF MINNESOTA; DEPARTMENT OF COMMERCE Date Initiated: 07/18/2003 Docket/Case Number: SE2304869

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

Resolution: Settled Resolution Date: 10/13/2003 Sanctions Ordered: Monetary/Fine $379,051.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $379,051.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 19, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 13, 2003. i Disclosure 40 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF RHODE ISLAND ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN ©2021 FINRA. All rights reserved. Report aboutRESEARCH J.P. MORGAN COVERAGE SECURITIES ON INC. CERTAIN COMPANIES WITH INVESTMENT 155 BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF RHODE ISLAND ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED www.finra.org/brokercheck ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING User Guidance ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS; DEPARTMENT OF BUSINESS REGULATION; DIVISION OF SECURITIES Date Initiated: 07/16/2003 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 CEASE AND DESIST Sought:

Resolution: Settled Resolution Date: 09/15/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 11, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 15, 2003. i Disclosure 41 of 102 Reporting Source: Firm

Current Status: Final Allegations: THE ATTORNEY GENERAL OF THE STATE OF NEW YORK ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: ATTORNEY GENERAL OF THE STATE OF NEW YORK; BUREAU OF INVESTMENT PROTECTION Date Initiated: 07/14/2003 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 CEASE AND DESIST Sought:

Resolution: Settled Resolution Date: 09/02/2003 Sanctions Ordered: Monetary/Fine $1,462,158.00 ©2021 FINRA. All rights reserved. Report aboutCease J.P. and MORGAN Desist/Injunction SECURITIES INC. 157 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $1,462,158.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $1,462,158.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 3, 2003. Firm Statement SETTLED BY AN ASSURANCE OF DISCONTINUANCE THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 2, 2003. i Disclosure 42 of 102 Reporting Source: Firm Current Status: Final Allegations: THE COMMONWEALTH OF KENTUCKY ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: COMMONWEALTH OF KENTUCKY; DEPARTMENT OF FINANCIAL INSTITUTIONS Date Initiated: 07/10/2003 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 CEASE AND DESIST Sought:

Resolution: Settled Resolution Date: 08/28/2003 Sanctions Ordered: Monetary/Fine $311,423.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $311,423.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON AUGUST 27, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON AUGUST 28, 2003. i Disclosure 43 of 102 Reporting Source: Regulator Current Status: Final Allegations: THE RESPONDENT SETTLED ALLEGATIONS THAT UNDUE INFLUENCE BY THE INVESTMENT BANKING DIVISION ON SECURITIES RESEARCH AT THE FIRM RESULTED IN TAINTED RESEARCH. Initiated By: GEORGIA SECRETARY OF STATE - SECURITIES DIVISION Date Initiated: 09/08/2003 Docket/Case Number: EN-19517 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): SEE #7 Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief THE RESPONDENT SHALL PAY $500,000.00 IN CIVIL PENALTIES TO GA, Sought: $50,000.00 IN INVESTIGATIVE COSTS TO GA, AND $80,775.00 TO THE INVESTOR PROTECTION TRUST FOR THE PROMOTION OF INVESTOR PROTECTION AND EDUCATION FOR THE BENEFIT OF GA INVESTORS AND ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 159 CITIZENS. www.finra.org/brokercheck User Guidance THE RESPONDENT SHALL PAY $500,000.00 IN CIVIL PENALTIES TO GA, $50,000.00 IN INVESTIGATIVE COSTS TO GA, AND $80,775.00 TO THE INVESTOR PROTECTION TRUST FOR THE PROMOTION OF INVESTOR PROTECTION AND EDUCATION FOR THE BENEFIT OF GA INVESTORS AND CITIZENS.

Resolution: Consent Resolution Date: 09/25/2003 Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $630,775.00 Cease and Desist/Injunction Other Sanctions Ordered: SEE #2 Sanction Details: FIRM AGREED TO PAY MONETARY PENALTIES, DISGORGEMENT, AND FUND INDEPENDENT RESEARCH AND INVESTOR EDUCATION. FIRM ALSO AGREED TO REFORM PRACTICES TO MINIMIZE THE POSSIBILITY OF FUTURE CONFLICTS OF INTEREST. i Reporting Source: Firm Current Status: Final Allegations: THE STATE OF GEORGIA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN ©2021 FINRA. All rights reserved. Report aboutOFFERING J.P. MORGAN DOCUMENTS SECURITIES ORINC. ELSEWHERE THE FACT OF SUCH PAYMENTS. 160 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF GEORGIA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE www.finra.org/brokercheck RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT User Guidance INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF GEORGIA; SECRETARY OF STATE; COMMISSIONER OF SECURITIES Date Initiated: 07/17/2003 Docket/Case Number: CASE NUMBER EN-19002

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

Resolution: Settled Resolution Date: 09/25/2003 Sanctions Ordered: Monetary/Fine $630,775.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $630,775.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 3, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 25, 2003. i Disclosure 44 of 102 Reporting Source: Regulator Current Status: Final Allegations: FIRM FAILED TO ESTABLISH AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONBLY DESIGNED TO ENSURE THAT ANALYST WERE NOT UNDULY INFLUENCED BY INVESTMENT BANKING CONCERNS. THE FIRM MADE PAYMENTS FOR RESEARCH TO OTHER BROKER DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE AND FAILED TO DISCLOSE IN OFFERING DOCUMENTS THE FACT THAT SUCH PAYMENTS WERE MADE. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 161 www.finra.org/brokercheck User Guidance

Initiated By: FLORIDA Date Initiated: 09/19/2003 Docket/Case Number: 0039-S-6/03 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): RESEARCH. Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 09/19/2003 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $123,461.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: NA Regulator Statement FIRM FAILED TO ESTABLISH AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONBLY DESIGNED TO ENSURE THAT ANALYST WERE NOT UNDULY INFLUENCED BY INVESTMENT BANKING CONCERNS. THE FIRM MADE PAYMENTS FOR RESEARCH TO OTHER BROKER DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE AND FAILED TO DISCLOSE IN OFFERING DOCUMENTS THE FACT THAT SUCH PAYMENTS WERE MADE i Reporting Source: Firm Current Status: Final Allegations: THE STATE OF FLORIDA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER ©2021 FINRA. All rights reserved. Report aboutRESEARCH J.P. MORGAN ANALYSTS SECURITIES AND INC. THEREBY CREATED CONFLICTS OF INTEREST 162 FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. www.finra.org/brokercheck User Guidance THE STATE OF FLORIDA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF FLORIDA; OFFICE OF FINANCIAL REGULATION Date Initiated: 07/18/2003 Docket/Case Number: OFR NO. 0039-S-6/03

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

Resolution: Settled Resolution Date: 09/19/2003 Sanctions Ordered: Monetary/Fine $1,231,461.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $1,231,461.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 11, 2003. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 163 www.finra.org/brokercheck User Guidance

FINE OF $1,231,461.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 11, 2003. Firm Statement SETTLED BY A CONSENT AGREEMENT THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 19, 2003. i Disclosure 45 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF NORTH DAKOTA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF NORTH DAKOTA; NORTH DAKOTA SECURITIES DEPARTMENT Date Initiated: 07/07/2003 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 CEASE AND DESIST ©2021Sought: FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 164 www.finra.org/brokercheck User Guidance

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

Resolution: Settled Resolution Date: 10/21/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $242,500.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 16, 2003. ON THAT DATE, JPMSI ALSO MADE A DONATION OF $7,500.00 TO THE INVESTOR EDUCATION AND TECHNOLOGY FUND, ADMINISTERED BY THE NORTH DAKOTA SECURITIES DEPARTMENT. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 21, 2003. i Disclosure 46 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF MICHIGAN ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, ©2021 FINRA. All rights reserved. Report aboutAND J.P. PROCEDURES MORGAN SECURITIES REASONABLY INC. DESIGNED TO DETECT AND PREVENT 165 THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF MICHIGAN ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT www.finra.org/brokercheck INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW User Guidance THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF MICHIGAN; OFFICE OF FINANCIAL AND INSURANCE SERVICES; DEPARTMENT OF CONSUMER AND INDUSTRY SERVICES Date Initiated: 07/02/2003 Docket/Case Number: ORDER NO. 03-040-M

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

Resolution: Settled Resolution Date: 08/28/2003 Sanctions Ordered: Monetary/Fine $765,768.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $765,768.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON AUGUST 27, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON AUGUST 28, 2003. i Disclosure 47 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF ARKANSAS ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ©2021 FINRA. All rights reserved. Report aboutACTIVITIES, J.P. MORGAN AND SECURITIES USED THIS INC. PARTICIPATION AS A FACTOR IN EVALUATING 166 AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF ARKANSAS ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER www.finra.org/brokercheck RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST User Guidance FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF ARKANSAS; ARKANSAS SECURITIES DEPARTMENT Date Initiated: 07/03/2003 Docket/Case Number: S-03-016-03-C005

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

Resolution: Settled Resolution Date: 10/01/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 3, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 1, 2003. i Disclosure 48 of 102 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 167 www.finra.org/brokercheck User Guidance

Disclosure 48 of 102 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULES 3110 AND 3320, NASD MARKETPLACE RULES 4613(B) AND 4613(E)(1)(C), AND SEC RULES 11AC1-1 AND 17A-3 - RESPONDENT MEMBER ("FIRM"), A MARKET MAKER IN SECURITIES, WAS A PARTY TO A LOCKED OR CROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING AND RECEIVED A TRADE-OR-MOVE MESSAGE IN EACH INSTANCE THROUGH SELECTNET AND WITHIN 30 SECONDS OF RECEIVING SUCH MESSAGES, FAILED TO FILL THE INCOMING TRADE-OR-MOVE MESSAGE FOR THE FULL SIZE OF THE MESSAGE OR MOVE ITS BID DOWN (OFFER UP) BY A QUOTATION INCREMENT THAT WOULD HAVE UNLOCKED/UNCROSSED THE MARKET. IN ADDITION, THE FIRM WAS A REGISTERED MARKET MAKER IN SECURITIES, AND AN ORDER WAS PRESENTED TO THE FIRM AT THE FIRM'S PUBLISHED BID OR PUBLISHED OFFER IN AN AMOUNT UP TO ITS PUBLISHED QUOTATION SIZE. THE FIRM FAILED TO EXECUTE THE ORDERS UPON PRESENTMENT AND THEREBY FAILED TO HONOR ITS PUBLISHED QUOTATION. FURTHERMORE, THE FIRM FAILED TO SHOW CERTAIN TERMS AND CONDITIONS ON THE MEMORANDUM OF BROKERAGE ORDERS IN CONNECTION WITH ORDERS RECEIVED ON THE FIRST DAY OF SECONDARY TRADING IMMEDIATELY FOLLOWING 12 INITIAL PUBLIC OFFERINGS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/02/2003 Docket/Case Number: CMS030150

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: 07/02/2003 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRM ©2021 FINRA. All rights reserved. Report aboutCONSENTED J.P. MORGAN TO SECURITIES THE DESCRIBED INC. SANCTIONS AND TO THE ENTRY OF 168 FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $50,000. www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $50,000. i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGES VIOLATION OF NASD CONDUCT RULES 3110 AND 3320, NASD MARKETPLACE RULES 4613(B) AND 4613(E)(1)(C), AND SEC RULES 11AC1-1 AND 17A-3. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/02/2003 Docket/Case Number: CMS030150

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: 07/02/2003 Sanctions Ordered: Censure Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, JPMSI CONSENTED TO A CENSURE AND A FINE OF $50,000 (COMPOSED OF A $10,000 FINE FOR THE TRADE-OR-MOVE VIOLATIONS, A $15,000 FINE FOR THE FIRM QUOTE VIOLATIONS {COMPOSED OF A $10,000 FINE FOR THE JPMSI FIRM QUOTE VIOLATIONS AND A $5,000 FINE FOR THE HMQT FIRM QUOTE VIOLATIONS} AND A $25,000 FINE FOR THE RECORD KEEPING VIOLATIONS). i Disclosure 49 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF WYOMING ALLEGES THAT DURING THE PERIOD OF JULY 1, ©2021 FINRA. All rights reserved. Report about1999 J.P. TO MORGAN JUNE 30, SECURITIES 2001 J.P. INC. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS 169 AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. www.finra.org/brokercheck User Guidance

Allegations: THE STATE OF WYOMING ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF WYOMING; SECRETARY OF STATE Date Initiated: 06/18/2003 Docket/Case Number: CASE NO. 02-10

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

©2021Sanction FINRA. Details: All rights reserved. Report aboutFINE J.P. OF MORGAN $250,000.00, SECURITIES ALL INC.OF WHICH WAS LEVIED AGAINST JPMSI AND PAID 170 BY JPMSI ON AUGUST 27, 2003. www.finra.org/brokercheck User Guidance

Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON AUGUST 27, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 4, 2003. i Disclosure 50 of 102 Reporting Source: Firm Current Status: Final Allegations: THE COMMONWEALTH OF PUERTO RICO ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: COMMONWEALTH OF PUERTO RICO; COMMISSIONER OF FINANCIAL INSTITUTIONS Date Initiated: 06/09/2003 Docket/Case Number: NUM. C03-V-010

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) ©2021Sought: FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 171 www.finra.org/brokercheck User Guidance

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

Resolution: Settled Resolution Date: 09/30/2003 Sanctions Ordered: Monetary/Fine $293,457.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $293,457.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON AUGUST 27, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 30, 2003. i Disclosure 51 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF NEW JERSEY ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 172 AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF NEW JERSEY ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT www.finra.org/brokercheck INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW User Guidance THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF NEW JERSEY; BUREAU OF SECURITIES Date Initiated: 06/16/2003 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 CEASE AND DESIST Sought:

Resolution: Settled Resolution Date: 09/02/2003 Sanctions Ordered: Monetary/Fine $648,335.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $648,335.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON AUGUST 27, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 2, 2003. i Disclosure 52 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF WEST VIRGINIA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING ©2021 FINRA. All rights reserved. Report aboutAND J.P. COMPENSATING MORGAN SECURITIES RESEARCH INC. ANALYSTS. 4. THE RESEARCH 173 DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF WEST VIRGINIA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF www.finra.org/brokercheck INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE User Guidance CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF WEST VIRGINIA; WEST VIRGINIA SECURITIES DIVISION; COMMISSIONER OF SECURITIES Date Initiated: 06/04/2003 Docket/Case Number: E03-1349

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

Resolution: Settled Resolution Date: 12/29/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON DECEMBER 22, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON DECEMBER 29, 2003. i Disclosure 53 of 102 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 174 www.finra.org/brokercheck User Guidance

Disclosure 53 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF NEBRASKA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF NEBRASKA; DEPARTMENT OF BANKING & FINANCE Date Initiated: 06/09/2003 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 CEASE AND DESIST Sought:

Resolution Date: 11/03/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 31, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON NOVEMBER 3, 2003. i Disclosure 54 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF CONNECTICUT ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF CONNECTICUT; DEPARTMENT OF BANKING Date Initiated: 06/11/2003 Docket/Case Number: CO-2003-6798-S ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 176 www.finra.org/brokercheck User Guidance

Docket/Case Number: CO-2003-6798-S

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

Resolution: Settled Resolution Date: 09/05/2003 Sanctions Ordered: Monetary/Fine $262,402.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $262,402.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 3, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 5, 2003. i Disclosure 55 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF TENNESSEE ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT ©2021 FINRA. All rights reserved. Report aboutINVOLVED J.P. MORGAN IN AN SECURITIES UNDERWRITING INC. TRANSACTION WHEN THE FIRM KNEW 177 THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF TENNESSEE ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT www.finra.org/brokercheck BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY User Guidance INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF TENNESSEE; TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE; TENNESSEE SECURITIES DIVISION. Date Initiated: 06/06/2003 Docket/Case Number: 03-005

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

Resolution: Settled Resolution Date: 10/16/2003 Sanctions Ordered: Monetary/Fine $438,366.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $438,366.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 14, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 16, 2003. i Disclosure 56 of 102 Reporting Source: Regulator Current Status: Final Allegations: TIME PERIOD BEGINNING JULY 1, 1999, TO JUNE 30, 2001, TO WIT, JPMSI FAILED TO ENSURE THAT RESEARCH ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED ©2021 FINRA. All rights reserved. Report aboutCOMPANIES J.P. MORGAN AND SECURITIES INVESTMENT INC. BANKING, AND JPMSI FAILED TO 178 REASONABLY SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS RESEARCH ANALYSTS WERE ADEQUATELY INSULATED FROM SUCH PRESSURES AND INFLUENCES. www.finra.org/brokercheck User Guidance TIME PERIOD BEGINNING JULY 1, 1999, TO JUNE 30, 2001, TO WIT, JPMSI FAILED TO ENSURE THAT RESEARCH ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING, AND JPMSI FAILED TO REASONABLY SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS RESEARCH ANALYSTS WERE ADEQUATELY INSULATED FROM SUCH PRESSURES AND INFLUENCES. Initiated By: OKLAHOMA Date Initiated: 05/02/2003 Docket/Case Number: ODS 03-132 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): ANALYST INDEPENDENCE (IPO) Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 09/18/2003 Sanctions Ordered: Monetary/Fine $265,877.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: JPMSI ALSO AGREED TO COMPLY WITH ALL UNDERTAKINGS ESTABLISHED AS PART OF THE GLOBAL ANALYST SETTLEMENT IN CONNECTION WITH THE FIRM'S RESEARCH PRACTICES. Regulator Statement . i Reporting Source: Firm Current Status: Final Allegations: THE STATE OF OKLAHOMA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH ©2021 FINRA. All rights reserved. Report aboutDEPARTMENT J.P. MORGAN COORDINATEDSECURITIES INC. THE DECISION TO INITIATE AND MAINTAIN 179 RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF OKLAHOMA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST www.finra.org/brokercheck FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS User Guidance IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF OKLAHOMA; DEPARTMENT OF SECURITIES Date Initiated: 05/20/2003 Docket/Case Number: ODS 03-132

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

Resolution: Settled Resolution Date: 09/18/2003 Sanctions Ordered: Monetary/Fine $265,877.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $265,877.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON AUGUST 28, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 18, 2003. i Disclosure 57 of 102

Reporting Source: Firm Current Status: Final Allegations: THE STATE OF INDIANA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF INDIANA; OFFICE OF THE SECRETARY OF STATE; SECURITIES DIVISION Date Initiated: 05/30/2003 Docket/Case Number: CAUSE NO. 03-0065 CO

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

Sanctions Ordered: Monetary/Fine $468,508.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $468,508.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 20, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 27, 2003. i Disclosure 58 of 102 Reporting Source: Firm Current Status: Final Allegations: THE DISTRICT OF COLUMBIA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: DISTRICT OF COLUMBIA; DEPARTMENT OF INSURANCE AND SECURITIES REGULATION Date Initiated: 05/29/2003

Docket/Case Number: SEC CO 03-04

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

Resolution: Settled Resolution Date: 11/20/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON NOVEMBBER 17, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON NOVEMBER 20, 2003. i Disclosure 59 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF COLORADO ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT ©2021 FINRA. All rights reserved. Report aboutINVOLVED J.P. MORGAN IN AN SECURITIES UNDERWRITING INC. TRANSACTION WHEN THE FIRM KNEW 183 THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF COLORADO ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT www.finra.org/brokercheck BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY User Guidance INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF COLORADO; SECURITIES COMMISSIONER Date Initiated: 06/05/2003 Docket/Case Number: ORDER NO. 04-L-14

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

Resolution: Settled Resolution Date: 10/09/2003 Sanctions Ordered: Monetary/Fine $331,417.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $331,417.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 7, 2003. Firm Statement SETTLED BY A STIPULATION FOR CONSENT ORDER AND CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 9, 2003. i Disclosure 60 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF ALASKA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER ©2021 FINRA. All rights reserved. Report aboutRESEARCH J.P. MORGAN ANALYSTS SECURITIES AND INC. THEREBY CREATED CONFLICTS OF INTEREST 184 FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. www.finra.org/brokercheck THE STATE OF ALASKA ALLEGES THAT DURING THE PERIOD OF JULY 1, User Guidance 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF ALASKA; DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT; DIVISION OF BANKING, SECURITIES, AND CORPORATIONS. Date Initiated: 05/30/2003 Docket/Case Number: ALASKA ORDER 04-03 S

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

Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 11, 2003. i Disclosure 61 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF WASHINGTON ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF WASHINGTON; DEPARTMENT OF FINANCIAL INSTITUTIONS; SECURITIES DIVISION Date Initiated: 05/21/2003 Docket/Case Number: S-03-088

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

Resolution: Settled Resolution Date: 10/06/2003 Sanctions Ordered: Monetary/Fine $454,149.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $454,149.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 2, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 6, 2003. i Disclosure 62 of 102 Reporting Source: Regulator Current Status: Final Allegations: COMMISSION RULES 21 VAC 5-20-260 B AND 21 VAC 5-20-280 E 12 WERE VIOLATED. CONTACT THE UNDERSIGNED FOR FURTHER INFORMATION ABOUT THE CONCLUSIONS OF LAW. Initiated By: VIRGINIA - DIVISION OF SECURITIES Date Initiated: 12/04/2003 Docket/Case Number: SEC-2003-00017 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): CONTACT UNDERSIGNED FOR INFORMATION. Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CONTACT UNDERSIGNED FOR INFORMATION Sought:

Resolution: Settled Resolution Date: 12/04/2003 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about J.P. MORGAN SECURITIES INC. 187 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 $545,408.00 Other Sanctions Ordered: CONTACT UNDERSIGNED FOR INFORMATION Sanction Details: CONTACT UNDERSIGNED FOR INFORMATION Regulator Statement $545,408.00 WAS RECEIVED AS PART OF THE SETTLEMENT AGREEMENT JP MORGAN SECURITIES, INC. ENTERED INTO WITH ALL FIFTY STATES, THE DISTRICT OF COLUMBIA AND THE COMMONWEALTH OF PUERTO RICO, THROUGH A COMMITTEE OF THE NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION ("NASAA"). JURISDICTION REPORTING INCIDENT: VIRGINIA, STATE CORPORATION COMMISSION, DIVISION OF SECURITIES & RETAIL FRANCHISING. CONTACT KEVIN M. FURR AT 804-371- 9081. i Reporting Source: Firm Current Status: Final Allegations: THE COMMONWEALTH OF VIRGINIA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 188 AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE COMMONWEALTH OF VIRGINIA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT www.finra.org/brokercheck INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW User Guidance THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: COMMONWEALTH OF VIRGINA, STATE CORPORATION COMMISSION Date Initiated: 05/08/2003 Docket/Case Number: SEC-2003-00017

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

Resolution: Settled Resolution Date: 12/04/2003 Sanctions Ordered: Monetary/Fine $545,408.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $545,408.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON NOVEMBER 26, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON DECEMBER 4, 2003. i Disclosure 63 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF SOUTH DAKOTA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING ©2021 FINRA. All rights reserved. Report aboutAND J.P. COMPENSATING MORGAN SECURITIES RESEARCH INC. ANALYSTS. 4. THE RESEARCH 189 DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF SOUTH DAKOTA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF www.finra.org/brokercheck INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE User Guidance CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF SOUTH DAKOTA Date Initiated: 05/12/2003 Docket/Case Number: 647

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:

Reporting Source: Firm Current Status: Final Allegations: THE STATE OF MONTANA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF MONTANA, MONTANA STATE AUDITOR Date Initiated: 05/12/2003 Docket/Case Number: I 05-01-03-113

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

Resolution: Settled Resolution Date: 11/17/2003 Sanctions Ordered: Monetary/Fine $250,000.00 ©2021 FINRA. All rights reserved. Report aboutCease J.P. and MORGAN Desist/Injunction SECURITIES INC. 191 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON NOVEMBER 17, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 31, 2003. i Disclosure 65 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF MISSOURI ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF MISSOURI, OFFICE OF THE SECRETARY OF STATE Date Initiated: 05/14/2003 Docket/Case Number: AO-03-14 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 192 www.finra.org/brokercheck User Guidance

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

Resolution: Settled Resolution Date: 11/06/2003 Sanctions Ordered: Monetary/Fine $431,117.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $431,117.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 31, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON NOVEMBER 6, 2003. i Disclosure 66 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF MISSISSIPPI ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW ©2021 FINRA. All rights reserved. Report aboutTHAT J.P. THESE MORGAN PAYMENTS SECURITIES WEREINC. MADE, AT LEAST IN PART, FOR RESEARCH 193 COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF MISSISSIPPI ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE www.finra.org/brokercheck SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE User Guidance INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF MISSISSIPPI, SECRETARY OF STATE, BUSINESS REGULATION AND ENFORCEMENT DIVISION Date Initiated: 05/02/2003 Docket/Case Number: 02-11-06-S

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

Resolution: Settled Resolution Date: 09/18/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 10, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 18, 2003. i Disclosure 67 of 102 Reporting Source: Regulator Current Status: Final Allegations: THE FIRM ENGAGED IN UNETHICAL AND DISHONEST CONDUCT BY FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES OF COVERED COMPANIES AND INVESTMENT BANKING. THE FIRM ALSO FAILED TO REASONABLY SUPERVISE ITS EMPLOYEES IN CONNECTION WITH THE ©2021 FINRA. All rights reserved. Report aboutISSUANCE J.P. MORGAN OF RESEARCH. SECURITIES INC. 194 THE FIRM ENGAGED IN UNETHICAL AND DISHONEST CONDUCT BY FAILING www.finra.org/brokercheck TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY User Guidance INSULATED FROM PRESSURES AND INFLUENCES OF COVERED COMPANIES AND INVESTMENT BANKING. THE FIRM ALSO FAILED TO REASONABLY SUPERVISE ITS EMPLOYEES IN CONNECTION WITH THE ISSUANCE OF RESEARCH. Initiated By: MAINE OFFICE OF SECURITIES Date Initiated: 05/30/2003 Docket/Case Number: 03-104 URL for Regulatory Action: Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 08/28/2003 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: PENALTY OF $250,000 WAS PAID ON 8/28/2003. Regulator Statement THE FIRM WAS ORDERED TO CEASE AND DESIST FROM VIOLATING THE RMSA IN CONNECTION WITH CERTAIN CONFLICTS OF INTEREST TO WHICH ITS RESEARCH ANALYSTS WERE SUBJECT AND TO IMPLEMENT CERTAIN CHANGES WITH RESPECT TO ITS RESEARCH AND BANKING PRACTICES. THE CONSENT ORDER WAS EXECUTED AS PART OF A GLOBAL SETTLEMENT OF COORDINATED INVESTIGATIONS ENTERED INTO BY FEDERAL AND STATE REGULATORS, AND SEVERAL LARGE BROKER- DEALERS WHO ENGAGED IN THE RESEARCH PRACTICES AT ISSUE. i Reporting Source: Firm Current Status: Final Allegations: THE STATE OF MAINE ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND ©2021 FINRA. All rights reserved. Report aboutPRACTICES J.P. MORGAN THAT SECURITIES CREATED INC. AND/OR MAINTAINED INAPPROPRIATE 195 INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. www.finra.org/brokercheck User Guidance

Allegations: THE STATE OF MAINE ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF MAINE, DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION, OFFICE OF SECURITIES Date Initiated: 05/02/2003 Docket/Case Number: 03-104

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

Resolution: Settled Resolution Date: 08/28/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 196 www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON AUGUST 27, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON AUGUST 28, 2003. i Disclosure 68 of 102 Reporting Source: Regulator Current Status: Final Allegations: J.P. MORGAN'S ACTIVITIES IN CONNECTION WITH CERTAIN CONFLICTS OF INTEREST THAT RESEARCH ANALYSTS WERE SUBJECT TO DURING THE PERIOD OF JULY 1, 1999, THROUGH JUNE 30, 2001. Initiated By: KANSAS SECURITIES COMMISSIONER Date Initiated: 05/19/2003 Docket/Case Number: 2003E046/KSC 2003-4739 URL for Regulatory Action: Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 10/09/2003 Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: J.P. MORGAN WILL CEASE AND DESIST FROM VIOLATING KSA 17-1254(M)(7) & (12) IN CONNECTION WITH THE RESEARCH PRACTICES REFERENCED IN THE ORDER, WILL COMPLY WITH KSA 17-1254 (M) (7)&(12) IN CONNECTION ©2021 FINRA. All rights reserved. Report aboutWITH J.P. THE MORGAN RESEARCH SECURITIES PRACTICES INC. REFERENCED IN THE ORDER, AND WILL 197 COMPLY WITH THE UNDERTAKINGS. www.finra.org/brokercheck User Guidance J.P. MORGAN WILL CEASE AND DESIST FROM VIOLATING KSA 17-1254(M)(7) & (12) IN CONNECTION WITH THE RESEARCH PRACTICES REFERENCED IN THE ORDER, WILL COMPLY WITH KSA 17-1254 (M) (7)&(12) IN CONNECTION WITH THE RESEARCH PRACTICES REFERENCED IN THE ORDER, AND WILL COMPLY WITH THE UNDERTAKINGS. i Reporting Source: Firm Current Status: Final Allegations: THE STATE OF KANSAS ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: KANSAS, OFFICE OF THE SECURITIES COMMISSIONER Date Initiated: 05/19/2003 Docket/Case Number: 2003E046

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

Resolution: Settled Resolution Date: 10/09/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON OCTOBER 7, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON OCTOBER 9, 2003. i Disclosure 69 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF IDAHO ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF IDAHO, DEPARTMENT OF FINANCE ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 199 www.finra.org/brokercheck User Guidance

Initiated By: STATE OF IDAHO, DEPARTMENT OF FINANCE Date Initiated: 05/20/2003 Docket/Case Number: 2003-7-25

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

Resolution: Settled Resolution Date: 09/02/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON AUGUST 28, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 2, 2003. i Disclosure 70 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF HAWAII ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE ©2021 FINRA. All rights reserved. Report aboutSUBJECT J.P. MORGAN TO CONFLICTS SECURITIES INC.OF INTEREST BETWEEN SUPPORTING THE 200 INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. THE STATE OF HAWAII ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING www.finra.org/brokercheck AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH User Guidance DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF HAWAII, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS Date Initiated: 05/13/2003 Docket/Case Number: SEU2002-042

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

Resolution: Settled Resolution Date: 09/17/2003 Sanctions Ordered: Monetary/Fine $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $250,000.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 11, 2003. Firm Statement SETTLED BY A CONSENT ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 17, 2003. i Disclosure 71 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF ARIZONA ALLEGES THAT DURING THE PERIOD OF JULY 1, ©2021 FINRA. All rights reserved. Report about1999 J.P. TO MORGAN JUNE 30, SECURITIES 2001 J.P. INC. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS 201 AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. www.finra.org/brokercheck User Guidance

Allegations: THE STATE OF ARIZONA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF ARIZONA, ARIZONA CORPORATION COMMISSION Date Initiated: 05/05/2003 Docket/Case Number: S-03534A-03-0000

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

Resolution: Settled Resolution Date: 09/24/2003 Sanctions Ordered: Monetary/Fine $395,321.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES.

©2021Sanction FINRA. Details: All rights reserved. Report aboutFINE J.P. OF MORGAN $395,321.00.00, SECURITIES ALL INC. OF WHICH WAS LEVIED AGAINST JPMSI AND 202 PAID BY JPMSI ON AUGUST 27, 2003. www.finra.org/brokercheck User Guidance

Sanction Details: FINE OF $395,321.00.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON AUGUST 27, 2003. Firm Statement SETTLED BY AN ORDER TO CEASE AND DESIST, ORDER FOR ADMINISTRATIVE PENALTIES AND CONSENT TO SAME THAT WERE FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 24, 2003. i Disclosure 72 of 102 Reporting Source: Firm Current Status: Final Allegations: THE STATE OF ALABAMA ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. THE RESEARCH DEPARTMENT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH INVESTMENT BANKING DEPARTMENT, AND SUCH DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. Initiated By: STATE OF ALABAMA, ALABAMA SECURITIES COMMISSION Date Initiated: 05/22/2003 Docket/Case Number: CO-2003

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

Resolution: Settled Resolution Date: 09/23/2003 Sanctions Ordered: Monetary/Fine $342,654.00 Cease and Desist/Injunction Other Sanctions Ordered: ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE OF $342,654.00, ALL OF WHICH WAS LEVIED AGAINST JPMSI AND PAID BY JPMSI ON SEPTEMBER 18, 2003. Firm Statement SETTLED BY AN ADMINISTRATIVE ORDER THAT WAS FULLY EXECUTED AND EFFECTIVE ON SEPTEMBER 23, 2003. i Disclosure 73 of 102 Reporting Source: Firm Current Status: Final Allegations: NYSE ALLEGES THAT J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREFORE IMPOSED CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 4. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE FOREGOING INVESTMENT BANKING INFLUENCES AND CONFLICTS OF INTEREST, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO ASSURE COMPLIANCE WITH APPLICABLE NYSE RULES. ALLEGED VIOLATIONS: VIOLATION OF NYSE EXCHANGE RULES 342, 401, 472 AND 476(A)(6) Initiated By: NEW YORK STOCK EXCHANGE, INC. ("NYSE") Date Initiated: 04/22/2003

Docket/Case Number:

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY PENALTY, DISGORGEMENT/RESTITUTION, PAYMENTS FOR Sought: INDEPENDENT RESEARCH AND INVESTOR EDUCATION.

Resolution: Stipulation and Consent Resolution Date: 04/22/2003 Sanctions Ordered: Censure Monetary/Fine $25,000,000.00 Disgorgement/Restitution Other Sanctions Ordered: $25,000,000.00, TO BE USED FOR THE PROCUREMENT OF INDEPENDENT RESEARCH; $5,000,000.00, TO BE USED FOR INVESTOR EDUCATION, AS DESCRIBED IN THE FINAL JUDGMENT REFERRED TO IN C BELOW; ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: CENSURE AND TOTAL PAYMENTS OF $80,000,000.00, AS SPECIFIED IN THE FINAL JUDGMENT ORDERED IN A RELATED ACTION FILED BY THE U.S. SECURITIES AND EXCHANGE COMMISSION, AND SUBJECT TO THE DECISION OF STATE SECURITIES REGULATORS NOT TO SETTLE, AS FOLLOWS: $25,000,000.00, AS A PENALTY; $25,000,000.00, AS DISGORGEMENT; $25,000,000.00, TO BE USED FOR THE PROCUREMENT OF INDEPENDENT RESEARCH; AND $5,000,000.00, TO BE USED FOR INVESTOR EDUCATION. THE MONETARY SANCTIONS IMPOSED BY NYSE SHALL BE REDUCED BY THE AMOUNTS PAID BY JPMSI PURSUANT TO THE FINAL JUDGMENT. OF THE PENALTY AND DISGORGEMENT, $25,000,000.00 TO BE PAID WITHIN 10 DAYS OF ENTRY OF THE FINAL JUDGMENT, AND $25,000,000.00 TO BE PAID TO THE STATES AS THEY JOIN THE SETTLEMENT; THE OTHER AMOUNTS TO BE PAID OVER 5 YEARS. Firm Statement THE PROCEEDING SETTLED AS FOLLOWS: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, JPMSI CONSENTED TO FINDINGS BY THE EXCHANGE HEARING PANEL. i Disclosure 74 of 102 Reporting Source: Regulator Current Status: Final Allegations: J.P. MORGAN SECURITIES INC FAILED TO ENFORCE SUPERVISORY ©2021 FINRA. All rights reserved. Report aboutPROCEDURES J.P. MORGAN ANDSECURITIES ENGAGED INC. IN INEQUITABLE PRACTICES BY FAILING TO 205 MAMAGE CONFLICTS BETWEEN ITS INVESTMENT BANKING DEPT & RESEARCH ANALYSTS. www.finra.org/brokercheck User Guidance

Allegations: J.P. MORGAN SECURITIES INC FAILED TO ENFORCE SUPERVISORY PROCEDURES AND ENGAGED IN INEQUITABLE PRACTICES BY FAILING TO MAMAGE CONFLICTS BETWEEN ITS INVESTMENT BANKING DEPT & RESEARCH ANALYSTS. Initiated By: TEXAS Date Initiated: 04/24/2003 Docket/Case Number: SSB DKT NO 03-019;ORDER NO. CAF-1510 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE Sought:

Resolution: Order Resolution Date: 04/24/2003 Sanctions Ordered: Monetary/Fine $1,606,657.00 Other Sanctions Ordered: REPRIMAND & UNDERTAKING Sanction Details: FINE PAID ON APRIL 24, 2003. Regulator Statement J.P. MORGAN SECURITIES, INC. WAS FINED AND REPRIMANDED & FILED AN UNDERTAKING IN CONNECTION WITH FINDINGS THAT RESPONDENT FAILED TO ENFORCE SUPERVISORY PROCEDURES AND ENGAGED IN INEQUITABLE PRACTICES BY FAILING TO MANAGE CONFLICTS BETWEEN ITS INVESTMENT BANKING DEPT & RESEARCH ANALYSTS. i Reporting Source: Firm Current Status: Final Allegations: TEXAS ALLEGES THAT J.P. MORGAN SECURITIES INC. FAILED TO ENFORCE SUPERVISORY PROCEDURES AND ENGAGED IN INEQUITABLE PRACTICES BY FAILING TO MANAGE CONFLICTS OF INTEREST BETWEEN ITS INVESTMENT BANKING DEPARTMENT AND RESEARCH ANALYSTS. Initiated By: TEXAS Date Initiated: 04/24/2003 Docket/Case Number: SSB DKT NO 03-019; ORDER NO. CAF-1510 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 206 www.finra.org/brokercheck User Guidance

Docket/Case Number: SSB DKT NO 03-019; ORDER NO. CAF-1510

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

Resolution: Order Resolution Date: 04/24/2003 Sanctions Ordered: Monetary/Fine $1,606,657.00 Other Sanctions Ordered: REPRIMAND & UNDERTAKING TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: FINE PAID ON APRIL 24, 2003. Firm Statement ON APRIL 21, 2003 J.P. MORGAN SECURITIES INC. AGREED TO A FINE AND REPRIMAND AND FILED AN UNDERTAKING TO CHANGE CERTAIN BUSINES PRACTICES. THE ORDER DISPOSING OF THE PROCEEDING WAS SIGNED AND ENTERED BY THE TEXAS SECURITIES COMMISSIONER ON APRIL 24, 2003. i Disclosure 75 of 102 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULE 2110, 2210(D)(1)(A) AND 3010(A) - RESPONDENT MEMBER J.P. MORGAN SECURITIES, INC. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREFORE IMPOSED CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. MADE PAYMENTS TO OTHER BROKER-DELEARS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE. THE FIRM DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; AND, FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES FOR SUPERVISION AND CONTROL OF THE RESEARCH AND INVESTMENT BANKING DEPARTMENTS REASONABLY DESIGNED TO DETECT AND PREVENT THE FOREGOING INVESTMENT BANKING INFLUENCES AND CONFLICTS OF INTEREST, INCLUDING A SEPARATE ©2021 FINRA. All rights reserved. Report aboutSYSTEM J.P. MORGAN OF FOLLOW-UP SECURITIES ANDINC. REVIEW TO ASSURE COMPLIANCE WITH 207 APPLICABLE NASD RULES. NASD CONDUCT RULE 2110, 2210(D)(1)(A) AND 3010(A) - RESPONDENT MEMBER J.P. MORGAN SECURITIES, INC. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREFORE IMPOSED CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. MADE PAYMENTS TO OTHER BROKER-DELEARS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE. THE FIRM DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; AND, www.finra.org/brokercheck FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND User Guidance PROCEDURES FOR SUPERVISION AND CONTROL OF THE RESEARCH AND INVESTMENT BANKING DEPARTMENTS REASONABLY DESIGNED TO DETECT AND PREVENT THE FOREGOING INVESTMENT BANKING INFLUENCES AND CONFLICTS OF INTEREST, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO ASSURE COMPLIANCE WITH APPLICABLE NASD RULES. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/24/2003 Docket/Case Number: CAF030019

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: 04/24/2003 Sanctions Ordered: Censure Monetary/Fine $25,000,000.00 Disgorgement/Restitution Other Sanctions Ordered: $25,000,000, TO BE USED FOR THE PROCUREMENT OF INDEPENDENT RESEARCH AND $5,000,000, TO BE USED FOR INVESTOR EDUCATION, AS DESICRBED IN THE FINAL JUDGMENT. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE FINDING OF THE ALLEGATIONS AND TO THE FOLLOWING SANCTIONS: CENSURE AND A TOTAL PAYMENT OF $80,000,000.00, AS SPECIFIED IN THE FINAL JUDGEMENT ORDERED IN A RELATED ACTION FILED BY THE SECURITIES AND EXCHANGE COMMISSION. $25,000,000, AS A FINE, $25,000,000, AS DISGORGEMENT OF COMMISSIONS, FEES, AND OTHER MONIES; $25,000,000, TO BE USED FOR THE PROCUREMENT OF INDEPENDENT RESEARCH AND $5,000,000, TO BE USED FOR INVESTOR EDUCATION, AS DESICRBED IN THE FINAL JUDGMENT. THE MONETARY SANCTIONS IMPOSED BY NASD SHALL BE REDUCED BY THE AMOUNTS PAID BY RESPONDENT MEMBER PURSUANT TO THE FINAL JUDGMENT. Regulator Statement RESPONDENT AGREES THAT IT SHALL NOT SEEK OR ACCEPT, DIRECTLY OR INDIRECTLY, REIMBURSEMENT OR INDEMNIFICATION, INCLUDING BUT NOT LIMITED TO PAYMENT MADE PURSUANT TO ANY INSURANCE POLICY, WITH REGARD TO ANY FINE/PENALTY AMOUNTS THAT RESPONDENT SHALL PAY PURSUANT TO SECTION II OF THE FINAL JUDGMENT, REGARDLESS OF WHETHER SUCH FINE/PENALTY AMOUNTS OR ANY PART THEREOF ARE ADDED TO THE DISTRIBUTION FUND ACCOUNT OR ©2021 FINRA. All rights reserved. Report aboutOTHERWISE J.P. MORGAN USED SECURITIES FOR THE INC. BENEFIT OF INVESTORS. RESPONDENT 208 FURTHER AGREES THAT IT SHALL NOT CLAIM, ASSERT, OR APPLY FOR A TAX DEDUCTION OR TAX CREDIT WITH REGARD TO ANY FEDERAL, STATE, OR LOCAL TAX FOR ANY FINE/PENALTY AMOUNTS THAT RESPONDENT SHALL PAY PURSUANT TO SECTION II OF FINAL JUDGMENT, REGARDLESS OF WHETHER SUCH FINE/PENALTY AMOUNTS OR ANY PART THEREOF ARE ADDED TO THE DISTRIBUTION FUND ACCOUNT OR OTHERWISE USED FOR THE BENEFIT OF INVESTORS. RESPONDENT UNDERSTANDS AND ACKNOWLEDGES THAT THESE PROVISIONS ARE NOT INTENDED TO IMPLY THAT NASD WOULD AGREE THAT ANY OTHER AMOUNTS RESPONDENT SHALL PAY PURSUANT TO THE FINAL JUDGEMENT MAY BE REIMBURSED OR INDEMNIFIED (WHETHER PURSUANT TO AN INSURANCE POLICY OR OTHERWISE) UNDER APPLICABLE LAW OR MAY BE THE BASIS FOR ANY TAX DEDUCTION OR TAX CREDIT WITH REGARD TO ANY FEDERAL, STATE, OR LOCAL TAX. RESPONDENT AGREES THAT IT SHALL NOT SEEK OR ACCEPT, DIRECTLY OR INDIRECTLY, REIMBURSEMENT OR INDEMNIFICATION, INCLUDING BUT www.finra.org/brokercheck NOT LIMITED TO PAYMENT MADE PURSUANT TO ANY INSURANCE POLICY, User Guidance WITH REGARD TO ANY FINE/PENALTY AMOUNTS THAT RESPONDENT SHALL PAY PURSUANT TO SECTION II OF THE FINAL JUDGMENT, REGARDLESS OF WHETHER SUCH FINE/PENALTY AMOUNTS OR ANY PART THEREOF ARE ADDED TO THE DISTRIBUTION FUND ACCOUNT OR OTHERWISE USED FOR THE BENEFIT OF INVESTORS. RESPONDENT FURTHER AGREES THAT IT SHALL NOT CLAIM, ASSERT, OR APPLY FOR A TAX DEDUCTION OR TAX CREDIT WITH REGARD TO ANY FEDERAL, STATE, OR LOCAL TAX FOR ANY FINE/PENALTY AMOUNTS THAT RESPONDENT SHALL PAY PURSUANT TO SECTION II OF FINAL JUDGMENT, REGARDLESS OF WHETHER SUCH FINE/PENALTY AMOUNTS OR ANY PART THEREOF ARE ADDED TO THE DISTRIBUTION FUND ACCOUNT OR OTHERWISE USED FOR THE BENEFIT OF INVESTORS. RESPONDENT UNDERSTANDS AND ACKNOWLEDGES THAT THESE PROVISIONS ARE NOT INTENDED TO IMPLY THAT NASD WOULD AGREE THAT ANY OTHER AMOUNTS RESPONDENT SHALL PAY PURSUANT TO THE FINAL JUDGEMENT MAY BE REIMBURSED OR INDEMNIFIED (WHETHER PURSUANT TO AN INSURANCE POLICY OR OTHERWISE) UNDER APPLICABLE LAW OR MAY BE THE BASIS FOR ANY TAX DEDUCTION OR TAX CREDIT WITH REGARD TO ANY FEDERAL, STATE, OR LOCAL TAX. i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGES THAT J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREFORE IMPOSED CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. MADE PAYMENTS TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 4. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE FOREGOING INVESTMENT BANKING INFLUENCES AND CONFLICTS OF INTEREST, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO ASSURE COMPLIANCE WITH APPLICABLE NASD RULES. ALLEGED VIOLATIONS: VIOLATION OF NASD CONDUCT RULES 2110, 2210(D)(1)(A) AND 3010(A). Initiated By: NASD, INC. Date Initiated: 04/24/2003 Docket/Case Number: CAF030019

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE, DISGORGEMENT/RESTITUTION, PAYMENTS FOR Sought: INDEPENDENT RESEARCH AND INVESTOR EDUCATION.

Allegations: SECTION 17(A) OF THE SECURITIES EXCHANGE ACT, SEC RULE 17A-3 PROMULGATED THEREUNDER, NASD RULES 2110, 2330, 2710(B)(5)(A)(II), 3010, 3110 - RESPONDENT MEMBER ENGAGED IN IMPROPER PROFIT- SHARING WITH CERTAIN PUBLIC CUSTOMERS THROUGH THE FIRM'S RECEIPT OF INFLATED COMMISSIONS IN UNRELATED STOCK TRANSACTIONS FROM CUSTOMERS THAT SOUGHT AND RECEIVED HOT IPO ALLOCATIONS OF NUMEROUS ISSUERS; THE COMMISSIONS WERE PAID ON INSTITUTION-SIZED AGENCY TRANSACTIONS IN HIGHLY LIQUID LISTED SECURITIES UNRELATED TO THE IPOS; THE FIRM'S INSTITUTIONAL SALES TRADERS KNEW OF THE HOT IPO ALLOCATION BEING ALLOCATED TO CUSTOMER ACCOUNTS, DISCUSSED THE COMMISSION RATE THAT CUSTOMERS PLACED ON EVERY TRADE AND ENTERED THE COMMISSION RATE IN THE FIRM'S INPUT SYSTEM; CUSTOMER ACCOUNTS ALSO ENGAGED IN NON-ECONOMIC OFFSETTING TRADING TO SHARE PROFITS WITH THE FIRM THAT RESULTED IN AN IMMEDIATE LOSS FOR THE CUSTOMER BUT GENERATED HIGH COMMISSION PAYMENTS TO SHARE PROFITS FROM IPO ALLOCATIONS;AS MANAGING UNDERWRITER IN A PUBLIC OFFERING, FAILED TO FILE WITH NASD DOCUMENTS AND INFORMATION DESCRIBING ANY ARRANGEMENTS IN CONNECTION WITH, OR RELATED TO, THE DISTRIBUTION OF AN IPO THAT MAY HAVE A BEARING ON NASD'S REVIEW AND APPROVAL OF THE UNDERWRITING AND OTHER TERMS AND ARRANGEMENTS; FAILED TO REFLECT ACCURATELY IN ITS BOOKS AND RECORDS THAT THE FIRM SHARED IN ITS CUSTOMERS' IPO PROFITS; AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE FEDERAL SECURITIES, LAWS, AND NASD RULES. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/19/2003 Docket/Case Number: CAF030006

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/19/2003 Sanctions Ordered: Censure Monetary/Fine $1,000,000.00 ©2021 FINRA. All rights reserved. Report aboutDisgorgement/Restitution J.P. MORGAN SECURITIES INC. 211 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $1,000,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN SECURITIES, INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $1 MILLION, AND REQUIRED TO DISGORGE $5 MILLION. PAYMENT OF FINE AND DISGORGEMENT TO NASD SHALL BE MADE WITH 10 DAYS OF NOTICE OF ACCEPTANCE OF THIS AWC. i Reporting Source: Firm Current Status: Final Allegations: NASD ALLEGES THAT HAMBRECHT & QUIST LLC (SINCE ACQUIRED BY J.P. MORGAN CHASE) ENGAGED IN IMPROPER PROFIT-SHARING BY RECEIVING INFLATED COMMISSIONS FROM IPO CUSTOMERS ON UNRELATED AGENCY TRADES. NASD ALSO ALLEGES THAT HAMBRECHT & QUIST LLC FAILED TO ACCURATELY REPORT THESE PROFITS IN ITS BOOKS AND RECORDS AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLE SUPERVISORY SYSTEM. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/19/2003 Docket/Case Number: CAF0300006

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/19/2003 Sanctions Ordered: Censure Monetary/Fine $1,000,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN SECURITIES INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TO ©2021 FINRA. All rights reserved. Report aboutTHE J.P. ENTRY MORGAN OF SECURITIESFINDINGS; INC. THE FIRM AGREED TO A $1 MILLION FINE AND $5 212 MILLION DISGORGEMENT. www.finra.org/brokercheck User Guidance

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN SECURITIES INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THE FIRM AGREED TO A $1 MILLION FINE AND $5 MILLION DISGORGEMENT. i Disclosure 77 of 102 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010 AND 3360 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT IT SUBMITTED TO NASD ITS MONTHLY SHORT INTEREST POSITION REPORT. THIS REPORT INCLUDED A SHORT INTEREST POSITION OF 0 SHARES OF A COMPANY ("COMPANY"), WHEN THE FIRM'S ACTUAL SHORT INTEREST IN COMPANY WAS 885,348 SHARES; A SHORT INTEREST POSITION OF 0 SHARE IN ANOTHER COMPANY, WHEN THE FIRM'S ACTUAL SHORT INTEREST IN ANOTHER COMPANY WAS 315,610 SHARES; AND A SHORT INTEREST POSITION OF 787,299 SHARES OF THIRD COMPANY, WHEN THE FIRM'S ACTUAL SHORT INTEREST IN THIRD COMPANY WAS 794,699. THE FIRM?S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS CONCERNING SHORT INTEREST REPORTING. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR THE IDENTIFICATION OF THE PERSON RESPONSIBLE AT THE FIRM TO ENSURE COMPLIANCE WITH THE APPLICABLE RULES; A STATEMENT OF THE STEPS THAT SUCH PERSON SHOULD TAKE TO ENSURE COMPLIANCE; A STATEMENT AS TO HOW OFTEN SUCH PERSON SHOULD TAKE SUCH STEPS; AND A STATEMENT AS TO HOW ENFORCEMENT OF SUCH WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED AT THE FIRM. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 10/14/2002 Docket/Case Number: CMS020184

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: 10/14/2002 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $7,500 ($2,500 FOR SHORT INTEREST REPORTING AND $5,000 FOR SUPERVISION). i Reporting Source: Firm Current Status: Final Allegations: VIOLATION OF NASD CONDUCT RULES 2110, 3010 AND 3360 - WITHOUT ADMITING OR DENYING THE ALLEGATIONS, J.P MORGAN SECURITIES INC. CONSENTED TO THE ENTRY OF THE FOLLOWING FINDINGS BY NASD REGULATION,INC.: JPMSI SUBMITTED TO NASD ITS MONTHLY SHORT INTEREST POSITION REPORT. THIS REPORT INCLUDED A SHORT INTEREST OF 0 SHARES OF A COMPANY, WHEN THE FIRM'S ACTUAL SHORT INTEREST IN SAID COMPANY WAS 885,348 SHARES; A SHORT INTEREST POSITION OF 0 SHARES IN ANOTHER COMPANY, WHEN THE FIRM'S ACTUAL SHORT INTEREST IN SAID COMPANY WAS 315,610 SHARES; AND A SHORT INTEREST POSITION OF 787,299 SHARES OF A THIRD COMPANY, WHEN THE FIRM'S ACTUAL SHORT INTEREST IN THE THIRD COMPANY WAS 794,699. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS CONCERNING SHORT INTEREST REPORTING. SPECIFICALLY, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURES PROVIDING FOR THE IDENTIFICATION OF THE PERSON RESPONSIBLE AT THE FIRM TO ENSURE COMPLIANCE WITH THE APPLICABLE RULES; A STATEMENT OF THE STEPS THAT SUCH PERSON SHOULD TAKE TO ENSURE COMPLIANCE; A STATEMENT AS TO HOW OFTEN SUCH PERSON SHOULD TAKE SUCH STEPS; AND A STATEMENT AS TO HOW ENFORCEMENT OF SUCH WRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED AT THE FIRM. Initiated By: DEPARTMENT OF MARKET REGULATION - NASD REGULATION, INC. Date Initiated: 10/01/2000 Docket/Case Number: CMS020184 AWC

Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief A CENSURE AND A FINE OF $7,500 ($2,500 FOR SHORT INTEREST Sought: REPORTING AND $5,000 FOR SUPERVISION).

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief AND FINE OF $10,000.00 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/28/2001 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM HEREBY ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, TO THE ENTRY OF THE FOLLOWING ©2021 FINRA. All rights reserved. Report aboutFINDINGS J.P. MORGAN BY NASDR SECURITIES INC. INC. VIOLATIONS OF NASD MARKETPLACE RULES 215 4613 (E) (1) (C) AND ALSO CONSENTS TO THE IMPOSITION, AT A MAXIMUM, OF THE FOLLOWING SANCTIONS A CENSURE AND FINE OF $10,000.00. THE LETTER OF ACCEPTANCE WAIVER AND CONSENT WAS SIGNED BY THE FIRM ON 6/28/2001. www.finra.org/brokercheck User Guidance

Sanction Details: THE FIRM HEREBY ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, TO THE ENTRY OF THE FOLLOWING FINDINGS BY NASDR INC. VIOLATIONS OF NASD MARKETPLACE RULES 4613 (E) (1) (C) AND ALSO CONSENTS TO THE IMPOSITION, AT A MAXIMUM, OF THE FOLLOWING SANCTIONS A CENSURE AND FINE OF $10,000.00. THE LETTER OF ACCEPTANCE WAIVER AND CONSENT WAS SIGNED BY THE FIRM ON 6/28/2001. i Disclosure 79 of 102 Reporting Source: Firm Current Status: Final Allegations: SEC INVESTIGATION INTO THE DISTRIBUTION OF GSE SECURITIES. Initiated By: SECURITIES AND EXCHANGE COMMISSION, INC. Date Initiated: 01/16/1992 Docket/Case Number: N/A

Principal Product Type: Other Other Product Type(s): GSE SECURITIES Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CEASE AND DESIST AND $100,000.00 FINE. Sought:

Resolution: Settled Resolution Date: 01/16/1992 Sanctions Ordered: Monetary/Fine $100,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CEASE AND DESIST ORDER WITH A $100,000.00 FINE. Firm Statement THE FIRM IS ONE OF APPROX. ONE HUNDRED DEALERS IN GOVERNMENT SPONSORED ENTERPRISE ("GSE") SECURITIES SUBJECT TO THE ORDER WHICH RESULTED FROM THE SEC'S INVESTIGATION INTO THE DISTRIBUTION OF GSE SECURITIES. THE FIRM, WITHOUT ADMITTING OR DENYING ANY FINDINGS, SUBMITTED AN OFFER OF SETTLEMENT, WHICH WAS ACCEPTED BY THE SEC. JPMSI WAS FINED AND ORDERED TO CEASE AND DESISIT FROM COMMITTING OR CAUSING ANY VIOLATIONS OR FROM COMMITING OR CAUSING ANY FUTURE VIOLATIONS OF SECT. 17(A) OF THE EXCHANGE ACT IN CONNECTION WITH THE PRIMARY DISTRIBUTION OF GSE UNSECURED DEBT SECURITIES. ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 216 THE FIRM IS ONE OF APPROX. ONE HUNDRED DEALERS IN GOVERNMENT SPONSORED ENTERPRISE ("GSE") SECURITIES SUBJECT TO THE ORDER WHICH RESULTED FROM THE SEC'S INVESTIGATION INTO THE DISTRIBUTION OF GSE SECURITIES. THE FIRM, WITHOUT ADMITTING OR DENYING ANY FINDINGS, SUBMITTED AN OFFER OF SETTLEMENT, WHICH www.finra.org/brokercheck WAS ACCEPTED BY THE SEC. JPMSI WAS FINED AND ORDERED TO CEASE User Guidance AND DESISIT FROM COMMITTING OR CAUSING ANY VIOLATIONS OR FROM COMMITING OR CAUSING ANY FUTURE VIOLATIONS OF SECT. 17(A) OF THE EXCHANGE ACT IN CONNECTION WITH THE PRIMARY DISTRIBUTION OF GSE UNSECURED DEBT SECURITIES. i Disclosure 80 of 102 Reporting Source: Firm Current Status: Final Allegations: ALLEGED THAT ON 13 OCCASIONS FROM 8/7 THROUGH 9/15/2000, J.P. MORGAN SECURITIES INC., A MARKET MAKER IN THE REFLECTED SECURITIES, (EXHIBIT A OF AWC), WITHOUT MAKING REASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET BY EXECUTING TRANSACTIONS WITH ALL MARKET MAKERS WHOSE QUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED A BID OR ASKED QUOTATION IN THE NASDAQ STOCK MARKET WHICH CAUSED A LOCKED OR CROSSED MARKET CONDITION TO OCCUR IN EACH INSTANCE. Initiated By: NASDR, INC. Date Initiated: 07/01/2000 Docket/Case Number: MRD200027150

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 FINE OF $5000.00 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/14/2001 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: FINE OF $5000.00 Firm Statement THE FIRM HEREBY ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS TO THE FOLLOWING FINDINGS BY NASDR: ON 13 OCCASIONS FROM 8/7 THROUGH 9/15/2000, J.P. MORGAN SECURITIES INC., A MARKET MAKER IN THE REFLECTED SECURITIES, (EXHIBIT A OF AWC), WITHOUT MAKING REASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET BY EXECUTING TRANSACTIONS WITH ALL MARKET MAKERS WHOSE QUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED A BID OR ASKED QUOTATION IN THE NASDAQ STOCK MARKET WHICH CAUSED A LOCKED OR CROSSED MARKET CONDITION TO ©2021 FINRA. All rights reserved. Report aboutOCCUR J.P. MORGAN IN EACH SECURITIES INSTANCE. INC. THIS CONDUCT CONSTITUTES ALLEGED 217 VIOLATIONS OF NASD MARKET PLACE RULE 4613(E). THE FIRM ALSO CONSENTS TO THE IMPOSITION, AT A MAXIMUM, OF THE FOLLOWING SANCTIONS: FINE OF $5000.00. THE FIRM HEREBY ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS TO THE FOLLOWING FINDINGS BY NASDR: ON 13 OCCASIONS FROM 8/7 THROUGH 9/15/2000, J.P. MORGAN SECURITIES INC., A MARKET MAKER IN THE REFLECTED SECURITIES, www.finra.org/brokercheck (EXHIBIT A OF AWC), WITHOUT MAKING REASONABLE EFFORTS TO AVOID A User Guidance LOCKED OR CROSSED MARKET BY EXECUTING TRANSACTIONS WITH ALL MARKET MAKERS WHOSE QUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED A BID OR ASKED QUOTATION IN THE NASDAQ STOCK MARKET WHICH CAUSED A LOCKED OR CROSSED MARKET CONDITION TO OCCUR IN EACH INSTANCE. THIS CONDUCT CONSTITUTES ALLEGED VIOLATIONS OF NASD MARKET PLACE RULE 4613(E). THE FIRM ALSO CONSENTS TO THE IMPOSITION, AT A MAXIMUM, OF THE FOLLOWING SANCTIONS: FINE OF $5000.00. i Disclosure 81 of 102 Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF ACTS, PRACTICES AND CONDUCT OF CBOE RULE 4.11 (POSITION LIMITS). Initiated By: CHICAGO BOARD OF OPTIONS EXCHANGE ("CBOE") Date Initiated: 04/03/1998 Docket/Case Number: CBOE FILE NO. 98-SF002

Principal Product Type: Other Other Product Type(s): POSITION LIMITS Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief SETTLEMENT - $8000.00 Sought:

Resolution: Settled Resolution Date: 08/07/1998 Sanctions Ordered: Monetary/Fine $8,000.00 Other Sanctions Ordered: SETTLEMENT OF CHARGES BY PAYMENT OF $8,000.00 Sanction Details: SEE 12B Firm Statement N/A i Disclosure 82 of 102 Reporting Source: Firm Current Status: Final Allegations: SEE ITEM 13 AND ITEM 3 SUMMARY Initiated By: SECURITIES AND EXCHANGE COMMISSION, INC. Date Initiated: 01/11/1999 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 218 www.finra.org/brokercheck User Guidance

Date Initiated: 01/11/1999 Docket/Case Number: 34-40900 & 34-40910

Principal Product Type: Other Other Product Type(s): NASDAQ SECURITIES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief SEE 12B Sought:

Resolution: Settled Resolution Date: 01/11/1999 Sanctions Ordered: Monetary/Fine $1,275,000.00 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: WITHOUT ADMITTING OR DENYING THE ALLEGATINS, JPMS AGREED TO PAY A DISGORGEMENT OF $42,218.00 AND A CIVIL PENALTY OF $1.275 MILLION TO SETTLE THE MATTER. IN ADDITION, IT AGREED TO A CEASE AND DESIST ORDER AND TO SUBMIT CERTAIN OF ITS POLICIES TO AN INDEPENDENT CONSULTANT. Sanction Details: SEE 12B Firm Statement JPMSI'S CIVIL FINE ALSO INCLUDED PAYMENT OF A PENALTY IMPOSED FOR AN ALLEGED VIOLATION, NEITHER ADMITTED NOR DENIED BY JPMS, OF SECTION 15 (F) OF THE EXCHANGE ACT, WHICH REQUIRES FIRMS TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN POLICIES AND PROCEDURES TO PREVENT THE MISUSE OF MATERIAL, NONPUBLIC INFORMATION. i Disclosure 83 of 102 Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF SEC RULE 11AC1-4 AND NASD CONDUCT RULE 2110,IM-2110-2 AND 2320, NASD RULE 3010 , NASD CONDUCT RULE 3370, NASD CONDUCT RULES 4632, NASD MARKETPLACE RULE 6130 (D), NASD MARKETPLACE RULE 6620, NASD MARKETPLACE RULE 4632. Initiated By: NASD REGULATION, INC. Date Initiated: 11/18/1999 Docket/Case Number: CMS000109AWC ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 219 www.finra.org/brokercheck User Guidance

Docket/Case Number: CMS000109AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief A CENSURE AND A FINE OF $200,000.00 ($100,000 FOR SUPERVISION, Sought: $75,000 FOR LIMIT ORDER DISPLAY, $5,000 FOR TRADE REPORTING, $9,000 FOR LIMIT ORDER PROTECTION, $10,000 FOR BEST EXECUTION AND $1,000 FOR AFFIRMATIVE DETERMINATION), RESTITUTION BY THE FIRM TO THE INVESTORS LISTED ON EXHIBIT C AND D IN THE THE TOTAL AMOUNT OF $3,987.65, PLUS INTEREST.

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/26/2000 Sanctions Ordered: Censure Monetary/Fine $200,000.00 Disgorgement/Restitution Other Sanctions Ordered: RESTITUTION AMOUNT $3,987.65, PLUS INTEREST. Sanction Details: SEE ITEM #2 UNDER CENSURE FOR A DETAILED LISTING OF THE IMPOSITION OF SANCTIONS. Firm Statement THE LETTER OF ACCEPTANCE WAIVER AND CONSENT NO. CMS000109AWC WAS ACCEPTED BY THE NASD REGULATION, INC'S OFFICE OF DISCIPLINARY AFFAIRS ON MAY 26, 2000. J.P. MORGAN SECURITIES INC., (JPMSI) HAS NEITHER ADMITTED NOR DENIED THE ALLEGED VIOLATIONS CONTAINED IN THE AWC. AS WELL, THE AWC HAS BEEN ACCEPTED ON THE CONDITION THAT THE NASDR WILL NOT BRING ANY FUTURE ACTIONS AGAINST JPMSI ALLEGING VIOLATIONS BASED ON THE SAME FACTUAL FINDINGS. JPMSI HAS AGREED TO PAY THE MONETARY SANTIONS IMPOSED ON IT AND WILL PROVIDE PROOF OF PAYMENT TO THE NASDR STAFF NO LATER THAN 120 DAYS FROM ACCEPTANCE OF THE AWC. A COPY OF THE AWC, ALONG WITH THE RESPONDENT'S STATEMENT OF CORRECTIVE ACTION, HAS BEEN SUBMITTTED TO THE ORGANIZATION DISCLOSURE REVIEW DEPARTMENT FOR RECORD KEEPING. i Disclosure 84 of 102 Reporting Source: Firm Current Status: Final Allegations: SEE 13

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/16/1998 Docket/Case Number: CMS980100 AWC

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief LETTER OF ACCEPTANCE, WAIVER AND CONSENT Sought: CENSURE AND FINE

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/16/1998 Sanctions Ordered: Censure Monetary/Fine $4,500.00 Other Sanctions Ordered: ACCEPTANCE, WAIVER AND CONSENT Sanction Details: AWC, CENSURE AND $4500.00 FINE Firm Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS980100 AWC. ON NOVEMBER 16, 1998, J. P. MORGAN SECURITIES, INC. (JPMS) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED HAS BEEN ACCEPTED BY NASD REGULATION, INC.'S DEPARTMENT OF ENFORCEMENT AND THE NATIONAL ADJUDICATORY COUNCIL. THE AWC ALLEGES THAT THE FOLLOWING ACTIVITY OCCURRED: JPMS FAILED TO CONTEMPORANEOUSLY EXECUTE A CUSTOMER LIMIT ORDER AFTER IT EXECUTED TRANSACTIONS FOR ITS OWN MARKET MAKING ACCOUNT. THIS CONDUCT CONSTITUTES A VIOLATION OF NASD CONDUCT RULE 2110 AND IM-2110-2. JPMS INCORRECTLY STATED THE NET PRICE TO THE CUSTOMER AS AN AVERAGE PRICE IN 20 CUSTOMER CONFIRMATIONS. THIS CONDUCT CONSTITUTES A SEPARATE AND DISTINCT VIOLATION OF SEC RULE 10B-10. JPMS FAILED TO RECORD THE CORRECT TIME OF EXECUTION OF A CQS TRADE ON THE MEMORANDUM OF ONE BROKERAGE ORDER; FAILED TO DOCUMENT, IN 45 INSTANCES, THE TERMS AND CONDITIONS ON THE MEMORANDUM OF BROKERAGE ORDERS; AND FAILED TO ACCURATELY DOCUMENT, IN ONE INSTANCE, THE TIME OF RECEIPT AND EXECUTION OF AN ORDER. IN ADDITION, FOR THE PERIOD FROM AT LEAST MARCH 10 THROUGH APRIL 17, 1997, THE FIRM FAILED TO DOCUMENT ALL INTER-DEALER LIMIT ORDERS RECEIVED. THIS CONDUCT CONSTITUTES A VIOLATION OF SEC RULES 17A-3 AND 17A- 4 AND NASD CONDUCT RULE 3110. JPMS WAS CENSURED AND FINED $4,500. *** $4,500 PAID ON 1/11/99 - INVOICE NO. 98-MS-1005 ****

i Disclosure 85 of 102 Reporting Source: Firm Current Status: Final Allegations: SEE SUMMARY Initiated By: CHICAGO BOARD OF OPTIONS EXCHANGE, INC. (CBOE) Date Initiated: 07/11/2000 Docket/Case Number: 00-0022

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief CENSURE, $15,000.00 FINE AND EDUCATIONAL UNDERTAKING Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 11/21/2000 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: RESPONDENT J.P. MORGAN SECURITIES INC. ("MORGAN"), IS ORDERED TO PARTICIPATE IN AN EDUCATIONAL UNDERTAKING PURSUANT TO WHICH TRADERS IN ITS NY EQUITY DERIVATIVES GROUP WILL ATTEND AN EDUCATIONAL SESSION CONDUCTED BY THE EXCHANGE CONCERNING THE PROVISIONS OF EXCHANGE RULE 6.9 - SOLICITATION. Sanction Details: SEE A AND B.

FINE AMOUNT OF $15,000.00 WAS PAID IN FULL BY MORGAN (RESPONDENT) 12/2000 Firm Statement FINDINGS: ALLEGED VIOLATIONS OF EXCHANGE RULE 4.1 BY MORGAN, IN THAT MORGAN ALLEGEDLY CAUSED A SOLICITED ORDER TO BE CROSSED WITH AN ORIGINAL ORDER PRIOR TO THE DISCLOSURE OF THE ORIGINAL ORDER TO THE SPX TRADING CROWD ON MARCH 24,1999. AS A RESULT, MORGAN ALLEGEDLY FAILED TO PROVIDE MEMBERS OF THE SPX TRADING CROWD WITH AN OPPORTUNITY TO ASSERT THEIR PRIORITY OVER THE SOLICITED ORDER AS REQUIRED BY EXCHANGE RULE 6.9(D). A COPY OF THE DECISION ACCEPTING OFFER OF SETTLEMENT HAS BEEN SUBMITTED TO THE ORGANIZATION DISCLOSURE REVIEW DEPARTMENT ©2021 FINRA. All rights reserved. Report aboutFOR J.P. RECORD MORGAN KEEPING. SECURITIES INC. 222 FINDINGS: ALLEGED VIOLATIONS OF EXCHANGE RULE 4.1 BY MORGAN, IN THAT MORGAN ALLEGEDLY CAUSED A SOLICITED ORDER TO BE CROSSED WITH AN ORIGINAL ORDER PRIOR TO THE DISCLOSURE OF THE ORIGINAL ORDER TO THE SPX TRADING CROWD ON MARCH 24,1999. AS A RESULT, MORGAN ALLEGEDLY FAILED TO PROVIDE MEMBERS OF THE SPX www.finra.org/brokercheck TRADING CROWD WITH AN OPPORTUNITY TO ASSERT THEIR PRIORITY User Guidance OVER THE SOLICITED ORDER AS REQUIRED BY EXCHANGE RULE 6.9(D). A COPY OF THE DECISION ACCEPTING OFFER OF SETTLEMENT HAS BEEN SUBMITTED TO THE ORGANIZATION DISCLOSURE REVIEW DEPARTMENT FOR RECORD KEEPING. i Disclosure 86 of 102 Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLOATION OF FIRM QUOTE RULES. NASD RULES 3320 AND 4613(B) AND SEC RULE 11AC1-1. RESPONDENT MEMBER FAILED TO EXECUTE ORDERS UPON PRESENTMENT AND THEREBY FAILED TO HONOR ITS PUBLISHED QUOTATION. Initiated By: NASD REGULATION INC. - MARKET REGULATION DEPARTMENT Date Initiated: 01/01/1998 Docket/Case Number: MRD 199805742/AWC #CMS990168

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief ACCEPTANCE, WAIVER AND CONSENT (AWC) SUBMITTED AND ACCEPTED Sought: 10/18/1999. FINE OF $5000.00 PAID IN FEBRUARY 2000

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/18/1999 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: ACCEPTANCE, WAIVER AND CONSENT Sanction Details: AWC AND $5000.00 FINE i Disclosure 87 of 102 Reporting Source: Firm Current Status: Final Allegations: ALLEGED FAILURE TO SUBMIT REQUIRED ADVANCE REFUNDING DOCUMENTATION AND TIMELY SUBMIT OFFICIAL STATEMENTS AND/OR OTHER DOCUMENTS TO THE MSRB AS REQUIRED BY RULES G-36 AND G-8 Initiated By: NASD REGULATION, INC. Date Initiated: 12/15/1997 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 223 www.finra.org/brokercheck User Guidance

Date Initiated: 12/15/1997 Docket/Case Number: C10970182

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief CENSURE AND FINE OF $25,000.00 Sought:

Resolution: Settled Resolution Date: 12/15/1997 Sanctions Ordered: Censure Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF $25,000.00 i Disclosure 88 of 102 Reporting Source: Firm Current Status: Final Allegations: ACTS, PRACTICED AND CONDUCT CONSTITUTED VIOLATIONS OF THE CHICAGO BOARD OF OPTIONS EXCHANGE RULES 4.11 (POSITION LIMITS), 24.4(A) (POSTION LIMITS FOR BROAD-BASED INDEX OPTIONS) AND 4.2 (ADHERENCE TO LAW). Initiated By: CHICAGO BOARD OF OPTIONS EXCHANGE, INC. (CBOE) Date Initiated: 03/08/1996 Docket/Case Number: CBOE FILE NO. 96-0009

Principal Product Type: Other Other Product Type(s): POSITION LIMITS Principal Sanction(s)/Relief Undertaking Sought: Other Sanction(s)/Relief UNDERTAKING AND $15000.00 FINE Sought:

Resolution: Settled

Resolution Date: 06/05/1996 Sanctions Ordered: Monetary/Fine $15,000.00 Other Sanctions Ordered: UNDERTAKING AND $15000.00 FINE Sanction Details: UNDERTAKING AND FINE IN THE AMOUNT OF $15000.00 i Disclosure 89 of 102 Reporting Source: Firm Current Status: Final Allegations: MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS920082-AWC (A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED JUNE 1, 1992 AGAINST RESPONDENT MEMBER J.P. MORGAN SECURITIES INC. ALLEGING VIOLATIONS OF PART VI; SECTIO 5(A) OF SCHEDULE D IN THAT THE FOLLOWING RESPONDENT FAILED TO REPORT NASDAQ VOLUME. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/01/1992 Docket/Case Number: CMS920082

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief AWC ACCEPTED BY MARKET SURVEILLANCE COMMITTEE AND NATIONAL Sought: BUSINESS CONDUCT COMMITTEE ON OCTOBER 12, 1992. $1000.00 FINE

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/12/1992 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON SEPTEMBER 11, 1992 AND BY THE NATIONAL BUSINESS CONDUCT COMMITEE ON OCTOBER 12, 1992. *$1000.00 FINE i Disclosure 90 of 102

Reporting Source: Firm Current Status: Final Allegations: MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS920046-AWC: A LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED APRIL 2, 1992 AGAINST RESPONDENT MEMBER J.P. MORGAN SECURITIES DEALERS, INC. ALLEGING VIOLATIONS OF PART VI, SECTION 5(A) OF SCHEDULE D IN THAT THE FOLLOWING RESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/02/1992 Docket/Case Number: CMS920046-AWC

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief AWC ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE AND BY Sought: NATIONAL BUSINESS CONDUCT COMMITTEE

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/03/1992 Sanctions Ordered: Monetary/Fine $1,750.00 Other Sanctions Ordered: Sanction Details: THE AWC WAS ACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON 5/8/1992 AND BY NBCC ON 6/3/1992. $1750.00 FINE PAID (INVOICE # 92MS571) i Disclosure 91 of 102 Reporting Source: Firm Current Status: Final Allegations: ALLEGED THAT FIRM FAILED TO PROVIDE CERTAIN AUDIT TRAIL INFORMATION Initiated By: NEW YORK STOCK EXCHANGE INC. Date Initiated: 03/20/1990 Docket/Case Number: JDS10065-08190

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

Resolution: Settled Resolution Date: 03/20/2001 Sanctions Ordered: Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: FINE OF $1000.00 i Disclosure 92 of 102 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010, 4632, 6130 AND 6420 - REPORTED TRANSACTIONS TO THE AUTOMATED CONFIRMATION TRANSACTION SERVICES IN VIOLATION OF APPLICABLE SECURITIES LAWS AND REGULATIONS REGARDING TRADE REPORTING; AND,FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS CONCERNING TRANSACTION REPORTING. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/11/2000 Docket/Case Number: CMS000012

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

Sanctions Ordered: Censure Monetary/Fine $12,500.00 Other Sanctions Ordered: SUBMIT TO THE NASD WITHIN 60 DAYS REVISED WRITTEN SUPERVISORY PROCEDURES CONCERNING TRANSACTION REPORTING. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED $12,500, AND REQUIRED TO SUBMIT TO THE NASD WITHIN 60 DAYS REVISED WRITTEN SUPERVISORY PROCEDURES CONCERNING TRANSACTION REPORTING. i Reporting Source: Firm Current Status: Final Allegations: 07/26/01 GS: (03/27/00 GS): NASD RULES 2110, 3010, 4632, 6130 AND 6420 - REPORTED TRANSACTIONS TO THE AUTOMATED CONFIRMATION TRANSACTION SERVICES IN VIOLATION OF APPLICABLE SECURITIES LAWS AND REGULATIONS REGARDING TRADE REPORTING; AND , FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS CONCERNING TRANSACTION REPORTING. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 02/11/2000 Docket/Case Number: CMS000012

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/11/2000 Sanctions Ordered: Censure Monetary/Fine $12,500.00 Other Sanctions Ordered: SUBMIT TO THE NASD WITHIN 60 DAYS REVISED WRITTEN SUPERVISORY PROCEDURES CONCERNING TRANSCTION REPORTING. Sanction Details: 09-08-00, $12,500 PAID 03/27/00, INVOICE 00-MS-194 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 228 www.finra.org/brokercheck User Guidance

Sanction Details: 09-08-00, $12,500 PAID 03/27/00, INVOICE 00-MS-194 i Disclosure 93 of 102 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110 AND 4613(E) - RESPONDENT MEMBER, A MARKET MAKER IN SECURITIES, WITHOUT MAKING REASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET BY EXECUTING TRANSACTIONS WITH ALL MARKET MAKERS WHOSE QUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED (OR MAINTAINED) A BID OR ASKED QUOTATION IN THE NASDAQ STOCK MARKET, INC. DURING THE PERIOD OF TIME THAT SECONDARY TRADING COMMENCED IMMEDIATELY FOLLOWING THE COMPLETION OF AN INITIAL PUBLIC OFFERING OF THE SUBJECT SECURITY, WHICH CAUSED A LOCKED OR CROSSED MARKET CONDITION TO OCCUR IN EACH INSTANCE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/02/2001 Docket/Case Number: CMS010089

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/02/2001 Sanctions Ordered: Censure Monetary/Fine $8,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $8,000. i Reporting Source: Firm

Current Status: Final Allegations: ALLEGED VIOLATION OF NASD MARKET PLACE RULE 4613 (E) AND NASD CONDUCT RULE 2110. Initiated By: NASD REGULATION, INC. Date Initiated: 03/01/1999 Docket/Case Number: MRD199914878

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief AND A FINE OF $8,500.00 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/02/2001 Sanctions Ordered: Censure Monetary/Fine $8,500.00 Other Sanctions Ordered: Sanction Details: CENSURE AND FINE OF $8,500.00 Firm Statement THE LETTEROF ACCEPTANCE WAIVER AND CONSENT NUMBER CMS010089 WAS ACCEPTED BY THE NASD REGULATION, INC. OFFICE ON 7/2/01. J.P. MORGAN SECURITIES INC. HAS NEITHER ADMITTED NOR DENIED THE ALLEGED VIOLATIONS CONTAINED IN THE AWC. JPMSI HAS AGREED TO PAY THE MONETARY SANCTIONS IMPOSED ON IT. A COPY OF THE AWC ALONG WITH THE RESPONDENTS STATEMENT OF CORRECTIVE ACTION WILL BE SUBMITTED TO THE ORGANIZATION DISCLOSURE REVIEW DEPARTMENT FOR RECORD KEEPING. i Disclosure 94 of 102 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110 AND 4613(E)(1)(C) - RESPONDENT MEMBER, A MARKET MAKER IN SECURITIES WAS A PARTY TO A LOCKED OR CROSSED MARKET CONDITION PRIOR TO THE MARKETING OPENING DURING THE PERIOD BETWEEN 9:20 AND 9:29:59 A.M., EASTERN TIME AND RECEIVED A TRADE- OR-MOVE MESSAGE THROUGH SELECTNET. RESPONDENT MEMBER ©2021 FINRA. All rights reserved. Report aboutWITHIN J.P. MORGAN 30 SECOND SECURITIES OF RECEIVING INC. SUCH MESSAGE, FAILED TO FILL THE 230 INCOMING TRADE-OR-MOVE MESSAGE FOR THE FULL SIZE OF THE MESSAGE OR MOVE ITS BID DOWN (OFFER UP) BY A QUOTATION INCREMENT THAT WOULD HAVE UNLOCKED/UNCROSSED THE MARKET; RECEIVED AN ORDER TO BUY OR SELL AND FAILED TO IMMEDIATELY DISPLAY A REVISED QUOTATION AT A PRICE THAT WAS INFERIOR TO IS PREVIOUS PUBLISHED QUOTATION; FAILED TO EXECUTE ORDERS PRESENTED AT THE FIRM?S PUBLISHED BID OR PUBLISHED OFFER IN AN AMOUNT UP TO ITS PUBLISHED QUOTATION SIZE, AND THEREBY, FAILED TO HONOR ITS PUBLISHED QUOTATION;WITHOUT MAKING REASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET BY EXECUTING TRANSACTIONS WITH ALL MARKET MAKERS WHOSE QUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED BID OR ASK QUOTATIONS IN THE NASDAQ STOCK MARKET, INC. WHICH CAUSED A LOCKED OR CROSSED MARKET CONDITION TO OCCUR IN EACH INSTANCE. NASD RULES 2110 AND 4613(E)(1)(C) - RESPONDENT MEMBER, A MARKET www.finra.org/brokercheck MAKER IN SECURITIES WAS A PARTY TO A LOCKED OR CROSSED MARKET User Guidance CONDITION PRIOR TO THE MARKETING OPENING DURING THE PERIOD BETWEEN 9:20 AND 9:29:59 A.M., EASTERN TIME AND RECEIVED A TRADE- OR-MOVE MESSAGE THROUGH SELECTNET. RESPONDENT MEMBER WITHIN 30 SECOND OF RECEIVING SUCH MESSAGE, FAILED TO FILL THE INCOMING TRADE-OR-MOVE MESSAGE FOR THE FULL SIZE OF THE MESSAGE OR MOVE ITS BID DOWN (OFFER UP) BY A QUOTATION INCREMENT THAT WOULD HAVE UNLOCKED/UNCROSSED THE MARKET; RECEIVED AN ORDER TO BUY OR SELL AND FAILED TO IMMEDIATELY DISPLAY A REVISED QUOTATION AT A PRICE THAT WAS INFERIOR TO IS PREVIOUS PUBLISHED QUOTATION; FAILED TO EXECUTE ORDERS PRESENTED AT THE FIRM?S PUBLISHED BID OR PUBLISHED OFFER IN AN AMOUNT UP TO ITS PUBLISHED QUOTATION SIZE, AND THEREBY, FAILED TO HONOR ITS PUBLISHED QUOTATION;WITHOUT MAKING REASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET BY EXECUTING TRANSACTIONS WITH ALL MARKET MAKERS WHOSE QUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED BID OR ASK QUOTATIONS IN THE NASDAQ STOCK MARKET, INC. WHICH CAUSED A LOCKED OR CROSSED MARKET CONDITION TO OCCUR IN EACH INSTANCE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/03/2001 Docket/Case Number: CMS010111

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/03/2001 Sanctions Ordered: Censure Monetary/Fine $30,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $3,000. i Reporting Source: Firm Current Status: Final Allegations: ALLEGED VIOLATIONS OF THE NASD'S TRADE OR MOVE RULE, NASD MARKETPLACE RULE 4613 (E)(1)(A)AND (B); TRADE OR FADE RULE, NASD ©2021 FINRA. All rights reserved. Report aboutMARKETPLACE J.P. MORGAN SECURITIES RULE 4613 INC. (E) (1) (C); AND LOCKED AND CROSSED MARK 231 RULE, NASD MARKETPLACE RULE 4613 (B) (2) www.finra.org/brokercheck User Guidance

Allegations: ALLEGED VIOLATIONS OF THE NASD'S TRADE OR MOVE RULE, NASD MARKETPLACE RULE 4613 (E)(1)(A)AND (B); TRADE OR FADE RULE, NASD MARKETPLACE RULE 4613 (E) (1) (C); AND LOCKED AND CROSSED MARK RULE, NASD MARKETPLACE RULE 4613 (B) (2) Initiated By: DEPARTMENT OF MARKET REGULATION - NASD REGULATION INC. Date Initiated: 03/30/2001 Docket/Case Number: AWC# CMS010111

Principal Product Type: Other Other Product Type(s): TRADE OR MOVE RULE, TRADE OR FADE RULE, AND LOCKED AND CROSS MARKET RULE. Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CENSURE AND FINE OF $30,000 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/02/2001 Sanctions Ordered: Censure Monetary/Fine $30,000.00 Other Sanctions Ordered: Sanction Details: A CENSURE AND A FINE OF $30,000.00 ($10,000 FOR VIOLATIONS OF TRADE OR MOVE RULE, $10,000 FOR VIOLATIONS OF TRADE OR FADE RULE, $10,000 FOR VIOLATIONS OF LOCKED AND CROSSED MARKET RULE) Firm Statement THE FIRM, WITHOUT ADMITTING NOR DENYING THE ALLEGATIONS CONSENTS TO THE IMPOSITION, AT A MAXIMUM, OF THE SANCTIONS LISTED IN SECTION 12C. A COPY OF THE SIGNED AND ACCEPTED AWC HAS BEEN SUBMITTED TO THE ORGANINZATION DISCLOSURE REVIEW DEPARTMENT FOR RECORD KEEPING. i Disclosure 95 of 102 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 210, 2320, 4132(A)(9) AND SEC RULE 11AC1-4 - FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS; FAILED TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS ©2021 FINRA. All rights reserved. Report aboutPUBLIC J.P. MORGAN QUOTATION, SECURITIES WHEN INC. EACH SUCH ORDER WAS AT A PRICE THAT 232 WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER FOR EACH SUCH SECURITY, OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY; INCORRECTLY DESIGNED AS ".PRP" THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN NNM SECURITIES; TRANSMITTED THOUGH ACT LAST SALE REPORT OF TRANSACTION IN A NASDAQ NNM SECURITY THAT SHOULD NOT HAVE A .PRP MODIFIER APPENDED TO IT; FAILED TO REPORT THE TIME OF EXECUTION THOUGH ACT IN A LAST SALE REPORT OF A TRANSACTION IN A NNM SECURITY THAT SHOULD HAVE HAD A .PRP MODIFIER APPENDED TO IT. NASD RULES 210, 2320, 4132(A)(9) AND SEC RULE 11AC1-4 - FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER www.finra.org/brokercheck MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THE User Guidance RESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS; FAILED TO DISPLAY IMMEDIATELY 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 FOR EACH SUCH SECURITY, OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY; INCORRECTLY DESIGNED AS ".PRP" THROUGH ACT LAST SALE REPORTS OF TRANSACTIONS IN NNM SECURITIES; TRANSMITTED THOUGH ACT LAST SALE REPORT OF TRANSACTION IN A NASDAQ NNM SECURITY THAT SHOULD NOT HAVE A .PRP MODIFIER APPENDED TO IT; FAILED TO REPORT THE TIME OF EXECUTION THOUGH ACT IN A LAST SALE REPORT OF A TRANSACTION IN A NNM SECURITY THAT SHOULD HAVE HAD A .PRP MODIFIER APPENDED TO IT. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 06/14/2001 Docket/Case Number: CMS010087

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/14/2001 Sanctions Ordered: Censure Monetary/Fine $9,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $9,500. i Reporting Source: Firm Current Status: Final Allegations: VIOLATIONS OF NASD CONDUCT RULES 2110 AND 2320, VIOLATIONS OF SEC RULE 11 AC1-4 AND VIOLATIONS OF NASD MARKETPLACE RULE 4632(A)(9). ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 233 www.finra.org/brokercheck User Guidance

VIOLATIONS OF NASD CONDUCT RULES 2110 AND 2320, VIOLATIONS OF SEC RULE 11 AC1-4 AND VIOLATIONS OF NASD MARKETPLACE RULE 4632(A)(9). Initiated By: DEPARTMENT OF MARKET REGULATION - NASD REGULATION, INC. Date Initiated: 05/07/1999 Docket/Case Number: NO. CMS010087 AWC

Principal Product Type: Other Other Product Type(s): TMMS EXAMINATION ETR01-99042 AND TMMS EXAMINATION ETR01-200026 Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief A CENSURE AND A $9,500 FINE. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/14/2001 Sanctions Ordered: Censure Monetary/Fine $9,500.00 Other Sanctions Ordered: Sanction Details: CENSURE AND A FINE OF $9,500, (COMPOSED OF A $6000 FINE FOR THE BEST EXECUTION VIOLATIONS, A $2500 FINE FOR THE LIMIT ORDER DISPLAY VIOLATIONS AND A $1000 FINE FOR THE TRADE REPORTING VIOLATIONS). Firm Statement THE FIRM, WITHOUT ADMITTING NOR DENYING THE ALLEGATIONS CONSENTS TO THE IMPOSITION, AT A MAXIMUM, OF THE FOLLOWING SANCTIONS: CENSURE AND A FINE OF $9,500, (COMPOSED OF A $6000 FINE FOR THE BEST EXECUTION VIOLATIONS, A $2500 FINE FOR THE LIMIT ORDER DISPLAY VIOLATIONS AND A $1000 FINE FOR THE TRADE REPORTING VIOLATIONS). i Disclosure 96 of 102 Reporting Source: Firm Current Status: Final Allegations: FAILURE TO COMPLY WITH RULE 15C3 3(E)1 BY NOT MAINTAINING THE REQUIRED RESERVE DEPOSIT IN ITS SPECIAL RESERVE ACCOUNT. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/01/1991 Docket/Case Number: N/A

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/30/1999 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS SIGNED WITHOUT ADMITTING OR DENYING THE CLAIMS. CSI ALSO CONSENTED TO A CENSURE AND $5,000 FINE. i Disclosure 97 of 102 Reporting Source: Firm Current Status: Final Appealed To and Date Appeal N/A Filed: Allegations: CSI WAS ALLEGED TO HAVE FAILED TO TIMELY REPORT TRADES TO ACT FOR THE TIME PERIOD OF JUNE 2,1997 THROUGH JUNE 13, 1997 AND JUNE 20, 1997 THROUGH JULY 10, 1998. CSI ALSO ALLEGEDLY FAILED TO ESTABLISH AND MAINTAIN WRITTEN SUPERVISORY PROCEDURES REASONABLY REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH TRANSACTION REPORTING RULES. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 11/04/1997 Docket/Case Number: N/A

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 235 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/28/1999 Sanctions Ordered: Censure Monetary/Fine $12,500.00 Other Sanctions Ordered: Sanction Details: A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS SIGNED WITHOUT ADMITTING OR DENYING THE CLAIMS. CSI CONSENTED TO A CENSURE AND A FINE. i Disclosure 98 of 102 Reporting Source: Firm Current Status: Final Allegations: FAILURE TO COMPLY WITH RULE 15C3-3(E)(1) BY NOT MAINTAINING THE REQUIRED RESERVE DEPOSIT IN ITS SPECIAL RESERVE ACCOUNT. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 05/01/1991 Docket/Case Number: N/A

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/30/1990 Sanctions Ordered: Censure Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS SIGNED WITHOUT ADMITTING OR DENYING THE CLAIMS. CSI ALSO CONSENTED TO A CENSURE AND $5,000.00 FINE.

i Disclosure 99 of 102 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULE G-36 AND G-8 - RESPONDENT MEMBER SERVED AS SOLE OR MANAGING UNDERWRITER IN PRIMARY OFFERINGS OF MUNICIPAL SECURITIES AND, IN CONNECTION WITH THOSE OFFERINGS, FAILED TO TIMELY SUBMIT OFFICIAL STATEMENTS AND/OR OTHER DOCUMENTS TO THE MSRB; FAILED TO SEND REQUIRED DOCUMENTS TO THE MSRB BY CERTIFIED OR REGISTERED MAIL, OR SOME OTHER EQUALLY PROMPT MEANS THAT PROVIDES A RECORD OF SENDING; AND FAILED TO MAINTAIN RECORDS AS REQUIRED BY MSRB RULE G-8(A)(XV)). Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 01/19/1999 Docket/Case Number: C10980147

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/19/1999 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, J.P. MORGAN CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE, THE FIRM IS CENSURED AND FINED $3,000 i Reporting Source: Firm Current Status: Final Allegations: ON 7 OCASSIONS FAILED TO TIMELY SUBMIT OFFICIAL STATEMENTS AS REQUIRED BY MSRB RULE G-36 AND ON 2 OCCASIONS FAILED TO SEND ©2021 FINRA. All rights reserved. Report aboutREQUIRED J.P. MORGAN DOCUMENTS SECURITIES TOINC. THE MSRB BY CERTIFIED OR REGISTERED 237 MAIL. ON 2 OCASSIONS FAILED TO MAINTAIN RECORDS AS REQUIRED BY MSRB RULE G-8 (A) (XV). www.finra.org/brokercheck User Guidance

ON 7 OCASSIONS FAILED TO TIMELY SUBMIT OFFICIAL STATEMENTS AS REQUIRED BY MSRB RULE G-36 AND ON 2 OCCASIONS FAILED TO SEND REQUIRED DOCUMENTS TO THE MSRB BY CERTIFIED OR REGISTERED MAIL. ON 2 OCASSIONS FAILED TO MAINTAIN RECORDS AS REQUIRED BY MSRB RULE G-8 (A) (XV). Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 12/09/1998 Docket/Case Number: N/A

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

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/19/1999 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS SIGNED WITHOUT ADMITTING OR DENYING THE CLAIMS. CSI ALSO, CONSENTED TO A CENSURE AND A $1,000.00 FINE. i Disclosure 100 of 102 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 03/26/1998 Docket/Case Number: C01970019

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 238 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/26/1998 Sanctions Ordered: Censure Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON MARCH 26, 1998, DISTRICT NO. 1 NOTIFIED RESPONDENT CHASE SECURITIES, INC. (FORMERLY KNOWN AS CHEMICAL SECURITIES, INC.) THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C01970019 WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $250 - (RESPONDENT MEMBER FAILED TO DISCLOSE ITS PARTICIPATION IN TWO NEGOTIATED UNDERWRITINGS, IN VIOLATION OF MSRB RULE G-37).

****** $250.00 PAID ON 4/29/98, INVOICE NO. 98-01-313 ***** i Reporting Source: Firm Current Status: Final Allegations: FAILURE TO COMPLY WITH MSRB RULE G-37, BY FAILING TO DISCLOSE ON ITS FORM G-37 FILED WITH THE MSRB, ITS PARTICIPATION IN TWO MUNICIPAL UNDERWRITINGS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/28/1997 Docket/Case Number: N/A

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

Resolution Date: 04/23/1998 Sanctions Ordered: Censure Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS SIGNED WITHOUT ADMITTING OR DENYING THE CLAIMS. CSI ALSO CONSENTED TO A CENSURE AND A $500.00 FINE. THE NATIONAL BUSINESS CONDUCT COMMITTEE (NBCC) REDUCED THIS FINE TO $250.00. i Disclosure 101 of 102 Reporting Source: Regulator Current Status: Final Allegations: FAILURE TO FILE REQUIRED DOCUMENTS AND PAY LATE FILING FEE. Initiated By: ILLINOIS ILLINOIS SECURITIES DEPARTMENT Date Initiated: 10/15/1992 Docket/Case Number: 9200238 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 11/30/1992 Sanctions Ordered: Other Sanctions Ordered: Sanction Details: NOTICE OF HEARING ISSUED OCTOBER 15, 1992. HEARING SET DECEMBER 16, 1992. SETTLEMENT AGREEMENT WAS ISSUED NOVEMBER 30, 1992. NO FINDINGS OF FACT OR ENTERED ANY CONCLUSIONS OF LAW TO ANY VIOLATIONS. THE RESPONDENT HAS SUBMITTED AN AFFIDAVIT DETAILING REMEDIAL MEASURES AND REIMBURSED TO THE SECRETARY OF STATE A AMOUNT OF $250.00 FOR ©2021 FINRA. All rights reserved. Report aboutCOST J.P. OF MORGAN INVESTIGATION. SECURITIES INC. THE FORMAL ADMINISTRATIVE HEARING IN 240 THIS MATTER HAS BEEN DISMISSED. NOTICE OF HEARING ISSUED OCTOBER 15, 1992. HEARING SET DECEMBER 16, 1992. SETTLEMENT AGREEMENT WAS www.finra.org/brokercheck ISSUED User Guidance NOVEMBER 30, 1992. NO FINDINGS OF FACT OR ENTERED ANY CONCLUSIONS OF LAW TO ANY VIOLATIONS. THE RESPONDENT HAS SUBMITTED AN AFFIDAVIT DETAILING REMEDIAL MEASURES AND REIMBURSED TO THE SECRETARY OF STATE A AMOUNT OF $250.00 FOR COST OF INVESTIGATION. THE FORMAL ADMINISTRATIVE HEARING IN THIS MATTER HAS BEEN DISMISSED. i Reporting Source: Firm Current Status: Final Allegations: CSI VIOLATED SECTION 130.821 OF THE RULES UNDER THE ILLINOIS SECURITIES LAW OF 1953 BY FAILING TO FILE THE "ANNUAL REPORT OF BRANCH OFFICES" WITH THE STATE OF ILLINOIS. FURTHERMORE, CSI DID NOT FILE THE ADDITIONAL FEES ASSOCIATED WITH THIS FAILURE TO FILE, CONSTITUTING A FRAUDULENT BUSINESS PRACTICE. Initiated By: STATE OF ILLINOIS - SECRETARY OF STATE - SECURITIES DEPARTMENT Date Initiated: 10/15/1992 Docket/Case Number: CASE # 9200238

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

Resolution: Settled Resolution Date: 11/30/1992 Sanctions Ordered: Monetary/Fine $250.00 Other Sanctions Ordered: Sanction Details: CSI AGREED TO PAY $250.OO TO REIMBURSE THE STATE OF ILLINOIS FOR COSTS INCURRED WITH REGARD TO THIS ACTION, AND AGREED TO FILE: ANNUAL REPORTS RELATING TO BRANCH OFFICES LOCATED IN ILLINOIS; IDENTIFY DESIGNATED PRINCIPALS RESPONSIBLE FOR THE SALE OF SECURITIES IN ILLINOIS; AND AUDITED FINANCIAL STATEMENTS. IN ADDITION, CSI AGREED TO IMPLEMENT PROCEDURES TO PREVENT A SIMILAR REOCCURANCE AND TO SUBMIT DETAILS OF THESE PROCEDURES. i Disclosure 102 of 102 Reporting Source: Regulator ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 241 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: VIOLATION OF SECTION 17(A) OF THE EXCHANGE ACT AND 17 C.F.R. $240.17A-3 AND 240.17A-4 THEREUNDER IN CONNECTION WITH ANY PRIMARY DISTRIBUTION OF UNSECURED DEBT SECURITIES ISSUED BY THE CSES. Initiated By: SECURITIES AND EXCHANGE COMMISSION Date Initiated: 01/16/1992 Docket/Case Number: UNKNOWN

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

Resolution: Order Resolution Date: 01/28/1992 Sanctions Ordered: Monetary/Fine $100,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CEASE AND DESIST FROM COMMITTING OR CAUSING ANY FUTURE VIOLATION OF SECTION 17(A) OF THE EXCHANGE ACT AND 17 C.F.R. $240.17A-3 AND 240.17A-4 THEREUNDER IN CONNECTION WITH ANY PRIMARY DISTRIBUTION OF UNSECURED DEBT SECURITIES ISSUED BY THE CSES AND SHALL, PRIOR TO THE CLOSE OF BUSINESS ON THE DATE OF THIS ORDER, PAY A CIVIL MONEY PENALTY TO THE US TREASURY IN THE AMOUNT OF $100,000 AND ALSO CONTINUE TO MAINTAIN OR, WITHIN 60 DAYS OF THE DATE OF THIS ORDER, DEVELOP, IMPLEMENT AND, MAINTAIN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE CHEMICAL'S FUTURE COMPLIANCE WITH THE PROVISIONS OF THE EXCHANGE ACT. SUCH POLICIES AND PROCEDURES SHALL BE AVAILABLE FOR INSPECTION UPON REQUEST BY THE SEC. CHEMICAL SHALL COMPLY WITH ALL POLICIES AND PROCEDURES IMPLEMENTED OR MAINTAINED PURSUANT TO THIS PARAGRAPH. CHEMICAL MAY MODIFY SUCH POLICIES AND PROCEDURES. Regulator Statement [TOP] 3/12/92 SEC NEWS DIGEST, ISSUE 92-11, DATED 1/16/92 ADMINISTRATIVE PROCEEDINGS DISCLOSES; THE SEC TODAY ANNOUNCED ADMINISTRATIVE PROCEEDINGS INSTITUTED JOINTLY BY THE SEC, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) ©2021 FINRA. All rights reserved. Report aboutAND J.P. THE MORGAN BOARD SECURITIES OF GOVERNORS INC. OF THE FEDERAL RESERVE SYSTEM 242 (FRB) AGAINST 98 REGISTERED BROKER-DEALERS. THE ISSUANCE OF SEC, OCC AND FRB ORDERS IMPOSING SANCTIONS, DIRECTING THE RESPONDENTS TO CEASE AND DESIST FROM COMMITTING FUTURE VIOLATIONS AND REQUIRING THE PAYMENT OF CIVIL MONEY PENALTIES TO THE US TREASURY IN THE TOTAL AMOUNT OF $5,165,000; AND THE SEC'S ISSUANCE OF A REPORT PURSUANT TO SECTION 21(A) OF THE SECURITIES EXCHANGE ACT OF 1934 REGARDING THE DISTRIBUTION OF CERTAIN DEBT SECURITIES ISSUED BY GOVERNMENT-SPONSORED ENTERPRISES. (RELS. 34-30192 - 34-30251) 3/17/92 SEC DOCKET VOLUME 50 NO. 12, DATED 1/28/92 ADMINISTRATIVE PROCEEDINGS FILE NO. 3-7646 PAGE 1194 & 1195 DISCLOSES; IT IS ORDERED THAT CHEMICAL SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY FUTURE VIOLATION OF SECTION 17(A) OF THE EXCHANGE ACT AND 17 C.F.R. $240.17A-3 AND 240.17A-4 THEREUNDER IN CONNECTION WITH ANY PRIMARY DISTRIBUTION OF UNSECURED DEBT SECURITIES ISSUED BY THE CSES AND SHALL, PRIOR TO THE CLOSE OF BUSINESS ON THE DATE OF THIS ORDER, PAY A CIVIL MONEY PENALTY TO THE US TREASURY IN THE AMOUNT OF $100,000 AND ALSO CONTINUE TO MAINTAIN OR, WITHIN 60 DAYS OF THE DATE OF THIS ORDER, DEVELOP, IMPLEMENT AND, MAINTAIN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE CHEMICAL'S FUTURE COMPLIANCE WITH THE PROVISIONS OF THE EXCHANGE ACT. SUCH POLICIES AND PROCEDURES SHALL BE AVAILABLE FOR INSPECTION UPON REQUEST BY THE SEC. CHEMICAL SHALL COMPLY WITH ALL POLICIES AND PROCEDURES IMPLEMENTED OR MAINTAINED PURSUANT TO THIS PARAGRAPH. CHEMICAL MAY MODIFY SUCH POLICIES AND PROCEDURES. www.finra.org/brokercheck User Guidance [TOP] 3/12/92 SEC NEWS DIGEST, ISSUE 92-11, DATED 1/16/92 ADMINISTRATIVE PROCEEDINGS DISCLOSES; THE SEC TODAY ANNOUNCED ADMINISTRATIVE PROCEEDINGS INSTITUTED JOINTLY BY THE SEC, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC) AND THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (FRB) AGAINST 98 REGISTERED BROKER-DEALERS. THE ISSUANCE OF SEC, OCC AND FRB ORDERS IMPOSING SANCTIONS, DIRECTING THE RESPONDENTS TO CEASE AND DESIST FROM COMMITTING FUTURE VIOLATIONS AND REQUIRING THE PAYMENT OF CIVIL MONEY PENALTIES TO THE US TREASURY IN THE TOTAL AMOUNT OF $5,165,000; AND THE SEC'S ISSUANCE OF A REPORT PURSUANT TO SECTION 21(A) OF THE SECURITIES EXCHANGE ACT OF 1934 REGARDING THE DISTRIBUTION OF CERTAIN DEBT SECURITIES ISSUED BY GOVERNMENT-SPONSORED ENTERPRISES. (RELS. 34-30192 - 34-30251) 3/17/92 SEC DOCKET VOLUME 50 NO. 12, DATED 1/28/92 ADMINISTRATIVE PROCEEDINGS FILE NO. 3-7646 PAGE 1194 & 1195 DISCLOSES; IT IS ORDERED THAT CHEMICAL SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY FUTURE VIOLATION OF SECTION 17(A) OF THE EXCHANGE ACT AND 17 C.F.R. $240.17A-3 AND 240.17A-4 THEREUNDER IN CONNECTION WITH ANY PRIMARY DISTRIBUTION OF UNSECURED DEBT SECURITIES ISSUED BY THE CSES AND SHALL, PRIOR TO THE CLOSE OF BUSINESS ON THE DATE OF THIS ORDER, PAY A CIVIL MONEY PENALTY TO THE US TREASURY IN THE AMOUNT OF $100,000 AND ALSO CONTINUE TO MAINTAIN OR, WITHIN 60 DAYS OF THE DATE OF THIS ORDER, DEVELOP, IMPLEMENT AND, MAINTAIN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE CHEMICAL'S FUTURE COMPLIANCE WITH THE PROVISIONS OF THE EXCHANGE ACT. SUCH POLICIES AND PROCEDURES SHALL BE AVAILABLE FOR INSPECTION UPON REQUEST BY THE SEC. CHEMICAL SHALL COMPLY WITH ALL POLICIES AND PROCEDURES IMPLEMENTED OR MAINTAINED PURSUANT TO THIS PARAGRAPH. CHEMICAL MAY MODIFY SUCH POLICIES AND PROCEDURES. i Reporting Source: Firm Current Status: Final Allegations: APPILCANT HAD VIOLATED SECT. 17(A)OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES 17A-3 AND 17A-4 THEREUNDER BY MAKING AND KEEPING CERTAIN RECORDS THAT DID NOT ACCURATELY REFLECT CUSTOMER ORDER FOR TRANSACTION IN CERTAIN UNSECURED DEBT SECURITIES OF GOVERNMENT SPONSORED ENTERPRISES. Initiated By: SECURITIES EXCHANGE COMMISSION Date Initiated: 01/16/1992 Docket/Case Number: N/A

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: 01/16/1992 Sanctions Ordered: Monetary/Fine $125,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: ENTRY OF CEASE AND DESIST ORDER, AGREEMENT TO MAINTAIN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH SUCH RULES, AND PAYMENT OF CIVIL MONEY PENALTIES IN THE AMOUNT OF $125,000.00.

Regulatory - Pending This type of disclosure event may include a pending formal proceeding initiated by a regulatory authority (e.g., a state securities agency, self-regulatory organization, federal regulatory agency such as the Securities and Exchange Commission, foreign financial regulatory body) for alleged violations of investment-related rules or regulations. Disclosure 1 of 1 Reporting Source: Firm Current Status: Pending Allegations: THE BRAZILIAN SECURITIES COMMISSION ("CVM") COMMENCED AN ADMINISTRATIVE PROCEEDING AGAINST JPMSI AND ALFREDO GUTTIEREZ (AN EMPLOYEE OF JP MORGAN INTERNATIONAL CAPITAL CORPORATION AND MEMBER OF LATASA'S BOARD OF DIRECTORS) RELATING TO A STOCK REPURCHASE PROGRAM LAUNCHED BY LATASA (A BRAZILIAN COMPANY) IN 1997, FOR ALLEGEDLY VIOLATING A CVM INSTRUCION PROHIBITING THE REPURCHASE OF A COMPANY'S STOCK FROM A CONTROLLING SHAREHOLDER. Initiated By: BRAZILIAN SECURITIES COMMISSION ("CVM") Date Initiated: 03/10/2005 Docket/Case Number: 2005/98

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

Firm Statement WE EXPECT AN INITIAL DETERMINATION BY THE CVM IN MID-2006.

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 3 Reporting Source: Regulator Current Status: Final Allegations: SEC LITIGATION RELEASE 18385, OCTOBER 1, 2003: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") FILED A CIVIL INJUNCTIVE ACTION IN FEDERAL COURT AGAINST J.P. MORGAN SECURITIES INC. ("J.P. MORGAN") RELATING TO THE FIRM'S ALLOCATION OF STOCK TO INSTITUTIONAL CUSTOMERS IN INITIAL PUBLIC OFFERINGS ("IPOS") IT UNDERWROTE DURING 1999 AND 2000. THE SEC ALLEGED THAT J.P. MORGAN VIOLATED RULE 101 OF REGULATION M UNDER THE SECURITIES EXCHANGE ACT OF 1934 BY ATTEMPTING TO INDUCE CERTAIN CUSTOMERS WHO RECEIVED ALLOCATIONS OF IPOS TO PLACE PURCHASE ORDERS FOR ADDITIONAL SHARES IN THE AFTERMARKET. THE SEC FURTHER ALLEGED THAT J.P. MORGAN DID IN FACT INDUCE CERTAIN CUSTOMERS TO PLACE SUCH ORDERS AND SUCH CUSTOMERS OFTEN PURCHASED STOCK DURING THE NEW ISSUES' FIRST FEW TRADING DAYS. THE SEC FURTHER ALLEGED THAT, IN ANOTHER INSTANCE, J.P. MORGAN VIOLATED NASD CONDUCT RULE 2110, WHICH REQUIRES MEMBER FIRMS TO OBSERVE JUST AND EQUITABLE PRINCIPLES OF TRADE, BY PERSUADING ONE OR MORE CUSTOMERS IN JULY 1999, TO ACCEPT AN ALLOCATION OF A "COLD" IPO (I.E., ONE WHERE THERE IS LITTLE INTEREST IN IPO SHARES) BY PROMISING THE REWARD OF AN ALLOCATION OF AN UPCOMING OVERSUBSCRIBED IPO. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Court Details: THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA, CIVIL ACTION NO. 1:03 CV 02028 (ESH) (D.D.C.) Date Court Action Filed: 10/01/2003 Principal Product Type: Other Other Product Types: STOCK Relief Sought: Injunction Other Relief Sought: CIVIL PENALTY Resolution: Judgment Rendered Resolution Date: 10/01/2003 Sanctions Ordered or Relief Monetary/Fine $25,000,000.00 ©2021Granted: FINRA. All rights reserved. Report aboutCease J.P. and MORGAN Desist/Injunction SECURITIES INC. 246 www.finra.org/brokercheck User Guidance

Sanctions Ordered or Relief Monetary/Fine $25,000,000.00 Granted: Cease and Desist/Injunction Other Sanctions: Sanction Details: ON OCTOBER 1, 2003, THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA, FILED A FINAL JUDGMENT THAT PERMANENTLY ENJOINED J.P. MORGAN FROM VIOLATING RULE 101 OF THE COMMISSION'S REGULATION M AND NASD CONDUCT RULE 2110, AND ORDERED IT TO PAY A $25 MILLION CIVIL PENALTY. Regulator Statement IN SETTLEMENT OF THE MATTER, J.P. MORGAN CONSENTED, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT, TO A FINAL JUDGMENT THAT WOULD PERMANENTLY ENJOIN J.P. MORGAN FROM VIOLATING RULE 101 OF THE COMMISSION'S REGULATION M AND NASD CONDUCT RULE 2110, AND ORDER IT TO PAY A $25 MILLION CIVIL PENALTY. THE SETTLEMENT TERMS ARE SUBJECT TO APPROVAL BY THE COURT. i Reporting Source: Firm Current Status: Final Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT DURING THE PERIOD FROM MARCH 1999 THROUGH AUGUST 2000, J.P. MORGAN SECURITIES INC. ("JPMSI") VIOLATED (1) RULE 101 OF REGULATION M [17 C.F.R. S 242.101] OF THE SECURITIES EXCHANGE ACT OF 1934 BY ATTEMPTING TO INDUCE CERTAIN INSTITUTIONAL CUSTOMERS TO PLACE ORDERS FOR SHARES IN THE AFTERMARKET FOR CERTAIN INITIAL PUBLIC OFFERINGS ("IPO'S") IT UNDERWROTE DURING THE RESTRICTED PERIOD OF SUCH IPO'S AND (II) THE NASD, INC. ("NASD") CONDUCT RULE 2110 BY PERSUADING ONE OR MORE INSTITUTIONAL INVESTORS TO TAKE AN ALLOCATION OF ONE "COLD" IPO BY PROMISING TO REWARD THE CUSTOMER WITH AN ALLOCATIN OF ANOTHER UPCOMING "HOT" IPO. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Court Details: UNITED STATES COURT FOR THE DISTRICT OF COLUMBIA, CASE NO. 3:CV02028 (ESH) Date Court Action Filed: 10/01/2003 Principal Product Type: Other Other Product Types: INITIAL PUBLIC OFFERINGS (EQUITIES) Relief Sought: Civil Penalty(ies)/Fine(s) Other Relief Sought: INJUNCTION ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 247 www.finra.org/brokercheck User Guidance

Other Relief Sought: INJUNCTION Resolution: Settled Resolution Date: 10/01/2003 Sanctions Ordered or Relief Monetary/Fine $25,000,000.00 Granted: Cease and Desist/Injunction Other Sanctions: Sanction Details: ON OCTOBER 1, 2003, THE U.S. DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ENTERED A FINAL JUDGMENT: (1) ENJOINING JPMSI, ITS OFFICERS, AGENTS, SERVANTS, EMPLOYEES AND ATTORNEYS, AND ALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH DEFENDANT WHO RECEIVE ACTUAL NOTICE OF THE FINAL JUDGMENT BY PERSONAL SERVICE OR OTHERWISE FROM VIOLATING RULE 101 OF REGULATION M [17 C.F.R. S 242.101] OF THE SECURITIES EXCHANGE ACT OF 1934 AND THE NASD CONDUCT RULE 2110; AND (2) ORDERING JPMSI TO PAY A CIVIL PENALTY OF $25,000,000.00. NO PORTION OF THE PENALTY WAS WAIVED. JPMSI MADE PAYMENT OF $25,000,000.00 ON OCTOBER 17, 2003. Firm Statement THE ACTION WAS SETTLED AS FOLLOWS: JPMSI CONSENTED, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE COMPLAINT, EXCEPT AS TO JURISDICTION, TO THE ENTRY OF A FINAL JUDGMENT, IMPOSING THE INJUNCTION AND PAYMENT OF THE CIVIL PENALTY. ON OCTOBER 1, 2003, THE FINAL JUDGMENT WAS SUBMITTED AND ENTERED BY THE COURT. NO FINDINGS WERE MAKE BY THE COURT OR THE SEC. i Disclosure 2 of 3 Reporting Source: Regulator Current Status: Final Allegations: SEC LITIGATION RELEASE 18114, APRIL 28, 2003: DURING THE PERIOD JULY 1, 1999 THROUGH JUNE 30, 2001 (THE "RELEVANT PERIOD"), DEFENDANT ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, THEREBY CREATING CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. DEFENDANT FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE MANNER. DURING THE RELEVANT PERIOD, DEFENDANT ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR TO EVALUATE ANALYSTS AND DETERMINE THEIR COMPENSATION. THE RESEARCH DEPARTMENT OF DEFENDANT COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH DEFENDANT'S INVESTMENT BANKING DEPARTMENT, AND COVERAGE DECISIONS WERE INFLUENCED ©2021 FINRA. All rights reserved. Report aboutBY INVESTMENT J.P. MORGAN SECURITIES BANKING INC. INTERESTS. AS A RESULT OF THE FOREGOING, 248 RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING DEFENDANT'S INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. IN ADDITION, DURING THE RELEVANT PERIOD DEFENDANT MADE PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN DEFENDANT KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE. DEFENDANT DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. FINALLY, DEFENDANT FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. BY ITS CONDUCT, DEFENDANT VIOLATED NASD RULES 2110, 2210(D)(1)(A) AND 3010, AND NYSE RULES 342, 401, 472, AND 476(A)(6). SEC LITIGATION RELEASE 18114, APRIL 28, 2003: DURING THE PERIOD JULY 1, 1999 THROUGH JUNE 30, 2001 (THE "RELEVANT PERIOD"), DEFENDANT ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, THEREBY CREATING CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. DEFENDANT FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE MANNER. DURING THE RELEVANT PERIOD, DEFENDANT ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR TO EVALUATE ANALYSTS AND DETERMINE THEIR www.finra.org/brokercheck COMPENSATION. THE RESEARCH DEPARTMENT OF DEFENDANT User Guidance COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH DEFENDANT'S INVESTMENT BANKING DEPARTMENT, AND COVERAGE DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. AS A RESULT OF THE FOREGOING, RESEARCH ANALYSTS WERE SUBJECT TO CONFLICTS OF INTEREST BETWEEN SUPPORTING DEFENDANT'S INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. IN ADDITION, DURING THE RELEVANT PERIOD DEFENDANT MADE PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN DEFENDANT KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE. DEFENDANT DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. FINALLY, DEFENDANT FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. BY ITS CONDUCT, DEFENDANT VIOLATED NASD RULES 2110, 2210(D)(1)(A) AND 3010, AND NYSE RULES 342, 401, 472, AND 476(A)(6). Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Court Details: UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, CIVIL ACTION NO. 03 CV 2939 (WHP) Date Court Action Filed: 04/28/2003 Principal Product Type: Other Other Product Types: EQUITY SECURITIES Relief Sought: Injunction Other Relief Sought: DISGORGE ALL PROCEEDS, CIVIL MONEY PENALTIES Resolution: Judgment Rendered Resolution Date: 10/31/2003 Sanctions Ordered or Relief Monetary/Fine $25,000,000.00 Granted: Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions: Sanction Details: SEC LITIGATION RELEASE 18438, OCTOBER 31, 2003: IT IS HEREBY ORDERED THAT THE DEFENDANT BE PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING RULE 2110 OF THE CONDUCT RULES OF NASD AND RULES 401 AND 476 OF THE NEW YORK STOCK EXCHANGE, INC.; PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING NASD RULE 2210 AND NYSE RULE 472 BY ISSUING COMMUNICATIONS TO THE PUBLIC THAT FAIL TO DISCLOSE THE USE OF PROCEEDS FROM OFFERINGS TO MAKE PAYMENTS TO OTHER PERSONS OR ENTITIES FOR RESEARCH COVERAGE. PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING NASD RULE 3010 AND NYSE RULE 342 BY FAILING TO MAINTAIN APPROPRIATE SUPERVISORY PROCEDURES REGARDING OR ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 249 CONTROLS OVER THE FOLLOWING THAT ARE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS: INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS: COMPENSATION AND EVALUATION OF RESEARCH ANALYSTS: USE OF RESEARCH OR RESEARCH ANALYSTS IN CONNECTION WITH THE SOLICITATION OR MARKETING OF INVESTMENT BANKING BUSINESS; PUBLICATION OF RESEARCH REGARDING A SECURITIES ISSUER WITH WHICH DEFENDANT HAS, HAS SOLICITED, OR IS SOLICITING AN INVESTMENT BANKING RELATIONSHIP; AND PAYMENTS BY DEFENDANT TO OTHER ENTITIES OF THE PUBLICATION OF RESEARCH BY SUCH OTHER ENTITIES REGARDING DEFENDANT'S INVESTMENT BANKING CLIENTS. IT IS FURTHER ORDERED THAT DEFENDANT SHALL PAY A TOTAL OF $80,000,000, WHICH INCLUDES $25,000,000 AS A PENALTY, $25,000,000 AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25,000,000 TO BE USED FOR THE PROCUREMENT OF INDEPENDENT RESEARCH, AND $5,000,000, TO BE USED FOR INVESTOR EDUCATION. DEFENDANT SHALL PAY TO THE FEDERAL PAYMENT OF $25,000,000 BY WIRE TRANSFER INTO AN INTEREST BEARING ACCOUNT WITH THE FEDERAL RESERVE BANK OF NEW YORK ("FRB-NY"), TO BE DESIGNATED THE "J.P. MORGAN SECURITIES INC. DISTRIBUTION FUND ACCOUNT" ON THE TENTH BUSINESS DAY AFTER ENTRY OF THIS FINAL JUDGMENT IN ACCORDANCE WITH INSTRUCTIONS TO BE PROVIDED TO DEFENDANT BY THE FRB-NY AND AUTHORIZED OR ORDERED BY THE COURT. SEC LITIGATION RELEASE 18438, OCTOBER 31, 2003: IT IS HEREBY ORDERED THAT THE DEFENDANT BE PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING RULE 2110 OF THE CONDUCT RULES OF NASD AND RULES 401 AND 476 OF THE NEW YORK STOCK EXCHANGE, INC.; PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING NASD RULE 2210 AND NYSE RULE 472 BY ISSUING COMMUNICATIONS TO THE www.finra.org/brokercheck PUBLIC THAT FAIL TO DISCLOSE THE USE OF PROCEEDS FROM User Guidance OFFERINGS TO MAKE PAYMENTS TO OTHER PERSONS OR ENTITIES FOR RESEARCH COVERAGE. PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING NASD RULE 3010 AND NYSE RULE 342 BY FAILING TO MAINTAIN APPROPRIATE SUPERVISORY PROCEDURES REGARDING OR CONTROLS OVER THE FOLLOWING THAT ARE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS: INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS: COMPENSATION AND EVALUATION OF RESEARCH ANALYSTS: USE OF RESEARCH OR RESEARCH ANALYSTS IN CONNECTION WITH THE SOLICITATION OR MARKETING OF INVESTMENT BANKING BUSINESS; PUBLICATION OF RESEARCH REGARDING A SECURITIES ISSUER WITH WHICH DEFENDANT HAS, HAS SOLICITED, OR IS SOLICITING AN INVESTMENT BANKING RELATIONSHIP; AND PAYMENTS BY DEFENDANT TO OTHER ENTITIES OF THE PUBLICATION OF RESEARCH BY SUCH OTHER ENTITIES REGARDING DEFENDANT'S INVESTMENT BANKING CLIENTS. IT IS FURTHER ORDERED THAT DEFENDANT SHALL PAY A TOTAL OF $80,000,000, WHICH INCLUDES $25,000,000 AS A PENALTY, $25,000,000 AS DISGORGEMENT OF COMMISSIONS AND OTHER MONIES, $25,000,000 TO BE USED FOR THE PROCUREMENT OF INDEPENDENT RESEARCH, AND $5,000,000, TO BE USED FOR INVESTOR EDUCATION. DEFENDANT SHALL PAY TO THE FEDERAL PAYMENT OF $25,000,000 BY WIRE TRANSFER INTO AN INTEREST BEARING ACCOUNT WITH THE FEDERAL RESERVE BANK OF NEW YORK ("FRB-NY"), TO BE DESIGNATED THE "J.P. MORGAN SECURITIES INC. DISTRIBUTION FUND ACCOUNT" ON THE TENTH BUSINESS DAY AFTER ENTRY OF THIS FINAL JUDGMENT IN ACCORDANCE WITH INSTRUCTIONS TO BE PROVIDED TO DEFENDANT BY THE FRB-NY AND AUTHORIZED OR ORDERED BY THE COURT. Regulator Statement J.P. MORGAN HAS AGREED TO SETTLE THE COMMISSION'S ACTION AND HAS CONSENTED, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT, TO THE ENTRY OF A FINAL JUDGMENT THAT, IF APPROVED BY THE COURT, PERMANENTLY ENJOINS J.P. MORGAN FROM VIOLATIONS OF NASD AND NYSE RULES PERTAINING TO JUST AND EQUITABLE PRINCIPLES OF TRADE (NASD RULE 2110; NYSE RULES 401 AND 476), ADVERTISING (NASD RULE 2210; NYSE RULE 472), AND SUPERVISORY PROCEDURES (NASD RULE 3010; NYSE RULE 342). THE FINAL JUDGMENT ALSO ORDERS THE FIRM TO MAKE THE PAYMENTS DESCRIBED BELOW, AND PROVIDES FOR THE APPOINTMENT OF A FUND ADMINISTRATOR WHO, SUBJECT TO COURT APPROVAL, WILL FORMULATE AND ADMINISTER A PLAN OF DISTRIBUTION FOR THOSE MONIES PLACED INTO THE DISTRIBUTION FUND. $25 MILLION AS DISGORGEMENT AND AN ADDITIONAL $25 MILLION IN PENALTIES. ONE-HALF OF THE TOTAL OF THESE PAYMENTS - $25 MILLION - WILL BE PAID IN CONNECTION WITH THE SEC ACTION AND RELATED PROCEEDINGS BY THE NASD AND NYSE AND WILL BE PLACED INTO A DISTRIBUTION FUND FOR THE BENEFIT OF CUSTOMERS OF THE FIRM. THE REMAINDER WILL BE PAID TO RESOLVE RELATED PROCEEDINGS BY STATE REGULATORS. IN THE SEC ACTION, J.P. MORGAN HAS AGREED TO A FEDERAL COURT ORDER THAT WILL ENJOIN THE FIRM FROM FUTURE VIOLATIONS OF NASD AND NYSE RULES AND REQUIRE THE FIRM TO MAKE CHANGES IN THE OPERATIONS OF ITS ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 250 EQUITY RESEARCH AND INVESTMENT BANKING DEPARTMENTS. IN ADDITION, J.P. MORGAN WILL PAY, OVER FIVE YEARS, $25 MILLION TO PROVIDE THE FIRM'S CLIENTS WITH INDEPENDENT RESEARCH, AND $5 MILLION TO BE USED FOR INVESTOR EDUCATION.

SEC LITIGATION RELEASE 21457, MARCH 19, 2010: THE HONORABLE JUDGE OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ISSUED AN ORDER ON MARCH 15, 2010 APPROVING MODIFICATIONS TO THE FINAL JUDGMENTS ENTERED AGAINST THE DEFENDANT AND OTHERS. THE FINAL JUDGMENTS CONTAINED AN EXTENSIVE ADDENDUM WITH PROVISIONS MANDATING STRUCTURAL AND OTHER REFORMS THAT ADDRESSED POTENTIAL CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. THE SETTLEMENT PROVIDED THAT WITH RESPECT TO ANY PROVISION THAT HAD NOT BEEN EXPRESSLY SUPERSEDED BY SUBSEQUENT RULEMAKING WITHIN FIVE YEARS, THE SEC WOULD AGREE TO AN AMENDMENT/MODIFICATION OF SUCH TERM, SUBJECT TO COURT APPROVAL, UNLESS THE SEC BELIEVES IT WOULD NOT BE IN THE PUBLIC INTEREST. THE COURT APPROVED REMOVING A NUMBER OF PROVISIONS. THE ADDENDUM NO LONGER INCLUDES PROHIBITIONS AGAINST INVESTMENT BANKING INPUT INTO RESEARCH ANALYST COMPENSATION AND THE BAR AGAINST RESEARCH ANALYSTS PARTICIPATING IN EFFORTS TO SOLICIT INVESTMENT BANKING BUSINESS, AMONG OTHER THINGS. THE MODIFIED ADDENDUM AS ORDERED BY THE COURT AND SUPPORTED BY THE SEC MAINTAINED THE REQUIREMENT THAT A CHAPERONE FROM LEGAL OR COMPLIANCE BE PRESENT WHEN INVESTMENT BANKING SEEKS THE VIEWS OF RESEARCH ANALYSTS CONCERNING A PROPOSED TRANSACTION OR A POTENTIAL CANDIDATE FOR A TRANSACTION. ONE PROPOSED MODIFICATION WOULD HAVE ALLOWED INVESTMENT BANKING TO SEEK THE VIEWS OF RESEARCH ANALYSTS REGARDING MARKET OR INDUSTRY TRENDS, CONDITIONS, OR DEVELOPMENTS WITHOUT THE REQUIREMENT OF A CHAPERONE, SUBJECT TO CERTAIN LIMITATIONS INCLUDING THE IMPLEMENTATION OF CONTROLS AND TRAINING AS DESCRIBED IN THE NOVEMBER 30, 2009 LETTER TO THE COURT FROM THE SETTLING FIRMS. IN HIS MARCH 15, 2010 ORDER, THE HONORABLE JUDGE DID NOT APPROVE THIS PROPOSED MODIFICATION. AS A RESULT OF THE COURT'S ORDER, THE DEFENDANT REMAINS SUBJECT TO A NUMBER OF IMPORTANT RESTRICTIONS THAT APPLY ONLY TO IT AND OTHER FIRMS AFFECTED BY THE FINAL JUDGMENTS AND SETTLEMENT. TOGETHER WITH THE REST OF THE INDUSTRY, THEY ALSO REMAIN SUBJECT TO ALL OF THE PROVISIONS OF NASD RULE 2711, NYSE RULE 472, AND THE SEC'S REGULATION AC THAT ADDRESS RESEARCH ANALYST CONFLICTS OF INTEREST. J.P. MORGAN HAS AGREED TO SETTLE THE COMMISSION'S ACTION AND HAS CONSENTED, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT, TO THE ENTRY OF A FINAL JUDGMENT THAT, IF APPROVED BY THE COURT, PERMANENTLY ENJOINS J.P. MORGAN FROM VIOLATIONS OF NASD AND NYSE RULES PERTAINING TO JUST AND EQUITABLE PRINCIPLES OF TRADE (NASD RULE 2110; NYSE RULES 401 AND 476), ADVERTISING (NASD RULE 2210; NYSE RULE 472), AND SUPERVISORY PROCEDURES (NASD RULE 3010; NYSE RULE 342). THE FINAL JUDGMENT ALSO ORDERS THE FIRM TO MAKE THE PAYMENTS DESCRIBED BELOW, AND PROVIDES FOR THE APPOINTMENT OF A FUND ADMINISTRATOR WHO, SUBJECT TO COURT APPROVAL, WILL FORMULATE AND ADMINISTER A PLAN OF DISTRIBUTION FOR THOSE MONIES PLACED INTO THE DISTRIBUTION FUND. $25 MILLION AS DISGORGEMENT AND AN ADDITIONAL $25 MILLION IN PENALTIES. ONE-HALF OF THE TOTAL OF THESE PAYMENTS - $25 MILLION - WILL BE PAID IN CONNECTION WITH THE SEC ACTION AND RELATED PROCEEDINGS BY THE NASD AND NYSE AND WILL BE PLACED INTO A DISTRIBUTION FUND FOR THE BENEFIT OF www.finra.org/brokercheck CUSTOMERS OF THE FIRM. THE REMAINDER WILL BE PAID TO RESOLVE User Guidance RELATED PROCEEDINGS BY STATE REGULATORS. IN THE SEC ACTION, J.P. MORGAN HAS AGREED TO A FEDERAL COURT ORDER THAT WILL ENJOIN THE FIRM FROM FUTURE VIOLATIONS OF NASD AND NYSE RULES AND REQUIRE THE FIRM TO MAKE CHANGES IN THE OPERATIONS OF ITS EQUITY RESEARCH AND INVESTMENT BANKING DEPARTMENTS. IN ADDITION, J.P. MORGAN WILL PAY, OVER FIVE YEARS, $25 MILLION TO PROVIDE THE FIRM'S CLIENTS WITH INDEPENDENT RESEARCH, AND $5 MILLION TO BE USED FOR INVESTOR EDUCATION.

i Reporting Source: Firm Current Status: Final Allegations: SEC ALLEGES THAT DURING THE PERIOD OF JULY 1, 1999 TO JUNE 30, 2001 J.P. MORGAN SECURITIES INC: 1. ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS AND THEREBY CREATED CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS. 2. FAILED TO MANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER. 3. ENCOURAGED ITS RESEARCH ANALYSTS TO PARTICIPATE IN INVESTMENT BANKING ACTIVITIES, AND USED THIS PARTICIPATION AS A FACTOR IN EVALUATING AND COMPENSATING RESEARCH ANALYSTS. 4. COORDINATED THE DECISION TO INITIATE AND MAINTAIN RESEARCH COVERAGE ON CERTAIN COMPANIES WITH THE INVESTMENT BANKING DEPARTMENT, AND COVERAGE DECISIONS WERE INFLUENCED BY INVESTMENT BANKING INTERESTS. 5. SUBJECTED RESEARCH ANALYSTS TO CONFLICTS OF INTEREST BETWEEN SUPPORTING THE INVESTMENT BANKING BUSINESS AND PUBLISHING OBJECTIVE RESEARCH. 6. MADE PAYMENTS TO OTHER BROKER- DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGE, AND DID NOT DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS. 7. FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE INVESTMENT BANKING INFLUENCES OR MANAGE THE CONFLICTS OF INTEREST. ALLEGED VIOLATIONS: VIOLATION OF NASD CONDUCT RULES 2110, 2210(D)(1)(A) AND 3010, AND NYSE RULES 342, 401, 472, AND 476(A)(6). Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Court Details: 03 CV 2939 (WHP) (S.D.N.Y.) Date Court Action Filed: 04/28/2003 Principal Product Type: Other Other Product Types: Relief Sought: Injunction Other Relief Sought: DISGORGE PROCEEDS, CIVIL MONEY PENALTY, PAYMENTS FOR INDEPENDENT RESEARCH AND INVESTOR EDUCATION. Resolution: Other Resolution Date: 10/31/2003 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 252 www.finra.org/brokercheck User Guidance

Resolution Date: 10/31/2003 Sanctions Ordered or Relief Monetary/Fine $25,000,000.00 Granted: Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions: $25,000,000.00, TO BE USED FOR THE PROCUREMENT OF INDEPENDENT RESEARCH; $5,000,000.00, TO BE USED FOR INVESTOR EDUCATION; ORDER TO COMPLY WITH UNDERTAKINGS TO CHANGE CERTAIN BUSINESS PRACTICES. Sanction Details: 1. JPMSI PERMANENTLY ENJOINED FROM VIOLATING THE NASD NASD AND NYSE RULES SET FORTH IN 7 ABOVE, EFFECTIVE ON ENTRY OF THE FINAL JUDGMENT. 2. JPMSI SHALL PAY A TOTAL AMOUNT OF $80,000,000.00, SUBJECT TO THE DECISION OF ANY STATE SECURITIES REGULATOR(S) NOT TO SETTLE, AS FOLLOWS: $25,000,000.00, AS A PENALTY; $25,000,000.00, AS DISGORGEMENT; $25,000,000.00, TO BE USED FOR THE PROCUREMENT OF INDPENDENT RESEARCH; AND $5,000,000.00, TO BE USED FOR INVESTOR EDUCATION. OF THE FINE AND DISGORGEMENT, $25,000,000.00 TO BE PAID WITHIN 10 DAYS OF ENTRY OF THE FINAL JUDGMENT AND $15,000,000.00 TO BE PAID TO THE STATES AS THEY JOIN THE SETTLEMENT; THE OTHER AMOUNTS TO BE PAID OVER 5 YEARS. Firm Statement THE ACTION WAS SETTLED AS FOLLOWS: JPMSI CONSENTED, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT, TO THE ENTRY OF A FINAL JUDGMENT IMPOSING THE SANCTIONS SET FORTH IN 13 ABOVE. THE FINAL JUDGMENT WAS ENTERED ON OCTOBER 31, 2003. i Disclosure 3 of 3 Reporting Source: Firm Current Status: Final Allegations: ON 7/17/1996 JMPSI (APPLICANT), ALONG WITH 23 OTHER BROKER/DEALERS, ENETERED A STIPULATION AND ORDER THAT SETTLED ANTITRUST CHARGES SET FORTH IN A COMPLAINT THAT WAS FILED SIMULTANEOUSLY. THE COMPLAINT ALLEGED AN INDUSTRY WIDE PRICING CONVENTION THAT SUPPOSEDLY RESULTED IN NASDAQ SPREADS BEING WIDER THAN THEY OTHERWISE WOULD HAVE BEEN. UNDER THE STIP. AND ORDER ENETERED TO RESOLVE THE MATTER, JPMSI AND THE OTHER DEFENDANTS AGREED CHALLENGED CONDUCT WITH OTHER B/D'S, NOT TO INTIMIDATE PERSONS WHO DO NOT FOLLOW CERTAIN MARKET CONVESNTIONS, TO TAPE TRADER CONVERSATIONS AND TO ESTABLISH AN ANTITRUST COMPLIANCE PROGRAM WHICH INCLUDES THE APPT. OF AN ANTITRUST OFFICER. Initiated By: UNITED STATES DEPARTMENT OF JUSTICE Court Details: UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 253 YORK. www.finra.org/brokercheck User Guidance

Court Details: UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK. Date Court Action Filed: 07/17/1996 Principal Product Type: Other Other Product Types: NASDAQ MARKET MAKERS/MARKET MAKING PRACTICES Relief Sought: Other Relief Sought: N/A Resolution: Settled Resolution Date: 04/22/1997 Sanctions Ordered or Relief Granted: Other Sanctions: N/A Sanction Details: N/A Firm Statement N/A

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 2 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 04/07/2011 Case Number: 11-01330 Disputed Product Type: Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 07/01/2013 Sum of All Relief Awarded: $55,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 2 of 2 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/13/1993 Case Number: 93-05002 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $9,200.00 ©2021 FINRA. All rights reserved. Report about J.P. MORGAN SECURITIES INC. 255 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $9,200.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/20/1994 Sum of All Relief Awarded: $4,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

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