0000824468-23-000007.txt : 20230905 0000824468-23-000007.hdr.sgml : 20230905 20230905161805 ACCESSION NUMBER: 0000824468-23-000007 CONFORMED SUBMISSION TYPE: SBSE/A PUBLIC DOCUMENT COUNT: 12 FILED AS OF DATE: 20230829 DATE AS OF CHANGE: 20230905 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CREDIT SUISSE AG/ CENTRAL INDEX KEY: 0000824468 IRS NUMBER: 135015677 FILING VALUES: FORM TYPE: SBSE/A SEC ACT: 1934 Act SEC FILE NUMBER: 026-00191 FILM NUMBER: 231235994 BUSINESS ADDRESS: STREET 1: PARADEPLATZ 8 CITY: ZURICH STATE: V8 ZIP: CH 8001 BUSINESS PHONE: 41 44333 2751 MAIL ADDRESS: STREET 1: PARADEPLATZ 8 CITY: ZURICH STATE: V8 ZIP: CH 8001 FORMER COMPANY: FORMER CONFORMED NAME: CREDIT SUISSE/ DATE OF NAME CHANGE: 20050629 FORMER COMPANY: FORMER CONFORMED NAME: CREDIT SUISSE FIRST BOSTON/ DATE OF NAME CHANGE: 19970211 FORMER COMPANY: FORMER CONFORMED NAME: CREDIT SUISSE DATE OF NAME CHANGE: 19921119 SBSE/A 1 primary_doc.xml SBSE/A 0000824468 XXXXXXXX true false CREDIT SUISSE AG/ 13-5015677 ANGGYXNX0JLX3X63JN86 0000824468 PARADEPLATZ 8 ZURICH V8 CH 8001 41 44333 2751 www.credit-suisse.com DREW SHOEMAKER GLOBAL HEAD OF REGULATORY SERVICES 1-919-994-1161 drew.shoemaker@credit-suisse.com Nita Patel CHIEF COMPLIANCE OFFICER 442078881700 nita.patel@credit-suisse.com CREDIT SUISSE AG/ Y N maintains a substantial security-based swap position has substantial counterparty exposure is highly leveraged to its capital position N Y FINMA Details will be submitted using the process detailed at https://www.sec.gov/tm/Substituted-compliance-Notices Y Y The Federal Reserve Board N CREDIT SUISSE AG OPERATES AS A BANK. ITS BUSINESS COVERS ALL ASSOCIATED TYPES OF BANKING, FINANCE, CONSULTANCY, SERVICE AND TRADING ACTIVITIES IN SWITZERLAND AND ABROAD Corporation December V8 07-05-1856 N Y CREDIT SUISSE AG/ Y Y Y Y Y Y Y Y N N CREDIT SUISSE AG/ Y Y N Y Y Y Y Y Y Y N Y N N N N Y Y Y Y CREDIT SUISSE AG/ N N N Y Y Y CREDIT SUISSE AG/ N I CHIEF EXECUTIVE OFFICER 08/2022 NA Y Ulrich Korner is the CEO of CS Group AG. Ulrich rejoined CS as CEO of Asset Management in April 2021, following an 11 year stint at UBS, where he served as CEO of UBS Asset Management from 2014 to 2019, CEO of UBS EMEA from 2011 to 2019 and Group COO, CEO of Corporate Center from 2009 to 2013. Ulrich was previously an Executive at Credit Suisse from 1998 to 2009 and held roles, including CFO and COO at Credit Suisse Financial Services and CEO Switzerland. He holds a PhD in Business Administration from the University of St. Gallen. I CHIEF OPERATING OFFICER 09/2022 NA Y Francesca McDonagh is the Group Chief Operating Officer as of September 2022. From 2017 through 2022, she was the Group CEO for the Bank of Ireland. Prior to that, Francesca worked for HSBC from 1997 through 2017. Among her many roles with HSBC, she was the Group General Manager, Retail Banking and Wealth Management, HSBC UK and Europe from 2014 to 2017. She served as the Regional Head, Retail Banking and Wealth Management for HSBC Middle East and North Africa from 2011 to 2013. Francesca was also the Head of Personal Financial Services for both Hong Kong and Panama. She holds a BA in Politics, Philosophy and Economics from Oxford University, UK. I CHIEF COMPLIANCE OFFICER 11/2022 NA Y 007448928 REFER TO: https://www.credit-suisse.com/about-us/en/our-company/our-management/executive-board.html I CEO Asset Management 08/2022 NA Y 003118574 NFA ID 0466125 I Global Head of Human Resources 06/2022 NA Y Christine Graeff is the Global Head of People and a member of the Executive Board of Credit Suisse Group AG, based in Zurich. Prior to taking on the role as Global Head of People, she was the Global Head of Communications and Deputy Head of Human Resources from January 2020. Before she joined Credit Suisse, Ms. Graeff worked at the ECB where she was Head of Communications for its last two Presidents, Mario Draghi and Christine Lagarde. Prior to the ECB, Ms. Graeff was managing partner with the Brunswick Group from 2001 to 2013 where she founded and grew the German business while focusing on the financial sector. She started her career as an Investment Banker in the Corporate Finance team of Kleinwort Benson in London. Ms. Graeff holds a BA in European studies and is a trained business coach. I CEO International Wealth Management 08/2022 NA Y Francesco De Ferrari is a member of the Executive Board of Credit Suisse Group AG and the CEO of Wealth Management, which comprises the Private Banking businesses in Europe, including Switzerland, the Middle East, Africa, Latin America and Asia Pacific. He is also interim CEO of region EMEA. Before rejoining Credit Suisse in January 2022, he held executive roles in global financial services and spent 17 years at Credit Suisse in Asia and Europe. He was CEO of South East Asia & Frontier Markets from 2015-2018 during his simultaneous tenure as CEO of Private Banking Asia Pacific from 2012 to 2018. Prior to this, Francesco was CEO of Private Banking Italy from 2008 to 2011 and Business COO for Private Banking EMEA from 2007-2008. He held various management and other positions with Credit Suisse Italy from 2002-2006. UBS GROUP AG FE CORPORATION 06/2023 E Y PR 98-0186363 I CHIEF FINANCIAL OFFICER 06/2023 NA Y Simon Grimwood is a Managing Director and the Chief Financial Officer for Credit Suisse AG, based in London. Simon is the Global Head of Tax, a position he has held since January 2016, and the Global Head of CFO Data Strategy & Change Delivery, a position he has held since November 2019. Simon joined Credit Suisse from Barclays where he was the Head of Tax UK & Europe. From 2006 to 2013, he held senior management positions in Barclays in both the Tax and the Financial Accounting functions. From 2013 to 2014, he held the role of Global Head of Financial Reporting before assuming his role of Head of Tax UK & Europe, where he had responsibility for the tax obligations of the largest single part of Barclays business activities. Prior to this he was the Global Head of Tax for BPB plc. Simon holds a degree in Chemical Engineering from the University of Edinburgh and is a member of the Institute of Chartered Accountants in England and Wales and the Chartered Institute of Taxation. I CHIEF RISK OFFICER 06/2023 NA Y Damian Vogel is a Managing Director and the Chief Risk Officer for Credit Suisse AG and the Head of Risk Integration for UBS, based in Zurich. He re-joined Credit Suisse in June 2023, following a 13-year tenure at UBS, where he served as the Chief Risk Officer Global Wealth Management. At UBS, he also served as Chief Risk Officer for UBS Switzerland and Chief Risk Officer Personal and Corporate Banking and Region Switzerland. Damian began his career at Credit Suisse in 1999 and held a number of leadership roles, including Head of Structured Lombard Solutions. In his decade with the firm, he worked in Zurich, New York, and Bern. Damian holds a Master in Corporate Finance from IFZ, Zug. I Head of CS for the IB, Head of Americas for the IB at UBS 06/2023 NA Y 004556059 I GENERAL COUNSEL 06/2023 NA Y Jake Scrivens is General Counsel for Credit Suisse AG (since 2023) and the Global Head of Litigation & FCP Legal for UBS (since 2021). He was previously with Exiger Asia Limited, as a Senior Advisor from 2016-2017, following an 18-year tenure at Barclays Bank, where he was GC and later Regional Head of Markets Structuring for the Asia Pacific (APAC) region. Based in the United Kingdom, Scrivens graduated in 1989 from LLB, University College (London), and from Inns of Court School of Law, Grey's Inn (London) in 1990. CREDIT SUISSE AG/ CREDIT SUISSE AG/ INITIAL Item 16A ANGGYXNX0JLX3X63JN86 GMEI Utility CREDIT SUISSE AG TRANSACTS COMMODITY FUTURES, COMMODITIES AND COMMODITY OPTIONS. Item 16B ANGGYXNX0JLX3X63JN86 GMEI Utility CREDIT SUISSE AG BUSINESS FOCUSES ON TRANSACTIONS THAT ADDRESS THE BROAD FINANCING, RISK MANAGEMENT, AND INVESTMENT REQUIREMENTS OF ITS WORLDWIDE CLIENT BASE. CREDIT SUISSE AG PROVIDES PRIVATE BANKING AND WEATH MANAGEMENT SOLUTIONS, AND A WIDE SPECTRUM OF BANKING PRODUCTS SUCH AS TRADITIONAL AND STRUCTURED LENDING, PAYMENT SERVICES, FOREIGN EXCHANGE, COMMODITIES, DERIVATIVES AND CAPITAL GOODS LEASING. Item 11A PRICEWATERHOUSECOOPERS AG BIRCHSTRASSE 160 ZURICH V8 8050 04-30-2020 Item 11B THE BANK OF NEW YORK MELLON ONE WALL STREET NEW YORK NY 10286 01-01-1900 Item 11B CDS CLEARING AND DEPOSITORY SERVICES INC. 650 WEST GEORGIA STREET SUITE 2700 VANCOUVER Z4 V6B 4N9 01-01-1900 Item 11B SIX X-CLEAR AG BRANDSCHENKESTRASSE 47 ZURICH V8 8002 01-01-1900 Item 12A CREDIT SUISSE GROUP AG 0456539 549300506SI9CRFV9Z86 0001159510 PARADEPLATZ 8 ZURICH V8 8001 05-09-1989 06-12-2023 Item 12A UBS GROUP AG 0483182 0001610520 BAHNHOFSTRASSE 45 ZURICH V8 CH-8001 06-12-2023 Item 12B CREDIT SUISSE GROUP AG 0456539 549300506SI9CRFV9Z86 0001159510 PARADEPLATZ 8 ZURICH V8 8001 05-09-1989 06-12-2023 Item 12B UBS GROUP AG 0483182 0001610520 BAHNHOFSTRASSE 45 ZURICH V8 CH-8001 06-12-2023 CREDIT SUISSE AG/ INITIAL 13A ASSET BACKED SECURITIES CORP under common control with applicant 11 MADISON AVENUE NEW YORK NY 10010 05-21-1986 N Y N ASSET BACKED SECURITIES CORP AND CREDIT SUISSE AG ARE BOTH UNDER THE COMMON CONTROL OF CREDIT SUISSE GROUP AG, THE ULTIMATE PARENT. CREDIT SUISSE (USA), INC. under common control with applicant 11 MADISON AVENUE NEW YORK NY 10010 10-09-2000 N Y N CREDIT SUISSE (USA),INC., AND CREDIT SUISSE AG ARE BOTH UNDER THE COMMON CONTROL OF CREDIT SUISSE GROUP AG, THE ULTIMATE PARENT. CREDIT SUISSE ASSET MANAGEMENT LIMITED 000113463 under common control with applicant BEAUFORT HOUSE LONDON X0 EC3A 7JJ 04-07-1997 Y X0 N Y CREDIT SUISSE ASSET MANAGEMENT LIMITED, A REGISTERED INVESTMENT ADVISOR, IS 100% OWNED BY CREDIT SUISSE THROUGH CREDIT SUISSE ASSET MANAGEMENT (UK) HOLDINGS LTD. CREDIT SUISSE ASSET MANAGEMENT, LLC 000106012 under common control with applicant 11 MADISON AVENUE NEW YORK NY 10010 07-06-1999 N N Y CREDIT SUISSE ASSET MANAGEMENT, LLC (CSAM, LLC), A REGISTERED INVESTMENT ADVISOR IS INDIRECTLY OWNED BY CSG, THE ULTIMATE PARENT. CREDIT SUISSE CAPITAL LLC 000103821 under common control with applicant 11 MADISON AVENUE NEW YORK NY 10010 08-01-2000 N Y N CREDIT SUISSE CAPITAL LLC, A REGISTERED SEC BROKER-DEALER, IS INDIRECTLY OWNED BY CSG, THE ULTIMATE PARENT. CREDIT SUISSE FIRST BOSTON MORTGAGE ACCEPTANCE CORP under common control with applicant 11 MADISON AVENUE NEW YORK NY 10010 04-14-1988 N Y N CREDIT SUISSE FIRST BOSTON MORTGAGE ACCEPTANCE CORP AND CREDIT SUISSE AG ARE BOTH UNDER THE COMMON CONTROL OF CREDIT SUISSE GROUP AG, THE ULTIMATE PARENT. CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORP under common control with applicant 11 MADISON AVENUE NEW YORK NY 10010 11-03-2000 N Y N CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORP AND CREDIT SUISSE AG ARE BOTH UNDER THE COMMON CONTROL OF CREDIT SUISSE GROUP AG, THE ULTIMATE PARENT. CREDIT SUISSE PRIME SECURITIES SERVICES (USA) LLC 000151470 under common control with applicant 11 MADISON AVENUE NEW YORK NY 10010 08-18-2009 N Y N UNDER COMMON CONTROL DLJ MORTGAGE CAPITAL, INC. under common control with applicant 11 MADISON AVENUE NEW YORK NY 10010 11-03-2000 N Y N DLJ MORTGAGE CAPITAL, INC. AND CREDIT SUISSE AG ARE BOTH UNDER THE COMMON CONTROL OF CREDIT SUISSE GROUP AG, THE ULTIMATE PARENT. DLJ REAL ESTATE CAPITAL PARTNERS, LLC 000106238 under common control with applicant 11 MADISON AVENUE NEW YORK NY 10010 01-21-2021 N Y N DLJ REAL ESTATE CAPITAL PARTNERS LLC AND CREDIT SUISSE AG ARE BOTH UNDER THE COMMON CONTROL OF CREDIT SUISSE GROUP AG, THE ULTIMATE PARENT CREDIT SUISSE AG/ INITIAL 13B CREDIT SUISSE GROUP AG 549300506SI9CRFV9Z86 bank holding company 04-07-1997 06-12-2023 PARADEPLATZ 8 ZURICH V8 8001 V8 CREDIT SUISSE GROUP AG (CSG) IS THE TOP HOLDING COMPANY. THE GROUP INDIRECTLY AND DIRECTLY OWNS VARIOUS COMPANIES, THE MAJOR SUBSIDIARY BEING CREDIT SUISSE AG. IT IS THROUGH THIS COMPANY THAT CSG PRIMARILY CONDUCTS ITS FINANCIAL SERVICES BUSINESS. CREDIT SUISSE INTERNATIONAL E58DKGMJYYYJLN8C3868 foreign bank 02-18-1993 ONE CABOT SQUARE LONDON X0 E14 4QJ X0 CREDIT SUISSE INTERNATIONAL, (KNOWN UNTIL MARCH 27, 2000 AS CREDIT SUISSE FINANCIAL PRODUCTS) ("CSFP") OWNS 100% OF THE SHARES OF CREDIT SUISSE INTERNATIONAL(USA), INC., A HOLDING COMPANY NOT ENGAGED IN THE SECURITIES OR INVESTMENT ADVISORY BUSINESS. CREDIT SUISSE AG ANGGYXNX0JLX3X63JN86 foreign bank 04-07-1997 PARADEPLATZ 8 ZURICH V8 8001 V8 CREDIT SUISSE AG, A SWISS BANK IS 100% OWNED BY CREDIT SUISSE GROUP AG. CREDIT SUISSE AG OWNS A 100% ECONOMIC INTEREST IN CREDIT SUISSE HOLDINGS (USA), INC., AS WELL AS 100% OF THE VOTING STOCK. UBS GROUP AG bank holding company 06-12-2023 BAHNHOFSTRASSE 45 ZURICH V8 CH-8001 V8 UBS GROUP AG IS THE TOP HOLDING COMPANY. THE GROUP INDIRECTLY AND DIRECTLY OWNS VARIOUS COMPANIES, THE MAJOR SUBSIDIARY BEING CREDIT SUISSE AG. IT IS THROUGH THIS COMPANY THAT CSG PRIMARILY CONDUCTS ITS FINANCIAL SERVICES BUSINESS. CREDIT SUISSE AG/ Add 10-03-1983 11 MADISON AVENUE NEW YORK NY 10010 JJ MCDONALD Add 08-18-2014 PARK LANE, SPENCER DOCK DUBLIN 1 L2 00000 SINEAD MAHON Add 03-08-1973 UNIT #03-01/#04-01/#05-01 SINGAPORE U0 39393 JACKY ANG Add 04-22-1993 ONE CABOT SQUARE LONDON X0 E14 4QJ CHRISTOPHER HORNE Add 10-18-1971 CHARLOTTE & SHIRLEY STREET NASSAU C5 2002 TEODORO LIMA Add 04-08-1940 11 MADISON AVENUE NEW YORK NY 10010 JJ MCDONALD Add 10-01-2001 ONE FIRST CANADIAN PLACE TORONTO Z4 M5X 1C9 ON CHRISTOPHER GAGE Add 03-16-1990 VIA SANTA MARGHERITA NO. 3 MILAN L6 20121 FEDERICO IMBERT Add 05-13-2005 INTERNATIONAL COMMERCE CENTRE HONG KONG K3 999077 LAWRENCE CHEUNG Add 08-06-2010 PLOT F OF SHIVSAGAR ESTATE DR. ANNIE BESANT ROAD, WORLI MUMBAI K7 400018 SANDEEP AGARWAL Add 07-16-1994 8 CENTURY AVENUE, PUDONG SHANGHAI F4 200120 RICK MENG Add 03-01-1992 109 SOGONG-RO, JONGNO-GU SEOUL M5 100-755 SOOHYUN BAEK Add 08-28-1977 6-1 ROPPONGI 1 CHOME, MINATO-KU TOKYO M0 106-6024 MAKOTO KUWAHARA Add 09-15-1933 1 MACQUARIE PLACE SYDNEY, NEW SOUTH WALES C3 2000 LUCY REPASKY Add 07-08-1998 NO. 109, SECTION 3 MIN-SHENG EAST ROAD TAIPEI F5 11011 ISAAC CHANG Add 02-23-1998 AYALA 42 MADRID U3 28001 IGNACIO ALEJANDRE Add 01-04-1986 SOUTH ESPLANADE ST PETER PORT Y7 GY1 6LU GLEN RICHARD TONKS Add 01-03-2005 5 RUE JEAN MONNET LUXEMBOURG N4 L-2013 CHRISTIAN HUSS Add 10-15-2008 EAST TOWER BUILDING, LEVEL 21 KING FAISAL HIGHWAY MANAMA C6 316 SAAD OSSEIRAN Add 01-01-2005 DUBAI INTERNATIONAL FINANCIAL CENTRE DUBAI C0 00000 MOHAMMED HIJAZI CREDIT SUISSE AG/ Firm CREDIT SUISSE SECURITIES (USA) LLC 11 MADISON AVENUE NEW YORK NY 10010 DREW SHOEMAKER DREW SHOEMAKER GLOBAL HEAD OF REGULATORY SERVICES 11-01-2021 CAYMAN ISLANDS MONETARY AUTHORITY E9 CENTRAL BANK OF IRELAND L2 FINANCIAL CONDUCT AUTHORITY X0 BANK OF ITALY L6 MONETARY AUTHORITY OF SINGAPORE U0 OFFICE OF THE SUPERINTENDENT OF FINANCIAL INSTITUTIONS Z4 CENTRAL BANK OF THE BAHAMAS C5 RESERVE BANK OF INDIA K7 FINANCIAL SUPERVISORY SERVICE M5 FINMA V8 AMENDED 14A(1) 14A(2) Applicant CREDIT SUISSE AG/ N CREDIT SUISSE AG Y APPLICANT Federal Court UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA, ALEXANDRIA DIVISION ALEXANDRIA VA CRIMINAL NO. 1:14-CR-188 05-19-2014 Exact VIOLATIONS OF TITLE 26, UNITED STATES CODE, SECTION 7206(2) 1 Felony GUILTY PLEA, ENTERED 05/19/2014. N Final 05-19-2014 Exact Convicted 05-19-2014 GUILTY PLEA, ENTERED 05/19/2014. CREDIT SUISSE AG ("CSAG") AGREED TO A $2,000,000,000 RESOLUTION, THAT CONSISTED OF A CRIMINAL FINE IN THE AMOUNT OF $1,333,500,000, LESS A CREDIT OF $196,511,014 FOR CSAG'S PAYMENT TO THE U.S. SECURITIES AND EXCHANGE COMMISSION PURSUANT TO ITS ORDER OF FEBRUARY 21, 2014 IN ADMINISTRATIVE PROCEEDING FILE NO. 3-15763, TO BE PAID WITHIN ONE WEEK OF THE DATE OF SENTENCING; A MANDATORY SPECIAL ASSESSMENT OF $400; AND RESTITUTION TO THE U.S. INTERNAL REVENUE SERVICE IN THE AMOUNT OF $666,500,000, TO BE PAID WITHIN ONE WEEK OF SENTENCING. SENTENCING DATE SET FOR AUGUST 12, 2014. 05-19-2014 2000000000.00 08-12-2014 FOR A SIGNIFICANT PERIOD OF TIME LEADING UP TO AND THROUGH APPROXIMATELY 2009, CSAG DID UNLAWFULLY AID, ASSIST IN, PROCURE, COUNSEL, AND ADVISE THE PREPARATION AND PRESENTATION OF FALSE INCOME TAX RETURNS AND OTHER DOCUMENTS TO THE INTERNAL REVENUE SERVICE OF THE TREASURY DEPARTMENT ("IRS"). IN THE SAME TIME PERIOD, CSAG OPERATED AN ILLEGAL CROSS-BORDER BANKING BUSINESS THAT KNOWINGLY AND WILLFULLY AIDED AND ASSISTED U.S. CLIENTS IN OPENING AND MAINTAINING UNDECLARED ACCOUNTS AND CONCEALING OFFSHORE ASSETS AND INCOME FROM THE IRS. IN 2010, THE TAX DIVISION OF THE U.S. DEPARTMENT OF JUSTICE INFORMED CSAG THAT THE DEPARTMENT OF JUSTICE HAD BEGUN A CRIMINAL INVESTIGATION AND THE INVESTIGATION HAD UNCOVERED EVIDENCE OF TAX LAW VIOLATIONS BY CERTAIN CSAG EMPLOYEES. IN RESPONSE, IN 2011, CSAG BEGAN AN INTERNAL INVESTIGATION. ON MAY 19, 2014, CSAG AND THE DEPARTMENT OF JUSTICE ENTERED INTO AN AGREEMENT PURSUANT TO RULE 11 OF THE FEDERAL RULES OF CRIMINAL PROCEDURE, WHEREBY CSAG AGREED TO PLEAD GUILTY TO ONE FELONY COUNT OF AIDING, ASSISTING, PROCURING, COUNSELING, AND ADVISING OF THE PREPARATION AND PRESENTATION OF FALSE INCOME TAX RETURNS TO THE IRS. NONE OF THE ALLEGED CONDUCT IS ATTRIBUTABLE TO ANY CSAG AFFILIATE THAT IS REGISTERED WITH THE COMMISSION AS AN INVESTMENT ADVISER OR BROKER-DEALER. AMENDED 14C(1) 14C(2) 14C(4) 14C(5) 14D(1) 14D(2) 14D(4) 14D(5) 14E(2) One or more control affiliate(s) 000000816 Firm Y CREDIT SUISSE SECURITIES (USA) LLC N Y AMENDED 14C(2) One or more control affiliate(s) Firm N CLARIDEN ASSET MGMT (NEW YORK), INC N N SEC U.S. SECURITIES & EXCHANGE COMMISSION Civil and Administrative Penalty(ies)/Fine(s) 07-10-1995 Exact ADMIN. PROC. FILE NO. 3-8747 No Product THAT (I) ADVISER HAD EFFECTED TRADES ON A PRINCIPAL BASIS FOR CLIENTS USING AN AFFILIATE WITHOUT NOTIFYING THE CLIENTS OF THE CAPACITY IN WHICH IT ACTED, BEFORE THE COMPLETION OF THE TRANSACTION, AND OBTAINING THE CLIENTS' PRIOR CONSENT AND (II) POGUE KNEW THAT THE TRADES WOULD BE EFFECTED ON A PRINCIPAL BASIS WITHOUT SUCH NOTIFICATION OF CLIENTS AND SUCH PRIOR CONSENT. Final Settled 07-10-1995 Exact Monetary/Fine 50000.00 ADVISER AND POGUE AGREED TO CEASE AND DESIST FROM EFFECTING SUCH TRANSACTIONS WITHOUT NOTIFYING CLIENTS AND OBTAINING THEIR PRIOR CONSENT. ADVISER ALSO AGREED TO PAY A FINE OF $50,000.00 AND TO MAINTAIN ITS ENHANCED WRITTEN POLICIES AND PROCEDURES. SEE ABOVE AMENDED 14C(2) 14C(4) 14C(5) One or more control affiliate(s) Firm N CREDIT SUISSE ASSET MANAGEMENT, INC. N N SEC U.S. SECURITIES & EXCHANGE COMMISSION Civil and Administrative Penalty(ies)/Fine(s) 11-16-1994 Exact ADMIN. PROC. FILE NO. 3-8555 No Product THAT CREDIT SUISSE ASSET MANAGEMENT, INC. ("CSAM") EFFECTED TRADES ON A PRINCIPAL BASIS FOR CLIENTS USING AFFILIATES WITHOUT NOTIFYING CLIENTS AND OBTAINING THEIR PRIOR CONSENT. Final Settled 11-16-1994 Exact Monetary/Fine 35000.00 CSAM AGREED TO CEASE AND DESIST FROM THE ALLEGED ACTIVITY. CSAM ALSO AGREED TO PAY A FINE IN THE AMOUNT OF $35,000.00 AND TO ENHANCE ITS WRITTEN POLICIES AND PROCEDURES. SEE ABOVE AMENDED 14C(1) 14C(2) 14C(4) 14C(5) One or more control affiliate(s) 000106012 Firm Y CREDIT SUISSE ASSET MANAGEMENT, LLC N Y AMENDED 14C(2) 14C(4) 14C(5) One or more control affiliate(s) Firm N CREDIT SUISSE GROUP AG N N SEC SECURITIES & EXCHANGE COMMISSION Disgorgement Civil and Administrative Penalty(ies)/Fine(s) Censure Cease and Desist 03-07-2011 Exact 3-15763 No Product THE ALLEGATIONS ARE RELATED TO CSAG'S SOLICITATION AND PROVISION OF BROKER-DEALER AND INVESTMENT ADVICE SERVICES TO CERTAIN U.S. CROSS-BORDER CLIENTS DURING A TIME WHICH CSAG WAS NOT REGISTERED WITH COMMISSION AS A BROKER-DEALER OR INVESTMENT ADVISER. Final Decision & Order of Offer of Settlement 02-21-2014 Exact Monetary/Fine Censure Cease and Desist/ Injunction Disgorgement/Restitution 196511014.00 CSAG SHALL, WITHIN NINETY (90) DAYS OF THE ENTRY OF THE FEBRUARY 21, 2014 ORDER, PAY DISGORGEMENT OF $82,170,990, PREJUDGEMENT INTEREST OF $64,340,024 AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $50,000,000. ON FEBRUARY 21, 2014, CSAG REACHED A SETTLEMENT WITH THE SEC THAT RESOLVES AN INVESTIGATION RELATING TO ITS SOLICITATION AND PROVISION OF BROKER-DEALER AND INVESTMENT ADVICE SERVICES TO CERTAIN U.S. CROSS-BORDER CLIENTS. NONE OF THE CONDUCT SUBJECT TO THE INVESTIGATION IS ATTRIBUTABLE TO CREDIT SUISSE SECURITIES (USA) LLC ("CSSU") OR ANY CSAG AFFILIATE THAT IS REGISTERED WITH THE COMMISSION AS A BROKER-DEALER. IN A SETTLED ADMINISTRATIVE PROCEEDING, THE SEC CHARGED CSAG WITH VIOLATING THE REGISTRATION PROVISIONS OF THE SECURITIES EXCHANGE ACT OF 1934 AND THE INVESTMENT ADVISERS ACT OF 1940 ("VIOLATIONS"). AS PART OF THE SETTLMENT, CSAG HAS BEEN DIRECTED BY THE SEC TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS, AND CSAG HAS AGREED TO APPROXIMATELY USD 196.5 MILLION WHICH WAS RECORDED IN THE FOURTH QUARTER OF 2013 AS A LITIGATION PROVISION. AMENDED 14C(2) 14C(4) 14C(5) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N Other Federal COMMODITY FUTURES TRADING COMMISSION (CFTC) Cease and Desist 07-17-2012 Exact CFTC DOCKET NO. 16-10 Futures - Commodity WITHOUT ADMITTING OR DENYING THE FINDINGS, CREDIT SUISSE INTERNATIONAL ("CSI") CONSENTED TO THE ENTRY OF ORDER THAT CSI VIOLATED SECTION 4A(B)(2) OF THE ACT AND REGULATION 150.2 (2009). ON SEVERAL DAYS IN APRL AND JUNE 2009, CREDIT SUISSE INTERNATIONAL (CSI) EXCEEDED THE CFTC ALL-MONTHS SPECULATIVE POSITION LIMIT FOR CHICAGO BOARD OF TRADE ("CBOT") WHEAT FUTURES CONTRACTS. Final Decision & Order of Offer of Settlement 03-22-2016 Exact Monetary/Fine Cease and Desist/ Injunction 525000.00 ON MARCH 28, 2016, CSI PAID A CIVIL MONETARY PENALTY OF $525,000 AS A RESULT OF THE ALLEGATIONS DESCRIBED IN PARAGRAPH 7, ABOVE. NO PORTION OF THE PENALTY WAS WAIVED." SEE ABOVE AMENDED 14C(1) 14C(2) 14C(4) 14C(5) Applicant CREDIT SUISSE AG/ N SEC U.S. SECURITIES AND EXCHANGE COMMISSION Civil and Administrative Penalty(ies)/Fine(s) Cease and Desist 06-03-2013 Exact HO-12115 No Product THE U.S SECURITIES AND EXCHANGE COMMISSION ORDER FINDS THAT, FROM THE FOURTH QUARTER OF 2011 THROUGH THE FOURTH QUARTER OF 2012, CREDIT SUISSE AG IN CERTAIN INSTANCES IMPROPERLY APPLIED ITS PROCESS FOR RECOGNIZING NNA IN A WAY THAT WAS INCONSISTENT WITH ITS DISCLOSURES. SPECIFICALLY, RATHER THAN EVALUATING EACH CLIENT AND DETERMINING WHAT WAS APPROPRIATELY RECOGNIZED AS NNA, CREDIT SUISSE AG, AT TIMES, TOOK A RESULTS-DRIVEN APPROACH THAT ALLOWED TARGETS TO INFLUENCE THE TIMING AND AMOUNT OF NNA RECOGNITION. THE SEC'S ORDER FIND THAT CREDIT SUISSE AG VIOLATED SECTION 17(A)(2) AND (3) OF THE SECURITIES ACT OF 1933 AND SECTION 13(A) AND (B)(2)(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES 13A-1, 13A-16, AND 12B-20. Final Order 10-05-2016 Exact Monetary/Fine Cease and Desist/ Injunction 90000000.00 THE U.S SECURITIES AND EXCHANGE COMMISSION ISSUED A CEASE-AND-DESIST ORDER, AND DIRECTED CREDIT SUISSE AG TO PAY A CIVIL PENALTY OF $90 MILLION. CREDIT SUISSE AG ADMITS THE FACTS IN THE ORDER AND IS PLEASED TO RESOLVE THIS INVESTIGATION, WHICH ENDED WITHOUT ANY FINDINGS OF CLIENT HARM, WITHOUT ANY FINDINGS OF INTENTIONAL MISCONDUCT, AND WITHOUT ANY FINDINGS THAT ANY NNA WAS INCORRECTLY REALIZED. AMENDED 14C(2) One or more control affiliate(s) Firm N CREDIT SUISSE GROUP AG N N SEC UNITED STATES SECURITIES AND EXCHANGE COMMISSION Disgorgement Cease and Desist Other PRE-JUDGMENT INTEREST 07-05-2018 Exact FILE NO. 3-18571 No Product THE SEC ORDER ALLEGES THAT BETWEEN 2007 AND 2013, EMPLOYEES OF CREDIT SUISSE (HONG KONG) LIMITED IN THE ASIA PACIFIC REGION PROVIDED EMPLOYMENT OPPORTUNITIES TO RELATIVES AND ASSOCIATES OF GOVERNMENT OFFICIALS AND STATE-0WNED ENTERPRISE EMPLOYEES IN CHINA AND HONG KONG TO INFLUENCE THE AWARDING OF INVESTMENT BANKING MANDATES. Final Decision & Order of Offer of Settlement 07-05-2018 Exact Cease and Desist/ Injunction Disgorgement/Restitution PREJUDGMENT INTEREST DISGORGEMENT OF USD 24,989,843 AND PRE-JUDGMENT INTEREST OF USD 4,833,961. CREDIT SUISSE GROUP AG PAID A TOTAL OF USD 29,823,904 AND CONSENTED TO THE ENTRY OF A CEASE-AND-DESIST ORDER TO SETTLE ALLEGATIONS THAT EMPLOYEES OF CREDIT SUISSE (HONG KONG) LIMITED PROVIDED EMPLOYMENT OPPORTUNITIES TO RELATIVES AND ASSOCIATES OF GOVERNMENT OFFICIALS AND STATE-0WNED ENTERPRISE EMPLOYEES IN CHINA AND HONG KONG TO INFLUENCE THE AWARDING OF INVESTMENT BANKING MANDATES. NO MONITORSHIP OR OTHER AFFIRMATIVE UNDERTAKINGS WERE IMPOSED ON ANY CREDIT SUISSE ENTITY. AMENDED 14D(2) 14D(3) 14D(4) 14D(5) One or more control affiliate(s) Firm N CREDIT SUISSE ASSET MANAGEMENT LTD. N N Foreign FINANCIAL SUPERVIS AGY JPN-"FSA" FINANCE RECONSTR COMM JPN-FRC Revocation Other SUSPENSION OTHER - NEITHER THE APPLICANT NOR PERSONNEL OF TH 07-13-1999 Exact FSA #200, 1978-1983 Other DERIVATIVE PRODUCT DESIGNED TO TAKE ADVANTAGE OF JAPANESE GAAP BALANCE SHEET OR INCOME STATEMENT TREATMENT FOR CUSTOMERS. THE FSA AND THE FRC ALLEGED THAT THE CONTROL AFFILIATES LISTED IN 12(C) COMMITTED THE FOLLOWING ACTS: OBSTRUCTION OF FSA EXAMINATION; CREATION AND MARKETING OF FINANCIAL PRODUCTS ALLEGED TO BE INAPPROPRIATE TO JAPANESE PUBLIC INTEREST, BUT NOT IN VIOLATION OF APPLICABLE JAPANESE LAW; ACTIVITIES THAT VIOLATED THE BANKING LAW AND THE SECURITIES AND EXCHANGE LAW IN JAPAN; MISUSE OF TRUST ACCOUNTS; INADEQUATE COMPLIANCE SYSTEMS. Final Order 07-29-1999 Exact Revocation/Expulsion/Denial CREDIT SUISSE FINANCIAL PRODUCTS, TOKYO BRANCH - REVOCATION OF TOKYO BRANCH LICENSE, EFFECTIVE 11/30/1999. CREDIT SUISSE FIRST BOSTON, TOKYO BRANCH - ONE YEAR SUSPENSION OF NEW BUSINESS IN STRUCTURED DERIVATIVE PRODUCTS AND PRIVATE BANKING. CREDIT SUISSE FIRST BOSTON SECURITIES (JAPAN) LTD., TOKYO BRANCH - ONE MONTH SUSPENSION OF PRODUCT DEVELOPMENT GROUP AND JAPANESE DEBT CAPITAL MARKETS DEPT. CREDIT SUISSE TRUST AND BANKING CO. LTD. - UNLIMITED SUSPENSION OF NEW BUSINESS IN STRUCTURED TRUST PRODUCTS GROUP AND THE TRUST BUSINESS RELATING TO PRIVATE CLIENTS IN JAPAN WITH RIGHT TO REAPPLY AFTER ONE YEAR. CREDIT SUISSE ASSET MANAGEMENT LTD. - ONE MONTH SUSPENSION OF NEW ADVISORY BUSINESS IN JAPAN. IN 1999, THE FSA CONDUCTED AN ON-SITE EXAM OF APPLICANT'S CONTROL AFFILIATES. THE EXAM FOCUSED ON DERIVATIVES AND OTHER TRANSACTIONS ENTERED INTO BY CONTROL AFFILIATES, AS WELL AS SUPERVISORY AND OTHER ISSUES. SHORTLY AFTER THE FSA EXAM BEGAN, CS GROUP ("CSG") MANAGEMENT BECAME AWARE OF RUMORS OF MISCONDUCT REGARDING THE EXAM. AFTER REVIEW BY CSG'S INTERNAL AUDIT DEPT., CSG ENGAGED WILMER, CUTLER & PICKERING TO INVESTIGATE. WC&P FOUND THAT SEVERAL MANAGERS AND EMPLOYEES ATTEMPTED TO INTERFERE WITH THE EXAM BY CONCEALING AND/OR DESTROYING DOCUMENTS. NEITHER APPLICANT NOR ITS PERSONNEL WERE DIRECTLY INVOLVED IN SUCH MISCONDUCT. THE WC&P REPORT EMPHASIZED THAT CSG PROMPTLY ACTED TO DISCOVER MISCONDUCT AND DISCLOSE WRONGDOING TO REGULATORY AUTHORITIES. IN CONSULTATION WITH THE FSA, CSG AND ITS AFFILIATES HAVE TAKEN REMEDIAL MEASURES AND DISCIPLINARY ACTION INCLUDING TERMINATION OF CERTAIN EMPLOYEES. ON 7/29/99, CSG WAS NOTIFIED OF FSA/FRC AMINISTRATIVE SANCTIONS REGARDING THE EXAM. Firm N CREDIT SUISSE FINANCIAL PRODUCTS,TOKYO BRANCH N N Foreign FINANCIAL SUPERVIS AGY JPN-"FSA" FINANCE RECONSTR COMM JPN-FRC Revocation Other SUSPENSION OTHER - NEITHER THE APPLICANT NOR PERSONNEL OF TH 07-13-1999 Exact FSA #200, 1978-1983 Other DERIVATIVE PRODUCT DESIGNED TO TAKE ADVANTAGE OF JAPANESE GAAP BALANCE SHEET OR INCOME STATEMENT TREATMENT FOR CUSTOMERS. THE FSA AND THE FRC ALLEGED THAT THE CONTROL AFFILIATES LISTED IN 12(C) COMMITTED THE FOLLOWING ACTS: OBSTRUCTION OF FSA EXAMINATION; CREATION AND MARKETING OF FINANCIAL PRODUCTS ALLEGED TO BE INAPPROPRIATE TO JAPANESE PUBLIC INTEREST, BUT NOT IN VIOLATION OF APPLICABLE JAPANESE LAW; ACTIVITIES THAT VIOLATED THE BANKING LAW AND THE SECURITIES AND EXCHANGE LAW IN JAPAN; MISUSE OF TRUST ACCOUNTS; INADEQUATE COMPLIANCE SYSTEMS. Final Order 07-29-1999 Exact Revocation/Expulsion/Denial CREDIT SUISSE FINANCIAL PRODUCTS, TOKYO BRANCH - REVOCATION OF TOKYO BRANCH LICENSE, EFFECTIVE 11/30/1999. CREDIT SUISSE FIRST BOSTON, TOKYO BRANCH - ONE YEAR SUSPENSION OF NEW BUSINESS IN STRUCTURED DERIVATIVE PRODUCTS AND PRIVATE BANKING. CREDIT SUISSE FIRST BOSTON SECURITIES (JAPAN) LTD., TOKYO BRANCH - ONE MONTH SUSPENSION OF PRODUCT DEVELOPMENT GROUP AND JAPANESE DEBT CAPITAL MARKETS DEPT. CREDIT SUISSE TRUST AND BANKING CO. LTD. - UNLIMITED SUSPENSION OF NEW BUSINESS IN STRUCTURED TRUST PRODUCTS GROUP AND THE TRUST BUSINESS RELATING TO PRIVATE CLIENTS IN JAPAN WITH RIGHT TO REAPPLY AFTER ONE YEAR. CREDIT SUISSE ASSET MANAGEMENT LTD. - ONE MONTH SUSPENSION OF NEW ADVISORY BUSINESS IN JAPAN. IN 1999, THE FSA CONDUCTED AN ON-SITE EXAM OF APPLICANT'S CONTROL AFFILIATES. THE EXAM FOCUSED ON DERIVATIVES AND OTHER TRANSACTIONS ENTERED INTO BY CONTROL AFFILIATES, AS WELL AS SUPERVISORY AND OTHER ISSUES. SHORTLY AFTER THE FSA EXAM BEGAN, CS GROUP ("CSG") MANAGEMENT BECAME AWARE OF RUMORS OF MISCONDUCT REGARDING THE EXAM. AFTER REVIEW BY CSG'S INTERNAL AUDIT DEPT., CSG ENGAGED WILMER, CUTLER & PICKERING TO INVESTIGATE. WC&P FOUND THAT SEVERAL MANAGERS AND EMPLOYEES ATTEMPTED TO INTERFERE WITH THE EXAM BY CONCEALING AND/OR DESTROYING DOCUMENTS. NEITHER APPLICANT NOR ITS PERSONNEL WERE DIRECTLY INVOLVED IN SUCH MISCONDUCT. THE WC&P REPORT EMPHASIZED THAT CSG PROMPTLY ACTED TO DISCOVER MISCONDUCT AND DISCLOSE WRONGDOING TO REGULATORY AUTHORITIES. IN CONSULTATION WITH THE FSA, CSG AND ITS AFFILIATES HAVE TAKEN REMEDIAL MEASURES AND DISCIPLINARY ACTION INCLUDING TERMINATION OF CERTAIN EMPLOYEES. ON 7/29/99, CSG WAS NOTIFIED OF FSA/FRC AMINISTRATIVE SANCTIONS REGARDING THE EXAM. Firm N CREDIT SUISSE FIRST BOSTON SECURITIES(JAPAN) LTD., TOKYO N N Foreign FINANCIAL SUPERVIS AGY JPN-"FSA" FINANCE RECONSTR COMM JPN-FRC Revocation Other SUSPENSION OTHER - NEITHER THE APPLICANT NOR PERSONNEL OF TH 07-13-1999 Exact FSA #200, 1978-1983 Other DERIVATIVE PRODUCT DESIGNED TO TAKE ADVANTAGE OF JAPANESE GAAP BALANCE SHEET OR INCOME STATEMENT TREATMENT FOR CUSTOMERS. THE FSA AND THE FRC ALLEGED THAT THE CONTROL AFFILIATES LISTED IN 12(C) COMMITTED THE FOLLOWING ACTS: OBSTRUCTION OF FSA EXAMINATION; CREATION AND MARKETING OF FINANCIAL PRODUCTS ALLEGED TO BE INAPPROPRIATE TO JAPANESE PUBLIC INTEREST, BUT NOT IN VIOLATION OF APPLICABLE JAPANESE LAW; ACTIVITIES THAT VIOLATED THE BANKING LAW AND THE SECURITIES AND EXCHANGE LAW IN JAPAN; MISUSE OF TRUST ACCOUNTS; INADEQUATE COMPLIANCE SYSTEMS. Final Order 07-29-1999 Exact Revocation/Expulsion/Denial CREDIT SUISSE FINANCIAL PRODUCTS, TOKYO BRANCH - REVOCATION OF TOKYO BRANCH LICENSE, EFFECTIVE 11/30/1999. CREDIT SUISSE FIRST BOSTON, TOKYO BRANCH - ONE YEAR SUSPENSION OF NEW BUSINESS IN STRUCTURED DERIVATIVE PRODUCTS AND PRIVATE BANKING. CREDIT SUISSE FIRST BOSTON SECURITIES (JAPAN) LTD., TOKYO BRANCH - ONE MONTH SUSPENSION OF PRODUCT DEVELOPMENT GROUP AND JAPANESE DEBT CAPITAL MARKETS DEPT. CREDIT SUISSE TRUST AND BANKING CO. LTD. - UNLIMITED SUSPENSION OF NEW BUSINESS IN STRUCTURED TRUST PRODUCTS GROUP AND THE TRUST BUSINESS RELATING TO PRIVATE CLIENTS IN JAPAN WITH RIGHT TO REAPPLY AFTER ONE YEAR. CREDIT SUISSE ASSET MANAGEMENT LTD. - ONE MONTH SUSPENSION OF NEW ADVISORY BUSINESS IN JAPAN. IN 1999, THE FSA CONDUCTED AN ON-SITE EXAM OF APPLICANT'S CONTROL AFFILIATES. THE EXAM FOCUSED ON DERIVATIVES AND OTHER TRANSACTIONS ENTERED INTO BY CONTROL AFFILIATES, AS WELL AS SUPERVISORY AND OTHER ISSUES. SHORTLY AFTER THE FSA EXAM BEGAN, CS GROUP ("CSG") MANAGEMENT BECAME AWARE OF RUMORS OF MISCONDUCT REGARDING THE EXAM. AFTER REVIEW BY CSG'S INTERNAL AUDIT DEPT., CSG ENGAGED WILMER, CUTLER & PICKERING TO INVESTIGATE. WC&P FOUND THAT SEVERAL MANAGERS AND EMPLOYEES ATTEMPTED TO INTERFERE WITH THE EXAM BY CONCEALING AND/OR DESTROYING DOCUMENTS. NEITHER APPLICANT NOR ITS PERSONNEL WERE DIRECTLY INVOLVED IN SUCH MISCONDUCT. THE WC&P REPORT EMPHASIZED THAT CSG PROMPTLY ACTED TO DISCOVER MISCONDUCT AND DISCLOSE WRONGDOING TO REGULATORY AUTHORITIES. IN CONSULTATION WITH THE FSA, CSG AND ITS AFFILIATES HAVE TAKEN REMEDIAL MEASURES AND DISCIPLINARY ACTION INCLUDING TERMINATION OF CERTAIN EMPLOYEES. ON 7/29/99, CSG WAS NOTIFIED OF FSA/FRC AMINISTRATIVE SANCTIONS REGARDING THE EXAM. Firm N CREDIT SUISSE FIRST BOSTON, TOKYO BRANCH N N Foreign FINANCIAL SUPERVIS AGY JPN-"FSA" FINANCE RECONSTR COMM JPN-FRC Revocation Other SUSPENSION OTHER - NEITHER THE APPLICANT NOR PERSONNEL OF TH 07-13-1999 Exact FSA #200, 1978-1983 Other DERIVATIVE PRODUCT DESIGNED TO TAKE ADVANTAGE OF JAPANESE GAAP BALANCE SHEET OR INCOME STATEMENT TREATMENT FOR CUSTOMERS. THE FSA AND THE FRC ALLEGED THAT THE CONTROL AFFILIATES LISTED IN 12(C) COMMITTED THE FOLLOWING ACTS: OBSTRUCTION OF FSA EXAMINATION; CREATION AND MARKETING OF FINANCIAL PRODUCTS ALLEGED TO BE INAPPROPRIATE TO JAPANESE PUBLIC INTEREST, BUT NOT IN VIOLATION OF APPLICABLE JAPANESE LAW; ACTIVITIES THAT VIOLATED THE BANKING LAW AND THE SECURITIES AND EXCHANGE LAW IN JAPAN; MISUSE OF TRUST ACCOUNTS; INADEQUATE COMPLIANCE SYSTEMS. Final Order 07-29-1999 Exact Revocation/Expulsion/Denial CREDIT SUISSE FINANCIAL PRODUCTS, TOKYO BRANCH - REVOCATION OF TOKYO BRANCH LICENSE, EFFECTIVE 11/30/1999. CREDIT SUISSE FIRST BOSTON, TOKYO BRANCH - ONE YEAR SUSPENSION OF NEW BUSINESS IN STRUCTURED DERIVATIVE PRODUCTS AND PRIVATE BANKING. CREDIT SUISSE FIRST BOSTON SECURITIES (JAPAN) LTD., TOKYO BRANCH - ONE MONTH SUSPENSION OF PRODUCT DEVELOPMENT GROUP AND JAPANESE DEBT CAPITAL MARKETS DEPT. CREDIT SUISSE TRUST AND BANKING CO. LTD. - UNLIMITED SUSPENSION OF NEW BUSINESS IN STRUCTURED TRUST PRODUCTS GROUP AND THE TRUST BUSINESS RELATING TO PRIVATE CLIENTS IN JAPAN WITH RIGHT TO REAPPLY AFTER ONE YEAR. CREDIT SUISSE ASSET MANAGEMENT LTD. - ONE MONTH SUSPENSION OF NEW ADVISORY BUSINESS IN JAPAN. IN 1999, THE FSA CONDUCTED AN ON-SITE EXAM OF APPLICANT'S CONTROL AFFILIATES. THE EXAM FOCUSED ON DERIVATIVES AND OTHER TRANSACTIONS ENTERED INTO BY CONTROL AFFILIATES, AS WELL AS SUPERVISORY AND OTHER ISSUES. SHORTLY AFTER THE FSA EXAM BEGAN, CS GROUP ("CSG") MANAGEMENT BECAME AWARE OF RUMORS OF MISCONDUCT REGARDING THE EXAM. AFTER REVIEW BY CSG'S INTERNAL AUDIT DEPT., CSG ENGAGED WILMER, CUTLER & PICKERING TO INVESTIGATE. WC&P FOUND THAT SEVERAL MANAGERS AND EMPLOYEES ATTEMPTED TO INTERFERE WITH THE EXAM BY CONCEALING AND/OR DESTROYING DOCUMENTS. NEITHER APPLICANT NOR ITS PERSONNEL WERE DIRECTLY INVOLVED IN SUCH MISCONDUCT. THE WC&P REPORT EMPHASIZED THAT CSG PROMPTLY ACTED TO DISCOVER MISCONDUCT AND DISCLOSE WRONGDOING TO REGULATORY AUTHORITIES. IN CONSULTATION WITH THE FSA, CSG AND ITS AFFILIATES HAVE TAKEN REMEDIAL MEASURES AND DISCIPLINARY ACTION INCLUDING TERMINATION OF CERTAIN EMPLOYEES. ON 7/29/99, CSG WAS NOTIFIED OF FSA/FRC AMINISTRATIVE SANCTIONS REGARDING THE EXAM. Firm N CREDIT SUISSE TRUST AND BANKING CO. LTD. N N Foreign FINANCIAL SUPERVIS AGY JPN-"FSA" FINANCE RECONSTR COMM JPN-FRC Revocation Other SUSPENSION OTHER - NEITHER THE APPLICANT NOR PERSONNEL OF TH 07-13-1999 Exact FSA #200, 1978-1983 Other DERIVATIVE PRODUCT DESIGNED TO TAKE ADVANTAGE OF JAPANESE GAAP BALANCE SHEET OR INCOME STATEMENT TREATMENT FOR CUSTOMERS. THE FSA AND THE FRC ALLEGED THAT THE CONTROL AFFILIATES LISTED IN 12(C) COMMITTED THE FOLLOWING ACTS: OBSTRUCTION OF FSA EXAMINATION; CREATION AND MARKETING OF FINANCIAL PRODUCTS ALLEGED TO BE INAPPROPRIATE TO JAPANESE PUBLIC INTEREST, BUT NOT IN VIOLATION OF APPLICABLE JAPANESE LAW; ACTIVITIES THAT VIOLATED THE BANKING LAW AND THE SECURITIES AND EXCHANGE LAW IN JAPAN; MISUSE OF TRUST ACCOUNTS; INADEQUATE COMPLIANCE SYSTEMS. Final Order 07-29-1999 Exact Revocation/Expulsion/Denial CREDIT SUISSE FINANCIAL PRODUCTS, TOKYO BRANCH - REVOCATION OF TOKYO BRANCH LICENSE, EFFECTIVE 11/30/1999. CREDIT SUISSE FIRST BOSTON, TOKYO BRANCH - ONE YEAR SUSPENSION OF NEW BUSINESS IN STRUCTURED DERIVATIVE PRODUCTS AND PRIVATE BANKING. CREDIT SUISSE FIRST BOSTON SECURITIES (JAPAN) LTD., TOKYO BRANCH - ONE MONTH SUSPENSION OF PRODUCT DEVELOPMENT GROUP AND JAPANESE DEBT CAPITAL MARKETS DEPT. CREDIT SUISSE TRUST AND BANKING CO. LTD. - UNLIMITED SUSPENSION OF NEW BUSINESS IN STRUCTURED TRUST PRODUCTS GROUP AND THE TRUST BUSINESS RELATING TO PRIVATE CLIENTS IN JAPAN WITH RIGHT TO REAPPLY AFTER ONE YEAR. CREDIT SUISSE ASSET MANAGEMENT LTD. - ONE MONTH SUSPENSION OF NEW ADVISORY BUSINESS IN JAPAN. IN 1999, THE FSA CONDUCTED AN ON-SITE EXAM OF APPLICANT'S CONTROL AFFILIATES. THE EXAM FOCUSED ON DERIVATIVES AND OTHER TRANSACTIONS ENTERED INTO BY CONTROL AFFILIATES, AS WELL AS SUPERVISORY AND OTHER ISSUES. SHORTLY AFTER THE FSA EXAM BEGAN, CS GROUP ("CSG") MANAGEMENT BECAME AWARE OF RUMORS OF MISCONDUCT REGARDING THE EXAM. AFTER REVIEW BY CSG'S INTERNAL AUDIT DEPT., CSG ENGAGED WILMER, CUTLER & PICKERING TO INVESTIGATE. WC&P FOUND THAT SEVERAL MANAGERS AND EMPLOYEES ATTEMPTED TO INTERFERE WITH THE EXAM BY CONCEALING AND/OR DESTROYING DOCUMENTS. NEITHER APPLICANT NOR ITS PERSONNEL WERE DIRECTLY INVOLVED IN SUCH MISCONDUCT. THE WC&P REPORT EMPHASIZED THAT CSG PROMPTLY ACTED TO DISCOVER MISCONDUCT AND DISCLOSE WRONGDOING TO REGULATORY AUTHORITIES. IN CONSULTATION WITH THE FSA, CSG AND ITS AFFILIATES HAVE TAKEN REMEDIAL MEASURES AND DISCIPLINARY ACTION INCLUDING TERMINATION OF CERTAIN EMPLOYEES. ON 7/29/99, CSG WAS NOTIFIED OF FSA/FRC AMINISTRATIVE SANCTIONS REGARDING THE EXAM. AMENDED 14D(2) Applicant CREDIT SUISSE AG/ N Foreign SWISS BANKERS ASSOCIATION ("SBA") Other SEE ITEM 12 11-19-2000 Exact N/A Other CLIENT IDENTIFICATION,ESTABLISHMENT OF BENEFICIAL OWNERSHIP AND POLITICALLY EXPOSED PERSON ("PEP") CLASSIFICATION. VIOLATION DURING THE MID-1990 S OF FORMAL CLIENT IDENTIFICATION GUIDELINES UNDER SBA'S CONTRACTUAL CODE OF CONDUCT. Final Settled 10-14-2002 Exact CONTRACTUAL PENALTY CHF 750,000 A CONTRACTUAL PENALTY OF SWISS FRANCS 750,000, WHICH WAS LEVIED AGAINST THE CONTROL AFFILIATE CREDIT SUISSE, WAS ACCEPTED WITHOUT ANY ADMISSION OR DENIAL OF THE ALLEGATIONS AND PAID IN FULL ON 10/14/2002. VIOLATION OF SBA'S CONTRACTUAL CODE OF CONDUCT ON ESTABLISHING THE IDENTITY OF BENEFICIAL OWNER AND ACCOUNT OPENING DOCUMENTATION. AMENDED 14D(2) Applicant CREDIT SUISSE AG/ N Foreign SWISS BANKERS ASSOCIATION ("SBA") Other SEE ITEM 12 11-28-2000 Exact 00/58 CDB Other ACCOUNT OPENING DOCUMENTATION VIOLATION OF SBA'S CONTRACTUAL CODE OF CONDUCT ON ESTABLISHING THE IDENTITY OF THE BENEFICIAL OWNER; ACCOUNT OPENING DOCUMENTATION. Final Settled 09-18-2002 Exact CONTRACTUAL PENALTY CHF 100,000 A CONTRACTUAL PENALTY OF SWISS FRANCS 100,000 WHICH WAS LEVIED AGAINST THE CONTROL AFFILIATE CREDIT SUISSE, WAS ACCEPTED WITHOUT ANY ADMISSION OR DENIAL OF THE ALLEGATIONS AND PAID IN FULL ON 09/18/2002. DIFFERENT VIOLATIONS OF THE SBA'S CONTRACTUAL CODE OF CONDUCT RELATING TO THE DUTY TO IDENTIFY THE CONTRACTING PARTNER AND ESTABLISH THE IDENTITY OF THE BENEFICIAL OWNER. AMENDED 14D(2) One or more control affiliate(s) Firm N CREDIT SUISSE FINANCIAL PRODUCTS ("CSFP") NOW KNOWN N N Foreign FINANCIAL SERVICES AUTHORITY OF THE UNITED KINGDOM ("UKFSA") Civil and Administrative Penalty(ies)/Fine(s) 05-21-1999 Exact FSA/CSFP-080 Other DERIVATIVE PRODUCT DESIGNED TO TAKE ADVANTAGE OF JAPANESE GAAP BALANCE SHEET OR INCOME STATEMENT TREATMENT FOR CUSTOMERS. ON MAY 21,1999, THE U.K. SECURITIES AND FUTURES AUTHORITY ("SFA") COMMENCED AN INVESTIGATION INTO THE ALLEGED DESTRUCTION OR CONCEALMENT OF DOCUMENTS IN JANUARY 1999 AT CS FINANCIAL PRODUCTS (NOW KNOWN AS CREDIT SUISSE FIRST BOSTON INTERNATIONAL ("CSFP") TOKYO BRANCH, AND THE CONTROLS EXERCISED BY CSFP OVER THE TOKYO BRANCH, AND ANY MATTERS ARISING THEREFROM. THE SFA INTERVIEWED A NUMBER OF CURRENT AND/OR FORMER CSFB EMPLOYEES. IN ADDITION, THE FIRM PRODUCED DOCUMENTS AND INFORMATION IN RESPONSE TO SFA REQUESTS. IN JULY 2001, THE SFA CONCLUDED THE FACTUAL ASPECT OF THE INVESTIGATION. THE INVESTIGATION WAS CONTINUED BY THE SFA'S SUCCESSOR REGULATOR, THE FINANCIAL SERVICES AUTHORITY OF THE UNITED KINGDOM ("UKFSA"). ON MARCH 8, 2002, CSFP RECEIVED THE UKFSA'S "PRELIMINARY FINDINGS LETTER", WHICH SET FORTH THE UKFSA'S FINDINGS OF FACT UPON WHICH A DECISION TO INSTITUTE DISCIPLINARY PROCEEDINGS AGAINST CSFB WOULD BE BASED. Final Settled 12-11-2002 Exact Monetary/Fine 6400000.00 ON DECEMBER 11, 2002, THE FIRM REACHED AN AGREEMENT WITH THE UKFSA RESOLVING THIS INVESTIGATION. THE UKFSA FOUND THAT CSFP VIOLATED CERTAIN UK REGULATORY RULES. THE COMPANY HAS ACCEPTED THESE FINDINGS AND AGREED TO PAY A FINE (4,000,000 POUNDS). AS CSFB HAS PREVIOUSLY ACKNOWLEDGED, CERTAIN FORMER EMPLOYEES FAILED TO ACT IN AN OPEN AND COOPERATIVE MANNER TOWARDS THE JAPANESE AUTHORITIES. THE ACTIONS OF THESE FORMER EMPLOYEES WERE AN ABERRATION AND CONTRARY TO THE HIGH STANDARDS EXPECTED OF THEM BY THE FIRM. THE INDIVIDUALS CONCERNED ARE NO LONGER WITH THE FIRM. AS THE FSA ACKNOWLEDGED IN A STATEMENT ON DECEMBER 19, 2002, THE EXTENSIVE ORGANIZATIONAL, PERSONNEL AND STRUCTURAL CHANGES IMPLEMENTED BY CSFB'S NEW MANAGEMENT HAVE SIGNIFICANTLY IMPROVED THE FIRMS'S CONTROLS AND COMPLIANCE CULTURE. SEE ABOVE AMENDED 14D(2) Applicant CREDIT SUISSE AG/ N Foreign SWISS BANKERS ASSOCIATION ("SBA") Other SEE ITEM 12 04-01-1998 Exact 98/4 CDB Other ACCOUNT OPENING DOCUMENTATION VIOLATION OF ESTABLISHING THE IDENTITY OF THE BENEFICIAL OWNER. VIOLATION OF ACCOUNT OPENING DOCUMENTATION. Final Settled 03-28-2003 Exact CONTRACTUAL PENALITY OF CHF 500,000 A CONTRACTUAL PENALITY OF SWISS FRANCS 500,000, WHICH WAS LEVIED AGAINST THE CONTROL AFFILATE CREDIT SUISSE, WAS ACCEPTED WITHOUT ANY ADMISSION OR DENIAL OF THE ALLEGATIONS AND PAID IN FULL ON 03/28/2003. DIFFERENT VIOLATIONS OF SBA'S CONTRACTUAL CODE OF CONDUCT ON ESTABLISHING THE IDENTITY OF THE CONTRACTING PARTNER AND THE BENEFICIAL OWNER. AMENDED 14D(2) One or more control affiliate(s) Firm N CREDIT SUISSE ASSET MANAGEMENT LIMITED N N Foreign JAPAN SECURITIES INVESTMENT ADVISORY ASSOCIATION Civil and Administrative Penalty(ies)/Fine(s) 02-23-2000 Exact N/A Investment Contract(s) FROM SEPTEMBER 1999 TO JANUARY 2000, THE JAPAN SECURITIES INVESTMENT ADVISORY ASSOCIATION (THE "JSIAA") CONDUCTED AN INSPECTION AT CREDIT SUISSE ASSET MANAGEMENT LIMITED (THE "CSAML"). ON FEBRUARY 23, 2000, JSIAA MADE THE FOLLOWING FINDINGS AND IMPOSED THE SANCTION SET FORTH BELOW. 1. CSAML DID NOT ESTABLISH AND KEEP DOCUMENTS WHICH RECORDED THE DETAILS OF SECURITIES TRADES RELATING TO INVESTMENTS MADE ACCORDING TO DISCRETIONARY INVESTMENT CONTRACTS, AMONG OTHER THINGS; 2, CSAML DID NOT DELIVER CERTAIN DOCUMENTS THAT SHOULD HAVE BEEN DELIVERED TO CUSTOMERS WHEN CONCLUDING DISCRETIONARY INVESTMENT CONTRACTS; AND 3. CSAML LACKED ADEQUATE INTERNAL CONTROLS AND COMPLIANCE SYSTEMS, WHICH LED TO VIOLATIONS OF ITS DUTY AS AN INVESTMENT ADVISOR IN THE ABOVE AREAS. Final Order 02-23-2000 Exact Monetary/Fine 5650.00 THE JSIAA RESOLVED THE COLLECTION OF PENALITY FOR NEGLIGENCE JPY 700,000 (APPROXIMATELY USD 5,650). THE JSIAA RESOLVED THE COLLECTION OF PENALITY FOR NEGLIGENCE JPY 700,000 (APPROXIMATELY USD 5,650). AMENDED 14D(2) 14D(3) 14D(4) 14D(5) One or more control affiliate(s) Firm N CREDIT SUISSE, TOKYO BRANCH (F.K.A.CREDIT SUISSE FIRST BOSTON N N Foreign FINANCIAL SUPERVISORY AGENCY OF JAPAN Suspension 02-23-2000 Exact N/A CREDIT SUISSE FIRST BOSTON Derivative(s) IN 1999, THE FINANCIAL SUPERVISORY AGENCY OF JAPAN ("FSA") COMPLETED A FORMAL ON-SITE EXAMINATION OF THE BUSINESSES IN JAPAN OF CREDIT SUISSE FIRST BOSTON (THE "BANK"), THE PARENT OF THE APPLICANT, AS WELL AS CERTAIN OTHER SUBSIDIARIES OF THE BANK IN JAPAN THAT ARE NOT ADVISORY AFFILIATES OF THE APPLICANT. THE EXAMINATION FOCUSED ON CERTAIN DERIVATIVES AND OTHER TRANSACTIONS ENTERED INTO BY THE BANK IN JAPAN AND INQUIRED INTO CERTAIN SUPERVISORY AND OTHER ISSUES. SEVERAL MANAGERS (WHO ARE NO LONGER EMPLOYEES OF THE BANK) AND OTHER MEMBERS OF THE STAFF OF SUBSIDIARIES OF THE BANK (THAT ARE NOT ADVISORY AFFILIATES) ATTEMPTED TO INTERFERE WITH THE EXAMINATION DURING ITS INITIAL STAGES BY CONCEALING AND/OR DESTROYING DOCUMENTS. THE FSA AND THE FINANCIAL RECONSTRUCTION COMMISSION IN JAPAN IMPOSED THE SANCTIONS SET FORTH BELOW. NEITHER THE APPLICANT NOR PERSONNEL OF THE APPLICANT WERE DIRECTLY INVOLVED IN ANY SUCH MISCONDUCT. Final Order 07-29-1999 Exact Suspension AS AN ATTACHMENT DUE TO SPACE LIMITATION PURSUANT TO AN ADMINISTRATIVE ORDER, THE FSA AND FINANCIAL RECONSTRUCTION COMMISSION IN JAPAN IMPOSED A ONE YEAR SUSPENSION ON NEW BUSINESS RELATING TO STRUCTURED DERIVATIVES PRODUCTS AND PRIVATE BANKING IN JAPAN BY THE TOKYO BRANCH OF THE BANK WITH THE RIGHT TO REAPPLY TO ENGAGE IN SUCH OPERATIONS AFTER ONE YEAR. AFTER THE END OF THE APPLICABLE SUSPENSION PERIOD, THE FSA GRANTED THE BANK PERMISSION TO RESUME PROVIDING NEW BUSINESS ACTIVITIES IN JAPAN AND TO EXPAND INTO OTHER ACTIVITIES IN JAPAN AMENDED 14D(5) One or more control affiliate(s) Firm N CREDIT SUISSE ASSET MANAGEMENT LIMITED(TOKYO) N N Foreign FINANCIAL SUPERVISORY AGENCY OF JAPAN Prohibition 07-29-1999 Exact N/A Investment Contract(s) THE FINANCIAL SUPERVISORY AGENCY OF JAPAN (THE "FSA") CONDUCTED AN ON-SITE INSPECTION AT CREDIT SUISSE ASSET MANAGEMENT LIMITED ("CSAML") ON APRIL, 1999 AND NOTIFIED US OF THE INSPECTION RESULTS AS FOLLOWS: 1. CSAML DID NOT ESTABLISH AND KEEP DOCUMENTS WHICH RECORDED THE DETAILS OF SECURITIES TRADES RELATING TO INVESTMENT MADE ACCORDING TO DISCRETIONARY CONTRACTS; 2. CSAML DID NOT DELIVER DOCUMENTS THAT SHOULD HAVE BEEN DELIVERED TO CUSTOMERS WHEN CONCLUDING DISCRETIONARY INVESTMENT CONTRACTS; 3. CSAML WAS FOUND TO HAVE DEFICIENT INTERNAL CONTROLS AND COMPLIANCE SYSTEMS, WHICH LED VIOLATIONS OF FIDUCIARY DUTY AS AN INVESTMENT ADVISOR, AMONG OTHER THINGS. ON JULY 29TH, 1999, BASED ON THE ABOVE FINDINGS, THE FSA IMPOSED THE SANCTIONS SET FORTH BELOW. Final Order 07-29-1999 Exact 1. PROHIBITION 2. THE BUSINESS IMPROVEMENT THE FSA IMPOSED THE FOLLOWING ADMINISTRATIVE ACTIONS: 1. AN ORDER TO PROHIBIT THE CONCLUSION OF A NEW CONTRACT RELATING TO INVESTMENT ADVISORY AND DISCRETIONARY INVESTMENT MANAGEMENT BUSINESS FROM AUGUST 5TH TO SEPTEMBER 4TH, 1999. (PURSUANT TO LAWS REGULATING SECURITIES INVESTMENT ADVISORY BUSINESS ARTICLE 38 [EXECUTIVE AUTHORITY OF THE HEAD OF THE LOCAL FINANCE BUREAU] 2. A BUSINESS IMPROVEMENT ORDER TO CLARIFY LOCUS OF RESPONSIBILITY, TO IMPLEMENT PREVENTION MEASURES AGAINST RECURRENCE, TO SOLIDIFY AND STRENGTHEN INTERNAL CONTROL SYSTEM, AND TO SECURE STRICT COMPLIANCE, AMONG OTHER THINGS. (PURSUANT TO LAWS REGULATING SECURITIES INVESTMENT ADVISORY BUSINESS ARTICLE 37 [EXECUTIVE AUTHORITY OF THE HEAD OF THE LOCAL FINANCE BUREAU]) THE PROHIBITION EXPIRED ON SEPTEMBER 4TH, 1999 (THE END DATE OF THE APPLICABLE PROHIBITION PERIOD). AMENDED 14D(2) Applicant CREDIT SUISSE AG/ N Foreign SWISS BANKERS ASSOCIATION ("SBA") Civil and Administrative Penalty(ies)/Fine(s) Other SEE ITEM 12 11-25-2005 Exact 98/4 CDB ["NO.303"] Other DOCUMENTATION OF IDENTITY VIOLATION OF ESTABLISHING THE DOCUMENTATION OF THE IDENTITY OF THE CONTRACTING PARTY AND BENEFICIAL OWNER. VIOLATION OF DOCUMENTATION OF IDENTITY FOR ACCOUNT OPENINGS. Final Settled 04-05-2007 Exact CONTRACTUAL PENALTY CHE 900,000 A CONTRACTUAL PENALTY OF SWISS FRANCS 900,000, WHICH WAS LEVIED AGAINST THE CONTROL AFFILIATE CREDIT SUISSE, WAS ACCEPTED WITHOUT ADMISSION OR DENIAL OF THE ALLEGATIONS AND PAID IN FULL ON APRIL 5, 2007. DIFFERENT VIOLATIONS OF SBA'S CONTRACTUAL CODE OF CONDUCT ON ESTABLISHING THE DOCUMENTATION OF THE IDENTITY OF THE CONTRACTING PARTNER AND THE BENEFICIAL OWNER AMENDED 14D(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N Foreign THE UK'S FINANCIAL SERVICES AUTHORITY (UK FSA) Other MONETARY FINE 08-13-2008 Exact N/A Debt - Asset Backed CS INTERNATIONAL AND CS SECURITIES (EUROPE) LIMITED (THE "UK SUBSIDIARIES") WERE FOUND TO HAVE BREACHED THE UK FINANCIAL SERVICES AUTHORITY'S ("UKFSA") PRINCIPLE 2 REQUIRING A FIRM TO CONDUCT ITS BUSINESS WITH DUE SKILL, CARE AND DILIGENCE AND PRINCIPLE 3 REQUIRING A FIRM TO TAKE REASONABLE CARE TO ORGANIZE AND CONTROL ITS AFFAIRS RESPONSIBLY AND EFFECTIVELY, WITH ADEQUATE RISK MANAGEMENT SYSTEMS. Final Settled 08-13-2008 Exact Monetary/Fine 10473866.98 THE UK SUBSIDIARIES AGREED TO PAY A FINE OF GBP 5.6 MILLION TO THE UK FSA. THE UKFSA ISSUED FINAL NOTICE CONCLUDING THAT UK SUBSIDIARIES BREACHED PRINCIPLES FOR BUSINESS AS A RESULT OF MISPRICING ASSET BACKED SECURITIES IN THE STRUCTURED PRODUCTS BUSINESS WITHIN CS'S INVESTMENT BANK. CS DETERMINED THAT MISMARKS AND PRICING ERRORS WERE, IN PART, RESULTS OF INTENTIONAL MISCONDUCT BY A SMALL NUMBER OF TRADERS. THESE EMPLOYEES HAVE EITHER BEEN TERMINATED OR SUSPENDED. CONTROLS IN PLACE TO PREVENT OR DETECT MISMARKS AND PRICING ERRORS, INCLUDING SUPERVISION AND MONITORING OF THE VALUATIONS AND RELATED PRICE TESTING AND SUPERVISION, WERE INEFFECTIVE. CS HAS REASSIGNED TRADING RESPONSIBILITY FOR THE BUSINESS AND IS ENHANCING RELATED CONTROL PROCESSES. CS REMEDIATION PLAN INCLUDES IMPROVING SUPERVISORY REVIEWS, FORMALIZING ESCALATION PROCEDURES, IMPROVING COORDINATION AMONG TRADING, PRODUCT CONTROL AND RISK MANAGEMENT, ADDING ADDITIONAL RESOURCES, IMPROVING TRAINING AND ENHANCING TOOLS AND TECHNICAL RESOURCES AVAILABLE TO CS PERSONNEL Firm N CREDIT SUISSE SECURITIES (EUROPE)LIMITED N N Foreign THE UK'S FINANCIAL SERVICES AUTHORITY (UK FSA) Other MONETARY FINE 08-13-2008 Exact N/A Debt - Asset Backed CS INTERNATIONAL AND CS SECURITIES (EUROPE) LIMITED (THE "UK SUBSIDIARIES") WERE FOUND TO HAVE BREACHED THE UK FINANCIAL SERVICES AUTHORITY'S ("UKFSA") PRINCIPLE 2 REQUIRING A FIRM TO CONDUCT ITS BUSINESS WITH DUE SKILL, CARE AND DILIGENCE AND PRINCIPLE 3 REQUIRING A FIRM TO TAKE REASONABLE CARE TO ORGANIZE AND CONTROL ITS AFFAIRS RESPONSIBLY AND EFFECTIVELY, WITH ADEQUATE RISK MANAGEMENT SYSTEMS. Final Settled 08-13-2008 Exact Monetary/Fine 10473866.98 THE UK SUBSIDIARIES AGREED TO PAY A FINE OF GBP 5.6 MILLION TO THE UK FSA. THE UKFSA ISSUED FINAL NOTICE CONCLUDING THAT UK SUBSIDIARIES BREACHED PRINCIPLES FOR BUSINESS AS A RESULT OF MISPRICING ASSET BACKED SECURITIES IN THE STRUCTURED PRODUCTS BUSINESS WITHIN CS'S INVESTMENT BANK. CS DETERMINED THAT MISMARKS AND PRICING ERRORS WERE, IN PART, RESULTS OF INTENTIONAL MISCONDUCT BY A SMALL NUMBER OF TRADERS. THESE EMPLOYEES HAVE EITHER BEEN TERMINATED OR SUSPENDED. CONTROLS IN PLACE TO PREVENT OR DETECT MISMARKS AND PRICING ERRORS, INCLUDING SUPERVISION AND MONITORING OF THE VALUATIONS AND RELATED PRICE TESTING AND SUPERVISION, WERE INEFFECTIVE. CS HAS REASSIGNED TRADING RESPONSIBILITY FOR THE BUSINESS AND IS ENHANCING RELATED CONTROL PROCESSES. CS REMEDIATION PLAN INCLUDES IMPROVING SUPERVISORY REVIEWS, FORMALIZING ESCALATION PROCEDURES, IMPROVING COORDINATION AMONG TRADING, PRODUCT CONTROL AND RISK MANAGEMENT, ADDING ADDITIONAL RESOURCES, IMPROVING TRAINING AND ENHANCING TOOLS AND TECHNICAL RESOURCES AVAILABLE TO CS PERSONNEL AMENDED 14D(4) Applicant CREDIT SUISSE AG/ N Other Federal "THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM" Cease and Desist Other ORDERED TO SUBMIT AND ADOPT AN ENHANCED GLOBAL REGULATORY CO 12-16-2009 Exact 09-210-B-FB No Product THE ORDER RECITES THAT CREDIT SUISSE AG IS A FOREIGN BANK AS DEFINED IN SECTION 3101(7) OF THE INTERNATIONAL BANKING ACT AND HAS ENTERED INTO SETTLEMENT AGREEMENTS TO RESOLVE INVESTIGATIONS BY THE U.S. DEPARTMENT OF JUSTICE, THE DISTRICT ATTORNEY FOR THE COUNTY OF NEW YORK, NY, AND THE OFFICE OF FOREIGN ASSET CONTROL (OFAC) OF THE U.S. DEPARTMENT OF THE TREASURY CONCERNING THE TRANSMISSION OF FUNDS TO AND FROM THE UNITED STATES BY AND THROUGH ENTITIES AND INDIVIDUALS SUBJECT TO SANCTIONS REGIMES IMPOSED UNDER THE INTERNATIONAL EMERGENCY ECONOMIC POWERS ACT ("IEEPA"), 50 U.S.C. 1701-06, WHICH IS ADMINISTERED BY OFAC. Final Consent 12-16-2009 Exact Cease and Desist/ Injunction ORDERED TO SUBMIT AND ADOPT AN ENHANCED GLOBAL REGULATORY COMPLIANCE PROGRAM AND TO SUBMIT WRITTEN PROGRESS REPORTS ON COMPLIANCE WITH THE ORDER. N/A CS AG HAS ENTERED INTO SETTLEMENT AGREEMENTS TO RESOLVE INVESTIGATIONS BY THE U.S. DOJ, THE DISTRICT ATTORNEY FOR THE COUNTY OF NY, NY, AND THE TREASURT DEPARTMENT OFFICE OF FOREIGN ASSET CONTROL (OFAC) CONCERNING THE TRANSMISSION OF FUNDS TO AND FROM THE U.S. BY AND THROUGH ENTITIES AND INDIVIDUALS SUBJECT TO SANCTIONS REGIMES IMPOSED UNDER THE INTERNATIONAL EMERGENCY ECONOMIC POWERS ACT ("IEEPA"), 50 U.S.C. 1701-06, WHICH IS ADMINISTERED BY OFAC. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, CREDIT SUISSE AG WAS ORDERED TO ADOPT AND SUBMIT AN ENHANCED GLOBAL REGULATORY COMPLIANCE PROGRAM AND TO SUBMIT WRITTEN PROGRESS REPORTS RELATING TO COMPLIANCE WITH THE ORDER. PURSUANT TO THE SETTLEMENTS, CS AG AGREED TO PAY A TOTAL OF $536,000,000 IN SATISFACTION OF OBLIGATIONS UNDER CONTEMPORANEOUS DEFERRED PROSECUTION AGREEMENTS BETWEEN CS AG AND THE NY COUNTRY DISTRICT ATTORNEY'S OFFICE AND THE U.S. DOJ. AMENDED 14D(4) Applicant CREDIT SUISSE AG/ N Other Federal "U.S. DEPARTMENT OF THE TREASURY, OFFICE OF FOREIGN ASSETS CONTROL" Civil and Administrative Penalty(ies)/Fine(s) 12-16-2009 Exact MUL-473923 No Product SETTLEMENT AGREEMENT BETWEEN OFAC AND CREDIT SUISSE AG RESULTING IN PAYMENT OF $536,000,000 IN GLOBAL SETTLEMENT OF ALLEGED VIOLATIONS OF THE INTERNATIONAL EMERGENCY ECONOMIC POWERS ACT ("IEEPA"), 50 U.S.C. 1701-06, THE TRADING WITH THE ENEMY ACT ("TWEA"), 50 U.S.C. 1-44, CERTAIN EXECUTIVE ORDERS, AND CERTAIN OFAC REGULATIONS, AND IN SATISFACTION OF CREDIT SUISSE AG'S PAYMENT OBLIGATIONS UNDER CONTEMPORANEOUS DEFERRED PROSECUTION AGREEMENTS BETWEEN CREDIT SUISSE AG AND THE NEW YORK COUNTRY DISTRICT ATTORNEY'S OFFICE AND THE UNITED STATES DEPARTMENT OF JUSTICE. Final Settled 12-16-2009 Exact Monetary/Fine 536000000.00 N/A N/A ACCORDING TO THE SETTLEMENT AGREEMENT WITH OFAC, IN WHICH CREDIT SUISSE AG NEITHER ADMITTED NOR DENIED THE ALLEGATION, CREDIT SUISSE AG PROCESSED ELECTRONIC FUNDS TRANSFERS THROUGH FINANCIAL INSTITUTIONS LOCATED IN THE UNITED STATES TO THE BENEFIT OF CERTAIN COUNTRIES, PERSONS AND/OR ENTITIES SUBJECT TO U.S. ECONOMIC SANCTIONS. PURSUANT TO THE SETTLEMENT,CREDIT SUISSE AG AGREED TO PAY A TOTAL OF $536,000,000 IN SATISFACTION OF OBLIGATIONS UNDER CONTEMPORANEOUS DEFERRED PROSECUTION AGREEMENTS BETWEEN CREDIT SUISSE AG AND THE NEW YORK COUNTRY DISTRICT ATTORNEY'S OFFICE AND THE UNITED STATES DEPARTMENT OF JUSTICE. AMENDED 14D(1) 14D(2) 14D(4) Applicant CREDIT SUISSE AG/ N State NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES Civil and Administrative Penalty(ies)/Fine(s) Cease and Desist 05-19-2014 Exact N/A CREDIT SUISSE AG No Product THE ALLEGATIONS ARE RELATED TO CSAG'S OPERATION OF A REPRESENTATIVE OFFICE IN NEW YORK CITY WHICH WAS UTILIZED BY THE BANK'S ILLEGAL CROSS-BORDER BANKING BUSINESS THAT KNOWINGLY AND WILLFULLY AIDED AND ASSISTED U.S. CLIENTS IN OPENING AND MAINTAINING UNDECLARED ACCOUNTS AND CONCEALING THEIR OFFSHORE ASSETS AND INCOME FROM THE IRS AND NEW YORK AUTHORITIES. NONE OF THE ALLEGED CONDUCT IS ATTRIBUTABLE TO THE REGISTRANT OR ANY CSAG AFFILIATE THAT IS REGISTERED WITH THE COMMISSION AS AN INVESTMENT ADVISER OR BROKER-DEALER. Final Order 05-19-2014 Exact Monetary/Fine Cease and Desist/ Injunction 715000000.00 CSAG SHALL PAY A CIVIL MONETARY PENALTY TO THE DEPARTMENT IN THE AMOUNT OF $715,000,000, WITHIN TEN DAYS OF EXECUTING THE CONSENT ORDER ON MAY 19, 2014, CSAG ENTERED INTO A CONSENT ORDER WITH THE DFS THAT RESOLVES AN INVESTIGATION RELATING TO THE OPERATION OF AN ILLEGAL CROSS-BORDER BANKING BUSINESS THAT AIDED AND ASSISTED U.S. CLIENTS IN OPENING AND MAINTAINING UNDECLARED ACCOUNTS AND CONCEALING OFFSHORE ASSETS AND INCOME FROM THE IRS AND NY AUTHORITIES. CSAG UTILIZED THE BANK'S NY REPRESENTATIVE OFFICE (CLOSED IN 2009) BY HOSTING MEETINGS, PROVIDING ACCOUNT STATEMENTS, AND OTHERWISE ASSISTING U.S. CLIENTS FILING FALSE AND FRAUDULENT U.S. TAX REPORTING DOCUMENTS; ADVISING U.S. CLIENTS NOT TO MAINTAIN ACCOUNT RECORDS; AND MAINTAINING INEFFECTIVE POLICIES, TRAINING, AND AUDITS THAT WERE UNSUCCESSFUL IN PREVENTING EMPLOYEES' ILLEGAL CONDUCT OR REMEDYING MISCONDUCT. IN THE CONSENT ORDER, CSAG AGREED TO PAY A CIVIL PENALTY OF $715,000,000; ENGAGE AN INDEPENDENT MONITOR TO CONDUCT A REVIEW OF THE BANK'S POLICIES AND PROCEDURES; MAINTAIN AND MAKE AVAILABLE RELEVANT RECORDS; AND TERMINATE THREE EMPLOYEES. AMENDED 14D(1) 14D(2) 14D(4) Applicant CREDIT SUISSE AG/ N Other Federal THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM Civil and Administrative Penalty(ies)/Fine(s) Cease and Desist 05-19-2014 Exact 14-009-B-FB; 14-009-CMP-FB CREDIT SUISSE AG No Product THE ALLEGATIONS ARE RELATED TO THE OPERATION BY CREDIT SUISSE AG ("CSAG") OF A REPRESENTATIVE OFFICE IN NEW YORK CITY WHICH ENGAGED IN INVESTMENT ADVISORY ACTIVITIES THAT WERE NOT PERMISSIBLE FOR A REPRESENTATIVE OFFICE TO CONDUCT UNDER PROVISIONS OF THE IBA AND REGULATION K OF THE BOARD OF GOVERNORS; AND WHICH FACILITATED ACTIVITIES OF CSAG REPRESENTATIVES IN OPENING FINANCIAL ACCOUNTS FOR U.S. TAXPAYERS THAT, IN CERTAIN INSTANCES, WERE NOT REPORTED TO THE U.S. GOVERNMENT. THE ALLEGATIONS ALSO CONCERN THE PROVISION OF INFORMATION TO THE FEDERAL RESERVE BANK OF NEW YORK THAT CONCEALED RELEVANT INFORMATION ABOUT THE OPERATIONS OF THE REPRESENTATIVE OFFICE. NONE OF THE ALLEGED CONDUCT IS ATTRIBUTABLE TO THE REGISTRANT OR ANY CSAG AFFILIATE THAT IS REGISTERED WITH THE COMMISSION AS AN INVESTMENT ADVISER OR BROKER-DEALER. Final Order 05-19-2014 Exact Monetary/Fine Cease and Desist/ Injunction 100000000.00 CSAG SHALL PAY A CIVIL MONETARY PENALTY TO THE DEPARTMENT IN THE AMOUNT OF $100,000,000, PAID AT THE EXECUTION OF THE ORDER ON MAY 19, 2014. ON MAY 19, 2014, CSAG AGREED TO THE ISSUANCE OF A CEASE AND DESIST ORDER AND CIVIL MONEY PENALTY ASSESSMENT ISSUED BY THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM, AGREEING TO PAYMENT OF A CIVIL MONEY PENALTY IN THE AMOUNT OF $100,000,000; A LIMITATION ON REPRESENTATIVE OFFICE ACTIVITIES; ACCOUNTABILITY FOR EMPLOYEES INVOLVED IN MISCONDUCT; AND ADOPTION OF A WRITTEN MANAGEMENT OVERSIGHT PLAN. THE AGREEMENT RESOLVED CLAIMS THAT CSAG OPERATED A REPRESENTATIVE OFFICE IN NEW YORK CITY - CLOSED IN 2009 - THAT: ENGAGED IN IMPERMISSIBLE ADVISORY ACTIVITIES AND FACILITATED ACTIVITIES OF CSAG EMPLOYEES IN OPENING UNREPORTED FINANCIAL ACCOUNTS FOR U.S. TAXPAYERS; AND CONCEALED RELEVANT INFORMATION ABOUT THE OPERATIONS OF THE OFFICE FROM THE FEDERAL RESERVE BANK OF NEW YORK. AMENDED 14D(1) 14D(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N Foreign FINANCIAL CONDUCT AUTHORITY Civil and Administrative Penalty(ies)/Fine(s) 06-16-2014 Exact N/A Other CAPITAL PROTECTED STRUCTURED PRODUCT THE FINANCIAL CONDUCT AUTHORITY ALLEGED INADEQUACIES IN CERTAIN FINANCIAL PROMOTIONS FOR CAPITAL PROTECTED STRUCTURED DEPOSIT PRODUCTS SOLD TO UK RETAIL CUSTOMERS BETWEEN NOVEMBER 2009 AND JUNE 2012. Final Settled 06-16-2014 Exact Monetary/Fine 2398100.00 CONDUCT A PAST BUSINESS REVIEW UNDER WHICH AFFECTED RETAIL CUSTOMERS WILL BE ELIGIBLE TO CLAIM COMPENSATION. PURSUANT TO A SETTLEMENT AGREEMENT, THE UK FINANCIAL CONDUCT AUTHORITY IMPOSED ON CREDIT SUISSE INTERNATIONAL ("CSI") A FINANCIAL PENALTY OF GBP 2,398,100. CSI IS ALSO REQUIRED TO CONDUCT A PAST BUSINESS REVIEW (IN CONJUNCTION WITH DISTRIBUTORS OF THE PRODUCTS) UNDER WHICH AFFECTED RETAIL CUSTOMERS WILL BE ELIGIBLE TO CLAIM COMPENSATION. THE CSI DOES NOT BELIEVE THAT THE LIKELY COSTS OF THE PAST BUSINESS REVIEW WILL MATERIALLY IMPACT ITS FINANCIAL POSITION. SEE ABOVE AMENDED 14D(2) One or more control affiliate(s) Firm N CREDIT SUISSE EQUITIES (AUSTRALIA) N N Foreign AUSTRALIAN SECURITIES AND INVESTMENTS COMMISSION (ASIC) Civil and Administrative Penalty(ies)/Fine(s) 02-18-2015 Exact MDP03/16 Equity Listed (Common & Preferred Stock) CREDIT SUISSE EQUITIES (AUSTRALIA) WAS FINED FOR A "FAT-FINGER" TYPE ERROR WHICH LED TO THE PRICE OF TWO LITTLE-TRADED STOCKS INCREASING BY 42% AND 19 % RESPECTIVELY. THIS WAS AN ISOLATED INCIDENT WITH ONE SHARE TRADED IN EACH SECURITY. CS DID NOT DERIVE ANY BENEFIT FROM THE TRANSACTIONS AND CS HAS FULLY COOPERATED WITH ASIC AND TAKEN THE NECESSARY STEPS TO PREVENT REOCCURRENCE OF THE BREACH. Final Settled 05-20-2016 Exact Monetary/Fine 74000.00 THE FIRM WAS FINED $74,000.00 (AUSTRALIAN DOLLARS.) SEE ABOVE AMENDED 14D(2) Applicant CREDIT SUISSE AG/ N Foreign MONETARY AUTHORITY OF SINGAPORE Civil and Administrative Penalty(ies)/Fine(s) 09-03-2016 Exact N/A No Product BASED ON AN ON-SITE AML INSPECTION OF CREDIT SUISSE AG SINGAPORE BRANCH ("CSSB"), THE MONETARY AUTHORITY OF SINGAPORE ("MAS") IDENTIFIED CERTAIN AML CONTROL WEAKNESSES THAT IT CONCLUDED AMOUNTED TO SEVEN CATEGORIES OF BREACHES OF SINGAPORE'S PRINCIPAL AML REGULATION, MAS NOTICE 626. THESE FINDINGS PERTAIN TO WEAKNESSES IN AML CONTROLS GENERALLY AND ARE NOT LIMITED TO THE MANAGEMENT AND MONITORING OF ANY PARTICULAR ACCOUNTS. Final Decision 05-30-2017 Exact Monetary/Fine Censure 1700000.00 SGD 1.7 MLN FINE PAID IN ONE LUMP SUM TO MAS (PAID ON 31 MAY 2017) AND THE APPOINTMENT OF AN INDEPENDENT PARTY TO ASSESS AND REPORT TO MAS ON THE EFFECTIVENESS OF REMEDIAL MEASURES ENACTED BY THE BANK. THE MAS CONCLUDED THAT CSSB BREACHED MAS NOTICE 626 IN RELATION TO ACCOUNTS THAT WERE THE SUBJECT OF THE MAS'S INSPECTION. CSSB HAS MADE A COMMITMENT TO IMPLEMENT SPECIFIC MEASURES TO STRENGTHEN ITS AML CONTROLS AND PROCESSES (IN ADDITION TO RECENT ENHANCEMENTS WHICH HAVE ALREADY BEEN MADE OVER THE PAST 12 MONTHS). THE MAS HAS FINED CSSB S$1.7M FOR THE IDENTIFIED BREACHES OF MAS NOTICE 626 FOLLOWING THE AML INSPECTION. THE MAS HAS ATTRIBUTED S$700K OF THIS FINE TO BREACHES OF AML REQUIREMENTS AND SUSPICIOUS TRANSACTIONS THAT MAY BE CONNECTED TO 1MDB AND IT IS THIS S$700K FINE THAT WAS PUBLICLY ANNOUNCED. HOWEVER, THE MAS DID NOT DETECT PERVASIVE CONTROL WEAKNESSES WITHIN CS. THE FINE WILL NOT AFFECT CSSB'S OPERATIONS AND THE BANK DOES NOT EXPECT ANY FURTHER ENFORCEMENT ACTION BY MAS ON THE MATTER. AMENDED 14D(1) 14D(2) 14D(4) Applicant CREDIT SUISSE AG/ N State THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES Civil and Administrative Penalty(ies)/Fine(s) 11-13-2017 Exact NOT APPLICABLE Other FOREIGN EXCHANGE THE DFS'S ALLEGATIONS RELATE TO CREDIT SUISSE'S FOREIGN EXCHANGE(FX) VOICE AND ELECTRONIC TRADING BUSINESSES, INCLUDING THAT (1)CREDIT SUISSE FX VOICE TRADERS MAY HAVE MANIPULATED FX RATES BY ENGAGING IN COORDINATED TRADING OR SHARING CONFIDENTIAL INFORMATION, (2) CREDIT SUISSE INAPPROPRIATELY USED AND DISCLOSED A TRADING FEATURE KNOWN AS "LAST LOOK," AND (3) CREDIT SUISSE PROGRAMMED AN ALGORITHM THAT MAY HAVE FRONT RUN CLIENT ORDERS. Final Consent 11-13-2017 Exact Monetary/Fine 135000000.00 CREDIT SUISSE WILL SUBMIT TO THE DFS WRITTEN REMEDIATION PLANS AND PROGRAMS REGARDING ITS FX BUSINESS. CREDIT SUISSE WILL ALSO ENGAGE A THIRD-PARTY CONSULTANT TO REVIEW CREDIT SUISSE'S REMEDIAL EFFORTS WITH REGARD TO ITS FX BUSINESS. CREDIT SUISSE WAS FINE $135,000,000.00, AND WILL SUBMIT TO THE DFS WRITTEN REMEDIATION PLANS AND PROGRAMS REGARDING ITS FX BUSINESS. CREDIT SUISSE WILL ALSO ENGAGE A THIRD-PARTY CONSULTANT TO REVIEW CS'S REMEDIAL EFFORTS WITH REGARD TO ITS FX BUSINESS. SEE ABOVE AMENDED 14D(2) One or more control affiliate(s) Firm N CREDIT SUISSE EQUITIES (AUSTRALIA) LIMITED N N Foreign AUSTRALIA SECURITIES EXCHANGE Civil and Administrative Penalty(ies)/Fine(s) 01-30-2017 Exact N/A Equity Listed (Common & Preferred Stock) THE ASX CHIEF COMPLIANCE OFFICER, HAS DETERMINED THAT CREDIT SUISSE EQUITIES (AUSTRALIA) LIMITED ("CSEAL") DID NOT COMPLY WITH ITS OBLIGATIONS UNDER: 1) ASX SETTLEMENT OPERATING RULE ("ASX SR") 4.18.1, TO HAVE ADEQUATE RESOURCES AND PROCESSES TO COMPLY WITH ITS OBLIGATIONS AS A PARTICIPANT; AND 2) ASX SR 4.7.1(B), TO MEET THE TECHNICAL AND PERFORMANCE REQUIREMENTS APPLICABLE TO PARTICIPANTS BY FAILING TO HAVE SUCH SETTLEMENT AND RECORDING SYSTEMS AS ARE NECESSARY FOR ITS OPERATIONS. Final Decision 11-27-2017 Exact Monetary/Fine 30000.00 CREDIT SUISSE WAS FINED $30,000 SEE ABOVE AMENDED 14D(2) Applicant CREDIT SUISSE AG/ N Foreign AUSTRALIA SECURITIES EXCHANGE Civil and Administrative Penalty(ies)/Fine(s) 06-11-2017 Exact N/A Other ASX CLEAR (FUTURES) MATTER 1:THE CCO HAS DETERMINED THAT CREDIT SUISSE AG, SYDNEY BRANCH ("CS-AG") DID NOT COMPLY WITH ASX CLEAR (FUTURES) OPERATING RULE ("ASX CFR") 46.5 AND RULE 46.5 OF THE ASX CLEAR (FUTURES) PROCEDURES, DETERMINATIONS AND PRACTICE NOTES (THE "DIRECTION"), BY FAILING TO CLOSE OUT BACK-TO-BACK OPEN POSITIONS IN ACCORDANCE WITH THE DIRECTION, RESULTING IN ITS REPORTED DAILY BENEFICIAL OWNERSHIP REPORT ("DBOR") DAY 1 POSITIONS BEING INACCURATE IN CONTRAVENTION OF ASX 24 OPERATING RULE 6704 (EACH A "CONTRAVENTION"). MATTER 2: CS AG CONDUCTED A REVIEW OF THE PRE-SUBMISSION RECONCILIATION CHECK FOR DBOR REPORTING. THE REVIEW IDENTIFIED THAT THE SAME OMNIBUS ACCOUNT SYSTEM SHOWED A POSITION OF 1 LONG AND 1 SHORT IN PARTICULAR CONTRACT FOR A RELATED ENTITY, WHILE IN CS-AG'S SYSTEM THESE TWO POSITIONS WERE NETTED TO ZERO. CS-AG WENT ON TO IDENTIFY FOUR AFFILIATED ENTITIES. Final Decision 08-24-2017 Exact Monetary/Fine 50000.00 CREDIT SUISSE AG, SYDNEY BRANCH WAS FINE $50,000. SEE ABOVE AMENDED 14D(2) Applicant and one or more control affiliate(s) CREDIT SUISSE AG/ N Foreign SECURITIES AND FUTURES COMMISSION OF HONG KONG Reprimand 02-08-2018 Exact N/A Other AS DESCRIBED MORE FULLY IN RESPONSE TO QUESTION 7 BELOW, THIS MATTER WAS A COMPENDIOUS RESOLUTION OF A NUMBER OF HISTORICAL, LEGACY INTERNAL CONTROL ISSUES IN THE HONG KONG EQUITIES AND PRIVATE BANKING BUSINESSES. ON 2/8/2018, HONG KONG SFC ANNOUNCED IT HAD REACHED RESOLUTION WITH 3 HONG KONG CS ENTITIES TO RESOLVE REGULATORY BREACHES AND INTERNAL CONTROL FAILURES RELATING TO CS'S HONG KONG-BASED EQUITIES AND PRIVATE BANKING BUSINESSES. RESOLUTION RELATES TO THE FOLLOWING: 1) SHORT POSITION REPORTING 2) SEGREGATION OF CLIENT SECURITIES 3) REGULATORY REPORTING OF DIRECT BUSINESS TRANSACTIONS 4) SHORT SELLING ACTIVITIES 5) ENSURING SUITABILITY OF RISK MISMATCH TRANSACTIONS FOR PRIVATE BANKING CLIENTS 6) ELECTRONIC TRADING AND 7) DISCLOSURE IN CONTRACT NOTES AND CHARGING OF COMMISSIONS TO PRIVATE BANKING CLIENTS. SFC AND CS JOINTLY ENGAGED INDEPENDENT REVIEWERS TO REVIEW CS'S INTERNAL SYSTEMS AND CONTROLS. IN REACHING RESOLUTION, SFC TOOK INTO ACCOUNT THAT CS HAD SELF-REPORTED ITS BREACHES AND INVOLVED SENIOR MANAGEMENT AT EARLY STAGES TO ADDRESS SFC CONCERNS, THAT CS HAD FULLY COOPERATED IN SFC INQUIRIES AND IN RESOLVING SFC REGULATORY CONCERNS, AND HAD TAKEN REMEDIAL ACTIONS TO STRENGTHEN INTERNA Final Decision 02-08-2018 Exact Monetary/Fine 5025575.00 CREDIT SUISSE (HONG KONG) LIMITED WAS FINED $2,301,790.00, CREDIT SUISSE SECURITIES (HONG KONG) LIMITED WAS FINED $1,150,895.00, AND CREDIT SUISSE AG, HONG KONG BRANCH WAS FINED $1,572,890.00 THE FINE WAS PAID ON FEBRUARY 8, 2018. Firm N CREDIT SUISSE (HONG KONG) LIMITED N N Foreign SECURITIES AND FUTURES COMMISSION OF HONG KONG Reprimand 02-08-2018 Exact N/A Other AS DESCRIBED MORE FULLY IN RESPONSE TO QUESTION 7 BELOW, THIS MATTER WAS A COMPENDIOUS RESOLUTION OF A NUMBER OF HISTORICAL, LEGACY INTERNAL CONTROL ISSUES IN THE HONG KONG EQUITIES AND PRIVATE BANKING BUSINESSES. ON 2/8/2018, HONG KONG SFC ANNOUNCED IT HAD REACHED RESOLUTION WITH 3 HONG KONG CS ENTITIES TO RESOLVE REGULATORY BREACHES AND INTERNAL CONTROL FAILURES RELATING TO CS'S HONG KONG-BASED EQUITIES AND PRIVATE BANKING BUSINESSES. RESOLUTION RELATES TO THE FOLLOWING: 1) SHORT POSITION REPORTING 2) SEGREGATION OF CLIENT SECURITIES 3) REGULATORY REPORTING OF DIRECT BUSINESS TRANSACTIONS 4) SHORT SELLING ACTIVITIES 5) ENSURING SUITABILITY OF RISK MISMATCH TRANSACTIONS FOR PRIVATE BANKING CLIENTS 6) ELECTRONIC TRADING AND 7) DISCLOSURE IN CONTRACT NOTES AND CHARGING OF COMMISSIONS TO PRIVATE BANKING CLIENTS. SFC AND CS JOINTLY ENGAGED INDEPENDENT REVIEWERS TO REVIEW CS'S INTERNAL SYSTEMS AND CONTROLS. IN REACHING RESOLUTION, SFC TOOK INTO ACCOUNT THAT CS HAD SELF-REPORTED ITS BREACHES AND INVOLVED SENIOR MANAGEMENT AT EARLY STAGES TO ADDRESS SFC CONCERNS, THAT CS HAD FULLY COOPERATED IN SFC INQUIRIES AND IN RESOLVING SFC REGULATORY CONCERNS, AND HAD TAKEN REMEDIAL ACTIONS TO STRENGTHEN INTERNA Final Decision 02-08-2018 Exact Monetary/Fine 5025575.00 CREDIT SUISSE (HONG KONG) LIMITED WAS FINED $2,301,790.00, CREDIT SUISSE SECURITIES (HONG KONG) LIMITED WAS FINED $1,150,895.00, AND CREDIT SUISSE AG, HONG KONG BRANCH WAS FINED $1,572,890.00 THE FINE WAS PAID ON FEBRUARY 8, 2018. Firm N CREDIT SUISSE SECURITIES (HONG KONG) LIMITED N N Foreign SECURITIES AND FUTURES COMMISSION OF HONG KONG Reprimand 02-08-2018 Exact N/A Other AS DESCRIBED MORE FULLY IN RESPONSE TO QUESTION 7 BELOW, THIS MATTER WAS A COMPENDIOUS RESOLUTION OF A NUMBER OF HISTORICAL, LEGACY INTERNAL CONTROL ISSUES IN THE HONG KONG EQUITIES AND PRIVATE BANKING BUSINESSES. ON 2/8/2018, HONG KONG SFC ANNOUNCED IT HAD REACHED RESOLUTION WITH 3 HONG KONG CS ENTITIES TO RESOLVE REGULATORY BREACHES AND INTERNAL CONTROL FAILURES RELATING TO CS'S HONG KONG-BASED EQUITIES AND PRIVATE BANKING BUSINESSES. RESOLUTION RELATES TO THE FOLLOWING: 1) SHORT POSITION REPORTING 2) SEGREGATION OF CLIENT SECURITIES 3) REGULATORY REPORTING OF DIRECT BUSINESS TRANSACTIONS 4) SHORT SELLING ACTIVITIES 5) ENSURING SUITABILITY OF RISK MISMATCH TRANSACTIONS FOR PRIVATE BANKING CLIENTS 6) ELECTRONIC TRADING AND 7) DISCLOSURE IN CONTRACT NOTES AND CHARGING OF COMMISSIONS TO PRIVATE BANKING CLIENTS. SFC AND CS JOINTLY ENGAGED INDEPENDENT REVIEWERS TO REVIEW CS'S INTERNAL SYSTEMS AND CONTROLS. IN REACHING RESOLUTION, SFC TOOK INTO ACCOUNT THAT CS HAD SELF-REPORTED ITS BREACHES AND INVOLVED SENIOR MANAGEMENT AT EARLY STAGES TO ADDRESS SFC CONCERNS, THAT CS HAD FULLY COOPERATED IN SFC INQUIRIES AND IN RESOLVING SFC REGULATORY CONCERNS, AND HAD TAKEN REMEDIAL ACTIONS TO STRENGTHEN INTERNA Final Decision 02-08-2018 Exact Monetary/Fine 5025575.00 CREDIT SUISSE (HONG KONG) LIMITED WAS FINED $2,301,790.00, CREDIT SUISSE SECURITIES (HONG KONG) LIMITED WAS FINED $1,150,895.00, AND CREDIT SUISSE AG, HONG KONG BRANCH WAS FINED $1,572,890.00 THE FINE WAS PAID ON FEBRUARY 8, 2018. AMENDED 14D(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N Foreign ICE FUTURES EUROPE Other WRITTEN WARNING 10-18-2018 Exact N/A Other FUTURES ICE FUTURES EUROPE CONDUCTED AN INVESTIGATION INTO THE CLOSING OF A SPOT MONTH POSITION BY CSI WHICH VIOLATED ICE RULE F8.1(C), WHICH FORBIDS POSITION TRANSFERS WHICH HAVE THE EFFECT OF OFF-SETTING (CLOSING-OUT) EXISTING OPEN POSITIONS IN THE SPOT MONTH OF THE CONTRACT. THE WARNING ACKNOWLEDGES THAT ALTHOUGH CSI DID TAKE VARIOUS ISSUES INTO CONSIDERATIONS PRIOR TO THE POSITION TRANSFER IT FAILED TO CONSIDER THE EFFECT OF AUTO NETTING. Final Decision 11-21-2018 Exact SEE BELOW WRITTEN WARNING WHICH ACKNOWLEDGES THAT ALTHOUGH CSI DID TAKE VARIOUS ISSUES INTO CONSIDERATIONS PRIOR TO THE POSITION TRANSFER IT FAILED TO CONSIDER THE EFFECT OF AUTO NETTING. THE WARNING MAY BE TAKEN INTO CONSIDERATION SHOULD ANY FURTHER INCIDENTS OF A SIMILAR NATURE ARISE AMENDED 14D(2) One or more control affiliate(s) Firm N CREDIT SUISSE(SINGAPORE) LIMITED N N Foreign KOREAN FINANCIAL SERVICES COMMISSION (FSC) Civil and Administrative Penalty(ies)/Fine(s) 02-24-2021 Exact N/A Equity Listed (Common & Preferred Stock) THE KOREAN FINANCIAL SERVICES COMMISSION (FSC) IMPOSED AN ADMINISTRATIVE FINE UPON CREDIT SUISSE (SINGAPORE) LIMITED (CSSL) IN CONNECTION WITH THREE POTENTIAL UNCOVERED SHORT SALES OF KOREAN-LISTED SECURITIES DATING FROM JANUARY AND JUNE 2018. THE POTENTIAL UNCOVERED SHORT SALES WERE ISOLATED AND UNINTENTIONAL IN NATURE. IN EACH CASE, CSSL WAS ABLE TO SECURE THE INVENTORY NECESSARY TO ENSURE THERE WERE NO SETTLEMENT FAILURES. Final Decision 02-24-2021 Exact Monetary/Fine 87000.00 THE KOREAN FINANCIAL SERVICES COMMISSION IMPOSED A FINE OF KRW 97,200,000, APPROXIMATELY $87,000 USD. AFTER EARLY PAYMENT DISCOUNT FROM FSC, CSSL ULTIMATELY PAID KRW 77,760,000, APPROXIMATELY $68,600 USD. WE UNDERSTAND THAT CSSL'S NAME WILL BE REDACTED FROM THE PUBLIC RECORD OF THE HEARINGS AND ADMINISTRATIVE SANCTION. AMENDED 14E(2) One or more control affiliate(s) 000007973 Firm Y SWISS AMERICAN SECURITIES INC. N Y AMENDED 14E(2) One or more control affiliate(s) Firm N FIRST BOSTON FUTURES INC. N N SRO THE CHICAGO MERCANTILE EXCHANGE Civil and Administrative Penalty(ies)/Fine(s) 02-07-1989 Exact 89-CH-8906 Futures - Financial ALLEGED LATE DELIVERY OF CURRENCIES UNDERLYING CERTAIN FUTURES CONTRACTS. Final Decision 03-27-1989 Exact Monetary/Fine 1000.00 FIRST BOSTON FUTURES INC. WAS FINED $1000.00 BY THE CHICAGO MERCANTILE EXCHANGE SEE ABOVE AMENDED 14E(2) One or more control affiliate(s) 000007973 Firm Y SWISS AMERICAN SECURITIES INC. N Y AMENDED 14E(2) One or more control affiliate(s) Firm N CREDIT SUISSE FIRST BOSTON (EUROPE) LIMITED N N SRO CHICAGO BOARD OF TRADE FLOOR GOVERNORS COMMITTEE ("COMMITTEE") Other SEE BELOW 03-26-2002 Exact 2002-INV-1B CREDIT SUISSE FIRST BOSTON (EUROPE) LIMITED No Product WITHOUT ADMITTING OR DENYING ANY VIOLATION, CSFB CONSENTED TO THE ENTRY OF A CONCLUSION THAT THE FLOOR GOVERNORS COMMITTEE HAD REASON TO BELIEVE THAT CSFB VIOLATED REGULATION 9B.16, IN THAT ORDERS ARISING FROM PRE-EXECUTION DISCUSSIONS FACILITATED BY CSFB'S FOREIGN AFFILIATE WERE NOT ENTERED IN ACCORDANCE WITH PRESCRIBED REQUIREMENTS; AND REGULATION 9B.16A, IN THAT CSFB'S FOREIGN AFFILIATE KNOWINGLY ASSUMED THE OPPOSITE SIDE OF ORDERS ENTERED ON BEHALF OF ITS OWN ACCOUNT. Final Settled 05-16-2002 Exact Monetary/Fine 15000.00 A FINE OF $15,000. SEE ABOVE AMENDED 14E(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N SRO ICE CLEAR CREDIT LLC Other SEE BELOW 07-23-2015 Exact 2015-404B-028 Other INDEX END-OF-DAY PRICES ICE CLEAR CREDIT DETERMINED THAT CREDIT SUISSE INTERNATIONAL FAILED TO SUBMIT 252 SINGLE NAME END-OF-DAY PRICES AND 32 INDEX END-OF-DAY PRICES ON JUNE 15, 2015, IN VIOLATION OF ICE CLEAR CREDIT RULE 404(B). Final Decision 08-11-2015 Exact Monetary/Fine 102000.00 THE FIRM IS FINED $102,000.00 SEE ABOVE AMENDED 14E(2) Applicant CREDIT SUISSE AG/ N SRO CBOE FUTURES EXCHANGE Civil and Administrative Penalty(ies)/Fine(s) 10-30-2013 Exact CFE 15-0011 Futures - Financial ON SEPTEMBER 30, 2015, THE BUSINESS CONDUCT COMMITTEE FOR THE CBOE FUTURES EXCHANGE ACCEPTED A LETTER OF CONSENT FROM CREDIT SUISSE AG RELATING TO CERTAIN ALLEGED TECHNICAL VIOLATIONS OF CFE RULE 412B (REPORTABLE POSITIONS). THE SETTLEMENT AGREEMENT, WHICH CREDIT SUISSE AG ENTERED INTO ON A WITHOUT-ADMITTING-OR-DENYING BASIS, (A) INCLUDES FINDINGS THAT ON VARIOUS OCCASIONS FROM OCTOBER 2013 THROUGH MAY 2015, CREDIT SUISSE AG FAILED TO FILE LARGE TRADER REPORTABLE POSITIONS TO THE CBOE FUTURES EXCHANGE ELECTRONICALLY, VIA THE SECURITIES INDUSTRY AUTOMATION CORPORATION ("SIAC") IN VIOLATION OF CFE RULE 412B; AND (B) REFLECTS CREDIT SUISSE AG'S AGREEMENT TO PAY A $15,000 FINE. Final Decision & Order of Offer of Settlement 09-30-2015 Exact Monetary/Fine 15000.00 CREDIT SUISSE AG WAS FINED $15,000.00 CREDIT SUISSE AG CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS, TO A SETTLEMENT WITH CBOE FUTURES EXCHANGE (CFE) OF POTENTIAL CHARGES ARISING OUT OF ALLEGED TECHNICAL VIOLATIONS OF CFE RULE 412B (REPORTABLE POSITIONS) FOR THE PERIOD OCTOBER 2013 THROUGH MAY 2015. AS PART OF THE SETTLEMENT, CREDIT SUISSE AG AGREED TO PAY A $15,000 FINE. AMENDED 14E(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N SRO ICE CLEAR CREDIT LLC Civil and Administrative Penalty(ies)/Fine(s) 01-06-2016 Exact 2015-404B-048 Derivative(s) Other CREDIT DEFAULT SWAP ICE CLEAR CREDIT LLC DETERMINED THAT CREDIT SUISSE INTERNATIONAL FAILED TO SUBMIT FIFTY-THREE (53) INDEX END OF DAY PRICES ON DECEMBER 11, 2015, IN VIOLATION OF RULE 404B. Final Decision 02-01-2016 Exact Monetary/Fine 53000.00 THE FIRM WAS FINED $53,000.00 SEE ABOVE AMENDED 14E(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N SRO ICE CLEAR CREDIT LLC Civil and Administrative Penalty(ies)/Fine(s) 06-02-2016 Exact 2016-404B-017 Derivative(s) ICE CLEAR CREDIT DETERMINED THAT CREDIT SUISSE INTERNATIONAL FAILED TO SUBMIT 2 INDEX END OF DAY PRICES DURING MAY 2016, IN VIOLATION OF ICE CLEAR CREDIT RULE 404(B). Final Decision 06-20-2016 Exact Monetary/Fine 2000.00 THE FIRM WAS FINED $2,000 SEE ABOVE AMENDED 14E(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N SRO CHICAGO MERCANTILE EXCHANGE Civil and Administrative Penalty(ies)/Fine(s) 07-22-2014 Exact 15-0151-BC Futures - Financial PURSUANT TO A SETTLEMENT AGREEMENT IN WHICH CREDIT SUISSE INTERNATIONAL ("CSI") NEITHER ADMITTED NOR DENIED THE RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, THE CME FINDS THAT ON JUNE 23, 2014, CSI ENTERED INTO AN EXCHANGE FOR RELATED POSITION ("EFRP") TRANSACTION WHEREBY IT BOUGHT E-MINI S&P 500 FUTURES AND SOLD SPDR S&P 500 EXCHANGE TRADED FUND ("SPY") CONTRACTS. CONTEMPORANEOUS WITH THE EXECUTION OF THE EFRP, CSI BOUGHT THE SPY CONTRACTS AND SOLD CBOE SEPTEMBER 2014 1950 STRIKE S&P 500 INDEX ("SPX") OPTION COMBOS WITH THE SAME COUNTERPARTY. THE SPY CONTRACTS, USED AT THE RELATED POSITION IN THE EFRP TRANSACTION, WERE IMMEDIATELY OFFSET. FURTHER, THE EXECUTIONS OF THE TWO TRANSACTIONS INVOLVING THE SPY CONTRACTS WERE NOT INDEPENDENT TRANSACTIONS EXPOSED TO MARKET RISK AND THEREFORE RESULTED IN A "TRANSITORY" EFRP. MOREOVER, THE CME CONCLUDED THAT THIS WAS NOT A BONA FIDE EFRP AND THAT CSI VIOLATED CME RULE 538.A. Final Settled 06-21-2016 Exact Monetary/Fine 15000.00 THE FIRM WAS FINED $15,000 SEE ABOVE AMENDED 14E(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N SRO BLOOMBERG SEF LLC Civil and Administrative Penalty(ies)/Fine(s) 03-23-2016 Exact N/A Derivative(s) Other CREDIT DEFAULT SWAP CREDIT SUISSE INTERNATIONAL HAS VIOLATED BSEF RULE 516 BY FAILING TO NOTIFY AND RECEIVE APPROVAL FROM BSEF PRIOR TO ENTERING INTO OFFSETTING AND CORRECTING TRADES. Final Decision 06-27-2016 Exact Monetary/Fine 1250.00 CREDIT SUISSE INTERNATIONAL WAS FINED $1250.00 SEE ABOVE AMENDED 14E(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N SRO ICE CLEAR CREDIT LLC Civil and Administrative Penalty(ies)/Fine(s) 08-01-2016 Exact ICE CLEAR CREDIT MATTER NO. 2016-404B-027 Derivative(s) ICE CLEAR CREDIT LLC ALLEGED THAT CREDIT SUISSE INTERNATIONAL("CSI") FAILED TO SUBMIT ONE INDEX END OF DAY PRICE IN ACCORDANCE WITH THE ICE CLEAR CREDIT RULES AND PROCEDURES. Final Decision 08-23-2016 Exact Monetary/Fine 1000.00 ON AUGUST 23, 2016, ICE CLEAR CREDIT ASSESSED A $1,000 PENALTY AGAINST CSI TO BE BILLED IN A MONTHLY CLEARING FEE INVOICE. SEE ABOVE AMENDED 14E(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N SRO BLOOMBERG SEF, LLC Civil and Administrative Penalty(ies)/Fine(s) 01-30-2017 Exact N/A Futures - Financial BLOOMBERG SEF (BSEF) HAS CONCLUDED THAT CSI VIOLATED BSEF RULE 516.A, "TRADE CANCELLATION, CORRECTION, OFFSET AND ADJUSTMENT" BY INCLUDING TICKETING COSTS IN THE PRICE OF THE OFFSETTING TRADE AND FAILING TO MATCH ALL OFFSETTING TERMS WITH THE CORRESPONDING ERROR TRADE. BSEF RULE 516.A(G) REQUIRES THAT "OFFSETTING TERMS" MATCH ALL OF THE TERMS OF THE CORRESPONDING ERROR TRADE ASIDE FROM THE DIRECTION OF THE TRADE. SPECIFICALLY, CSI AND WESTERN ASSET MANAGEMENT COMPANY ("WESTERN ASSET") AGREED TO EXECUTE OFFSETTING AND CORRECTING TRADES TO CORRECT AN INITIAL TRANSACTION THAT WAS EXECUTED AT THE WRONG PRICE. THE PARTIES RECEIVED THE PRIOR APPROVAL OF BSEF TO OFFSET AND CORRECT THE ERROR TRADE. HOWEVER, THE CORRECTION TRADE WAS EXECUTED AT A PRICE THAT WAS ADJUSTED TO INCLUDE THE TICKET COSTS OF THE OFFSETTING AND CORRECTION TRADES, IN VIOLATION OFBSEF RULE 516.A(G). CSI WAS FINED $1,750 FOR THIS VIOLATION, AS THIS WAS THE THIRD VIOLATION OF BSEF RULE 516 IN 2016. Final Decision 01-30-2017 Exact Monetary/Fine 1750.00 THE FIRM WAS FINED $1750.00 SEE ABOVE AMENDED 14E(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N SRO ICE CLEAR CREDIT LLC Civil and Administrative Penalty(ies)/Fine(s) 07-07-2017 Exact ICE CLEAR CREDIT MATTER NO. 2017-404B-014 Derivative(s) ICE CLEAR CREDIT LLC ALLEGED THAT CSI FAILED TO SUBMIT 72 SINGLE NAME AND 1 INDEX END-OF-DAY PRICES IN ACCORDANCE WITH THE ICE CLEAR CREDIT RULES AND PROCEDURES. Final Decision 07-27-2017 Exact Monetary/Fine 61000.00 THE FIRM WAS FINED. ON JULY 27, 2017, ICE CLEAR CREDIT ASSESSED A $61,000 PENALTY AGAINST CSI TO BE BILLED IN A MONTHLY CLEARING FEE INVOICE. THE INVOICE IS EXPECTED TO BE ISSUED ON SEPTEMBER 5, 2017 AND DUE FOR COLLECTION ON SEPTEMBER 21, 2017. AMENDED 14E(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N SRO NEW YORK MERCANTILE EXCHANGE Civil and Administrative Penalty(ies)/Fine(s) 05-30-2018 Exact NYMEX 18-0956-BC Other FUTURES ON THE MORNING OF MAY 30, 2018, THE EXCHANGE NOTIFIED CSI THAT IT HELD A FUTURES-EQUIVALENT SHORT POSITION OF 239 NYMEX JUNE 2018 PALLADIUM FUTURE ("JUNE18 PA") CONTRACTS AND THE POSITION OF 50 JUN18 PA WOULD BE GOING INTO EFFECT AT THE CLOSE OF BUSINESS ON MAY 30, 2018. DESPITE SUCH NOTICE, CSI DID NOT REDUCE ITS POSITION BELOW THE APPLICABLE LIMIT BY THE CLOSE OF BUSINESS ON MAY 30, 2018 AND THEREFORE EXCEEDED THE POSITION LIMIT IN THE JUN18 PA CONTRACT BY 189 CONTRACTS OR 378%. Final Decision 01-31-2019 Exact Monetary/Fine 95000.00 CSI ORDERED TO PAY A FINE TO THE EXCHANGE IN THE AMOUNT OF $95,000.00. CSI NEITHER ADMITS NOR DENIES THE FINDINGS OR RULE VIOLATION UPON WHICH THE PENALTY IS BASED. THE BCC PANEL FINDS THAT CSI VIOLATED EXCHANGE RULE 562 AND ORDERED CSI TO PAY A FINE TO THE EXCHANGE IN THE AMOUNT OF $95,000. AMENDED 14E(2) One or more control affiliate(s) Firm N CREDIT SUISSE INTERNATIONAL N N SRO ICE FUTURES U.S., INC. Other MONETARY FINE 02-27-2020 Exact 2018-37 Other MSCI EMERGING MARKETS INDEX FUTURE CREDIT SUISSE INTERNATIONAL ("CSI") AND CREDIT SUISSE SECURITIES (EUROPE) LIMITED ("CSSEL") AGREED ON A WITHOUT-ADMITTING-OR DENYING BASIS TO RESOLVE THE MATTER. ICE FUTURES U.S. ("IFUS") EXCHANGE DETERMINED THAT CSSEL AND CSI MAY HAVE VIOLATED EXCHANGE RULE 4.02(C) IN ONE INSTANCE BY EXECUTING A BLOCK TRADE BETWEEN EACH OTHER THAT RESULTED IN A WASH TRADE, AND EXCHANGE RULE 4.07(C) IN ONE INSTANCE BY REPORTING THE BLOCK TRADE TO THE EXCHANGE PAST THE 15-MINUTE WINDOW FROM ITS EXECUTION. THE IFUS BUSINESS CONDUCT COMMITTEE (BCC) FURTHER DETERMINED THAT CSSEL MAY HAVE VIOLATED EXCHANGE RULE 4.07(C) IN AN ADDITIONAL INSTANCE BY REPORTING THE BLOCK TRADE TO THE EXCHANGE AS A BLOCK AT INDEX CLOSE (BIC) WHEN THE TRADE DID NOT MEET THE DEFINITION OF A BIC TRADE Final Settled 02-27-2020 Exact Monetary/Fine 40000.00 IFUS IMPOSED A $15,000 FINE ON CSI, AND A $25,000 FINE ON CSSEL. SEE ABOVE Firm N CREDIT SUISSE SECURITIES (EUROPE) LIMITED N N SRO ICE FUTURES U.S., INC. Other MONETARY FINE 02-27-2020 Exact 2018-37 Other MSCI EMERGING MARKETS INDEX FUTURE CREDIT SUISSE INTERNATIONAL ("CSI") AND CREDIT SUISSE SECURITIES (EUROPE) LIMITED ("CSSEL") AGREED ON A WITHOUT-ADMITTING-OR DENYING BASIS TO RESOLVE THE MATTER. ICE FUTURES U.S. ("IFUS") EXCHANGE DETERMINED THAT CSSEL AND CSI MAY HAVE VIOLATED EXCHANGE RULE 4.02(C) IN ONE INSTANCE BY EXECUTING A BLOCK TRADE BETWEEN EACH OTHER THAT RESULTED IN A WASH TRADE, AND EXCHANGE RULE 4.07(C) IN ONE INSTANCE BY REPORTING THE BLOCK TRADE TO THE EXCHANGE PAST THE 15-MINUTE WINDOW FROM ITS EXECUTION. THE IFUS BUSINESS CONDUCT COMMITTEE (BCC) FURTHER DETERMINED THAT CSSEL MAY HAVE VIOLATED EXCHANGE RULE 4.07(C) IN AN ADDITIONAL INSTANCE BY REPORTING THE BLOCK TRADE TO THE EXCHANGE AS A BLOCK AT INDEX CLOSE (BIC) WHEN THE TRADE DID NOT MEET THE DEFINITION OF A BIC TRADE. Final Settled 02-27-2020 Exact Monetary/Fine 40000.00 IFUS IMPOSED A $15,000 FINE ON CSI, AND A $25,000 FINE ON CSSEL. SEE ABOVE INITIAL 14H(1)(a) 14H(1)(b) 14H(1)(c) 14H(2) One or more control affiliate(s) 000000816 Firm Y CREDIT SUISSE SECURITIES (USA) LLC N Y INITIAL 14H(2) One or more control affiliate(s) Firm N ASSET BACKED SECURITIES CORPORATION N N PEOPLE OF THE STATE OF NEW YORK BY ERIC SCHNEIDERMAN, ATTORNEY GENERAL Other STATE OF NEW YORK Injunction Disgorgement Money Damages (Private/Civil Complaint) Restitution Other ACCOUNTING 11-20-2012 Exact Other RESIDENTIAL MORTGAGE BACKED SECURITIES State Court SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK NY 451802/2012 ON NOVEMBER 20, 2012, THE NEW YORK ATTORNEY GENERAL ("NYAG") FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, F/K/A CREDIT SUISSE FIRST BOSTON LLC, DLJ MORTGAGE CAPITAL, INC., CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORPORATION, ASSET BACKED SECURITIES CORPORATION AND CREDIT SUISSE MORTGAGE ACCEPTANCE CORPORATION (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN PROMOTING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES. IN PARTICULAR, THENYAG ALLEGES THAT CREDIT SUISSE MISREPRESENTED ITS DUE DILIGENCE AND QUALITY CONTROL PROCESSES. Pending 11-28-2012 Exact ON NOVEMBER 20, 2012, THE NEW YORK ATTORNEY GENERAL ("NYAG") FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, F/K/A CREDIT SUISSE FIRST BOSTON LLC, DLJ MORTGAGE CAPITAL, INC., CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORPORATION, ASSET BACKED SECURITIES CORPORATION AND CREDIT SUISSE MORTGAGE ACCEPTANCE CORPORATION (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN PROMOTING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES. IN PARTICULAR, THE NYAG ALLEGES THAT CREDIT SUISSE MISREPRESENTED ITS DUE DILIGENCE AND QUALITY CONTROL PROCESSES Firm N CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES N N PEOPLE OF THE STATE OF NEW YORK BY ERIC SCHNEIDERMAN, ATTORNEY GENERAL Other STATE OF NEW YORK Injunction Disgorgement Money Damages (Private/Civil Complaint) Restitution Other ACCOUNTING 11-20-2012 Exact Other RESIDENTIAL MORTGAGE BACKED SECURITIES State Court SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK NY 451802/2012 ON NOVEMBER 20, 2012, THE NEW YORK ATTORNEY GENERAL ("NYAG") FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, F/K/A CREDIT SUISSE FIRST BOSTON LLC, DLJ MORTGAGE CAPITAL, INC., CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORPORATION, ASSET BACKED SECURITIES CORPORATION AND CREDIT SUISSE MORTGAGE ACCEPTANCE CORPORATION (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN PROMOTING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES. IN PARTICULAR, THENYAG ALLEGES THAT CREDIT SUISSE MISREPRESENTED ITS DUE DILIGENCE AND QUALITY CONTROL PROCESSES. Pending 11-28-2012 Exact ON NOVEMBER 20, 2012, THE NEW YORK ATTORNEY GENERAL ("NYAG") FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, F/K/A CREDIT SUISSE FIRST BOSTON LLC, DLJ MORTGAGE CAPITAL, INC., CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORPORATION, ASSET BACKED SECURITIES CORPORATION AND CREDIT SUISSE MORTGAGE ACCEPTANCE CORPORATION (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN PROMOTING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES. IN PARTICULAR, THE NYAG ALLEGES THAT CREDIT SUISSE MISREPRESENTED ITS DUE DILIGENCE AND QUALITY CONTROL PROCESSES Firm N CREDIT SUISSE MORTGAGE ACCEPTANCE CORPORATION N N PEOPLE OF THE STATE OF NEW YORK BY ERIC SCHNEIDERMAN, ATTORNEY GENERAL Other STATE OF NEW YORK Injunction Disgorgement Money Damages (Private/Civil Complaint) Restitution Other ACCOUNTING 11-20-2012 Exact Other RESIDENTIAL MORTGAGE BACKED SECURITIES State Court SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK NY 451802/2012 ON NOVEMBER 20, 2012, THE NEW YORK ATTORNEY GENERAL ("NYAG") FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, F/K/A CREDIT SUISSE FIRST BOSTON LLC, DLJ MORTGAGE CAPITAL, INC., CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORPORATION, ASSET BACKED SECURITIES CORPORATION AND CREDIT SUISSE MORTGAGE ACCEPTANCE CORPORATION (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN PROMOTING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES. IN PARTICULAR, THENYAG ALLEGES THAT CREDIT SUISSE MISREPRESENTED ITS DUE DILIGENCE AND QUALITY CONTROL PROCESSES. Pending 11-28-2012 Exact ON NOVEMBER 20, 2012, THE NEW YORK ATTORNEY GENERAL ("NYAG") FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, F/K/A CREDIT SUISSE FIRST BOSTON LLC, DLJ MORTGAGE CAPITAL, INC., CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORPORATION, ASSET BACKED SECURITIES CORPORATION AND CREDIT SUISSE MORTGAGE ACCEPTANCE CORPORATION (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN PROMOTING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES. IN PARTICULAR, THE NYAG ALLEGES THAT CREDIT SUISSE MISREPRESENTED ITS DUE DILIGENCE AND QUALITY CONTROL PROCESSES Firm N DLJ MORTGAGE CAPITAL INC. N N PEOPLE OF THE STATE OF NEW YORK BY ERIC SCHNEIDERMAN, ATTORNEY GENERAL Other STATE OF NEW YORK Injunction Disgorgement Money Damages (Private/Civil Complaint) Restitution Other ACCOUNTING 11-20-2012 Exact Other RESIDENTIAL MORTGAGE BACKED SECURITIES State Court SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK NY 451802/2012 ON NOVEMBER 20, 2012, THE NEW YORK ATTORNEY GENERAL ("NYAG") FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, F/K/A CREDIT SUISSE FIRST BOSTON LLC, DLJ MORTGAGE CAPITAL, INC., CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORPORATION, ASSET BACKED SECURITIES CORPORATION AND CREDIT SUISSE MORTGAGE ACCEPTANCE CORPORATION (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN PROMOTING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES. IN PARTICULAR, THENYAG ALLEGES THAT CREDIT SUISSE MISREPRESENTED ITS DUE DILIGENCE AND QUALITY CONTROL PROCESSES. Pending 11-28-2012 Exact ON NOVEMBER 20, 2012, THE NEW YORK ATTORNEY GENERAL ("NYAG") FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, F/K/A CREDIT SUISSE FIRST BOSTON LLC, DLJ MORTGAGE CAPITAL, INC., CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORPORATION, ASSET BACKED SECURITIES CORPORATION AND CREDIT SUISSE MORTGAGE ACCEPTANCE CORPORATION (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN PROMOTING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES. IN PARTICULAR, THE NYAG ALLEGES THAT CREDIT SUISSE MISREPRESENTED ITS DUE DILIGENCE AND QUALITY CONTROL PROCESSES INITIAL 14H(2) One or more control affiliate(s) Firm N CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES N N JOHN J. HOFFMAN, ACTING ATTORNEY GENERAL OF NEW JERSEY ON BEHALF OF Other STATE OF NEW JERSEY Restitution Civil Penalty(ies)/Fine(s) Disgorgement Injunction Other RESCISSION 12-18-2013 Exact Other RESIDENTIAL MORTGAGE-BACKED State Court SUPERIOR COURT OF NEW JERSEY, CHANCERY DIVISION MERCER COUNTY,NEW JERSEY NJ MER-C-000137-13. ON DECEMBER 18, 2013, THE NEW JERSEY ATTORNEY GENERAL ON BEHALF OF THE NEW JERSEY BUREAU OF SECURITIES FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORP., AND DLJ MORTGAGE CAPITAL (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE MADE MATERIAL MISREPRESENTATIONS OR OMITTED TO DISCLOSE MATERIAL FACTS AS WELL AS ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN OFFERING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES TO INSTITUTIONAL INVESTORS Pending 12-18-2013 Exact ON DECEMBER 18, 2013, THE NEW JERSEY ATTORNEY GENERAL ON BEHALF OF THE NEW JERSEY BUREAU OF SECURITIES FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORP., AND DLJ MORTGAGE CAPITAL (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE MADE MATERIAL MISREPRESENTATIONS OR OMITTED TO DISCLOSE MATERIAL FACTS AS WELL AS ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN OFFERING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES TO INSTITUTIONAL INVESTORS Firm N DLJ MORTGAGE CAPITAL INC N N JOHN J. HOFFMAN, ACTING ATTORNEY GENERAL OF NEW JERSEY ON BEHALF OF Other STATE OF NEW JERSEY Restitution Civil Penalty(ies)/Fine(s) Disgorgement Injunction Other RESCISSION 12-18-2013 Exact Other RESIDENTIAL MORTGAGE-BACKED State Court SUPERIOR COURT OF NEW JERSEY, CHANCERY DIVISION MERCER COUNTY, NEW JERSEY NJ NO. MER-C-000137-13. ON DECEMBER 18, 2013, THE NEW JERSEY ATTORNEY GENERAL ON BEHALF OF THE NEW JERSEY BUREAU OF SECURITIES FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORP., AND DLJ MORTGAGE CAPITAL (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE MADE MATERIAL MISREPRESENTATIONS OR OMITTED TO DISCLOSE MATERIAL FACTS AS WELL AS ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN OFFERING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES TO INSTITUTIONAL INVESTORS Pending 12-18-2013 Exact ON DECEMBER 18, 2013, THE NEW JERSEY ATTORNEY GENERAL ON BEHALF OF THE NEW JERSEY BUREAU OF SECURITIES FILED A LAWSUIT AGAINST CREDIT SUISSE SECURITIES (USA) LLC, CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORP., AND DLJ MORTGAGE CAPITAL (TOGETHER "CREDIT SUISSE") ALLEGING THAT CREDIT SUISSE MADE MATERIAL MISREPRESENTATIONS OR OMITTED TO DISCLOSE MATERIAL FACTS AS WELL AS ENGAGED IN CERTAIN FRAUDULENT AND DECEPTIVE ACTS IN OFFERING AND SELLING RESIDENTIAL MORTGAGE-BACKED SECURITIES TO INSTITUTIONAL INVESTORS INITIAL 14H(2) Applicant and one or more control affiliate(s) CREDIT SUISSE AG/ N PRIVATE PLAINTIFF - CITY OF LIVONIA Other PRIVATE PLAINTIFF - CITY OF LIVONIA Other SEE BELOW Other ADJUDGE THAT DEFENDANTS VIOLATED FEDERAL AND STATE LAWS; AWARD PLAINTIFFS AND MEMBERS OF THE CLASS TREBLE DAMAGES; AWARD REASONABLE ATTORNEY'S FEES AND COSTS OF SUIT; AWARD PRE- AND POST-JUDGMENT INTEREST; ESTABLISH A CONSTRUCTIVE TRUST INTO WHICH DE 01-31-2019 Exact Other LIBOR State Court UNITED STATES DISTRICT COURT, SOUTHERN DISTRICT OF NEW YORK; NEW YORK NY CASE 1:19-CV-00965 THE COMPLAINT ALLEGES THAT THE USD ICE LIBOR RATE FROM 2014 TO THE PRESENT HAS COLLUSIVELY BEEN SET ARTIFICIALLY LOW BY ALL DEFENDANTS, WHO INCLUDE THE PANEL BANKS AND CERTAIN AFFILIATES AND ICE AND ITS AFFILIATES. PLAINTIFF ALLEGES A "PROFIT-MOTIVATED CONSPIRACY" TO SET USD ICE LIBOR LOWER SO THAT THE PANEL BANK DEFENDANTS COULD MAKE LOWER INTEREST PAYMENTS ON FLOATING RATE NOTES AND INTEREST RATE SWAPS. IN ADDITION TO THE MOTIVE, PLAINTIFF CONTENDS THAT DEFENDANTS HAD THE OPPORTUNITY TO CONSPIRE THROUGH THE ICE PROCESS AND RECIDIVISM (ALLEGED MISCONDUCT WITH RESPECT TO LIBOR RATES IN THE PAST) SUPPORTS THE PRESENT CONSPIRACY. PLAINTIFF ALSO ASSERTS THAT ICE AND THE PANEL BANK DEFENDANTS FURTHERED THE CONSPIRACY BY CONCEALING THE "LACK OF INTERBANK FUNDING UNDERLYING USD ICE LIBOR DURING THE CLASS PERIOD." TO SET ICE LIBOR, THE PANEL BANKS WERE INSTRUCTED TO ANSWER THE QUESTION: "AT WHAT RATE COULD YOU BORROW FUNDS, WERE YOU TO DO SO BY ASKING FOR AND THEN ACCEPTING INTERBANK OFFERS IN A REASONABLE MARKET SIZE JUST PRIOR TO 11AM?" PLAINTIFF ASSERTS THAT TO ANSWER OR EVEN ASK THIS QUESTION SUGGESTED THE EXISTENCE OF AN ACTIVE "INTERBANK" FUNDING MARKET; HOWEVER, THERE WAS NO SUCH UNDERLYING MARKET, THE PLAINTIFF CLAIMS. PLAINTIFF HAS ASSERTED TWO CLAIMS: ONE FOR PRICE-FIXING UNDER THE SHERMAN ACT AND ONE FOR UNJUST ENRICHMENT, BOTH PURPORTEDLY ON BEHALF OF A CLASS OF ALL PERSONS OR ENTITIES RESIDING IN THE UNITED STATES THAT DIRECTLY TRANSACTED WITH A PANEL BANK DEFENDANT IN AN ICE LIBOR-LINKED FLOATING RATE DEBT INSTRUMENT OR SWAP DURING THE CLASS PERIOD. CITY OF LIVONIA HAS NOT ALLEGED ANY SPECIFIC TRADES WITH CREDIT SUISSE, AND THERE ARE NO CREDIT SUISSE-SPECIFIC ALLEGATIONS OTHER THAN ICE LIBOR SUBMISSION DATA AND RELATED STATISTICS. Pending 01-31-2019 Explanation WHILE THE COMPLAINT WAS FILED ON 01/31/2019; IT HAS NOT YET BEEN FORMALLY SERVED. THE COMPLAINT ALLEGES THAT THE USD ICE LIBOR RATE FROM 2014 TO THE PRESENT HAS COLLUSIVELY BEEN SET ARTIFICIALLY LOW BY ALL DEFENDANTS, WHO INCLUDE THE PANEL BANKS AND CERTAIN AFFILIATES AND ICE AND ITS AFFILIATES. PLAINTIFF ALLEGES A "PROFIT-MOTIVATED CONSPIRACY" TO SET USD ICE LIBOR LOWER SO THAT THE PANEL BANK DEFENDANTS COULD MAKE LOWER INTEREST PAYMENTS ON FLOATING RATE NOTES AND INTEREST RATE SWAPS. IN ADDITION TO THE MOTIVE, PLAINTIFF CONTENDS THAT DEFENDANTS HAD THE OPPORTUNITY TO CONSPIRE THROUGH THE ICE PROCESS AND RECIDIVISM (ALLEGED MISCONDUCT WITH RESPECT TO LIBOR RATES IN THE PAST) SUPPORTS THE PRESENT CONSPIRACY. PLAINTIFF ALSO ASSERTS THAT ICE AND THE PANEL BANK DEFENDANTS FURTHERED THE CONSPIRACY BY CONCEALING THE "LACK OF INTERBANK FUNDING UNDERLYING USD ICE LIBOR DURING THE CLASS PERIOD." TO SET ICE LIBOR, THE PANEL BANKS WERE INSTRUCTED TO ANSWER THE QUESTION: "AT WHAT RATE COULD YOU BORROW FUNDS, WERE YOU TO DO SO BY ASKING FOR AND THEN ACCEPTING INTERBANK OFFERS IN A REASONABLE MARKET SIZE JUST PRIOR TO 11AM?" PLAINTIFF ASSERTS THAT TO ANSWER OR EVEN ASK THIS QUESTION SUGGESTED THE EXISTENCE OF AN ACTIVE "INTERBANK" FUNDING MARKET; HOWEVER, THERE WAS NO SUCH UNDERLYING MARKET, THE PLAINTIFF CLAIMS. PLAINTIFF HAS ASSERTED TWO CLAIMS: ONE FOR PRICE-FIXING UNDER THE SHERMAN ACT AND ONE FOR UNJUST ENRICHMENT, BOTH PURPORTEDLY ON BEHALF OF A CLASS OF ALL PERSONS OR ENTITIES RESIDING IN THE UNITED STATES THAT DIRECTLY TRANSACTED WITH A PANEL BANK DEFENDANT IN AN ICE LIBOR-LINKED FLOATING RATE DEBT INSTRUMENT OR SWAP DURING THE CLASS PERIOD. CITY OF LIVONIA HAS NOT ALLEGED ANY SPECIFIC TRADES WITH CREDIT SUISSE, AND THERE ARE NO CREDIT SUISSE-SPECIFIC ALLEGATIONS OTHER THAN ICE LIBOR SUBMISSION DATA AND RELATED STATISTICS. Firm N CREDIT SUISSE GROUP AG N N PRIVATE PLAINTIFF - CITY OF LIVONIA Other PRIVATE PLAINTIFF - CITY OF LIVONIA Other SEE BELOW Other ADJUDGE THAT DEFENDANTS VIOLATED FEDERAL AND STATE LAWS; AWARD PLAINTIFFS AND MEMBERS OF THE CLASS TREBLE DAMAGES; AWARD REASONABLE ATTORNEY'S FEES AND COSTS OF SUIT; AWARD PRE- AND POST-JUDGMENT INTEREST; ESTABLISH A CONSTRUCTIVE TRUST INTO WHICH DE 01-31-2019 Exact Other LIBOR State Court UNITED STATES DISTRICT COURT, SOUTHERN DISTRICT OF NEW YORK NEW YORK NY CASE 1:19-CV-00965 THE COMPLAINT ALLEGES THAT THE USD ICE LIBOR RATE FROM 2014 TO THE PRESENT HAS COLLUSIVELY BEEN SET ARTIFICIALLY LOW BY ALL DEFENDANTS, WHO INCLUDE THE PANEL BANKS AND CERTAIN AFFILIATES AND ICE AND ITS AFFILIATES. PLAINTIFF ALLEGES A "PROFIT-MOTIVATED CONSPIRACY" TO SET USD ICE LIBOR LOWER SO THAT THE PANEL BANK DEFENDANTS COULD MAKE LOWER INTEREST PAYMENTS ON FLOATING RATE NOTES AND INTEREST RATE SWAPS. IN ADDITION TO THE MOTIVE, PLAINTIFF CONTENDS THAT DEFENDANTS HAD THE OPPORTUNITY TO CONSPIRE THROUGH THE ICE PROCESS AND RECIDIVISM (ALLEGED MISCONDUCT WITH RESPECT TO LIBOR RATES IN THE PAST) SUPPORTS THE PRESENT CONSPIRACY. PLAINTIFF ALSO ASSERTS THAT ICE AND THE PANEL BANK DEFENDANTS FURTHERED THE CONSPIRACY BY CONCEALING THE "LACK OF INTERBANK FUNDING UNDERLYING USD ICE LIBOR DURING THE CLASS PERIOD." TO SET ICE LIBOR, THE PANEL BANKS WERE INSTRUCTED TO ANSWER THE QUESTION: "AT WHAT RATE COULD YOU BORROW FUNDS, WERE YOU TO DO SO BY ASKING FOR AND THEN ACCEPTING INTERBANK OFFERS IN A REASONABLE MARKET SIZE JUST PRIOR TO 11AM?" PLAINTIFF ASSERTS THAT TO ANSWER OR EVEN ASK THIS QUESTION SUGGESTED THE EXISTENCE OF AN ACTIVE "INTERBANK" FUNDING MARKET; HOWEVER, THERE WAS NO SUCH UNDERLYING MARKET, THE PLAINTIFF CLAIMS. PLAINTIFF HAS ASSERTED TWO CLAIMS: ONE FOR PRICE-FIXING UNDER THE SHERMAN ACT AND ONE FOR UNJUST ENRICHMENT, BOTH PURPORTEDLY ON BEHALF OF A CLASS OF ALL PERSONS OR ENTITIES RESIDING IN THE UNITED STATES THAT DIRECTLY TRANSACTED WITH A PANEL BANK DEFENDANT IN AN ICE LIBOR-LINKED FLOATING RATE DEBT INSTRUMENT OR SWAP DURING THE CLASS PERIOD. CITY OF LIVONIA HAS NOT ALLEGED ANY SPECIFIC TRADES WITH CREDIT SUISSE, AND THERE ARE NO CREDIT SUISSE-SPECIFIC ALLEGATIONS OTHER THAN ICE LIBOR SUBMISSION DATA AND RELATED STATISTICS. Pending 01-31-2019 Explanation WHILE THE COMPLAINT WAS FILED ON 01/31/2019; IT HAS NOT YET BEEN FORMALLY SERVED. THE COMPLAINT ALLEGES THAT THE USD ICE LIBOR RATE FROM 2014 TO THE PRESENT HAS COLLUSIVELY BEEN SET ARTIFICIALLY LOW BY ALL DEFENDANTS, WHO INCLUDE THE PANEL BANKS AND CERTAIN AFFILIATES AND ICE AND ITS AFFILIATES. PLAINTIFF ALLEGES A "PROFIT-MOTIVATED CONSPIRACY" TO SET USD ICE LIBOR LOWER SO THAT THE PANEL BANK DEFENDANTS COULD MAKE LOWER INTEREST PAYMENTS ON FLOATING RATE NOTES AND INTEREST RATE SWAPS. IN ADDITION TO THE MOTIVE, PLAINTIFF CONTENDS THAT DEFENDANTS HAD THE OPPORTUNITY TO CONSPIRE THROUGH THE ICE PROCESS AND RECIDIVISM (ALLEGED MISCONDUCT WITH RESPECT TO LIBOR RATES IN THE PAST) SUPPORTS THE PRESENT CONSPIRACY. PLAINTIFF ALSO ASSERTS THAT ICE AND THE PANEL BANK DEFENDANTS FURTHERED THE CONSPIRACY BY CONCEALING THE "LACK OF INTERBANK FUNDING UNDERLYING USD ICE LIBOR DURING THE CLASS PERIOD." TO SET ICE LIBOR, THE PANEL BANKS WERE INSTRUCTED TO ANSWER THE QUESTION: "AT WHAT RATE COULD YOU BORROW FUNDS, WERE YOU TO DO SO BY ASKING FOR AND THEN ACCEPTING INTERBANK OFFERS IN A REASONABLE MARKET SIZE JUST PRIOR TO 11AM?" PLAINTIFF ASSERTS THAT TO ANSWER OR EVEN ASK THIS QUESTION SUGGESTED THE EXISTENCE OF AN ACTIVE "INTERBANK" FUNDING MARKET; HOWEVER, THERE WAS NO SUCH UNDERLYING MARKET, THE PLAINTIFF CLAIMS. PLAINTIFF HAS ASSERTED TWO CLAIMS: ONE FOR PRICE-FIXING UNDER THE SHERMAN ACT AND ONE FOR UNJUST ENRICHMENT, BOTH PURPORTEDLY ON BEHALF OF A CLASS OF ALL PERSONS OR ENTITIES RESIDING IN THE UNITED STATES THAT DIRECTLY TRANSACTED WITH A PANEL BANK DEFENDANT IN AN ICE LIBOR-LINKED FLOATING RATE DEBT INSTRUMENT OR SWAP DURING THE CLASS PERIOD. CITY OF LIVONIA HAS NOT ALLEGED ANY SPECIFIC TRADES WITH CREDIT SUISSE, AND THERE ARE NO CREDIT SUISSE-SPECIFIC ALLEGATIONS OTHER THAN ICE LIBOR SUBMISSION DATA AND RELATED STATISTICS. 08-29-2023 CREDIT SUISSE AG/ Alfred Nunn Alfred Nunn Director, Compliance EX-99.34 OPIN COUNSL 2 CSAG-Opin-SECNonresidentSBSD.pdf OPINION OF UK COUNSEL begin 644 CSAG-Opin-SECNonresidentSBSD.pdf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