J.P. Morgan Investment Management Inc.

Event Detail: 2 COUNTS OF WIRE FRAUD, IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1343 Status: Final Disposition: DEFERRED PROSECUTION AGREEMENT ~$920MM PENALTY WAS PAID ON OCT. 9TH AND THE FIRM IS REQUIRED TO COMPLY WITH THE OBLIGATIONS SET FORTH IN THE DEFERRED PROSECUTION AGREEMENT FOR A PERIOD OF 3 YEARS

Event Detail: JPMC WAS CHARGED WITH A ONE COUNT FELONY CRIME CHARGE IN VIOLATION OF THE SHERMAN ANTITRUST ACT, 15 U.S.C. SECTION 1 RELATING TO THE FOREIGN CURRENCY EXCHANGE SPOT MARKET ("FX SPOT MARKET"). JPMC PLED GUILTY PURSUANT TO A PLEA AGREEMENT WITH THE DOJ. Status: Final Disposition: JPMC ENTERED A GUILTY PLEA ON MAY 20, 2015 PURSUANT TO A PLEA AGREEMENT WITH THE DOJ. JPMC AGREED TO PAY A CRIMINAL FINE OF $550 MILLION AND A MANDATORY ASSESSMENT OF $400. JPMC AGREED TO BE SUBJECT TO PROBATION FOR 3 YEARS. ON JANUARY 10, 2017 JUDGMENT WAS ENTERED CONSISTENT WITH THE TERMS OF THE PLEA AGREEMENT. THE FINE WAS PAID ON JANUARY 17, 2017. Summary: ON MAY 20, 2015, THE DOJ FILED A CRIMINAL INFORMATION IN THE DISTRICT COURT CHARGING JPMC WITH A ONE COUNT CRIME CHARGE IN VIOLATION OF THE SHERMAN ANTITRUST ACT, 15 U.S.C. § 1 (THE "INFORMATION"). THE INFORMATION CHARGES THAT, FROM JULY 2010 UNTIL AT LEAST JANUARY 2013, JPMC, THROUGH ONE OF ITS EURO/U.S. DOLLAR ("EUR/USD") TRADERS, ENTERED INTO AND ENGAGED IN A CONSPIRACY TO FIX, STABILIZE, MAINTAIN, INCREASE OR DECREASE THE PRICE OF, AND RIG BIDS AND OFFERS FOR, THE EUR/USD CURRENCY PAIR EXCHANGED IN THE FX SPOT MARKET BY AGREEING TO ELIMINATE COMPETITION IN THE PURCHASE AND SALE OF THE EUR/USD CURRENCY PAIR IN THE U.S. AND ELSEWHERE.

Allegations: ON MAY 20, 2015, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FRB") ISSUED AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY AGAINST JPMORGAN CHASE & CO. ("JPMC") RELATING TO ITS FOREIGN EXCHANGE ("FX") ACTIVITIES ("ORDER") FROM 2008 THROUGH 2013. THE ORDER STATES THAT JPMC ENGAGED IN UNSAFE AND UNSOUND BANKING PRACTICES BECAUSE (A) JPMC LACKED ADEQUATE FIRM-WIDE GOVERNANCE, RISK MANAGEMENT, COMPLIANCE AND AUDIT POLICIES AND PROCEDURES TO ENSURE THAT CERTAIN OF THE FIRM'S FX ACTIVITIES CONDUCTED AT THE FX SUBSIDIARIES COMPLIED WITH SAFE AND SOUND BANKING PRACTICES, APPLICABLE U.S. LAWS AND REGULATIONS, INCLUDING POLICIES AND PROCEDURES TO PREVENT POTENTIAL VIOLATIONS OF THE U.S. COMMODITIES, ANTITRUST AND CRIMINAL FRAUD LAWS, AND APPLICABLE INTERNAL POLICIES; (B) JPMC'S DEFICIENT POLICIES AND PROCEDURES PREVENTED JPMC FROM DETECTING AND ADDRESSING UNSAFE AND UNSOUND CONDUCT BY THE FX SUBSIDIARIES' TRADERS RELATING TO CERTAIN COMMUNICATIONS BY TRADERS IN MULTIBANK CHATROOMS; AND (C) JPMC'S DEFICIENT POLICIES AND PROCEDURES PREVENTED JPMC FROM DETECTING AND ADDRESSING UNSAFE AND UNSOUND CONDUCT BY THE FX SUBSIDIARIES' SALES PERSONNEL REGARDING THE PROVISION OF INFORMATION TO CUSTOMERS REGARDING PRICE QUOTES; AND THE PROVISION OF INFORMATION TO CUSTOMERS ABOUT HOW A CUSTOMER'S FX ORDER IS FILLED. Status: Final Sanction Detail: IN THE ORDER, JPMC AGREED TO PAY A CIVIL MONEY PENALTY IN THE TOTAL AMOUNT OF $342MIL, WHICH WAS PAID ON MAY 20, 2015, AND CONTINUE TO IMPLEMENT ADDITIONAL IMPROVEMENTS IN ITS OVERSIGHT, INTERNAL CONTROLS, COMPLIANCE, RISK MANAGEMENT, AND AUDIT PROGRAMS FOR THE FX ACTIVITIES IN ORDER TO COMPLY WITH JPMC POLICIES, SAFE AND SOUND BANKING PRACTICES, AND APPLICABLE U.S. LAWS/REGULATION. JPMC AGREED: (A) THE BOARD OF DIRECTORS OF JPMC OR AN AUTHORIZED COMMITTEE THEREOF SHALL SUBMIT A WRITTEN PLAN TO IMPROVE SENIOR MANAGEMENT'S OVERSIGHT OF JPMC'S COMPLIANCE WITH APPLICABLE U.S. LAWS/REGULATIONS AND INTERNAL POLICIES RELATING TO CERTAIN FX ACTIVITIES; (B) JPMC SHALL SUBMIT AN ENHANCED WRITTEN INTERNAL CONTROLS AND COMPLIANCE PROGRAM TO COMPLY WITH APPLICABLE U.S. LAWS/REGULATIONS RELATING TO CERTAIN FX ACTIVITIES; (C) JPMC SHALL SUBMIT A WRITTEN PLAN TO IMPROVE ITS COMPLIANCE RISK MANAGEMENT PROGRAM WITH REGARD TO COMPLIANCE WITH APPLICABLE U.S. LAWS/REGULATIONS RELATING TO CERTAIN FX ACTIVITIES FIRM-WIDE; (D) JPMC MANAGEMENT SHALL ANNUALLY CONDUCT A REVIEW OF COMPLIANCE POLICIES AND PROCEDURES APPLICABLE TO CERTAIN FX ACTIVITIES AND THEIR IMPLEMENTATION AND AN APPROPRIATE RISK-FOCUSED SAMPLING OF OTHER KEY CONTROLS FOR CERTAIN FIRM-WIDE FX ACTIVITIES; (E) JPMC SHALL SUBMIT AN ENHANCED WRITTEN INTERNAL AUDIT PROGRAM RELATING TO THE JPMC'S COMPLIANCE WITH U.S. LAWS/REGULATIONS IN CERTAIN FX ACTIVITIES; AND (F) JPMC SHALL NOT IN THE FUTURE DIRECTLY OR INDIRECTLY RETAIN ANY INDIVIDUAL AS AN OFFICER, EMPLOYEE, AGENT, CONSULTANT, OR CONTRACTOR OF JPMC OR OF ANY SUBSIDIARY WHO, BASED ON THE INVESTIGATIVE RECORD COMPILED BY U.S. AUTHORITIES, PARTICIPATED IN THE MISCONDUCT UNDERLYING THE ORDER, WHO HAS BEEN SUBJECT TO FORMAL DISCIPLINARY ACTION AS A RESULT OF JPMC'S INTERNAL DISCIPLINARY REVIEW OR PERFORMANCE REVIEW IN CONNECTION WITH THE CONDUCT, AND HAS EITHER SEPARATED FROM JPMC OR ANY SUBSIDIARY THEREOF OR HAD HIS/HER EMPLOYMENT TERMINATED IN CONNECTION WITH THE CONDUCT. Summary: IN SETTLEMENT OF THIS MATTER, JPMC CONSENTED AND AGREED TO THE ISSUANCE OF THE ORDER, WHICH THE FRB HAS DETERMINED TO ACCEPT AND HAS ISSUED. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

Allegations: ON NOVEMBER 17, 2016, JPMORGAN CHASE & CO. ("JPMC") ENTERED INTO A SETTLEMENT WITH THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FRB") RESULTING IN THE FRB ISSUING AN ORDER ("ORDER"). THE ORDER FINDS THAT FROM AT LEAST 2008 THROUGH 2013, JPMC'S ASIA-PACIFIC REGION INVESTMENT BANKING GROUP OPERATED A REFERRAL HIRING PROGRAM WHEREBY CANDIDATES WHO WERE REFERRED, DIRECTLY OR INDIRECTLY, BY FOREIGN GOVERNMENT OFFICIALS AND EXISTING OR PROSPECTIVE COMMERCIAL CLIENTS, AND WHO IN MOST INSTANCES WERE LESS QUALIFIED THAN NON-REFERRED CANDIDATES WHO WERE HIRED THROUGH THE JPMC'S STANDARD HIRING PROGRAMS, WERE OFFERED INTERNSHIPS, TRAINING, AND OTHER EMPLOYMENT OPPORTUNITIES IN ORDER TO OBTAIN IMPROPER BUSINESS ADVANTAGES FOR JPMC. Status: Final Sanction Detail: THE ORDER DIRECTS JPMC TO CEASE-AND-DESIST AND TO PAY A CIVIL MONEY PENALTY OF $61,932,500, WHICH WAS PAID ON NOVEMBER 17, 2016. IN ADDITION, THE ORDER REQUIRES JPMC TO TAKE THE FOLLOWING STEPS: A) SUBMIT AN ACCEPTABLE WRITTEN PLAN, AND TIMELINE FOR IMPLEMENTATION, TO IMPROVE SENIOR MANAGEMENT'S OVERSIGHT OF JPMC'S FIRM-WIDE COMPLIANCE RISK MANAGEMENT PROGRAM WITH REGARD TO COMPLIANCE WITH APPLICABLE U.S. LAWS AND REGULATIONS AND APPLICABLE INTERNAL POLICIES AND PROCEDURES IN CONNECTION WITH THE FIRM'S HIRING OF CANDIDATES WHO WERE REFERRED, DIRECTLY OR INDIRECTLY, BY FOREIGN GOVERNMENT OFFICIALS AND EXISTING OR PROSPECTIVE COMMERCIAL CLIENTS ("REFERRAL HIRING PRACTICES"); B) SUBMIT AN ACCEPTABLE WRITTEN PLAN, AND TIMELINE FOR IMPLEMENTATION, TO ENHANCE THE EFFECTIVENESS OF JPMC'S FIRM-WIDE COMPLIANCE RISK MANAGEMENT PROGRAM WITH REGARD TO THE OVERSIGHT AND IMPLEMENTATION OF ANTI-BRIBERY PROCESSES AND PROCEDURES IN CONNECTION WITH THE FIRM'S REFERRAL HIRING PRACTICES; AND C) SUBMIT AN ACCEPTABLE WRITTEN PLAN, AND TIMELINE FOR IMPLEMENTATION, TO ENHANCE THE EFFECTIVENESS OF THE FIRM'S COMPLIANCE WITH INTERNAL POLICIES AND PROCEDURES AS WELL AS APPLICABLE U.S. LAWS AND REGULATIONS IN ITS REFERRAL HIRING PRACTICES. Summary: THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12. IN COORDINATION WITH THE FRB SETTLEMENT, JPMC AND CERTAIN OF ITS AFFILIATES ALSO ENTERED INTO SETTLEMENTS WITH OTHER AGENCIES TO RESOLVE CONCURRENT INVESTIGATIONS ARISING OUT OF THE SAME CONDUCT. THOSE SETTLEMENTS ARE AS FOLLOWS: JPMORGAN APAC ENTERED INTO A NON-PROSECUTION AGREEMENT WITH THE DEPARTMENT OF JUSTICE AND CONSENTED TO THE ISSUANCE OF A CRIMINAL FINE FOR VIOLATIONS OF FEDERAL ANTI-BRIBERY LAWS AND THE U.S. SECURITIES AND EXCHANGE COMMISSION ENTERED AN ADMINISTRATIVE CEASE-AND-DESIST ORDER AGAINST JPMC FINDING VIOLATIONS OF FEDERAL ANTI-BRIBERY AND SECURITIES LAWS.

Allegations: THE INVESTIGATION CONCERNED ALLEGED MISREPRESENTATIONS AND OMISSIONS IN CONNECTION WITH THE MARKETING, SALE AND DISTRIBUTION OF AUCTION RATE SECURITIES. Status: Final Sanction Detail: THE FINE WAS PAID ON JUNE 25, 2014. THE FINE REPRESENTS THE NORTH CAROLINA PORTION OF A TOTAL FINE OF $25 MILLION NEGOTIATED WITH THE NYAG AND THE STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION ON BEHALF OF THE NASAA TASK FORCE. THE REMAINING AMOUNT WILL BE PAID SEPARATELY TO OTHER STATES. ALSO PAID WAS $15,000 TO NASAA AS REIMBURSEMENT FOR INVESTIGATIVE COSTS INCURRED BY NASAA. Summary: THE ACTION RELATED TO ALLEGATIONS WITH RESPECT TO MISREPRESENTATIONS AND OMISSIONS IN CONNECTION WITH THE MARKETING, SALE AND DISTRIBUTION OF AUCTION RATE SECURITIES. AS DESCRIBED HEREIN, THE PRINICPAL TERMS OF THE SETTLEMENT WERE NEGOTIATED WITH THE NYAG AND THE STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION ON BEHALF OF THE NASAA TASK FORCE THAT CONTEMPLATES SEPARATE SIMILAR AGREEMENTS WITH OTHER STATES.

Allegations: THE INVESTIGATION CONCERNED ALLEGED MISREPRESENTATIONS AND OMISSIONS IN CONNECTION WITH THE MARKETING, SALE AND DISTRIBUTION OF AUCTION RATE SECURITIES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, JPMORGAN CHASE & CO CONSENTED TO A FINE OF $97706.22 WHICH WAS PAID ON 01/04/2017. THE FINE REPRESENTS THE NEW HAMPSHIRE PORTION OF A TOTAL FINE OF $25 MILLION NEGOTIATED WITH THE NYAG AND THE STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION ON BEHALF OF THE NASAA TASK FORCE. THE REMAINING AMOUNT WILL BE PAID SEPARATELY TO OTHER STATES. ALSO PAID WAS $15,000 TO NASAA AS REIMBURSEMENT FOR INVESTIGATIVE COSTS INCURRED BY NASAA. Summary: THE ACTION RELATED TO ALLEGATIONS WITH RESPECT TO MISREPRESENTATIONS AND OMISSIONS IN CONNECTION WITH THE MARKETING, SALE AND DISTRIBUTION OF AUCTION RATE SECURITIES. AS DESCRIBED HEREIN, THE PRINCIPAL TERMS OF THE SETTLEMENT WERE NEGOTIATED WITH THE NYAG AND THE STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION ON BEHALF OF THE NASAA TASK FORCE THAT CONTEMPLATES SEPARATE SIMILAR AGREEMENTS WITH OTHER STATES.

Allegations: ON FEBRUARY 5, 2018, THE TAIWAN FINANCIAL SUPERVISORY COMMISSION ("FSC") ISSUED A PUBLIC NOTICE OF ITS IMPOSITION OF A SANCTION OF RECTIFICATION AND AN ADMINISTRATIVE PENALTY ("SANCTION") AGAINST JPMORGAN ASSET MANAGEMENT (TAIWAN) LIMITED ("JPMAM TAIWAN") BECAUSE JPMAM TAIWAN, HAD NOT EFFECTIVELY ESTABLISHED A MECHANISM TO REVIEW TRAINING AND MARKETING EVENTS AND TO APPROVE AND REPORT EXPENSES. THE SANCTION IMPOSED AN ADMINISTRATIVE PENALTY UNDER ARTICLE 2(2) OF THE REGULATIONS GOVERNING SECURITIES INVESTMENT TRUST ENTERPRISES, ARTICLE 13 OF REGULATIONS GOVERNING THE RESPONSIBLE PERSONNEL AND BUSINESS PERSONNEL OF SECURITIES INVESTMENT TRUST ENTERPRISES, ARTICLE 6(2) OF THE STANDARDS GOVERNING THE ESTABLISHMENT OF INTERNAL CONTROL SYSTEMS BY SERVICE ENTERPRISES IN SECURITIES AND FUTURES MARKETS, AS WELL AS ARTICLES 102 AND 111(7) OF THE SECURITIES INVESTMENT TRUST AND CONSULTING ACT. THE FSC DETERMINED THAT JPMAM TAIWAN HAD NOT IMPLEMENTED EFFECTIVE INTERNAL CONTROL SYSTEMS AND ADEQUATELY SUPERVISED ITS EMPLOYEES. Status: Final Sanction Detail: IN THE SANCTION, JPMAM TAIWAN WAS REQUIRED TO PAY AN ADMINISTRATIVE PENALTY NT$1.2 MILLION (~USD 40,900), WHICH IT PAID ON FEBRUARY 13, 2018. Summary: THE ALLEGED CONDUCT DOES NOT RELATE IN ANY WAY TO THE REGISTRANT'S INVESTMENT ADVISER BUSINESS. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE SANCTION ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

Allegations: THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ALLEGED THAT JF ASSET MANAGEMENT LIMITED ("JFAML") (NOW KNOWN AS JPMORGAN ASSET MANAGEMENT (ASIA PACIFIC) LIMITED) VIOLATED REGULATION 19(2) OF THE SECURITIES CONTRACTS (REGULATION) (STOCK EXCHANGES AND CLEARING CORPORATIONS) REGULATIONS, 2012 RESCINDED AND REPLACED WITH SECURITIES CONTRACTS (REGULATION) (STOCK EXCHANGES AND CLEARING CORPORATIONS) REGULATIONS, 2018. Status: Final Sanction Detail: ON FEBRUARY 11, 2019, JFAML ACCEPTED THE PROPOSED SETTLEMENT AND PAID THE SETTLEMENT AMOUNT OF 15,625 RUPEES (APPROXIMATELY $7,500). Summary: ON MARCH 5, 2019 THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") PASSED A SETTLEMENT ORDER REGARDING THE LATE APPLICATION TO ACQUIRE SHARES IN MULTI COMMODITY EXCHANGE OF INDIA LIMITED ("MCX"), A RECOGNIZED STOCK EXCHANGE IN INDIA. PURSUANT TO REGULATION 19(2) OF THE SECURITIES CONTRACTS (REGULATION) (STOCK EXCHANGES AND CLEARING CORPORATIONS) REGULATIONS, 2012 RESCINDED AND REPLACED WITH SECURITIES CONTRACTS (REGULATION) (STOCK EXCHANGES AND CLEARING CORPORATIONS) REGULATIONS, 2018, JFAML WAS REQUIRED TO APPLY FOR SEBI'S APPROVAL WITHIN FIFTEEN DAYS OF ITS AGGREGATED SHAREHOLDING REPRESENTING GREATER THAN 2% OF MCX. JFAML, ON BEHALF OF CERTAIN CLIENT ACCOUNTS, ACQUIRED SHARES REPRESENTING IN AGGREGATE GREATER THAN 2% OF MCX ON JANUARY 27, 2017 AND, UPON REALIZING THE INADVERTENT OMISSION IN SEEKING APPROVAL FROM SEBI, JFAML SUBMITTED THE APPLICATION FOR APPROVAL ON FEBRUARY 28, 2018. SEBI GRANTED APPROVAL ON APRIL 23, 2018. ON JANUARY 15, 2019 SEBI ISSUED A NOTICE OF SUMMARY SETTLEMENT REGARDING THE ABOVE MATTER. ON FEBRUARY 11, 2019, JFAML ACCEPTED THE PROPOSED SETTLEMENT AND PAID THE SETTLEMENT AMOUNT OF 515,625 RUPEES (APPROXIMATELY $7,500).

Allegations: NEGLIGENT BREACH OF SUPERVISORY AND ORGANIZATIONAL DUTIES IN CONNECTION WITH INFRINGEMENTSOF SECTION 21 OF THE GERMAN SECURITIES TRADING ACT. Status: Final Sanction Detail: AN ADMINISTRATIVE FINE OF 1,830,000 EUROS Summary: AN ADMINISTRATIVE FINE OF 1,830,000 EUROS IS IMPOSED PURSUANT TO SECTION 30 (1) NO. 1, (4) SENTENCE 1 OF THE GERMAN ACT ON BREACHES OF ADMINISTRATIVE REGULATIONS, ON THE GROUNDS OF ANEGLIGENT BREACH OF SUPERVISORY AND ORGANIZATIONAL DUTIES IN CONNECTION WITH INFRINGEMENTS OF SECTION 21 OF THE GERMAN SECURITIES TRADING ACT RELATING TO THE FILING OF VOTING RIGHTS NOTIFICATIONS.

Allegations: ON NOVEMBER 17, 2016, JPMORGAN CHASE & CO. ("JPMC") ENTERED INTO A SETTLEMENT WITH THE SECURITIES AND EXCHANGE COMMISSION ("SEC") UNDER WHICH JPMC CONSENTED TO THE ENTRY OF AN ORDER (THE "ORDER") THAT FINDS THAT JPMC VIOLATED SECTIONS 13(B)(2)(A), 13(B)(2)(B) AND 30A OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"). THE ORDER FINDS THAT JPMC VIOLATED THE ANTI-BRIBERY PROVISIONS OF THE FEDERAL SECURITIES LAWS BY CORRUPTLY PROVIDING VALUABLE INTERNSHIPS AND EMPLOYMENT TO RELATIVES AND FRIENDS OF FOREIGN GOVERNMENT OFFICIALS ("REFERRAL HIRES") IN ORDER TO ASSIST JPMC IN RETAINING AND OBTAINING BUSINESS. IN ADDITION, THE ORDER FINDS THAT JPMC VIOLATED THE BOOKS AND RECORDS PROVISIONS AND THE INTERNAL ACCOUNTING CONTROLS PROVISIONS OF THE FOREIGN CORRUPT PRACTICES ACT ("FCPA") IN CONJUNCTION WITH CERTAIN REFERRAL HIRES. Status: Final Sanction Detail: THE ORDER DIRECTS JPMC TO CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF THE ABOVE-ENUMERATED STATUTORY PROVISIONS. ADDITIONALLY, THE ORDER REQUIRES JPMC TO PAY A TOTAL OF $105,507,668 IN DISGORGEMENT AND PREJUDGMENT INTEREST OF $25,083,737, WHICH WAS PAID ON NOVEMBER 27, 2016. IN ADDITION, JPMC WAS ORDERED TO COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING REPORTING TO THE SEC STAFF PERIODICALLY, AT NO LESS THAN NINE-MONTH INTERVALS DURING A THREE-YEAR TERM, THE STATUS OF JPMC'S REMEDIATION AND IMPLEMENTATION OF COMPLIANCE MEASURES RELATING TO FCPA AND APPLICABLE ANTI-CORRUPTION LAWS, AND CERTIFYING THAT JPMC HAS MADE A GOOD FAITH EFFORT TO COMPLY WITH THE UNDERTAKINGS. THE SEC DID NOT IMPOSE A CIVIL PENALTY BASED UPON THE IMPOSITION OF A $72,000,000 CRIMINAL FINE AS PART OF JPMORGAN SECURITIES (ASIA PACIFIC) LIMITED'S ("JPMORGAN APAC") SETTLEMENT WITH THE UNITED STATES DEPARTMENT OF JUSTICE. Summary: SOLELY FOR THE PURPOSE OF SETTLING THESE PROCEEDINGS, JPMC ADMITTED THE SEC'S JURISDICTION AND THE SUBJECT MATTER OF THESE PROCEEDINGS AND CONSENTED TO THE ORDER. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12. IN COORDINATION WITH THE SEC SETTLEMENT, JPMC AND CERTAIN OF ITS AFFILIATES ALSO ENTERED INTO SETTLEMENTS WITH OTHER AGENCIES TO RESOLVE CONCURRENT INVESTIGATIONS ARISING OUT OF THE SAME CONDUCT. THOSE SETTLEMENTS ARE AS FOLLOWS: JPMORGAN APAC ENTERED INTO A NON-PROSECUTION AGREEMENT WITH THE DEPARTMENT OF JUSTICE THAT ACKNOWLEDGES RESPONSIBILITY FOR CRIMINAL CONDUCT RELATING TO CERTAIN FINDINGS IN THE ORDER AND THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ENTERED AN ADMINISTRATIVE CEASE-AND-DESIST ORDER AGAINST JPMC.

Allegations: ON OCTOBER 14, 2015, THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ISSUED AN ORDER IN A SETTLED ADMINISTRATIVE PROCEEDING AGAINST JPMIM RELATING TO TEN INSTANCES OF TRANSACTIONS ON BEHALF OF CLIENT ACCOUNTS INVOLVING SHORT SALES OF SECURITIES FOLLOWED BY PURCHASES OF THE SAME SECURITIES IN SECONDARY OFFERINGS DURING THE PERIOD 2009 THROUGH 2012. THE ORDER STATES THE CITED SHORT SALES AND PURCHASES OCCURRED WITHIN A RESTRICTED PERIOD SPECIFIED UNDER RULE 105 OF REGULATION M OF THE EXCHANGE ACT AND VIOLATED THE RULE. JPMIM DID NOT ADMIT OR DENY THE SEC'S FINDINGS IN THE ORDER. Status: Final Sanction Detail: THE ORDER REQUIRES JPMIM TO PAY A TOTAL OF $1,084,210.40. PAYMENT WAS MADE IN FULL ON 10/22/2015. Summary: JPMIM CONSENTED TO THE ISSUANCE OF THE ORDER, WHICH WAS ISSUED ON OCTOBER 14, 2015. THE ORDER MADE THE FINDINGS DESCRIBED ABOVE, WITHOUT JPMIM ADMITTING OR DENYING THE FINDINGS. RULE 105 OF REGULATION M CONTAINS NO INTENT REQUIREMENT, AND THERE IS NO FINDING IN THE ORDER THAT JPMIM INTENTIONALLY VIOLATED THE RULE.

Allegations: ON OCTOBER 31, 2024, J.P. MORGAN INVESTMENT MANAGEMENT, INC. ("JPMIM") ENTERED INTO A SETTLEMENT WITH THE SECURITIES AND EXCHANGE COMMISSION ("SEC") RESULTING IN THE SEC ISSUING AN ADMINISTRATIVE ORDER (THE "ORDER"). WITHOUT ADMITTING OR DENYING THE FINDINGS IN THE ORDER, JPMIM CONSENTED TO THE ENTRY OF THE ORDER, WHICH FOUND THAT JPMIM CAUSED JP MORGAN SECURITIES LLC ("JPMS") TO VIOLATE SECTION 17(A)(1) OF THE INVESTMENT COMPANY ACT OF 1940 ("INVESTMENT COMPANY ACT") AND THAT JPMIM WILLFULLY VIOLATED SECTIONS 206(3) AND (4) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AND RULE 206(4)-7 THEREUNDER. THE ORDER ALSO FOUND THAT JPMIM CAUSED CERTAIN REGISTERED INVESTMENT COMPANIES TO VIOLATE RULE 38A-1 OF THE INVESTMENT COMPANY ACT. THE ORDER FOUND THAT JPMIM, FROM JUNE 2019 UNTIL MARCH 2021, ENGAGED IN CERTAIN PROHIBITED PRINCIPAL TRADES FOR BOTH REGISTERED INVESTMENT COMPANY AND NON-REGISTERED INVESTMENT COMPANY CLIENTS. WITH RESPECT TO THE REGISTERED INVESTMENT COMPANY CLIENTS, THE ORDER FOUND THAT JPMIM FAILED TO COMPLY WITH THE CONDITIONS OF EXEMPTIVE RELIEF PREVIOUSLY GRANTED TO JPMIM BY THE SEC REGARDING TRADING WITH JPMS. WITH RESPECT TO THE NON-REGISTERED INVESTMENT COMPANY CLIENTS, THE ORDER FOUND THAT JPMIM FAILED TO PROVIDE THE REQUIRED CLIENT DISCLOSURES OR OBTAIN CLIENT CONSENT FOR THE PRINCIPAL TRADES. THE ORDER ALSO FOUND THAT FROM JULY 2019 UNTIL MARCH 2024, JPMIM DID NOT HAVE REASONABLY DESIGNED POLICIES AND PROCEDURES TO PREVENT ITS PERSONNEL FROM CONDUCTING PROHIBITED PRINCIPAL TRADES. Status: Final Sanction Detail: THE ORDER ACKNOWLEDGED THAT JPMIM NOTIFIED SEC ENFORCEMENT STAFF UPON LEARNING ABOUT THE TRADES AND PROMPTLY UNDERTOOK REMEDIAL ACTS. THE ORDER CENSURED JPMIM AND DIRECTED JPMIM TO CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(1) OF THE INVESTMENT COMPANY ACT AND RULE 38A-1 THEREUNDER, AND SECTIONS 206(3) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ADDITIONALLY, THE ORDER REQUIRES JPMIM TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $1,000,000. JPMIM WILL PAY THE CIVIL MONETARY PENALTY IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

Allegations: ON OCTOBER 31, 2024, J.P. MORGAN INVESTMENT MANAGEMENT, INC. ("JPMIM") ENTERED INTO A SETTLEMENT WITH THE SECURITIES AND EXCHANGE COMMISSION ("SEC") RESULTING IN THE SEC ISSUING AN ADMINISTRATIVE ORDER (THE "ORDER"). WITHOUT ADMITTING OR DENYING THE FINDINGS IN THE ORDER, JPMIM CONSENTED TO THE ENTRY OF THE ORDER, WHICH FOUND THAT JPMIM CAUSED VIOLATIONS OF SECTION 17(D) OF THE INVESTMENT COMPANY ACT OF 1940 ("INVESTMENT COMPANY ACT") AND RULE 17D-1 THEREUNDER. THE ORDER AROSE OUT OF JPMIM CAUSING PROHIBITED JOINT TRANSACTIONS BETWEEN THREE U.S. MONEY MARKET MUTUAL FUNDS FOR WHICH JPMIM SERVES AS A REGISTERED INVESTMENT ADVISER ("DOMESTIC FUNDS") AND AN AFFILIATED FOREIGN MONEY MARKET FUND FOR WHICH JPMIM SERVES AS A DELEGATED PORTFOLIO MANAGER ("FOREIGN FUND") WITHOUT HAVING OBTAINED AN EXEMPTION FROM THE SEC. THE ORDER ALSO FOUND THAT THE PROHIBITED JOINT TRANSACTIONS ADVANTAGED THE FOREIGN FUND OVER THE DOMESTIC FUNDS. Status: Final Sanction Detail: THE ORDER DIRECTED JPMIM TO CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(D) OF THE INVESTMENT COMPANY ACT OF 1940 AND RULE 17D-1 PROMULGATED THEREUNDER. ADDITIONALLY, THE ORDER REQUIRES JPMIM TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $5,000,000. JPMIM WILL PAY THE CIVIL MONETARY PENALTY IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

Allegations: THE CFTC ENTERED AN ORDER RESOLVING AN ACTION AGAINST JPMORGAN CHASE & CO., AN AFFILIATED BANK (THE "BANK") AND AN AFFILIATED BROKER-DEALER (THE "BROKER-DEALER") (COLLECTIVELY, "JPM"). ACCORDING TO THE ORDER, FROM AT LEAST 2008 THROUGH 2016, NUMEROUS TRADERS ON THE PRECIOUS METALS AND U.S. TREASURIES TRADING DESKS AT THE BANK AND THE BROKER-DEALER ENGAGED IN A MANIPULATIVE AND DECEPTIVE SCHEME BY ENGAGING IN THE PRACTICE OF "SPOOFING" (BIDDING OR OFFERING WITH THE INTENT TO CANCEL THE BID OR OFFER BEFORE EXECUTION) WHILE PLACING ORDERS FOR FUTURES CONTRACTS ON A REGISTERED ENTITY, RESULTING IN SIGNIFICANT BENEFIT TO THEMSELVES AND HARM TO OTHER MARKET PARTICIPANTS. BY VIRTUE OF THIS CONDUCT, JPM ENGAGED IN MANIPULATION AND ATTEMPTED MANIPULATION IN VIOLATION OF SECTION 9(A)(2) OF THE ACT, 7 U.S.C. § 13(A)(2) (2018); FOR CONDUCT OCCURRING ON OR AFTER JULY 16, 2011, ENGAGED IN SPOOFING IN VIOLATION OF SECTION 4C(A)(5)(C) OF THE ACT, 7 U.S.C. § 6C(A)(5)(C) (2018); AND FOR CONDUCT OCCURRING ON OR AFTER AUGUST 15, 2011, ENGAGED IN MANIPULATION AND ATTEMPTED MANIPULATION IN VIOLATION OF SECTION 6(C)(1) AND 6(C)(3) OF THE ACT, 7 U.S.C. § 9(1), (3) (2018), AND REGULATIONS 180.1(A)(1) AND (3) AND 180.2, 17 C.F.R. §§ 180.1(A)(1), (3), 180.2 (2019). FURTHER, IN CONJUNCTION WITH THE ABOVE-REFERENCED MISCONDUCT, THE BROKER-DEALER FAILED TO DILIGENTLY SUPERVISE IN VIOLATION OF COMMISSION REGULATION 166.3, 17 C.F.R. § 166.3 (2019). THE BANK AND THE BROKER-DEALER DO NOT CONTROL, NOR ARE THEY CONTROLLED BY, THE ADVISER. Status: Final Sanction Detail: THE ORDER DIRECTS JPM TO CEASE AND DESIST FROM VIOLATING SECTIONS 4C(A)(5)(C), 6(C)(1), 6(C) (3), AND 9(A)(2) OF THE ACT, 7 U.S.C. §§ 6C(A)(5)(C), 9(1), (3), 13(A)(2) (2018), AND REGULATIONS 180.1(A)(1) AND (3) AND 180.2, 17 C.F.R. §§ 180.1(A)(1), (3), 180.2 (2019). ADDITIONALLY, THE ORDER REQUIRES THE BANK AND JPMC & CO. TO PAY RESTITUTION IN THE AMOUNT OF $205,992,102, AND THE BROKER-DEALER AND JPMC & CO. TO PAY ADDITIONAL RESTITUTION IN THE AMOUNT OF $105,744,906. THE ORDER FURTHER REQUIRES JPM TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $436,431,811. THE ORDER ALSO REQUIRES THE BANK AND JPMC & CO. TO PAY DISGORGEMENT IN THE AMOUNT OF $120,332,430 AND THE BROKER-DEALER AND JPMC & CO. TO PAY DISGORGEMENT IN THE AMOUNT OF $51,702,360. Summary: RESPONDENTS JPM HAVE SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. ACCORDINGLY, IT IS HEREBY ORDERED THAT JPM SHALL CEASE AND DESIST FROM VIOLATING SECTIONS 4C(A)(5)(C), 6(C)(1), 6(C)(3), AND 9(A)(2) OF THE ACT AND REGULATIONS 180.1(A)(1) AND (3) AND 180.2, AND THE BROKER-DEALER SHALL CEASE AND DESIST FROM VIOLATING REGULATION 166.3. THE BROKER-DEALER SHALL PAY RESTITUTION OF ONE HUNDRED FIVE MILLION SEVEN HUNDRED FORTY-FOUR THOUSAND NINE HUNDRED SIX DOLLARS ($105,744,906), JOINTLY AND SEVERALLY WITH JPMC & CO; A CIVIL MONETARY PENALTY OF FOUR HUNDRED THIRTY-SIX MILLION FOUR HUNDRED THIRTY-ONE THOUSAND EIGHT HUNDRED ELEVEN DOLLARS ($436,431,811), JOINTLY AND SEVERALLY WITH THE BANK AND JPMC & CO; DISGORGEMENT IN THE AMOUNT OF FIFTY ONE MILLION SEVEN HUNDRED TWO THOUSAND THREE HUNDRED SIXTY DOLLARS ($51,702,360), JOINTLY AND SEVERALLY WITH JPMC & CO; ADDITIONALLY, THE BANK AND JPMC & CO SHALL PAY TWO HUNDRED FIVE MILLION NINE HUNDRED NINETY-TWO THOUSAND ONE HUNDRED TWO DOLLARS ($205,992,102) IN RESITUTION AND ONE HUNDRED TWENTY MILLION THREE HUNDRED THIRTY-TWO THOUSAND FOUR HUNDRED THIRTY DOLLARS ($120,332,430) IN DISGORGEMENT, JOINTLY AND SEVERALLY; JPM SHALL COMPLY WITH THE UNDERTAKINGS SET FORTH IN THE ORDER.