Invesco Private Capital, Inc.

Allegations: ALLEGEDLY, AIM AND ADI FAILED TO DISCLOSE THAT THEY HAD ENTERED INTO CERTAIN ARRANGEMENTS PERMITTING MARKET TIMING OF SUCH FUNDS, THEREBY BREACHING THEIR FIDUCIARY DUTIES TO THE FUNDS. Status: Pending Summary: ON AUGUST 30, 2005, THE WEST VIRGINIA OFFICE OF THE STATE AUDITOR - SECURITIES COMMISSION ("WVASC") ISSUED A SUMMARY ORDER TO CEASE AND DESIST AND NOTICE OF RIGHT TO HEARING TO AIM AND ADI (ORDER NO. 05-1318). THE WVASC ALLEGES THAT AIM AND ADI FAILED TO DISCLOSE MARKET TIMING ARRAGEMENTS. THE WVASC PURPORTS TO ORDER AIM AND ADI TO CEASE ANY FURTHER VIOLATIONS AND SEEKS TO IMPOSE MONETARY SANCTIONS, INCLUDING RESTITUTION TO AFFECTED INVESTORS, DISGORGEMENT OF FEES, REIMBURSEMENT OF INVESTIGATORY, ADMINISTRATIVE AND LEGAL COSTS AND AN "ADMINISTRATIVE ASSESSMENT" TO BE DETERMINED BY THE COMMISSIONER. WE BELIEVE THIS MATTER HAS BEEN INDEFINITELY SUSPENDED.

Allegations: INVESCO LTD AND AIM INTERNATIONAL MUTUAL FUNDS FAILED TO SUBMIT VOTING RIGHTS NOTIFICATIONS TO BAFIN AND THE ISSUERS BY THE REQUIRED DEADLINE. BAFIN ISSUED A NOTICE OF HEARING ON JULY 30, 2020 TO INVESCO LTD ALLEGING THAT VIOLATIONS OF THE VOTING RIGHTS REQUIREMENTS OCCURED ON 26 OCCASSIONS RELATING TO THE VOTING RIGHTS NOTIFICATIONS OF INVESCO LTD AND ON 28 OCCASIONS RELATING TO VOTING RIGHTS NOTIFICATIONS OF AIM INTERNATIONAL MUTUAL FUNDS. Status: Final Sanction Detail: DECISION TO IMPOSE A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 USD) AGAINST INVESCO LTD WILL BE PAID BY THE JULY 2, 2021 DEADLINE. Summary: BAFIN IMPOSED A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 US DOLLARS) AGAINST INVESCO LTD FOR 54 INCORRECT THRESHOLD FILINGS BETWEEN 05/2019 AND 10/2019. THE FINE WILL BE PAID BY THE JULY 2, 2021 DEADLINE.

Allegations: THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") AND INVESCO DISTRIBUTORS, INC. ("IDI") FAILED TO ADEQUATELY PRESERVE CERTAIN ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. Status: Final Sanction Detail: THE SETTLEMENT REQUIRED IAI AND IDI TO PAY A CIVIL MONETARY PENALTY OF $35 MILLION AND COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING THE RETENTION OF A COMPLIANCE CONSULTANT. INVESCO PAID THE CIVIL MONETARY PENALTY ON OCTOBER 1, 2024. Summary: ON SEPTEMBER 24, 2024, INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF INVESCO PRIVATE CAPITAL, INC. AND INVESCO DISTRIBUTORS, INC. ("IDI"), AN AFFILIATED BROKER-DEALER THEREOF (TOGETHER, WITH IAI, "INVESCO"), HAVE ENTERED INTO A SETTLEMENT WITH THE SEC IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE INVESTIGATION INTO THE MAINTENANCE AND PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. THE SETTLEMENT CENSURES INVESCO AND REQUIRES THAT INVESCO CEASE AND DESIST FROM ANY EXISTING AND FUTURE VIOLATIONS, PAY A CIVIL MONETARY PENALTY OF $35,000,000 AND RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT, FOLLOWING THE FORMAT FOR ALL OTHER RECENT ELECTRONIC COMMUNICATIONS SETTLEMENTS. INVESCO COOPERATED WITH THE GOVERNMENT'S INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO ELECTRONIC COMMUNICATIONS, INCLUDING BY ENHANCING ITS POLICIES AND PROCEDURES, IMPLEMENTING INCREASED TRAINING REGARDING THE USE OF ELECTRONIC COMMUNICATIONS, AND BEGINNING TO IMPLEMENT CHANGES TO THE TECHNOLOGY AVAILABLE TO EMPLOYEES.

Allegations: THE SEC ALLEGED THAT WL ROSS FAILED TO ADEQUATELY DISCLOSE ITS FEE ALLOCATION PRACTICES TO CERTAIN PRIVATE EQUITY FUNDS IT ADVISED (THE "WLR FUNDS") AND THEIR INVESTORS AND THAT AMBIGUOUS LANGUAGE IN ITS PRIVATE EQUITY FUND LIMITED PARTNERSHIP AGREEMENTS RESULTED IN CERTAIN WLR FUNDS PAYING HIGHER MANAGEMENT FEES BEWTEEN 2001 AND 2011. Status: Final Sanction Detail: THE ORDER IMPOSES A CIVIL PENALTY OF $2.3 MILLION. THE PORTION LEVIED AGAINST WL ROSS IS 100%. THE PENALTY WAS PAID ON AUGUST 26, 2016 Summary: THE SEC ADMINISTRATIVE ORDER IS FINAL. IN DETERMINING TO ACCEPT THE OFFER, THE COMMISSION CONSIDERED REMEDIAL ACTS PROMPTLY UNDERTAKEN BY WL ROSS AND COOPERATION AFFORDED THE COMMISSION STAFF, INCLUDING WL ROSS' SELF-REPORTING OF THE TRANSACTION FEE ALLOCATION ISSUE TO THE OCIE STAFF, WL ROSS' VOLUNTARY DETERMINATION TO REVISE ITS FEE ALLOCATION METHODOLOGY, AND WL ROSS' VOLUNTARY REIMBURSEMENT, WITH INTEREST, OF $11,873,571 IN MANAGEMENT FEE CREDITS RESULTING FROM ITS RETROACTIVE APPLICATION OF THE REVISED ALLOCATION METHODOLOGY TO THE INCEPTION OF THE WLR FUNDS.

Allegations: THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO ALLEGED THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED. Status: Final Sanction Detail: THE SETTLEMENT REQUIRED INVESCO ADVISERS, INC. ("IAI") TO PAY A CIVIL MONETARY PENALTY OF $17.5 MILLION. IAI PAID THE CIVIL MONETARY PENALTY ON NOVEMBER 14, 2024. Summary: ON NOVEMBER 8, 2024, INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF INVESCO PRIVATE CAPITAL, INC., ENTERED INTO A SETTLEMENT WITH THE SEC REGARDING IAI'S ENVIRONMENTAL, SOCIAL AND GOVERNANCE ("ESG") POLICIES AND PROCEDURES. THE SEC FOUND THAT IAI LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO FOUND THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED. IAI WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM VIOLATING SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULES 206(4)-1, 206(4)-7 AND 206(4)-8 THEREUNDER. IAI AGREED TO PAY A PENALTY OF $17.5 MILLION.