Aperio Group, Llc

Allegations: THE CME CONCLUDED THAT BLACKROCK VIOLATED CHICAGO BOARD OF TRADE (CBOT) RULE 562, WHICH PROHIBITS FIRMS FROM HOLDING POSITIONS ON THE CME LARGER THAN THE LIMITS PROSCRIBED BY THE CME RULES. Status: Final Sanction Detail: IN ACCORDANCE WITH THE SETTLEMENT OFFER, THE PANEL ORDERED BLACKROCK TO PAY A FINE IN THE AMOUNT OF $20,000 AND ORDERED DISGORGEMENT IN THE AMOUNT OF $99,605.60 WHICH BLACKROCK PAID ON JULY 29TH, 2021 Summary: PURSUANT TO AN OFFER OF SETTLEMENT IN WHICH BLACKROCK INC. NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, ON JULY 26, 2021, A PANEL OF THE CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE ("PANEL") FOUND THAT ON NOVEMBER 12, 2019, AND NOVEMBER 13, 2019, BLACKROCK-MANAGED ACCOUNTS HELD AN ALL MONTHS COMBINED CBOT SOYBEAN MEAL POSITION THAT EXCEEDED THE ALL MONTHS POSITION LIMIT ON AN END OF DAY AND INTRADAY BASIS. SPECIFICALLY, BLACKROCK-MANAGED ACCOUNTS HELD AN AGGREGATE POSITION OF 6,919 CONTRACTS LONG ON NOVEMBER 12, AND 6,920 CONTRACTS LONG ON NOVEMBER 13, 2019. THIS EXCEEDED THE ALL MONTHS COMBINED POSITION LIMIT FOR SOYBEAN MEAL BY 419 CONTRACTS, OR 6.45%, ON NOVEMBER 12, AND BY 420 CONTRACTS, OR 6.46%, ON NOVEMBER 13. BLACKROCK RECOGNIZED THE OVERAGE ON NOVEMBER 13, AND ATTEMPTED TO REDUCE ITS POSITION VIA AN EXCHANGE FOR RISK ("EFR") TRANSACTION, BUT WAS UNABLE TO EXECUTE THE TRADE ON THAT DAY. HOWEVER, ON THE MORNING OF NOVEMBER 14, 2019, BLACKROCK EXECUTED THE EFR AND BROUGHT THE ACCOUNTS' POSITIONS INTO COMPLIANCE, WHICH RESULTED IN A TOTAL MONETARY BENEFIT OF $99,605.60 TO THE ACCOUNTS. THE PANEL CONCLUDED THAT BLACKROCK THEREBY VIOLATED CBOT RULE 562. IN ACCORDANCE WITH THE SETTLEMENT OFFER, THE PANEL ORDERED BLACKROCK TO PAY A FINE IN THE AMOUNT OF $20,000 AND ORDERED DISGORGEMENT IN THE AMOUNT OF $99,605.60 WHICH BLACKROCK PAID ON JULY 29TH, 2021.

Allegations: ON SEPTEMBER 12, 2013, BLACKROCK, INC. BROUGHT TO THE ATTENTION OF THE FINANCIAL SUPERVISORY AUTHORITY OF FINLAND ("FINNISH FSA") THAT BLACKROCK, INC. HAD NOT FILED, WITHIN THE SPECIFIED TIME PERIOD, A NOTIFICATION THAT THE INDIRECT AGGREGATE SHAREHOLDING IN A FINNISH ISSUER, OUTOTEC OYJ, CROSSED A CERTAIN THRESHOLD ("LATE NOTIFICATION"). Status: Final Sanction Detail: ON JUNE 5, 2015, THE FINNISH FSA ISSUED A PUBLIC REPRIMAND TO BLACKROCK, INC. BECAUSE OF THE LATE NOTIFICATION. Summary: BLACKROCK, INC. IS NOT APPEALING THE DECISION AND CONSIDERS THE MATTER CLOSED.

Allegations: ON OCTOBER 31, 2014, BLACKROCK, INC. BROUGHT TO THE ATTENTION OF THE FINANCIAL SUPERVISORY AUTHORITY OF SWEDEN ("SWEDISH FSA") THAT BLACKROCK, INC. HAD NOT FILED, WITHIN THE SPECIFIED TIME PERIOD, A NOTIFICATION THAT ITS INDIRECT AGGREGATE SHAREHOLDING IN A SWEDISH ISSUER, ASSA ABLOY AB, CROSSED A CERTAIN THRESHOLD ("LATE NOTIFICATION"). Status: Final Sanction Detail: AS A RESULT OF THE LATE NOTIFICATION, THE SWEDISH FSA NOTIFIED BLACKROCK, INC., IN A LETTER DATED APRIL 29, 2015, OF ITS DECISION TO IMPOSE A PENALTY FEE OF SEK 1,000,000 (APPROXIMATELY $120,700 USD). BLACKROCK, INC. PAID THE PENALTY FEE ON JUNE 10, 2015. Summary: THE PENALTY FEE, INVOICE DATE MAY 29, 2015, WAS PAID ON JUNE 10, 2015.

Allegations: THE FINANCIAL SUPERVISORY AUTHORITY OF SWEDEN (THE "SFSA") ALLEGED THAT BLACKROCK, INC. VIOLATED LOCAL SWEDISH LAW BY NOT FILING IN SWEDEN, WITHIN A PRESCRIBED TIME, REPORTS THAT ITS COLLECTIVE SHAREHOLDINGS IN LUNDIN MINING CORPORATION (A CANADIAN COMPANY WITH A PRIMARY LISTING ON TORONTO STOCK EXCHANGE AND A LISTING OF SWEDISH DEPOSITARY RECEIPTS ON NASDAQ OMX STOCKHOLM) CROSSED CERTAIN OWNERSHIP THRESHOLDS. Status: Final Sanction Detail: FINANCIAL SUPERVISORY AUTHORITY OF SWEDEN IMPOSED A SPECIAL FEE OF 1,000,000 SEK (APPROXIMATELY $138,200 USD). BLACKROCK, INC. PAID THE SPECIAL FEE ON OCTOBER 15, 2014. Summary: BLACKROCK, INC. PAID THE SPECIAL FEE ON OCTOBER 15, 2014.

Allegations: ON DATES IN 2017 AND IN 2018, BLACKROCK, INC. WAS LATE IN MAKING CERTAIN THRESHOLD FILINGS WITH THE SWISS REGULATOR. THESE LATE FILINGS WERE CAUSED BY TWO SEPARATE ISSUES: (1) INCORRECT SHARE ISSUE INFORMATION PROVIDED TO BLACKROCK BY ITS THIRD PARTY VENDOR; AND, (2) BLACKROCK'S OUTGOING EMAIL QUARANTINE SYSTEM INCORRECTLY QUARANTINING THRESHOLD INFORMATION EMAILS FROM BLACKROCK TO THE SWISS REGULATOR. Status: Final Sanction Detail: THE SWISS FEDERAL DEPARTMENT OF FINANCE IMPOSED A SETTLEMENT SUM OF CHF 50,000. BLACKROCK, INC. PAID THE FEE ON APRIL 22, 2022. Summary: BLACKROCK, INC. PAID SETTLEMENT SUM OF CHF 50,000 ON APRIL 22, 2022.

Allegations: ON OCTOBER 24, 2023, THE SEC ANNOUNCED AN AGREEMENT WITH BLACKROCK ADVISORS, LLC ("BAL") TO SETTLE FINDINGS RELATING TO MISSTATEMENTS IN ANNUAL AND SEMI-ANNUAL REPORTS OF A MUTUAL FUND FOR WHICH BAL SERVES AS THE REGISTERED INVESTMENT ADVISER. THE SEC FOUND THAT THE REPORTS INACCURATELY DESCRIBED THE INTEREST RATE AND INDUSTRY CLASSIFICATION OF A LENDING FACILITY WITH A PRIVATELY HELD ENTITY IN WHICH THE MUTUAL FUND INVESTED. WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, BAL AGREED TO THE ENTRY OF AN ADMINISTRATIVE ORDER CONTAINING FINDINGS THAT BAL VIOLATED SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-8 THEREUNDER AND SECTION 34(B) OF THE INVESTMENT COMPANY ACT OF 1940. Status: Final Sanction Detail: ON OCTOBER 24, 2023, THE SEC ANNOUNCED AN AGREEMENT WITH BLACKROCK ADVISORS, LLC ("BAL") TO SETTLE FINDINGS RELATING TO MISSTATEMENTS IN ANNUAL AND SEMI-ANNUAL REPORTS OF A MUTUAL FUND FOR WHICH BAL SERVES AS THE REGISTERED INVESTMENT ADVISER. THE SEC FOUND THAT THE REPORTS INACCURATELY DESCRIBED THE INTEREST RATE AND INDUSTRY CLASSIFICATION OF A LENDING FACILITY WITH A PRIVATELY HELD ENTITY IN WHICH THE MUTUAL FUND INVESTED. WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, BAL AGREED TO THE ENTRY OF AN ADMINISTRATIVE ORDER CONTAINING FINDINGS THAT BAL VIOLATED SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-8 THEREUNDER AND SECTION 34(B) OF THE INVESTMENT COMPANY ACT OF 1940. BAL PAID THE $2.5 MILLION CIVIL MONEY PENALTY ON OCTOBER 30, 2023. BAL DOES NOT EXPECT THE RESOLUTION OF THIS MATTER TO HAVE A MATERIAL ADVERSE EFFECT ON ITS FINANCIAL RESULTS OR OPERATIONS. Summary: ON OCTOBER 24, 2023, THE SEC ANNOUNCED AN AGREEMENT WITH BLACKROCK ADVISORS, LLC ("BAL") TO SETTLE FINDINGS RELATING TO MISSTATEMENTS IN ANNUAL AND SEMI-ANNUAL REPORTS OF A MUTUAL FUND FOR WHICH BAL SERVES AS THE REGISTERED INVESTMENT ADVISER. THE SEC FOUND THAT THE REPORTS INACCURATELY DESCRIBED THE INTEREST RATE AND INDUSTRY CLASSIFICATION OF A LENDING FACILITY WITH A PRIVATELY HELD ENTITY IN WHICH THE MUTUAL FUND INVESTED. WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, BAL AGREED TO THE ENTRY OF AN ADMINISTRATIVE ORDER CONTAINING FINDINGS THAT BAL VIOLATED SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-8 THEREUNDER AND SECTION 34(8) OF THE INVESTMENT COMPANY ACT OF 1940. BAL PAID THE $2.5 MILLION CIVIL MONEY PENALTY ON OCTOBER 30, 2023. BAL DOES NOT EXPECT THE RESOLUTION OF THIS MATTER TO HAVE A MATERIAL ADVERSE EFFECT ON ITS FINANCIAL RESULTS OR OPERATIONS.

Allegations: THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC") FOUND THAT A HISTORIC VERSION OF BLACKROCK INC.'S ("BLACKROCK") FORM EMPLOYEE SEPARATION AND RELEASE AGREEMENT ("AGREEMENT") VIOLATED DODD FRANK'S WHISTLEBLOWER PROVISIONS, (RULE 21F-17 UNDER THE SECURITIES AND EXCHANGE ACT OF 1934). THE AGREEMENT, WHICH WAS IN USE BETWEEN OCTOBER 2011 AND MARCH 2016, DID NOT PROHIBIT FORMER EMPLOYEES FROM REPORTING ALLEGED WRONGDOING TO THE SEC. HOWEVER, EMPLOYEES WHO ACCEPTED A VOLUNTARY SEPARATION PAYMENT FROM BLACKROCK WAIVED THEIR RIGHT TO RECOVER A MONETARY REWARD FROM THE SEC IN CONNECTION WITH ITS WHISTLEBLOWING PROGRAM. BLACKROCK STOPPED USING THE AGREEMENT AT ISSUE BEFORE BEING CONTACTED BY THE SEC AND THE SEC WAS UNAWARE OF ANY INSTANCES IN WHICH FORMER BLACKROCK EMPLOYEES WERE PREVENTED FROM COMMUNICATING WITH THE SEC. Status: Final Sanction Detail: BLACKROCK PAID THE $340,000 CIVIL MONETARY PENALTY ON JANUARY 25, 2017. Summary: ON JANUARY 17, 2017, BLACKROCK INC. REACHED AN AGREEMENT WITH THE SEC TO RESOLVE ALLEGATIONS THAT A HISTORIC VERSION OF BLACKROCK'S FORM EMPLOYEE SEPARATION AND RELEASE AGREEMENT ("AGREEMENT") VIOLATED DODD FRANK'S WHISTLEBLOWER PROVISIONS, (RULE 21F-17 UNDER THE SECURITIES AND EXCHANGE ACT OF 1934). THE SETTLEMENT WITH THE SEC INCLUDED A $340,000 PAYMENT, WHICH WAS PAID ON JANUARY 25, 2017. BLACKROCK ALSO AGREED TO NOTIFY FORMER EMPLOYEES WHO SIGNED AN AGREEMENT TO ADVISE THEM THAT BLACKROCK DOES NOT PREVENT FORMER EMPLOYEES FROM COLLECTING A MONETARY AWARD FOR REPORTING INFORMATION TO THE SEC UNDER ITS WHISTLEBLOWER PROGRAM.