Bofa Securities, Inc.

Allegations: THE ATTORNEY GENERAL OF THE STATE OF NEW YORK ALLEGES THAT BANK OF AMERICA CORPORATION (BAC"), ITS FORMER CEO KENNETH D. LEWIS AND ITS FORMER CFO JOSEPH L. PRICE ENGAGED IN ACTS PRACTICES IN CONNECTION WITH THE MERGER (THE "MERGER") BETWEEN BAC AND MERRILL LYNCH & CO. INC. ("MERRILL LYNCH") THAT VIOLATED CERTAIN PROVISIONS OF THE NEW YORK GENERAL BUSINESS LAW (THE "MARTIN ACT") AND THE NEW YORK EXECUTIVE LAW. Status: Final Summary: ON FEBRUARY 4, 2010, THE NEW YORK ATTORNEY GENERAL FILED A CIVIL COMPLAINT IN THE SUPREME COURT OF NEW YORK STATE, ENTITLED PEOPLE OF THE STATE OF NEW YORK V. BANK OF AMERICA, ET AL. THE COMPLAINT NAMES AS DEFENDANTS BAC AND BAC'S FORMER CHIEF EXECUTIVE AND CHIEF FINANCIAL OFFICER, KENNETH D. LEWIS, AND JOSEPH L. PRICE, AND ALLEGES VIOLATIONS OF SECTIONS 352, 352-C(1)(A), 352-C(1)(C), AND 353 OF THE NEW YORK MARTIN ACT, AND SECTION 63(12) OF THE NEW YORK EXECUTIVE LAW. THE COMPLAINT ATTACKS THE SUFFICIENCY AND ACCURACY OF BANK OF AMERICA'S DISCLOSURES AND ITS PRACTICES RELATED TO PRACTICES RELATED TO BANK OF AMERICA'S MERGER WITH MERRILL LYNCH, INCLUDING : (I)THE DISCLOSURE OF MERRILL LYNCH'S FINANCIAL CONDITION AND ITS INTERIM AND PROJECTED LOSSES DURING THE FOURTH QUARTER OF 2008, (II)BAC'S CONTACTS WITH FEDERAL GOVERNMENT OFFICIALS REGARDING THE BAC'S CONSIDERATION OF INVOKING THE MATERIAL ADVERSE EFFECT CLAUSE IN THE MERGER AGREEMENT WITH MERRILL LYNCH AND POSSIBILITY OF OBTAINING ADDITIONAL GOVERNMENT ASSISTANCE, (III)THE DISCLOSURE OF THE PAYMENT AND TIMING OF YEAR-END INCENTIVE COMPENSATION TO MERRILL LYNCH EMPLOYEES, AND (IV)PUBLIC STATEMENTS REGARDING THE DUE DILIGENCE CONDUCTED IN CONNECTION WITH THE MERGER AND POSITIVE STATEMENTS REGARDING THE MERGER. THE COMPLAINT SEEKS AN UNSPECIFIED AMOUNT IN DISGORGEMENT, PENALTIES, RESTITUTION, AND DAMAGES, COSTS AND OTHER EQUITABLE RELIEF, ALTHOUGH THE NYAG WITHDREW ITS DEMAND FOR DAMAGES. ON MARCH 25, 2014, BAC ENTERED INTO A SETTLEMENT AGREEMENT TERMINATING THE NEW YORK ATTORNEY GENERAL'S LAWSUIT AGAINST BAC.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT BANK OF AMERICA CORPORATION (THE "CORPORATION") VIOLATED SECTION 14(A) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND RULE 14A-9 THEREUNDER BY FAILING TO DISCLOSE IN THE CORPORATION'S JOINT PROXY STATEMENT FILED ON NOVEMBER 3, 2008 THE INCENTIVE COMPENSATION THAT MERRILL LYNCH & CO., INC. COULD, IN ITS DISCRETION, AWARD TO ITS EMPLOYEES PRIOR TO COMPLETION OF ITS MERGER WITH THE CORPORATION. Status: Final Summary: ON FEBRUARY 24, 2010, A FINAL CONSENT JUDGMENT (THE "FINAL JUDGMENT") WAS ENTERED BY THE COURT. UNDER THE TERMS OF THE FINAL JUDGMENT, THE CORPORATION AGREED TO PAY $1 IN DISGORGEMENT AND A $150 MILLION CIVIL PENALTY TO BE DISTRIBUTED TO SHAREHOLDERS AS PART OF THE SEC'S FAIR FUNDS PROGRAM AT A LATER DATE IN ACCORDANCE WITH FURTHER ORDER OF THE COURT. IN ADDITION, AS PART OF THE FINAL JUDGMENT, THE CORPORATION AGREED, FOR A PERIOD OF THREE YEARS, TO COMPLY WITH AND MAINTAIN CERTAIN REQUIREMENTS RELATED TO THE CORPORATION'S CORPORATE GOVERNANCE AND DISCLOSURE PRACTICES.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT BANK OF AMERICA CORPORATION (THE "CORPORATION") VIOLATED THE FEDERAL PROXY RULES BY FAILING TO DISCLOSE INFORMATION CONCERNING MERRILL LYNCH & CO., INC.'S KNOWN AND ESTIMATED LOSSES IN THE FOURTH QUARTER OF 2008 PRIOR TO THE SHAREHOLDER VOTE ON DECEMBER 5, 2008 TO APPROVE THE MERGER BETWEEN THE TWO COMPANIES. Status: Final Summary: ON FEBRUARY 24, 2010, A FINAL CONSENT JUDGMENT (THE "FINAL JUDGMENT") WAS ENTERED BY THE COURT. UNDER THE TERMS OF THE FINAL JUDGMENT, THE CORPORATION AGREED TO PAY $1 IN DISGORGEMENT AND A $150 MILLION CIVIL PENALTY TO BE DISTRIBUTED TO SHAREHOLDERS AS PART OF THE SEC'S FAIR FUNDS PROGRAM AT A LATER DATE IN ACCORDANCE WITH FURTHER ORDER OF THE COURT. IN ADDITION, AS PART OF THE FINAL JUDGMENT, THE CORPORATION AGREED, FOR A PERIOD OF THREE YEARS, TO COMPLY WITH AND MAINTAIN CERTAIN REQUIREMENTS RELATED TO THE CORPORATION'S CORPORATE GOVERNANCE AND DISCLOSURE PRACTICES.

Allegations: ON MARCH 12, 2012, THE DEPARTMENT OF JUSTICE AND THE ATTORNEYS GENERAL OF 49 STATES AND THE DISTRICT OF COLUMBIA FILED A COMPLAINT ("COMPLAINT") AND CONSENT JUDGMENT AGAINST BANK OF AMERICA CORPORATION, BANK OF AMERICA, N.A., BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, COUNTRYWIDE HOME LOANS, INC., COUNTRYWIDE FINANCIAL CORPORATION, COUNTRYWIDE MORTGAGE VENTURES, LLC, AND/OR COUNTRYWIDE BANK, FSB (TOGETHER, "BANK OF AMERICA") AND OTHER MAJOR MORTGAGE SERVICERS TO SETTLE A NUMBER OF RELATED INVESTIGATIONS INTO RESIDENTIAL LOAN SERVICING AND ORIGINATION PRACTICES (THE "SETTLEMENT"). THE COMPLAINT ALLEGED THE DEFENDANT'S MISCONDUCT RELATED TO ITS ORIGINATION AND SERVICING OF SINGLE FAMILY RESIDENTIAL MORTGAGES CAUSED THE DEFENDANTS TO HAVE VIOLATED, AMONG OTHER LAWS, THE UNFAIR AND DECEPTIVE ACTS AND PRACTICES LAWS OF THE PLAINTIFF STATES, THE FALSE CLAIMS ACT, THE FINANCIAL INSTITUTIONS REFORM, RECOVERY, AND ENFORCEMENT ACT OF 1989, THE SERVICEMEMBERS CIVIL RELIEF ACT, AND THE BANKRUPTCY CODE AND FEDERAL RULES OF BANKRUPTCY PROCEDURE. Status: Final Summary: BANK OF AMERICA CONSENTED TO THE ENTRY OF THE CONSENT JUDGMENT WITHOUT ADMITTING THE ALLEGATIONS IN THE COMPLAINT OTHER THAN THOSE FACTS DEEMED NECESSARY TO JURISDICTION. THE ALLEGATIONS ARE DESCRIBED IN ITEM 7 ABOVE AND THE SANCTIONS ARE DESCRIBED IN ITEM 13 ABOVE. BANK OF AMERICA MADE ITS PAYMENT TO THE ESCROW AGENT N APRIL 11, 2012. THE SETTLEMENT DOES NOT RESULT IN AN INJUNCTION OR ANY FINDINGS OF VIOLATIONS OF LAW.

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) ALLEGED THAT BETWEEN JULY 2022 AND DECEMBER 2022, BOFA SECURITIES, INC. (BOFAS) AND MERRILL LYNCH, PIERCE, FENNER & SMITH (MLPFS) FAILED TO TIMELY FILE AMENDMENTS FOR THEIR REGISTERED REPRESENTATIVES' UNIFORM APPLICATIONS FOR SECURITIES INDUSTRY REGISTRATION (FORMS U4) TO UPDATE THE REPRESENTATIVES' OUTSIDE BUSINESS ACTIVITIES AND TO REFLECT CHANGES IN THE REPRESENTATIVES' BUSINESS ADDRESSES, IN VIOLATION OF ARTICLE V, SECTION 2(C) OF FINRA'S BY-LAWS AND FINRA RULES 1122 AND 2010, AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ENSURE THE TIMELY FILING OF FORM U4 AMENDMENTS, IN VIOLATION OF FINRA RULES 3110 AND 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, BOFAS AGREED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $60,000. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, BOFAS AGREED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $60,000. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC.

Allegations: ON APRIL 13, 2011, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FEDERAL RESERVE") ISSUED A CEASE AND DESIST CONSENT ORDER ("CONSENT ORDER") AGAINST BANK OF AMERICA CORPORATION ("BAC"). THE CONSENT ORDER MAKES NO FINDING ON ANY ISSUES OF FACT OR LAW ANY EXPLICIT ALLEGATION CONCERNING BAC. THE CONSENT ORDER DESCRIBES A CONSENT ORDER THAT THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC") AND BANK OF AMERICA, N.A. (THE "BANK"), WHICH IS OWNDED AND CONTROLLED BY BAC, ENTERED INTO ADDRESSING AREAS OF WEAKNESS IDENTIFIED BY THE OCC IN MORTGAGE LOAN SERVICING, LOSS MITIGATION, FORECLOSURE ACTIVITIES, AND RELATED FUNCTIONS BY THE BANK. THE CONSENT ORDER ALSO STATES THAT THE OCC'S FINDINGS RAISED CONCERNS THAT BAC DID NOT ADEQUATELY ASSESS THE POTENTIAL RISKS ASSOCIATED WITH SUCH ACTIVITIES OF THE BANK. THE CONSENT ORDER DIRECTS THE BOARD OF DIRECTORS OF BAC TO TAKE APPROPRIATE STEPS TO ENSURE THAT THE BANK COMPLIES WITH THE OCC CONSENT ORDER. Status: Final Sanction Detail: THE CONSENT ORDER REQUIRES BAC AND ITS INSTITUTION-AFFILIATED PARTIES TO CEASE AND DESIST AND TAKE SPECIFIED AFFIRMATIVE ACTION, INCLUDING THAT BAC OR ITS BOARD: (1)TAKE STEPS TO ENSURE THE BANK COMPLIES WITH OCC ORDER; (2) SUBMIT WRITTEN PLANS TO STRENGTHEN THE BOARD'S OVERSIGHT OF RISK MANAGEMENT, INTERNAL AUDIT, AND COMPLIANCE PROGRAMS CONCERNING CERTAIN MORTGAGE LOAN SERVICING, LOSS MITIGATION, AND FORECLOSURE ACTIVITIES CONDUCTED THROUGH THE BANK; AND (3) PERIODICALLY SUBMIT WRITTEN PROGRESS REPORTS DETAILING THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE WITH THE CONSENT ORDER. Summary: BAC SUBMITTED AN OFFER OF SETTLEMENT TO THE FEDERAL RESERVE. IN THE OFFER OF SETTLEMENT, BAC AGREED TO CONSENT TO THE ENTRY OF THE CONSENT ORDER, WITHOUT THE CONSENT ORDER CONSTITUTING AN ADMISSION BY BAC OR ANY OF ITS SUBSIDIARIES OF ANY ALLEGATION MADE OR IMPLIED BY THE FEDERAL RESERVE IN CONNECTION WITH THE MATTER. THE CONSENT ORDER WAS ISSUED ON APRIL 13, 2011, THE HIGHLIGHTS OF WHICH ARE DESCRIBED ABOVE IN ITEM 7. THE SANCTIONS IMPOSED ARE EXPLAINED ABOVE IN ITEM 12.C.

Allegations: ON MAY 20, 2015, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FRB") ISSUED ON ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY AGAINST BANK OF AMERICA CORPORATION ("BAC") RELATING TO ITS FOREIGN EXCHANGE ("FX") ACTIVITIES ("ORDER") FROM 2008 THROUGH 2013. THE ORDER STATES THAT (A)BAC LACKED ADEQUATE FIRM-WIDE GOVERNANCE, RICH MANAGEMENT, COMPLIANCE AND AUDIT POLICIES AND PROCEDURES TO ENSURE THAT CERTAIN OF THE FIRM'S FX ACTIVITIES 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)BAC'S DEFICIENT POLICIES AND PROCEDURES PREVENTED BAC FROM DETECTING AND ADDRESSING PERIODIC CONDUCT BY BANK OF AMERICA, N.A.'S TRADERS RELATING TO CERTAIN COMMUNICATIONS BY THESE TRADERS; AND (C)AS A RESULT OF DEFICIENT POLICIES AND PROCEDURES DESCRIBED ABOVE, BAC ENGAGED IN UNSAFE AND UNSOUND BANKING PRACTICES. Status: Final Sanction Detail: IN THE ORDER, BAC AGREED TO PAY A CIVIL MONEY PENALTY IN THE TOTAL AMOUNT OF $205 MILLION AND CONTINUE TO IMPLEMENT ADDITIONAL IMPROVEMENTS IN ITS INTERNAL CONTROLS, COMPLIANCE, RISK MANAGEMENT, AND AUDIT PROGRAMS FOR THE FX ACTIVITIES IN ORDER TO COMPLY WITH BAC POLICIES, SAFE AND SOUND BANKING PRACTICES, AND APPLICABLE U.S. LAWS/REGULATION. SPECIFICALLY BAC AGREED: (A)BAC SHALL SUBMIT A WRITTEN PLAN TO IMPROVE SENIOR MANAGEMENT'S OVERSIGHT OF BAC'S COMPLIANCE WITH APPLICABLE U.S. LAWS/REGULATIONS AND INTERNAL POLICIES IN CONNECTION WITH CERTAIN WHOLESALE TRADING AND SALES ACTIVITIES; (B)BAC SHALL SUBMIT AN ENHANCED WRITTEN INTERNAL CONTROLS AND COMPLIANCE PROGRAM TO COMPLY WITH APPLICABLE U.S. LAWS/REGULATIONS WITH RESPECT TO CERTAIN WHOLESALE TRADING AND SALES ACTIVITIES; (C)BAC SHALL SUBMIT A WRITTEN PLAN TO IMPROVE ITS COMPLIANCE RISK MANAGEMENT PROGRAM WITH REGARD TO COMPLIANCE WITH APPLICABLE U.S. LAWS/REGULATIONS WITH RESPECT TO CERTAIN WHOLESALE TRADING AND SALES ACTIVITIES; (D)BAC MANAGEMENT SHALL ANNUALLY CONDUCT A REVIEW OF COMPLIANCE POLICIES AND PROCEDURES APPLICABLE TO CERTAIN WHOLESALE TRADING AND SALES ACTIVITIES AND THEIR IMPLEMENTATION AND AN APPROPRIATE RISK-FOCUSED SAMPLING OF OTHER KEY CONTROLS FOR CERTAIN WHOLESALE TRADING AND SALES ACTIVITIES; (E)BAC SHALL SUBMIT AN ENHANCED WRITTEN INTERNAL AUDIT PROGRAM WITH RESPECT TO COMPLIANCE WITH U.S. LAWS/REGULATIONS IN CERTAIN WHOLESALE TRADING AND SALES ACTIVITIES; AND (F)BAC SHALL NOT IN THE FUTURE DIRECTLY OR INDIRECTLY RETAIN ANY INDIVIDUALS AS AN OFFICER, EMPLOYEE, AGENT, CONSULTANT, OR CONTRACTOR OF BAC OR ANY SUBSIDIARY WHO, BASED ON THE INVESTIGATIVE RECORD COMPLIED BY U.S. AUTHORITIES, PARTICIPATED IN THE MISCONDUCT UNDERLYING THE ORDER, HAS BEEN SUBJECT TO FORMAL DISCIPLINARY ACTION AS A RESUL OF BAC'S INTERNAL DISCIPLINARY REVIEW OR PERFORMANCE REVIEW IN CONNECTION WITH THE CONDUCT AND HAS EITHER SEPARATED FROM BAC OR ANY SUBSIDIARY THEREOF OR HAD HIS/HER EMPLOYMENT TERMINATED Summary: IN SETTLEMENT OF THIS MATTER, BAC CONSENTED AND AGREED TO THE ISSUANCE OF THE ORDER, WHICH 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: THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM CONDUCTED A REVIEW CONCERNING VARIOUS TYPES OF ANTI-COMPETITIVE ACTIVITY BY CERTAIN BANK OF AMERICA CORPORATION (THE "BANK") EMPLOYEES IN CONJUNCTION WITH THE SALE OF CERTAIN DERIVATIVE FINANCIAL PRODUCTS TO MUNICIPALITIES AND NON-PROFIT ORGANIZATIONS VARIOUSLY BETWEEN 1998 AND 2003. FOLLOWING THE REVIEW, THE BANK AND THE RESERVE BANK ENTERED INTO A FORMAL WRITTEN AGREEMENT TO ENSURE THAT THE BANK PROACTIVELY AND APPROPRIATELY MANAGED ITS COMPLIANCE RISK RELATED TO CERTAIN COMPETITIVELY BID TRANSACTIONS. Status: Final Sanction Detail: THE BANK HAS ENTERED INTO A WRITTEN AGREEMENT ON DECEMBER 6, 2010, WITH THE RESERVE BANK. UNDER THE TERMS OF THE WRITTEN AGREEMENT, THE BANK HAS AGREED TO SUBMIT A WRITTEN PLAN TO STRENGTHEN BOARD OVERSIGHT OF THE BANK'S COMPLIANCE RISK MANAGEMENT PROGRAM AS IT RELATES TO CERTAIN TYPES OF COMPETITIVELY BID TRANSACTIONS. IN ADDITION, THE BANK AGREED TO SUBMIT A WRITTEN PLAN TO STRENGTHEN THE BANK'S COMPLIANCE RISK MANAGEMENT PROGRAM REGARDING THOSE SAME COMPETITIVELY BID TRANSACTIONS, AND TO PROMPTLY IMPLEMENT THAT PLAN ONCE IT IS APPROVED BY THE RESERVE BANK. Summary: THE BANK HAS ENTERED INTO A WRITTEN AGREEMENT ON DECEMBER 6, 2010, WITH THE RESERVE BANK. UNDER THE TERMS OF THE WRITTEN AGREEMENT, THE BANK HAS AGREED TO SUBMIT A WRITTEN PLAN TO STRENGTHEN BOARD OVERSIGHT OF THE BANK'S COMPLIANCE RISK MANAGEMENT PROGRAM AS IT RELATES TO CERTAIN TYPES OF COMPETITIVELY BID TRANSACTIONS. IN ADDITION, THE BANK AGREED TO SUBMIT A WRITTEN PLAN TO STRENGTHEN THE BANK'S COMPLIANCE RISK MANAGEMENT PROGRAM REGARDING THOSE SAME COMPETITIVELY BID TRANSACTIONS, AND TO PROMPTLY IMPLEMENT THAT PLAN ONCE IT IS APPROVED BY THE RESERVE BANK.

Allegations: BANK OF AMERICA CORPORATION (THE "BANK") VIOLATED CERTAIN BIDDING REQUIREMENTS SET FORTH IN THE TREASURY REGULATIONS RELATED TO CERTAIN INVESTMENT CONTRACTS, AND ENTERED INTO CERTAIN INVESTMENT AND/OR SWAP CONTRACTS (OR PROVIDED BIDS TO ENTER INTO SUCH CONTRACTS) THAT DID NOT REFLECT THE FAIR MARKET VALUE OF THOSE CONTRACTS. Status: Final Sanction Detail: ON DECEMBER 8, 2010, THE BANK ENTERED INTO A CLOSING AGREEMENT WITH IRS THAT THE BANK'S VIOLATION OF CERTAIN BIDING REQUIREMENTS SET FORTH IN THE TREASURY REGULATIONS RELATED TO CERTAIN INVESTMENT CONTRACTS, AND THE BANK'S ENTERING INTO CERTAIN INVESTMENT AND/OR SWAP CONTRACTS (OR PROVIDING BIDS TO ENTER INTO SUCH CONTRACTS) THAT DID NOT REFLECT THE FAIR MARKET VALUE OF THOSE CONTRACTS. THE BANK AGREED TO PAY THE IRS $25,000,000 AS RESTITUTION FOR ARBITRAGE REBATE PAYMENTS AND OTHER AMOUNTS THAT WOULD HAVE BEEN PAYABLE TO THE IRS AS A RESULT OF THE CONDUCT AND THE BANK RECEIVED A RELEASE RELATED TO ITS PARTICIPATION IN, BIDS FOR, OR STATEMENTS OR OMISSIONS RELATED TO ANY CONTRACTS THAT THE BANK BID ON FROM 1998 THROUGH 2006. Summary: ON DECEMBER 8, 2010, THE BANK ENTERED INTO A CLOSING AGREEMENT WITH IRS THAT THE BANK'S VIOLATION OF CERTAIN BIDING REQUIREMENTS SET FORTH IN THE TREASURY REGULATIONS RELATED TO CERTAIN INVESTMENT CONTRACTS, AND THE BANK'S ENTERING INTO CERTAIN INVESTMENT AND/OR SWAP CONTRACTS (OR PROVIDING BIDS TO ENTER INTO SUCH CONTRACTS) THAT DID NOT REFLECT THE FAIR MARKET VALUE OF THOSE CONTRACTS. THE BANK AGREED TO PAY THE IRS $25,000,000 AS RESTITUTION FOR ARBITRAGE REBATE PAYMENTS AND OTHER AMOUNTS THAT WOULD HAVE BEEN PAYABLE TO THE IRS AS A RESULT OF THE CONDUCT AND THE BANK RECEIVED A RELEASE RELATED TO ITS PARTICIPATION IN, BIDS FOR, OR STATEMENTS OR OMISSIONS RELATED TO ANY CONTRACTS THAT THE BANK BID ON FROM 1998 THROUGH 2006.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") ALLEGED THAT BANK OF AMERICA CORPORATION ("BAC") FAILED TO MAKE REQUIRED DISCLOSURES IN THE MANAGEMENT'S DISCUSSION AND ANALYSIS AND RESULTS OF OPERATIONS ("MD&A") SECTIONS OF PERIODIC FILINGS, RELATED TO KNOWN UNCERTAINTIES AS TO WHETHER CERTAIN COSTS RELATED OT LOANS BAC WOULD ULTIMATELY BE REQUIRED TO REPURCHASE FROM CERTAIN INSURERS WOULD HAVE A MATERIAL EFFECT ON BAC'S FUTURE INCOME FROM CONTINUING OPERATIONS. THE COMMISSION ALLEGED THAT BAC VIOLATED SECTION 13(A) OF THE EXCHANGE ACT AND RULES 12B-20 AND 13A-13 THEREUNDER. Status: Final Sanction Detail: BAC AGREED TO (1) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 13(A) OF THE EXCHANGE ACT AND RULES 12B-20 AND 13A-13 PROMULGATED THEREUNDER; AND (2) PAY A CIVIL MONEY PENALTY OF $20 MILLION. Summary: BAC ADMITTED TO CERTAIN FACTS SET OUT IN AN ANNEX TO THE ADMINISTRATIVE ORDER, ACKNOWLEDGE THAT ITS CONDUCT SET FORTH IN THE ANNEX TO THE ADMINISTRATIVE ORDER VIOLATED THE FEDERAL SECURITIES LAW AND ADMITTED TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") ALLEGED THAT BANK OF AMERICA CORPORATION ("BAC"), AS PART OF ITS REGULATORY CAPITAL CALCULATIONS, FAILED TO DEDUCT CERTAIN REALIZED LOSSES ON CERTAIN STRUCTURED NOTES AND OTHER FINANCIAL INSTRUMENTS (THE "NOTES") ISSUED BY MERRILL LYNCH & CO., INC. ("ML&CO.") THAT BAC ASSUMED OR ACQUIRED AS PART OF ITS ACQUISITION OF ML&CO. AND, THEREFORE, BAC OVERSTATED ITS REGULATORY CAPITAL IN ITS FORM 10-Q FILINGS FROM 2009-2014 AND IN ITS FORM 10-K FILINGS FOR FINANCIAL YEARS 2009-2013. THE COMMISSION ALLEGED THAT BAC VIOLATED SECTION 13(B)(2)(A) AND (B) OF THE EXCHANGE ACT. Status: Final Sanction Detail: BAC, WITHOUT ADMITTING OR DENYING THE COMMISSION'S FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS, AGREED TO (1)CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE EXCHANGE ACT, AND (2) PAY A CIVIL MONEY PENALTY OF $7,650,000. THE PENALTY WAS PAID ON OCTOBER 7, 2014. Summary: THE COMMISSION NOTED THAT BAC SELF IDENTIFIED AND SELF REPORTED THE OVERSTATEMENTS AND THE COMMISSION NOTED THAT BAC HAD PROVIDED SUBSTANTIAL COOPERATION TO THE COMMISSION STAFF. THE COMMISSION ALSO NOTED THAT BAC HAD VOLUNTARILY UNDERTAKEN STEPS TO REMEDIATE AND ADDRESS, AMONG OTHER THINGS, THE INADEQUATE BOOKS AND INTERNAL ACCOUNTING CONTROL DEFICIENCIES THAT WERE THE SUBJECT OF THE PROCEEDING.

Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ENTERED INTO A SETTLEMENT ORDER ("ORDER") WITH MERRILL LYNCH COMMODITIES, INC. ("MLCI") TO SETTLE AN ADMINISTRATIVE ACTION THAT FOUND MLCI (A) HELD POSITIONS IN CERTAIN FIXED PRICE FUTURES CONTRACTS THAT VIOLATED FEDERAL SPOT-MONTH POSITION LIMITS AND DID NOT OTHERWISE MEET THE REQUIREMENTS FOR AN EXEMPTION FROM THE FEDERAL POSITION LIMITS PURSUANT TO CFTC REGULATIONS, IN VIOLATION OF SECTION 4A(B)(2) OF THE COMMODITY EXCHANGE ACT ("CEA") AND CFTC REGULATION 150.2; (B) EXCEEDED THE ICE FUTURES U.S.-SET SPOT-MONTH POSITION LIMIT IN CERTAIN FIXED PRICE FUTURES CONTRACTS AND DID NOT COMPLY WITH THE TERMS OF AN EXEMPTION THAT HAD BEEN GRANTED BY ICE FUTURES U.S., IN VIOLATION OF SECTION 4A(E) OF THE CEA; AND (C) DID NOT ESTABLISH AND ENFORCE WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO MONITOR FOR AND PREVENT VIOLATIONS OF APPLICABLE FEDERAL, DESIGNATED CONTRACT MARKET, OR SWAP EXECUTION FACILITY POSITION LIMITS AND TO MONITOR FOR AND PREVENT IMPROPER RELIANCE UPON ANY EXEMPTION OR EXCLUSIONS FROM SUCH POSITION LIMITS, AND THEREBY DID NOT DILIGENTLY SUPERVISE ITS EMPLOYEES, IN VIOLATION OF SECTION 4S(H)(1)(B) AND (C) OF THE CEA AND CFTC REGULATIONS 23.601(A) AND 23.602(A). Status: Final Sanction Detail: MCLI ADMITTED TO CERTAIN FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED ITS CONDUCT VIOLATED CERTAIN PROVISIONS OF THE CEA AND CFTC REGULATIONS AND AGREED TO THE FOLLOWING SANCTIONS: (A) TO CEASE AND DESIST FROM VIOLATING SECTIONS 4A(B)(2) AND (E) AND 4S(H)(1)(B) AND (C) OF THE CEA AND CFTC REGULATIONS 23.601(A), 23.602(A), AND 150.2, (B) TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,500,000, AND (C) TO COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS. Summary: MCLI ADMITTED TO CERTAIN FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED ITS CONDUCT VIOLATED CERTAIN PROVISIONS OF THE CEA AND CFTC REGULATIONS AND AGREED TO THE FOLLOWING SANCTIONS: (A) TO CEASE AND DESIST FROM VIOLATING SECTIONS 4A(B)(2) AND (E) AND 4S(H)(1)(B) AND (C) OF THE CEA AND CFTC REGULATIONS 23.601(A), 23.602(A), AND 150.2, (B) TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,500,000, AND (C) TO COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS.

Allegations: THE NEW YORK STOCK EXCHANGE LLC ("NYSE") ALLEGED THAT MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED (MLPFS) AND BOFA SECURITIES, INC. (BOFAS) (1) ROUTED TWO COMPETING PARENT ORDERS ON BEHALF OF TWO DIFFERENT PORTFOLIOS MANAGED BY THE SAME ADVISOR TO TWO DIFFERENT FLOOR BROKER FIRMS, RESULTING IN EXECUTIONS AT THE SAME TIME AND PRICE OF ORDERS ON BEHALF OF THE SAME CUSTOMERS BY TWO FLOOR BROKERS IN VIOLATION (UNINTENTIONALLY) OF NYSE RULE 122, AND (2) FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULE 122 IN VIOLATION OF NYSE RULE 3110(A) AND (B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, MLPFS AND BOFAS AGREED TO THE IMPOSITION OF A CENSURE AND FINE IN THE AMOUNT OF $25,000, ALLOCATED JOINTLY AND SEVERALLY BETWEEN MLPFS AND BOFAS. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, MLPFS AND BOFAS AGREED TO THE IMPOSITION OF A CENSURE AND FINE IN THE AMOUNT OF $25,000, ALLOCATED JOINTLY AND SEVERALLY BETWEEN MLPFS AND BOFAS. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC.

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) ALLEGED THAT BOFA SECURITIES, INC. (BOFAS), FROM 2019 TO PRESENT, AND MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED (MLPFS), FROM DECEMBER 2015 THROUGH PRESENT, FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT POTENTIALLY MANIPULATIVE TRADING BY CUSTOMERS OF BOFAS AND MLPFS, IN VIOLATION OF FINRA RULES 3110(A), 3110(B), AND 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE, A FINE IN THE AMOUNT OF $669,000, AND CERTAIN UNDERTAKINGS. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE NASDAQ STOCK EXCHANGE LLC, NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE, A FINE IN THE AMOUNT OF $669,000, AND CERTAIN UNDERTAKINGS. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE NASDAQ STOCK EXCHANGE LLC, NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC.

Allegations: THE NASDAQ STOCK MARKET LLC (NASDAQ) ALLEGED THAT BOFA SECURITIES, INC. (BOFAS), FROM 2019 TO PRESENT, AND MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED (MLPFS), FROM DECEMBER 2015 THROUGH PRESENT, FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT POTENTIALLY MANIPULATIVE TRADING BY CUSTOMERS OF BOFAS AND MLPFS, IN VIOLATION OF NASDAQ RULES GENERAL 9, SECTION 20(A) AND ITS PREDECESSOR, NASDAQ RULE 3010, AND NASDAQ RULE GENERAL 9, SECTION 1(A) AND ITS PREDECESSOR, NASDAQ RULE 2010A.. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE, A FINE IN THE AMOUNT OF $333,000, AND CERTAIN UNDERTAKINGS. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE, A FINE IN THE AMOUNT OF $333,000, AND CERTAIN UNDERTAKINGS. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC.

Allegations: THE INVESTORS EXCHANGE LLC (IEX) ALLEGED THAT BOFA SECURITIES, INC. (BOFAS), FROM 2019 TO PRESENT, AND MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED (MLPFS), FROM AUGUST 2016 THROUGH PRESENT, FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT POTENTIALLY MANIPULATIVE TRADING BY CUSTOMERS OF BOFAS AND MLPFS, IN VIOLATION OF IEX RULES 5.110 AND 3.110. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE, A FINE IN THE AMOUNT OF $333,000, AND CERTAIN UNDERTAKINGS. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND THE NASDAQ STOCK MARKET LLC, AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE, A FINE IN THE AMOUNT OF $333,000, AND CERTAIN UNDERTAKINGS. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND THE NASDAQ STOCK MARKET LLC, AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY.

Allegations: NYSE ARCA, INC. (ARCA) ALLEGED THAT BOFA SECURITIES, INC. (BOFAS), FROM JULY 2019 TO PRESENT, AND MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED (MLPFS), FROM DECEMBER 2015 TO JULY 2019, FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT POTENTIALLY MANIPULATIVE TRADING BY CUSTOMERS OF BOFAS AND MLPFS, IN VIOLATION OF NYSE ARCA RULES 11.18(B) AND (C) (SUPERVISION). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE, A FINE IN THE AMOUNT OF $333,000, AND CERTAIN UNDERTAKINGS. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, THE NASDAQ STOCK MARKET LLC, CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE, A FINE IN THE AMOUNT OF $333,000, AND CERTAIN UNDERTAKINGS. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, THE NASDAQ STOCK MARKET LLC, CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC.

Allegations: CBOE EDGA EXCHANGE, INC. (EDGA) ALLEGED THAT BOFA SECURITIES, INC. (BOFAS), FROM SEPTEMBER 2018 TO PRESENT, AND MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED (MLPFS), FROM DECEMBER 2015 TO JUNE 2019, FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO DETECT AND PREVENT POTENTIALLY MANIPULATIVE TRADING, IN VIOLATION OF EDGA RULE 5.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EXCHANGE RULES WERE COMMITTED, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $333,000. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, THE NASDAQ STOCK MARKET LLC, NYSE ARCA, INC., CBOE EDGX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EXCHANGE RULES WERE COMMITTED, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $333,000. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, THE NASDAQ STOCK MARKET LLC, NYSE ARCA, INC., CBOE EDGX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC.

Allegations: CBOE BZX EXCHANGE, INC. (BZX) ALLEGED THAT BOFA SECURITIES, INC. (BOFAS), FROM SEPTEMBER 2018 TO PRESENT, AND MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED (MLPFS), FROM DECEMBER 2015 TO PRESENT, FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO DETECT AND PREVENT POTENTIALLY MANIPULATIVE TRADING, IN VIOLATION OF BZX RULE 5.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EXCHANGE RULES WERE COMMITTED, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $333,000. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, THE NASDAQ STOCK MARKET LLC, NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EXCHANGE RULES WERE COMMITTED, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $333,000. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, THE NASDAQ STOCK MARKET LLC, NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC.

Allegations: CBOE BYX EXCHANGE, INC. (BYX) ALLEGED THAT BOFA SECURITIES, INC. (BOFAS), FROM SEPTEMBER 2018 TO PRESENT, AND MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED (MLPFS), FROM DECEMBER 2015 TO PRESENT, FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO DETECT AND PREVENT POTENTIALLY MANIPULATIVE TRADING, IN VIOLATION OF BYX RULE 5.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EXCHANGE RULES WERE COMMITTED, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $333,000. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, THE NASDAQ STOCK MARKET LLC, NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EXCHANGE RULES WERE COMMITTED, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $333,000. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, THE NASDAQ STOCK MARKET LLC, NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC.

Allegations: CBOE EDGX EXCHANGE, INC. (EDGX) ALLEGED THAT BOFA SECURITIES, INC. (BOFAS), FROM SEPTEMBER 2018 TO PRESENT, AND MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED (MLPFS), FROM DECEMBER 2015 TO JUNE 2019, FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO DETECT AND PREVENT POTENTIALLY MANIPULATIVE TRADING, IN VIOLATION OF EDGX RULE 5.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EXCHANGE RULES WERE COMMITTED, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $333,000. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, THE NASDAQ STOCK MARKET LLC, NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EXCHANGE RULES WERE COMMITTED, BOFAS AND MLPFS CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $333,000. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT BOFAS AND MLPFS REACHED WITH THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, THE NASDAQ STOCK MARKET LLC, NYSE ARCA, INC., CBOE EDGA EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., AND INVESTORS EXCHANGE LLC.

Allegations: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE CLEARING HOUSE RISK COMMITTEE ("COMMITTEE") FOUND THAT THE FIRM VIOLATED CBOT RULE 971.E. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE COMMITTEE IMPOSED A $50,000 FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE COMMITTEE IMPOSED A $50,000 FINE.

Allegations: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE CLEARING HOUSE RISK COMMITTEE ("COMMITTEE") FOUND THAT THE FIRM VIOLATED CBOT RULE 971.A.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE COMMITTEE IMPOSED A $100,000 FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE COMMITTEE IMPOSED A $100,000 FINE.

Allegations: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE CLEARING HOUSE RISK COMMITTEE ("COMMITTEE") FOUND THAT THE FIRM VIOLATED CBOT RULE 971.A. AND 971.A.3. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE COMMITTEE IMPOSED A $50,000 FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE COMMITTEE IMPOSED A $50,000 FINE.

Allegations: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE CLEARING HOUSE RISK COMMITTEE ("COMMITTEE") FOUND THAT THE FIRM VIOLATED CBOT RULE 971.A. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE COMMITTEE IMPOSED A $75,000 FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE COMMITTEE IMPOSED A $75,000 FINE.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED NYSE RULE 123C(3) AND ITS SUCCESSOR RULE, NYSE RULE 7.35B(F)(2), BY IMPROPERLY CANCELLING CERTAIN MARKET-ON-CLOSE (MOC) AND LIMIT-ON-CLOSE (LOC) ORDERS AFTER THE PRESCRIBED CUT-OFF TIME ON SEPARATE TRADE DATES, WHEN CANCELLATIONS ARE ONLY PERMITTED TO CORRECT LEGITIMATE ERRORS. THE NYSE FOUND THAT THE FIRM ALSO VIOLATED NYSE RULE 3110 BY FAILING TO IMPLEMENT ADEQUATE SUPERVISORY SYSTEMS AND CONTROLS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULE 123C(3) AND NYSE RULE 7.35B(F)(2). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED $25,000. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED $25,000.

Allegations: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION OR FACTUAL FINDINGS UPON WHICH THE PENALTY IS BASED, A PANEL OF THE CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE ("COMMITTEE") FOUND THAT, ON TWO DATES, BOFA SECURITIES, INC. ("THE FIRM") EXECUTED CERTAIN EXCHANGE FOR RELATED POSITION ("EFRP") TRANSACTIONS THAT WERE CONTINGENT UPON THE EXECUTION OF OTHER EFRP TRANSACTIONS AND THAT THE FIRM EXECUTED THESE TRANSACTIONS SIMULTANEOUSLY AND WITHOUT INCURRING MATERIAL RISK, IN VIOLATION OF CBOT RULE 538.C. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION OR FACTUAL FINDINGS UPON WHICH THE PENALTY IS BASED, THE COMMITTEE ISSUED A NOTICE OF DISCIPINARY ACTION AND ORDERED THE FIRM TO PAY A $55,000 FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION OR FACTUAL FINDINGS UPON WHICH THE PENALTY IS BASED, THE COMMITTEE ISSUED A NOTICE OF DISCIPINARY ACTION AND ORDERED THE FIRM TO PAY A $55,000 FINE.

Allegations: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE CHICAGO BOARD OF TRADE CLEARING HOUSE RISK COMMITTEE ("COMMITTEE") FOUND THAT BOFA SECURITIES, INC. VIOLATED CBOT RULES 930.E.1., 930.E.2., 930.E.3., 930.F., AND 971.A. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE COMMITTEE ORDERED THE FIRM TO PAY A $75,000 FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, THE COMMITTEE ORDERED THE FIRM TO PAY A $75,000 FINE.

Allegations: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, THE CHICAGO BOARD OF TRADE CLEARING HOUSE RISK COMMITTEE ("COMMITTEE") FOUND THAT BOFA SECURITIES, INC. ("THE FIRM") VIOLATED CBOT RULES 930.E.1., 930.E.2., 930.E.3., 930.F., AND 971.A. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, THE COMMITTEE ORDERED THE FIRM TO PAY A $100,000 FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, THE COMMITTEE ORDERED THE FIRM TO PAY A $100,000 FINE.

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) PUBLISHED INACCURATE DATA IN CERTAIN MONTHLY REPORTS IT WAS REQUIRED TO PUBLISH PURSUANT TO RULE 605 OF REGULATION NMS BETWEEN JANUARY 2014 AND FEBRUARY 2022, IN VIOLATION OF SEC RULE 605 AND FINRA RULE 2010; AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SEC RULE 605 BETWEEN JANUARY 2014 AND NOVEMBER 2021, IN VIOLATION OF NASD RULE 3010 AND FINRA RULES 3110 AND 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AGREED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $325,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AGREED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $325,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) FAILED TO REPORT OVER-THE-COUNTER (OTC) OPTIONS POSITIONS TO THE LARGE OPTIONS POSITION REPORTING SYSTEM (LOPR) IN MORE THAN 7.4 MILLION INSTANCES BETWEEN JANUARY 2009 AND OCTOBER 2020, IN VIOLATION OF FINRA RULES 2360(B)(5) AND 2010; VIOLATED APPLICABLE OTC POSITION LIMITS FOR 26 POSITIONS THAT THE FIRM FAILED TO REPORT TO THE LOPR, IN VIOLATION OF FINRA RULES 2360(B)(3) AND 2010; AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 2360(B) BETWEEN JANUARY 2014 AND OCTOBER 2020, IN VIOLATION OF NASD RULE 3010 AND FINRA RULES 3110 AND 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AGREED TO THE IMPOSITION OF A CENSURE, A FINE IN THE AMOUNT OF $5,000,000, AND CERTIFICATION THAT, AS OF OCTOBER 31, 2022, THE FIRM HAS ESTABLISHED, MAINTAINS, AND ENFORCES SUPERVISORY PROCEDURES, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 2360. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AGREED TO THE IMPOSITION OF A CENSURE, A FINE IN THE AMOUNT OF $5,000,000, AND CERTIFICATION THAT, AS OF OCTOBER 31, 2022, FIRM HAS ESTABLISHED, MAINTAINS, AND ENFORCES SUPERVISORY PROCEDURES, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 2360. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: NYSE ARCA, INC. (ARCA) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) MISMARKED CERTAIN ORDERS ON ARCA WITH A "PRINCIPAL" CAPACITY CODE FROM MARCH 2014 TO MAY 2020, IN VIOLATION OF ARCA RULE 7.33-E; AND DID NOT HAVE ANY WRITTEN SUPERVISORY PROCEDURES OR SUPERVISORY PROCESSES IN PLACE TO ENSURE COMPLIANCE WITH ARCA RULES THAT REQUIRE ORDERS SUBMITTED TO ARCA ARE MARKED WITH ACCURATE AGENCY OR PRINCIPAL CAPACITY CODES, IN VIOLATION OF ARCA RULES 11.18(B) AND (C). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $400,000 (AWC). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH ARCA, CBOE BZX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., THE NASDAQ STOCK EXCHANGE, LLC, AND NEW YORK STOCK EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $400,000 (AWC). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH ARCA, CBOE BZX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., THE NASDAQ STOCK EXCHANGE, LLC, AND NEW YORK STOCK EXCHANGE LLC.

Allegations: CBOE BYX EXCHANGE, INC. (BYX) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) MISMARKED CERTAIN ORDERS ON BYX WITH A "PRINCIPAL" CAPACITY CODE FROM MARCH 2014 TO OCTOBER 2021, RESULTING IN INACCURATE FIRM BOOKS AND RECORDS, IN VIOLATION OF BYX RULES 3.2, 4.1, AND 11.21 AS WELL AS SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT) AND RULE 17A-3 THEREUNDER; AND DID NOT HAVE ANY WRITTEN SUPERVISORY PROCEDURES OR SUPERVISORY PROCESSES IN PLACE TO ENSURE COMPLIANCE WITH BYX RULES THAT REQUIRE ORDERS SUBMITTED TO BYX ARE MARKED WITH ACCURATE AGENCY OR PRINCIPAL CAPACITY CODES, IN VIOLATION OF BYX RULE 5.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF BYX RULES OR THE EXCHANGE ACT HAVE BEEN COMMITTED, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $57,750 (DECISION). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE DECISION. THE DECISION WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH BYX, CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., THE NASDAQ STOCK MARKET, LLC, NEW YORK STOCK EXCHANGE LLC, AND NYSE ARCA, INC. Summary: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF BYX RULES OR THE EXCHANGE ACT HAVE BEEN COMMITTED, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $57,750 (DECISION). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE DECISION. THE DECISION WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH BYX, CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., THE NASDAQ STOCK MARKET, LLC, NEW YORK STOCK EXCHANGE LLC, AND NYSE ARCA, INC.

Allegations: CBOE BZX EXCHANGE, INC. (BZX) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) MISMARKED CERTAIN ORDERS ON BZX WITH A "PRINCIPAL" CAPACITY CODE FROM MARCH 2014 TO OCTOBER 2021, RESULTING IN INACCURATE FIRM BOOKS AND RECORDS, IN VIOLATION OF BZX RULES 3.2, 4.1, AND 11.21 AS WELL AS SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT) AND RULE 17A-3 THEREUNDER; AND DID NOT HAVE ANY WRITTEN SUPERVISORY PROCEDURES OR SUPERVISORY PROCESSES IN PLACE TO ENSURE COMPLIANCE WITH BZX RULES THAT REQUIRE ORDERS SUBMITTED TO BZX ARE MARKED WITH ACCURATE AGENCY OR PRINCIPAL CAPACITY CODES, IN VIOLATION OF BZX RULE 5.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF BZX RULES OR THE EXCHANGE ACT HAVE BEEN COMMITTED, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $673,750 (DECISION). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE DECISION. THE DECISION WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH BZX, CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., THE NASDAQ STOCK MARKET, LLC, NEW YORK STOCK EXCHANGE LLC, AND NYSE ARCA, INC. Summary: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF BZX RULES OR THE EXCHANGE ACT HAVE BEEN COMMITTED, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $673,750 (DECISION). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE DECISION. THE DECISION WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH BZX, CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., THE NASDAQ STOCK MARKET, LLC, NEW YORK STOCK EXCHANGE LLC, AND NYSE ARCA, INC.

Allegations: CBOE EDGA EXCHANGE, INC. (EDGA) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) MISMARKED CERTAIN ORDERS ON EDGA WITH A "PRINCIPAL" CAPACITY CODE FROM MARCH 2014 TO OCTOBER 2021, RESULTING IN INACCURATE FIRM BOOKS AND RECORDS, IN VIOLATION OF EDGA RULES 3.2, 4.1, AND 11.5 AS WELL AS SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT) AND RULE 17A-3 THEREUNDER; AND DID NOT HAVE ANY WRITTEN SUPERVISORY PROCEDURES OR SUPERVISORY PROCESSES IN PLACE TO ENSURE COMPLIANCE WITH EDGA RULES THAT REQUIRE ORDERS SUBMITTED TO EDGA ARE MARKED WITH ACCURATE AGENCY OR PRINCIPAL CAPACITY CODES, IN VIOLATION OF EDGA RULE 5.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EDGA RULES OR THE EXCHANGE ACT HAVE BEEN COMMITTED, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $134,750 (DECISION). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE DECISION. THE DECISION WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH EDGA, CBOE BZX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., THE NASDAQ STOCK MARKET, LLC, NEW YORK STOCK EXCHANGE LLC, AND NYSE ARCA, INC. Summary: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EDGA RULES OR THE EXCHANGE ACT HAVE BEEN COMMITTED, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $134,750 (DECISION). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE DECISION. THE DECISION WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH EDGA, CBOE BZX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., THE NASDAQ STOCK MARKET, LLC, NEW YORK STOCK EXCHANGE LLC, AND NYSE ARCA, INC.

Allegations: CBOE EDGX EXCHANGE, INC. (EDGX) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) MISMARKED CERTAIN ORDERS ON EDGX WITH A "PRINCIPAL" CAPACITY CODE FROM MARCH 2014 TO OCTOBER 2021, RESULTING IN INACCURATE FIRM BOOKS AND RECORDS, IN VIOLATION OF EDGX RULES 3.2, 4.1, AND 11.5 AS WELL AS SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT) AND RULE 17A-3 THEREUNDER; AND DID NOT HAVE ANY WRITTEN SUPERVISORY PROCEDURES OR SUPERVISORY PROCESSES IN PLACE TO ENSURE COMPLIANCE WITH EDGX RULES THAT REQUIRE ORDERS SUBMITTED TO EDGX ARE MARKED WITH ACCURATE AGENCY OR PRINCIPAL CAPACITY CODES, IN VIOLATION OF EDGX RULE 5.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EDGX RULES OR THE EXCHANGE ACT HAVE BEEN COMMITTED, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $1,058,750 (DECISION). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE DECISION. THE DECISION WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH EDGX, CBOE BZX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., THE NASDAQ STOCK MARKET, LLC, NEW YORK STOCK EXCHANGE LLC, AND NYSE ARCA, INC. Summary: WITHOUT ADMITTING OR DENYING THAT VIOLATIONS OF EDGX RULES OR THE EXCHANGE ACT HAVE BEEN COMMITTED, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $1,058,750 (DECISION). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE DECISION. THE DECISION WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH EDGX, CBOE BZX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., THE NASDAQ STOCK MARKET, LLC, NEW YORK STOCK EXCHANGE LLC, AND NYSE ARCA, INC.

Allegations: THE NASDAQ STOCK EXCHANGE, LLC (NASDAQ) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) MISMARKED CERTAIN ORDERS ON NASDAQ WITH A "PRINCIPAL" CAPACITY CODE FROM MARCH 2014 TO MAY 2020, IN VIOLATION OF NASDAQ RULES 4611(A)(6), 2010A (FOR CONDUCT BEFORE DECEMBER 6, 2019) AND NASDAQ GENERAL 9 SECTION 1(A) (FOR CONDUCT ON OR AFTER DECEMBER 6, 2019) ; AND DID NOT HAVE A SUPERVISORY SYSTEM OR WRITTEN SUPERVISORY PROCEDURES TO ACHIEVE COMPLIANCE WITH RESPECT TO THE REQUIREMENTS TO ENTER ACCURATE CAPACITY CODES, IN VIOLATION OF NASDAQ RULES 3010 AND 2010A (FOR CONDUCT PRIOR TO DECEMBER 6, 2019) AND NASDAQ RULE GENERAL 9, SECTIONS 20(A) AND 1(A) (FOR CONDUCT ON OR AFTER DECEMBER 6, 2019). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $385,000 (AWC). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH NASDAQ, CBOE BZX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., NEW YORK STOCK EXCHANGE LLC, AND NYSE ARCA, INC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $385,000 (AWC). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH NASDAQ, CBOE BZX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., NEW YORK STOCK EXCHANGE LLC, AND NYSE ARCA, INC.

Allegations: NEW YORK STOCK EXCHANGE LLC (NYSE) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) MISMARKED CERTAIN ORDERS ON NYSE WITH A "PRINCIPAL" CAPACITY CODE FROM MARCH 2014 TO MAY 2020, IN VIOLATION OF NYSE RULE 7.33; AND DID NOT HAVE A REASONABLY DESIGNED SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES TO COMPLY WITH ITS CAPACITY CODE OBLIGATIONS, IN VIOLATION OF NYSE RULES 3110(A) AND (B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $40,000 (AWC). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH NYSE, CBOE BZX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., THE NASDAQ STOCK EXCHANGE, LLC, AND NYSE ARCA, INC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $40,000 (AWC). THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH NYSE, CBOE BZX EXCHANGE, INC., CBOE BYX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., THE NASDAQ STOCK EXCHANGE, LLC, AND NYSE ARCA, INC.

Allegations: CME GROUP MARKET REGULATION ALLEGED THAT BOFA SECURITIES, INC. ("THE FIRM") FAILED TO APPROPRIATELY REGISTER CERTAIN OPERATOR IDS ON THE CME GROUP GLOBEX TRADING SYSTEM, IN VIOLATION OF RULE 576. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS UPON WHICH THE SUMMARY FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $5,000 FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS UPON WHICH THE SUMMARY FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $5,000 FINE.

Allegations: THE CHICAGO MERCANTILE EXCHANGE INC. ("CME") CLEARING HOUSE RISK COMMITTEE ("COMMITTEE") FOUND THAT BOFA SECURITIES, INC. ("THE FIRM") VIOLATED CUSTOMER GROSS MARGINING TECHNICAL OVERVIEW REQUIREMENTS AND CME RULE 980.G. THE FIRM NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THIS PENALTY IS BASED. Status: Final Sanction Detail: THE COMMITTEE ORDERED THE FIRM TO PAY A $1,000,000 FINE. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE DISCIPLINARY NOTICE. Summary: THE COMMITTEE ORDERED THE FIRM TO PAY A $1,000,000 FINE. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE DISCIPLINARY NOTICE.

Allegations: CME GROUP MARKET REGULATION ALLEGED THAT BETWEEN OCTOBER 1, 2022 AND DECEMBER 31, 2022, BOFA SECURITIES, INC. ("THE FIRM") SUBMITTED INCORRECT ACCOUNT NUMBERS AT ORDER ENTRY FOR ORDERS ON THE CME GROUP GLOBEX TRADING SYSTEM, IN VIOLATION OF RULE 536.B.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE SUMMARY ACTION IS BASED, THE FIRM WAS ORDERED TO PAY A $2,000 FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE SUMMARY ACTION IS BASED, THE FIRM WAS ORDERED TO PAY A $2,000 FINE.

Allegations: CME GROUP ALLEGED THAT BOFA SECURITIES, INC. ("THE FIRM") INACCURATELY REPORTED ITS OPEN INTEREST IN A CERTAIN FUTURES CONTRACT ON A SINGLE DAY, IN VIOLATION OF NYMEX RULE 854. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE SUMMARY FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $1,500 FINE. THE FIRM PAID THE FINE IN ACCORDANCE WITH THE TERMS OF THE SUMMARY FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE SUMMARY FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $1,500 FINE. THE FIRM PAID THE FINE IN ACCORDANCE WITH THE TERMS OF THE SUMMARY FINE.

Allegations: THE CHICAGO BOARD OF TRADE CLEARING HOUSE RISK COMMITTEE ("COMMITTEE") FOUND THAT BOFA SECURITIES, INC. ("THE FIRM") VIOLATED CBOT RULES 930.E.1., 930.E.2., 930.E.3., AND 930.F. THE FIRM NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THIS PENALTY IS BASED. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE SUMMARY FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $150,000 FINE. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE NOTICE OF DISCIPLINARY ACTION. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE SUMMARY FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $150,000 FINE. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE NOTICE OF DISCIPLINARY ACTION.

Allegations: CME GROUP ALLEGED THAT BETWEEN JANUARY 2023 AND JULY 2023, BOFA SECURITIES, INC. ("THE FIRM") SUBMITTED PROPRIETARY BLOCK TRADES IN FUTURES UNDER AN ACCOUNT DESIGNATED FOR CUSTOMER ORDERS, THUS SUBMITTING INACCURATE FUTURES BLOCK TRADE REPORTS TO THE EXCHANGE, IN VIOLATION OF CBOT AND CME RULES 526 AND 526.F. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE SUMMARY ACTION IS BASED, THE FIRM WAS ORDERED TO PAY A $4,000 FINE ($2000 TO CBOT AND $2000 TO CME). Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE SUMMARY ACTION IS BASED, THE FIRM WAS ORDERED TO PAY A $4,000 FINE ($2000 TO CBOT AND $2000 TO CME).

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ALLEGED THAT FROM OCTOBER 2014 THROUGH FEBRUARY 2021, BOFA SECURITIES, INC. ("THE FIRM"), THROUGH TWO FORMER TRADERS, ENGAGED IN SPOOFING IN VIOLATION OF FINRA RULE 2010 AND, FROM AT LEAST OCTOBER 2014 THROUGH SEPTEMBER 2022, FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO DETECT SPOOFING, INCLUDING POTENTIAL CROSS-PRODUCT SPOOFING IN THE U.S. TREASURY MARKETS IN VIOLATION OF FINRA RULES 2010 AND 3110 AND NASD RULE 3010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AGREED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $24,000,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AGREED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $24,000,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC.

Allegations: NASDAQ OPTIONS MARKET LLC (NOM) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) ROUTED CERTAIN MANUAL OPTIONS ORDERS TO NOM AND OTHER EXCHANGES THAT LACKED ORDER TRANSMISSION TIMES FROM OCTOBER 2012 TO OCTOBER 2019, IN VIOLATION OF NOM RULE CHAPTER IX, SECTION 1 AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, TO ENSURE THE ACCURATE RECORDING OF ORDER TRANSMISSION TIMES FROM OCTOBER 2012 TO APRIL 2023, IN VIOLATION OF NOM RULE CHAPTER III, SECTION 1, AND SUBSEQUENTLY OPTIONS 9, SECTION 2, NOM RULE CHAPTER III, SECTION 2, AND SUBSEQUENTLY OPTIONS 9, SECTION 2(B)(1), NASDAQ RULE 3010, AND SUBSEQUENTLY GENERAL 9, SECTION 20, AND NASDAQ RULES 2110 AND 2010A, AND SUBSEQUENTLY GENERAL 9, SECTION 1(A). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $23,980. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ PHLX LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $23,980. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ PHLX LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: NASDAQ ISE, LLC (ISE) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) DID NOT RECORD ACCURATE TRANSMISSION TIMES FOR CERTAIN MANUAL OPTIONS ORDERS ROUTED TO VARIOUS OPTIONS EXCHANGES, INCLUDING ISE, FROM OCTOBER 2019 TO DECEMBER 2022, IN VIOLATION OF ISE RULE OPTIONS 6E, SECTION 1 AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, TO ENSURE THE ACCURATE RECORDING OF ORDER TRANSMISSION TIMES FROM OCTOBER 2019 TO APRIL 2023, IN VIOLATION OF ISE RULE OPTION 9, SECTIONS 1 AND 2. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $29,140. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $29,140. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: NASDAQ GEMX, LLC (GEMX) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) DID NOT ACCURATELY RECORD TRANSMISSION TIMES FOR CERTAIN MANUAL OPTIONS ORDERS ROUTED TO VARIOUS OPTIONS EXCHANGES, INCLUDING GEMX, FROM OCTOBER 2019 TO DECEMBER 2022, IN VIOLATION OF GEMX RULE OPTIONS 6E, SECTION 1 AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, TO ENSURE THE ACCURATE RECORDING OF ORDER TRANSMISSION TIMES FROM OCTOBER 2019 TO APRIL 2023, IN VIOLATION OF GEMX RULE OPTIONS 9, SECTIONS 1 AND 2. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $19,200. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $19,200. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: CBOE EDGX EXCHANGE, INC. (EDGX) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, AND A SUPERVISORY SYSTEM TO PREVENT AND DETECT VIOLATIONS OF SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER AND EDGX RULES RELATED TO CAPTURING TRANSMISSION TIMES FOR MANUALLY-ROUTED OPTIONS ORDERS FROM OCTOBER 2019 TO APRIL 2023, IN VIOLATION OF EDGX RULE 5.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $10,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $10,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: CBOE C2 EXCHANGE, INC. (C2) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) DID NOT RECORD ACCURATE TRANSMISSION TIMES FOR CERTAIN MANUALLY ROUTED OPTIONS ORDERS EXECUTED ON C2 AND OTHER OPTIONS EXCHANGES FROM OCTOBER 2019 TO DECEMBER 2022, IN VIOLATION OF C2 RULES 15.1, 7.1 AND 8.2, AND CBOE EXCHANGE, INC. (CBOE) RULES 7.1 AND 8.2 BY AND THROUGH C2 CHAPTER 7 AND 8 DURING THEIR RESPECTIVE DATES OF APPLICABILITY, AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, AND A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER AND C2 RULES FROM OCTOBER 2019 TO APRIL 2023, IN VIOLATION OF C2 RULES 4.24 AND CBOE RULE 8.16 BY AND THROUGH CHAPTER 5 OF C2'S RULEBOOK AND C2 RULE 8.16 DURING THEIR RESPECTIVE DATES OF APPLICABILITY. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $15,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $15,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: CBOE EXCHANGE, INC. (CBOE) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) ROUTED CERTAIN OPTIONS ORDERS TO CBOE AND OTHER OPTIONS EXCHANGES THAT LACKED ORDER TRANSMISSION TIMES FROM OCTOBER 2012 TO OCTOBER 2019, AND DID NOT RECORD ACCURATE TRANSMISSION TIMES FOR OPTIONS ORDERS MANUALLY ROUTED TO CBOE FLOOR BROKERS OR OTHER THIRD-PARTY BROKERS FOR EXECUTION FROM OCTOBER 2019 TO DECEMBER 2022, IN VIOLATION OF CBOE RULES 15.1, RENUMBERED TO 7.1, AND 4.2, RENUMBERED TO 8.2, AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, AND A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER AND APPLICABLE CBOE RULES FROM OCTOBER 2012 TO APRIL 2023, IN VIOLATION OF CBOE RULE 4.24, RENUMBERED AS 8.16. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $350,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $350,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: CBOE BZX EXCHANGE, INC. (BZX) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) MANUALLY ROUTED CERTAIN OPTIONS ORDERS TO BZX AND OTHER EXCHANGES THAT LACKED ORDER TRANSMISSION TIMES FROM OCTOBER 2012 TO OCTOBER 2019 AND DID NOT ACCURATELY RECORD TRANSMISSION TIMES FOR OPTIONS ORDERS MANUALLY ROUTED TO A FLOOR BROKER OR OTHER-PARTY BROKERS FOR EXECUTION, FROM OCTOBER 2019 TO DECEMBER 2022, IN VIOLATION OF BZX RULES 24.1 AND 18.1 AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, AND A SUPERVISORY SYSTEM REASONABLY DESIGNED TO COMPLY WITH THE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND APPLICABLE BZX RULES FROM OCTOBER 2012 TO APRIL 2023, IN VIOLATION OF BZX RULE 5.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $30,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $30,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: NASDAQ PHLX LLC (PHLX) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) ROUTED CERTAIN MANUAL OPTIONS ORDERS TO PHLX AND OTHER EXCHANGES THAT LACKED ORDER TRANSMISSION TIMES FROM OCTOBER 2012 TO OCTOBER 2019 AND DID NOT RECORD ACCURATE TRANSMISSION TIMES FOR CERTAIN MANUALLY ROUTED OPTIONS ORDERS EXECUTED ON PHLX AND OTHER OPTIONS EXCHANGES FROM OCTOBER 2019 TO DECEMBER 2022, IN VIOLATION OF PHLX RULES 760 AND OPTIONS 6E, SECTION 1 AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, TO ENSURE THE ACCURATE RECORDING OF ORDER TRANSMISSION TIMES FROM OCTOBER 2012 TO APRIL 2023, IN VIOLATION OF PHLX RULE 748, SUBSEQUENTLY GENERAL 9, SECTION 20, AND PHLX RULE 707, SUBSEQUENTLY OPTIONS 9, SECTION 1 AND GENERAL 9, SECTION 1(C). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $100,300. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $100,300. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: NYSE ARCA, INC. (NYSE ARCA) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) DID NOT RECORD ACCURATE TRANSMISSION TIMES FOR OPTIONS ORDERS MANUALLY ROUTED TO NYSE ARCA FLOOR BROKERS OR OTHER THIRD-PARTY BROKERS FOR EXECUTION FROM OCTOBER 2019 TO DECEMBER 2022, IN VIOLATION OF NYSE ARCA RULES 6.68-O AND 11.16 AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE ARCA RULES AND FEDERAL SECURITIES LAWS RELATED TO RECORDKEEPING FROM OCTOBER 2019 TO APRIL 2023, IN VIOLATION OF NYSE ARCA RULES 11.18(B) AND 11.18(C). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $28,900. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $28,900. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: NYSE AMERICAN LLC (NYSE AMERICAN) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) DID NOT RECORD ACCURATE TRANSMISSION TIMES FOR OPTIONS ORDERS MANUALLY ROUTED TO NYSE AMERICAN FLOOR BROKERS OR OTHER THIRD-PARTY BROKERS FOR EXECUTION FROM OCTOBER 2019 TO DECEMBER 2022, IN VIOLATION OF NYSE AMERICAN RULES 956NY AND 324, AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE ARCA RULES AND FEDERAL SECURITIES LAWS RELATED TO RECORDKEEPING FROM OCTOBER 2019 TO APRIL 2023, IN VIOLATION OF NYSE AMERICAN RULE 320(E). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $27,900. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $27,900. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ GEMX, LLC, NASDAQ OPTIONS MARKET LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: NYSE CHICAGO, INC. (NYSE CHICAGO) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) SUBMITTED UNTIMELY AND INACCURATE NOTIFICATIONS TO NYSE CHICAGO IN CONNECTION WITH ITS PARTICIPATION IN CERTAIN DISTRIBUTIONS OF SECURITIES SUBJECT TO REGULATION M FROM DECEMBER 2019 TO AUGUST 2022, IN VIOLATION OF NYSE CHICAGO RULE 11.5190; AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE CHICAGO RULE 11.5190 FROM AUGUST 2019 TO MARCH 2024, IN VIOLATION OF NYSE CHICAGO ARTICLE 6 RULES 5(C) AND 5(A). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $30,160. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER. THE ORDER WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, THE NEW YORK STOCK EXCHANGE LLC, NYSE ARCA, INC., NYSE NATIONAL, INC., NYSE AMERICAN LLC, AND THE NASDAQ STOCK MARKET LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $30,160. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER. THE ORDER WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, THE NEW YORK STOCK EXCHANGE LLC, NYSE ARCA, INC., NYSE NATIONAL, INC., NYSE AMERICAN LLC, AND THE NASDAQ STOCK MARKET LLC.

Allegations: THE NASDAQ STOCK MARKET LLC (NASDAQ) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) SUBMITTED UNTIMELY RESTRICTED PERIOD NOTIFICATIONS TO NASDAQ IN CONNECTION WITH ITS PARTICIAPTION IN TWO SECURITY DISTRIBUTIONS SUBJECT TO REGULATION M FROM DECEMBER 2020 TO JANUARY 2021, IN VIOLATION OF NASDAQ RULE EQUITY 2, SECTION 10(E)(1) AND NASDAQ RULE GENERAL 9, SECTION 1(A); AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDAQ RULE EQUITY 2, SECTION 10(E) FROM AUGUST 2019 TO MARCH 2024, IN VIOLATION OF NASDAQ RULES 3010(A) AND 2010A (FOR CONDUCT PRIOR TO DECEMBER 6, 2019) AND NASDAQ GENERAL RULE 9, SECTION 20(A) AND NASDAQ GENERAL RULE 9, SECTION 1(A) (FOR CONDUCT ON OR AFTER DECEMBER 6, 2019). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $10,840. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, THE NEW YORK STOCK EXCHANGE LLC, NYSE ARCA, INC., NYSE NATIONAL, INC., NYSE CHICAGO, INC., AND NYSE AMERICAN LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $10,840. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, THE NEW YORK STOCK EXCHANGE LLC, NYSE ARCA, INC., NYSE NATIONAL, INC., NYSE CHICAGO, INC., AND NYSE AMERICAN LLC.

Allegations: NYSE NATIONAL, INC. (NYSE NATIONAL) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) SUBMITTED UNTIMELY AND INACCURATE NOTIFICATIONS TO NYSE NATIONAL IN CONNECTION WITH ITS PARTICIPATION IN DISTRIBUTIONS OF SECURITIES SUBJECT TO REGULATION M FROM DECEMBER 2019 TO AUGUST 2022, IN VIOLATION OF NYSE NATIONAL RULE 11.5190; AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE NATIONAL RULE 11.5190 FROM AUGUST 2019 TO MARCH 2024, IN VIOLATION OF NYSE NATIONAL RULES 11.5.1 AND 11.3.2. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $44,720. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, THE NEW YORK STOCK EXCHANGE LLC, NYSE ARCA, INC., NYSE AMERICAN LLC, NYSE CHICAGO, INC., AND THE NASDAQ STOCK MARKET LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $44,720. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, THE NEW YORK STOCK EXCHANGE LLC, NYSE ARCA, INC., NYSE AMERICAN LLC, NYSE CHICAGO, INC., AND THE NASDAQ STOCK MARKET LLC.

Allegations: NYSE ARCA, INC. (NYSE ARCA) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) SUBMITTED UNTIMELY AND INACCURATE NOTIFICATIONS TO NYSE ARCA IN CONNECTION WITH ITS DISTRIBUTIONS OF SECURITIES SUBJECT TO REGULATION M FROM AUGUST 2019 TO AUGUST 2022, IN VIOLATION OF NYSE ARCA RULE 9.5190-E; AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE ARCA RULE 9.5190-E FROM AUGUST 2019 TO MARCH 2024, IN VIOLATION OF NYSE ARCA RULE 11.18. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $62,080. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, THE NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE NATIONAL, INC., NYSE CHICAGO, INC., AND THE NASDAQ STOCK MARKET LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $62,080. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, THE NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE NATIONAL, INC., NYSE CHICAGO, INC., AND THE NASDAQ STOCK MARKET LLC.

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) FILED UNTIMELY OR INACCURATE NOTIFICATIONS WITH FINRA IN CONNECTION ITS PARTICIPATION IN CERTAIN SECURITY DISTRIBUTIONS SUBJECT TO REGULATION M FROM AUGUST 2019 TO AUGUST 2022, IN VIOLATION OF FINRA RULES 5190 AND 2010; AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 5190 FROM AUGUST 2019 TO MARCH 2024, IN VIOLATION OF FINRA RULES 3110(A), 3110(B), AND 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $90,080. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH THE NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., NYSE NATIONAL, INC., NYSE CHICAGO, INC., AND THE NASDAQ STOCK MARKET LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $90,080. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH THE NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., NYSE NATIONAL, INC., NYSE CHICAGO, INC., AND THE NASDAQ STOCK MARKET LLC.

Allegations: NYSE AMERICAN LLC (NYSE AMERICAN) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) SUBMITTED UNTIMELY AND INACCURATE NOTIFICATIONS TO NYSE AMERICAN IN CONNECTION WITH ITS PARTICIPATION IN DISTRIBUTIONS OF CERTAIN SECURITIES SUBJECT TO REGULATION M FROM AUGUST 2019 TO AUGUST 2022, IN VIOLATION OF NYSE AMERICAN RULE 5190; AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE AMERICAN RULE 5190 FROM AUGUST 2019 TO MARCH 2024, IN VIOLATION OF NYSE AMERICAN RULE 3110(A) AND (B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $52,560. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, THE NEW YORK STOCK EXCHANGE LLC, NYSE ARCA, INC., NYSE NATIONAL, INC., NYSE CHICAGO, INC., AND THE NASDAQ STOCK MARKET LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $52,560. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, THE NEW YORK STOCK EXCHANGE LLC, NYSE ARCA, INC., NYSE NATIONAL, INC., NYSE CHICAGO, INC., AND THE NASDAQ STOCK MARKET LLC.

Allegations: THE NEW YORK STOCK EXCHANGE LLC (NYSE) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) SUBMITTED UNTIMELY AND INACCURATE NOTIFICATIONS TO NYSE IN CONNECTION WITH ITS PARTICIPATION IN DISTRIBUTIONS OF SECURITIES SUBJECT TO REGULATION M FROM AUGUST 2019 TO AUGUST 2022, IN VIOLATION OF NYSE RULE 5190; AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULE 5190 FROM AUGUST 2019 TO MARCH 2024, IN VIOLATION OF NYSE RULE 3110(A) AND (B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $59,560. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, NYSE AMERICAN LLC, NYSE ARCA, INC., NYSE NATIONAL, INC., NYSE CHICAGO, INC., AND THE NASDAQ STOCK MARKET LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $59,560. THE FINE WAS PAID IN ACCORDANCE WITH THE TERMS OF THE AWC. THE AWC WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH FINRA, NYSE AMERICAN LLC, NYSE ARCA, INC., NYSE NATIONAL, INC., NYSE CHICAGO, INC., AND THE NASDAQ STOCK MARKET LLC.

Allegations: MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC (MIAX) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) DID NOT ACCURATELY RECORD TRANSMISSION TIMES FOR CERTAIN MANUAL OPTIONS ORDERS ROUTED TO VARIOUS OPTIONS EXCHANGES, INCLUDING MIAX, FROM OCTOBER 2019 TO DECEMBER 2022, IN VIOLATION OF MIAX RULE 800 AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, TO ENSURE THE ACCURATE RECORDING OF ORDER TRANSMISSION TIMES FROM OCTOBER 2019 TO APRIL 2023, IN VIOLATION OF MIAX RULE 300. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $21,730. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $21,730. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAX EMERALD, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: MIAX PEARL, LLC (PEARL) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) DID NOT ACCURATELY RECORD TRANSMISSION TIMES FOR CERTAIN MANUAL OPTIONS ORDERS ROUTED TO VARIOUS OPTIONS EXCHANGES, INCLUDING PEARL FROM OCTOBER 2019 TO DECEMBER 2022, IN VIOLATION OF PEARL RULE 800 AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, TO ACHIEVE THE ACCURATE RECORDING OF ORDER TRANSMISSION TIMES FROM OCTOBER 2019 TO APRIL 2023, IN VIOLATION OF PEARL RULES 300 AND 2300. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $19,150. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL STOCK EXCHANGE, LLC, MIAX EMERALD, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $19,150. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL STOCK EXCHANGE, LLC, MIAX EMERALD, LLC, AND BOX EXCHANGE LLC.

Allegations: BOX EXCHANGE LLC (BOX) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) DID NOT RECORD ACCURATE TRANSMISSION TIMES FOR CERTAIN MANUAL OPTIONS ORDERS ROUTED TO VARIOUS OPTIONS EXCHANGES, INCLUDING BOX FROM OCTOBER 2019 THROUGH DECEMBER 2022, IN VIOLATION OF BOX RULE 10000 AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, TO ASSURE THE ACCURATE RECORDING OF ORDER TRANSMISSION TIMES FROM OCTOBER 2019 TO APRIL 2023, IN VIOLATION OF BOX RULE 3010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $30,400. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, AND MIAX PEARL, LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $30,400. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, MIAX EMERALD, LLC, AND MIAX PEARL, LLC.

Allegations: MIAX EMERALD, LLC (EMERALD) ALLEGED THAT BOFA SECURITIES, INC. (THE FIRM) DID NOT ACCURATELY RECORD TRANSMISSION TIMES FOR CERTAIN MANUAL OPTIONS ORDERS ROUTED TO VARIOUS OPTIONS EXCHANGES, INCLUDING EMERALD, FROM OCTOBER 2019 TO DECEMBER 2022, IN VIOLATION OF EMERALD RULE 800 AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-3 THEREUNDER; AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN PROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, TO ASSURE THE ACCURATE RECORDING OF ORDER TRANSMISSION TIMES FROM OCTOBER 2019 TO APRIL 2023, IN VIOLATION OF EMERALD RULE 300. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $19,300. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL STOCK EXCHANGE, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE IN THE AMOUNT OF $19,300. THE FINE WILL BE PAID IN ACCORDANCE WITH THE TERMS OF THE LETTER OF CONSENT. THE LETTER OF CONSENT WAS PART OF A TOTAL SETTLEMENT THE FIRM REACHED WITH CBOE EXCHANGE, INC., CBOE C2 EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ OPTIONS MARKET LLC, NASDAQ GEMX, LLC, NASDAQ ISE, LLC, NASDAQ PHLX LLC, NYSE AMERICAN LLC, NYSE ARCA, INC., MIAMI INTERNATIONAL STOCK EXCHANGE, LLC, MIAX PEARL, LLC, AND BOX EXCHANGE LLC.

Allegations: A PANEL OF THE CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE ("BCC") ALLEGED THAT BANK OF AMERICA, NATIONAL ASSOCIATION (THE "FIRM") (1) EXECUTED AN EXCHANGE FOR RELATED RISK ("EFR") TRANSACTION THAT CONSISTED OF THE SIMULTANEOUS EXECUTION OF FUTURES POSITIONS WITHOUT THE EXCHANGE OF CORRESPONDING OTC SWAPS, THEREBY CONSTITUTING A NON-BONA FIDE EFR; AND (2) AS PART OF THE SAME LARGE, COUNTERPARTY-PROPOSED TRANSACTION, EXECUTED BUY AND SELL ORDERS FOR THE SAME ACCOUNT AND KNEW OR REASONABLY SHOULD HAVE KNOWN THAT THE ORDERS WOULD MATCH AND AVOID ANY MARKET RISK. THE BCC FOUND THAT THE FIRM VIOLATED CBOT RULES 538.C AND 534. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION OR FACTUAL FINDINGS UPON WHICH THE PENALTY IS BASED, THE BCC ORDERED THE FIRM TO PAY A $30,000 FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION OR FACTUAL FINDINGS UPON WHICH THE PENALTY IS BASED, THE BCC ORDERED THE FIRM TO PAY A $30,000 FINE.

Allegations: BLOOMBERG SEF LLC ("BLOOMBERG SEF") ALLEGED THAT BANK OF AMERICA, NATIONAL ASSOCIATION ("THE FIRM") FAILED TO NOTIFY BLOOMBERG SEF OF AN ERROR TRADE AND FAILED TO USE BLOOMBERG SEF'S OFFSET AND CORRECT FUNCTIONALITY, IN VIOLATION OF RULE 516. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE NOTICE OF FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $2,000 FINE. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE NOTICE OF FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE NOTICE OF FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $2,000 FINE. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE NOTICE OF FINE.

Allegations: BLOOMBERG SEF LLC ("BLOOMBERG SEF") ALLEGED THAT BANK OF AMERICA, NATIONAL ASSOCIATION ("THE FIRM") FAILED TO NOTIFY BLOOMBERG SEF OF AN ERROR TRADE AND FAILED TO USE BLOOMBERG SEF'S OFFSET AND CORRECT FUNCTIONALITY, IN VIOLATION OF RULE 516. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE NOTICE OF FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $1,750 FINE. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE NOTICE OF FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE NOTICE OF FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $1,750 FINE. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE NOTICE OF FINE.

Allegations: BLOOMBERG SEF LLC ("BLOOMBERG SEF") ALLEGED THAT BANK OF AMERICA, NATIONAL ASSOCIATION ("THE FIRM") FAILED TO NOTIFY BLOOMBERG SEF OF AN ERROR TRADE AND FAILED TO USE BLOOMBERG SEF'S OFFSET AND CORRECT FUNCTIONALITY, IN VIOLATION OF RULE 516. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE NOTICE OF FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $1,250 FINE. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE NOTICE OF FINE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION UPON WHICH THE NOTICE OF FINE IS BASED, THE FIRM WAS ORDERED TO PAY A $1,250 FINE. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE NOTICE OF FINE.

Allegations: THE ATTORNEY GENERAL OF THE STATE OF NEW YORK INVESTOR PROTECTION BUREAU ALLEGED THAT BANK OF AMERICA CORPORATION (BAC) AND THE FIRM (1) CONCEALED FROM ITS INSTITUTIONAL CLIENTS THAT ORDERS WERE ROUTED TO AND EXECUTED BY "ELECTRONIC LIQUIDITY PROVIDERS," (2) MISSTATED THE COMPOSITION OF ORDERS AND TRADES IN ITS DARK POOL, AND (3) DID NOT ACCURATELY DESCRIBE ITS USE OF A PROPRIETARY "VENUE RANKING" ANALYSIS, IN VIOLATION OF THE MARTIN ACT AND EXECUTIVE LAW § 63(12). Status: Final Sanction Detail: IN CONNECTION WITH THE AGREEMENT, BOFAML AGREED (1) NOT TO ENGAGE, OR ATTEMPT TO ENGAGE, IN CONDUCT IN VIOLATION OF ANY APPLICABLE LAWS, INCLUDING BUT NOT LIMITED TO THE MARTIN ACT AND EXECUTIVE LAW § 63(12); (2) TO PAY A PENALTY IN THE AMOUNT OF $42,000,000; AND (3) PROVIDE THE NYAG A SUMMARY OF THE REVIEW OF ITS ELECTRONIC TRADING POLICIES AND PROCEDURES. Summary: IN CONNECTION WITH THE AGREEMENT, BOFAML AGREED (1) NOT TO ENGAGE, OR ATTEMPT TO ENGAGE, IN CONDUCT IN VIOLATION OF ANY APPLICABLE LAWS, INCLUDING BUT NOT LIMITED TO THE MARTIN ACT AND EXECUTIVE LAW § 63(12); (2) TO PAY A PENALTY IN THE AMOUNT OF $42,000,000; AND (3) PROVIDE THE NYAG A SUMMARY OF THE REVIEW OF ITS ELECTRONIC TRADING POLICIES AND PROCEDURES.

Allegations: THE BAFIN ALLEGED THAT NECESSARY AND REASONABLE SUPERVISORY AND ORGANIZATIONAL MEASURES WHICH COULD HAVE ENSURED THE CORRECT AND COMPLETE SUBMISSION OF VOTING RIGHTS NOTIFICATIONS WITHIN THE TIME STIPULATED WERE NOT TAKEN ON TIME OR TO THE ADEQUATE EXTENT BY THE COMPANY CONCERNED, WHICH LED TO VIOLATIONS OF VOTING RIGHTS NOTIFICATION REQUIREMENTS. Status: Final Sanction Detail: THE BAFIN IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF EUR 1,340,000/USD 1,635,872 AND A FEE FOR COSTS OF THE PROCEEDING IN THE AMOUNT OF EUR 7,500/USD 9,156. THE EFFECTIVE DATE OF THE NOTICE IS TWO WEEKS AFTER THE DELIVERY OF THE NOTICE - DURING WHICH TIME THE FIRM CAN APPEAL THE NOTICE. THE FIRM DID NOT APPEAL THE NOTICE AND THE NOTICE BECAME EFFECTIVE ON MAY 14, 2018. Summary: THE BAFIN IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF EUR 1,340,000/USD 1,635,872 AND A FEE FOR COSTS OF THE PROCEEDING IN THE AMOUNT OF EUR 7,500/USD 9,156. THE EFFECTIVE DATE OF THE NOTICE IS TWO WEEKS AFTER THE DELIVERY OF THE NOTICE - DURING WHICH TIME THE FIRM CAN APPEAL THE NOTICE. THE FIRM DID NOT APPEAL THE NOTICE AND THE NOTICE BECAME EFFECTIVE ON MAY 14, 2018.

Allegations: THE BANGKO SENTRAL NG PILIPINAS (BSP) APPROVED THE IMPOSITION OF A MONETARY PENALTY ON BANK OF AMERICA, NATIONAL ASSOCIATION (BANA) FOR NON-COMPLIANCE WITH THE MANDATORY CREDIT ALLOCATION FOR AGRARIAN REFORM CREDIT/OTHER AGRICULTURAL CREDIT (AGRI-AGRA) FOR THE QUARTERS ENDED 3-31-2020 THROUGH 12-31-2020. Status: Final Sanction Detail: THE BSP IMPOSED A PENALTY IN THE AMOUNT OF PHP12,785,711.62 (APPROXIMATELY USD244,002) ON BANA. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE LETTER. Summary: THE BSP IMPOSED A PENALTY IN THE AMOUNT OF PHP12,785,711.62 (APPROXIMATELY USD244,002) ON BANA. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE LETTER.

Allegations: THE BANGKO SENTRAL NG PILIPINAS (BSP) APPROVED THE IMPOSITION OF A MONETARY PENALTY ON BANK OF AMERICA, NATIONAL ASSOCIATION (BANA) FOR NON-COMPLIANCE WITH THE MANDATORY CREDIT ALLOCATION FOR AGRARIAN REFORM CREDIT/OTHER AGRICULTURAL CREDIT (AGRI-AGRA) FOR THE QUARTERS ENDED 3-31-2021 THROUGH 12-31-2021. Status: Final Sanction Detail: THE BSP IMPOSED A PENALTY IN THE AMOUNT OF PHP12,588,039.11 (APPROXIMATELY USD223,827) ON BANA. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE LETTER. Summary: THE BSP IMPOSED A PENALTY IN THE AMOUNT OF PHP12,588,039.11 (APPROXIMATELY USD223,827) ON BANA. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE LETTER.

Allegations: THE BUNDESANSTALT FUR FINANZDIENSTLEISTUNGSAUFSICHT (BAFIN) APPROVED THE IMPOSITION OF AN ADMINISTRATIVE FINE ON BANK OF AMERICA CORPORATION FOR FAILURE TO TAKE THE SUPERVISORY AND ORGANISATIONAL MEASURES THAT WOULD HAVE BEEN REQUIRED IN ORDER TO ENSURE THE CORRECT AND COMPLETE SUBMISSION OF VOTING RIGHTS NOTIFICATIONS WITHIN THE PRESCRIBED PERIOD, IN BREACH OF SECTION 130(1) OF THE GERMAN ACT ON BREACHES OF ADMINISTRATIVE REGULATIONS IN CONJUNCTION WITH SECTIONS 33 (1) SENTENCE 1, SECTION 38(1) SENTENCE 1 AND 39 (1) OF THE GERMAN SECURITIES TRADING ACT. Status: Final Sanction Detail: BAFIN IMPOSED A PENALTY IN THE AMOUNT OF EUR5,100,000 (APPROXIMATELY USD5,071,950) ON BAC AND COSTS OF THE PROCEEDING IN THE AMOUNT OF EUR7,500 (APPROXIMATELY USD 7,479). THE PAYMENTS WERE MADE IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: BAFIN IMPOSED A PENALTY IN THE AMOUNT OF EUR5,100,000 (APPROXIMATELY USD5,071,950) ON BAC AND COSTS OF THE PROCEEDING IN THE AMOUNT OF EUR7,500 (APPROXIMATELY USD 7,479). THE PAYMENTS WERE MADE IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: COMMISSIONE NAZIONALE PER LE SOCIETA E LA BORSA (CONSOB) ISSUED A DECISION IMPOSING AN ADMINISTRATIVE FINE ON BANK OF AMERICA CORPORATION (BAC) FOR IN CONNECTION WITH THE LATE COMMUNICATION TO THE PUBLIC OF INSIDE INFORMATION CONCERNING THE DECISION TO EXERCISE THE CALL OF A BOND ISSUED BY BAC BECAUSE THE PRESS RELEASE WAS ISSUED TOO CLOSE IN TIME TO THE DATE OF THE EARLY REDEMPTION IN VIOLATION OF ARTICLE 17, PARAGRAPH 1 OF THE COUNCIL OF 16 APRIL 2014 ON MARKET ABUSE. Status: Final Sanction Detail: CONSOB IMPOSED A PENALTY IN THE AMOUNT OF EUR15,000 (APPROXIMATELY USD14,582) ON BAC. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE DECISION. Summary: CONSOB IMPOSED A PENALTY IN THE AMOUNT OF EUR15,000 (APPROXIMATELY USD14,582) ON BAC. THE PAYMENT WAS MADE IN ACCORDANCE WITH THE TERMS OF THE DECISION.

Allegations: THE BANGKO SENTRAL NG PILIPINAS (BSP) APPROVED THE IMPOSITION OF A MONETARY PENALTY ON BANK OF AMERICA, NATIONAL ASSOCIATION (BANA) FOR NON-COMPLIANCE WITH THE MANDATORY CREDIT ALLOCATION FOR AGRARIAN REFORM CREDIT/OTHER AGRICULTURAL CREDIT (AGRI-AGRA) FOR THE QUARTERS ENDED 3-31-2022 THROUGH 6-30-2022. Status: Final Sanction Detail: THE BSP IMPOSED A PENALTY IN THE AMOUNT OF PHP6,701,462.54 (APPROXIMATELY USD121,723) ON BANA. THE PAYMENT WILL BE MADE IN ACCORDANCE WITH THE TERMS OF THE LETTER. Summary: THE BSP IMPOSED A PENALTY IN THE AMOUNT OF PHP6,701,462.54 (APPROXIMATELY USD121,723) ON BANA. THE PAYMENT WILL BE MADE IN ACCORDANCE WITH THE TERMS OF THE LETTER.

Allegations: THE BANGKO SENTRAL NG PILIPINAS (BSP) APPROVED THE IMPOSITION OF A MONETARY PENALTY ON BANK OF AMERICA, NATIONAL ASSOCIATION (BANA) FOR CERTAIN REPORTING VIOLATIONS BETWEEN MARCH 31, 2022 AND SEPTEMBER 30, 2022. Status: Final Sanction Detail: THE BSP IMPOSED A PENALTY IN THE AMOUNT OF PHP49,200.00 (APPROXIMATELY USD877) ON BANA. THE PAYMENT WILL BE MADE IN ACCORDANCE WITH THE TERMS OF THE LETTER. Summary: THE BSP IMPOSED A PENALTY IN THE AMOUNT OF PHP49,200.00 (APPROXIMATELY USD877) ON BANA. THE PAYMENT WILL BE MADE IN ACCORDANCE WITH THE TERMS OF THE LETTER.

Allegations: THE BANGKO SENTRAL NG PILIPINAS (BSP) APPROVED THE IMPOSITION OF A MONETARY PENALTY ON BANK OF AMERICA, NATIONAL ASSOCIATION (BANA) FOR NON-COMPLIANCE WITH THE MANDATORY CREDIT ALLOCATION FOR AGRICULTURE, FISHERIES AND RURAL DEVELOPMENT (AFRD) FOR THE QUARTERS ENDED 9-30-2022 THROUGH 12-31-2022. Status: Final Sanction Detail: THE BSP IMPOSED A PENALTY IN THE AMOUNT OF PHP3,309,740.78 (APPROXIMATELY USD59,030) ON BANA. THE PAYMENT WILL BE MADE IN ACCORDANCE WITH THE TERMS OF THE LETTER. Summary: THE BSP IMPOSED A PENALTY IN THE AMOUNT OF PHP3,309,740.78 (APPROXIMATELY USD59,030) ON BANA. THE PAYMENT WILL BE MADE IN ACCORDANCE WITH THE TERMS OF THE LETTER.

Allegations: THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ALLEGED THAT BANK OF AMERICA, NATIONAL ASSOCIATION (THE FIRM) (1) ENGAGED IN UNFAIR ACTS AND PRACTICES BY RESPONDING TO AND PROCESSING GARNISHMENT NOTICES AGAINST OUT-OF-STATE BANK ACCOUNTS IN VIOLATION OF CERTAIN GARNISHMENT-ISSUING STATES' PROHIBITIONS AGAINST OUT-OF-STATE GARNISHMENT; (2) ENGAGED IN UNFAIR ACTS AND PRACTICES BY FAILING TO APPLY THE APPROPRIATE STATE EXEMPTIONS TO CERTAIN CONSUMERS' DEPOSIT ACCOUNTS AFTER RECEIVING GARNISHMENT NOTICES; (3) ENGAGED IN DECEPTIVE ACTS AND PRACTICES BY MISREPRESENTING TO CONSUMERS, BY IMPLICATION, THE APPLICABLE STATE EXEMPTION RIGHTS FOR GARNISHMENT BY APPLYING THE ISSUING STATE'S EXEMPTIONS INSTEAD OF THE EXEMPTIONS OF THE CONSUMER'S STATE OF RESIDENCE, WHERE THE STATES OF ISSUANCE AND RESIDENCE DIFFER; (4) ENGAGED IN UNFAIR ACTS AND PRACTICES BY USING A DEPOSIT AGREEMENT THAT REQUIRED CONSUMERS TO DIRECT THE FIRM NOT TO CONTEST LEGAL PROCESS AND WAIVE THE FIRM'S LIABILITY FOR ITS UNLAWFUL GARNISHMENT CONDUCT; AND (5) ENGAGED IN DECEPTIVE ACTS AND PRACTICES BY SUGGESTING CONSUMERS COULD NOT BRING LEGAL CLAIMS MISREPRESENTING CONSUMERS' LEGAL RIGHTS AGAINST THE FIRM REGARDING GARNISHMENT PROCEEDINGS. THE CFPB ALLEGES THAT THESE ACTS VIOLATED SECTIONS 1031(A) AND 1036(A)(1)(B) OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010 ("CFPA"), 12 USC §§ 5531(A) AND (C)(1) AND 5536(A)(1)(B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO (1) THE ENTRY OF THE ORDER, (2) NOT VIOLATE SECTIONS 1031(A) AND 1036(A)(1)(B) OF THE CFPA, 12 USC §§ 5531(A) AND (C)(1) AND 5536(A)(1)(B), (3) REFUND ALL GARNISHMENT-RELATED FEES PAID BY THE AFFECTED CONSUMERS TOTALING NO LESS THAN $592,000 AND CANCEL ANY UNPAID GARNISHMENT RELATED FEES, (4) CERTAIN UNDERTAKINGS, AND (5) PAYMENT OF A CIVIL MONETARY PENALTY IN THE AMOUNT OF $10,000,000. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO (1) THE ENTRY OF THE ORDER, (2) NOT VIOLATE SECTIONS 1031(A) AND 1036(A)(1)(B) OF THE CFPA, 12 USC §§ 5531(A) AND (C)(1) AND 5536(A)(1)(B), (3) REFUND ALL GARNISHMENT-RELATED FEES PAID BY THE AFFECTED CONSUMERS TOTALING NO LESS THAN $592,000 AND CANCEL ANY UNPAID GARNISHMENT RELATED FEES, (4) CERTAIN UNDERTAKINGS, AND (5) PAYMENT OF A CIVIL MONETARY PENALTY IN THE AMOUNT OF $10,000,000. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ALLEGED THAT BANK OF AMERICA, NATIONAL ASSOCIATION (THE FIRM) (1) ENGAGED IN UNFAIR ACTS OR PRACTICES BY DETERMINING NO ERROR HAD OCCURRED AND FREEZING CARDHOLDER ACCOUNTS BASED SOLELY ON THE RESULTS OF ITS AUTOMATED FRAUD FILTER, IN VIOLATION OF SECTIONS 1031 AND 1036 OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010 (CFPA), 12 U.S.C. §§ 5531(A) AND (C), 5536(A)(1)(B); (2) FAILED TO CONDUCT REASONABLE INVESTIGATIONS OF UNEMPLOYMENT INSURANCE BENEFIT PREPAID DEBIT CARDHOLDERS' NOTICES OF ERROR, IN VIOLATION OF SECTIONS 908 AND 909 OF THE ELECTRONIC FUND TRANSFER ACT (EFTA), 15 U.S.C. §§ 1693F AND 1693G, AND SECTION 1005.11 OF REGULATION E; (3) ENGAGED IN ABUSIVE ACTS OR PRACTICES BY RETROACTIVELY APPLYING ITS AUTOMATED FRAUD FILTER TO REVERSE PERMANENT CREDITS FOR UNEMPLOYMENT INSURANCE BENEFIT PREPAID DEBIT CARDHOLDERS WHOSE NOTICES OF ERROR IT HAD PREVIOUSLY INVESTIGATED AND PAID, IN VIOLATION OF SECTIONS 1031 AND 1036 OF THE CFPA, 12 U.S.C. §§ 5531(A) AND (D)(2)(B), 5536(A)(1)(B); (4) ENGAGED IN UNFAIR ACTS OR PRACTICES BY IMPEDING UNEMPLOYMENT INSURANCE BENEFIT PREPAID DEBIT CARDHOLDERS' EFFORTS TO FILE NOTICES OF ERROR AND SEEK LIABILITY PROTECTION FROM UNAUTHORIZED EFTS, IN VIOLATION OF SECTIONS 1031 AND 1036 OF THE CFPA, 12 U.S.C. §§ 5531(A) AND (C), 5536(A)(1)(B); AND (5) FAILED TO TIMELY INVESTIGATE AND RESOLVE UNEMPLOYMENT INSURANCE BENEFIT PREPAID DEBIT CARDHOLDERS' NOTICES OF ERROR CONCERNING ALLEGED UNAUTHORIZED EFTS, IN VIOLATION OF EFTA, 15 U.S.C. § 1693F(A), (C), AND SECTION 1005.11(C)(2)-(3) OF REGULATION E. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FAT OF CONCLUSIONS OF LAW CONTAINED WITHIN THE ORDER, THE FIRM CONSENTED TO (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF THE PROVISIONS DETAILED ABOVE, (B) CERTAIN UNDERTAKINGS, (C) PAYMENT OF REDRESS TO AFFECTED CUSTOMERS, AND (D) PAYMENT OF A CIVIL MONETARY PENALTY IN THE AMOUNT OF $100 MILLION. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FAT OF CONCLUSIONS OF LAW CONTAINED WITHIN THE ORDER, THE FIRM CONSENTED TO (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF THE PROVISIONS DETAILED ABOVE, (B) CERTAIN UNDERTAKINGS, (C) PAYMENT OF REDRESS TO AFFECTED CUSTOMERS, AND (D) PAYMENT OF A CIVIL MONETARY PENALTY IN THE AMOUNT OF $100 MILLION.

Allegations: THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC") ALLEGED THAT BANK OF AMERICA, NATIONAL ASSOCIATION (THE FIRM) (1) IN CONNECTION WITH THE FIRM'S ADMINISTRATION OF PREPAID CARDS FOR UNEMPLOYMENT BENEFITS, ENGAGED IN (I) UNSAFE OR UNSOUND PRACTICE(S), INCLUDING DEFICIENCIES IN ITS RISK MANAGEMENT, OPERATIONAL PROCESSES AND CONTROLS, INTERNAL AUDIT, AND INVESTIGATION AND RESOLUTION OF CONSUMER CLAIMS OF UNAUTHORIZED TRANSACTIONS; AND (II) UNFAIR AND DECEPTIVE PRACTICES IN VIOLATION(S) OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT ("FTC ACT"), 15 U.S.C. § 45(A)(1); AND (2) ENGAGED IN UNSAFE OR UNSOUND PRACTICES RELATED TO DEFICIENCIES IN ITS ENTERPRISE-WIDE COMPLAINTS RISK MANAGEMENT FRAMEWORK. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE ORDER, THE FIRM CONSENTED TO A CIVIL MONETARY PENALTY OF $125,000,000. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE ORDER, THE FIRM CONSENTED TO A CIVIL MONETARY PENALTY OF $125,000,000.

Allegations: THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ALLEGED THAT BANK OF AMERICA, NATIONAL ASSOCIATION (THE FIRM) (1) WITH RESPECT TO PROMOTIONAL BONUS OFFERS ON REWARDS CREDIT CARDS, CREATED THE DECEPTIVE NET IMPRESSION THAT BONUSES LINKED TO REWARDS CREDIT CARDS WERE AVAILABLE TO ALL CONSUMERS WHEN THOSE BONUSES WERE ONLY AVAILABLE TO CONSUMERS WHO APPLIED ONLINE, AND DENIED BONUSES TO CERTAIN TARGETED CONSUMERS WHO APPLIED IN-PERSON AND OVER THE PHONE; AND (2) WITH RESPECT TO OFFERING CONSUMER CREDIT CARD ACCOUNTS, IN SOME INSTANCES, APPLIED FOR AND OPENED CREDIT CARDS FOR CONSUMERS WITHOUT THEIR CONSENT AND OBTAINED CONSUMER REPORTS FOR THOSE CONSUMERS WITHOUT A PERMISSIBLE PURPOSE. THE CFPB ALLEGES THAT THESE ACTS VIOLATED THE TRUTH IN LENDING ACT, 15 U.S.C. § 1601 ET SEQ., AND ITS IMPLEMENTING REGULATION, REGULATION Z, 12 C.F.R. PART 1026; THE FAIR CREDIT REPORTING ACT (CFPA), 15 U.S.C. § 1681B(F); AND THE CONSUMER FINANCIAL PROTECTION ACT OF 2010, 12 U.S.C. §§ 5531 AND 5536. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT OR CONCLUSIONS OF LAW, THE FIRM CONSENTED TO (1) THE ENTRY OF THE ORDER, (2) NOT VIOLATE SECTIONS 1031 AND 1036 OF THE CFPA, 12 USC §§ 5531 AND 5536, (3) IDENTIFY AFFECTED CONSUMERS NOT PREVIOUSLY REMEDIATED TO PAY OR PROVIDE REDRESS, (4) CERTAIN UNDERTAKINGS, AND (5) PAYMENT OF A CIVIL MONETARY PENALTY IN THE AMOUNT OF $30,000,000. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT OR CONCLUSIONS OF LAW, THE FIRM CONSENTED TO (1) THE ENTRY OF THE ORDER, (2) NOT VIOLATE SECTIONS 1031 AND 1036 OF THE CFPA, 12 USC §§ 5531 AND 5536, (3) IDENTIFY AFFECTED CONSUMERS NOT PREVIOUSLY REMEDIATED TO PAY OR PROVIDE REDRESS, (4) CERTAIN UNDERTAKINGS, AND (5) PAYMENT OF A CIVIL MONETARY PENALTY IN THE AMOUNT OF $30,000,000. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: THE RESERVE BANK OF INDIA (RBI) ISSUED A SPEAKING ORDER AND IMPOSED A MONETARY PENALTY AGAINST BANK OF AMERICA, NATIONAL ASSOCIATION (BANA) FOR ALLEGEDLY CONTRAVENING INSTRUCTIONS ISSUED TO AD BANKS VIDE A.P. (DIR SERIES) CIRCULAR NO. 23 DATED APRIL 12, 2018 BY FAILING TO UPLOAD CERTAIN INFORMATION RELATED TO TRANSACTIONS UNDERTAKEN UNDER THE LIBERALISED REMITTANCE SCHEME. Status: Final Sanction Detail: RBI IMPOSED A FINE IN THE AMOUNT OF INR10,000 (APPROXIMATELY USD120) ON BANA. THE FINE WAS PAID AS DIRECTED. Summary: RBI IMPOSED A FINE IN THE AMOUNT OF INR10,000 (APPROXIMATELY USD120) ON BANA. THE FINE WAS PAID AS DIRECTED.

Allegations: THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ALLEGED THAT BANK OF AMERICA, NATIONAL ASSOCIATION (THE FIRM) FAILED TO ACCURATELY COLLECT, RECORD, AND REPORT INFORMATION ON MORTGAGE LOAN APPLICANTS' RACE, ETHNICITY, AND SEX, IN VIOLATION OF SECTION 2803 OF THE HOME MORTGAGE DISCLOSURE ACT ("HDMA"), REGULATION C, 12 C.F.R. §§ 1003.4, 1003.5, AND SECTION 1036(A)(1)(A) OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010 ("CFPA"), 12 U.S.C. § 5536(A)(1)(A). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT OR CONCLUSIONS OF LAW, THE FIRM CONSENTED TO (1) THE ENTRY OF THE CONSENT ORDER, (2) NOT VIOLATE THE HMDA, 12 U.S.C. §§ 2801-2810, AND REGULATION C, 12 C.F.R. PT. 1003, (3) CERTAIN UNDERTAKINGS, AND (4) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $12,000,000. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT OR CONCLUSIONS OF LAW, THE FIRM CONSENTED TO (1) THE ENTRY OF THE CONSENT ORDER, (2) NOT VIOLATE THE HMDA, 12 U.S.C. §§ 2801-2810, AND REGULATION C, 12 C.F.R. PT. 1003, (3) CERTAIN UNDERTAKINGS, AND (4) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $12,000,000. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: THE CONSUMER FINANCIAL PROTECTION BUREAU (CFPB) ALLEGED THAT BANK OF AMERICA, NATIONAL ASSOCIATION (THE FIRM) COMMITTED UNFAIR ACTS AND PRACTICES WHEN IT CHARGED CONSUMERS REPEAT NON-SUFFICIENT FUNDS (NSF) FEES ON TRANSACTIONS RESUBMITTED TO THE FIRM FOR PAYMENT AFTER THEY WERE INITIALLY DECLINED (RE-PRESENTMENT FEES) IN VIOLATION OF SECTIONS 1031 AND 1036 OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010 (CFPA), 12 U.S.C. §§ 5531(A) AND (C)(1), 5536(A)(1)(B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT OR CONCLUSIONS OF LAW, THE FIRM CONSENTED TO (1) THE ENTRY OF THE ORDER, (2) NOT VIOLATE SECTIONS 1031 AND 1036 OF THE CFPA, 12 U.S.C. §§ 5531 AND 5536 AND NOT ASSESS RE-PRESENTMENT NSF FEES, (3) COMPLY WITH CERTAIN UNDERTAKINGS, (4) PAY REDRESS TO AFFECTED CUSTOMERS, AND (5) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $60 MILLION. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT OR CONCLUSIONS OF LAW, THE FIRM CONSENTED TO (1) THE ENTRY OF THE ORDER, (2) NOT VIOLATE SECTIONS 1031 AND 1036 OF THE CFPA, 12 U.S.C. §§ 5531 AND 5536 AND NOT ASSESS RE-PRESENTMENT NSF FEES, (3) COMPLY WITH CERTAIN UNDERTAKINGS, (4) PAY REDRESS TO AFFECTED CUSTOMERS, AND (5) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $60 MILLION. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC") ALLEGED THAT BANK OF AMERICA, NATIONAL ASSOCIATION (THE FIRM) ASSESSED MULTIPLE OVERDRAFT AND INSUFFICIENT FUNDS FEES AGAINST CUSTOMERS FOR A SINGLE TRANSACTION IN VIOLATION OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT ("FTC ACT"), 15 U.S.C. § 45(A)(1). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE ORDER, THE FIRM CONSENTED TO PAY A CIVIL PENALTY IN THE AMOUNT OF $60 MILLION. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE ORDER, THE FIRM CONSENTED TO PAY A CIVIL PENALTY IN THE AMOUNT OF $60 MILLION. THE CIVIL MONETARY PENALTY WAS PAID IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Allegations: THE COMMODITIES FUTURES TRADING COMMISSION ("CFTC") ENTERED INTO A SETTLEMENT ORDER ("ORDER") WITH BOFAS SECURITIES, INC. ("BOFAS"), MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED ("MLPFS"), AND BANK OF AMERICA, N.A. ("BANA", AND COLLECTIVELY WITH BOFAS AND MLPFS, THE "RESPONDENTS") SETTLING AN ADMINISTRATIVE ACTION CONCERNING (A) BANA'S FAILURE TO MAINTAIN REQUIRED RECORDS IN VIOLATION OF SECTIONS 4S(F)(1)(C) AND 4S(G)(1) AND (3) OF THE COMMODITY EXCHANGE ACT ("ACT") AND CFTC REGULATIONS ("REGULATIONS") 23.201(A) AND 23.202(A)(1) AND (B)(1); (B) BOFAS AND MLPFS' FAILURE TO KEEP REQUIRED RECORDS IN VIOLATION OF SECTION 4G OF THE ACT AND REGULATION 1.35; (C) RESPONDENTS' FAILURE TO KEEP RECORDS IN THE REQUIRED MANNER IN VIOLATION OF REGULATION 1.31; (D) BANA'S FAILURE TO SUPERVISE DILIGENTLY IN VIOLATION OF SECTIONS 4S(H)(1)(B) OF THE ACT AND REGULATION 23.602(A); AND (E) BOFAS AND MLPFS' FAILURE TO DILIGENTLY SUPERVISE IN VIOLATION OF REGULATION 166.3. Status: Final Sanction Detail: THE RESPONDENTS ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, EXCEPT AS TO SECTIONS II.A.2 AND II.C.2 OF THE ORDER, WHICH FACTS THEY NEITHER ADMITTED NOR DENIED, ACKNOWLEDGED THEIR CONDUCT VIOLATED THE ACT AND REGULATIONS AND AGREED TO THE FOLLOWING SANCTIONS: (A) BANA TO CEASE AND DESIST FROM VIOLATING SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE ACT, AND REGULATIONS 1.31, 23.201, 23.202(A)(1) AND (B)(1) AND 23.602(A) AND BOFAS AND MLPFS TO CEASE AND DESIST FROM VIOLATING SECTION 4G OF THE ACT AND REGULATIONS 1.31, 1.35 AND 166.3, (B) TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $100,000,000, AND (C) TO COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS. Summary: THE RESPONDENTS ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, EXCEPT AS TO SECTIONS II.A.2 AND II.C.2 OF THE ORDER, WHICH FACTS THEY NEITHER ADMITTED NOR DENIED, ACKNOWLEDGED THEIR CONDUCT VIOLATED THE ACT AND REGULATIONS AND AGREED TO THE FOLLOWING SANCTIONS: (A) BANA TO CEASE AND DESIST FROM VIOLATING SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE ACT, AND REGULATIONS 1.31, 23.201, 23.202(A)(1) AND (B)(1) AND 23.602(A) AND BOFAS AND MLPFS TO CEASE AND DESIST FROM VIOLATING SECTION 4G OF THE ACT AND REGULATIONS 1.31, 1.35 AND 166.3, (B) TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $100,000,000, AND (C) TO COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ALLEGED, IN CONNECTION WITH THE BROKER-DEALER OFF-CHANNEL COMMUNICATIONS INITIATIVE, THAT BOFA SECURITIES, INC. AND MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED (COLLECTIVELY, BAML) FAILED TO (1) MAINTAIN AND PRESERVE OFF-CHANNEL COMMUNICATIONS RELATED TO THE BUSINESS OF THE BROKER-DEALERS OPERATED BY BAML, IN WILLFUL VIOLATION OF SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-4(B)(4) THEREUNDER; AND (2) REASONABLY SUPERVISE THEIR EMPLOYEES WITH A VIEW TO PREVENTING OR DETECTING CERTAIN OF THEIR EMPLOYEES' AIDING AND ABETTING VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER, WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. Status: Final Sanction Detail: BAML ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED THEIR CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS AND AGREED TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER, (B) BE CENSURED, (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $125,000,000, AND (D) COMPLY WITH CERTAIN UNDERTAKINGS RELATED TO RETENTION OF ELECTRONIC COMMUNICATIONS. Summary: BAML ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED THEIR CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS AND AGREED TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER, (B) BE CENSURED, (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $125,000,000, AND (D) COMPLY WITH CERTAIN UNDERTAKINGS RELATED TO RETENTION OF ELECTRONIC COMMUNICATIONS.

Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ENTERED INTO A SETTLEMENT ORDER ("ORDER") WITH BANK OF AMERICA, N.A. ("BANA") AND MERRILL LYNCH INTERNATIONAL ("MLI", AND COLLECTIVELY WITH BANA, ("BOFA")). SETTLING AN ADMINISTRATIVE ACTION CONCERNING BOFA'S (A) FAILURE TO ACCURATELY REPORT SWAP DATA IN VIOLATION OF SECTION 2(A)(13)(F) AND (G) OF THE COMMODITY EXCHANGE ACT ("ACT") AND CFTC REGULATIONS ("REGULATIONS") 43.3, 45.3, 45.4, AND 45.14 AND (B) FAILURE TO DILIGENTLY SUPERVISE THE BANA AND MLI SWAP DEALER BUSINESSES IN VIOLATION OF SECTION 4S(H)(1)(B) OF THE ACT AND REGULATION 23.602(A). Status: Final Sanction Detail: BOFA ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED THEIR CONDUCT VIOLATED THE ACT AND REGULATIONS AND AGREED TO THE FOLLOWING SANCTIONS: (A) TO CEASE AND DESIST FROM VIOLATING SECTIONS 2(A)(13)(F) AND (G) AND 4S(H)(1)(B) OF THE ACT, AND REGULATIONS 23.602(A), 43.3, 45.3, 45.4, AND 45.14, (B) TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $8,000,000, AND (C) TO COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS. Summary: BOFA ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED THEIR CONDUCT VIOLATED THE ACT AND REGULATIONS AND AGREED TO THE FOLLOWING SANCTIONS: (A) TO CEASE AND DESIST FROM VIOLATING SECTIONS 2(A)(13)(F) AND (G) AND 4S(H)(1)(B) OF THE ACT, AND REGULATIONS 23.602(A), 43.3, 45.3, 45.4, AND 45.14, (B) TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $8,000,000, AND (C) TO COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS.